61. What is an eligible development service and what does the Applicant need to submit in the narrative?

An eligible Development Service is a formal structured training, counseling, or technical assistance service that promotes access to and/or success with an entity’s Financial Products and Financial Services is offered regularly to eligible clients, have a defined curriculum or written set of goals and objectives, and 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.

62. How must an Applicant demonstrate Accountability to its proposed Target Market(s)?

Applicants must demonstrate individual and, if required, collective accountability to their proposed Target Market(s) through one of the following options:

Option 1: Governing Board Only

  • At least one governing board member is accountable to each proposed Target Market type, and
  • At least 33% of the governing board is accountable to the overall proposed Target Market(s);

Option 2: Governing Board Supplemented by Advisory Board

64. Can board membership with a non-Affiliated, third-party, community development mission-driven organization that primarily provides services to Low-Income people be used as a means of accountability to a particular Target Market?

No, for the purposes of CDFI Certification the CDFI Fund does not consider status as a board member of a third-party, mission-driven organization by itself to demonstrate a sufficient level of accountability to a Target Market. However, such an individual still may be treated as accountable to a Target Market if it meets one of the other accepted means of accountability, for example, as resident of a qualified Investment Area census tract or as a member of a Targeted Population.

66. Can a board member meet the accountability test for more than one Target Market?

Yes. For example, an African American resident of an Investment Area may serve as a board member of an Applicant that has a Target Market of Pre-qualified Investment Areas and OTP-African American and meet the accountability criteria for both Target Markets. However, the Applicant still must meet other minimum accountability requirements, e.g., that at least 33% of the governing board is accountable to the overall proposed Target Market(s) when using a governing board to meet the Accountability test. See Question 67 for additional discussion.

67. What are some examples of eligible board representation for the Accountability test for entities with more than one Target Market?

To meet the Accountability test through an Applicant's governing board, an Applicant must demonstrate that at least one governing board member is accountable to each proposed Target Market, and at least 33% of the governing board is accountable to the overall proposed Target Market(s).

For example, a CDFI with a Target Market of Pre-qualified Investment Areas, LITP, and OTP-Hispanic, and a governing board consisting of fifteen members would have to have:

68. What are the advisory board policy requirements for an Applicant using an advisory board to demonstrate accountability to a proposed Target Market(s)?

An organizational advisory board policy can be a stand-alone document or can be incorporated into an Applicant’s governance or organizing document. At minimum, an advisory board policy must include a description of all of the following:

69. Are board members who have active loan products from the Applicant or who are compensated for their board service eligible to meet the accountability requirements?

Yes, board members who have active loan products or are compensated for their board service are eligible to meet the individual accountability requirements. However, to avoid a financial conflict of interest, if an Applicant’s board member, the board member’s employer, or any covered member of the board member’s family has an active Financial Product(s) from the Applicant, the Applicant should have policies requiring such board members to recuse themselves from any decision that may affect, directly or indirectly their Financial Product or relationship.