Today, the Native CDFI Network (NCN) and 23 Native CDFI and other partner organizations submitted a comment 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 Level 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 raised five issues of concern on Native CDFIs’ behalf, which are centrally focused on how the proposed TLR reporting changes are likely to increase the overall reporting burden and make it more complicated.
To read the comment letter, please click here.