APPLICATION INSTRUCTIONS
OFFICE OF CERTI FICATI ON POLICY
AND EVALUATI ON
CDFI
CERTIFICATION
AP
PLICATION
RELEASED DECEMBER 2023
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Contents
CERTIFICATION APPLICATION OVERVIEW ..................................................................................................... 2
KEY TERMS ..................................................................................................................................................... 3
ADDITIONAL CDFI CERTIFICATION REQUIREMENTS AND PROVISIONS BY ENTITY TYPE .............................. 6
APPLICATION PROCESS ................................................................................................................................ 13
OBTAINING DETERMINATION OF RESPONSIBLE FINANCING PRACTICES, SIMILAR FINANCIAL PRODUCTS,
SIMILAR FINANCIAL SERVICES, DISREGARDED OR INCLUDED MAJOR ASSETS/STAFF TIME, TARGETED
POPULATIONS, AND TARGET MARKET ASSESSMENT METHODOLOGIES .................................................... 17
APPLICANT BASIC INFORMATION ................................................................................................................ 21
LEGAL ENTITY ............................................................................................................................................... 36
PRIMARY MISSION ....................................................................................................................................... 37
FINANCING ENTITY ...................................................................................................................................... 63
TARGET MARKET .......................................................................................................................................... 79
DEVELOPMENT SERVICES ............................................................................................................................ 92
ACCOUNTABILITY ......................................................................................................................................... 97
NON-GOVERNMENT ENTITY ...................................................................................................................... 115
NATIVE AMERICAN CDFI DESIGNATION .................................................................................................... 118
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CERTIFICATION APPLICATION OVERVIEW
COMMUNITY DEVELOPMENT FINANCIAL INSTITUTIONS FUND (CDFI FUND) MISSION
The mission of the CDFI Fund is to expand economic opportunity for underserved people and
communities by supporting the growth and capacity of a national network of community development
lenders, investors, and Financial Service providers.
COMMUNITY DEVELOPMENT FINANCIAL INSTITUTION (CDFI) CERTIFICATION
CDFI Certification” or “CDFI Certified” is the official U.S. Department of the Treasury designation issued
by the CDFI Fund to entities that provide financing activities
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to underserved people and communities.
CDFI Certification does not constitute an opinion by the CDFI Fund as to the effectiveness or financial
viability of an entity. The questions in this Application are based on existing laws, regulations, and CDFI
Fund Policy.
To be certified as a CDFI, an entity must meet all of the following criteria:
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- be a legal entity;
- have a primary mission of promoting community development;
- be a financing entity that predominantly engages in the provision of arm’s-length,
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on-balance
sheet
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Financial Products,
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and/or Financial Services and has done so for at least one full fiscal
year;
- primarily serve one or more Target Markets with its arms-length, on-balance sheet Financial
Products and, if elected, Financial Services;
- provide Development Services in conjunction with its arm’s-length, on-balance sheet Financial
Products;
- maintain accountability to each component of its CDFI Certification Target Market; and
- be a non-government
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entity.
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Activities that support the provision of Financial Products and/or Financial Services.
2
In some cases, the Applicant, as well as its Affiliates, may be subject to some or all of the listed criteria.
3
Entities that are Controlled by a Certified CDFI and seek to participate in the CDFI Fund’s Bond Guarantee Program (BG
Program) can meet the Certification requirements using Financial Product activity or Development Services that are not arm’s-
length, as long as the activity is by and between such entities and their Controlling Certified CDFIs. Such activity must be
pursuant to operating agreements that include management and ownership provisions and are in a form and substance
acceptable to the CDFI Fund (see 12 CFR 1805.201(b)(2)(C)(iii)). Depository Institution Holding Companies (DIHCs) that do not
engage in their own direct Financial Product or Financial Services activity can rely on the activity of entities subject to the CDFI
Certification collective review process to meet the CDFI Certification requirements.
4
Unless otherwise noted, balance sheet also refers to statement of financial position or statement of financial condition,
which shows an organization’s assets, liabilities, and owner's equity (or stockholders’ equity); based on entity type.
5
The CDFI Fund recognizes the following types of Financial Products: loans; Equity Investments; loan guarantees; debt with
equity features; the purchase of loans originated by Certified CDFIs; the purchase of certain loans from organizations that are
not certified as CDFIs; and any similar financing activity pre-approved by the CDFI Fund.
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A CDFI that is operated or Controlled by a tribal government is eligible to apply for Certification. Indian tribes are not agencies
or instrumentalities of the United States or any state.
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KEY TERMS
All capitalized terms in this Application are defined herein, in 12 CFR Part 1805, or in 12 U.S.C. 4701 et
seq.
KEY TERMS FOR IDENTIFYING AFFILIATES/SUBSIDIARIES
Affiliate: a company or entity that Controls, is Controlled by, or operates under common Control with
another company.
Subsidiary: a company that is owned or Controlled directly, or indirectly, by another company.
Control, Controlled, or Controlling:
(1) Ownership, Control, or power to vote 25% or more of the outstanding shares of any class of
voting securities of any company, directly or indirectly or acting through one or more other
persons;
(2) Control in any manner over the election of a majority of the directors, trustees, general
partners, or individuals exercising similar functions of any company; or
(3) Power to exercise, directly or indirectly, a Controlling influence over the management, credit, or
investment decisions or policies of any company.
Spin-off: An entity that (1) has received a transferred (not purchased) Financial Product portfolio from
one or more separate entity(ies) that was an Affiliate at the time the transfer took place and for which
the portfolio consists of arm’s-length Financial Product transactions closed by the Affiliate; and (2) will
continue Financial Product activity of the same type as the Affiliate.
KEY TERMS OF REGULATED FINANCING ENTITIES
Depository Institution Holding Company (DIHC): a bank holding company or a savings and loan holding
company, as defined in section 3 of the Federal Deposit Insurance Act (12 U.S.C. 1813(w)(1)).
Insured Depository Institution (IDI): any bank or thrift with deposits insured by the Federal Deposit
Insurance Corporation.
Insured Credit Union: any credit union with member accounts insured by the National Credit Union Share
Insurance Fund.
State-Insured Credit Unions: credit unions that are regulated by and/or have insurance for their member
accounts from a State agency or instrumentality.
State: any of the 50 U.S. states, the District of Columbia, or territory of the United States (Puerto Rico,
Guam, American Samoa, the U.S. Virgin Islands, and Northern Mariana Islands).
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ELIGIBLE FINANCIAL PRODUCTS
The CDFI Fund currently recognizes the following types of Financial Products, and terms, for CDFI
Certification purposes:
- arm’s-length transaction: a transaction between independent, unrelated parties, each acting in its
own best interest;
- loans: a type of debt in which a lender transfers funds to a borrower with the expectation of
repayment over time;
- Equity Investments: an arms-length Investment with a third party such as a stock purchase, a
purchase of partnership interest, a purchase of a limited liability company membership interest, a
loan made on such terms that it has sufficient characteristics of equity, a purchase of secondary
capital;
- loan guarantees: in general, a promise by a party to assume a debt obligation of a borrower if the
borrower defaults;
- forgivable loans: a type of loan in which the principle and interest can be entirely or partially
forgiven or deferred for a period of time by the lender when certain conditions are met. Such loans
are eligible for purposes of CDFI Certification only if they require at least one payment within 12
months of the loan closing date (excluding payment of fees associated with the loan closing);
- on-balance sheet: items that are recorded on an entity’s non-consolidated balance sheet;
- loan purchase: (1) Purchase of loans originated by Certified CDFIs; (2) Purchase of loans originated
by entities that do not have the CDFI Certification but were made to members of the Applicant’s
Target Market;
- credit cards: a payment mechanism that facilitates both consumer and commercial business
transactions, including purchases and cash advances where the borrower is required to pay at least
part of the card’s outstanding balance each billing cycle, depending on the terms as set forth in the
cardholder agreement;
- lines of credit: an arrangement between the creditor and a customer that establishes the maximum
loan amount the customer can borrow; and
- debt with equity features: a loan agreement that stipulates that the loan may be converted to
equity upon meeting specified conditions.
Unless otherwise indicated, to be recognized as a Financial Product, the related transaction(s) must be
arm’s-length and on-balance sheet. Even though they no longer appear on-balance sheet, Financial Product
transactions originated during the reporting fiscal year that may have been sold or paid off prior to the last
day of the reporting fiscal year should still be included in the Financial Product activity data.
To be certified as a CDFI, an Applicant’s Financial Products must comply with any applicable standards for
responsible financing practices described in the Primary Mission section of this application.
For any financing activity not clearly identified above, an Applicant must submit a request to the CDFI Fund
for specific recognition as an eligible Financial Product. If the Applicant is uncertain whether the product it
offers aligns with the Financial Product type(s) shown above, the Applicant should obtain clarification. To
obtain clarification, the Applicant must submit a Service Request in the CDFI Fund’s Awards Management
Information System (AMIS) prior to submitting the CDFI Certification Application.
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ELIGIBLE FINANCIAL SERVICES
The CDFI Fund currently recognizes the following types of Financial Services for CDFI Certification purposes:
- consumer checking accounts;
- consumer savings and share accounts;
- check cashing;
- money orders;
- certified checks;
- automated teller machines;
- money market accounts; and
- safe deposit box services.
Any similar services not listed above must be specifically approved by the CDFI Fund to be recognized as a
Financial Service.
The CDFI Fund recognizes all of the above Financial Services for the purpose of meeting the CDFI
Certification requirements, except in connection with the Target Market test and the Development Services
test, for which only the direct holding of consumer depository accounts will be accepted as an eligible
Financial Service. Depository accounts are savings/share accounts, checking accounts, and money market
accounts.
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ADDITIONAL CDFI CERTIFICATION REQUIREMENTS AND PROVISIONS BY
ENTITY TYPE
REQUIREMENTS FOR DEPOSITORY INSTITUTION HOLDING COMPANIES (DIHCs), AFFILIATES OF DIHCs,
AND SUBSIDIARIES OF INSURED DEPOSITORY INSTITUTIONS (IDIs)
If the entity seeking CDFI Certification is a DIHC, an Affiliate of a DIHC, or a Subsidiary of an IDI, it must
meet the CDFI Certification requirements based on a review of its compliance with those requirements
on its own, as well as a collective review of the following relevant Affiliates (even if all such Affiliates are
not seeking to obtain or maintain CDFI Certification):
- any Affiliate that is a DIHC or an IDI that Controls the Applicant;
- if an Applicant is a DIHC, any Affiliate that the Applicant Controls that directly engages in the
provision of Financial Products and/or Financial Services; or
- any Affiliate that is mutually Controlled with the Applicant by a DIHC or an IDI and that directly
engages in the provision of Financial Products and/or Financial Services.
DIHCs, Affiliates of DIHCs, and Subsidiaries of IDIs may obtain or maintain CDFI Certification only if
- they individually meet each of the CDFI Certification requirements (DIHCs can meet the Target
Market requirements based on the activity of an Affiliate[s]);
- all of their relevant Affiliates individually meet primary mission, Accountability, and
Development Services requirements; and
- they and their relevant Affiliate(s) meet the Target Market test in the aggregate.
For the purposes of the CDFI Certification collective review,
- any entity subject to the CDFI Certification collective review process must have a current
governing leadership
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-approved primary mission of community development;
- if the entity seeking to obtain or maintain the CDFI Certification is a DIHC that does not engage
in its own Financial Product activity, in addition to having an acceptable current primary mission
of community developmentand any other entity subject to the CDFI Certification collective
review process that engages in Financial Product activitymust also have a governing board-
approved primary mission of community development in place for at least the most recent six
full months prior to Application submission (can be via a series of acceptable missions);
- any Financial Product or Financial Services activity engaged in by an entity subject to the CDFI
Certification collective review process must be included along with that of the Applicant and any
other relevant Affiliate in the aggregated Financial Product and, if elected, Financial Services
activity used for the collective assessment of compliance with the Target Market requirements
of the primary entity under review; and
- any entity subject to the CDFI Certification collective review process must be able to
demonstrate its accountability to the CDFI Certification Target Market of the primary entity
under review via its own governing or formal advisory board(s) or, if it does not engage in its
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Governing leadership includes governing/managing board members, managing member, managing partner, or
similar.
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own Financial Product activity, via the accountability of an entity that Controls it, even if it has
not adopted the board(s) used as a means of accountability by the Controlling entity as its own
board(s).
PRIMARY MISSION REQUIREMENTS FOR CERTIFICATION APPLICANTS WITH AFFILIATES
For DIHCs, Affiliates of DIHCs, and Subsidiaries of IDIs, including Subsidiaries of a tribal government, the
CDFI Certification primary mission requirements must be met by all entities subject to the collective
review process, as described in the “Requirements for DIHCs, Affiliates of DIHCs, and Subsidiaries of
IDIs” above, to the collective CDFI Certification review.
For all other Applicants, the CDFI Certification primary mission requirements must be met by any
Affiliate of the Applicant that Controls the Applicant or that directly engages in the provision of Financial
Products and/or Financial Services.
For more information, see the Primary Mission section of the Application form and the guidance
materials.
ADDITIONAL PROVISIONS FOR MEETING THE CDFI CERTIFICATION REQUIREMENTS
The following policies detail how different types of entities can meet CDFI Certification requirements in
a manner consistent with their structure.
ENTITIES CONTROLLED BY TRIBAL GOVERNMENTS PRIMARY MISSION REQUIREMENTS
Entities Controlled by a tribal government are eligible to apply for CDFI Certification. Indian tribes are
not agencies or instrumentalities of the United States or any State. An entity’s affiliation with a tribal
government will not affect its ability to meet the non-government entity criteria.
A CDFI Certification Applicant and/or entities subject to the collective review process that are Controlled
by a tribal government will need to demonstrate that they meet the primary mission requirements; the
tribal government is not required to meet primary mission requirements.
DEPOSITORY INSTITUTION HOLDING COMPANIES, INSURED DEPOSITORY INSTITUTIONS, INSURED
CREDIT UNIONS, AND STATE-INSURED CREDIT UNIONS FINANCING ENTITY REQUIREMENTS
As regulated and insured financial institutions, DIHCs, IDIs, Insured Credit Unions, and State-Insured
Credit Unions automatically meet the CDFI Certification Financing Entity requirements, provided they
have been engaged in eligible financing for at least one full fiscal year prior to submission of the
Application.
DIHCs THAT DO NOT ENGAGE IN THEIR OWN FINANCIAL PRODUCT OR FINANCIAL SERVICES ACTIVITY
TARGET MARKET REQUIREMENTS
A DIHC that does not directly provide Financial Products or Financial Services may meet the Target
Market requirements by relying on the collective activity of its Affiliates if at least one Affiliate has been
engaged in closing Financial Products transactions or completing Financial Services activities for at least
one full fiscal year prior to submission of the Application.
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ENTITIES APPLYING FOR CERTIFICATION SOLELY FOR PARTICIPATION AS ELIGIBLE CDFIs IN THE CDFI
BOND GUARANTEE PROGRAM (BG PROGRAM) FINANCING ENTITY AND ARM’S-LENGTH
TRANSACTION REQUIREMENTS
Entities applying for Certification solely to participate as Eligible CDFIs in the CDFI BG Program
- that are unable to meet CDFI Certification Financing Entity requirements based on their own
status will be considered Financing Entities if they are Controlled by a Certified CDFI. Such
entities may also need to meet additional parameters and restrictions established via the
applicable Notice of Guarantee Availability for the particular CDFI BG Program Application round
(see 12 CFR 1805.201(b)(2)(C)(ii)).
- must be Controlled by a Certified CDFI and meet CDFI Certification requirements using on-
balance sheet Financial Products, Financial Services, and Development Services activity that is
not arm’s-length, provided that the activity is directed to their Controlling Certified CDFI. Such
activity must be pursuant to operating agreements that include management and ownership
provisions, and that are in a form and substance acceptable to the CDFI Fund (see 12 CFR
1805.201(b)(2)(C)(iii)).
Entities Certified under this provision will not be accepted as Certified for CDFI Fund assistance
programs other than the CDFI BG Program. If such an entity seeks access to other CDFI Fund assistance
programs, it must apply for CDFI Certification using the standard CDFI Certification Application process
and demonstrate it meets all the mandated requirements for CDFI Certification.
SPIN-OFF ENTITIES PRIMARY MISSION, FINANCING ENTITY, AND TARGET MARKET REQUIREMENTS
An entity spun off from one or more Certified CDFIs is not eligible for this provision.
An entity spun off from one or more non-CDFI-Certified entities that offer arm’s-length, on-balance
sheet Financial Products is eligible to seek CDFI Certification, even if it has less than one full fiscal year
financing activity of its own. Such entities must be able to meet the requirements of the CDFI
Certification provision for Spin-off entities outlined in the Financing Entity and Target Market sections.
In addition, if an Applicant seeks to use the CDFI Certification provision for Spin-off entities, it must meet
the primary mission timeframe requirement by demonstrating that either the Applicant, or an entity
from which the Applicant received Financial Products, had an appropriate primary mission of community
development in place throughout the full six months immediately prior to submission of the CDFI
Certification Application.
For more detail on these above policies, please see the instructions for each relevant CDFI Certification
criterion in the CDFI Certification Application form and in the guidance materials.
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OTHER CONDITIONS
OBTAINING DETERMINATIONS FOR SIMILAR FINANCIAL PRODUCTS, SIMILAR FINANCIAL SERVICES,
RESPONSIBLE FINANCING PRACTICES, DISREGARDED OR INCLUDED ASSETS/STAFF TIME, TARGETED
POPULATIONS,
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AND TARGET MARKET ASSESSMENT METHODOLOGIES
The CDFI Certification Application identifies those Financial Products, Financial Services, disregarded or
included assets and staff time, Targeted Populations, and Target Market assessment methodologies
approved by the CDFI Fund for purposes of CDFI Certification, as well as the standards for responsible
financing practices. Approved Target Market assessment methodologies must be used exactly as
outlined in the CDFI Certification Application and/or other related guidance materials unless and until
modification of the method is authorized by the CDFI Fund.
If an Applicant wishes to seek consideration to include any similar Financial Products, similar Financial
Services, amended standards for responsible financing practices, the ability to disregard major assets
and/or staff time, Other Targeted Populations, or the use of alternative or modified Target Market
assessment methodologies, it must first respond to a set of questions at the start of the CDFI
Certification Application. For each request to be considered, the Applicant must provide detailed
information and/or justification for the CDFI Fund to review. The Applicant will not be able to continue
the Application process until the CDFI Fund renders a decision on the request. When a decision is made,
the Applicant may continue with the Application process and complete the Transaction Level Report and
CDFI Certification Application.
If the CDFI Fund approves new similar Financial Products, similar Financial Services, major assets and/or
staff time to be disregarded or included, Other Targeted Populations, Target Market assessment
methodologies, or amended standards for responsible financing practices, the CDFI Fund will publicly
release information related to this change and update relevant list(s) or standards, as well as any CDFI
Certification guidance materials.
Obtaining Determination to Include Similar Financial Products or Similar Financial Services
Applicants seeking consideration to include Financial Products or Financial Services not currently
recognized or previously approved by the CDFI Fund as eligible for the purposes of the Financing Entity
or Target Market tests must provide the following information for the CDFI Fund’s consideration in
advance of completing and submitting their Application:
- name of proposed similar Financial Product or similar Financial Service;
- type of proposed similar Financial Product or similar Financial Service;
- target borrower, investee, service recipient;
- description (e.g., rates, terms, conditions) and purpose of similar Financial Product or similar
Financial Service;
- any protections that ensure the similar Financial Product does not harm consumers;
- evidence that consumers are not harmed (e.g., the rate of successful repayment under the
original rates, terms, and conditions of the Financial Product); and
- any additional information necessary for the CDFI Fund to consider the request.
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Targeted Population means individuals or an identifiable group of individuals meeting the requirements of 12
CFR § 1805.201(3).
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Obtaining Determination to Amend the Standards for Responsible Financing Practices
The current standards for responsible financing practices allow for certain circumstances under which an
otherwise disqualifying practice might serve an acceptable community development purpose. For example,
Applicants that offer consumer loans that exceed an annual percentage rate (APR) of 36% may still be
determined eligible for Certification if certain conditions are met, such as a default rate no greater than 5%,
limits on fees to refinance the loan, substantially equal loan payments that amortize to a zero balance, and so
on. Similarly, certain otherwise disqualifying residential real estate mortgage loan characteristics are
allowable for the purposes of CDFI Certification if the Applicant meets additional criteria.
Applicants seeking to engage in financing activities that do not currently meet the standards for
responsible financing practices of the primary mission test may seek amendment to the standards that
allows for additional activity that serves a community development purpose. To do so, Applicants must
provide the following information for the CDFI Fund’s consideration in advance of an Application
submission:
- description of the financing activity;
- current standard that the financing activity does not meet;
- reasons the Applicant believes the financing activity serves a community development purpose;
- any protections that ensure the financing activity does not harm consumers and/or conditions
under which the financing activity should be considered an acceptable community development
activity (e.g., limits on rates charged, purpose, borrower characteristics);
- evidence that consumers are not harmed (e.g., if discussing a Financial Product characteristic,
the rate of successful repayment under the original rates, terms, and conditions of the Financial
Product); and
- any additional relevant information.
The CDFI Fund will not approve individual exceptions to the primary mission test; any amendments to the
standards for responsible financing practices will be made available to all CDFIs and future Applicants.
Obtaining Determination to Disregard or Include Major Assets and/or Staff Time to Meet Financing
Entity Predominance Requirements
Applicants that seek to disregard or include major assets and/or staff time not currently listed as eligible
to be disregarded or included for the purpose of the Financing Entity predominance test must obtain a
determination from the CDFI Fund before those assets and/or staff time may be disregarded or included
for the purpose of this test.
To request consideration to disregard or include any major assets and/or staff time, Applicants must
provide the following information for the CDFI Fund’s consideration in advance of an Application
submission:
- a description of the major asset(s) and/or staff time to be disregarded or included;
- the dollar amount for the portion of the balance sheet line item(s) to be disregarded or included
and the name of the balance sheet line item(s);
- the average full-time equivalent (FTE) staff time to be disregarded or included;
- how the amount of the asset(s) and/or staff time to be disregarded or included was determined;
- if seeking to disregard any major asset(s) and/or staff time, why such asset(s) and/or staff time
incorrectly appear to indicate that the Applicant is not predominately a financing entity;
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- if seeking to include any major asset(s) and/or staff time, why the asset(s) and/or staff time is
essential for the Applicant to conduct its Financial Product and/or Financial Services activity; and
- a copy of the Applicant’s most recently completed fiscal year income statement and balance
sheet; and current fiscal year-to-date balance sheet.
Obtaining Determination for Additional Targeted Populations
Targeted Populations that are not already recognized by the CDFI Fund must be approved by the CDFI
Fund before they are included as part of an entity’s Target Market for CDFI Certification purposes. To
request a new Targeted Population, Applicants must provide the following information for the CDFI
Fund’s consideration in advance of an Application submission:
- a name and description of the Targeted Population;
- the geographic location of the Targeted Population intended to be served (e.g., national,
statewide, specific census tracts). Unless “national,” include a map generated in the CDFI
Information Mapping System (CIMS) depicting the geography to be served;
- a narrative demonstrating that the specific Targeted Population(s) has significant unmet capital
or Financial Services needs;
- whether the Applicant serves the members of the Targeted Population directly or indirectly or
through borrowers or investees that serve such members; and
- specific evidence showing the proposed Targeted Population has disparities, controlling for
poverty and income effects, in its access to Financial Products and Services for the geographic
population service area.
If seeking recognition of a new Targeted Population, Applicants also must submit a proposed Target
Market assessment methodology for the Targeted Population.
Obtaining Determination for Target Market Assessment Methodologies
A Target Market assessment methodology or combination of such methodologies must be used to verify
whether Financial Products, depository accounts, board members, and/or credit union members meet
the Target Market criteria.
Only methodologies approved by the CDFI Fund may be used when compiling Target Market data. A list
of pre-approved Target Market assessment methodologies can be found on the CDFI Fund website.
Applicants may request separate approval of a methodology not previously approved by the CDFI Fund.
Applicants that seek to use a Target Market assessment methodology other than one that appears on
the list of approved methodologies, including the use of programmatic proxy assessments, must provide
the following information for the CDFI Fund to consider in advance of completing their Application for
submission:
- the applicable Target Market (i.e., Investment Area, Low-Income Targeted Population, or Other
Targeted Population);
- assessment methodology (e.g., description of methodology and/or model design, including the
step-by-step process used to collect the data, review any documents, and/or run the model and
process its results);
- supporting or supplemental documentation;
- description of how the proposed assessment methodology provides sufficient confidence that a
transaction can be assigned to a specific Target Market;
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- if proposing a programmatic proxy, the program’s detailed eligibility criteria or the step-by-step
process used to compare programmatic data to CDFI Fund definitions (e.g., income sources,
income thresholds);
- the process for recordkeeping; and
- the process for updating any methodology dependent on underlying data changes.
Applicants may attach documents that provide a fuller description of the proposed assessment
methodology than what is allowed by the online form’s character-length restriction on answers.
All Target Market assessment methodologieswhether from the list of approved methodologies or
allowed to present separatelymust be used exactly as prescribed, unless and until modification of the
process is authorized by the CDFI Fund. Failure to use an approved assessment methodology (or
maintain required documentation) may result in the termination of a Certified CDFI’s certification.
TARGET MARKET TRANSACTION LEVEL REPORT
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Upon launching the CDFI Certification Application and responding to the “Obtaining determination”
questions, Applicants must complete and submit a Transaction Level Report (TLR). The TLR is a data
collection tool that provides a method to evaluate the extent to which an entity serves distressed areas
and underserved populations. Data provided through the TLR will be used to determine the share of an
entity’s Financial Products and/or Financial Services that are deployed to the entity’s proposed Target
Market. If an entity is not meeting the required Target Market benchmarks, it will not be allowed to
submit a CDFI Certification Application. For additional information on the TLR, review the related CDFI
Transaction Level Report documents.
ACCOUNTABILITY REQUIREMENTS FINANCIAL INTEREST POLICY
Governing board and advisory board members who are principals
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or staff members of the Applicant or
its Subsidiaries or Affiliates, or whose family
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members are principals or staff members, cannot be used
to demonstrate Target Market Accountability.
TRANSITION FROM GOVERNMENT CONTROL TO NON-GOVERNMENT ENTITY
If an Applicant was previously Controlled by a government or government-Controlled entity, it can
demonstrate that it is no longer Controlled by a government entity if its governance, organizing
documents, and board’s activities demonstrate that it allows for an election or appointment of a non-
governmentally Controlled board, and such board remains non-governmentally Controlled for one year
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For the purpose of the CDFI Certification Application, all references to the Transaction Level Report include the
abbreviated TLR (for entities that are not CDFI Fund Financial Assistance [FA] award recipients with a TLR reporting
requirement) and the full-length TLR (for entities that are recipients of CDFI Fund Financial Assistance [FA] awards
with a TLR reporting requirement).
10
The CDFI Fund defines “principal as an individual that retains ownership, Control, or power to vote 25% or more
of the outstanding shares of voting securities of the Applicant.
11
Family members include spouses, children (including step-, in-law, and adopted children), and other members
of the board member’s family (i.e., siblings [including step-, half-, and in-law siblings], parents [including step- and
in-law parents], and grandparents related by blood or adoption).
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from the date of the change. The date and authorizing signature of approval of the non-governmentally
Controlled board must be clearly displayed in the organizing documents.
APPLICATION PROCESS
(1) Review the Certification as a Community Development Financial Institution section and
Definitions section of the CDFI Program Revised Interim Regulations, 12 CFR Part 1805, available
on the CDFI Fund’s public website at cdfifund.gov. Note that capitalized words or phrases
throughout the CDFI Certification Application are defined terms that can be found in the Interim
Regulation or the Community Development Banking and Financial Institutions Act of 1994 (12
U.S.C. 4701 et seq.).
(2) Review the Application and supplemental Application guidance documents provided on the CDFI
Fund’s CDFI Certification webpage.
(3) Create a System for Award Management (SAM) account to obtain a Unique Entity ID (UEI).
(4) Refer to guidance materials on how to access and use the CDFI Fund’s online portal, AMIS.
(5) Create or access an existing account for the Applicant entity in AMIS using the guidance
materials located on the CDFI Fund’s webpage.
(6) Review and update the Applicant’s Employer Identification Number (EIN) on the Organization
Detail Page in AMIS, if needed.
Note: Each CDFI Certification Applicant must have its own valid EIN and be a legal entity at the
time it submits the CDFI Certification Application. The EIN in AMIS must match the
organization’s name and EIN found in SAM.
(7) Review and update the Applicant’s contact information on the organization detail page in
AMIS, if needed. At least one Authorized Representative must be identified in order to submit a
completed CDFI Certification Application. Anyone listed as a contact in the Applicant’s online
account can fill out the CDFI Certification Application. However, only a contact designated as an
Authorized Representative will be able to make submissions.
Note: An Authorized Representative must be a person who is authorized to act and legally
bind on behalf of the Applicant. Consultants cannot be identified as an Authorized
Representative.
(8) Email systems and firewalls should be set to accept messages generated by AMIS. Contact the
AMIS Help Desk via an AMIS Service Request for assistance if needed.
(9) Applicants must provide additional Basic Information for entities subject to the collective review
process in the Applicant’s account in AMIS and/or within the CDFI Certification Application.
Note: Relevant documents not written in English must be translated.
14
(10) Review and update information on Applicant’s Affiliates and entities subject to the collective
review process in AMIS, as needed.
(11) Review the CDFI Fund’s lists of, for the purposes of CDFI Certification, eligible Financial Products,
Financial Services, disregarded and qualified assets/staff time, Targeted Populations, and Target
Market assessment methodologies, as well as the list of ineligible financing practices. Prior to
submitting the Application, Applicants must indicate whether they are requesting an eligibility
determination for any related item it requires or would like to submit to the CDFI Fund for
purposes of CDFI Certification. If any requested similar Financial Product, similar Financial
Service, financing practice, asset/staff time, Targeted Population, or Target Market assessment
methodology is deemed ineligible by the CDFI Fund for the requested purpose, the Applicant is
prohibited from presenting that information in the CDFI Certification Application in the manner
requested. See “Obtaining Determination for Responsible Financing Practices, Similar Financial
Products, Similar Financial Services, Disregarded or Included Assets/Staff Time, Targeted
Populations, and Target Market Assessment Methodologies,p. 17.
(12) Upload transactional data to the TLR collection tool that supports the proposed Target Market
and Accountability criteria using the eligible American Community Survey (ACS) dataset
approved by the CDFI Fund.
Note: This step must be done AFTER responding to the questions related to Obtaining
Determination for Responsible Financing Practices, Similar Financial Products, Similar
Financial Services, Disregarded or Included Assets/Staff Time, Targeted Populations, and
Target Market Assessment Methodologies” and BEFORE beginning the full Application.
(13) If required, create a Customized Investment Area and/or Other-OTP Target Market map(s) using
the guidance materials for CIMS. If an AMIS-created map is not created, or the analysis
demonstrates that the geography is not eligible, the respective Target Market will not be
approved.
(14) If required, create a map using CIMS to demonstrate accountability to certain sources of
Accountability.
(15) The following Application sections will require the Applicant to confirm and/or update
information in the Applicant’s Organization Detail Page in AMIS: Basic Information, Target
Market, and Accountability.
(16) Complete and submit the full CDFI Certification Application in AMIS. Upon submission of the
CDFI Certification Application, the Applicant’s contacts identified in AMIS will receive
notification that the Application has been received.
(17) The Application cannot be reopened for modification by the Applicant after submission in AMIS.
If upon review the CDFI Fund finds any Application that is incomplete or contains inaccurate
information, it will be rejected. The CDFI Fund expects all organizations to fully review
Applications for completeness and accuracy prior to submission. Organizations whose
Applications are rejected for missing or inaccurate information will be required to submit a new
Application.
15
(18) If approved, a CDFI Certification Agreement and a Certified CDFI Logo toolkit will be sent to the
Applicant’s Authorized Representative via email. An Authorized Representative must
electronically review, sign, and return the CDFI Certification Agreement within 30 business days
via AMIS. A copy of the executed Agreement will be available in the AMIS account for future
reference.
A successful Applicant will need to sign a Certification Agreement. When the Applicant signs the
CDFI Certification Agreement: (1) the Certification shall be administered pursuant to the General
Terms and Conditions, and (2) the CDFI Certification shall be subject to further provisions, terms,
conditions, requirements, certifications, and representations that are set forth in additional
schedules that will be attached and become a material part of the agreement.
Note: Upon Certification, certain organizational information about the Applicant and its
activities may be posted on the CDFI Fund’s public website for the purpose of creating a public
list and description of Certified CDFIs. A copy of the CDFI Certification Agreement template can
be found on the CDFI Fund website.
(19) If an Applicant is denied CDFI Certification, a determination letter will be sent to the Applicant’s
Authorized Representative via email. Applicants that receive denials can request a debriefing
through the submission of a Service Request via AMIS. New CDFI Certification Applications can
be submitted with or without a debriefing.
(20) Upon an Applicant’s Certification, the CDFI shall comply with all record retention and access
requirements set forth in the Uniform Requirements at 2 CFR 200.334-338. Public access to
Recipient records shall be maintained in accordance with the Uniform Requirements at 2 CFR
200.337, including access applicable under the Freedom of Information Act (5 U.S.C. § 552)
(FOIA). The CDFI shall maintain all CDFI Certification-related records for a minimum of five years
after submission of the document(s) or record(s) to the CDFI Fund. The CDFI shall maintain
documentation supporting the data reported to the CDFI Fund.
(21) Upon Certification, the CDFI will be required to meet annual reporting requirements through the
submission of an Annual Certification and Data Collection Report (ACR) and TLR, no later than
180 days after its fiscal year end or as requested by the CDFI Fund.
In addition to the above, all Applicants should note the following:
- Applications may be denied for CDFI Certification if they contain inconsistencies between the
Applicant’s name in the Application and required documents.
- Applications that contain incomplete or inaccurate information will be declined for CDFI
Certification without a full review.
- Upon designation as a Certified CDFI, entities must continue to meet all Certification
requirements. CDFI Certification may be revoked if the entity fails to provide documentation
demonstrating it continues to meet CDFI Certification requirements.
- Personally Identifiable Information (PII) is information that if lost, compromised, or disclosed
without authorization could result in substantial harm, embarrassment, inconvenience, or
unfairness to an individual. The protection of PII is extremely important to the CDFI Fund. As
such, the CDFI Fund will not disclose PII information on its website.
16
- With the exception of personally identifiable information, any organizational information or
data collected in AMIS or otherwise provided to the CDFI Fund (e.g., CDFI Certification
Application, Target Market modification request, ACR, TLR, periodic requests for additional
information) may be posted on the CDFI Fund’s public website, shared with other federal
agencies, or accessed via a Freedom of Information Act (FOIA) request.
- The CDFI Certification is conferred on an entity as identified by a specific EIN. The CDFI
Certification cannot be extended to cover entities other than the primary holder of a specific
EIN, such as entities that may share the EIN but that are considered to be disregarded entities
for federal tax purposes, or Affiliates. Neither can the CDFI Certification be transferred to an
entity with a different EIN, including successor entities formed under a new EIN. If a federal EIN
to which a CDFI Certification was connected ceases to exist, the CDFI Certification also ceases to
exist.
- Applicants that are acquired or merge with another entity while the Certification Application
review is in progress will not be reviewed, regardless of whether the Applicant is the surviving
entity; the merger or acquisition is considered a material event. In such cases, the surviving
entity must submit a new Certification Application after the merger or acquisition is
consummated.
Additional Questions and Resources
If you have questions regarding the CDFI Certification Application process, you can contact the CDFI
Fund Office of Certification Policy and Evaluation team by submitting a Service Request in AMIS.
Information regarding the CDFI Certification Application and the Application process can also be
obtained by visiting the CDFI Fund’s CDFI Certification webpage.
Authorized Representative Signature
The Authorized Representative is required to attest to the following terms:
I hereby consent to conducting this transaction by electronic means, and I hereby agree that I have
executed an electronic process that constitutes, and provides the CDFI Fund with, my electronic
signature, which shall be treated as an original signature and as having signed this Application just the
same as a pen-and paper signature; I hereby acknowledge that all information contained in this
Application and any attachments or supplements thereto will be subject to disclosure pursuant to the
FOIA 5 U.S.C. 552 et seq.; I hereby certify that all of the information that the Applicant has provided in
this Application is true, correct, and complete to the best of my information, knowledge, and belief; I
hereby certify that the execution and submission of this Application has been duly authorized by the
governing body of the Applicant; and hereby certify that I am aware that any false, fictitious, or
fraudulent statements or claims may subject me to criminal, civil, or administrative penalties (U.S. Code,
title 218, Section 1001).
By selecting this checkbox, I agree to the terms stated above.
Name: Authorized Representative Name Selected via AMIS
Date: Electronically stamped
17
The following sections include specific guidance, questions, and data points for Applicants to complete the
CDFI Certification Application in AMIS. The Application contains conditional questions that will appear in
AMIS only for those Applicants to which the questions apply, based upon financial institution type and/or
responses to other questions. In this document, which is for illustrative purposes only, such questions are
generally identified and/or appear nested below the questions to which they apply.
OBTAINING DETERMINATION OF RESPONSIBLE FINANCING PRACTICES,
SIMILAR FINANCIAL PRODUCTS, SIMILAR FINANCIAL SERVICES,
DISREGARDED OR INCLUDED MAJOR ASSETS/STAFF TIME, TARGETED
POPULATIONS, AND TARGET MARKET ASSESSMENT METHODOLOGIES
Section
Question or purpose of data field
Response
OD01
Does the Applicant want to propose a similar
Financial Product or similar Financial Services that
are not currently pre-approved?
Yes or No.
If “No,” skip to OD02.
If “Yes”:
OD01.1
Select the proposed activity.
Select one:
- Similar Financial.
Product.
- Similar Financial Service.
OD01.2
Provide the name of the proposed
similar Financial Product/similar
Financial Service.
Enter name.
OD01.3
Provide a description of the proposed
similar Financial Product/similar
Financial Service (e.g., rates, terms,
conditions) and its purpose.
Narrative.
OD01.4
Identify the target borrower, investee,
and/or service recipient.
Narrative.
OD01.5
Describe any protections that ensure
the proposed similar Financial Product
does not harm consumers.
Narrative.
OD01.6
Provide evidence that consumers are
not harmed by the proposed similar
Financial Product (e.g., the rate of
successful repayments under the
original rates, terms, and conditions of
the product).
Narrative.
OD01.7
Provide any additional information
necessary for the CDFI Fund to
consider the request.
Narrative or N/A.
18
Section
Question or purpose of data field
Response
OD01.8
Attach relevant support document(s).
Attachment(s).
If the Applicant requests consideration of multiple similar Financial Products or similar Financial
Services, repeat questions OD01.1 through OD01.8.
OD02
Does the Applicant want to propose an amended
responsible financing practice standards?
Yes or No.
If “No,” skip to OD03.
If “Yes”:
OD02.1
Describe the financing activity.
Narrative.
OD02.2
Identify the current standard the
financing activity does not meet.
Narrative.
OD02.3
Describe how the financing activity
serves a community development
purpose.
Narrative.
OD02.4
Describe any protections that ensure
the financing activity does not harm
consumers and/or conditions under
which the financing activity should be
considered an acceptable community
development activity.
Narrative.
OD02.5
Provide evidence that consumers are
not harmed.
Narrative.
OD02.6
Provide any additional information
necessary for the CDFI Fund to
consider the request.
Narrative.
OD02.7
Attach relevant support document(s).
Attachment(s).
If the Applicant requests amendment of multiple financing practice standards, repeat questions
OD02.1 through OD02.7
OD03
Does the Applicant want to propose major assets
and/or staff time to be disregarded or included for
purposes of the Financing Entity predominance
test?
Yes or No.
If “No,” skip to OD04.
If “Yes”:
OD03.1
Does the Applicant seek to disregard or
include major assets and/or staff time?
Select one:
- Include major assets
and/or staff time.
- Disregard major assets
and/or staff time.
OD03.2
Provide a description of the major
assets and/or staff time to be
disregarded or included.
Narrative.
OD03.3
Enter the dollar amount for the
portion of the balance sheet line
item(s) to be disregarded or included,
and the name of the balance sheet line
item(s).
Enter dollar amount and name
of balance sheet line item.
OD03.4
Enter the average FTE staff time to be
disregarded.
Enter average FTE staff time.
19
Section
Question or purpose of data field
Response
OD03.5
How did the Applicant determine the
amount of the major asset(s) and/or
staff time to be disregarded or
included?
Narrative.
OD03.6
If seeking to disregard any major
asset(s) and/or staff time, provide an
explanation for why the major asset(s)
and/or staff time incorrectly appears
to indicate the Applicant is not
predominately a financing entity.
Narrative.
OD03.7
If seeking to include any major asset(s)
and/or staff time, provide an
explanation for why the major asset(s)
and/or staff time dedicated to this
activity is essential for the Applicant to
conduct its Financial Product and/or
Financial Services activity.
Narrative.
OD03.8
Attach Applicant’s most recently
completed fiscal year balance sheet
and income statement, and current
fiscal year-to-date balance sheet.
Attachment(s).
If the Applicant requests consideration of multiple major assets and/or staff time to be disregarded or
included, repeat questions OD03.1 through OD03.8.
OD04
Does the Applicant want to propose additional
Targeted Population(s)?
Yes or No.
If “No,” skip to OD05.
If “Yes”:
OD04.1
Provide the name of/for the Targeted
Population.
Enter Name.
OD04.2
Provide a description of the Targeted
Population.
Narrative.
OD04.3
Identify the geographic location of the
Targeted Population intended to be
served.
Enter geography.
OD04.4
Unless “national,” enter map name of
geography created in CIMS.
Enter Map Name.
OD04.5
Provide a narrative that demonstrates
that the specific Targeted Population
has significant unmet capital for
Financial Services needs.
Narrative.
OD04.6
Identify whether the Applicant serves
the members of the Targeted
Population directly or indirectly (e.g.,
through borrowers or investees that
serve such members).
Select all that apply:
- Directly.
- Indirectly.
OD04.7
Provide a description of the specific
Narrative.
20
Section
Question or purpose of data field
Response
evidence showing the proposed
Targeted Population has disparities,
controlling for poverty and income
effects, in their access to Financial
Products and Services for the
geographic population service area.
OD04.8
Attach the specific evidence used to
demonstrate support of the need.
Attachment(s).
OD04.9
Provide any additional information
necessary for the CDFI Fund to
consider the request.
Narrative or N/A.
If the Applicant requests consideration of multiple Targeted Populations, repeat questions OD04.1
through OD04.9. For each proposed Targeted Population, the Applicant also must submit a proposed
Target Market assessment methodology for that Targeted Population.
OD05
Does the Applicant want to propose other Target
Market assessment methodologies?
Yes or No.
If responses to OD01, OD02,
OD03, OD04, and OD05 are No,
the Applicant may continue with
the Application process by
completing the Transaction
Level Report.
If “Yes”:
OD05.1
Identify the applicable Target Market
Type.
Select one:
- Investment Area.
- Low-Income Targeted
Population.
- Other Targeted
Population.
OD05.2
Describe the assessment methodology
(including the step-by-step process
used to collect the data, review any
documents, and/or run the model and
process its results.)
Narrative.
OD05.3
Attach any supporting or supplemental
documentation necessary to provide a
full description of the proposed
assessment methodology.
Attachment.
OD05.4
Describe how the proposed
assessment methodology provides
sufficient confidence that a transaction
can be assigned to a specific Target
Market.
Narrative.
OD05.5
If proposing a programmatic proxy,
provide the program’s detailed
eligibility criteria or the step-by-step
Narrative.
21
Section
Question or purpose of data field
Response
process used to compare
programmatic data to CDFI Fund
definitions (e.g., income sources,
income thresholds).
OD05.6
Describe the process for recordkeeping
as well as updating any methodology
dependent on underlying data
changes.
Narrative.
OD05.7
Provide any additional information
necessary for the CDFI Fund to
consider the request.
Narrative.
If the Applicant requests consideration of multiple Target Market assessment methodologies, repeat
questions OD05.1 through OD05.7.
APPLICANT BASIC INFORMATION
The Basic Information section of the CDFI Certification Application collects general information about
the CDFI Certification Applicant and its Affiliates that must be reviewed in connection with CDFI
Certification requirements. Certain information in this section will be auto-populated based on data
from the Applicant’s AMIS account.
To ensure accurate data is auto-populated into the Application’s Basic Information section, Applicant
and Affiliate AMIS accounts must be up to date.
To complete the Basic Information section, the Applicant should
- review auto-populated information in the Basic Information fields for accuracy. If information is
missing or inaccurate, submit all updates and make corrections in the Organization Detail Page
in AMIS prior to submitting the full Application for review. For assistance with technical issues,
submit a Service Request in AMIS.
- complete the unpopulated Basic Information fields.
- attach copies of all required documentation in the Basic Information section of the Application.
Governing leadership member and Executive Staff information collected by the CDFI Fund to report is
not included as evaluation criteria and has no bearing on the CDFI Certification determination.
The Applicant and/or Affiliate names in AMIS and registered with SAM.gov
12
must match those listed in
the Basic Information section, or the Application may be rejected.
Section
Question or purpose of data field
Response
BI01
Applicant Entity Name
[Auto-populated from the
12
Applicants must register with SAM.gov to obtain a UEI and confirm they meet the Legal Entity requirement.
22
Section
Question or purpose of data field
Response
Applicant’s AMIS account.]
BI02
Applicant Financial Institution Type
[Auto-populated from the
Applicant’s AMIS account.]
BI03
Applicant Depository Institution Holding
Company
Yes or No.
BI04
Applicant Minority Depository Institution as
designated by the Federal Deposit Insurance
Corporation (FDIC) or the National Credit Union
Administration (NCUA)
Yes or No.
BI05
Applicant EIN
[Auto-populated from the
Applicant’s AMIS account.]
BI06
Applicant Unique Entity ID
[Auto-populated from Applicant’s
AMIS account.]
BI07
Applicant Date of
Incorporation/Organization/Establishment
[Auto-populated from the
Applicant’s AMIS account.]
BI08
Applicant Fiscal Year End Month
[Auto-populated from the
Applicant’s AMIS account.]
BI09
Applicant Fiscal Year End Day
[Auto-populated from the
Applicant’s AMIS account.]
BI10
Can the Applicant meet the CDFI Certification
requirements based on its own arm’s-length, on-
balance sheet Financial Product and/or direct
Financial Services activity?
Yes or No.
BI10.1
If “No,” identify the CDFI
Certification provision(s) the
Applicant seeks to use that either
enables it to use the Financial
Product or Financial Services activity
of an Affiliate(s) or to use on-
balance sheet Financial Product
activity with an Affiliated Controlling
Certified CDFI to meet the CDFI
Certification requirements.
Select one:
- Applicant is applying for
Certification solely to
participate in the BG
Program and is Controlled
by a Certified CDFI.
- Applicant is a DIHC that
does not engage in its own
direct Financial Product or
Financial Services activity
and is relying on the
activity of an Affiliate(s) to
meet the CDFI Certification
requirements.
BI11
Has the Applicant completed at least one full 12-
month fiscal year since the date of its
incorporation/organization/establishment
documentation was filed with or approved by
the appropriate authorizing agency?
Yes or No.
BI11.1
If “No,” identify the exception(s) to
the CDFI Certification requirement
that 12 full months must have
passed since an entity began its
Select all that apply:
- Applicant seeks to use the
CDFI Certification provision
for Spin-off entities.
23
Section
Question or purpose of data field
Response
financing activity that the Applicant
seeks to use.
- Applicant is a DIHC that
does not engage in its own
direct Financial Product or
Financial Services activity
and is relying on the
activity of an Affiliate(s) to
meet the CDFI Certification
requirements.
BI12
If the Applicant seeks to use a CDFI Certification
provision for entities seeking CDFI Certification
solely for participation in the CDFI Fund’s BG
Program:
Identify the Certified CDFI that Controls the
Applicant.
Select the Certified CDFI Affiliate
from Picklist.
BI13
If the Applicant is a DIHC that does not engage
directly in the provision of Financial Products
and/or Financial Services:
Identify the Affiliate that has completed at least
one full 12-month fiscal year prior to submission
of the CDFI Certification Application.
Select the Affiliate from Picklist.
BI13.1
Affiliate date of incorporation.
[Auto-populated from AMIS.]
BI14
Is the CDFI Certification Applicant an Affiliate of
a DIHC?
Yes or No.
BI15
Is the CDFI Certification Applicant a Subsidiary of
an IDI?
Yes or No.
BI16
Does the Applicant issue stock?
Yes or No.
BI16.1
If “Yes,” attach stock certificate
summary report that indicates
voting securities held.
Attach document(s).
BI17
If the Applicant seeks to use the CDFI Certification provision for Spin-off entities:
BI17.1
Can the Applicant demonstrate that
at least one Financial Product it
currently offers was transferred to
the Applicant by at least one
Affiliate?
Yes or No.
If “No,” the Applicant is not eligible
to use the CDFI Certification
provision for Spin-off entities.
BI17.2
Can the Applicant demonstrate that
at least one of its currently offered,
transferred Financial Products has
been offered by the Applicant
and/or an original entity from which
it received the Financial Product
activity for at least one full fiscal
year prior to submission of this
Application?
Yes or No.
If “No,” the Applicant is not eligible
to use the CDFI Certification
provision for Spin-off entities.
24
Section
Question or purpose of data field
Response
BI17.3
Subsequent to the receipt of any
transferred Financial Products, can
the Applicant demonstrate that it
has closed at least one such
Financial Product using its own
capital?
Yes or No.
If “No,” the Applicant is not eligible
to use the CDFI Certification
provision for Spin-off entities.
BI17.4
Can the Applicant demonstrate that
for either the Applicant, or an
Affiliate from which it received
Financial Product activity, an
acceptable primary mission has been
in place for at least the immediate
six months completed prior to
submission of the CDFI Certification
Application?
Yes or No.
If “No,” the Applicant is not eligible
for CDFI Certification.
BI18
Does the Applicant have a Controlling Entity or
any Affiliate(s) that engage in the provision of
Financial Products or Financial Services?
Yes or No.
BI19
Attach a copy of the Applicant’s signed and
dated board/owner-approved document
(bylaws, operating agreement, partnership
agreement, or similar documentation).
Attach documentation.
BI20
If the Applicant is a non-depository institution,
indicate how governing or managing
board/owner approval of the Applicant’s bylaws,
partnership agreement, or similar document and
the date of approval is evidenced in the attached
documentation.
Select all that apply:
- Statement signed by an
officer(s) of the
governing/managing
board, owner, or
Authorized Representative
that was incorporated into
the document when it was
ratified indicates the
document was approved
by an officer(s) of the
governing/managing
board, owner, or
Authorized Representative.
- Statement signed by
officer(s) of the
governing/managing
board, owner, or
Authorized Representative
that was prepared
separately but references
the document or the
decision was approved by
the board/owner and
25
Section
Question or purpose of data field
Response
specifies the approval date.
- Document evidences filing
with a government agency
responsible for the
registration or oversight of
entities operating within a
certain jurisdiction or
industry.
- Governing body meeting
minutes confirm approval
of the document or the
board/owner’s decision
and the meeting date and a
statement signed by an
Authorized Representative
that was incorporated into
the original preparation of
minutes are true and
accurate.
- Governing body meeting
minutes confirm approval
of the relevant document
or the decision it records
and the meeting date and a
statement validly signed by
an Authorized
Representative(s) that was
prepared separately from
the original minutes, but
clearly references the
version of the minutes
provided, affirms that they
are true and accurate.
- N/A.
BI21
If governing or managing board or owner
approval and/or the date of approval of the
Applicant’s bylaws, partnership agreement, or
similar document is not evidenced within the
relevant document itself:
Attach additional documentation that evidences
approval.
Attach documentation.
BI22
Designate an Authorized Representative for the
CDFI Certification Application.
Select Authorized Representative.
BI23
Designate a Point of Contact for the CDFI
Certification Application.
Select Point of Contact.
26
BASIC INFORMATION BOARD AND EXECUTIVE STAFF DEMOGRAPHIC INFORMATION
Provide the following information about the members of the Applicant’s governing leadership and
Executive Staff.
13
Governing leadership or Executive Staff members who identify as a member of more
than one race and ethnicity may be counted under each race and ethnicity with which they identify.
Section
Question or purpose of data field
Response
BI-DI01
Indicate the total number of governing
leadership members.
Enter number.
BI-DI02
Indicate the total number of governing
leadership members who identify as a member
of a minority
14
population.
Enter number.
BI-DI03
Percentage of governing leadership members
who identify as a member of a minority
population.
[Auto-calculated.]
BI-DI03.1
Indicate the number of governing
leadership members who identify as
Black.
Enter number.
BI-DI03.2
Percentage of governing leadership
members who identify as Black.
[Auto-calculated.]
BI-DI03.3
Indicate the number of governing
leadership members who identify as
Asian.
Enter number.
BI-DI03.4
Percentage of governing leadership
members who identify as Asian.
[Auto-calculated.]
BI-DI03.5
Indicate the number of governing
leadership members who identify as
Native American.
Enter number.
BI-DI03.6
Percentage of governing leadership
members who identify as Native
American.
[Auto-calculated.]
BI-DI03.7
Indicate the number of governing
leadership members who identify as
Native Alaskan.
Enter number.
BI-DI03.8
Percentage of governing leadership
members who identify as Native
Alaskan.
[Auto-calculated.]
BI-DI03.9
Indicate the number of governing
leadership members who identify as
Native Hawaiian.
Enter number.
BI-
DI03.10
Percentage of governing leadership
members who identify as Native
[Auto-calculated.]
13
Executive Staff means the chief executive and all executive officers or senior decision-makers that have a
reporting relationship to the chief executive or the Board of Directors.
14
For purposes of this Application, the CDFI Fund relies on definitions established by the 1997 Office of
Management and Budget (OMB) standards on race and ethnicity.
27
Section
Question or purpose of data field
Response
Hawaiian.
BI-
DI03.11
Indicate the number of governing
leadership members who identify as
Pacific Islander.
Enter number.
BI-
DI03.12
Percentage of governing leadership
members who identify as Pacific
Islander.
[Auto-calculated.]
BI-
DI03.13
Indicate the number of governing
leadership members who identify as
Hispanic.
Enter number.
BI-
DI03.14
Percentage of governing leadership
members who identify as Hispanic.
[Auto-calculated.]
BI-DI04
Indicate the number of governing leadership
members who identify as Non-Hispanic White.
Enter number.
BI-DI05
Percentage of governing leadership members
who identify as Non-Hispanic White.
[Auto-calculated.]
BI-DI06
Indicate the number of governing leadership
members whose race and ethnicity are not
known or who prefer not to say.
Enter number.
BI-DI07
Percentage of governing leadership members
whose race and ethnicity are not known or who
prefer not to say.
[Auto-calculated.]
BI-DI08
Indicate the number of governing leadership
members who identify as female.
Enter number.
BI-DI09
Percentage of governing leadership members
who identify as female.
[Auto-calculated.]
BI-DI10
Indicate the number of governing leadership
members who identify as male.
Enter number.
BI-DI11
Percentage of governing leadership members
who identify as male.
[Auto-calculated.]
BI-DI12
Indicate the number of governing leadership
members who identify as non-binary or other.
Enter number.
BI-DI13
Percentage of governing leadership members
who identify as non-binary or other.
[Auto-calculated.]
BI-DI14
Indicate the total number of Executive Staff.
Enter number.
BI-DI15
Indicate the total number of Executive Staff who
identify as a member of a minority population.
Enter number.
BI-DI16
Percentage of Executive Staff who identify as a
member of a minority population.
[Auto-calculated.]
BI-DI16.1
Indicate the number of Executive
Staff who identify as Black.
Enter number.
BI-DI16.2
Percentage of Executive Staff who
identify as Black.
[Auto-calculated.]
BI-DI16.3
Indicate the number of Executive
Staff who identify as Asian.
Enter number.
BI-DI16.4
Percentage of Executive Staff who
[Auto-calculated.]
28
Section
Question or purpose of data field
Response
identify as Asian.
BI-DI16.5
Indicate the number of Executive
Staff who identify as Native
American.
Enter number.
BI-DI16.6
Percentage of Executive Staff who
identify as Native American.
[Auto-calculated.]
BI-DI16.7
Indicate the number of Executive
Staff who identify as Native Alaskan.
Enter number.
BI-DI16.8
Percentage of Executive Staff who
identify as Native Alaskan.
[Auto-calculated.]
BI-DI16.9
Indicate the number of Executive
Staff who identify as Native
Hawaiian.
Enter number.
BI-
DI16.10
Percentage of Executive Staff who
identify as Native Hawaiian.
[Auto-calculated.]
BI-
DI16.11
Indicate the number of Executive
Staff who identify as Pacific Islander.
Enter number.
BI-
DI16.12
Percentage of Executive Staff who
identify as Pacific Islander.
[Auto-calculated.]
BI-
DI16.13
Indicate the number of Executive
Staff who identify as Hispanic.
Enter number.
BI-
DI16.14
Percentage of Executive Staff who
identify as Hispanic.
[Auto-calculated.]
BI-DI17
Indicate the number of Executive Staff who
identify as Non-Hispanic White.
Enter number.
BI-DI18
Percentage of Executive Staff who identify as
Non-Hispanic White.
[Auto-calculated.]
BI-DI19
Indicate the number of Executive Staff whose
race and ethnicity are not known or who prefer
not to say.
Enter number.
BI-DI20
Percentage of Executive Staff whose race and
ethnicity are not known or who prefer not to
say.
[Auto-calculated.]
BI-DI21
Indicate the number of Executive Staff who
identify as female.
Enter number.
BI-DI22
Percentage of Executive Staff who identify as
female.
[Auto-calculated.]
BI-DI23
Indicate the number of Executive Staff who
identify as male.
Enter number.
BI-DI24
Percentage of Executive Staff who identify as
male.
[Auto-calculated.]
BI-DI25
Indicate the number of Executive Staff who
identify as non-binary or other.
Enter number.
BI-DI26
Percentage of Executive Staff who identify as
non-binary or other.
[Auto-calculated.]
BI-DI27
Indicate the race/ethnicity of the Applicant’s
Select all that apply:
29
Section
Question or purpose of data field
Response
Chief Executive Officer/Executive Director.
- Non-Hispanic White.
- Black.
- Asian.
- Native American.
- Native Alaskan.
- Native Hawaiian.
- Pacific Islander.
- Hispanic.
- Prefer not to say.
BI-DI28
Indicate the gender of the Applicant’s Chief
Executive Officer/Executive Director.
Select one:
- Female.
- Male.
- Non-Binary.
- Other.
BASIC INFORMATION AFFILIATES
CDFI Certification Applicants that have Affiliates subject to the CDFI Certification review, as indicated
below, must identify those Affiliates and present information regarding them in the Affiliates section of
the Application and elsewhere, as noted in the different section instructions.
In order for Affiliate information to auto-populate the CDFI Certification Application where indicated, an
Affiliate record must be created on the Applicant’s AMIS Organization Profile page.
Applicants that are DIHCs, Affiliates of DIHCs, or Subsidiaries of IDIs
If the entity seeking CDFI Certification is a DIHC, an Affiliate of a DIHC, or a Subsidiary of an IDI, it must
identify any Affiliate in its family of entities that meets any of the following criteria for consideration in
connection with the CDFI Certification collective review (even if all such Affiliates are not seeking to
obtain or maintain the CDFI Certification):
- any Affiliate that is a DIHC or an IDI that Controls the Applicant;
- any Affiliate of a DIHC Applicant that the Applicant Controls that directly engages in the
provision of Financial Products and/or Financial Services; or
- any Affiliate that is mutually Controlled with the Applicant by a DIHC or an IDI and that directly
engages in the provision of Financial Products and/or Financial Services.
30
Applicants that are not DIHCs, Affiliates of DIHCs, or Subsidiaries of IDIs
In addition to presenting Affiliates subject to any alternative CDFI Certification provision, a CDFI
Certification Applicant that is not a DIHC, an Affiliate of a DIHC, or a Subsidiary of an IDI must identify
any Affiliate in its family of entities that meets any of the following criteria for consideration in
connection with the primary mission requirements:
- The Affiliate Controls the Applicant, except if the Controlling entity is a tribal government;
- The Affiliate directly engages in Financial Product activity, and the Applicant and the Affiliate are
under the mutual Control of another entity; or
- The Affiliate directly engages in Financial Product activity, and the Applicant Controls the
Affiliate.
Applicants seeking Certification solely for participating in the CDFI Fund’s Bond Guarantee Program (BG
Program)
Applicants seeking to use the CDFI Certification provision for entities seeking Certification solely for
participating in the CDFI Fund’s BG Program must, in addition to presenting Affiliates subject to other
CDFI Certification requirements, present information on their Controlling Certified CDFI(s).
Spin-off Entities
Applicants seeking to use the CDFI Certification provision for Spin-off entities must identify and present
for review the original entity(ies) from which they received spun-off Financial Product or Financial
Services activity.
Section
Question or purpose of data field
Response
BI-A01
Affiliate Entity Name
Identify Affiliate.
BI-A02
Affiliate EIN
[Auto-populated from the
Applicant’s AMIS account.]
BI-A03
Affiliate Date of
Incorporation/Organization/Establishment
[Auto-populated from the
Applicant’s AMIS account.]
BI-A04
Is the Affiliate a Certified CDFI?
Yes or No.
If “Yes”:
BI-A04.1
Does the Applicant seek to use
the CDFI Certification provision
for BG Program participation
solely to participate in the CDFI
Fund’s BG Program?
Yes or No.
BI-A04.2
Does the Affiliate Control the
Applicant?
Yes or No.
BI-A05
Is the Affiliate a Certified Community
Development Entity (CDE)?
Yes or No.
BI-A06
Is the Affiliate’s sole line of business the
administration of another federal financing
program(s)?
Yes or No.
If “Yes”:
31
Section
Question or purpose of data field
Response
BI-A06.1
Identify the other federal
financing program(s).
Enter name(s).
BI-A07
If the Applicant is a DIHC or an Affiliate of a
DIHC:
Identify the relationship between the Applicant
and the Affiliate.
Select one:
- The Affiliate is a DIHC
that Controls the
Applicant.
- The Affiliate directly
engages in Financial
Product and/or Financial
Services activity, and it
and the Applicant are
under the mutual Control
of a DIHC.
- The Affiliate directly
engages in Financial
Product and/or Financial
Services activity, and the
Applicant is a DIHC that
Controls the Affiliate.
BI-A08
If the Applicant is a Subsidiary of an IDI:
Identify the relationship between the Applicant
and the Affiliate.
Select one:
- The Affiliate is an IDI that
Controls the Applicant.
- The Affiliate directly
engages in Financial
Product and/or Financial
Services activity, and the
Affiliate and the Applicant
are under the mutual
Control of an IDI.
BI-A09
If the Applicant is not a DIHC, an Affiliate of a
DIHC, or a Subsidiary of an IDI:
Identify the relationship between the Applicant
and the Affiliate.
Select one:
- The Affiliate Controls the
Applicant (do not include
tribal governments).
- The Affiliate is Controlled
by the Applicant and
directly engages in the
provision of Financial
Products and/or Financial
Services.
- The Affiliate and
Applicant are mutually
Controlled by another
entity, and the Affiliate
directly engages in the
provision of Financial
Products and/or Financial
Services.
32
Section
Question or purpose of data field
Response
BI-A10
If the Applicant seeks to use the CDFI
Certification provision for Spin-offs in order to
meet the Financing Entity and Target Market
criteria:
Identify the relationship between the Applicant
and the original entity from which it received
Spin-off Financial Product activity.
Select one:
- The entity Controlled the
Applicant at the time it
transferred Financial
Product activity to the
Applicant.
- The entity was Controlled
by the Applicant at the
time it transferred
Financial Product activity
to the Applicant.
- The entity and Applicant
were mutually Controlled
by another entity at the
time it transferred
Financial Product activity
to the Applicant.
BI-A11
If the Applicant relies on the Affiliate to provide
Development Services and the Affiliate
relationship was not identified in any of the
other Affiliate relationship data fields:
Identify the relationship between the Applicant
and the Affiliate.
Select one:
- The Affiliate currently
Controls the Applicant.
- The Affiliate is currently
Controlled by the
Applicant.
- The Affiliate and
Applicant are currently
mutually Controlled by
another entity.
BI-A12
If the Applicant seeks to use the CDFI
Certification provision for BG Program
participation, solely to participate in the CDFI
Fund’s BG Program and such Affiliate is a
Certified CDFI that Controls the Applicant:
What is the earliest date that the Affiliate can
demonstrate that it closed an arm’s-length, on-
balance sheet Financial Product or completed a
Financial Services transaction?
Enter date.
BI-A13
If the Applicant is a DIHC that is relying on the
activity of its Affiliate(s) to meet the Target
Market requirements:
Is this Affiliate a depository institution that
currently provides Financial Services?
Yes or No.
BI-A14
If the Applicant seeks to use the CDFI
Certification provision for Spin-off entities and
the Applicant received Spin-off Financial Product
Yes or No.
If “No,” the Applicant is not
33
Section
Question or purpose of data field
Response
activity from this entity:
Is the Applicant currently offering at least one
arm’s-length, on-balance sheet Financial Product
that was spun off by the original entity?
eligible to use the special CDFI
Certification provision for Spin-off
entities.
If “Yes”:
BI-A14.1
Identify at least one Financial
Product that was spun off to the
Applicant by the original entity.
Enter name.
BI-A14.2
Provide the earliest date the
original entity can demonstrate it
closed a Spin-off Financial Product
currently offered by the
Applicant.
Enter date.
If the Applicant has multiple Affiliates that need to be reviewed in connection with one or more of
the CDFI Certification requirements, repeat the Affiliate Basic Information data entry for each
applicable Affiliate.
APPLICANT FINANCIAL PRODUCTS AND FINANCIAL SERVICES BASIC INFORMATION
To be eligible for CDFI Certification, an entity must provide at least one Financial Product or be eligible
to rely on the Financial Product activity of an Affiliate(s).
Financial Services can be used in combination with Financial Products to meet the CDFI Certification
requirements by depository institutions (i.e., bank/thrifts, credit unions, or bank/thrift holding
companies) only.
BASIC INFORMATION FINANCIAL PRODUCT INFORMATION APPLICANT
Section
Question or purpose of data field
Response
BI-FP01
Is the Applicant a DIHC that does not directly
offer any arm’s-length, on-balance sheet
Financial Products?
Yes or No.
BI-FP02
Is the Applicant seeking to use the CDFI
Certification provision that allows on-balance
sheet Financial Product activity that is not
arm’s-length to meet the CDFI Certification
requirements solely for the purposes of
participating in the BG Program?
Yes or No.
If “Yes,” the Applicant will skip question
BI-FP09.
BI-FP03
Identify the Financial Product transaction
types offered directly by the Applicant.
Select all that apply:
- Loans.
- Lines of credit.
- Credit Cards.
- Equity Investments.
- Debt with Equity features.
- Loan guarantees.
- Loans purchased from Certified
34
Section
Question or purpose of data field
Response
CDFIs.
- Loans directed to the
Applicant’s proposed Target
Market purchased from entities
without CDFI Certification.
- Other similar financing (pre-
approved by the CDFI Fund).
BI-FP04
If “Other similar financing was selected as a
Financial Product transaction type:
Has the “Other similar financing been pre-
approved as an eligible new Financial Product
category by the CDFI Fund?
Yes or No.
If “No,” the Applicant cannot include
the financing as an eligible Financial
Product.
If “Yes”:
BI-FP04.1
Provide the name of the new
Financial Product category
exactly as it appears in the
approval letter from the CDFI
Fund.
Enter name.
BI-FP05
For each of the Financial Product types offered
directly by the Applicant, select the available
Financial Product purpose(s).
Select all that apply:
- Home purchase.
- Home improvement.
- Real estate Construction/
Permanent/Acquisition w/o
RehabilitationCommercial.
- Real estate Construction
HousingMulti-Family.
- Real estate Construction
HousingSingle Family.
- Real estate Rehabilitation
Commercial.
- Real estate Rehabilitation
HousingMulti-Family.
- Real estate Rehabilitation
HousingSingle-Family.
- Consumer.
- Non-real estate business.
- Non-Real Estate
Microenterprise.
- Climate-Centered Finance.
- Other (e.g., Intermediary
support other Certified CDFIs).
BI-FP06
If “Other” was selected for Financial Product
Purpose, describe the purpose.
Provide description.
BI-FP07
Are the selected Financial Product transaction
types offered directly by the Applicant?
Yes or No.
35
Section
Question or purpose of data field
Response
If “No,” only a DIHC Applicant may
include the Financial Products as eligible
Financial Products.
BI-FP08
Are the selected Financial Product transaction
types on-balance sheet for the Applicant?
Yes or No.
If “No,” only a DIHC Applicant can
include the Financial Products as eligible
Financial Products.
BI-FP09
Are the selected Financial Product transaction
types offered by the Applicant at arm’s-
length?
Yes or No.
If “No,” the Applicant cannot include
the Financial Products as eligible
Financial Products.
If BI-FP02 response is “Yes,” the
Applicant will skip this question.
BI-FP10
What is the earliest date that the Applicant
can demonstrate that it closed an arm’s-
length, on-balance sheet transaction with its
Financial Product?
Enter date.
BI-FP11
Does the Applicant report all consumer
Financial Product transactions to a major
credit bureau?
Yes, No, or N/A (i.e., does not offer
consumer loan products).
BASIC INFORMATION FINANCIAL SERVICES INFORMATION APPLICANT
Section
Question or purpose of data field
Response
BI-FS01
Does the Applicant offer Financial Services?
Yes or No.
BI-FS02
If the Applicant is a DIHC, does it directly offer
any Financial Services?
Yes or No.
BI-FS03
Identify each of the Financial Services
categories offered directly by the Applicant.
Select all that apply:
- Savings and Share
Accounts.
- Checking Accounts.
- Certificates of Deposit.
- Money Market Accounts.
- Check Cashing.
BI-FS04
Provide the earliest date a Financial Services
transaction was completed.
Enter date.
BASIC INFORMATION FINANCIAL PRODUCT INFORMATION AFFILIATE
The Applicant must enter Financial Product information for any Affiliate subject to review in connection
with any of the CDFI Certification requirements.
36
BASIC INFORMATION FINANCIAL SERVICES INFORMATION AFFILIATE
The Applicant must enter Financial Services information for any Affiliate that is subject to review in
connection with any of the CDFI Certification requirements.
LEGAL ENTITY
To be a Certified CDFI, the Applicant must be duly organized and operating under the laws of the State
or jurisdiction in which it is incorporated or established as of the date the Application is submitted. The
Applicant must also have a valid EIN.
The CDFI Fund requires all CDFI Certification Applicants and entities subject to the collective review
process to register with the U.S. federal government’s System for Award Management (SAM) to
demonstrate that it is a legal entity. SAM will provide each registrant with a Unique Entity ID (UEI) that
must be provided in the organization’s profile page in AMIS.
To complete the Legal Entity section of the Application, Applicants will
- register with SAM.gov to obtain a UEI; and
- review auto-populated information in the Legal Entity fields for accuracy. If information is
missing or inaccurate, submit all updates and make corrections in the Organization Detail Page
in AMIS prior to submitting the full Application for review. For assistance with technical issues,
submit a Service Request in AMIS.
The Applicant and/or Affiliate names in AMIS and SAM should match those listed in the Basic
Information section. If not, the Application will be rejected.
A regulated financial institution that does not have a charter issued by the appropriate federal
banking agency or State agency cannot apply for CDFI Certification.
Section
Question or purpose of data field
Response
LE01
Applicant EIN.
[Auto-populated.]
LE02
Applicant Unique Entity ID.
[Auto-populated.]
LE03
Date of
Incorporation/Organization/Establishment.
[Auto-populated.]
LE04
Applicant Institution Type.
[Auto-populated.]
LE05
Applicant Federal Regulator.
[Auto-populated.]
LE06
Applicant Charter Number.
[Auto-populated.]
LE07
Applicant FDIC Insurance Certificate Number.
[Auto-populated.]
LE08
Applicant RSSID Number.
[Auto-populated.]
LE09
Applicant State or Other Regulator.
[Auto-populated.]
LE10
If the Applicant is a depository institution,
identify the Applicant’s insurer.
Select one:
- FDIC.
- NCUA.
- State Regulator.
37
Section
Question or purpose of data field
Response
- Other.
- None.
- N/A.
Applicants other than those
insured by the FDIC, NCUA, or a
State Regulator must complete the
Financing Entity section of the
Application.
LE11
If the Applicant seeks to use the CDFI
Certification provision solely for participation in
the BG Program:
Attach the operating agreement between the
Applicant and a Controlling Certified CDFI that
includes management and ownership provisions.
The operating agreement will be evaluated to
ensure it is in a form and substance acceptable
to the CDFI Fund per 12 CFR 1805.201(b)(2)(C)(ii-
iii).
Attach operating agreement.
PRIMARY MISSION
A Certified CDFI shall have a primary mission of promoting community development.
In determining whether an entity has a primary mission of promoting community development, the CDFI
Fund will consider whether the activities of the Applicant (and of certain Affiliates) are, per regulation,
15
purposefully directed toward improving the social and/or economic conditions of underserved people
16
and/or residents of economically distressed communities. As part of its assessment, the CDFI Fund will
consider whether the entity has a community development mission and strategy and whether the entity
meets the CDFI Fund’s standards for responsible financing practices.
DIHCs, Affiliates of DIHCs, and Subsidiaries of IDIs
An Applicant that is a DIHC, an Affiliate of a DIHC, or a Subsidiary of an IDI, including Subsidiaries of a
tribal government, is required by statute to meet the CDFI Certification requirements based on a
collective review of its family of entities. Such entities must demonstrate that any Affiliate that meets
any of the following criteria also meets the primary mission requirements:
15
12 CFR § 1805.201(b)(1).
16
Includes Low-Income persons and/or, as approved by the CDFI Fund, other persons who lack adequate access to
capital and/or Financial Services.
38
- The Affiliate is a DIHC or an IDI that Controls the Applicant.
- The Affiliate is Controlled by the Applicant, and the Applicant is a DIHC.
- The Applicant and the Affiliate are mutually Controlled by a DIHC or an IDI, and the Affiliate
directly engages in the provision of Financial Products and/or Financial Services.
Applicants other than DIHCs, Affiliates of DIHCs, and Subsidiaries of IDIs
Applicants that are not a DIHC, Affiliate of a DIHC, or Subsidiary of an IDI must demonstrate that any
Affiliate in its family of entities that meets any of the following criteria each individually meet the
primary mission requirements:
- The Affiliate Controls the Applicant, except if the Controlling entity is a tribal government.
- The Affiliate engages in the provision of Financial Products and/or Financial Services.
Affiliates listed in the Basic Information section that are separately Certified CDFIs or Community
Development Entities (CDEs), as well as Affiliates whose sole activity is the participation in other federal
financing programs, are presumed to meet the CDFI Certification primary mission requirements and are
exempt from completing this section of the Application.
Spin-offs
Any Applicant that seeks to use the CDFI Certification provision for Spin-off entities must demonstrate
that the Applicant and/or original entity has had an acceptable primary mission of community
development in place for at least six full months immediately prior to submission of the CDFI
Certification Application. Spin-offs also must demonstrate that all entities subject to the collective
review process individually meet all of the primary mission criteria.
DOCUMENTING MISSION
The Applicant must be able to demonstrate that it has had a primary mission of promoting community
development in place for at least the six full months immediately prior to submission of the Application.
Applicants also must demonstrate that any relevant Affiliate has a mission currently in place that
supports and/or is consistent with that of the Applicant’s.
To demonstrate that it has a primary mission of promoting community development, an entity must
present documentation that the Applicant’s mission has been approved by the Applicant’s board
governance or owner. Examples of promoting community development include providing responsible
Financial Products and Financial Services to Low-Income borrowers, Other Targeted Populations, and/or
residents of and businesses located in economically distressed communities, as well as efforts to
promote affordable housing, community-serving facilities, economic development in economically
distressed communities, and/or supporting the provision of community services such as child care,
education, health care, social services, or workforce development.
COMMUNITY DEVELOPMENT STRATEGY
The Applicant must be able to demonstrate that it has a community development strategy such that the
Financial Products and/or Financial Services it offers support a community development objective(s) for
underserved populations and/or residents of economically distressed communities. To demonstrate that
39
it has an acceptable community development strategy, the Applicant must submit a board-approved (or,
for institutions without a board of directors, owner-approved) strategic plan that shows evidence of
such a community development strategy. If the Applicant does not have a strategic plan, it must submit
a board- or owner-approved narrative that describes the community development outcomes that the
Applicant believes will result from the provision of its Financial Products and Financial Services, and how
those Financial Products and Financial Services lead to those outcomes.
As evidence of a community development strategy, the Applicant’s strategic plan or narrative should
include references to
- the Applicant’s geographic and/or demographic Target Market and the needs of and/or
opportunities in the Target Market, which might include quantitative data or qualitative input
from members of that Target Market;
- one or more community development goals and objectives and/or how the Applicant intends to
meet those goals and objectives; and
- how the Applicant’s Financial Products and Financial Services, Development Services, and/or
other activities are expected to improve the social and/or economic conditions of that Target
Market.
A separate community development strategy is not required for Affiliates, but an Applicant must
describe how the activities of any Affiliate(s) support and/or are consistent with the community
development mission of the Applicant.
RESPONSIBLE FINANCING PRACTICES
To meet the CDFI Certification standards for responsible financing practices, an Applicant (and its
Affiliates) should provide Financial Products and Financial Services that are consistent with promoting
community development. Such Financial Products should not harm consumers, be affordable, be
originated based upon an assessment of whether a borrower can pay back a loan, and have terms and
conditions that are transparent and understandable to the borrower. CDFIs should practice
transparency, fair collections, and compliance with federal, State, and local laws and regulations. The
CDFI Fund also considers the safety, affordability, and transparency of an Applicant’s Financial Services
to be an important aspect of the Applicant’s commitment to a community development mission.
The Application asks a series of questions related to the Applicant’s (and its Affiliates’) Financial
Products and Financial Services to determine whether they are consistent with these principles and with
a community development mission. These questions apply to all Financial Products and Financial
Services offered by an Applicant and its Affiliates, not only those directed to one or more of the
Applicant’s Target Markets.
Ineligible Practices
Any Applicant that either directly or through an Affiliate engages in the following practices is ineligible
for CDFI Certification:
- originates or otherwise offers loans that exceed the interest limits that apply to non-depository
institutions in the state where the borrower resides;
40
- offers consumer loans that allow for an APR in excess of 36%
17
and
o the loans have an annual default rate over 5%;
o the loans in question include a leveraged payment mechanism;
o any such loans of $1,000 or less have repayment timeframes that exceed 12 months;
o for a period of 12 full months after the issuance of any such loan, the Applicant does not
waive any upfront fees for any refinance or new loan issued to the same borrower;
o any fees associated with such installment loans are not spread evenly over the life of the
loan or pro rata refundable in the event of early repayment (including through a
refinance); or
o all payments on any such installment loans are not substantially equal and do not
amortize smoothly to a zero balance by the end of the loan term;
- offers covered
18
single-family, owner-occupied, residential mortgage loan products secured by a
non-subordinate lien
o for which the Applicant fails to verify the income or assets of the borrower;
o that include negative amortization or interest-only payments;
o that charge upfront points and fees to the consumer in excess of 3%, or in excess of the
Qualified Mortgage limits for smaller loans; or
o that are underwritten at less than the maximum rate in the first five years;
- sells its charged-off consumer or small business debt to debt buyers;
- has a current Community Reinvestment Act rating below Satisfactory;
- uses its Equity Investment Financial Products to gain Control over an investee (except if the
Applicant must save a business through ownership as a last resort for a limited period of time);
or
- leverages, for its own benefit, the assets of any of its active equity investees.
17
If a Certified CDFI that has attested it does not offer consumer or small business loans that allow for an APR in
excess of 36% later determines that a transaction’s APR exceeds 36%, the CDFI may remain eligible for CDFI
Certification without having to meet the additional conditions for consumer loans above 36% provided the CDFI,
within 210 days after consummation, makes any necessary rate correction and pays to the consumer the dollar
amount by which the transactions total points and fees and/or interest payments caused the transaction to
exceed a 36% APR.
18
For purposes of question PM19 on an Applicant’s mortgage loan products, a covered mortgage loan product is
limited to a consumer credit transaction that is secured by a lien on a single-family, owner-occupied residence
other than
(i) transactions secured by a subordinate lien;
(ii) a reverse mortgage subject to 12 CFR 1026.33;
(iii) a temporary or “bridge” loan with a term of 12 months or less, such as a loan to finance the purchase of a
new dwelling where the consumer plans to sell a current dwelling within 12 months or a loan to finance
the initial construction of a dwelling;
(iv) a construction phase of 12 months or less of a construction-to-permanent loan;
(v) an extension of credit made pursuant to a program administered by a Housing Finance Agency, as defined
under 24 CFR 266.5;
(vi) an extension of credit made pursuant to a program administered by the U.S. Department of Housing and
Urban Development, the U.S. Department of Veterans Affairs, or the U.S. Department of Agriculture;
(vii) a transaction that does not require payment of interest;
(viii) a transaction made for the purpose of foreclosure avoidance or prevention; or
(ix) for loans with interest-only payments and loans with balloon payments, a transaction with a payment
schedule that is adjusted to the seasonal or irregular income of the consumer.
41
For purposes of determining the highest allowable APR for any of an Applicant’s consumer loan
products, the CDFI Fund requires Applicants use the methodology prescribed in 32 CFR § 232.4 of the
Military Lending Act (referred to as the Military Annual Percentage Rate [MAPR]), regardless of covered
borrower status.
19
Practices Requiring Further Explanation
Unless an acceptable explanation of how the below practices have a community development purpose
consistent with the principles described in this section is provided, an Applicant may also be determined
to be ineligible for CDFI Certification for engaging in the following activities:
- does not evaluate the ability of certain mortgage, consumer, or small business borrowers to pay
back a loan;
- offers small business
20
loans that allow for an APR in excess of 36%;
- offers covered mortgages with balloon payments or that carry an original maximum term longer
than 30 years (unless offered through a government program); or
- charges excessive overdraft or nonsufficient funds (NSF) fees or has practices that are related to
these fees that are harmful.
For purposes of determining the highest allowable APR for any of an Applicant’s small business loan
products, Applicants must use the standard Truth in Lending Act (TILA) methodology in 12 CFR Part 1026
(Regulation Z).
Other questions provide Applicants an opportunity to further demonstrate community development
intent, such as how they assist struggling borrowers. Depository institution Applicants must also provide
information on checking or share account features they offer.
Beginning January 1, 2026, new Applicants that offer small business loan products that do not disclose in
writing the periodic payment due, the total amount to be repaid over the life of the loan, the total
finance charges over the life of the loan, and APR of the loan will be ineligible for CDFI Certification.
Certified CDFIs that offer small business loan products will be required to attest in their ACR to making
such disclosures no later than October 1, 2026, in order to maintain their Certification.
Obtaining Determination to Amend the Standards for Responsible Financing Practices
The current standards for responsible financing practices allow for certain circumstances under which an
otherwise disqualifying practice might serve an acceptable community development purpose. For
example, Applicants that offer consumer loans that exceed an APR of 36% may still be determined
19
The CDFI Fund does not require that an Applicant calculate, disclose, or report the MAPR of its consumer loan
products unless otherwise required by statute or regulation to do so. Applicants must attest as to whether or not
any of its consumer loan products “allow for an MAPR in excess of 36% MAPR. If so, Applicants must respond to a
set of secondary questions about the loan product’s characteristics. For additional guidance on calculating the
MAPR, see the Consumer Financial Protection Bureau’s (CFPB) Military Lending Act (MLA), Interagency
Examination Procedures2015 Amendments, Terms of Consumer Credit Extended to Covered Borrowers
(Calculation of MAPR), 32 CFR 232.4, pp. 6-9.
20
For purposes of CDFI Certification, small business has the same meaning as the term “small business concern”
in 15 U.S.C. 632(a), as implemented in 13 CFR 121.101 through 121.107. Notwithstanding the size standards set
forth in 13 CFR 121.201, for purposes of this subpart, a business is a small business if its gross annual revenue, as
defined in § 1002.107(a)(14), for its preceding fiscal year is $5 million or less.
42
eligible for Certification if certain conditions are met, such as a default rate no greater than 5%, limits on
fees to refinance the loan, or substantially equal loan payments that amortize to a zero balance.
Similarly, certain otherwise disqualifying residential real estate mortgage loan characteristics are
allowable for the purposes of CDFI Certification if the Applicant meets additional criteria.
Applicants seeking to engage in financing activities that do not currently meet the standards for
responsible financing practices of the primary mission test may seek amendment to the standards to
allow for additional activity that serves a community development purpose. To do so, Applicants must
provide the following information for the CDFI Fund’s consideration in advance of an Application
submission:
- description of the financing activity;
- current standard that the financing activity does not meet;
- reasons the Applicant believes the financing activity serves a community development purpose;
- protections that ensure the financing activity does not harm consumers;
- evidence that consumers are not harmed (e.g., if discussing a Financial Product characteristic,
the rate of successful repayment under the original rates, terms, and conditions of the Financial
Product);
- conditions or parameters under which the financing activity should be considered an acceptable
community development activity (e.g., limits on rates charged, purpose, borrower
characteristics); and
- any additional relevant information.
The CDFI Fund will not approve individual exceptions to the primary mission test, and any amendment
to the standards for responsible financing practices will be made available to all CDFIs and future
Applicants.
PRIMARY MISSION APPLICANT
Section
Question or purpose of data field
Response
PM01
Indicate the type(s) of document(s)
presented as evidence of the Applicant’s
current primary mission of promoting
community development (or, for Affiliates,
a mission that supports and/or is
consistent with the community
development mission of the Applicant).
Select all that apply:
- Legal Entity documents.
- Bylaws.
- Governing or managing board
resolution.
- Owner resolution/directive.
PM02
Attach all document(s) needed to evidence
the Applicant’s
Current primary mission of
promoting community
development (or, for Affiliates, a
mission that supports and/or is
consistent with the community
development mission of the
Applicant);
Governing or managing board or
owner approval of the current
mission; and
Attach all documents.
43
Section
Question or purpose of data field
Response
Date the current mission went
into effect.
PM03
Indicate how the document(s)
demonstrate governing or managing board
or owner approval of the Applicant’s
current mission documentation.
Select all that apply:
- The document(s) is signed by an
officer(s) of the governing leadership.
- The document(s) is supplemented by
official governing leadership meeting
minutes.
- The document(s) is supplemented by
a statement that confirms approval
of the document(s) by the governing
or managing board or owner, and is
signed by an officer(s) of the
governing or managing board, owner,
or Authorized Representative.
PM04
Indicate how the document(s)
demonstrates the date the current mission
went into effect.
Select all that apply:
- The document(s) shows the date it
was adopted via the date it was
signed.
- The document(s) is supplemented by
official governing leadership meeting
minutes that clearly indicate the date
of the meeting at which the
document(s) was adopted.
- The document(s) is supplemented by
a statement that clearly indicates the
date the document(s) was approved
by the governing or managing board
or owner.
PM05
Applicant’s current mission as stated in the
attached mission documentation.
Enter current mission.
PM06
Page number(s) in the attached mission
documentation where the Applicant’s
current mission is articulated.
Enter page number(s).
PM07
Enter the date that the Applicant’s current
mission was formally approved.
Enter date.
PM08
Date by which an appropriate primary
mission must have been in place.
[Auto-populated.]
PM09
Is the date by which an appropriate
primary mission was formally approved
less than six months?
Yes or No.
If Yes, the date the Applicant’s current mission was formally approved is less than six full
months prior to the submission of the CDFI Certification Application:
PM09.1
Indicate the type(s) of
document(s) presented as
evidence that the Applicant
Select all that apply:
- Legal Entity documents.
- Bylaws.
44
Section
Question or purpose of data field
Response
had an immediate prior
primary mission of promoting
community development.
- Governing or managing board
resolution.
- Owner resolution/directive.
PM09.2
Attach all document(s) needed
to evidence the Applicant’s
Immediate prior
primary mission of
promoting community
development;
Governing or
managing board or
owner approval of the
immediate prior
mission; and
Date when the
immediate prior
mission went into
effect.
Attach document(s).
PM09.3
Indicate how the document(s)
demonstrates governing or
managing board or owner
approval of the Applicant’s
immediate prior mission
documentation.
Select all that apply:
- The document(s) is signed by an
officer(s) of the governing or
managing board or the owner.
- The document(s) is supplemented by
official governing leadership meeting
minutes for the meeting at which the
document(s) was adopted, are signed
by an officer(s) of the
governing/managing board, and
clearly indicate approval of the
document(s) by the board.
- The document(s) is supplemented by
a statement that confirms approval
of the document(s) by the governing
or managing board or owner and is
signed by an officer(s) of the
governing or managing board, owner,
or Authorized Representative.
PM09.4
Indicate how the document(s)
demonstrates the date the
immediate prior mission went
into effect.
Select all that apply:
- The document(s) shows the date it
was adopted via the date it was
signed.
- The document(s) is supplemented by
official governing leadership meeting
minutes that clearly indicate the date
of the meeting at which the
document(s) was adopted.
45
Section
Question or purpose of data field
Response
- The document(s) is supplemented by
a statement that clearly indicates the
date the document(s) was approved
by the governing or managing board
or owner.
PM09.5
Enter the Applicant’s
immediate prior mission
exactly as stated in the
attached mission
documentation.
Enter mission statement(s).
PM09.6
For each type of document
presented as evidence of the
Applicant’s immediate prior
mission, enter the page
number(s) in that document
where the immediate prior
mission is articulated.
[The type(s) of document(s) presented as
evidence of current mission may be auto-
populated based on information entered in
PM09.1.]
Enter page number(s).
PM09.7
Enter the date that the
Applicant’s immediate prior
mission was formally approved
by its governing or managing
board or owner.
Enter date.
If the date the Applicant’s most recent prior mission is still less than six complete, full
months prior to the submission of the CDFI Certification Application, repeat the prior
mission documentation questions, as needed, until a full six-months timeframe has been
provided.
PRIMARY MISSION APPLICANT COMMUNITY DEVELOPMENT STRATEGY
PM10
What are the Applicant’s community
development objective(s) that address the
social and/or economic conditions of
underserved people and/or residents of
economically distressed communities?
Select all that apply:
- Promote housing opportunity.
- Promote financial access (e.g., access
to capital in persistent-poverty
communities).
- Promote economic development.
- Promote the development of
Community Facilities.
21
- Promote infrastructure development.
- Promote the availability of
community services (such as child
care, education, health care, social
services, workforce development).
- Promote community revitalization.
- Promote the availability of consumer
products/services.
21
Community Facility means a facility where health care, child care, educational, cultural, or social services are
provided.
46
Section
Question or purpose of data field
Response
- Promote the closure of the racial
wealth gap.
- Promote the creation of quality jobs.
- Promote business development.
- Promote increased energy, water,
and/or location efficiency.
- Promote financial inclusion and
access to affordable Financial
Services, particularly for the un- and
underbanked and/or in banking
deserts (depository institutions only).
- Other.
PM10.1
If Other, describe the
objective and explain why it
can be considered a
community development
objective.
Provide explanation.
PM11
For each community development
objective selected in question PM09,
identify the type of goal(s) supported by
the Financial Product(s) in which the
Applicant engages.
[A list of the Applicant’s community
development objectives will be auto-
populated based on information entered in
PM10.]
Select all that apply:
- Business development.
- Asset/wealth building.
- Homeless/transitional
housing/services.
- Senior housing/services.
- Community Facilities development/
improvements.
- Special needs housing/services.
- Accessibility modifications.
- Affordable housing.
- Job creation/retention.
- Charter school development.
- Community health care centers
development.
- Commercial real estate development.
- Climate resilience.
- Reduced poverty and/or inequality.
- Credit-building.
- Financial stability.
- Other.
PM11.1
If Other, describe.
Provide description.
PM12
Does the Applicant have a board- or
owner-approved strategic plan that
Yes or No.
47
Section
Question or purpose of data field
Response
provides evidence of a community
development strategy?
If “Yes”:
PM12.1
Indicate how the document(s)
demonstrate governing board
or owner approval of the
Applicant’s strategic plan that
provides evidence of a
community development
strategy.
Select all that apply:
- The document(s) shows the date it
was adopted via the date it was
signed.
- The document(s) is supplemented by
official governing leadership meeting
minutes that clearly indicate the date
of the meeting at which the
document(s) was adopted.
- The document(s) is supplemented by
a statement that clearly indicates the
date the document(s) was approved
by the governing or managing board
or owner.
PM12.2
Attach board- or owner-
approved strategic plan that
provides evidence of a
community development
strategy.
Attach document(s).
PM12.3
Identify the page number(s)
from the attached
document(s) where the
community development
strategy is articulated.
Enter page number(s).
If No (i.e., if the Applicant does not have
a board- or owner-approved strategic
plan, or if that strategic plan does not
clearly evidence a community
development strategy):
PM12.4
Attach a brief board- or
owner-approved narrative that
describes the community
development outcomes that
the Applicant believes will
result from the provision of its
Financial Products and
Financial Services, and how
those Financial Products and
Financial Services lead to
those outcomes.
Attach narrative.
PM12.5
Indicate how the document(s)
demonstrate governing board
or owner approval of the
Select all that apply:
- The document(s) shows the date it
was adopted via the date it was
48
Section
Question or purpose of data field
Response
Applicant’s community
development outcomes
narrative.
signed.
- The document(s) is supplemented by
official governing leadership meeting
minutes that clearly indicate the date
of the meeting at which the
document(s) was adopted.
- The document(s) is supplemented by
a statement that clearly indicates the
date the document(s) was approved
by the governing or managing board
or owner.
PRIMARY MISSION APPLICANT Responsible Financing Practices
PM13
Has the CDFI Fund provided the Applicant
with documentation of any amended
standards for responsible financing
practices applicable to the Applicant’s own
financing practices for the purpose of CDFI
Certification?
Yes, No, or N/A.
Questions PM14 through PM22 will be asked of Applicants that offer loan products (including credit
cards or purchased loans) only.
PM14
Do the Applicant’s underwriting
standards for each of its covered
mortgage, consumer, and/or small
business loan products include an
assessment of the borrower’s ability to
pay back the loan according to the terms
of the loan, meet any of the borrower’s
other major financial obligations, and still
pay basic expenses without having to
reborrow or refinance (except for any
final mortgage balloon payment)?
For the purposes of question PM14, the
Applicant should respond as it pertains to
all consumer and small business loans;
however, there are some exclusions for
mortgage loans. For purposes of this
question (PM14), a covered mortgage
loan product is limited to a consumer
credit transaction that is secured by a lien
on a single-family, owner-occupied
residence other than
(i) A reverse mortgage subject to 12
CFR 1026.33;
(ii) A temporary or “bridge” loan with a
term of 12 months or less, such as a
loan to finance the purchase of a
Yes, No, or N/A (i.e., does not offer covered
mortgage, consumer, or small business loan
products).
49
Section
Question or purpose of data field
Response
new dwelling where the consumer
plans to sell a current dwelling
within 12 months or a loan to
finance the initial construction of a
dwelling;
(iii) A construction phase of 12 months
or less of a construction-to-
permanent loan;
(iv) An extension of credit made
pursuant to a program
administered by a Housing Finance
Agency, as defined under 24 CFR
266.5;
(v) An extension of credit made
pursuant to a program
administered by the U.S.
Department of Housing and Urban
Development, the U.S. Department
of Veterans Affairs, or the U.S.
Department of Agriculture;
(vi) A transaction that does not require
payment of interest; or
(vii) A transaction made for the
purpose of foreclosure avoidance
or prevention.
PM14.1
If “No,” please explain how
the absence of consideration
of whether the borrower is
able to pay back each type of
loan serves a community
development purpose.
Provide narrative.
An Applicant that does not originate based
upon an assessment of whether a borrower
is able to pay back a loan may be determined
ineligible for CDFI Certification.
PM15
Does the Applicant originate, purchase
interests in, offer, arrange, market, or
service any consumer loan products
(including credit cards and purchased
loans) that allow for an annual percentage
rate in excess of 36% when that rate is
calculated using the Military Annual
Percentage Rate standard
22
?
Yes, No, or N/A (i.e., does not offer consumer
loan products).
If “Yes,” the Applicant will be required to
respond to additional financing-practices
questions about the consumer loan products
that allow for an annual percentage rate in
excess of 36% when that rate is calculated
using the MAPR standard.
If “Yes”:
Only for Applicants that originate, purchase
interests in, offer, arrange, market, or service
22
For additional guidance on calculating the MAPR, see the CFPB’s Military Lending Act (MLA), Interagency
Examination Procedures2015 Amendments, Terms of Consumer Credit Extended to Covered Borrowers
(Calculation of MAPR), 32 CFR 232.4, pp. 6-9.
50
Section
Question or purpose of data field
Response
any consumer loan products (including credit
cards or purchased loans) that allow for an
annual percentage rate in excess of 36%
when that rate is calculated using the MAPR
standard.
PM15.1
What is the current highest
allowable MAPR charged on
any of the Applicant’s
consumer loans (including
credit cards and purchased
loans)?
Enter the highest allowable MAPR on any of
the Applicant’s consumer loan products.
Questions PM15.2 through PM15.7 For any consumer loan product with an MAPR in
excess of 36%:
PM15.2
Did any of the consumer loan
products in question have an
annual default rate over 5%
during the 12 full months
immediately prior to
submission of the
Application?
23
Yes or No.
If “Yes,” the Applicant is not eligible for CDFI
Certification.
PM15.3
Do any of the consumer loans
in question include a
leveraged payment
mechanism?
24
Yes or No.
If “Yes,” the Applicant is not eligible for CDFI
Certification.
PM15.4
If the product in question
includes loans of $1,000 or
less, have the repayment
timeframes been limited to no
more than 12 months?
Yes, No, or N/A (i.e., does not offer loans of
$1,000 or less).
If “No,” the Applicant is not eligible for CDFI
Certification.
PM15.5
For a period of 12 full months
after the issuance of such a
consumer loan, does the
Applicant waive any upfront
fees for any refinance or new
loan issued to the same
borrower?
Yes or No.
If “No,” the Applicant is not eligible for CDFI
Certification.
PM15.6
Are all fees spread evenly over
the life of the loan and pro
rata refundable in the event of
early repayment (including
Yes or No, or N/A (i.e., does not offer
consumer installment loan products with an
MAPR in excess of 36%).
23
Calculate on a per borrower basis for single payment loans.
24
The CDFI Fund will rely on the CFPB’s definition of a leveraged payment mechanism: “A loan has a leveraged
payment mechanism if the lender or a service provider has the right to initiate a transfer of money, through any
means, from a consumer’s account to satisfy an obligation on a loan. See CFPB final rule and interpretations,
Payday, Vehicle Title, and Certain High-Cost Installment Loans, 12 CFR § 1041.3(c).
51
Section
Question or purpose of data field
Response
through a refinance) for each
of the Applicant’s consumer
installment loan products in
question?
If “No,” the Applicant is not eligible for CDFI
Certification.
PM15.7
Are all loan payments
substantially equal, and do
they amortize smoothly to a
zero balance by the end of the
loan term for each of the
Applicant’s consumer
installment loan products in
question?
Yes or No, or N/A (i.e., does not offer
consumer installment loan products with an
MAPR in excess of 36%).
If “No,” the Applicant is not eligible for CDFI
Certification.
PM16
Does the Applicant originate, purchase
interests in, offer, arrange, market, or
service small business loan products
(including credit cards and purchased
loans) that allow for an annual percentage
rate in excess of 36%?
Yes, No, or N/A (i.e., does not offer small
business loan products).
If “Yes,” the Applicant will be required to
respond to additional financing-practices
questions about the small business loan
products that allow for an annual percentage
rate in excess of 36%.
If “Yes”:
Only for Applicants that originate, purchase
interests in, offer, arrange, market, or service
any small business loan products (including
credit cards or purchased loans) that allow
for an APR in excess of 36%.
PM16.1
What is the current highest
allowable APR charged on any
of the Applicant’s small
business loans (including
credit cards and purchased
loans)?
Enter the highest allowable APR on any of the
Applicant’s small business loan products.
Questions PM16.2 through PM16.6 For any small business loan product with an APR in
excess of 36%:
PM16.2
Did any of the small business
loan products in question have
an annual default rate over 5%
during the 12 full months
immediately prior to
submission of the
Application?
25
Yes or No.
PM16.3
Do any of the small business
loans in question include a
Yes or No.
25
Calculate on a per borrower basis for single payment loans.
52
Section
Question or purpose of data field
Response
leveraged payment
mechanism?
26
PM16.4
Are all fees spread evenly over
the life of the loan and pro
rata refundable in the event of
early repayment (including
through a refinance) for each
of the Applicant’s small
business installment loan
products in question?
Yes or No, or N/A (i.e., does not offer small
business installment loan products with an
APR in excess of 36%).
PM16.5
Are all installment loan
payments substantially equal,
and do they amortize
smoothly to a zero balance by
the end of the loan term for
each of the Applicant’s small
business installment loan
products in question?
Yes or No, or N/A (i.e., does not offer small
business installment loan products with an
APR in excess of 36%).
PM16.6
If the Applicant responded
“Yes” to either PM16.2 or
PM16.3, or responded “No” to
either PM16.4 or PM16.5,
describe why the small
business loan product should
be considered consistent with
an acceptable community
development mission.
Provide narrative.
An Applicant that offers a small business loan
product with an APR in excess of 36% and
responded “Yes” to either question PM16.2
or PM16.3, or responded “No” to either
PM16.4 or PM16.5 may be determined
ineligible for CDFI Certification.
PM17
For each of the Applicant’s small business
loan products, does the Applicant disclose
in writing:
27
PM17.1
The periodic payment due?
Yes, No, or N/A (i.e., does not offer small
business loan products).
PM17.2
The total amount to be repaid
over the life of the loan?
Yes, No, or N/A (i.e., does not offer small
business loan products).
PM17.3
The total finance charges over
the life of the loan?
Yes, No, or N/A (i.e., does not offer small
business loan products).
26
The CDFI Fund will rely on the CFPB’s definition of a leveraged payment mechanism: “A loan has a leveraged
payment mechanism if the lender or a service provider has the right to initiate a transfer of money, through any
means, from a consumer’s account to satisfy an obligation on a loan. See CFPB final rule and interpretations,
Payday, Vehicle Title, and Certain High-Cost Installment Loans, 12 CFR § 1041.3(c).
27
Beginning January 1, 2026, new Applicants that offer small business loan products that do not disclose, in
writing, the periodic payment due, the total amount to be repaid over the life of the loan, the total finance charges
over the life of the loan, or the APR of the loan will be ineligible for CDFI Certification. Certified CDFIs that offer
small business loan products will be required to attest in their ACR to making such disclosures no later than
October 1, 2026, in order to maintain their certification.
53
Section
Question or purpose of data field
Response
PM17.4
The annual percentage rate of
the loan?
Yes, No, or N/A (i.e., does not offer small
business loan products).
PM18
If the Applicant is a non-depository
institution, does the Applicant originate,
purchase interests in, offer, arrange,
market, or service loans that exceed the
interest limits that apply to non-
depository institutions in the state where
the borrower resides?
Yes, No, or N/A (i.e., Applicant is a depository
institution).
If “Yes,” the Applicant is not eligible for CDFI
Certification.
PM19
For purposes of this question, PM19, a
covered mortgage loan product is limited
to a consumer credit transaction that is
secured by a lien on a single-family,
owner-occupied residence other than
(i) Transactions secured by a
subordinate lien;
(ii) A reverse mortgage subject to 12
CFR 1026.33;
(iii) A temporary or “bridge” loan
with a term of 12 months or less,
such as a loan to finance the
purchase of a new dwelling
where the consumer plans to sell
a current dwelling within 12
months or a loan to finance the
initial construction of a dwelling;
(iv) A construction phase of 12
months or less of a construction-
to-permanent loan;
(v) An extension of credit made
pursuant to a program
administered by a Housing
Finance Agency, as defined under
24 CFR 266.5;
(vi) An extension of credit made
pursuant to a program
administered by the U.S.
Department of Housing and
Urban Development, the U.S.
Department of Veterans Affairs,
or the U.S. Department of
Agriculture;
(vii) A transaction that does not
require payment of interest;
(viii) A transaction made for the
purpose of foreclosure avoidance
or prevention; or
54
Section
Question or purpose of data field
Response
(ix) For PM19.2 (loans with interest-
only payments) and PM19.3
(loans with balloon payments)
only, a transaction with a
payment schedule that is
adjusted to the seasonal or
irregular income of the consumer.
For each of the Applicant’s covered
mortgage loan products, does the
Applicant:
PM19.1
Offer covered mortgage loans
that include negative
amortization?
Yes, No, or N/A (i.e., does not offer covered
mortgage loan products).
If “Yes,” the Applicant is not eligible for CDFI
Certification.
PM19.2
Offer covered mortgage loans
that include interest-only
payments?
Yes, No, or N/A (i.e., does not offer covered
mortgage loan products).
If “Yes,” the Applicant is not eligible for CDFI
Certification.
PM19.3
Offer covered mortgage loans
that include balloon
payments?
28
Yes, No, or N/A (i.e., does not offer covered
mortgage loan products).
If “Yes”:
PM19.3a
Do the covered
mortgage loans
meet the criteria
set forth in 12 CFR
§§ 1026.43(f)(1)(i)
-(vi)?
Yes or No.
PM19.3b
If the Applicant
renews the loan at
the time the
balloon payment
is due, does the
new loan retain
the original
amortization
period?
Yes or No.
PM19.3c
If the Applicant
renews the loan at
the time the
Yes or No.
28
A balloon payment is a payment that is more than two times a regular periodic payment.
55
Section
Question or purpose of data field
Response
balloon payment
is due, does the
Applicant (as
permitted by
regulation) waive
the need for a
new appraisal and
limit application
and origination
fees?
PM19.3d
If the Applicant
responded “No”
to any of the
questions
PM19.3a through
PM19.3c, please
describe how such
loans are
advantageous to
the borrower, any
additional
protections that
limit potential
harm to the
borrower, and
why the loan
should be
considered
consistent with an
acceptable
community
development
mission.
Provide narrative.
An Applicant that offers covered mortgage
loan products that include balloon payments
and responded “No” to any of the questions
PM19.3a through PM19.3c may be
determined ineligible for CDFI Certification.
PM19.4
Underwrite adjustable-rate
covered mortgages at less
than the maximum rate in the
first five years?
Yes, No, or N/A (i.e., does not offer covered
mortgage loan products).
If “Yes,” the Applicant is not eligible for CDFI
Certification.
PM19.5
Offer covered mortgage loans
with an original maximum
term longer than 30 years?
Yes, No, or N/A (i.e., does not offer covered
mortgage loan products).
PM19.5a
If “Yes,” for any
covered mortgage
loans with an
original term
longer than 30
Provide narrative.
An Applicant that offers covered mortgage
loan products with an original maximum
term longer than 30 years may be
56
Section
Question or purpose of data field
Response
years, what is the
maximum term
allowable, and
describe why the
loan should be
considered
consistent with an
acceptable
community
development
mission.
determined ineligible for CDFI Certification.
PM19.6
Verify the income or assets of
the borrower of a covered
mortgage loan product?
Yes, No, or N/A (i.e., does not offer covered
mortgage loan products).
If “No,” the Applicant is not eligible for CDFI
Certification.
PM19.7
Charge upfront points and fees
on a covered mortgage loan
product in excess of the
Qualified Mortgage limits
29
?
Yes, No, or N/A (i.e., does not offer covered
mortgage loan products).
If “Yes,” the Applicant is not eligible for CDFI
Certification.
PM20
Select the tools the Applicant uses to assist
struggling borrowers.
Select all that apply:
- Fees or interest waivers.
- Interest rate reductions.
- Loan term extensions.
- Principal forbearance.
- Principal forgiveness.
- Other.
- None.
PM20.1
If “Other,” please describe.
Provide description.
PM21
Does the Applicant sell its charged-off
consumer or small business debt to debt
buyers?
Yes or No.
If “Yes,” the Applicant is not eligible for CDFI
Certification.
PM22
If the Applicant is an FDIC-insured
depository institution, does the Applicant
have a current Community Reinvestment
Act rating of Satisfactory or higher?
Yes, No, or N/A (i.e., not an FDIC-insured
depository institution).
If “No,” the Applicant is not eligible for CDFI
Certification.
Questions PM23 and PM24 will be asked only of Applicants that offer Equity Investment Financial
Products.
PM23
Does the Applicant have a policy or
practice in place for its Equity Investment
Yes, No, or N/A (i.e., does not offer equity
products).
29
The Qualified Mortgage limits on upfront points and fees are adjusted annually for inflation on January 1.
See § 1026.43(e)(3) and Comment 43(e)(3)(ii)-1 for the annual limits.
57
Section
Question or purpose of data field
Response
Financial Products that prevents the
Applicant from gaining Control over an
investee except if the Applicant must save
a business through ownership as a last
resort for a limited period of time?
If “No,” the Applicant is not eligible for CDFI
Certification.
PM24
During the 12 full months completed
immediately prior to submission of the
Application, did the Applicant leverage, for
its own benefit, the assets of any of its
active investees?
Yes, No, or N/A (i.e., does not offer equity
products).
If “Yes,” the Applicant is not eligible for CDFI
Certification.
RESPONSIBLE FINANCING PRACTICES FINANCIAL SERVICES
Questions PM25 through PM27 will be asked of depository institution Applicants only.
PM25
Select each of the listed features
associated with a single checking or share
account (including checkless checking)
offered by the Applicant (i.e., only select
the features that are offered as part of the
same account; if other features are
offered by the Applicant in different
accounts, do not include).
Select all that apply:
- Free access to debit card network for
point of sale and bill payment.
- Minimum opening deposit of $25 or
less.
- Monthly maintenance fee of $5 or
less if not waivable, or $10 or less if
waivable.
30
- No overdraft or nonsufficient funds
fees.
31
- No account activation, closure,
dormancy, inactivity, or low-balance
fees.
- Free and unrestricted branch access
or (for Applicants without branches)
access to free ATM network and free
remote deposits.
- Free and unrestricted telephone
banking (including live support).
- Free and unrestricted in-network
ATM access.
- Out-of-network ATM fee of $2.50 or
less, or up to $3.00 if free access to a
partner ATM network is also
provided.
30
For monthly maintenance fee to be considered waivable, the Applicant must offer at least two options to waive
the fee entirely with a single transaction (e.g., direct deposit with no minimum deposit, online bill pay, or debit
card purchase).
31
An overdraft fee is a fee or charge on a consumer's account held by the institution for paying a transaction
(including a check or other item) when the consumer’s account has insufficient or unavailable funds.
A nonsufficient funds fee is a fee or charge on a consumer's account held by the institution for a transaction
(including a check or other item) returned unpaid when the consumer’s account has insufficient or unavailable
funds.
58
Section
Question or purpose of data field
Response
- Free deposit capability for cash and
checks in-branch and at ATM (when
available) and direct deposit.
- Free bill pay if available or at least
four free money orders and/or
cashier checks per month.
- Free check cashing for checks issued
by the Applicant.
- Free online banking, mobile banking,
and banking alerts (if offered).
- Free electronic monthly statements,
or $2 or less for mailed paper
statements (if offered).
- Account screening only deny new
customers for past incidences of
actual fraud.
- Alternative IDs (e.g., municipal,
consular) accepted.
- Free linked savings accounts and
account transfers.
- Money orders priced at the U.S.
Postal Service rate or less.
- Competitively priced remittances
(international wire).
- Credit-building product offerings
such as secured credit card or
secured personal loan available.
PM25.1
Identify the checking or share
account that includes each of
the selected features.
Name account.
PM26
For any of the Applicant’s depository
accounts, is the account holder subject to
any potential overdraft fees?
Yes or No.
If “Yes”:
PM26.1
Specify the highest dollar
amount charged for such a
fee.
Enter number.
PM26.2
Can such fees exceed the
amount of the item being
cleared?
Yes or No.
PM26.2a
If “Yes”:
Describe why such
fees should be
considered
reasonable and
Provide narrative.
An Applicant that charges overdraft fees in
excess of the amount of the item being
cleared may be determined ineligible for CDFI
Certification.
59
Section
Question or purpose of data field
Response
proportionate to
the amount of the
item being cleared
and consistent
with an
acceptable
community
development
mission.
PM26.3
Specify any daily limits on the
number and frequency of such
fees that can be charged to an
account holder.
Enter number.
PM26.4
Specify any annual limits on
the number and frequency of
such fees that can be charged
to an account holder.
Enter number.
PM26.4a
If an account
holder may be
charged such fees
on more than six
occasions in a
rolling 12-month
period, describe
why such fees
should be
considered
consistent with an
acceptable
community
development
mission.
Provide narrative.
An Applicant that charges overdraft fees on
more than six occasions in a rolling 12-month
period may be determined ineligible for CDFI
Certification.
PM26.5
Select each of the listed
features included in the
Applicant’s overdraft program.
Select all that apply:
- No overdraft fees on debit card
purchases.
- No overdraft fees on ATM
withdrawals.
- No extended/sustained overdraft
fees.
- Grace period provided before
charging an overdraft fee.
- Negative balances allowed without
triggering an overdraft fee.
- Balance-related alerts offered.
- Access to real-time balance
information.
60
Section
Question or purpose of data field
Response
- Consumer’s checking account linked
to another account for overdraft
protection.
- Overdraft fees collected from a
consumer’s next deposit only after
other items have been posted or
cleared.
- No additional fees charged when an
item is re-presented.
- No transfer fees on overdraft
transfers from savings or from a
credit account.
- Other.
- None.
PM26.5a
If “Other,
describe the
feature included
in the Applicant’s
overdraft
program.
Provide narrative.
PM27
For any of the Applicant’s depository
accounts, is the account holder subject to
any potential nonsufficient funds (NSF)
fees?
Yes or No.
If “Yes”:
PM27.1
Specify the highest dollar
amount charged for such a
fee.
Enter number.
PM27.2
Can such fees exceed the
amount of the item returned
unpaid?
Yes or No.
PM27.2a
If “Yes”:
Describe why such
fees should be
considered
reasonable and
proportionate to
the amount of the
item being
returned unpaid
and consistent
with an
acceptable
community
development
Provide narrative.
An Applicant that charges NSF fees in excess
of the amount of the item returned unpaid
may be determined ineligible for CDFI
Certification.
61
Section
Question or purpose of data field
Response
mission.
PM27.3
Specify any daily limits on the
number and frequency of such
fees that can be charged to an
account holder.
Enter number.
PM27.4
Can such fees be charged
more than once for the same
transaction, regardless of
whether the item is re-
presented?
Yes or No.
PM27.4a
If “Yes,” describe
why such fees
should be
considered
consistent with an
acceptable
community
development
mission.
An Applicant that charges NSF fees more
than once for the same transaction may be
determined ineligible for CDFI Certification.
PM27.5
Specify any annual limits on
the number and frequency of
such fees that can be charged
to an account holder.
Enter number.
PM27.6
Select each of the listed
features included in the
Applicant’s NSF policies.
Select all that apply:
- Balance-related alerts offered.
- Access to real-time or near real-time
balance information provided.
- NSF fees collected from a consumer’s
next deposit only after other items
have been posted or cleared.
- Consumer’s checking account linked
to another account for NSF
protection.
- No transfer fees on NSF transfers
from savings or from a credit
account.
- Other.
- None.
PM27.6a
If “Other,
describe the
feature included
in the Applicant’s
NSF policies.
Provide narrative.
PRIMARY MISSION AFFILIATES
For each Affiliate subject to review in connection with any of the CDFI Certification requirements, the
Applicant must provide the following primary mission information, as well as respond to relevant
62
Section
Question or purpose of data field
Response
Documentation and Responsible Financing Practices questions.
PM28
Describe the activities of the Affiliate and
how the Affiliate’s mission and activities
support and/or are consistent with the
community development mission of the
Applicant.
Provide description.
63
FINANCING ENTITY
The CDFI Fund’s regulations state that “a CDFI shall be an entity whose predominant business activity is
the provision, in arms-length transactions, of Financial Products and/or Financial Services.”
32
To meet
the CDFI Certification Financing Entity test, an Applicant must demonstrate the following:
- The predominance of its assets are derived from or dedicated to, and the predominance of its
staff time is dedicated to, the provision of Financial Products and/or Financial Services.
(Predominance does not require a majority, but occurs when an amount is the greatest as
compared with all other amounts.)
- Its predominant business activity is the provision of Financial Products and/or Financial
Services
33
and that it has been engaged in such activity for at least one full fiscal year. Unless
otherwise indicated, the provision of Financial Products must be arm’s-length and on-balance
sheet.
- It has begun closing arm’s-length, on-balance sheet Financial Products and/or has delivered
Financial Services.
- It has or will have access to sufficient capital to close at least one new Financial Product
transaction during the upcoming three months from the date the CDFI Certification Application
is submitted.
Entities participating in the CDFI Fund’s CDFI BG Program
- BG Program participants that are unable to meet CDFI Certification Financing Entity
requirements will, for the purpose of participating in the BG Program only, be deemed as
meeting the Financing Entity requirements if they are Controlled by a Certified CDFI.
- Entities seeking to obtain or maintain CDFI Certification solely for participation in the CDFI
Fund’s BG Program and that are Controlled by a Certified CDFI are allowed to meet CDFI
Certification requirements using on-balance sheet Financial Product activity that is not arm’s-
length provided that the activity is by and between such entities and a Controlling Certified
CDFI. Such activity must be pursuant to operating agreements that include management and
ownership provisions and that are in a form and substance acceptable to the CDFI Fund (see 12
CFR 1805.201(b)(2)(C)(iii)).
Certain Regulated Financial Institutions
The following entities are presumed to meet the CDFI Certification Financing Entity requirements and
are exempt from completing this section of the Application, as long as their dates of incorporation,
organization, or establishment occurred at least one full fiscal year prior to submission of a CDFI
Certification Application:
- DIHCs
- Depository institutions with FDIC deposit insurance
32
12 CFR § 1805.201(b)(2).
33
Only depository institutions (bank/thrifts, credit unions or bank/thrift holding companies) may use Financial
Services to meet the Financing Entity test.
64
- Depository Institutions with NCUA share insurance
- State-Insured Credit Unions (includes state-regulated credit unions)
CDFI Certification Provision for Spin-off Entities
To fulfill the Financing Entity requirements, in lieu of a history of closing Financial Product transactions
over the 12 months of the most recently completed full fiscal year, a Spin-off entity must demonstrate
that it closed at least one Financial Product within the 12 months prior to submission of this Application
and must meet the additional following conditions:
- be a separate legal entity;
- have received a transferred Financial Product portfolio from at least one original Affiliate
entity;
- demonstrate that it currently offers at least one of the transferred Financial Products;
- demonstrate that at least one of the transferred Financial Products currently offered was
available from the original entity for at least the 12 full months immediately prior to
submission of this Application;
- demonstrate that at least one original Affiliate entity from which it received a Financial
Products portfolio had an acceptable primary mission in place for at least the six full months
immediately prior to submission of this Application; and
- demonstrate that it closed at least one Financial Product of the type transferred at any time
during the 12 full months immediately prior to submission of this Application, using its own
capital.
For the purposes of the Financing Entity test, the Spin-off should include any transferred Financial
Products and Financial Services assets that appear on its balance sheet as part of its own overall
Financial Product and Financial Services asset amounts.
ELIGIBLE FINANCIAL PRODUCTS/FINANCIAL SERVICES
34
Financial Products
Financial Products that can be used to demonstrate compliance with the Financing Entity requirements
include loans, Equity Investments, and other similar financing activities approved by the CDFI Fund.
Other similar financing activities currently pre-approved by the CDFI Fund as Financial Products include
- the provision of loan guarantees;
- forgivable loans that require at least one payment within 12 months of the loan’s closing date;
- the purchase of loans originated by a Certified CDFI;
- the purchase of loans originated by entities that do not have CDFI Certification but were made
to members of the Applicant’s Target Market(s);
- lines of credit; and
- credit cards.
34
Financial Products and Financial Services are defined by the CDFI Fund in the CDFI Program Revised Interim
Regulations, 12 CFR Part 1805.104
65
If an entity wants to include any financing other than the pre-approved similar financing activities as
Financial Products for the purpose of meeting any of the CDFI Certification requirements, it must obtain
prior approval from the CDFI Fund to do so.
Financial Services
Financial Services can be used to meet the CDFI Certification requirements by depository institutions
only.
Financial Services that can be used to demonstrate compliance with the Financing Entity requirements
include the holding of checking, savings, and money market accounts and the provision of check cashing,
money orders, certified checks, automated teller machines, safe deposit box services, and other similar
services.
If a depository institution wants to include any similar Financial Service as an eligible Financial Service
for the purposes of meeting any of the CDFI Certification requirements, it must obtain prior approval
from the CDFI Fund to do so.
ASSETS DEDICATED TO OR DERIVED FROM THE DIRECT PROVISION OF FINANCIAL PRODUCTS AND/OR
FINANCIAL SERVICES
Unless otherwise directed, information on assets dedicated to or derived from the provision of Financial
Products and/or Financial Services, or available within three months of submission of the Application to
finance Financial Product closings, should be based on assets held directly by the Applicant. If
consolidated statements that do not show the Applicant’s assets separately from other Affiliated
entities are presented, the Application will be rejected.
Furthermore, Applicants must base all assets dedicated to or derived from the provision of Financial
Products and/or Financial Services, or available within three months of submission of the Application to
finance Financial Product closings, on assets held directly by the Applicant. Such assets must be reflected
in the Applicant’s current, non-consolidated (i.e., the financial statement[s] must show the Applicant’s
activity separate and independent of any other entities), fiscal year-to-date balance sheet. Examples of
assets dedicated to or derived from the provision of Financial Products and/or Financial Services include
cash/cash equivalents, loans receivable, Equity Investments, pre-paid expenses, equipment, and
buildings/real estate. Assets available within the next three months to finance Financial Product closings
include cash/cash equivalents, Financial Product receivables, and accounts receivable.
Assets dedicated to or derived from the provision of Financial Products and/or Financial Services include
- the portion of any assets reflected in the Applicant’s current fiscal year-to-date balance sheet
that are derived from or currently available to be used as capital to finance its Financial Product
closings;
- the portion of any assets reflected in the Applicant’s current fiscal year-to-date balance sheet
used to support staffing costs and other operating needs related to its direct provision of
Financial Products; or
- for depository institutions that do not automatically qualify as Financing Entities (e.g.,
banks/thrifts that do not have federal deposit insurance or holding companies that do not meet
the CDFI Fund’s definition of a DIHC), the portion of any assets held by an Applicant directly, as
66
reflected in its current, non-consolidated, fiscal year-to-date balance sheet, that are derived
from or are currently available to support the direct provision of Financial Services.
Consistent with CDFI Fund regulations,
35
the CDFI Fund does not consider the following types of
activities as assets or staff time that support the direct provision of Financial Products and/or Financial
Services:
- Real estate development
- Property management
- Financing for affiliated entities (unless the Applicant is using the CDFI Certification provision for
participants in the CDFI Fund’s Bond Guarantee Program)
- Financing products or services not approved by the CDFI Fund as eligible Financial Products or
Financial Services
- Loan originating, servicing, or packaging for financing provided by other entities
- Grant making
- Development Services
- Other non-financing activities
STAFF TIME DEDICATED TO THE DIRECT PROVISION OF FINANCIAL PRODUCTS AND/OR FINANCIAL
SERVICES
The predominance of an Applicant’s staff time must be dedicated and allocated toward the direct
provision of eligible financing activities. Unless otherwise directed, the staffing information provided in
the Financing Entity section of the Application should be based on only the Applicant’s staffing levels
and activities.
Staffing allocations for the Financing Entity predominance test must be based on the manner an
Applicant used its staff time during the 12 full months just prior to the submission of this Application.
The Applicant should calculate the average full-time equivalent staff time available to it during the last
12 full months and identify how that time was allocated to its different activities. If an Applicant relies
on staffing provided by another entity, only the portion of the other entity’s FTE staff time that is spent
directly on the activities undertaken on behalf of the Applicant should be included.
Examples of activities considered to be directed toward the direct provision of Financial Products and/or
Financial Services include
- general entity administration that supports the provision of Financial Products and/or Financial
Services;
- direct staffing for the provision of Financial Products and/or Financial Services;
- marketing and outreach for the provision of Financial Products and/or Financial Services; and
- fundraising/raising capital for the provision of Financial Products and/or Financial Services.
35
12 CFR § 1805.201(b)(2).
67
PREDOMINANCE AS A FINANCING ENTITY
The Applicant’s assets and staffing information must demonstrate that the direct provision of Financial
Products and/or Financial Services is the Applicant’s predominant business activity.
To be predominant, the provision of Financial Products and/or Financial Services does not have to be the
majority of the Applicant’s overall activity, but must be the activity that reflects the greatest use of the
Applicant’s assets and staff time when compared with any other separate and distinct type of activity in
which the Applicant engages. No other single activity type should claim more of an Applicant’s assets
and staff time.
All assets held by an Applicant and all available staff time, including those that do not support the direct
provision of Financial Products and/or Financial Services, must be presented in connection with the
Financing Entity predominance test. Applicants that engage in significant Financial Product and/or
Financial Services business activity but who also have major assets that skew their asset or staffing data
such that the direct provision of Financial Products and/or Financial Services does not appear to be the
predominant activity may request that certain assets and/or staff time be excluded from consideration.
When requesting that assets or staff time be excluded from consideration for the Financing Entity
predominance test, the Applicant must provide an explanation of why such assets incorrectly appear to
indicate that the Applicant is not predominantly a Financing Entity, or why the assets are essential for it
to conduct its Financial Product and/or Financial Services activity. The CDFI Fund maintains sole
discretion to determine the applicability of such assets and/or staff time in meeting the Financing Entity
test.
Types of major assets and activities that may be disregarded as counting toward the predominance test
include
- endowments held by Applicants that have acted as traditional foundations but that have shifted
their activities and staff time to provide more Financial Products than grants and are community
development focused (as per business strategy).
- real property held by Applicants because they own their own building where a percentage of the
building supports the provision of Financial Products and/or Financial Services.
- real property held by Applicants because it was donated and the Applicant intends to sell it
within the next fiscal year and some or all of the revenue raised will be used to support the
provision of Financial Products and/or Financial Services.
- real estate to be sold or transferred to non-Affiliated third parties in order to support real estate
development financing activity (Financial Products for real estate development must be
offered).
- staff time dedicated to the provision of Development Services.
Applicants that continue to appear not to meet the Financing Entity predominance requirement, after
providing asset and staff time data, will have the opportunity to explain why they should be considered
a financing entity.
The Applicant must obtain prior approval from the CDFI Fund to exclude any major assets and/or staff
time for any related financing activity not included above.
68
Obtaining Determination to Disregard or Include Major Assets and/or Staff Time to Meet Financing
Entity Predominance Requirements
Applicants that seek to disregard or include major assets and/or staff time dedicated to or derived from
the provision of Financial Products and/or Financial Services that are not currently recognized as
qualified or eligible to be disregarded or included for the purpose of the Financing Entity predominance
test must be approved by a determination from the CDFI Fund before they will be considered as those
assets and/or staff time that may be disregarded or included for the purpose of the meeting Financing
Entity requirement test.
To request consideration to disregard or include any major assets and/or staff time, Applicants must
provide the following information for the CDFI Fund’s consideration in advance of an Application
submission:
- a description of the major asset(s) and/or staff time to be disregarded or included;
- the dollar amount for the portion of the balance sheet line item(s) to be disregarded or included
and the name of the balance sheet line item(s);
- the average FTE staff time to be disregarded or included;
- how the amount of the asset(s) and/or staff time to be disregarded or included was determined;
- if seeking to disregard any major asset(s) and/or staff time, why such asset(s) and/or staff time
incorrectly appear to indicate that the Applicant is not predominately a financing entity or, if
seeking to include any major asset(s) and/or staff time, why the asset(s) and/or staff time is
essential for the Applicant to conduct its Financial Product and/or Financial Services activity; and
- a copy of the Applicant’s most recently completed fiscal year financial statements and current
fiscal year-to-date balance sheet.
SUFFICIENT CAPITAL TO CONTINUE CLOSING FINANCIAL PRODUCT TRANSACTIONS
The Applicant must possess sufficient capital to sustain its Financial Product activity. Generally, the CDFI
Fund deems that an entity has sufficient capital to continue its eligible Financial Product activity if it has,
or will have access to, enough capital available to close at least one Financial Product transaction during
the upcoming three months with a dollar volume that is typical for the Applicant based on its Financial
Product offerings.
The Applicant must provide information on liquid assets as identified in the Applicant’s current year-to-
date balance sheet and off-balance sheet capital sources. Types of capital that should not be included as
available to finance Financial Product closings include, but are not limited to, cash needed for operations
and cash or other liquid assets that have been earmarked, set aside, or board- or funder-designated for
activity other than eligible financing. This may include, but is not limited to, capital designated for
financing products or services not approved by the CDFI Fund as eligible Financial Products or Financial
Services; grant making; real estate development; property management; and land acquisition.
FINANCING ENTITY APPLICANT ONLY GENERAL INFORMATION
Section
Question or purpose of data field
Response
FE-G1
If the Applicant has indicated that it is seeking to use the CDFI Certification BG Program
provision:
FE-G1.1
Is the Applicant Controlled by a
Certified CDFI that has a date of
Yes or No.
69
Section
Question or purpose of data field
Response
incorporation/organization/
establishment at least 12 full
months prior to submission of this
CDFI Certification Application?
FE-G1.2
Will the Applicant use Financial
Product activity that is not arm’s-
length to meet any of the Financing
Entity requirements?
Yes or No.
FE-G2
Do the Applicant’s financial statements and current
fiscal year-to-date balance sheets show assets held
by the Applicant separately and independently
from all other entities (i.e., in a non-consolidated
manner)?
Yes or No.
If “No,” the Applicant is not eligible
for Certification.
FE-G3
Attach financial statements for Applicant’s most
recently completed fiscal year with non-
consolidated balance sheet information.
Attach required document(s).
FE-G4
Attach financial statements with non-consolidated
balance sheet information for Applicant’s current
fiscal year-to-date.
Attach required document(s).
FINANCING ENTITY APPLICANT ONLY ASSET PREDOMINANCE NON-CONSOLIDATED CURRENT
FISCAL YEAR-TO-DATE ASSET DATA
Section
Question or purpose of data field
Response
FE-A1
Applicant’s Total Assets
Provide the total assets from current fiscal year-
to-date balance sheet held by the Applicant only.
Enter only the Applicant’s current
fiscal year-to-date total assets.
FE-A2
Does the Applicant request that any of its assets
(as indicated by the Applicant’s non-consolidated
current fiscal year-to-date balance sheet) be
disregarded for the purposes of the Financing
Entity predominance test?
Yes or No.
If “No,” skip to FE-A3.
If “Yes”:
FE-A2.1
Identify the line item for the asset
held by the Applicant in the non-
consolidated current fiscal year-to-
date balance sheet for which it
requests that some or all of the
related asset be disregarded.
Enter balance sheet line item name.
FE-A2.2
Indicate how the asset is used that
qualifies it to be disregarded.
Select one:
- Endowment.
- Portion of owned building
used to support the direct
provision of Financial
Products and/or Financial
70
Section
Question or purpose of data field
Response
Services.
- Donated real property to be
sold within the next fiscal
year to raise funds to
support the direct provision
of Financial Products and/or
Financial Services.
- Real estate to be
sold/transferred to non-
Affiliated third parties in
order to support real estate
development financing
activity (Financial Products
for real estate development
must be offered).
- Other.
FE-A2.2a
If Other, identify the
other asset use.
Enter use.
FE-A2.2b
Has this asset use been
pre-approved by the
CDFI Fund as one for
which some or all of
the assets used in that
manner can be
disregarded for the
purposes of the CDFI
Certification Financing
Entity predominance
test?
Yes or No.
If “No,” the asset will not be
disregarded toward meeting the
Financing Entity predominance test.
FE-A2.2c
Attach disregarded
asset approval letter.
Attach relevant disregarded asset
approval letter from the CDFI Fund.
FE-A2.3
Indicate the dollar amount for the
portion of the line item in the
current fiscal year-to-date balance
sheet to be disregarded.
Enter dollar amount.
FE-A2.4
Explain how the amount of the asset
to be disregarded was determined.
Enter explanation.
If the Applicant has more than one balance sheet line item and/or asset use for which it
requests that some or all of the relevant assets be disregarded for the purposes of the
Financing Entity predominance test, repeat the data entry for each such item.
FE-A3
Based on the Applicant’s assets from the current fiscal year-to-date, non-consolidated
balance sheet, for each line item for which some or all of the asset is currently dedicated
to or derived from the direct provision of eligible Financial Products and/or Financial
Services:
FE-A3.1
Identify the line item.
Enter balance sheet line item name.
FE-A3.2
Indicate how the asset qualifies as
Select one:
71
Section
Question or purpose of data field
Response
being dedicated to or derived from
the direct provision of eligible
Financial Products and/or Financial
Services.
- Cash dedicated to or
derived from the direct
provision of eligible
Financial Products and/or
Financial Services.
- Cash equivalents dedicated
to or derived from the
direct provision of eligible
Financial Products and/or
Financial Services.
- Portion of owned building
from which revenue is
generated that supports the
direct provision of eligible
Financial Products and/or
Financial Services.
- Portion of owned
equipment used for the
direct provision of eligible
Financial Products and/or
Financial Services.
- Receivables derived from
the direct provision of
eligible Financial Products
and/or Financial Services.
- Other.
If Other:
FE-A3.2a
Identify the asset
source or committed
use that qualifies it as
being dedicated to or
derived from the direct
provision of eligible
Financial Products
and/or Financial
Services.
Enter activity.
FE-A3.2b
Has this asset been
pre-approved by the
CDFI Fund as being
dedicated to or derived
from the direct
provision of Financial
Products and/or
Financial Services?
Yes or No.
If “No,” the asset will not qualify
toward meeting the predominance
test.
FE-A3.3
Indicate the dollar amount for the
portion of the line item that is
Enter dollar amount.
72
Section
Question or purpose of data field
Response
dedicated to or derived from the
direct provision of eligible Financial
Products and/or Financial Services.
FE-A3.4
Explain how the amount was
determined.
Enter explanation.
If the Applicant has more than one balance sheet line item for which some or all of the
related assets are dedicated to or derived from the direct provision of Financial
Products and/or Financial Services, repeat data entry for each such item.
FE-A4
Based on assets in the Applicant’s current fiscal year-to-date, non-consolidated balance
sheet, for each line item for which some or all of the asset is currently dedicated to an
activity other than the direct provision of Financial Products and/or Financial Services and
that has not been listed as disregarded for the purposes of the Financing Entity
predominance test:
FE-A4.1
Identify the line item.
Enter balance sheet line item name.
FE-A4.2
Identify the relevant activity(ies)
associated with the asset.
Select one:
- Real estate development.
- Property management.
- Ineligible financing activity:
o Financing to
affiliated individuals
or entities.
o Financing
products/services
not approved by
the CDFI Fund as
eligible Financial
Products or
Financial Services.
o Loan packaging/
origination/
servicing for
financing provided
by another
entity(ies).
o Grant making.
- Development Services.
- Training, counseling, and/or
technical assistance that
does not qualify as
Development Services.
- Other.
FE-A4.2a
If Other, describe.
Enter description.
FE-A4.3
Indicate the dollar amount for the
portion of the line item that is
dedicated to the selected activity.
Enter dollar amount.
FE-A4.4
Explain how the amount was
Enter explanation.
73
Section
Question or purpose of data field
Response
determined.
If the Applicant has more than one balance sheet line item for which some or all of the
related assets are dedicated to an activity other than the direct provision of Financial
Products and/or Financial Services, repeat data entry for each such item.
FE-A5
Summary of total assets by activity:
FE-A5.1
Disregarded Assets.
[Auto-calculated.]
(Based on entries in FE-A2.)
FE-A5.2
Assets dedicated to or derived from
the direct provision of Financial
Products and/or Financial Services.
[Auto-calculated.]
(Based on entries in FE-A3.)
FE-A5.3
Real estate development.
[Auto-calculated.]
(Based on entries in FE-A4.)
FE-A5.4
Property management.
[Auto-calculated.]
(Based on entries in FE-A4.)
FE-A5.5
Ineligible financing to Affiliated
individuals or entities.
[Auto-calculated.]
(Based on entries in FE-A4.)
FE-A5.6
Loan packaging/origination/
servicing for financing provided by
another entity(ies).
[Auto-calculated.]
(Based on entries in FE-A4.)
FE-A5.7
Grant making.
[Auto-calculated.]
(Based on entries in FE-A4.)
FE-A5.8
Development Services.
[Auto-calculated.]
(Based on entries in FE-A4.)
FE-A5.9
Training, counseling, and/or
technical assistance that does not
qualify as Development Services.
[Auto-calculated.]
(Based on entries in FE-A4.)
FE-A5.10
Other.
[Auto-calculated.]
(Based on entries in FE-A4.)
FE-A5.11
Total.
[Auto-calculated.]
(Should match entry in FE-A1.)
If the share of all assets held by the Applicant
(other than disregarded assets) that are
dedicated to an activity other than eligible
financing is greater than the share of the
Applicant’s overall assets dedicated to or derived
from the direct provision of Financial Products
and/or Financial Services, explain why the
Applicant should nevertheless be considered
Provide explanation.
74
Section
Question or purpose of data field
Response
predominantly a Financing Entity.
FINANCING ENTITY APPLICANT ONLY STAFFING PREDOMINANCE
Section
Question or purpose of data field
Response
FE-AS1
Applicant’s average total full-time equivalent staff
for the 12 months immediately prior to the
submission of the CDFI Certification Application.
Enter Average Total FTE Staff.
FE-AS2
Does the Applicant request that the use of any of
its FTE staff be disregarded for the purposes of the
Financing Entity predominance test?
Yes or No.
If “No,” skip to FE-AS3.
If Yes:
FE-AS2.1
Indicate the use of FTE staff that
qualifies it to be disregarded for the
purposes of the Financing Entity
predominance test.
Select all that apply:
- Development Services.
- Endowment management.
- Management of portion of
owned building used to support
the direct provision of Financial
Products and/or Financial
Services.
- Management of donated Real
Property to be sold to raise
funds to support the direct
provision of Financial Products
and/or Financial Services.
- Management of real estate to
be sold/transferred to non-
Affiliated third parties in order
to support real estate
development financing activity
(Financial Products for real
estate development must be
offered).
- Other.
If Other:
FE-AS2.1a
Identify the other FTE
staff use.
Enter use.
FE-AS2.1b
Has this FTE staff use
been pre-approved by
the CDFI Fund as one
for which some or all of
the FTE staff used in
that manner can be
disregarded for the
purposes of the CDFI
Certification Financing
Yes or No.
75
Section
Question or purpose of data field
Response
Entity predominance
test?
FE-AS2.1c
Attach approval letter.
Attach relevant disregarded staff time
approval letter from the CDFI Fund.
FE-AS2.2
Indicate the amount of the
Applicant’s average FTE staff to be
disregarded.
Enter FTE staff number.
FE-AS2.3
Explain how the amount of FTE staff
to be disregarded was determined.
Enter explanation.
FE-AS3
For FTE staff dedicated to the provision of Financial Products and/or Financial Services:
FE-AS3.1
Indicate the use of FTE staff that
qualifies it as being dedicated to the
provision of Financial Products
and/or Financial Services.
Select all that apply:
- General entity administration
that supports the provision of
Financial Products and/or
Financial Services.
- Direct staffing for the provision
of Financial Products and/or
Financial Services.
- Marketing and outreach for the
provision of Financial Products
and/or Financial Services.
- Fundraising/raising capital for
the provision of Financial
Products and/or Financial
Services.
- Other.
If Other:
FE-AS3.1a
Identify the other FTE
staff use.
Enter use.
FE-AS3.1b
Has this FTE staff use
been pre-approved by
the CDFI Fund as one
for which some or all of
the staff time used in
that manner qualifies
as being dedicated to
the provision of
Financial Products
and/or Financial
Services for the
purposes of the CDFI
Certification Financing
Entity predominance
test?
Yes or No.
FE-AS3.1c
Attach approval letter.
Attach financing-related activity
approval letter(s) from the CDFI Fund.
76
Section
Question or purpose of data field
Response
FE-AS3.2
Indicate the average amount of
overall FTE staff dedicated to the
provision of Financial Products
and/or Financial Services.
Enter Average FTE staff number.
FE-AS3.3
Explain how the amount was
determined.
Enter explanation.
FE-AS4
For FTE staff dedicated to activity other than the provision of Financial Products and/or
Financial Services and that has not been listed as disregarded for the purposes of the
Financing Entity predominance test:
FE-AS4.1
Identify the relevant activity(ies).
Select one:
- Real estate development.
- Property management.
- Ineligible financing activity
o Financing to affiliated
individuals or entities.
o Financing
products/services not
approved by the CDFI
Fund as eligible
Financial Products or
Financial Services.
o Loan
packaging/origination/
servicing for financing
provided by another
entity(ies).
o Grant making.
- Training, counseling, and
technical assistance that does
not qualify as Development
Services.
- Other.
FE-AS4.1a
If Other, describe.
Enter description.
FE-AS4.2
Indicate the amount of the
Applicant’s average FTE staff
dedicated to the selected activity.
Enter FTE staff number.
FE-AS4.3
Explain how the amount was
determined.
Enter explanation.
If the Applicant has more than one type of activity for which related staff time is dedicated to an activity
other than the direct provision of Financial Products and/or Financial Services, repeat the data entry for
each relevant activity type.
FE-AS5
Summary of total staff time by activity:
FE-AS5.1
Disregarded Development Services
FTE staff.
[Auto-calculated.]
(Based on entries in FE-AS2.)
FE-AS5.2
Other disregarded FTE staff.
[Auto-calculated.]
77
Section
Question or purpose of data field
Response
(Based on entries in FE-AS2.)
FE-AS5.3
FTE staff dedicated to or derived
from the direct provision of
Financial Products and/or Financial
Services.
[Auto-calculated.]
(Based on entries in FE-AS3.)
FE-AS5.4
Real estate development.
[Auto-calculated.]
(Based on entries in FE-AS4.)
FE-AS5.5
Property management.
[Auto-calculated.]
(Based on entries in FE-AS4.)
FE-AS5.6
Ineligible financing to Affiliated
individuals or entities.
[Auto-calculated.]
(Based on entries in FE-AS4.)
FE-AS5.7
Loan packaging/origination/
servicing for financing provided by
another entity(ies.).
[Auto-calculated.]
(Based on entries in FE-AS4.)
FE-AS5.8
Grant making.
[Auto-calculated.]
(Based on entries in FE-AS4.)
FE-AS5.9
Training, counseling, and technical
assistance that does not qualify as
Development Services.
[Auto-calculated.]
(Based on entries in FE-AS4.)
FE-AS5.10
Other.
[Auto-calculated.]
(Based on entries in FE-AS4.)
FE-AS5.11
Average Total FTE Staff.
[Auto-calculated.]
(Should match entry in FE-AS1.)
If the share of any of the Applicant’s average FTE
staff (other than disregarded staff time) that has
been dedicated to an activity other than eligible
financing activity is greater than the share of the
Applicant’s average FTE staff dedicated to the
provision of Financial Products and/or Financial
Services, explain why the Applicant should still
be considered predominantly a Financing Entity.
Provide explanation.
FINANCING ENTITY APPLICANT ONLY CAPITAL TO FINANCE FINANCIAL PRODUCT CLOSING DURING
NEXT THREE MONTHS
Section
Question or purpose of data field
Response
FE-AC1
Average dollar amount of a Financial Product
transaction financed by the Applicant over the 12
months immediately prior to the submission of the
Enter dollar amount.
78
Section
Question or purpose of data field
Response
Application.
FE-AC2
Based on assets in the current fiscal year-to-date balance sheet, for each line item for which
some or all of the asset will be available during the next three months to finance the
Applicant’s Financial Product closings:
FE-AC2.1
Identify the line item.
Enter balance sheet line item name(s).
FE-AC2.2
Indicate why the asset is considered
to be liquid and available to finance
the Applicant’s Financial Product
closings over the next three months.
Select all that apply:
- Cash/cash equivalent asset
designated as Financial Product
capital.
- Current asset that is or will
become a cash/cash equivalent
asset within the next three
months and that will be
designated as Financial Product
capital.
- Portion of owned building from
which revenue is generated that
is designated as Financial
Product capital.
- Other.
FE-AC2.2a
If Other, explain.
Provide explanation.
FE-AC2.3
Indicate the dollar amount for the
portion of the line item that will be
available to finance the Applicant’s
Financial Product closings.
Enter dollar amount.
FE-AC2.4
Explain how the amount was
determined.
Provide explanation.
If the Applicant has more than one balance sheet line item for which some or all of the
related assets will be available to finance its Financial Product closings over the next three
months, repeat the data entry for each such item.
FE-AC3
Does the Applicant have any off-balance sheet
capital that will be available to it during the next
three months to finance its eligible Financial
Product closings?
Yes or No.
If “Yes”:
FE-AC3.1
Indicate the type of off-balance
sheet capital available.
Select type.
- Line of credit.
- Grant or loan funds formally
committed.
- Capital held by an Affiliate
formally committed.
- Other.
FE-AC3.1a
If “Other,” explain.
Provide explanation.
FE-AC3.2
Provide the dollar amount available.
Enter dollar amount.
FE-AC3.3
Explain why the off-balance sheet
capital is considered to be formally
Narrative.
79
Section
Question or purpose of data field
Response
committed.
FE-AC3.4
Provide documentation evidencing
that the off-balance sheet capital is
formally available and that includes
amount available.
Attach document(s).
If the Applicant has multiple off-balance sheet capital sources available, repeat data entry
for each source.
FE-AC4
Total capital available to finance eligible Financial
Product closings over the next three months.
[Auto-calculated.]
(Based on entries in FE-AC2 and FE-AC3.)
FE-AC5
Is the available capital greater than the average
dollar amount of a Financial Product transaction
financed by the Applicant over the 12 months
immediately prior to the submission of the
Application?
[Auto-populated.]
Yes or No.
If No, the Applicant is not eligible for
CDFI Certification.
TARGET MARKET
To be a Certified CDFI, an Applicant must demonstrate that it serves at least one eligible Target Market
(either an Investment Area or a Targeted Population). In addition, it must direct at least 60% of both the
number and dollar volume of arm’s-length, on-balance sheet Financial Products to one or more eligible
Target Market(s).
Financial Services Option
A Depository Institution that has directed less than 60% but at least 50% of either the dollar volume or
the total number of its Financial Products to one or more eligible Target Market(s) also has the option of
meeting the Target Market test by demonstrating that at least 60% of its total unique depository
account holders are members of one or more eligible Target Market(s) and that it delivers to one or
more eligible Target Market(s) at least
- 60% number of Financial Products and 50% dollar volume of Financial Products; or
- 50% number of Financial Products and 60% dollar volume of Financial Products.
New CDFI Applicants must meet the applicable Target Market percentage benchmarks over their most
recently completed fiscal year prior to submission of the Application.
New CDFI Applicants must meet the applicable Target Market percentage benchmarks over their most
recently completed fiscal year prior to submission of the Application. If an Applicant’s financing activity
in its submitted TLR data falls below the required level for any of the applicable Target Market
percentage benchmarks, the Applicant will not be eligible for CDFI Certification. The benchmarks must
be met as stated without any rounding of decimal points.
80
To meet the Target Market requirements, an Applicant may serve multiple eligible Target Markets. (For
example, an Applicant may demonstrate compliance with the Target Market percentage benchmarks by
serving both an Investment Area and one or more Targeted Populations.) However, for the purposes of
calculating the overall Target Market percentage of an Applicant’s financing activity, each Financial
Product transaction or Financial Service item shall be counted toward only one Target Market
component, which shall be identified by the Applicant or Certified CDFI (even if the transaction or
account qualifies as having been directed to more than one Target Market component).
To maintain Certification, Certified CDFIs must demonstrate compliance with the Target Market
percentage benchmarks each fiscal year. To confirm a CDFI continues to direct Financial Products and/or
Financial Services to its approved Target Market at the required levels, transaction level data will be
reviewed annually, through the submission of a TLR, in connection with the ACR. After initial
Certification (or recertification) through this Application and a Certified CDFI’s first two ACR submissions,
a Certified CDFI that fails to meet the Target Market benchmarks, based on its Financial Products and/or
Financial Services activity, over its most recently completed fiscal year may maintain its Certification by
demonstrating that it met the benchmarks over a three-year period through the last day of its most
recently completed fiscal year—as measured by the data submitted in the CDFI’s three most recent
TLRs, including as part of its Certification Application, if necessary. (A Certified CDFI that fails to meet the
Target Market benchmarks for the previous fiscal year in its first ACR submission will have the option to
be evaluated over a two-year period through the last day of its most recently completed fiscal year.)
Certified CDFIs that still fall below the Target Market benchmarks over three full fiscal years of financing
activity in their TLR (or over two full fiscal years for those with less than two years of Certification under
this Application) will be decertified, and no additional cure period will be granted.
Note: Only data submitted as part of this Certification Application, the new abbreviated TLR, and/or
the December 2023 version of the CDFI/NACA/RRP TLR may be used to meet the Target Market
benchmarks over a three-year period (i.e., data submitted as part of a previous Certification
Application, ACR, or earlier version of the CDFI/NACA/RRP TLR, may not be used for this option).
COLLECTIVE REVIEW FOR DIHCs, AFFILIATES OF DIHCS, OR SUBSIDIARIES OF IDIs
For a DIHC, an Affiliate of a DIHC, or a Subsidiary of an IDI to be certified as a CDFI, it must meet the
Target Market requirements both
- individually, based on the Applicant’s own Financial Product and, if elected, Financial Services
activity; and
- collectively, based on the aggregate Financial Product and, if elected, Financial Services activity
of the Applicant and any Affiliate in its family of entities.
ALTERNATIVE PROVISIONS BY ENTITY TYPE
The following entities may meet the CDFI Certification Target Market requirements through the
provisions described.
Depository Institution Holding Companies
DIHCs that do not directly provide Financial Products or Financial Services may rely on the activity of all
Affiliates subject to the statutory CDFI Certification collective review process. If a DIHC Applicant’s
81
Affiliates have also applied for CDFI Certification, the DIHC will identify the Affiliate’s Financial Product(s)
and, if elected, Financial Services activity of all covered Affiliates that will be used to satisfy the DIHC’s
TLR requirement. (This data will be aggregated to avoid duplication of TLR records.)
Entities participating in the CDFI BG Program
Entities applying for Certification solely for participation as Eligible CDFIs in the CDFI Fund’s BG Program
may meet CDFI Certification Target Market requirements using Financial Product activity that is not
arm’s-length, provided that the activity is by and between such entities and their Controlling Certified
CDFIs. Such activity must be pursuant to operating agreements that include management and ownership
provisions and that are in a form and substance acceptable to the CDFI Fund (see 12 CFR
1805.201(b)(2)(C)(iii)).
Spin-offs
If an entity is eligible for the CDFI Certification provision for Spin-offs (as described in the Financing
Entity section of the Application), it must include the following Financial Product and Financial Services
activity data for review in connection with the Target Market requirements:
- any Financial Product transactions it closed during the most recently completed full fiscal year
(This includes any Financial Product transactions received as part of a spun-off Financial Product
portfolio that were closed by the original entity during the most recently completed fiscal year
and that remain on the Spin-off’s balance sheet as of the end of that fiscal year); and
- any depository accounts held by the Spin-off entity that were still open as of the end of the
entity’s most recently completed fiscal year.
An entity spun off from a Certified CDFI is not eligible for this provision.
ELIGIBLE TARGET MARKETs
An entity’s Target Market can be composed of one or more of the following Target Market components
listed in this section under “Investment Area” and “Targeted Population.”
Investment Area
An Investment Area meets at least one of the following economic distress criteria and has significant
unmet needs for Financial Products and Services; or it is wholly located within an Empowerment Zone or
Enterprise Community (as designated under section 1391 of the Internal Revenue Code of 1986
[26 U.S.C 1391]).
Economic Distress Criteria:
- Poverty rate greater than 20%;
- Median family income (MFI) at 80% or below specific MFI benchmarks; or
- Unemployment rate 1.5 times the national average.
82
There are three types of Investment Areas (IAs):
(1) Pre-qualified Investment Area Qualified Census Tracts Only
A pre-qualified Investment Area consists only of individual census tracts that the CDFI Fund has
determined meet one or more of the statutory economic distress criteria. If an Applicant elects to
serve an Investment Area comprised of qualified census tracts only, the Financial Product and/or
Financial Services activity that falls within qualified census tracts anywhere within the United
States and its territories, as demonstrated by using the CDFI Fund’s approved assessment
methodologies, is counted as being within the entity’s Target Market.
(2) Customized Investment Areas
Applicants may also establish a customized Investment Area consisting of specially designated
geographic areas that
- include a contiguous mix of both qualified and non-qualified geographic units of a single type,
which may be census tracts or non-Metro
36
counties or parishes;
37
and
- validate as a distressed community per the CDFI Fund’s mapping system (CIMS) by meeting
the following criteria:
o More than 85% of the population must be in qualified geographic units.
o The geographic units must be contiguous.
If an Applicant designates a customized Investment Area as a Target Market component, only the
Financial Products and/or Financial Services activity that falls within the boundaries of the mix of
tracts is counted as being within a Target Market.
Although financing activity can occur and be counted in individually non-qualifying census tracts
within a customized Investment Area, the Applicant must direct at least 85% of its customized
Investment Area financing activity within the individually qualified census tracts of that
customized Investment Area for activity in the non-qualifying tracts of the customized
Investment Area to count toward the 60% Target Market benchmark. The Applicant must use the
CDFI Fund’s approved Target Market assessment methodologies to demonstrate that it is serving
the customized Investment Areas.
(3) Non-Metro Customized Investment Areas, Counties, and Parishes
Prior to October 1, 2026, an Applicant that serves a non-Metro customized Investment Area,
38
county, or parish also must direct at least 75% of its non-Metro customized Investment Area,
36
Non-Metro or Non-Metropolitan refers to any area that does not qualify as a Metropolitan Statistical Area,
which is defined by the Office of Management and Budget (OMB) as “at least one urbanized area of 50,000 or
more population, plus adjacent territory that has a high degree of social and economic integration with the core as
measured by commuting ties.” https://www.whitehouse.gov/wp-content/uploads/2020/03/Bulletin-20-01.pdf
37
Per 12 CFR § 1805.201(b)(3)(2)(B), “geographic units in Metropolitan Areas that are used to comprise an
Investment Area shall be limited to census tracts, and Indian Reservations.
38
A non-Metro customized Investment Area must consist exclusively of non-Metro geographic units.
83
county, or parish Financial Product and/or Financial Services activity within the individually
qualified census tracts of the respective non-Metro geography for activity in the non-qualifying
tracts of the non-Metro geography to count toward the 60% Target Market benchmark.
Beginning October 1, 2026, an Applicant that serves a non-Metro customized Investment Area,
county, or parish must direct at least 85% of its non-Metro customized Investment Area, county,
or parish Financial Products and/or Financial Services activity within the individually qualified
census tracts of the respective non-Metro geography for activity in the non-qualifying tracts of
the non-Metro geography to count toward the 60% Target Market benchmark. The Applicant
must use the CDFI Fund’s approved Target Market assessment methodologies to demonstrate
that it is servicing the non-Metro customized Investment Area(s), counties, and/or parishes.
Targeted Population
Targeted Population is defined as individuals, or an identifiable group of individuals, who are Low-
Income or lack adequate access to Financial Products or Financial Services. The Targeted Population is
specific to the individual borrowers whose socioeconomic characteristics are used to determine
inclusion in the Target Market. The Applicant must use the CDFI Fund’s approved Target Market
assessment methodologies to demonstrate that it serves the Targeted Population.
Targeted Populations include Low-Income Targeted Populations (LITP) and Other Targeted Populations
(OTP):
LITP
Individuals qualify as members of the Low-Income Targeted Population if their family income is
- for Metropolitan Areas,
o 80% of the area median family income (adjusted for family size); or
- for non-Metropolitan Areas, the greater of
o 80% of the area median family income (adjusted for family size); or
o 80% of the statewide non-Metropolitan Area median family income (adjusted for family
size).
OTP
Other Targeted Populations currently recognized by the CDFI Fund are
- Other Targeted Population African American.
- Other Targeted Population Hispanic.
- Other Targeted Population Native American.
- Other Targeted Population Native Alaskan.
- Other Targeted Population Native Hawaiian.
- Other Targeted Population Other Pacific Islander.
- Other Targeted Population Filipino.
- Other Targeted Population Vietnamese.
- Other Targeted Population Persons with Disabilities.
- Other Targeted Population Certified CDFIs.
84
Obtaining Determination for Additional Targeted Populations
Those Targeted Populations not currently accepted by the CDFI Fund must first be approved by the CDFI
Fund before they can be included as part of an entity’s Target Market for CDFI Certification purposes. To
request approval for a new Targeted Population, Applicants must provide the following information for
the CDFI Fund’s consideration in advance of an Application submission:
- a name and description of the Targeted Population;
- the geographic location of the Targeted Population intended to be served (e.g., national,
statewide, specific census tracts). Unless “national,” include a map generated in the CDFI
Information Mapping System depicting the geography to be served;
- a narrative that demonstrates that the specific Targeted Population(s) has significant unmet
capital or Financial Services needs;
- if the Applicant serves the members of the Targeted Population directly or indirectly or through
borrowers or investees that serve such members; and
- specific evidence showing the proposed Targeted Population has disparities, controlling for
poverty and income effects, in their access to Financial Products and Services for the geographic
population service area.
MAPPING REQUIREMENTS
Target Market maps are required for all customized Investment Area Target Market components and
certain Other Targeted Populations.
CIMS provides mapping and geocoding capabilities to support the Application process and to assess the
eligibility of investments, lending, and Financial and Development Services activities in specific
geographic areas. Through CIMS, Applicants are able to upload and process the accurate batch
geocoding of addresses, whether these be prospective locations for individual projects or actual
transactions funded, and to confirm addresses of relevant board members.
Maps must be created for each proposed customized Investment Area Target Market and Non-Metro
counties/parishes, and for any newly requested Other Targeted Populations not already on the CDFI
Fund’s list of currently recognized Other Targeted Populations. Applicants creating maps must utilize the
most recent set of eligible census tracts deployed for use by the CDFI Fund. Refer to the CIMS user
guidance for further information on creating Target Market maps.
COMPILING TARGET MARKET DATA
Data on Financial Product activity presented for review in connection with the Target Market
requirements must be submitted in the TLR based on the date the Financial Product transactions were
closed. In the case of active, outstanding loan purchases, data on Financial Product activity should be
based on the date the bundle of loans was purchased.
Even if related funds were not disbursed on that date or were not eventually fully disbursed, the
transaction amounts must be the total amount of financing approved.
The CDFI Fund accepts loan purchases from Certified CDFIs and Target Market loans purchased from
non-Certified CDFI entities as Financial Products. Loan Purchases should be presented for review in
connection with the Target Market requirements as follows:
85
- Loan Purchases from Certified CDFIs, whether purchased individually or in a bundle, are
recognized as Financial Products directed to an OTP Certified CDFIs Target Market. Each
bundled Loan Purchase from a Certified CDFI will count as a single Financial Product transaction.
- Target Market loans purchased from non-Certified CDFI entities are recognized as Financial
Products directed to the Target Market(s) of the original borrowers. Applicants that purchase
Target Market loans from non-Certified CDFI entities in a bundle may count each of the
purchased loans as a single Financial Product transaction.
Obtaining Determination for Other Target Market Assessment Methodologies
A Target Market assessment methodology or combination of such methodologies must be used to verify
whether Financial Products, depository accounts, board members, and/or credit union members meet
the Target Market criteria.
Only those methodologies approved by the CDFI Fund may be used when compiling Target Market data.
A list of approved Target Market assessment methodologies can be found on the CDFI Fund website.
Applicants may request separate approval of a methodology not previously approved by the CDFI Fund.
Applicants that seek to use a Target Market assessment methodology other than one that appears on
the list of approved methodologies, including the use of programmatic proxy assessments, must provide
the following information for the CDFI Fund to consider in advance of completing their Application for
submission:
- the applicable Target Market (i.e., Investment Area, Low-Income Targeted Population, or Other
Targeted Population).
- assessment methodology (e.g., description of methodology and/or model design, including the
step-by-step process used to collect the data, review any documents, and/or run the model and
process its results).
- supporting or supplemental documentation.
- description of how the proposed assessment methodology provides sufficient confidence that a
transaction can be assigned to a specific Target Market.
- if proposing a programmatic proxy, the program’s detailed eligibility criteria or the step-by-step
process used to compare programmatic data to CDFI Fund definitions (e.g., income sources,
income thresholds).
- the process for recordkeeping.
- the process for updating any methodology dependent on underlying data changes.
All Target Market assessment methodologieswhether from the list of approved methodologies or
allowed to present separatelymust be used exactly as prescribed, unless and until modification of the
process is authorized by the CDFI Fund. Failure to use an approved assessment methodology (or
maintain required documentation) may result in the termination of a Certified CDFI’s certification.
Section
Question or purpose of data field
Response
TM01
Identify a proposed Target Market.
Select at least one:
- Investment Area Pre-
qualified.
- Investment Area
Customized.
- Investment Area Non-
86
Section
Question or purpose of data field
Response
Metro Customized.
- Investment Area Non-
Metro counties/parishes.
- Low-Income Targeted
Population.
- Other Targeted Population
African American.
- Other Targeted Population
Hispanic.
- Other Targeted Population
Native American.
- Other Targeted Population
Native Alaskan.
- Other Targeted Population
Native Hawaiian.
- Other Targeted Population
Other Pacific Islander.
- Other Targeted Population
Filipino.
- Other Targeted Population
Vietnamese.
- Other Targeted Population
Persons with Disabilities.
- Other Targeted Population
Certified CDFIs.
- New Targeted Population
(Pre-approved by the CDFI
Fund).
TM02
If the proposed Target Market is a Customized
Investment Area:
Identify the map that represents the Customized
Investment Area, including both qualified and non-
qualified census tracts and Non-Metro
counties/parishes.
Enter map name.
TM03
If the proposed Target Market is an Investment
Area:
TM03.1
What type(s) of Financial Product(s)
and/or Financial Service(s) is needed
within the Investment Area but is not
currently available at a level sufficient to
meet the need?
Select all that apply:
- Consumer loans.
- Non-real estate business
loans.
- Non-Real Estate
Microenterprise loans.
- Equity Investments.
- Home purchase loans.
- Home Improvement loans.
- Real estate
87
Section
Question or purpose of data field
Response
Construction/Permanent/
Acquisition w/o Rehab
Commercial loans.
- Real estate
Construction/Housing
Multi-Family loans.
- Real estate
Construction/Housing
Single-Family loans.
- Real estate
Rehabilitation
Commercial.
- Real estate
Rehabilitation/Housing
Multi-Family rehab loans.
- Real estate
Rehabilitation/Housing
Single-Family rehab loans.
- Access to affordable
Financial Services
(Depository Institutions
only).
- Other.
TM03.1a
If Other, explain.
Provide explanation.
TM03.2
Indicate the basis for the Applicant’s
determination both that there exists a
significant need for the Financial
Products and/or Financial Services
identified within the Investment Area
and that they are not currently available
at sufficient levels to meet the existing
need.
Provide narrative.
TM04
If the Applicant selected “New Targeted
Population” in question TM01, has the new
Targeted Population been pre-approved by the
CDFI Fund?
Yes or No.
If No, the Applicant cannot
propose a new Targeted
Population.
If “Yes”:
TM04.1
Enter the name of the new Targeted
Population exactly as it appears in the
approval letter from the CDFI Fund.
Enter name.
TM05
Is the Applicant proposing multiple Target Markets?
Yes or No.
If Yes, the Applicant will need to
repeat the Target Market data
entry for each proposed Target
88
Section
Question or purpose of data field
Response
Market component.
TM06
Does the Applicant propose to use the Financial
Services option to meet the required Target Market
activity threshold?
Yes or No.
TM07
Target Market assessment methodology attestation
Financial Product(s) and/or Financial Service(s):
Applicant attests that only a CDFI Fund-approved
Target Market assessment methodology(ies) was
and will continue to be used to determine whether
or not Financial Product transactions and/or
depository accounts have been directed to an
eligible Target Market.
Yes or No.
TM08
Identify the Target Market assessment
methodology(ies) used by the Applicant.
Select all that apply:
- OTP-AA.1: Self-Report.
- OTP-AA.2:
Visual/Surname.
- OTP-Hisp.1: Self-Report.
- OTP-Hisp.2:
Visual/Surname.
- OTP-Native American.1:
Self-Report.
- OTP-Native American.2:
Tribal Identification
Verification.
- OTP-Native Alaskan.1:
Self-Report.
- OTP-Native Alaskan.2:
Tribal Identification
Verification.
- OTP-Native Hawaiian.1:
Self-Report.
- OTP-Native Hawaiian.2:
Origins Identification
Verification.
- OTP-Pacific Islander.1:
Self-Report.
- OTP-Filipino.1: Self-Report.
- OTP-Vietnamese.1: Self-
Report.
- OTP-PWD.1: Self-Report.
- OTP-PWD.2:
Visual/Auditory/
Documentation.
- OTP-PWD.3: Technology/
Accessibility.
- OTP-Certified CDFI.1:
89
Section
Question or purpose of data field
Response
Certified CDFI.
- LITP.1: Documented Full
Family Income.
- LITP.2: Programmatic
Proxy.
- LITP.3: Self-Reported
Family Income.
- LITP.4: Documented
Underwriting Income and
Default Family Size.
- LITP.5 Organization Proxy.
- IA.1: Residence.
- IA.2: Project/Service.
- Separately approved
assessment methodology.
TM08.1
If LITP.2 (programmatic proxy),
identify the Low-Income programmatic
proxy.
Select all that apply:
- Child and Adult Care Food
Program (CACFP).
- Children’s Health
Insurance Program (CHIP).
- Food Distribution Program
on Indian Reservations
(FDPIR).
- Head Start Program.
- HOME Investment
Partnership Program
(HOME).
- HUD Public Housing.
- HUD Section 8 Housing
Choice Voucher Program.
- Job Corps Program.
- Lifeline Discounted Phone
Program.
- Medicaid Program.
- National School Lunch
Program (NSLP).
- Pell Grants for Higher
Education.
- School Breakfast Program
(SBP).
- Social Security Disability
Insurance (SSDI).
- Special Supplemental
Nutrition Program for
Woman, Infants, and
Children (WIC).
- Summer Food Service
90
Section
Question or purpose of data field
Response
Program (SFSP).
- Supplemental Nutrition
Assistance Program
(SNAP)/Food Stamps.
- Supplemental Security
Income (SSI).
- Temporary Assistance for
Needy Families (TANF).
- USDA Single Family
Housing Direct Home
Loans (Section 502 Direct
Loan Program).
TM08.2
If “LITP.5” (Organization Proxy), identify
the Low-Income organization proxy.
Select all that apply:
- Federal Qualified Health
Centers (FQHC).
- Free and Charitable Clinics.
- Homeless Service
Providers.
- Rural Health Clinics (RHC).
- School-Based Health
Centers (SBHC).
TM08.3
If “Separately approved assessment
methodology:
TM08.3a
Identify the name of the
Target Market assessment
methodology(ies) that was
separately approved by CDFI
Fund.
Enter Name.
TARGET MARKET GENERAL FINANCIAL PRODUCTS AND FINANCIAL SERVICES ACTIVITY
INFORMATION
Section
Question or purpose of data field
Response
TM-G01
Financial Product transaction types closed by the
Applicant during its most recently completed fiscal
year.
[The Financial Product types will
auto-populate based on
information provided in BI-
FP03.]
TM-G02
Does the Financial Product activity data include any
other similar financing that does not appear on the
approved list of Financial Products?
[Auto-populated based on
response to BI-FP04.]
Question TM-G03 will be asked only of depository institution Applicants that have selected to use
Financial Services to meet the Target Market test.
TM-G03
Identify all of the Financial Services account types for
which the Applicant’s depository account holders had
open as of the last day of last full month completed just
Select all that apply:
- Savings/Share Accounts.
- Checking Accounts.
91
Section
Question or purpose of data field
Response
prior to submission of the CDFI Certification
Application.
- Certificates of Deposit.
- Money Market
Accounts.
TARGET MARKET ACTIVITY APPLICANT AND RELEVANT AFFILIATE(S) FINANCIAL PRODUCT AND
FINANCIAL SERVICES ACTIVITY BY FINANCIAL PRODUCT/FINANCIAL SERVICES CATEGORY AND TARGET
MARKET COMPONENT (MOST RECENTLY COMPLETED FISCAL YEAR)
Applicant and relevant Affiliate(s) data, presented by Financial Product category, will be collected in the
TLR. The data must include all Financial Product transactions, by number and dollar amount, that were
closed during the Applicant’s most recently completed fiscal year. Transactions provided to the
proposed Target Market components must be identified in the TLR in order to count toward the 60%
requirement. To be approved for each Target Market component identified in the TLR, the Applicant will
need to demonstrate the appropriate level of accountable board members using appropriate sources of
accountability.
(Simulated Table actual display in AMIS may differ)
Target Market Table 1: Financial Products Test
Proposed Target Market
Components
Percentage of Target Market
Financial Products Number
Percentage of Target Market
Financial Products Dollar
Volume
[Auto-display each separate
TM component by row.]
[Auto-calculated.]
[Auto-calculated.]
Total Target Market Activity
[Auto-calculated.]
[Auto-calculated.]
Target Market threshold met?
[Auto-display Yes or No.]
[Auto-display Yes or No.]
Depository Institutions selecting the option to use Financial Services to meet the Target Market test
because either their Target Market Financial Product dollar volume or their Target Market Financial
Product number is between 50% and 59% must also enter the data for all relevant, unique depository
account holders as of the fiscal year end in the TLR.
(Simulated Table actual display in AMIS may differ)
Target Market Table 2: Financial Services Test
Proposed Target
Market Components
Percentage of Target
Market Financial
Products Number
Percentage of
Target Market
Financial Products
Dollar Volume
Percentage Target
Market unique
depository account
holders
[Auto-display each
separate TM
component by row.]
[Auto-calculated.]
[Auto-calculated.]
[Auto-calculated.]
Total Target Market
Activity
[Auto-calculated.]
[Auto-calculated.]
[Auto-calculated.]
Target Market
threshold met?
[Auto-display Yes or
No.]
[Auto-display Yes
or No.]
[Auto-display Yes or
No.]
92
DEVELOPMENT SERVICES
To be a Certified CDFI, the Applicant must have a track record of providing Development Services in
conjunction with its Financial Products and/or Financial Services either directly, through an Affiliate, or
through a contract with another provider. Development Services are defined in the CDFI Fund’s
regulation as activities undertaken by a CDFI, its Affiliate or contractor that promote community
development and shall prepare or assist current or potential borrowers or investees to use the CDFIs
Financial Products or Financial Services.
39
An eligible Development Service is a structured training, counseling, or technical assistance service that
promotes access to and/or success with an entity’s Financial Products and Financial Services. A
structured Development Service should be offered regularly to eligible clients, have a defined curriculum
or written set of goals and objectives, and the outcome of success may be the completion of a specific
step that prepares current or potential customers to access or increase their knowledge about the
CDFI’s Financial Products and Financial Services.
A Development Service may be delivered in a classroom setting or one-on-one, in person or online, and
with or without a live instructor or facilitator. Development Services delivered without a live instructor
or facilitator must be well-developed online trainings with learning modules that include a method of
requiring the engagement of viewers and measuring their increased knowledge.
CDFI Certification Applicants must
- demonstrate that at least one Development Service is regularly offered to an Applicant’s clients
(or for DIHCs, its Affiliate’s clients) and is provided at least once per year;
- demonstrate that Development Service(s) provided via contract with a third-party entity or
third-party software platform are routinely reviewed and monitored, which may include such
activities as determining appropriateness of topics and outcomes, observing sessions with
borrowers, and/or obtaining customer feedback on the Development Service; and
- clearly identify how the Development Service(s) provided by the Applicant, an Affiliate, a third-
party entity under an agreement, or a third-party software platform prepares or assists current
or potential borrowers or investees to use at least one of the Applicant’s (or, for DIHCs, an
Affiliates) Financial Products or Financial Services.
A Development Service is separate and distinct from routine customer service, such as providing a
prospective or existing customer, borrower, or investee information about, or assistance completing, an
application for an Applicant’s Financial Products or Financial Services. Development Services should
address subject matter that prepares consumers to access and be successful in using an entity’s
Financial Products (e.g., first-time homebuyer counseling for prospective mortgage borrowers, financial
or credit counseling; or business planning and management assistance) and Financial Services (e.g.,
financial education that promotes the opening of a depository account or promotes savings).
Per regulation, the Development Service must be directed toward the use of the Applicant’s Financial
Products or Financial Services and not those of another entity. A CDFI does not need to establish that
participants in any Development Service actually secured financing from the CDFIonly that the
39
12 CFR § 1805.104 Definitions.
93
Development Service reasonably prepares them to access a Financial Product or Financial Service that
the CDFI offers at the time that the Development Service is offered.
For example, homebuyer counseling is a Development Service that may occur well in advance of a client
being prepared to access mortgage financing. However, a CDFI could not count housing counseling as a
Development Service if it did not offer a Financial Product or Service related to home purchase.
Depository institution Applicants are allowed to identify financial education as a Development Service if
it promotes opening a depository account or building savings in an account with the Applicant.
The CDFI Fund does not consider the following activities to be Development Services:
- responding to routine questions or providing routine explanation or instruction to prospective
or existing customers, borrowers, or investees on applying for the Applicant’s Financial Products
or Financial Services.
- underwriting completed applications for Financial Products or Services.
- training, counseling, or technical assistance not clearly intended to prepare consumers to access
and/or be successful with a Financial Product offered by the Applicant. Examples of such
services include workforce development, parenting training/support groups, and
training/counseling intended solely to enable consumers to access financing provided by other
entities.
- making referrals, whether it be to training, counseling, or technical assistance available to
services provided at the discretion of other entities.
- information presented in newsletters, fliers, or online (e.g., the Applicant’s website or blog posts
and distinct from online training described above).
- workshops for youth (other than financial education that promotes opening a depository
account or building savings in an account with the Applicant).
- Conferences/workshops for broad audiences.
- presentations made at one-off events (e.g., annual conferences, fairs, or non-recurring events)
or at events held by other entities.
- marketing events/activities.
- unstructured conversations with consumers on Development Services subject matter. (A series
of one-on-one, goal-oriented conversations with consumers that have measurable outcomes,
however, may count as Development Services.)
As a rule of thumb, if an activity takes less than 30 minutes to deliver, it is very unlikely to meet the
definition of a Development Service, though it may be a segment, component, or module in the delivery
of a Development Service.
For clarity, the CDFI Fund does not prohibit CDFIs from providing services that do not meet the
definition of Development Services. However, those activities cannot be counted as Development
Services.
94
Applicants participating in the CDFI Fund’s Bond Guarantee Program
Entities applying for Certification solely for participation as Eligible CDFIs
40
in the CDFI Fund’s CDFI BG
Program may be exempt from the following Development Services requirements that require
training/counseling to be
- offered to non-Affiliated third-party individuals or entities; and
- provided in connection with Financial Products that the Applicant directly financed at arm’s
length.
To qualify for this exemption, the training/counseling and/or the related non-arm’s-length financing
products or services must be provided to a Controlling Certified CDFI. Such activities must be pursuant
to operating agreements that include management and ownership provisions and that are in a form and
substance acceptable to the CDFI Fund (see 12 CFR 1805.201(b)(2)(C)(ii-iii)), and the relevant
training/counseling must meet all other Development Services requirements.
Section
Question or purpose of data field
Response
DS01
Does the Applicant seek to use the CDFI
Certification provision for BG Program
participation to meet the CDFI Certification
Development Services requirements?
Yes or No.
If “Yes”:
DS01.1
If the Applicant seeks to meet the CDFI
Certification Development Services
requirements using
training/counseling it offers to an
Affiliated Controlling Certified CDFI:
Identify the page number(s) and/or
section(s) of the operating agreement
between the Applicant and a
Controlling Certified CDFI that
indicates that the training/counseling
activity is provided to the Controlling
Certified CDFI, and provide the
relevant text.
Enter page number(s) and/or
section(s), and provide relevant
text.
DS01.2
If the Applicant seeks to meet the CDFI
Certification Development Services
requirements using
training/counseling it provides in
connection with a financing product(s)
it offers on-balance sheet, but to an
Affiliated Controlling Certified CDFI:
Enter page number(s) and/or
section(s), and provide relevant
text.
40
Eligible CDFI means a Certified CDFI that has submitted an application to a Qualified Issuer for a Bond Loan,
has been deemed creditworthy based on the Bond Loan Requirements, and has received a Bond Loan.
95
Section
Question or purpose of data field
Response
Identify the page number(s) and/or
section(s) of the operating agreement
between the Applicant and a
Controlling Certified CDFI, indicating
such financing product(s) for which
training/counseling is being provided
is offered to a Controlling Certified
CDFI, and provide the relevant text.
DS01.3
Attach the Operating Agreement
between the Applicant and a
Controlling Certified CDFI.
Attach Operating Agreement.
DS02
Identify the purpose of the Financial Product(s)
or Financial Service(s) that is offered by the
Applicant and connected to the Development
Service being offered by the Applicant.
Select all that apply:
- Home purchase.
- Home improvement.
- Real estate
Construction/
Permanent/Acquisition
without Rehabilitation
Commercial.
- Real estate
ConstructionHousing
Multi-Family.
- Real estate
ConstructionHousing
Single Family.
- Real estate
Rehabilitation
Commercial.
- Real estate
RehabilitationHousing
Multi-Family.
- Real estate
RehabilitationHousing
Single Family.
- Consumer.
- Non-real estate business.
- Non-Real Estate
Microenterprise.
- Climate-centered finance.
- Checking account.
- Savings account.
- Other.
DS02.1
If “Other, describe the Financial
Product or Financial Service.
Provide narrative.
DS03
Identify the topic of a Development Service
currently offered by the Applicant (directly or
Select all that apply:
- Financial
96
Section
Question or purpose of data field
Response
through another provider/resource) to un-
Affiliated third parties that promotes success
with at least one of the Applicants Financial
Products or Financial Services.
Education/Financial
Literacy.
- Credit-Building.
- Financial Management.
- Small Business
Development.
- Homeownership
Counseling/Foreclosure
Prevention.
- Nonprofit Capacity-
Building.
- Affordable
Housing/Commercial Real
Estate Development.
- Basic Banking Skills.
- Financial
Management/Budgeting.
- Banking for businesses.
- Other.
DS03.1
If “Other, describe the topic and
explain how it is relevant as a
Development Service.
Provide narrative.
DS03.2
Provide a description of the
Development Service offered
including format, frequency, and how
it prepares the current or potential
customers, borrowers, or investees to
use at least one of the Applicants
Financial Products or Financial
Services.
Provide narrative.
DS04
Identify the entity that provides one or more
Development Services.
Select all that apply:
- Applicant.
- Affiliate(s).
Non-Affiliate(s) (e.g., contractor).
DS04.1
If “Non-Affiliate, provide agreement.
Attach Agreement(s).
DS04.2
Does the agreement identify the
Development Service topics?
Yes or No.
If “No, the related Development
Service cannot be used.
DS04.3
Does the agreement describe how the
contracted third-party entitys activity
is routinely reviewed and monitored?
Select Yes or No.
If No, the related Development
Service cannot be used.
DS04.4
Does the agreement identify the
Development Service outcomes?
Select Yes or No.
If No,” the related Development
97
Section
Question or purpose of data field
Response
Service cannot be used.
DS04.5
Does the agreement identify the
number of sessions for the
Development Service?
Select Yes or No
If “No, the related Development
Service cannot be used.
DS04.6
Does the agreement identify the
mechanism for obtaining customer
feedback on the Development
Service?
Select Yes or No.
If “No, the Development Service
cannot be used.
A minimum of one Development Service must be offered and presented in the CDFI Certification
Application. However, the Applicant may present up to three Development Service activities offered
by the Applicant, an Affiliate, or a non-Affiliated third party. Repeat the data entry for each relevant
Development Service.
ACCOUNTABILITY
To be a Certified CDFI, an entity must demonstrate accountability to allowed CDFI Certification Target
Markets component(s) for itself and, if applicable, for any entity relevant to its CDFI Certification
collective review process by having a sufficient level of accountable individuals on its relevant governing
board and/or formal advisory board. As an option for credit unions only, demonstrating a sufficient level
of accountable individuals on an advisory board and having a sufficient level of credit union members
that are part of the credit union’s allowed Target Market component(s). Individual accountability to a
Target Market may be demonstrated through any of the following means:
Investment Area (IA)
Low-Income Targeted
Populations (LITP)
Other Targeted Population
(OTP)
Primary residence in a qualified
census tract.
Status as a Low-Income
individual.
Status as a member of the
Targeted Population.
Status as an owner of a small
business primarily located in a
qualified census tract(s) or
owner of a small business that
principally employs and/or
principally provides goods or
services to residents of the
qualified census tracts of an IA.
Status as a staff member of a
non-Affiliated, third-party,
community development
mission-driven organization that
primarily provides services to
Low-Income people.
Status as a staff member of a
Certified CDFI (OTP-CDFI only).
Status as an elected official
primarily representing residents
of qualified census tracts.
Status as a staff member of a
non-Affiliated, third-party,
community development
mission-driven organization that
primarily provides services to
people with disabilities (OTP
Persons with Disabilities only).
98
Investment Area (IA)
Low-Income Targeted
Populations (LITP)
Other Targeted Population
(OTP)
Status as a staff member of a
non-Affiliated, third-party,
community development
mission-driven organization that
primarily provides services to
residents of a qualified census
tract(s).
Status as a family member
41
of a
person with disabilities (OTP
Persons with Disabilities only).
Enrollment in a federally
recognized tribe (Applicants
serving IAs located in Native
geographies only).
ACCOUNTABILITY METHODS
Applicants must demonstrate individual and, if required, collective accountability to their proposed
Target Market(s) through one of the following options:
Option 1: Governing Board Only
- At least one governing board member is accountable to each proposed Target Market type, and
- At least 33% of the governing board is accountable to the overall proposed Target Market(s).
Option 2: Governing Board Supplemented by Advisory Board
- At least 20% of the governing board members are accountable to the overall proposed Target
Market;
- At least one advisory board member is accountable to each proposed Target Market type;
- At least 60% of the advisory board is accountable to the overall proposed Target Market(s);
- At least one governing board member is also a member of the advisory board; and
- The Applicant has adopted an advisory board policy.
Option 3: Advisory Board Supplemented by Credit Union Membership (Credit Union Applicant Only)
- At least 33% of the credit union’s members are determined to be members of at least one
Target Market type in the overall proposed Target Market, using a CDFI Fund-approved Target
Market assessment methodology;
- At least one advisory board member is accountable to each proposed Target Market type;
- At least 60% of the advisory board is accountable to the overall proposed Target Market(s);
- At least one governing board member is also a member of the advisory board; and
- The Applicant has adopted an advisory board policy.
Option 4: Advisory Board Only (DIHCs, IDIs, and entities without a formal governing board only)
- At least one advisory board member is accountable to each proposed Target Market type;
- At least 80% of the advisory board is accountable to the overall proposed Target Market(s);
41
Family members include those related by blood (including half-siblings), adoption, or marriage.
99
- At least one governing leadership member of the Applicant entity is also a member of the
advisory board; and
- The Applicant has adopted an advisory board policy.
BOARD TYPE AND SIZE REQUIREMENTS
For a board to be accepted as a means of CDFI Certification Accountability, it must be a governing board
duly established and operating in accordance with the legal and regulatory requirements that apply to
the entity it serves or an advisory board established by the governing board for the entity the advisory
board serves and operating in accordance with an advisory board policy adopted by that entity and any
legal and regulatory requirements that may exist.
For the purposes of CDFI Certification, the CDFI Fund requires that a governing board consist of no less
than three members and that an advisory board consist of no less than five members.
COLLECTIVE REVIEW FOR DIHCs, AFFILIATES OF DIHCS, OR SUBSIDIARIES OF IDIs
For a DIHC, an Affiliate of a DIHC, or a Subsidiary of an IDI to be certified as a CDFI, it must demonstrate
Accountability to its CDFI Certification Target Market, both
- individually to its own Target Market, based on its own Accountability method; and
- collectively, where any entity relevant to the CDFI Certification collective review process must
also demonstrate Accountability to the Applicant’s CDFI Certification Target Market via its own
allowable Accountability method; or, if the related entity does not engage in its own Financial
Product activity, via the Accountability of an entity that Controls it (there must be formally
approved documentation demonstrating a Control relationship), even if it has not adopted the
board(s) used as a means of Accountability by the Controlling entity as its own board(s).
DIHC and IDI Applicants may meet the Accountability requirements through use of an Affiliate’s
governing board as an advisory board if that governing board meets the Accountability requirements
described in Option 1 above.
Assessing an Advisory Board
The CDFI Fund will assess an advisory board to verify that
- the advisory board’s role includes providing input to the governing leadership on strategic and
policy matters;
- the members of the advisory board are appointed by a duly documented action of the governing
board;
- the advisory board is made up of no less than five active members;
- the advisory board meets at least three times per year; and
- the advisory board is established and governed by an advisory board policy that meets the
standards described below.
Assessing an Advisory Board Policy
An organizational advisory board policy can be a stand-alone document or can be incorporated into an
Applicant’s governance or organizing document. At minimum, an advisory board policy must include a
description of the following:
100
- the purpose of the advisory board and the scope of topics or strategic policy matters on which
the advisory board provides input or advice to the governing board or owners;
- how the input that the advisory board provides to the governing board is documented (for
example: regular meetings with the governing leadership, the inclusion of advisory board
meeting minutes in governing leadership meeting packets, written reports providing feedback
on decisions related to strategic policy matters, etc.);
- the process by which individuals are selected and approved as members of the advisory board;
and
- how the advisory board seeks input from, and/or reviews data on the financial needs and
opportunities in, the Target Market(s) for which it provides accountability.
FINANCIAL INTEREST CONFLICTS WITH ACCOUNTABILITY
Board members with certain types of financial interest in an Applicant (either directly or via a family
member) may not be considered accountable to any of the Applicant’s Target Market components, as
the financial interest may conflict with the board members ability to effectively represent the interests
of the Target Market. Governing board and advisory board members who are principals (i.e., individuals
who owns at least 25% of or Controls an entity, either individually or in combination with other family
members) or staff members of the Applicant organization or its Subsidiaries or Affiliates, or whose
family members are principals or staff members, cannot be used to demonstrate Target Market
Accountability. In addition, to avoid a financial conflict of interest, Applicants with board members who
have active Financial Products from the Applicant, or whose family members or employer have active
Financial Products from the Applicant, should have policies requiring such board members to recuse
themselves from any decision that may affect, directly or indirectly their Financial Product or
relationship.
For purposes of determining a financial Accountability conflict, covered family members include
spouses, children (including step-, in-law, and adopted children), and other members of the board
member’s family (i.e., siblings [including step-, half, and in-law siblings], parents [including step- and in-
law parents], and grandparents related by blood or adoption).
MAPPING REQUIREMENTS
Maps are required where noted to confirm board member accountability.
CIMS provides mapping and geocoding capabilities to support the Application process and to assess the
eligibility of board member source of accountability. Through CIMS, Applicants are able to upload and
process the accurate batch geocoding of addresses to confirm addresses and geographies being served.
ACCOUNTABILITY GENERAL INFORMATION
The Applicant will enter all relevant board and board member data for questions AC01 through AC05 for
each board presented.
Section
Question or purpose of data field
Response
AC01
Does the Applicant need to demonstrate
Accountability for the CDFI Certification collective
review process?
Yes or No.
101
Section
Question or purpose of data field
Response
AC01.1
If “Yes, identify the entity being
presented for the collective review.
Select one:
- Applicant.
- CDFI Certification collective
review related entity
Accountability CDFI
Certification collective
review Controlling Entity.
AC02
If related entity is selected, identify the relevant
Affiliate.
Select name from AMIS board
record.
AC03
If Controlling Entity:
AC03.1
Does the Applicant or relevant related
entity engage in the direct provision of
Financial Products or Financial Services?
Yes or No.
If Yes, the Applicant’s
Accountability cannot be provided
by the Controlling entity.
AC03.1a
If “No, identify the
Controlling Entity providing
Accountability.
Select name from AMIS board
record.
AC03.2
Provide document that demonstrates the
entity providing Accountability is a
Controlling Entity.
Attachment.
AC04
Method of Accountability Applicant.
Select one:
- Governing board only.
- Governing board and
advisory board.
- Advisory board and credit
union membership (credit
union only).
- Advisory board only (DIHCs,
IDIs, and those with no
formal governing board
only).
AC05
Method of Accountability Affiliate(s).
Select one:
- Governing board.
- Governing board and
advisory board.
- Credit union membership
and advisory board (credit
unions only).
- Advisory board only (DIHCs,
IDIs, and those with no
formal governing board
only).
102
ACCOUNTABILITY GOVERNING AND/OR ADVISORY BOARD
Section
Question or Purpose of data field
Response
AC-GA01
Will the Applicant or any relevant Affiliate use its
governing board to maintain Accountability to
the Applicant’s proposed Target Market(s)?
Yes or No.
AC-
GA01.1
If Yes, identify the governing
board.
Select from AMIS Board Record.
AC-GA02
Will the Applicant or any relevant Affiliate use
credit union membership and an advisory board
to maintain Accountability to the Applicant’s
proposed Target Market(s)?
Yes or No.
If “Yes”:
AC-
GA02.1
Enter the total number of credit union
members active with the entity as of
the end of the most recently
completed Fiscal Year prior to the
submission of the Application.
Enter number.
AC-
GA02.2
Identify the Target Market component
type(s) formally identified for the
entity presenting its accountability
information that will be used to
demonstrate accountability through
credit union membership.
Select one:
- Investment Area Pre-
qualified.
- Investment Area
Customized.
- Investment Area Non-
Metro Customized.
- Investment Area Non-
Metro counties/parishes.
- Low-Income Targeted
Population.
- Other Targeted Population
African American.
- Other Targeted Population
Hispanic.
- Other Targeted Population
Native American.
- Other Targeted Population
Native Alaskan.
- Other Targeted Population
Native Hawaiian.
- Other Targeted Population
Other Pacific Islander.
- Other Targeted Population
Filipino.
- Other Targeted Population
Vietnamese.
- Other Targeted Population
Persons with Disabilities.
103
Section
Question or Purpose of data field
Response
- Other Targeted Population
Certified CDFIs.
- New Targeted Population
(Pre-approved by the CDFI
Fund).
AC-
GA02.2a
If “New Targeted
Population,” enter the
name of the Targeted
Population exactly as it
appears in the approval
letter from the CDFI Fund.
Enter name.
AC-
GA02.3
Enter the total number of credit union
members who are members of the
Target Market identified in AC-
GA03.2.
Enter the total number of credit
union members who are members
of the Target Market.
AC-
GA02.4
Calculate percentage of credit union
members who are members of the
Target Market identified in AC-
GA03.2.
[Auto-calculated.]
AC-
GA02.5
Applicant attests that only a CDFI
Fund-approved Target Market
assessment methodology(ies) has
been and will continue to be used to
determine whether credit union
members are of an eligible Target
Market.
Yes or No.
If No, the advisory board and
credit union membership Native
Communities level method of
Accountability cannot be used.
AC-GA03
Will the Applicant or any relevant Affiliate use an
advisory board to maintain accountability to the
proposed Target Markets(s)?
Yes or No.
If “Yes”:
AC-
GA03.1
Identify the advisory board.
Select from AMIS Board Record.
AC-
GA03.2
Does the Applicant have an advisory
board policy that has been board
approved?
Yes or No.
If No, the Applicant is unable to
use an advisory board for
Accountability.
If “Yes”:
AC-
GA03.2a
Does the policy describe
the role of the advisory
board?
Yes or No.
If No, the Applicant is unable to
use the advisory board for
Accountability.
AC-
GA03.2b
Does the policy require
that the advisory board be
made up of no less than
Yes or No.
If No, the Applicant is unable to
104
Section
Question or Purpose of data field
Response
five members that are
appointed through a duly
documented action of the
governing board?
use the advisory board for
Accountability.
AC-
GA03.2c
Does the policy describe
how the input that the
advisory board provides to
the governing board is
documented?
Yes or No.
If No, the Applicant is unable to
use the advisory board for
Accountability
AC-
GA03.2d
Does the policy describe
how the advisory board
seeks input from and/or
reviews data on the
financial needs and
opportunities in the Target
Market(s) for which it
provides accountability?
Yes or No.
If No, the Applicant is unable to
use the advisory board for
Accountability.
AC-
GA03.2e
Does the policy state the
advisory board meets at
least three times a year?
Yes or No.
If No, the Applicant is unable to
use the advisory board as a means
of Accountability.
AC-
GA03.2f
Attach the board-approved
advisory board policy.
Attach.
Applicants will enter all relevant board member data in questions AC-GA04 through AC-GA11 for
each board and for each board member.
AC-GA04
Total number of board members.
Enter number.
AC-GA05
Board member name.
Enter name.
AC-GA06
If the Applicant is using an advisory board to
meet the Accountability test, does the member
of the advisory board also serve on the
Applicant’s governing board, or is the member
also a partner/owner?
Yes or No.
AC-GA07
Is this board member or any covered member of
their family
42
an employee of the Applicant or any
of its Affiliates?
Yes or No.
If Yes, no further information on
this board member is required as
this board member is ineligible to
be presented as accountable.
If No, continue to the next
question.
42
Covered family members include spouses, children (including step-, in-law, and adopted children), or other
family members of the board member’s household (i.e., siblings [including step-, half-, and in-law siblings], parents
[including step- and in-law parents], and grandparents related by blood or adoption).
105
Section
Question or Purpose of data field
Response
AC-GA08
Does the board member or any covered member
of their family, individually or in combination,
own 25% or more of, or Control, the entity for
which they serve as a board member or any of its
Affiliates?
Yes or No.
If Yes, no further information on
this board member is required as
this board member is ineligible to
be presented as accountable.
AC-GA09
Does the board member, the board member’s
employer, or any covered member of the board
member’s family have an active Financial Product
from the Applicant?
Yes or No.
AC-
GA09.1
If Yes, does the Applicant have
policies requiring such board members
to recuse themselves from any decision
that may affect, directly or indirectly,
their Financial Product or relationship?
Yes or No.
If No, no further information on
this board member is required as
this board member is ineligible to
be presented as accountable.
AC-GA10
Is this board member accountable to a Target
Market type(s) in the overall Target Market?
Yes or No.
If No, no further information on
this board member is required.
If Yes, continue to the next
question.
AC-GA11
Identify the Target Market types to which the
board member is accountable.
Select all that apply:
[A list of the Applicant’s Target
Market types will be auto-
populated based on information
entered in TM01.]
Source of Accountability Pre-qualified Investment Area
Questions AC-GA12 through AC-GA17 will be asked only of board members identified as accountable
to a Pre-qualified Investment Area.
AC-GA12
What source(s) of accountability does the board
member use to demonstrate that they are
currently connected to a Pre-qualified Investment
Area?
Select all that apply:
- Primary residence in a
qualified census tract.
- Owner of a small business
primarily located in a
qualified census tract(s).
- Owner of a small business
that principally employs
and/or principally provides
goods or services to
residents of qualified
census tracts.
- Elected official primarily
serving residents of
106
Section
Question or Purpose of data field
Response
qualified census tracts.
- Staff member of a non-
Affiliated, third-party,
mission-driven organization
that primarily provides
services to residents of
qualified census tracts.
- Enrollment in a federally
recognized tribe (for
Applicants serving IAs
located in Native
geographies only).
AC-GA13
If the board member is listed as accountable as a
resident of a qualified census tract, provide the
FIPS
43
code for the census tract in which the
board member resides.
Enter FIPS code.
(Include leading zeros where
appropriate.)
AC-GA14
If the board member is identified as accountable as the owner of a small business that is
primarily located in a qualified census tract or that principally employs and/or
principally provides goods or services to residents of the qualified census tract(s):
AC-
GA14.1
What percentage of ownership does
the board member have in the
business?
Enter percentage.
AC-
GA14.2
What is the name of the small
business owned by the board
member?
Enter name.
AC-
GA14.3
Does the small business have multiple
locations (e.g., a franchise)?
Yes or No.
If “Yes”:
AC-
GA14.3a
Are at least 51% of the
businesses locations in a
qualified census tract(s)?
Yes or No.
AC-
GA14.3b
Create a map in CIMS to
provide the census tracts
for the business locations,
and enter the name of the
map.
Enter map name.
If “No”:
AC-
GA14.3c
Is the business located in a
qualified census tract?
Yes or No.
AC-
GA14.3d
What is the FIPS code of
the business location?
Enter the business FIPS code.
(Include leading zeros where
43
The Federal Information Processing Standards (FIPS) code uniquely identifies states, counties, county
equivalents, and census tracts in the United States, certain U.S. possessions, and certain freely associated states.
107
Section
Question or Purpose of data field
Response
appropriate)
AC-
GA14.4
If the small business(es) is not
primarily located in a qualified census
tract(s), does the business principally
employ residents of a qualified census
tract(s).
Yes or No.
If “Yes”:
AC-
GA14.4
a
Describe how the small
business demonstrates that
it principally employs
residents of a qualified
census tract(s).
Provide narrative.
AC-
GA14.5
If the small business(es) is not
primarily located in a qualified census
tract(s), does the business(es)
principally provide goods or services
to residents of a qualified census
tract(s)?
Yes or No.
If “Yes”:
AC-
GA14.5
a
Create a map(s) in CIMS of
the geography(ies) served
by the small business, and
enter the name of the
map(s).
Enter map(s) name.
AC-
GA14.5
b
If the map does not clearly
evidence primarily serving
qualified census tracts,
describe how the business
demonstrates that it
principally provides goods or
services to residents of a
qualified census tract(s).
Provide narrative.
AC-GA15
If the board member is listed as accountable as an elected official primarily serving
residents of qualified census tracts:
AC-
GA15.1
Identify the elected official’s office
and jurisdiction.
Enter the name of the office and
jurisdiction.
AC-
GA15.2
Create a map in CIMS of the
geography served by the elected
official and enter the name of the
map.
Map name.
AC-GA16
If the board member is listed as accountable as a staff member of a non-Affiliated,
third-party, community development mission-driven organization that primarily
provides services to residents of qualified census tracts:
AC-
GA16.1
Provide the name of the non-
Affiliated, third-party, community
development mission-driven
Enter name.
108
Section
Question or Purpose of data field
Response
organization.
AC-
GA16.2
Provide the mission statement of the
organization primarily serving
residents of qualified census tracts.
Enter mission statement.
AC-
GA16.3
Describe how the organization’s
mission statement allows them to
primarily serve qualified census
tract(s) or primarily serve residents of
a qualified census tract(s)?
Provide narrative.
AC-
GA16.4
If the description does not evidence
that the organization primarily serves
qualified census tract(s) or primarily
serve residents of a qualified census
tract(s), create a map(s) in CIMS of
the geography(ies) served by the
organization, and enter the name of
the map(s).
Enter map(s) name.
AC-
GA16.5
Provide the employee’s job title.
Enter job title.
AC-
GA16.6
Describe how the board members
role in their place of employment can
demonstrate that it primarily serve
residents of qualified census tract(s).
Provide description.
AC-GA17
If the board member is identified as accountable as an enrolled member of a federally
recognized tribe (for Applicants serving an IA(s) located in a Native Communities
geography[ies] only):
AC-
GA17.1
Identify the federally recognized tribe.
Enter name of the federally
recognized tribe.
Source of Accountability Customized Investment Area or non-Metro county/parish Investment
Area
Questions AC-GA18 through AC-GA23 will be asked only for board members identified as accountable
to a Customized Investment Area or non-Metro county/parish Investment Area (eligible geography).
AC-GA18
What source(s) of accountability does the board
member use to demonstrate that the board
member is currently connected to the eligible
geography?
Select all that apply:
- Primary residence in a
qualified census tract of
the eligible geography.
- Owner of a small business
primarily located in a
qualified census tract(s) of
the eligible geography.
- Owner of a small business
that principally employs
and/or principally provides
goods or services to
residents of the qualified
census tract(s) of the
109
Section
Question or Purpose of data field
Response
eligible geography.
- Elected official primarily
serving the residents of
qualified census tracts of
the eligible geography.
- Staff member of a non-
Affiliated, third-party,
community development
mission-driven organization
that primarily provides
services to residents of
qualified census tracts of
the eligible geography.
- Enrollment in a federally
recognized tribe (for
Applicants serving qualified
census tracts of the eligible
geography located in a
Native Communities
geography[ies] only).
AC-GA19
If the board member is listed as accountable as a
resident of a qualified census tract of the eligible
geography, provide the FIPS code for the census
tract in which the board member resides.
Enter FIPS code.
(Include leading zeros where
appropriate.)
AC-GA20
If the board member is listed as accountable as the owner of a small business that is
located in a qualified census tract of the eligible geography or that principally employs
and/or principally provides goods or services to residents of the qualified census tract(s)
of the eligible geography:
AC-
GA20.1
What percentage of ownership does
the board member have in the
business?
Enter percentage.
AC-
GA20.2
What is the name of the business
owned by the board member?
Enter name.
AC-
GA20.3
Does the business have multiple
locations (e.g., a franchise)?
Yes or No.
If “Yes”:
AC-
GA20.3a
Are at least 51% of the
businesses locations in a
qualified census tract of
the eligible geography?
Yes or No.
AC-
GA20.3b
Create a map in CIMS to
provide the census tracts
for the business locations
and enter the name of
the map.
Enter map name.
If “No”:
110
Section
Question or Purpose of data field
Response
AC-
GA20.3c
Is the business located in
a qualified census tract of
the eligible geography?
Yes or No.
AC-
GA20.3d
What is the FIPS code of
the business location?
Enter the business FIPS code.
(Include leading zeros where
appropriate.)
AC-
GA20.4
If the small business(es) is not
primarily located in a qualified census
tract(s), does the business principally
employ residents of a qualified
census tract(s) of the eligible
geography(ies)?
Yes or No.
If “Yes”:
AC-
GA20.
4a
Describe how the small
business demonstrates that
it principally employs
residents of a qualified
census tract(s) of the eligible
geography.
Provide narrative.
AC-
GA20.5
If the small business(es) is not located
in a qualified census tract(s), does the
business(es) principally provide
goods or services to residents of a
qualified census tract(s) of the
eligible geography(ies)?
Yes or No.
If “Yes”:
AC-
GA20.
5a
Create a map(s) in CIMS of
the geography(ies) served
by the small business in an
eligible geography(ies), and
enter the name of the
map(s).
Enter map(s) name.
AC-
GA20.
5b
If the map does not clearly
evidence primarily serving
eligible census tract(s) in the
eligible geography(ies),
describe how the business
demonstrates that it
principally provides goods or
services to residents of a
qualified census tract(s) of
an eligible geography(ies).
Provide narrative.
AC-GA21
If the board member is listed as accountable as an elected official primarily serving
residents of qualified census tracts of the eligible geography:
AC-
Identify the elected official’s office
Enter the name of the office and
111
Section
Question or Purpose of data field
Response
GA21.1
and jurisdiction.
jurisdiction.
AC-
GA21.2
Create a map in CIMS of the
geography served by the elected
official and enter the name of the
map.
Map name.
AC-GA22
If the board member is listed as accountable as a staff member of a non-Affiliated,
third-party, community development mission-driven organization that primarily
provides services to residents of the qualified census tracts of the eligible geography:
AC-
GA22.1
Provide the name of the non-
Affiliated, third-party, community
development mission-driven
organization.
Enter name.
AC-
GA22.2
Provide the mission statement of the
organization primarily serving
residents of the eligible geography.
Enter mission statement.
AC-
GA22.3
Describe how the organization’s
mission statement allows it to
primarily serve qualified census
tract(s) or primarily serve residents of
a qualified census tract(s) in the
eligible geography.
Provide narrative.
AC-
GA22.4
If the description does not evidence
that the organization primarily serves
qualified census tract(s) or primarily
serve residents of an eligible
geography(ies), create a map(s) in
CIMS of the geography(ies) served by
the organization, and enter the name
of the map(s).
Enter map(s) name.
AC-
GA22.5
Provide the employee’s job title.
Enter job title.
AC-
GA22.6
Describe how the board members
employment demonstrates that the
organization primarily serves
residents of qualified census tracts of
the eligible geography.
Provide description.
AC-GA23
If the board member is identified as accountable as an enrolled member of a federally
recognized tribe (for Applicants serving an IA[s] located in a Native Communities
geography[ies] only):
AC-
GA23.1
Identify the federally recognized tribe.
Enter name of the federally
recognized tribe.
Source of Accountability Low-Income Targeted Population
Questions AC-GA24 through AC-GA26 will be asked only for board members identified as accountable
to a Low-Income Targeted Population.
AC-GA24
What source(s) of accountability does the board
member use to demonstrate that the member is
Select all that apply:
- Low-Income individual.
112
Section
Question or Purpose of data field
Response
currently connected to a Low-Income Targeted
Population?
- Staff member of a non-
Affiliated, third-party,
community development
mission-driven organization
that primarily provides
services to Low-Income
people.
AC-GA25
If the board member is listed as accountable to
the Low-Income Targeted Population as a Low-
Income person, does the Applicant attest that the
board member is Low-Income?
Yes, No, or N/A.
AC-GA26
If the board member is listed as accountable as a
staff member of a non-Affiliated, third-party,
community development mission-driven
organization that primarily provides services to
Low-Income people:
AC-
GA26.1
Provide the name of the third-party
organization.
Enter name.
AC-
GA26.2
Provide the mission statement of the
organization.
Enter mission statement.
AC-
GA26.3
Provide the employee’s job title.
Enter job title.
AC-
GA26.4
Describe how the board member’s
place of employment allows the
board member to primarily serve
Low-Income people.
Provide narrative.
Source of Accountability Other Targeted Population
Questions AC-GA27 through AC-GA31 will be asked only for board members identified as accountable
to an Other Targeted Population.
AC-GA27
Other Targeted Population.
What source(s) of accountability does the board
member use to demonstrate that the board
member is currently connected to the Other
Targeted Population?
Select all that apply:
- Member of the Other
Targeted Population.
- Staff member of a Certified
CDFI (OTP-CDFI only).
- Staff member of a non-
Affiliated, third-party,
community development
mission-driven organization
that primarily provides
services to people with
disabilities (OTP Persons
with Disabilities only).
- Family member of a person
with disabilities (OTP
Persons with Disabilities
only).
113
Section
Question or Purpose of data field
Response
AC-GA28
If the board member is listed as accountable as a
member of the Other Targeted Population,
identify the assessment methodology used to
confirm. (See guidance for acceptable means of
assessment by OTP.)
Identify each method used if the board member
is listed as accountable to more than one Other
Targeted Population.
Select all that apply:
- OTP-AA.1: Self-Report.
- OTP-AA.2: Visual/Surname.
- OTP-Hisp.1: Self-Report.
- OTP-Hisp.2:
Visual/Surname.
- OTP-Native American.1:
Self-Report.
- OTP-Native American.2:
Tribal Identification
Verification.
- OTP-Native Alaskan.1: Self-
Report.
- OTP-Native Alaskan.2:
Tribal Identification
Verification.
- OTP-Native Hawaiian.1:
Self-Report.
- OTP-Native Hawaiian.2:
Origins Identification
Verification.
- OTP-Pacific Islander.1: Self-
Report.
- OTP-Filipino.1: Self-Report.
- OTP-Vietnamese.1: Self-
Report.
- OTP-PWD.1: Self-Report.
- OTP-PWD.2:
Visual/Auditory/
Documentation
- OTP-PWD.3: Technology/
Accessibility.
- OTP-Certified CDFI.1:
Certified CDFI.
- LITP.1: Documented Full
Family Income.
- LITP.2: Programmatic
Proxy.
- LITP.3: Self-Reported
Family Income.
- LITP.4: Documented
Underwriting Income and
Default Family Size.
- LITP.5 Organization Proxy.
- IA.1: Residence.
- IA.2: Project/Service.
- Separately approved
114
Section
Question or Purpose of data field
Response
assessment methodology.
If “Separately approved assessment
methodology:
AC-GA28.1
Identify the assessment
methodology(ies) approved by
the CDFI Fund.
Narrative.
AC-GA29
If the board member is listed as accountable as a staff member of a Certified CDFI:
AC-
GA29.1
Provide the name of the Certified
CDFI.
Enter name.
AC-
GA29.2
Provide the employee’s job title.
Enter job title.
AC-GA30
If the board member is listed as accountable as a staff member of a non-Affiliated,
third-party, community development mission-driven organization that primarily serves
people with disabilities:
AC-
GA30.1
Provide the name of the
organization.
Enter name.
AC-
GA30.2
Provide the mission statement of the
organization.
Enter mission statement.
AC-
GA30.3
Provide the employee’s job title.
Enter job title.
AC-
GA30.4
Describe how the board member’s
place of employment allows him/her
to primarily serve people with
disabilities.
Provide description.
AC-GA31
If the board member is listed as accountable as a
family member
44
of a person with a disability,
identify the relationship of the board member to
the person with disabilities.
Select one:
- Spouse.
- Parent.
- Child.
- Sibling.
- Aunt or uncle.
- Grandparent.
- Stepparent.
- Stepchild.
- Step-sibling.
- In-law parent.
- In-law sibling.
Repeat board member data entry for each board member.
Repeat board and board member data entry for each board if multiple boards are being used to
demonstrate accountability.
If there are multiple entities that must demonstrate accountability to the Applicant’s proposed
Target Market, repeat board and all board member data entry for each such entity.
44
Family members include those related by blood (including half-siblings), adoption, or marriage.
115
NON-GOVERNMENT ENTITY
To be a Certified CDFI, the Applicant may not be an agency or instrumentality of the United States
government, or of any State or political subdivision therein. An entity that is created by, or formed in
partnership with a government or government-Controlled entity, or receives substantial assistance from
a government entity may be a CDFI, provided it is not Controlled by such entities and maintains
independent decision-making authority over its activities.
An entity that is operated or Controlled by a tribal government is eligible to apply for Certification.
Indian tribes are not agencies or instrumentalities of the United States or any state.
Transition Away from Government Control
If an Applicant was previously Controlled by a government or government-Controlled entity, it can
demonstrate that it is no longer Controlled by a government entity if its governance, organizing
documents, and board’s activities demonstrate that the following conditions have been met for at least
one year from the date of the change.
- No government or government-Controlled entity has a Controlling ownership interest in the
Applicant by being one of its owners, members, or partners or, if the Applicant issues stock, by
owning or having the power to vote 25% or more of the voting stock shares.
- No government or government-Controlled entity and no officials or employees of any such
entity have the authority to occupy or select who will occupy either the majority or a substantial
minority of the Applicant’s governing leadership positions (e.g., governing/managing board
members, managing member, managing partner, and so on).
- The Applicant’s governing leadership has not consisted of a majority or substantial minority of
officials or employees of a particular government or government-Controlled entity.
Section
Question or purpose of data field
Response
NGE01
Was the Applicant previously Controlled by a
government entity or government-Controlled entity?
Yes or No.
NGE01.1
If Yes, can the Applicant demonstrate
that it has been more than 12 months
since it transitioned from government
control?
Yes or No.
If No, the Applicant is not
eligible for CDFI Certification.
NGE01.2
Attach copy of document(s) that clearly
evidences that the Applicant is no longer
Controlled by a government entity or
government-Controlled entity.
Attach document.
NGE02
Do one or more government entities or officials
Control the election or appointment of a majority of
the members of the Applicants governing board or
Control a substantial minority of such members?
Yes or No.
NGE02.1
If “Yes, explain how this circumstance
is not evidence of government Control.
Provide narrative.
NGE03
Does a government or government-Controlled entity
Yes or No.
116
Section
Question or purpose of data field
Response
have a Controlling ownership interest in the Applicant
as one of its owners, members, or partners or, if the
Applicant issues stock, by owning or having the power
to vote 25% or more of the voting stock shares?
NGE03.1
If “Yes,” explain how this circumstance
is not evidence of government Control.
Provide explanation.
NGE04
Does the Applicant’s governing board contain
members that are government officials (elected,
appointed, employees, etc.)?
Yes or No.
If “Yes”:
NGE04.1
Identify the governing board members
that are government officials.
Select all that apply:
[Auto-populated list of board
members entered in
Accountability section.]
NGE04.1a
Identify the
government agency.
Enter name of government
agency.
NGE04.1b
Identify the board
member’s title and
role with the
government agency.
Enter title and role.
NGE04.2
Does a majority or substantial minority
of the Applicant’s board of directors
consist of government officials (elected,
appointed, employees, etc.)?
Yes or No.
NGE04.2a
If “Yes,” explain how
this circumstance is not
evidence of
government Control.
Provide explanation.
NGE04.3
Does the Applicant’s
organizing/establishing documents or
bylaws require that a certain number of
the Applicant’s governing board be
government employees or
elected/appointed government
officials?
Yes or No.
NGE04.3a
If “Yes,” explain how
this circumstance does
not constitute
government Control.
Provide explanation.
NGE05
Do one or more government entities have veto power
over the selection of the Applicant’s executive
director, CEO, or comparable officer, or over specific
investment decisions?
Yes or No.
NGE05.1
If “Yes,” explain how this circumstance
does not constitute government
Control.
Provide explanation.
117
Section
Question or purpose of data field
Response
NGE06
Does any government entity provide more than 50%
of the Applicant’s operating and/or capital budget?
Yes or No.
If “Yes”:
NGE06.1
Explain how this circumstance does not
constitute government Control.
Provide explanation.
NGE06.2
Does that government entity have the
ability to control the use of those
funds?
Yes or No.
NGE06.3
Attach a copy of the contract or grant
agreement(s) for any government entity
that provides operating and/or capital
funds to the Applicant.
Attachment(s).
NGE06.4
Provide the page number of the
document that provides confirmation.
Enter page number(s).
NGE07
Does any government entity manage any aspect of
the Applicant’s operations?
Yes or No.
NGE07.1
If “Yes,” explain how this circumstance
does not constitute government
Control.
Provide explanation.
NGE08
Are any of the employees of the Applicant
government employees or employees of an
organization Controlled by one or more government
entities?
Yes or No.
NGE08.1
If “Yes,” explain how this circumstance
does not constitute government
Control.
Provide explanation.
NGE09
If the Applicant is Controlled by another entity, is that
entity Controlled by one or more government
entities?
Yes or No.
NGE09.1
If “Yes,” explain how this circumstance
does not constitute government Control
of the Applicant.
Provide explanation.
NGE10
Does 50% or more of the Applicant’s funding to
support programs or activities developed by a
government entity and implemented by the Applicant
on behalf of that government entity come from a
single government entity?
Yes or No.
If “Yes”:
NGE10.1
Explain how this funding does not
constitute government Control.
Provide explanation.
NGE10.2
Attach a copy of contract(s).
Attachment(s).
NGE10.3
Provide the page number of the
document that provides confirmation.
Enter Page Number(s).
118
NATIVE AMERICAN CDFI DESIGNATION
To receive the Native American CDFI designation, an entity must
- meet all other CDFI Certification requirements;
- primarily serve Native Communities, as evidenced by at least 50% of its Financial Product activity
(both number and dollar volume) having been directed to one or more Native Communities
during the Applicant’s most recently completed full fiscal year prior to the submission of the
CDFI Certification Application;
45
and
- demonstrate accountability to at least one Native Community through at least one of the
following options:
ACCOUNTABILITY METHODS
Option 1: Governing Board Only
- At least 33% of the governing board is accountable to a Native Community population or Native
Community geography; and
- At least 50% of such representative board members are members of a Native Community
population(s).
Option 2: Governing Board Supplemented by Advisory Board
- At least 60% of an advisory board is accountable to a Native Community population or Native
Community geography;
- At least 50% of such representative board members are members of a Native Community
population(s);
- At least 20% of the governing board is accountable to a Native Community population or Native
Community geography;
- At least one governing board member is also a member of the advisory board; and
- The Applicant has adopted an advisory board policy.
Option 3: Advisory Board Supplemented by Credit Union Membership (Credit Union Applicant Only)
- At least 33% of the credit union’s members are determined to be either members of a Native
Community population or residents of a Native Community geography, using a CDFI Fund-
approved Target Market assessment methodology;
- At least 60% of the advisory board are accountable to a Native Community population or Native
Community geography;
45
To maintain the designation status, Native American CDFIs must demonstrate compliance with the Native
American CDFI Designation financing activity percentage benchmarks each fiscal year. After initial certification
through this Application, a Native American CDFI that fails to meet the Target Market benchmarks, based on its
Financial Products and/or Financial Services activity, over its most recently completed fiscal year may maintain its
Native American CDFI designation by demonstrating that it met the benchmarks over a three-year period through
the last day of its most recently completed fiscal year—as measured by the data submitted in the CDFI’s three
most recent TLRs, including as part of its Certification Application, if necessary. (A Certified CDFI that fails to meet
the Native American CDFI designation benchmarks for the previous fiscal year in its first ACR submission will have
the option to be evaluated over a two-year period through the last day of its most recently completed fiscal year.)
Native CDFIs that still fall below the Native American CDFI designation benchmarks over three full fiscal years of
financing activity in their TLR (or over two full fiscal years for those with less than two years of Certification under
this Application) will lose the Native American CDFI designation, and no additional cure period will be granted.
119
- At least 50% of such representative board members are members of a Native Community
population(s);
- At least one governing board member is also a member of the advisory board; and
- The Applicant has adopted an advisory board policy.
Option 4: Advisory Board Only (DIHCs, IDIs, and entities without a formal governing board only)
- At least 80% of the advisory board are accountable to a Native Community population or Native
Community geography;
- At least 50% of such representative board members are members of a Native Community
population(s);
- At least one governing leader of the Applicant entity is also a member of the advisory board;
and
- The Applicant has adopted an advisory board policy.
BOARD TYPE AND SIZE REQUIREMENTS
For a board to be accepted as a means of CDFI Certification Accountability, it must be a governing board
duly established and operating in accordance with the legal and regulatory requirements that apply to
the Applicant or an advisory board established by the governing board, in operating accordance with the
Applicant’s advisory board policy and any legal and regulatory requirements that may exist.
For the purposes of CDFI Certification, the CDFI Fund requires that a governing board consist of no less
than three members and that an advisory board consist of no less than five members.
Assessing an Advisory Board
The CDFI Fund will assess an advisory board to verify that
- the advisory board’s role includes providing input to the governing board or ownership on
strategic and policy matters;
- the members of the advisory board are appointed by a duly documented action of the governing
board;
- the advisory board is made up of no less than five active members;
- the advisory board meets at least three times per year; and
- the advisory board is established and governed by an advisory board policy that meets the
standards described below.
Assessing an Advisory Board Policy
An organizational advisory board policy can be a stand-alone document or can be incorporated into an
Applicant’s governance or organizing document. At minimum, an advisory board policy must include a
description of the following:
- the purpose of the advisory board and the scope of topics or strategic policy matters on which
the advisory board provides input or advice to the governing board or owners;
- how the input that the advisory board provides to the governing board is documented (for
example: regular meetings with the governing leadership, the inclusion of advisory board
meeting minutes in governing leadership meeting packets, written reports providing feedback
on decisions related to strategic policy matters);
120
- the process by which individuals are selected and approved as members of the advisory board;
and
- how the advisory board seeks input from and/or reviews data on the financial needs and
opportunities in the Target Market(s) for which it provides accountability.
Native Communities include the following populations: Native American/American Indian, Native
Alaskan, and Native Hawaiian; and the following geographies: Native American areas defined as
federally designated reservations, Hawaiian homelands, Alaska Native Villages, and/or U.S. Census
Bureau-designated Tribal Statistical Areas.
The individual accountability of board members to a Native Community may be demonstrated through
any of the following means:
- membership in a Native Community population;
- Primary Residence in a Native Community geography;
- status as a small business owner, where the business is located in a Native Community
geography;
- status as a small business owner that principally employs and/or principally provides goods or
services to residents of a Native Community geography;
- status as an elected tribal government official serving a Native Community; or
- status as a staff member of a non-Affiliated, third-party, community development mission-
driven organization that primarily provides services to members of a Native Community and/or
residents of Native Community geography.
Note: The statutorily required collective review process for DIHCs, Affiliates of DIHCs, and Subsidiaries
of IDIs, required for the general CDFI Certification, does not apply to the Native American CDFI
designation. However, DIHCs that do not directly provide Financial Products or Financial Services may
rely on the activity of an Affiliate to meet the Native American CDFI designation requirement.
NATIVE AMERICAN CDFI DESIGNATION GENERAL
Section
Question or purpose of data field
Response
NA01
Does the Applicant want to be designated as a
Native American CDFI?
Yes or No.
[If “No,” no further questions in
this section.]
NA02
If the Applicant provided Financial Products to any
Native Community(ies) during the immediate 12 full
months completed prior to submission of the CDFI
Certification Application, identify the Native
Community(ies) that received the Financial Products
and/or the depository accounts.
Select all that apply:
- Native American.
- Native Alaskan.
- Native Hawaiian.
- Native American areas
defined as federally
designated
reservation(s).
- Hawaiian homeland(s).
- Alaska Native Village(s).
- U.S. Census Bureau-
designated Tribal
121
Section
Question or purpose of data field
Response
Statistical Area(s).
NATIVE AMERICAN CDFI DESIGNATION ACTIVITY DIRECTED TO NATIVE COMMUNITIES
Applicant and relevant Affiliate(s) data presented by Financial Product category will be collected in the
TLR. The data must include all Financial Product transactions, by number and dollar, that were closed
during the Applicant’s most recently completed fiscal year. Transactions provided to Native
Communities must be identified in the TLR in order to count toward the 50% requirement for Native
American CDFI designation.
(Simulated Table actual display in AMIS may differ)
Native American CDFI Designation Table 1: Native Financing Test
Percentage of Native
Communities Financial
Products Number.
Native Communities
threshold met?
Percentage of Native
Communities Financial
Products Dollar
Volume.
Native Communities
threshold met?
[Auto-calculated.]
[Auto-display Yes or
No.]
[Auto-calculated.]
[Auto-display Yes or
No.]
Section
Question or purpose of data field
Response
NA-NC01
Is the Applicant a DIHC that does not engage in its own
direct Financial Product or Financial Service activity
and is relying on its Affiliates to meet the CDFI
Certification Financing Entity or Target Market
requirements?
Yes or No.
NA-NC01.1
If “Yes,” identify all Affiliate(s) that are
required to be presented for review in
connection with the CDFI Certification.
Select relevant Affiliates from
Affiliates record.
NA-NC02
Native Communities assessment methodology
attestation Financial Products:
Applicant attests that Financial Product transactions
counted have and will continue to be directed to
Native Communities using the assessment
methodology(ies) that was pre-approved by the CDFI
Fund.
Yes or No.
NA-NC03
Identify the assessment methodology(ies) used by the
Applicant.
Select all that apply:
- OTP-Native American.1:
Self-Report.
- OTP-Native American. 2:
Tribal Identification
Verification.
- OTP-Native Alaskan.1:
Self-Report.
- OTP-Native Alaskan.2:
Tribal Identification
122
Section
Question or purpose of data field
Response
Verification.
- OTP-Native Hawaiian.1:
Self-Report.
- OTP-Native Hawaiian.2:
Origins Identification
Verification.
- Separately approved
assessment
methodology.
If “Separately approved assessment methodology:
NA-NC03.1
Identify the assessment
methodology(ies) approved by the CDFI
Fund.
Provide narrative.
NATIVE AMERICAN CDFI DESIGNATION NATIVE COMMUNITIES ACCOUNTABILITY
Section
Question or purpose of data field
Response
NA-CA01
Identify the Applicant’s Native Communities method
of accountability.
Select one:
- Governing board.
- Governing board and
advisory board.
- Advisory board and
credit union
membership (credit
union only).
- Advisory board only
(DIHCs, IDIs, and
those with no formal
governing board
only).
NA-CA02
Will the Applicant use its governing board to
maintain its Native Communities accountability?
Yes or No.
NA-
CA02.1
If “Yes,” identify the board that will be
used as a means of accountability.
Select board name from
AMIS Board Record.
NA-CA03
Will the Applicant use credit union membership and
an advisory board to maintain Native Communities
accountability?
Yes or No.
If “Yes”:
NA-CA03.1
Enter the total number of credit union
members active with the Applicant as
of the last day of the end of the most
recently completed Fiscal Year prior to
submission of the Application.
Enter number.
NA-CA03.2
Identify the Native Community(ies)
that will be used to demonstrate
Native Community accountability
Select all that apply:
- Native American
areas defined as
123
Section
Question or purpose of data field
Response
through credit union membership.
federally designated
reservation(s).
- Hawaiian
homeland(s).
- Alaska Native
Village(s).
- U.S. Census Bureau-
designated Tribal
Statistical Area(s).
NA-CA03.3
Enter the total number of credit union
members who are members of the
Native Community(ies) identified in
NA-CA03.2.
Enter the total number of
credit union members who
are members of the Native
Community.
NA-CA03.4
Calculate percentage of credit union
members who are members of the
Native Community(ies) identified in
NA-CA03.2.
[Auto-calculated.]
NA-CA03.5
Applicant attests that only a CDFI
Fund-approved Target Market
assessment methodology(ies) has
been and will continue to be used to
determine whether credit union
members are of a Native
Community(ies).
Yes or No.
If “No,” the advisory board
and credit union
membership Native
Communities level method
of Accountability cannot be
used.
NA-CA04
Will the Applicant use an advisory board to maintain
its Native Community accountability?
Yes or No.
If “Yes”:
NA-CA04.1
Identify that advisory board.
Select Board Name from
AMIS Board record.
NA-CA04.2
Does the Applicant have an advisory
board policy that has been board
approved?
Yes or No.
If “No,” the Applicant is
unable to use an advisory
board.
If “Yes”:
NA-CA04.2a
Does the policy
describe the role of
the advisory board?
Yes or No.
If “No,” the Applicant is
unable to use an advisory
board for Accountability
NA-CA04.2b
Does the policy
require that the
advisory board be
made up of no less
than five members
Yes or No.
If “No,” the Applicant is
unable to use an advisory
board for Accountability.
124
Section
Question or purpose of data field
Response
that are appointed
through a duly
documented action of
the governing board?
NA-CA04.2c
Does the policy
describe a formal
mechanism for input
from the advisory
board to the
governing leadership?
Yes or No.
If “No,” the Applicant is
unable to use an advisory
board for Accountability.
NA-CA04.2d
Does the policy
describe how the
advisory board seeks
input from, and/or
reviews data on the
financial needs and
opportunities in the
Native
Community(ies) for
which it provides
accountability?
Yes or No.
If “No,” the Applicant is
unable to use the advisory
board as a means of
Accountability.
NA-CA04.2e
Does the policy state
the advisory board
meets at least three
times a year?
Yes or No.
If “No,” the Applicant is
unable to use the advisory
board as a means of
Accountability.
NA-CA04.2f
Attach the board-
approved advisory
board policy.
Attach document(s).
Applicants will enter all relevant board member data in questions NA-CA05 through NA-CA11 for
each board and for each representative board member accountable to a Native Community.
NA-CA05
Total number of board members.
Enter number.
NA-CA06
Representative board member name.
Enter name.
NA-CA07
If the Applicant is using an advisory board to meet
the Native Community accountability test, does this
member of the advisory board also serve on the
Applicant’s governing board, or is the member also a
partner/owner?
Yes or No.
NA-CA08
Is this board member or any member of this person’s
family an employee of the Applicant or any of its
Affiliates?
Yes or No.
If “Yes,” no further
information on this board
member is required, as this
board member is ineligible
to be presented as
125
Section
Question or purpose of data field
Response
accountable.
NA-CA09
Does the board member or any member of this
person’s family, individually or in combination,
control 25% or more of the Applicant or any of its
Affiliates?
Yes or No.
If “Yes,” no further
information on this board
member is required, as this
board member is ineligible
to be presented as
accountable.
NA-CA10
Does the board member, the board member’s
employer, or any member of the board member’s
family have an active Financial Product from the
Applicant?
Yes or No.
NA-
CA10.1
If “Yes,” does the Applicant have
policies requiring such board members
to recuse themselves from any decision
or meeting that may involve decisions,
directly or indirectly, on their Financial
Product or relationship?
If “No,” no further
information on this board
member is required as this
board member is ineligible
to be presented as
accountable.
NA-CA11
Identify the Native Community type to which the
board member is accountable.
Select all that apply:
- Native Community
Geography.
- Native Community
Population.
Source of Accountability Native Community Geography
Questions NA-CA12 through NA-CA16 will be asked only for board members identified as accountable
to a Native Community Geography.
NA-CA12
What sources of accountability does the board
member use to demonstrate that they are currently
connected to a Native Community geography?
Select all that apply:
- Primary residence in
a Native Community
geography.
- Owner of a small
business primarily
located in Native
Community
geography.
- Owner of a small
business that
principally employs
and/or principally
provides goods or
services to residents
of a Native
Community
geography.
126
Section
Question or purpose of data field
Response
- Elected tribal
government official
serving the Native
Community.
- Staff member of a
non-Affiliated, third-
party, mission-driven
organization that
primarily provides
services to residents
of a Native
Community
geography.
NA-CA13
If the board member is a resident of a qualified
census tract of a Native Community geography,
provide the FIPS code for the census tract within
which the board member resides.
Enter FIPS code.
(Include leading zeros where
appropriate.)
NA-CA14
If the board member is identified as accountable as the owner of a small business
that is located in a Native Community geography:
NA-CA14.1
What percentage of ownership does
the board member have in the
business?
Enter percentage.
NA-CA14.2
What is the name of the business
owned by the board member?
Enter name.
NA-CA14.3
Does the business have multiple
locations (e.g., a franchise)?
Yes or No.
If “Yes”:
NA-CA14.3a
Are at least 51% of the
businesses located in
a qualified Native
Community census
tract?
Yes or No.
NA-CA14.3b
Create a map in CIMS
to provide the census
tracts for the business
locations, and enter
the name of the map.
Enter map name.
If “No”:
NA-CA14.3c
Is the business located
in a qualified Native
Community census
tract?
Yes or No.
NA-CA14.3d
What is the FIPS code
of the business
location?
Enter the business FIPS code.
NA-CA14.4
If the small business(es) is not
Yes or No.
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Section
Question or purpose of data field
Response
primarily located in a Native
Community, does the business
principally employ residents of a
Native Community geography(ies)?
If “Yes”:
NA-CA14.5
Describe how the small business
demonstrates that it principally
employs residents of a Native
Community(ies).
Provide narrative.
NA-CA14.6
If the small business(es) is not
primarily located in a Native
Community census tract(s), does the
small business(es) principally provide
goods or services to residents of a
Native Community geography(ies)?
Yes or No.
If “Yes”:
NA-CA14.7
Create a map(s) in CIMS of the
geography(ies) served by the small
business(es), and enter the name of
the maps(s).
Enter map(s) name.
NA-CA14.8
If the map does not clearly evidence
primarily serving qualified census
tracts, describe how the business
demonstrates that it provides goods
and services to residents of a Native
Community geography(ies).
Provide narrative.
NA-CA15
If the board member is an elected tribal government official serving the Native
Community geography:
NA-CA15.1
Provide the elected tribal government
officials office and jurisdiction.
Enter office and jurisdiction.
NA-CA16
If the board member is accountable to a Native Community geography as a staff
member of a non-Affiliated, third-party, community development mission-driven
organization that primarily provides services to residents of the Native Community
geography:
NA-CA16.1
Provide the name of the non-Affiliated
third-party organization.
Enter name.
NA-CA16.2
Provide the mission statement of the
organization.
Enter mission statement.
NA-CA16.3
Identify, in terms of county(ies) or
State(s), the Native Community
geography of the market served by
the organization.
Enter market.
NA-CA16.4
Provide the employee’s job title.
Enter job title
NA-CA16.5
Describe how the board member’s
employment allows the board
member to be connected to the
Provide description.
128
Section
Question or purpose of data field
Response
Native Community geography that
consists of Native census tracts.
Source of Accountability Native Community Population
Question NA-CA17 will be asked only for board members identified as accountable to a Native
Community Population.
NA-CA17
If the board member is a member of a Native
Community Population, identify the assessment
methodology used to confirm. (See guidance for
acceptable means of assessment by OTP.)
Select all that apply:
- OTP-Native American.1:
Self-Report.
- OTP-Native American.2:
Tribal Identification
Verification.
- OTP-Native Alaskan.1:
Self-Report.
- OTP-Native Alaskan.2:
Tribal Identification
Verification.
- OTP-Native Hawaiian.1:
Self-Report.
- OTP-Native Hawaiian.2:
Origins Identification
Verification.
- Separately approved
assessment
methodology.
NA-NC17.1
If “Separately approved assessment
methodology”: identify the
assessment methodology(ies)
approved by the CDFI Fund.
Enter “Separately approved
methodology.”
Repeat board member data entry for each board member.
Repeat board and board member data entry for each board if multiple boards are being used to
demonstrate accountability.