Letter to the OMB on the Proposed Revisions to the Guidance for Federal Financial Assistance

Dear Mr. Reisig and Mr. Savary:

The American Bankers Association (ABA) appreciates the opportunity to comment on the Office of Management and Budget's (OMB) proposed revisions to the Guidance for Federal Financial Assistance. ABA represents banks of all sizes and charter types, including many Community Development Financial Institutions (CDFIs) that rely on programs administered by the U.S. Department of the Treasury's CDFI Fund to expand access to capital and financial services in underserved communities.

ABA supports OMB's objective of promoting accountability and responsible stewardship of federal financial assistance. At the same time, we encourage OMB to ensure that implementation of the revised guidance preserves the accessibility and operational effectiveness of CDFI Fund programs for regulated financial institutions.

CDFIs operate within a comprehensive prudential supervisory framework and often have limited staff dedicated to grant administration. As a result, changes that increase administrative complexity or create uncertainty in program administration may reduce participation in CDFI Fund programs and delay the deployment of capital into the communities these programs are intended to serve.

Fixed-Amount Awards

ABA is concerned that eliminating the availability of fixed-amount awards could significantly increase administrative burden for participating banks without providing a commensurate programmatic benefit. Fixed-amount awards have historically helped streamline administration while allowing institutions to focus resources on lending and community development activities.

ABA encourages OMB to preserve appropriate flexibility for the Treasury Department and the CDFI Fund to continue using fixed-amount awards where they are an effective and efficient program delivery mechanism.

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