Annual Certification And Data Collection Report (ACR) Submission
An entity that is certified under the new Certification policies, released in December 2023, is required to submit the new version of the ACR according to the submission date shown on their ACR Reporting Schedule in AMIS. The submission date will be 180 days after the FYE of its most recently completed Fiscal Year (FY) unless directed otherwise by the CDFI Fund.
An entity that is certified under the prior Certification policies is required to submit the current version of the ACR according to the submission date shown on its ACR Reporting Schedule in AMIS. The submission date is 90 days after the FYE of its most recently completed FY, unless directed otherwise by the CDFI Fund.
AMIS will automatically determine which ACR an entity must complete based on the Certification date in its AMIS Org Profile.
Yes, an entity that is certified under the new Certification Application, published in December 2023, can lose its certification based on its ACR submission. The entity’s answers in the ACR submission may show that the entity is no longer fulfilling all of the requirements of Certification and therefore should not have its Certification status reaffirmed. For example, if the Target Market activity thresholds are not met based on the submitted and certified Transaction Level Report (TLR) results, then the entity is not eligible for CDFI Certification renewal. There are also a series of questions in the Responsible Financing Practices section where a CDFI's Certification will not be reaffirmed if they respond that they do engage in certain practices that the CDFI Fund has deemed are contrary to the community development mission of CDFIs. All questions where the reporting entity’s CDFI Certification status will be automatically terminated based on the Yes/No response to the question are clearly marked in the ACR guidance materials.
For entities that are certified under the prior Certification policies, the CDFI Fund will continue its current policy whereby currently Certified CDFIs will NOT lose their Certification or be subject to a cure based on analysis or responses to their ACRs. However, to maintain their status as Certified CDFIs, organizations must adhere to the prior CDFI Certification Application eligibility and reporting requirements until they are notified by the CDFI Fund that they have been recertified under the new CDFI Certification Application. This includes submitting the ACR per their ACR Reporting Schedule in AMIS.
CDFIs that submit their ACR will receive notification that their Certification status has been reaffirmed. This is only a notification that the CDFI remains Certified under the prior CDFI Certification policies. Organizations are still required to submit a new CDFI Certification Application by their application submission deadlines to remain Certified after that date.
No, entities must complete and submit their TLR before they can submit the new ACR. There are data fields in the new ACR whose value is based on information in the TLR, so the TLR must be submitted and certified for those new ACR data fields to be populated with values.
All entities are required to complete the Source of Investment Capital section and the Contributed Operating Revenue section. Each section is required to have at least one entry. Guidance has been added to the new ACR Instruction document to provide examples of how a regulated financial institution might complete the sections.
The CDFI Fund will provide a crosswalk between the data fields from the various call report forms and their respective data field in the new ACR guidance materials. The applicable call report forms include:
- Consolidated Reports of Condition and Income (For Banks and Thrifts only); or
- Parent Company Only Financial Statements for Small Holding Companies—FR Y-9SP (For Holding Companies only); or
- Parent Company Only Financial Statements for Large Holding Companies—FR Y-9LP (For Holding Companies only); or
- 5300 Call Report (For Credit Unions (CUs) only); or
- AITSA Call Report (For Cooperativas only).
Regulated entities are required to attest to the accuracy of the values populated into the ACR from the various call reports and alert the CDFI Fund when an error is found.
For transactions closed prior to 1/4/2023, the entity should use the 2011-2015 ACS data file available here. For transactions closed between 1/5/2023 and 1/4/2024, the entity has the choice to use either the 2011-2015 ACS data file referenced above or the 2016-2020 ACS data file available here. For any transactions occurring on 1/5/2024, or later, the entity is required to use the 2016-2020 ACS data file available here. The transition date is based on the date in which the ACS data file was originally released to the public.
The CDFI Fund does require for reporting purposes that an entity choose one vintage of the ACS data file and use it consistently for all transactions during that fiscal year. For example, an entity whose fiscal year runs from 1/1/2023 to 12/31/2023 may use the 2016-2020 ACS data for the transactions that took place from 1/1/2023 to 1/4/2023 if it is using the 2016-2020 ACS data file for any transactions that took place from 1/5/2023 to 12/31/2023. Likewise, an entity whose fiscal year runs from 1/1/2024 to 12/31/2024 must use the 2016-2020 ACS data for the transactions that took place from 1/1/2024 to 1/4/2024 because it has to use the 2016-2020 ACS data file for any transactions that took place from 1/5/2024 to 12/31/2024.
Additional guidance is forthcoming for CDFI Equitable Recovery Program (CDFI ERP) award recipients.
The 3-year Target Market percentage will be calculated by assessing an entity’s cumulative Target Market activity over three full fiscal years (the most recently completed fiscal year being reported on in the ACR and the two preceding fiscal years) divided by their total lending activity over the same time period to assess whether the Target Market activity thresholds for dollar amount and count of transactions have been met. It is not an average of the Target Market activity percentages for each of the three years. The three-year assessment will commence once an entity has been Certified under the revised CDFI Certification application.
The CDFI Fund will allow entities to have a mix of ACS datasets across the three years. For example, year 1 could use the 2011-2015 ACS data file while years 2 and 3 use the 2016-2020 ACS data file. However, entities cannot mix ACS data file vintages within a reporting year. An entity must pick one ACS data vintage and use it throughout that year.
Entities will not be required to recode the geography of previously submitted TLR records.
Certified CDFIs that still fall below the Target Market benchmarks over three full fiscal years of financing activity in their TLR (or over two full fiscal years for those with less than two years of Certification under the current Application) will be decertified and no additional cure period will be granted.