The Native CDFI Network (NCN) invites Native CDFIs and partner organizations to sign on to its letter responding to the CDFI Fund’s request for public comment regarding the Fund’s proposed changes to the annual Transaction Level Report (TLR) that entities participating in the CDFI Equitable Recovery Program (ERP) must complete to maintain compliance.
The changes include the establishment of a new Grant Level Report and Consumer Loan Report, as well as a host of new required data points. The CDFI Fund seeks comments specifically on: (a) whether the collection of information is necessary for the proper performance of the functions of the CDFI Fund, including whether the information shall have practical utility; (b) the accuracy of the CDFI Fund’s estimate of the burden of the collection of information; (c) ways to enhance the quality, utility, and clarity of the information to be collected; (d) ways to minimize the burden of the collection of information on respondents, including through the use of technology; and (e) estimates of capital or start-up costs and costs of operation, maintenance, and purchase of services to provide information. In the letter, NCN raises five issues of concern on Native CDFIs’ behalf, which are centrally focused on how the proposed ERP reporting changes are likely to increase the overall reporting burden and make it more complicated.
The deadline to sign on to the NCN letter is EOB this Thursday, October 17.
If you have any questions about the comment letter, please contact NCN Consultant Lisa Wagner at [email protected].
To read the comment letter, click here.
To sign on to the comment letter, click here.