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).”
Under the revised CDFI Certification, an organization must direct at least 50% of its financing activity—by both number and dollar volume of transactions—to Native Communities to qualify for the Native CDFI Designation. The Target Market Calculator measures originations designated as Native Targeted Populations to count for the financing activity assessment. Therefore, CDFI Intermediaries seeking this designation should not report Native CDFI-directed activity as “OTP – Certified CDFI(s),” as those transactions would not count toward the Native Community activity threshold.
Instead, organizations should designate Native CDFI-directed activity to the applicable “OTP – Native American,” “OTP – Native Alaskan,” or “OTP – Native Hawaiian” market components. These designations align with the pre-approved Target Market Assessment Methodologies for nonprofit and for-profit Native Targeted Population recipient eligibility. If an organization qualifies for the Native American CDFI Designation, then it meets the criteria for transactions to be designated to the relevant Native Targeted Population market components.
CDFI Intermediaries may propose the “OTP – Certified CDFI(s)” market component, if they also maintain board Accountability to that component and to the relevant Native market components.”