* How do I determine if an Affiliate is engaging in eligible Financial Products or Financial Services activity?
To determine if an Affiliate is engaged in eligible Financial Products or Financial Service, the CDFI Fund considers the following:
* What is a “substantial minority” of Control over an organization’s board?
A substantial minority of a board is less than half of the number of board members, but still enough to be able to influence or impact how the board functions and/or the decisions it makes.
* How do I identify a relationship of Control between an Applicant and a possible Affiliate?
In examining the definitions for Control, Controlled, or Controlling, Affiliates can be identified clearly within an entity’s stock certificate summary report, organizing documents, or governance documents (including its bylaws or similar, Articles of Incorporation or similar, etc.).
Some common examples of Control outside of a stock ownership situation include:
* Can I reopen my TLR if I notice a mistake I made?
No. A certified TLR submitted in conjunction with its CDFI Certification Application cannot be reopened for modification by the Applicant after its CDFI Certification Application has been submitted in AMIS.
* How should I designate my CDFI Intermediary activity to Native CDFIs in the TLR?
CDFI Intermediaries directing activity to Native CDFIs and seeking the Native American CDFI Designation should use the Designated Target Market Type data point in the TLR to tag transactions as “OTP – Native American,” “OTP – Native Alaskan,” or “OTP – Native Hawaiian,” as applicable, rather than “OTP – Certified CDFI(s).”
* In which situations are Loan Purchase transactions allowed to be bundled in the TLR?
The CDFI Fund considers both bundled and individually purchased loans as eligible Financial Product activity for reporting in the TLR.
When loans are purchased in a bundle from a Certified CDFI, and the purchasing organization includes an OTP – Certified CDFI(s) market component in its Target Market and designates the transaction as having a “Designated Target Market Type” of “OTP-Certified CDFIs”, the entire bundle will be reported as a single Financial Product transaction in the TLR.
* For an Other Targeted Population – Certified CDFIs (OTP – Certified CDFI(s)) Target Market Type: how can I show that a board member is a staff member of an organization that serves Certified CDFIs?
When an Applicant proposes an OTP – Certified CDFI Target Market component, the Applicant must provide the name of the board member’s employer. The entity’s status as a Certified CDFI can be verified using the list of Certified CDFIs available on the CDFI Fund’s website.
* For Investment Area, Low-Income Target Population (LITP), or Other Targeted Population – Persons with Disabilities (OTP – PWD) Target Market types: how can I show that a board member is a staff member of an organization that primarily serves the relevan
When an Applicant proposes an Investment Area, LITP, or OTP – PWD Target Market component, in order to show that a board member is a staff member of an organization that primarily serves the relevant market, the Applicant must provide the following:
* Can my organization’s governing or advisory board member’s employment be a source of Accountability to a proposed Target Market component?
Yes. A board member’s employment may be used as a CDFI Certification source of Accountability for certain Target Market components, including:
- Investment Area
- Low-Income Target Population (LITP)
- Other Targeted Population – Persons with Disabilities (OTP – PWD)
- Other Targeted Population – Certified CDFI(s) (OTP – Certified CDFI)
* How do I create a CIMS map for a Non-Metro Customized Investment Area comprised of counties and parishes?
When creating a CIMS map for a Non-Metro Customized Investment Area made up of counties and parishes, it is important to also select all census tracts within each county or parish. This ensures the Target Market Calculator can properly assess financing activity thresholds (see other questions in the Target Market section for more information on the thresholds).