CDFI Certification Application FAQs

• Entities completing the new Certification Application for the first time are required to complete the abbreviated TLR. The TLR is required to be submitted and certified prior to submission of the Certification Application. Once Certified, these entities are required to submit the abbreviated version of the TLR on an annual basis as part of their ACR submission unless they receive a financial assistance award which has a full-length TLR reporting requirement. Both the TLR and ACR are due 180 days after the end of the entity’s most recently completed fiscal year.
• Currently Certified CDFIs that do not have an active Assistance Agreement for a CDFI Program, NACA Program, CDFI ERP, or CDFI RRP award are required to submit the abbreviated version of the TLR as part of the process to become certified under the new Certification Application. They are then required to submit the abbreviated version of the TLR on an annual basis as part of their ACR submission unless they receive a financial assistance award which has a full-length TLR reporting requirement. Both the TLR and ACR are due 180 days after the end of the entity’s most recently completed fiscal year.
• Currently Certified CDFIs with an active Assistance Agreement for a CDFI Program, NACA Program, or CDFI Rapid Response Program (CDFI RRP) award will submit the full-length version of the TLR according to the deadlines in their Award Reporting Schedule in AMIS. Typically, this deadline is 180 days after the end of their most recently completed fiscal year.
• Previously Certified CDFIs with an active Assistance Agreement for a CDFI Program, NACA Program, or CDFI Rapid Response Program (CDFI RRP) award will submit the full-length version of the TLR according to the deadlines in their Award Reporting Schedule in AMIS. Typically, this deadline is 180 days after the end of their most recently completed fiscal year. This case is applicable to Applicants who have an active Assistance Agreement as described above, but a status of “Not Certified” for their “CDFI Certification Status” data field in their AMIS Organization Profile page.
   

Additional guidance is forthcoming for CDFI Equitable Recovery Program (CDFI ERP) award recipients.

No, all entities are not required to complete the TLR’s Financial Services section. The Financial Services section should only be completed by those depository institutions that are using eligible Financial Services activity to meet the required Target Market Activity thresholds. For such purposes, the Financial Services section measures the total percentage of unique depository account holders who are members of one or more eligible Target Market(s).

No, the Loan Purchases section of the TLR must be completed as part of the TLR package submission only if an entity has loan purchases on its balance sheet and the loans were purchased within the reporting period. Such entities should complete the Loan Purchases section of the TLR even if they did not use loan purchases to meet their required Target Market activity thresholds.

No, while a transaction may qualify for multiple approved Target Market types, it can only be counted once in the calculation. For example, a mortgage could be located in an Investment Area to a low-income, Hispanic borrower. However, for purposes of the Target Market activity thresholds, a transaction can only be counted once, so an entity will be required to select which Target Market type should be assigned to a transaction. The entity can only select one of its approved Target Market types. In the cited example, the CDFI would have to tag the transaction in the TLR as either IA or LITP or OTP-Hispanic for the “Designated Target Market Type” data field

If an entity is a regulated financial institution such as a bank or credit union, then consumer loan transactions should be entered into the Consumer Loans/Investments TLR Object with a value of “CONSUMER” for the “Purpose” data field.

If an entity is an unregulated financial institution, then consumer loans transactions should be entered into the main section of the TLR by selecting “CONSUMER” for the “Purpose” data field and selecting ‘IND’ within the ‘Investee/Borrower Type’ field for a loan issued to an individual borrower.

Yes, if a regulated financial institution intends to serve an OTP Target Market, it now must report the aggregated consumer loan transaction totals for each specific OTP type in the Consumer Loans/Investments TLR Object. This information is necessary to determine how regulated financial institutions are serving their proposed or approved component(s) of their Target Market. 

Applicants must count a transaction for only one OTP category regardless of whether it qualifies for more than one. 

• The dollar amount entered for the “OTP Amount” data field must add up to the dollar amount sum of the individual OTP category data fields, such as “OTP Amount Native American,” “OTP Amount Native Alaskan,” and so on. 
• The number entered for “OTP Number” data field must add up to the number sum of the individual category data fields, such as “OTP Number Native American” or “OTP Number Native Alaskan,” and so on