50. Can an Applicant’s Target Market include a combination of different Investment Areas, e.g., both a pre-qualified Investment Area and a customized Investment Area?

Yes, an Applicant may be certified to serve both a pre-qualified Investment Area and a customized Investment Area and/or a non-Metro county-wide or parish-wide Investment Area. In such cases an Applicant must submit a map of any Customized Investment Areas and/or non-Metro county-wide or parish-wide Investment Areas in CIMS and meet the accountability requirements for each Investment Area type.

51. What if a CDFI with a customized Investment Area or non-Metro county or parish Investment Area does not direct the minimum level of financing activity to individually qualified census tracts within those Investment Areas?

If a CDFI fails to deliver at least 85% of its financing activity within the individually qualified census tracts of a Metro customized Investment Area or, prior to October 1, 2027, at least 75% (and at least 85% beginning October 1, 2027) within the individually qualified census tracts of a non-Metro customized Investment Area or county-wide or parish-wide Investment Area, it will still be able to treat the activity within the individually qualified census tracts of the respective geography as Investment Area Target Market activity, but will not be able to recognize the activity within non

52. Can loans that were originated by an entity that was acquired count towards meeting the Target Market requirements of the acquiring entity?

If an entity acquires another entity, the financing activity of the acquired entity may count toward the Target Market requirements of the acquiring entity only if that activity is included in the non-consolidated financial statements of the acquiring entity at the end of the acquiring entity’s fiscal year. Generally, such activity may not count toward the Target Market requirements of the acquiring entity if the acquired entity remains a separate legal entity, even if its financing activity is included in the consolidated financial statements of the acquiring entity.

53. When must a CDFI begin abiding by the new pre-approved Target Market Assessment Methodologies?

TM07 asks Applicants to attest “that only a CDFI Fund-approved Target Market assessment methodology(ies) was and will continue to be used to determine whether or not Financial Product transactions and/or depository accounts have been directed to an eligible Target Market,” while TM08 asks Applicants to identify the Target Market assessment methodology(ies) used by the Applicant.

54. Can a wholesale lender that buys loan participations from other CDFIs be designated as serving an OTP-Certified CDFIs Target Market?

Yes, a wholesale lender that purchases loan participations (i.e. a portion of a loan originated by a retail lender) from other Certified CDFIs may be designated as serving an OTP-Certified CDFIs Target Market.

55. Does it matter what naming convention is used for creating a Target Market in CIMS and AMIS?

Yes, it does matter. Part of the TLR’s Target Market Calculator’s logic is based on the names given to a Target Market in AMIS and CIMS. For AMIS, the relevant data field is the “Market Name” data field on the “CDFI Certification Market” object. For CIMS, the relevant data field is the “Map Name” data field for each Target Market map created.

56. What counts as an eligible Development Service for the purposes of CDFI Certification?

An eligible Development Service is a structured training, counseling, or technical assistance service that promotes access to and/or success with an entity’s Financial Products and Financial Services. A structured Development Service should be offered regularly to eligible clients, have a defined curriculum or written set of goals and objectives, and for which the outcome of success may be the completion of a specific step that prepares current or potential customers to access or increase their knowledge about the CDFI’s Financial Products and Financial Services.

57. Are one-on-one meetings with customers an eligible Development Service?

Yes, a Development Service may be delivered in a classroom setting or one-on-one, e.g., a series of one-on-one, goal-oriented conversations with consumers that have measurable outcomes. A Development Service, however, is separate and distinct from routine customer service, marketing or origination activity, such as providing a prospective or existing customer, borrower, or investee information about, or assistance with completing an application for an Applicant’s Financial Products or Financial Services.

58. Can a Development Service be delivered online or virtually?

Yes, a Development Service may be delivered in person or online and may be delivered with or without a live instructor or facilitator. Development Services delivered without a live instructor or facilitator must be well-developed, online trainings with learning modules that include a method of requiring the engagement of the viewer and measuring increased knowledge.

59. Can an Applicant meet the Development Services requirements if it provides financial education or training that is not connected to a Financial Product or Financial Service offered by the Applicant, even if it assists a beneficiary to access Financial

Per regulation, a Development Service must be directed toward the use of the Applicant’s Financial Products or Financial Services and not those of another entity. A CDFI does not need to establish that participants in any Development Service secured financing from the CDFI—only that the Development Service reasonably prepares them to access a Financial Product or Financial Service that the CDFI offers at the time the Development Service was offered.