The proposed Community Development Financial Institution (CDFI) Certification Application is flawed and should be reconsidered, CUNA wrote to the Treasury Thursday. The Treasury’s CDFI Fund recently proposed potential revisions to the application as part of its ongoing review of policies and procedures.

“While CUNA supports the CDFI Fund’s ongoing efforts to evaluate and consider the efficiency and relevance of its certification and monitoring process, we strongly believe the proposed revisions to the certification application fail to achieve these goals nor would they further the purposes of the CDFI Program,” the letter reads. “In fact, the proposed application changes could ultimately serve as unnecessary barriers for qualified credit unions to access the CDFI designation.”

CUNA’s comment notes several parts of the application that contain multiple redundant questions or fails to recognize requirements credit unions face from regulators such as NCUA.

“The Fund should reconsider this proposal and instead focus on evaluating its credit union participants by further developing a partnership with the NCUA and using the information collected by NCUA during its routine examination process to encourage greater CDFI participation,” the letter reads.

As of Oct. 14, credit unions make up 321 certified CDFIs out of 1,144 nationwide.