How will the CDFI Fund assess the 3-year Target Market percentage in the new ACR?

The 3-year Target Market percentage will be calculated by assessing an entity’s cumulative Target Market activity over three full fiscal years (the most recently completed fiscal year being reported on in the ACR and the two preceding fiscal years) divided by their total lending activity over the same time period to assess whether the Target Market activity thresholds for dollar amount and count of transactions have been met. It is not an average of the Target Market activity percentages for each of the three years.

Which version of the TLR does an entity file and what is its due date?

  • Entities completing the new Certification Application for the first time are required to complete the abbreviated TLR. The TLR is required to be submitted and certified prior to submission of the Certification Application. Once Certified, these entities are required to submit the abbreviated version of the TLR on an annual basis as part of their ACR submission unless they receive a financial assistance award which has a full-length TLR reporting requirement.

Are all entities required to complete the Financial Services section of the TLR?

No, all entities are not required to complete the TLR’s Financial Services section. The Financial Services section should only be completed by those depository institutions that are using eligible Financial Services activity to meet the required Target Market Activity thresholds. For such purposes, the Financial Services section measures the total percentage of unique depository account holders who are members of one or more eligible Target Market(s).

Are all entities required to complete the Loan Purchases section of the TLR?

No, the Loan Purchases section of the TLR must be completed as part of the TLR package submission only if an entity has loan purchases on its balance sheet and the loans were purchased within the reporting period. Such entities should complete the Loan Purchases section of the TLR even if they did not use loan purchases to meet their required Target Market activity thresholds.

Can a single transaction be counted for multiple approved Target Market types in the Target Market activity threshold calculation?

No, while a transaction may qualify for multiple approved Target Market types, it can only be counted once in the calculation. For example, a mortgage could be located in an Investment Area to a low-income, Hispanic borrower. However, for purposes of the Target Market activity thresholds, a transaction can only be counted once, so an entity will be required to select which Target Market type should be assigned to a transaction. The entity can only select one of its approved Target Market types.

Where should consumer loans be reported in the TLR?

If an entity is a regulated financial institution such as a bank or credit union, then consumer loan transactions should be entered into the Consumer Loans/Investments TLR Object with a value of “CONSUMER” for the “Purpose” data field.

If an entity is an unregulated financial institution, then consumer loans transactions should be entered into the main section of the TLR by selecting “CONSUMER” for the “Purpose” data field and selecting ‘IND’ within the ‘Investee/Borrower Type’ field for a loan issued to an individual borrower.

Do regulated financial institutions need to report on specific OTP types in the Consumer Loans section of the TLR?

Yes, if a regulated financial institution intends to serve an OTP Target Market, it now must report the aggregated consumer loan transaction totals for each specific OTP type in the Consumer Loans/Investments TLR Object. This information is necessary to determine how regulated financial institutions are serving their proposed or approved component(s) of their Target Market. 

Applicants must count a transaction for only one OTP category regardless of whether it qualifies for more than one. 

Learn about the Upcoming CY 2024-2025 New Markets Tax Credit Program Allocation Application Round - $10 Billion in Allocation Authority will be Available!

As previously announced, the next round of the New Markets Tax Credit Program (NMTC Program) will make $10 billion in Allocation Authority available, and the round will span calendar years (CYs) 2024 and 2025. The CDFI Fund is tentatively planning to open the CY 2024-2025 NMTC Program Allocation Application round this fall.