WASHINGTON– The Treasury Department’s CDFI Fund has published an update on revisions it is making to the CDFI certification application. In response, NAFCU said credit unions are getting the "runaround."
The CDFI fund is currently not accepting new applications, after a backlog developed that led to considerable delays in the processing of the applications. It instituted a blackout period on applications on Oct. 1, 2022 and expects to open the new CDFI certification process in the Fall of 2023 after the revisions are completed.
As CUToday.info reported earlier, a request for public comment on a draft of the CDFI Fund's CDFI Certification Application was published in the Federal Register in the Autumn of 2022. The draft application was developed after approximately six years of consideration and two previous requests for public input, according to the CDFI Fund, which said it has been “deliberate” in its efforts to update the CDFI certification process.
Upcoming Steps
Over the next several months, the CDFI Fund said it will undertake the following steps:
- Complete the Review of all Comments. The CDFI Fund will continue to review public comments about the CDFI certification process and is consulting with regulatory agencies regarding updates to the CDFI Certification Application.
- Publish Updated Information before Implementation. To provide stakeholders time to familiarize themselves with the new Application, the CDFI Fund said it will make the final Application form and related materials available in advance of it going into use.
- Conduct Public Outreach. After releasing the final Certification Application form and prior to opening the new application process, the CDFI Fund said it will schedule public engagements to provide information on the final CDFI Certification Application and implementation details.
- Enhance Data and Material Submission Infrastructure. The CDFI Fund said it is actively making improvements to its Awards Management Information System (AMIS) to ensure CDFIs are able to efficiently submit data and all supporting material required by the new CDFI Certification Application, including the new abbreviated Transaction Level Report (TLR) and updated Annual Certification and Data Collection Report (ACR), which will conform to the revised CDFI Certification Application.
- Institute a Grace Period. Currently Certified CDFIs will be afforded a grace period – sufficient time to apply for Certification under the new Certification Application while maintaining Certification status, according to Treasury. The CDFI Fund said it will also publish detailed guidance information on how to achieve compliance with the new CDFI Certification guidelines and the deadlines for currently Certified CDFIs to submit their Application. Technical assistance will be made available to applicants throughout the grace period.
Additional Information
Updated guidance information on the current 2023 ACR reporting round is available on the CDFI Fund’s website at www.cdfifund.gov/cdficert under “Step 2: Reporting.”
Those CDFIs that submitted Target Market Modification Applications prior to October 1, 2022 will receive determination notices by May 31, the CDFI Fund said.
For guidance and supporting information related to the CDFI Fund’s efforts in revising the CDFI Certification Application, ACR and abbreviated TLR, visit the CDFI Fund’s CDFI Certification Application & Data Collection Reporting Revisions webpage.
NAFCU Raises Concerns
In response to the CDFI update, NAFCU President and CEO Dan Berger said, "We are deeply concerned that the CDFI Fund continues to give community-based credit unions the runaround. From the beginning of their application reform process, we’ve advocated for clear communication and transparency. The latest ‘update’ from the fund is the complete opposite – after months of delay, there is still no definitive date of when credit unions can begin applying for CDFI certification and no indication of what revisions are being made. The CDFI Fund is restricting access to critical funds with its poor management, and communities in need of these resources are suffering as a result.”
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