Removing Barriers Blog

Comments submitted re: possible CDFI application revisions
Posted November 05, 2020 by CUNA Advocacy

CUNA submitted comments to the Treasury in response to the recently proposed potential revisions to the application as part of its ongoing review of policies and procedures.  In the letter, CUNA wrote that the proposed Community Development Financial Institution (CDFI) Certification Application is flawed and should be reconsidered.

“While CUNA supports the CDFI Fund’s ongoing efforts to evaluate and consider the efficiency and relevance of its certification and monitoring process, we strongly believe the proposed revisions to the certification application fail to achieve these goals nor would they further the purposes of the CDFI Program,” the letter reads. “In fact, the proposed application changes could ultimately serve as unnecessary barriers for qualified credit unions to access the CDFI designation.”

CUNA’s comment notes several parts of the application that contain multiple redundant questions or fails to recognize requirements credit unions face from regulators such as NCUA.

“The Fund should reconsider this proposal and instead focus on evaluating its credit union participants by further developing a partnership with the NCUA and using the information collected by NCUA during its routine examination process to encourage greater CDFI participation,” the letter reads.

As of October 14, credit unions make up 321 certified CDFIs out of 1,144 nationwide.