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.
- General Reapplication Submission Deadline. All currently Certified CDFIs are required to reapply for CDFI Certification utilizing the revised Application, which must be submitted between August 1, 2024 – December 20, 2024. Organizations that do not submit an Application by 11:59 pm Eastern Time (ET) on December 20, 2024 will lose their CDFI Certification. The CDFI Fund will begin reviewing these submissions on a rolling basis after December 20, 2024. All general Certification Application reviews will be completed by December 20, 2025.
As noted above, during this intervening time period—between the opening of the AMIS Application submission portal and December 20, 2024—currently Certified CDFIs will be in a grace period. During the grace period, they will remain Certified. After submission of an Application to recertify, CDFIs will still retain their Certified status unless they receive specific notification from the CDFI Fund that they were decertified.
- Early Reapplication Submission. In order to manage the flow of recertification Applications and expedite recertification determinations, the CDFI Fund will offer 700 slots for currently Certified CDFIs that would like to voluntarily submit a revised Application to recertify before the December 20, 2024 general submission deadline. Certified CDFIs that submit their recertification applications during this period will receive an earlier determination on their recertification application.
To apply early, currently Certified CDFIs must notify the CDFI Fund of their intent to submit an early reapplication no later than February 1, 2024. Early reapplications must be submitted between May 31, 2024, and July 31, 2024. The CDFI Fund will provide determinations via AMIS on all early Certification reapplication submissions by October 31, 2024.
Currently Certified CDFIs that reapply by the early reapplication submission deadline that are unsuccessful in retaining the CDFI Certification based on their early Application submissions will not be automatically terminated. They will retain their CDFI Certification status through the end of the submission grace period of December 20, 2024. However, if unsuccessful in early submission a CDFI must follow the general reapplication submission process to remain Certified, as specified above.
- Community Development Financial Institutions Program (CDFI Program) & Native CDFI Assistance Program (NACA Program) Applicants. Non-certified organizations will be allowed to apply for a fiscal year (FY) 2024 Financial Assistance (FA) award. In order to be considered for an FA Award, non-certified organizations will be required to submit a CDFI Certification Application by the due date indicated in the forthcoming FY 2024 CDFI Program and NACA Program Notices of Funds Availability (NOFAs). The CDFI Fund will review all timely submitted Certification Applications and provide a decision prior to announcing the FY 2024 CDFI Program and NACA Program awards. If an organization’s Certification Application is not approved, they will be ineligible to receive an FY 2024 FA award
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.
- Organizations certified as CDFIs using the revised CDFI Certification Application will now be required to submit the new ACR within 180 days of their fiscal year end. This updated ACR will only be used by those Certified as CDFIs using the revised CDFI Certification Application.
- Currently Certified CDFIs will follow the new ACR submission process once they recertify under the revised Certification Application. The recertification process ensures that existing currently Certified CDFIs are held to the same evaluation, benchmarks, and review criteria as newly Certified CDFIs.
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
- The AMIS CDFI Certification Application Portal Opens for new Applicants only on December 20, 2023.
- Requests to submit an early reapplication submission, must be received by the CDFI Fund via an AMIS Service Request no later than 11:59 pm ET on February 1, 2024.
- Early reapplications must be submitted to the CDFI Fund between May 31, 2024 and July 31, 2024.
- The CDFI Fund will make determinations on all early Certification reapplication submissions by October 31, 2024.
- Early reapplications that are not recertified will retain Certification through December 20, 2024.
- Existing CDFIs must reapply for Certification using the revised Application in AMIS by the general reapplication submission deadline beginning August 1, 2024 and no later than 11:59 pm ET on December 20, 2024.
- The CDFI Fund will begin reviewing general reapplication submissions on a rolling basis after December 20, 2024.
- All general Certification reapplication reviews by will be completed by December 20, 2025.
- The grace period for existing Certified CDFIs that intend to reapply for CDFI Certification will expire with the general Certification reapplication submission deadline after 11:59 pm ET on December 20, 2024.
Questions
Questions regarding the:
- CDFI Certification Application should be directed to the Office of Certification Policy and Evaluation (OCPE) via an AMIS Service Request (preferred), by email to ocpecert@cdfi.treas.gov, or by phone to (202) 653-0423.
- ACR, and abbreviated TLR should be directed to the Office of Financial Strategies and Research (FS&R), via an AMIS Service Request (preferred), or by email to CDFI-FinancialStrategiesandResearch@cdfi.treas.gov.
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
- Revised CDFI Certification Application
- Revised CDFI Fund Annual Certification and Data Collection Report Form & Instructions
- Abbreviated Transaction Level Report (TLR) Data Point Collection Guide
- CDFI/NACA/RRP Transaction Level Report (TLR) Data Point Collection Guide
- Pre-Approved Target Market Assessment Methodologies
- Low-Income Calculator
- Overview Presentation: Community Development Financial Institution Certification Application and Related Tools
- Frequently Asked Questions: CDFI Certification Application and Related Tools
- Overview of Key Updates to the CDFI Certification Application
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.