WASHINGTON—Both CUNA and NAFCU are asking the Environmental Protection Agency (EPA) to clarify that credit unions can participate in grant opportunities under the Greenhouse Gas Reduction (GHGR) Fund before issuing the Notice of Funding Opportunity (NOFO).
NAFCU Vice President of Regulatory Affairs Ann Petros wrote to the EPA with that request, and further stated “the EPA must confirm the threshold eligibility requirements in its new proposed implementation framework to confirm that credit unions and CDFIs can receive funding” from the fund.
She reminded the Clean Air Act allows the EPA to make grants to “a variety of lending intermediaries,” including credit unions – if they meet eligibility criteria.
Petros also noted that credit unions have experience in community and cooperative lending and “will ensure the long-term success of the GHGR Fund.”
CUNA’s Comment
Meanwhile, in its letter CUNA shared its concerns that the proposed method of severing direct and indirect investment into separate funds would be wasteful and “significantly hinder” the goal of serving low-income and disadvantaged communities.
“If the EPA’s goal is to ensure that these Funds are deployed effectively and efficiently, it should approach this holistically – allow capacity-building indirect investment to be bundled with funds for direct investment in qualified projects through a single entity,” the letter reads. “This would result in the least amount of waste and excess cost to borrowers. It would also create the most sustainable structure for entities that will ultimately deliver the benefits of these Funds to the communities intended to be served.”
CUNA suggested credit unions—particularly Community Development Financial Institution certified credit unions (CDCUs) and minority depository institution-certified credit unions—are “ideally suited” to meet the GGRF’s core objective.
History of ‘Working Collaboratively’
“Credit unions have a demonstrated history of working collaboratively to develop products and deliver services at a scale that achieves exceptional regulatory performance, public trust, and accountability,” the letter reads. “Credit unions and CDCUs already operate under existing federal and state regulatory structures that allow the EPA to be sure of the integrity of the use of those funds.”
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