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The Treasury’s Community Development Financial Institutions (CDFI) Fund’s proposed certification application contains multiple provisions that would inappropriately exclude credit unions doing good work, CUNA wrote to the CDFI Fund Monday.
“CUNA broadly supports the Fund’s efforts to ensure that organizations that obtain a CDFI certification are truly putting mission front and center and helping the people in their Target Markets. However, the Fund’s application is not properly calibrated to achieve that end,” the letter reads. “Many of the changes in the Proposed Certification Application would exclude significant swaths of credit unions from qualifying as CDFIs for reasons that are incidental or inexplicable.
“Many of these changes are not supported by policy justifications in the application and are in opposition to statutory or regulatory provisions applicable to credit unions,” it adds.
CUNA urges the CFDI Fund not to adopt these changes, and recommends: