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.

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