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.