Individual accountability to a Target Market may be demonstrated through any of the following means:

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.

A community development, mission-driven entity is an organization that focuses on improving the quality of life of underserved people and/or distressed geographies. Examples of promoting community development include:

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.

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:

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:

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.

No. To receive and/or maintain the Native American CDFI designation, an Applicant must also meet and maintain the requirements for CDFI Certification.

An entity that is certified under the new Certification policies, released in December 2023, is required to submit the new version of the ACR according to the submission date shown on their ACR Reporting Schedule in AMIS. The submission date will be 180 days after the FYE of its most recently completed Fiscal Year (FY) unless directed otherwise by the CDFI Fund.

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.