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.