December 7, 2023

CDFI Fund: Final Revised CDFI Certification Application Released

The U.S. Department of the Treasury’s Community Development Financial Institutions Fund (CDFI Fund) released a revised Community Development Financial Institution (CDFI) Certification Application today. This CDFI Certification Application, as well as the Annual Certification and Data Collection Report (ACR) and Transaction Level Report (TLR), were approved by the Office of Management and Budget (OMB) and encompass modifications made in response to public comments received last year. 

In November 2022, the revised CDFI Certification Application was released for a final round of public comment followed by an updated ACR and abbreviated TLR (together, “related tools”) in December 2022. The CDFI Fund received more than 250 comment letters in response to the revisions proposed to the CDFI Certification Application and 40 comment letters for the ACR and TLR. All of the comments were thoroughly reviewed and considered by the CDFI Fund, as mandated by the Paperwork Reduction Act (PRA).

As a result, this OMB-approved CDFI Certification Application, along with its related tools, has been considerably revised. In particular, substantial modifications have been made to the Basic Information, Legal Entity, Primary Mission, Financing Entity, Target Market, Development Services, and Accountability sections of the Application. An overview of principal changes to each section of the CDFI Certification Application is available in documents accessed via links in the Related Materials section below. 

Implementation and Important Deadlines

The CDFI Fund is instituting a phased approach for organizations seeking to become newly Certified or renew their CDFI Certification.

Non-Certified Organizations

Only non-certified organizations1 will be able to immediately apply for CDFI Certification. When the CDFI Fund’s Awards Management Information System (AMIS) reopens for submission of the CDFI Certification Application, only those entities that are currently not certified will be initially eligible to submit a Certification Application. For those non-certified organizations interested in submitting an Application for CDFI Certification, the CDFI Fund will reopen the CDFI Certification Application AMIS submission portal on December 20, 2023

Existing CDFIs

All currently Certified CDFIs2  will be required to reapply for Certification using the revised version of the Certification Application by December 20, 2024. Until this date, currently Certified CDFIs will: 1) retain their status as Certified CDFIs; and 2) remain eligible to apply for all CDFI Fund programs where CDFI Certification is an eligibility requirement—provided they abide by ACR reporting requirements and have no material event affecting their CDFI Certification status. 

ACR and TLR Modifications

The CDFI Fund is also releasing the final ACR and abbreviated TLR, which were released for final public comment in December 2022. Comments submitted in response to this request spurred further changes to align with the revised CDFI Certification Application. 

Transaction Level Reporting Modifications

Under the revised CDFI Certification policies, all new Applicants as well as all currently Certified CDFIs will be required to submit a TLR, both as part of an initial Certification Application and then on an annual basis as part of their ACR submission package. 

New Applicants will complete and submit an abbreviated version of the TLR—which has fewer data fields than the full-length version—prior to the submission of their CDFI Certification Application. This abbreviated TLR will be used to assess compliance with applicable Target Market percentage benchmarks in the Applicant’s proposed Target Market(s). In this abbreviated TLR, Applicants must report on origination activity for their most recently completed fiscal year prior to the submission of their Certification Application. 

The version of the TLR submitted by Certified CDFIs—whether in reapplying for Certification or as part of their ACR—will vary by award status. CDFIs with an active Assistance Agreement (for a CDFI Program, NACA Program, CDFI Rapid Recovery (CDFI RRP), or CDFI Equitable Recovery (CDFI ERP) award) will continue to submit the full-length version of the TLR which will be used to satisfy the TLR requirement of the Certification Application as well as the ACR. CDFIs that do not have an active Assistance Agreement will submit the new abbreviated version of the TLR to satisfy the TLR requirement of the Certification Application as well as the ACR.

Annual Certification and Data Collection Report Modifications

The ACR verifies that Certified CDFIs continue to meet the requirements of Certification. Currently, Certified CDFIs are required to submit an ACR on an annual basis within 90 days of the end of their organization’s fiscal year. Data collected under the new ACR has been substantially modified to align with final changes to the CDFI Certification Application, as well as with information collected in the abbreviated TLR.

Unless otherwise notified by the CDFI Fund, all CDFIs are required to complete the ACR on an annual basis in order to maintain their Certification status. Failure to file the ACR may result in loss of Certification status and lead to additional sanctions for CDFIs that are program Recipients. Full details about the new ACR and TLR requirements can be found in the Related Materials section below. 

Application Webinar and Conference Calls

To assist organizations in understanding the requirements of the revised CDFI Certification Application, the CDFI Fund will conduct a live webinar on Wednesday, December 13 at 1:30 pm Eastern Time. Information on the webinar, as well as the revised CDFI Certification Application, FAQs document, and additional guidance information are available on the CDFI Fund’s website at www.cdfifund.gov/cdficert under “Step 1: Apply.” Please check this page frequently; the CDFI Fund will post updates to this site on an ongoing basis.

The CDFI Fund will resume its monthly CDFI Certification conference calls and its quarterly ACR conference calls, which are intended to serve as a forum for questions and discussion surrounding the CDFI Certification Application, ACR, and the submission process. The calls are free to the general public and do not require advance registration. Information on the monthly CDFI Certification conference calls can be accessed on the CDFI Fund’s website, here. Information on the quarterly ACR conference calls can be viewed here

Timeline

Questions

Questions regarding the:

In anticipation of a high volume of questions and the potential of technical issues related with the new Application process, the CDFI Fund will dedicate resources to provide technical support and answer general questions related to the CDFI Certification Application, Transaction Level Report, and technology access.

In anticipation of a high volume of questions and the potential of technical issues related with the new Application process, the CDFI Fund will dedicate resources to provide technical support and answer general questions related to the CDFI Certification Application, Transaction Level Report, and technology access.

Related Materials


1Non-certified organizations includes all organizations that are currently NOT Certified CDFIs.

2Currently Certified CDFIs are those organizations that have CDFI Certification status as of the date the new CDFI Certification Application opens in AMIS on December 20, 2023.

This post was originally published here.