* How should loan purchases be presented for review in connection with the Target Market requirements?

  • All loan purchases closed during the relevant review timeframe in connection with the Target Market requirements must be presented as eligible Financial Products activity.
  • Loans purchased from Certified CDFI(s), whether purchased individually or in a bundle, may be counted toward meeting the CDFI Certification Target Market benchmark requirements when an “OTP – Certified CDFI(s)” Target Market component is an allowable part of the overall CDFI Certification Target Market or, if applicable, a component of the collective review Target Market for relevant entities.

* What Loan Purchase transactions should be reported in connection with the Target Market requirements?

All loan purchase transactions closed during the relevant review period must be reported in an organization’s Transaction Level Report in connection with the Target Market requirements as eligible Financial Product activity for CDFI Certification purposes. The CDFI Fund considers all loan purchases to be eligible Financial Product activity. 

The CDFI Fund recognizes loan purchases from both Certified CDFIs, and non-Certified entities may count toward meeting the Target Market benchmark requirements, provided certain conditions are met:

* May a Customized Investment Area include both Metro and Non-Metro census tracts or must it only include census tracts that are designated as metro census tracts?

A Customized Investment Area can include both Metro and non-Metro census tracts. However, Non-Metro Customized Investment Areas, Counties, and Parishes must be comprised of geographic units that are all designated as non-metro.

Customized Investment Areas include a contiguous mix of both qualified and non-qualified geographic units of a single type. 

* What is the Controlling Entity Option for collective review Accountability?

The Controlling Entity Option for collective review accountability allows an Affiliate entity that does not offer Financial Products to demonstrate collective review Accountability through a controlling entity. This Controlling Entity must be accountable to the selected market, even if it does not share that entity’s board or the Controlling Entity is not itself subject to review.

* How do I present my organization’s Affiliate collective review market and Accountability information in AMIS?

Each entity in a CDFI Certification collective review must show accountability to its selected collective review market through its own governing or advisory board. For each relevant Affiliate, a CDFI Certification Market record must be added in its AMIS Organization Detail page, using the Record Purpose: “CDFI Certification – collective review for another entity”.

The selected collective review market can be:

* What is required in the stock summary report for the CDFI Certification Application?

The stock summary report for the CDFI Certification Application must detail the ownership of voting stock shares in your organization, identifying all individuals and entities that own 25% or more of the voting stock. It should include the names of all owners, their respective ownership percentages, and clearly document any ownership exceeding 25%. If your report shows “0%” for Insured Depository Institutions or Depository Institution Holding Companies, it indicates no ownership in these categories.

* Can my organization submit a request for a Section Zero determination at any point in time?

No. During the General Recertification Submission Deadline Windows, currently certified CDFIs have been assigned a designated submission window for their Section Zero Application. Once this submission window closes, a currently Certified CDFI cannot submit a Section Zero Application until after a determination has been made on its submitted CDFI Certification Application. Entities whose CDFI Certification is reaffirmed will be able to submit a Section Zero Application prior to the Annual Certification and Data Collection Report (ACR) submission.