Rightsizing the CDFI Certification Application Process

Rightsizing the CDFI Certification Application Process

F.P. Report

NEW YORK: Over the past year, increased funding and enhanced recognition of the role Community Development Financial Institutions (CDFIs) play in facilitating economic recovery, inclusion and opportunity in distressed and underserved communities has generated a dramatic increase in the number of organizations seeking Certification as a Community Development Financial Institution (CDFI).

In particular, supplemental resources provided by Congress, specifically reserved for CDFIs, and designed to help communities recover from the economic impact of the COVID-19 pandemic, has highlighted the importance of Certification as a prerequisite to accessing CDFI Fund assistance. Beyond the ability to access CDFI Fund assistance, Certification also allows CDFIs to tap into investments from other public, private and philanthropic sources, and additional grant resources from other Federal agencies.

The number of organizations applying to be a Certified CDFI jumped dramatically and has remained high over the course of 2021. As a result, the time needed to review, evaluate and provide a Certification determination has also increased. The CDFI Fund has worked hard to follow through on its policy of providing all applicants a decision on their CDFI Certification applications and Certification-related modifications within 90 days.

However, the ongoing surge of applications has made it impossible to provide determinations in that time frame. In addition, the CDFI Fund has long provided a high degree of interaction with applicants in order to obtain information needed to make a decision, including working with organizations to obtain missing or incomplete application information. This customer service approach service has often extended the timeframe needed to make a determination, as well as delayed work on applications in the queue.

In order to right-size expectations of the time needed to provide a decision, going forward, the CDFI Fund can no longer commit to providing determinations on CDFI Certification Applications and Target Market Modification applications within 90 days. The CDFI Fund will review and provide determinations as quickly as reasonable.

Also, in order to provide the most expeditious review process possible, any application that is incomplete or contains inaccurate information will automatically be rejected. The CDFI Fund expects all organizations to fully review applications for completeness and accuracy prior to submission. Organizations whose applications are rejected for missing or inaccurate information will be required to submit a new application.

We understand that many organizations time the submission of applications to coincide with the opening of the CDFI Fund’s various award rounds. While we are unable to specify when funding rounds will open, we can say that the Certification application review process is taking an extended period of time and organizations are urged to take this into consideration when planning submission of a CDFI Certification Application.

Organizations contemplating submission of an application, with the intent to participate in an upcoming funding round, are STRONGLY encouraged to submit applications as soon as possible. For those programs where eligibility is limited to CDFIs, the CDFI Fund requires applicants to be Certified CDFIs at the time the Notice of Funding Availability is published in the Federal Register. We encourage organizations to review the CDFI Certification guidance materials and participate in monthly CDFI Certification conference calls.

Lastly, the CDFI Fund recently restructured its Office of Certification, Compliance Monitoring and Evaluation (CCME) and established separate offices for Compliance, Monitoring and Evaluation (CME) and Certification Policy and Evaluation (CPE). The separation of CCME into two units was done to optimize workflow, and balance management needs between the CDFI Fund’s certification activities and award compliance functions.

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