CDFI Fund Seeks Public Comment on CDFI Bond Guarantee Program Materials

The U.S. Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995, Pub. L. No. 104-13 (44 U.S.C. 3506(c)(2)(A)). Currently, the Community Development Financial Institutions Fund (CDFI Fund), U.S. Department of the Treasury, is soliciting comments concerning the CDFI Bond Guarantee Program’s information collection. The request for comment was published today in the Federal Register. 

The purpose of the CDFI Bond Guarantee Program is to support Community Development Financial Institution (CDFI) lending by providing Guarantees for Bonds issued by Qualified Issuers as part of a Bond Issue for Eligible Community or Economic Development Purposes. The CDFI Bond Guarantee Program provides CDFIs with a new source of long-term capital and furthers the mission of the CDFI Fund to increase economic opportunity and promote community development investments for underserved populations and distressed communities in the United States. 

In compliance with OMB Circular A–129, the CDFI Bond Guarantee Program will collect all necessary information to manage the portfolio effectively and track progress towards policy goals and statutory and regulatory requirements. The reporting forms are necessary for the Department of the Treasury’s review and impact analysis on the current and proposed use of Bond Proceeds in underserved communities and to support the CDFI Fund in proactively managing regulatory compliance. Risk detection and mitigation are crucial activities for the long-term operation and viability of the CDFI Bond Guarantee Program. The Department of the Treasury’s authority to collect this information and the specified data collection area and parameters are consistent with the requirements contained in 12 CFR Part 1808.101(d)(1)(2) of the CDFI Bond Guarantee Program Interim Rule.

The CDFI Bond Guarantee Program proposes minor revisions to the existing approved forms and is seeking approval for a Tertiary Loan Monitoring Report (TLM Report). The information collection currently includes the following applications and reports: (1) Qualified Issuer Application (including, Appendix QI-2E); (2) Guarantee Application (including, Appendices A-2A, A-2C, and B-ID); (3) Secondary Loan Requirements Certification; (4) Financial Condition Monitoring Report; (5) Pledged Loan Monitoring Report; (6) Annual Assessment Report; and (7) Secondary Loan Commitment Form.  

Comments are invited on all aspects of the information collections, but the CDFI Fund specifically requests comments concerning the following questions:

  1. Is there any input that the general public would like to share regarding our current information collection?
  2. Does the proposed TLM Report provide clarity on the expectations for meeting the requirements contained in 12 CFR Part 1808.101(d)(1)(2)?
  3. Is there additional information or guidance that the CDFI Fund can provide to clarify the commitment test review process?
  4. Does the proposed TLM Report contain the appropriate data points to ensure that it verifies the amount of collateralization pledged against the secondary loans for approved CDFIs that use the CDFI-to-financing entity asset class?

All comments must be received on or before November 15, 2021 and must be submitted in writing to Susan Suckfiel, CDFI Bond Guarantee Program Manager by e-mail to bgp@cdfi.treas.gov.

For more information about the CDFI Bond Guarantee Program, please visit www.cdfifund.gov/bond.   

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