RE: Request for Public Comment on CDFI Certification Application [OMB Control Number: 1559—0028]
Spencer W. Clark
PRA Clearance Officer
U.S. Department of Treasury
1500 Pennsylvania Avenue, NW
Washington DC 20220
To Whom it May Concern:
The American Bankers Association (ABA) appreciates the opportunity to comment on the Treasury Department’s notice of information collection and request for comment on the CDFI Certification Application published in the November 4, 2022 Federal Register. The proposed revisions to the CDFI Certification Application are intended to ensure certification policies and applications continue to meet statutory and regulatory requirements, are responsive to the evolving nature of the CDFI industry, and protect government resources.ABA supports the goals of the proposal and agrees that CDFI Certification should not subsidize entities whose products, services, or policies do not align with the CDFI Fund’s mission to expand economic opportunity for underserved people and communities. Careful calibration of CDFI certification standards is critical to ensure they are stringent enough to be meaningful, but also flexible enough to allow these mission-driven financial institutions to meet the unique needs of their communities.
ABA appreciates the significant revisions adopted by the CDFI Fund in response to comments received on the May 2020 proposed changes, including comments submitted by ABA. Nevertheless, we are very concerned that the CDFI Fund appears prepared to finalize the Certification Application changes despite significant remaining concerns regarding the potential on-the-ground impact of the proposed changes. If finalized as currently proposed, the new standards could disadvantage current CDFIs relative to new applicants, make it difficult for CDFIs to offer products and services responsive to community needs, and negatively impact the ability of rural CDFIs to meet certification standards. These results are inconsistent with the Fund’s stated policy objectives, and will undermine its ability to effectively and efficiently inject federal funds into areas that desperately need support.
Download the comment letter to read the full text.