Community Development Financial Institutions (CDFIs)

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I recently attended an NCUA webinar regarding the revised CDFI Certification Application and thought it may be helpful to provide a brief overview. Before we begin, let’s discuss what a CDFI actually is. CDFI stands for Community Development Financial Institutions and, according to this NCUA resource regarding the NCUA-CDFI Certification Initiative, “[t]he U. S. Treasury Department’s Community Development Financial Institutions Fund designates organizations that provide financial services to low-income communities and to people who lack access to financing and that meet certain criteria as Community Development Financial Institutions.”

When a credit union becomes certified as a CDFI it is then eligible to apply for awards which are administered by the CDFI Fund. Such awards “enable CDFIs to finance a wide range of activities”, which could include things such as “mortgage lending for first-time homebuyers” and “commercial loans for businesses in low-income areas.”

So, how would a CDFI certification benefit your credit union? Some of the benefits noted by NCUA include:

  • “Apply for funding through the CDFI Fund’s competitive CDFI Program and Native American CDFI Assistance Program, if applicable;
  • Training and Technical Assistance opportunities sponsored by the CDFI Fund; and
  • Funding from funders other than the CDFI Fund.”

There is a standardized application form that the CDFI Fund uses to collect information which is submitted through its Awards Management Information Systems (AMIS). This application is necessary for the CDFI Fund to make a decision regarding certification. Additionally, CDFIs are required to report their yearly lending and investment activity through the Annual Certification and Data Collection Report (ACR).

A revised CDFI Certification Application was published by the CDFI Fund in December of last year (2023). According to the CDFI Fund, applicants must meet the following requirements:

  • “Is a legal entity at the time of Certification application;
  • Has a primary mission of promoting community development;
  • Is a financing entity;
  • Primarily serves one or more target markets;
  • Provides development services in conjunction with its financing activities;
  • Maintains accountability to its defined target market; and
  • Is a non-government entity and not under the control of any government entity (Tribal governments excluded).”

As mentioned above, the CDFI Certification Application has been revised. One such revision is that applicants now must provide information pertaining to the demographics of their executive staff and governing-leadership. Another revision is that applicants must register with SAM.gov for purposes of the Legal Entity test. While this blog won’t attempt to address every revision, credit unions may want to watch NCUA’s webinar regarding the revised CDFI Certification Application for a more in-depth discussion.

Notably, currently certified CDFIs are being given a one-year grace period from December 2023 in order to come into compliance with the revised standards. The webinar’s Q&A noted that CDFIs can get recertified once they are in compliance.

Additionally, based on the CDFI Fund’s website, the following important deadlines should be noted:

  • “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.”

Furthermore, here are some resources that may be helpful for credit unions to review:

Questions regarding the CDFI Certification can be directed to the CDFI Fund’s Office of Certification Policy and Evaluations via email at ccme@cdfi.treas.gov. Additionally, questions regarding the ACR can be directed to the CDFI Fund’s Office of Financial Strategies and Research via cdfi-financialstrategiesandresearch@cdfi.treas.gov. And, of course, credit unions can always reach out to the America’s Credit Unions Compliance Team with compliance questions by emailing us at Compliance@americascreditunions.org.

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