16. What are some examples of an Affiliate mission that supports and/or is consistent with that of the Applicant’s as well as examples of those that do not support or are inconsistent with that of the Applicant’s?

An Affiliate mission that supports or is consistent with that of the Applicant’s would be one that may broadly benefit a community even if it is not specifically focused on community development. For example, a parent entity (i.e., the Controlling Affiliate) that has a mission related to environmental protection or sustainability may be considered consistent with a mission of community development, especially if the Applicant offers climate-related financing to a Target Market.

17. What if an Applicant does not have a board-approved strategic plan to demonstrate that it has a stated Primary Mission to promote Community Development?

If the Applicant does not have a board-approved strategic plan, it must submit a board- or owner-approved narrative that describes the community development outcomes that the Applicant believes will result from the provision of its Financial Products and Financial Services, and how those Financial Products and Financial Services lead to those outcomes.

As evidence of a community development strategy, the Applicant’s strategic plan or narrative should include references to:

18. How will the CDFI Fund evaluate an Applicant’s adherence to the responsible financing practices requirements?

To meet the CDFI Certification standards for responsible financing practices, an Applicant (and its Affiliates) should provide Financial Products and Financial Services that are consistent with promoting community development. Such Financial Products should not harm consumers, be affordable and originated based upon an assessment of whether a borrower is able to repay a loan and have terms and conditions that are transparent and understandable to the borrower. CDFIs should practice transparency, fair collections, and be in compliance with federal, state, and local laws and regulations.

19. Do the standards for responsible financing practices apply to all of an Applicant’s Financial Products (and those of any covered Affiliate), or only those directed to a Target Market?

The Application includes a series of questions related to an Applicant’s (and its covered Affiliates’) Financial Products and Financial Services to determine whether they are consistent with a set of community development principles and the standards for responsible financing practices established by the CDFI Fund for the purposes of CDFI Certification. These questions apply to all Financial Products and Financial Services offered by an Applicant and its Affiliates, not just those directed to one or more of the Applicant’s Target Markets.

21. If an Applicant does not consider a borrower’s ability to pay back a loan for any of its covered mortgage, consumer, or small business loan products, what information should it include in any explanation of how this practice serves a community develop

For Question PM14, an Applicant that does not include an assessment of a borrower’s ability to pay back a loan as part of its underwriting standards for each of its covered mortgage, consumer, and/or small business loan products may offer an explanation of how this practice serves a community development purpose. In addition to the community development purpose of the relevant loan product, examples of the types of information the Applicant could provide to support such an explanation include, but are not limited to:

22. What types of mortgages are covered by question PM14 related to a borrower’s ability to pay back a mortgage loan product?

Question PM14 asks whether the underwriting standards for the Applicant’s covered mortgage loan products (as well as for its consumer and/or small business loan products) include an assessment of the borrower’s ability to pay back the loan. For purposes of this question PM14, a covered mortgage loan product is limited to a consumer credit transaction that is secured by a lien (including subordinate liens) on a single-family, owner-occupied residence other than:

23. Are Applicants required to calculate the MAPR for all of their consumer loans?

No, for purposes of Certification the CDFI Fund does not require that an Applicant calculate, disclose, or report the MAPR of each of its consumer loan products, unless otherwise required by statute or regulation to do so. Applicants only must attest as to whether any of its consumer loan products “allow for” a MAPR in excess of 36%.