Native CDFI Leaders’ Discussion:
The Community Reinvestment Act NPR
TODAY, July 25, 2:00 to 3:00 p.m. EDT
Today, the Native CDFI Network (NCN) will convene Native CDFI leaders from across the country to discuss the Interagency CRA Notice of Proposed Rulemaking (NPR) for the Community Reinvestment Act. This important conversation will inform NCN’s formulation of its formal comments on the NPR as well as the formal comments that individual Native CDFIs are strongly encouraged to submit. The NPR comment deadline is Friday, August 5, 2022. To review the NPR, the NPR Fact Sheet, and related materials, please click here.
The CRA was signed into law in 1977 to encourage depository institutions to help serve the credit needs of the communities in which they operate, in particular low- and moderate-income (LMI) areas and populations. The CRA also sought to deter discriminatory credit and lending practices against those populations, a practice commonly known as “redlining.” To date, however, the CRA has failed to achieve these goals when it comes to tribal nations and communities. The regulations governing the CRA have not been substantively updated since 1995, so this current process represents a key opportunity for Native CDFI leaders to advise the federal government about how the CRA regulations should be modernized to better serve Native nations and communities generally and Native CDFIs specifically.
CFPB Extends Application Deadline for New Members on 2022 Advisory Committees
The Consumer Financial Protection Bureau (CFPB) has extended its application deadline to July 30, 2022 at 11:59 p.m. EDT for interested candidates to apply to serve on four CFPB advisory committees. CFPB’s advisory committees comprise a wide range of experts and stakeholders who provide input to the Director on a variety of consumer financial issues, as well as on the Bureau’s strategic research planning process and agenda. The advisory committees also allow CFPB to hear directly from small financial institutions.
Interested candidates can visit the Apply to serve on the advisory committees page for more information and for the application link. The advisory committees page has links to the charters and past public meeting videos, agendas, presentations, and minutes.
NCN “Difference Makers” Interview Series:
Julia Nemark and Lakota Vogel
Last week, the Native CDFI Network released its latest edition of “Native CDFIs: Difference Makers for Indian Country,” an interview with Julia Nelmark, who serves as President and CEO of Midwest Minnesota Community Development Corporation (MMCDC) and CEO of White Earth Investment Initiative (WEII), a MMCDC subsidiary. A federally certified Native CDFI, WEII helps create jobs and improve community life for the White Earth Nation and other Native communities across Minnesota through homebuyer education, individual homeownership advising, financial counseling, business and consumer lending, tax preparation support, and other efforts. To read the interview, please click here.
Coming this Thursday: “Difference Makers” sits down with Lakota Vogel, Executive Director of Four Bands Community Fund, Inc., a federally certified Native CDFI based on the Cheyenne River Sioux Reservation in South Dakota whose mission is to create economic opportunity by helping Native people build strong and sustainable small businesses and increase their financial capability to create assets and wealth.
To read the other interviews in NCN’s “Difference Makers” series, please click here.
CDFI Fund Extends Application Deadline for CDFI Equitable Recovery Program Funding
On June 23, 2022, the Community Development Financial Institutions Fund (CDFI Fund) announced the opening of the FY 2022 CDFI Equitable Recovery Program (ERP) round with the public release of a Notice of Funds Availability (NOFA). The NOFA set forth the deadline for submitting the FY 2022 CDFI ERP Application via the CDFI Fund’s Award Management Information System (AMIS) as 11:59 p.m. Eastern Time on August 23, 2022.
Meanwhile, on July 14, NCN hosted a webinar in which the CDFI Fund provided a detailed overview of the CDFI ERP program. To view a recording of this webinar, please click here. In addition to the deadline extensions, the CDFI Fund is also amending the NOFA to clarify eligibility requirements around audited financial statements. Loan funds, venture capital funds, and other Non-Regulated Institution Applicants are required to have audited financial statements for their two most recent historic fiscal years. However, if the audit for the Applicant’s most recent historic fiscal year is not complete as of the due date of the AMIS Application, the Applicant must have audited financial statements for its two historic fiscal years prior to its most recent historic fiscal year. Regulated Institution Applicants that file Call Reports to their regulator are exempt from the requirement to have audits.
Recently, the CDFI Fund announced it will be extending the upcoming deadline to submit CDFI ERP Applications in AMIS to September 22, 2022, at 11:59 p.m. ET. Additionally, the CDFI Fund will be extending the deadline to submit the OMB Standard Form-424 Mandatory via Grants.gov to August 18, 2022. This extension will provide organizations additional time to undertake a thorough review of the CDFI ERP Application requirements and prepare their Application submissions. The CDFI Fund continues to encourage all FY 2022 applicants to submit their CDFI ERP Applications as soon as possible to ensure a successful submission.
An additional webinar will be held to discuss updates to the Application FAQs, available new materials, and to take additional questions. The CDFI Fund will provide separate information on this upcoming webinar.
In addition to the deadline extensions, the CDFI Fund is also amending the NOFA to clarify eligibility requirements around audited financial statements. Loan funds, venture capital funds, and other Non-Regulated Institution Applicants are required to have audited financial statements for their two most recent historic fiscal years. However, if the audit for the Applicant’s most recent historic fiscal year is not complete as of the due date of the AMIS Application, the Applicant must have audited financial statements for its two historic fiscal years prior to its most recent historic fiscal year. Regulated Institution Applicants that file Call Reports to their regulator are exempt from the requirement to have audits.
The CDFI Fund is releasing updated deadlines in anticipation of the publication of an amended NOFA in the Federal Register on July 19, 2022.
The new deadlines are:
- August 18, 2022 at 11:59 p.m. ET: Last day to submit OMB Standard Form-424 Mandatory (Application for Federal Assistance) (SF-424)
- August 18, 2022 at 11:59 p.m. ET: Last day to enter Employer Identification Number (EIN) and Unique Entity Identifier (UEI) numbers in AMIS
- September 20, 2022 at 05:00 p.m. ET: Last day to contact CDFI Fund with questions about the CDFI ERP
- September 20, 2022 at 05:00 p.m. ET: Last day to contact CDFI Fund with questions about Compliance or CDFI Certification
- September 22, 2022 at 05:00 p.m. ET: Last day to contact AMIS-IT Help Desk (regarding AMIS technical problems only)
- September 22, 2022 at 11:59 p.m. ET: Last day to submit complete CDFI ERP Application Package
All of the guidance, application materials, reference documents, and webinar information for the FY 2022 CDFI ERP application round are available on the CDFI ERP page. The following materials have been added or updated on the CDFI Fund’s website since the Application release on June 23, 2022:
- Amended FY 2022 CDFI Equitable Recovery Program NOFA
- FY 2022 CDFI Equitable Recovery Program Application Instructions
- FY 2022 Equitable Recovery Program Application Frequently Asked Questions (FAQs)
- CDFI Equitable Recovery Program Application Overview
- FY 2022 CDFI Equitable Recovery Program AMIS Training Manual
The CDFI Fund will continue to update the application materials section of the CDFI ERP webpage as needed throughout the application round. Please refer back to the CDFI Fund’s website for updates.
For more information about FY 2022 CDFI Equitable Recovery Program Application, please visit www.cdfifund.gov/erp. For questions related to CDFI ERP, please submit a Service Request through your AMIS account, by emailing [email protected], or calling (202) 653-0421.