CUNA and other organizations met with House Financial Services and Senate Banking, Housing, and Urban Affairs leadership staff Tuesday to discuss proposed changes to the Community Financial Development Institution (CDFI) Fund certification application.
The CDFI Fund proposed the new guidance in November under the Paperwork Reduction Act, but CUNA is concerned that the proposed new application is outside the scope of the PRA and should go through the regular notice and comment process.
"We thank committee staff for their attention to this issue and proposal, which would re-shape the entire CDFI industry," said CUNA President/CEO Jim Nussle. "Such a massive change deserves to go through the formal rulemaking process with adequate opportunity for public comment."
CUNA previously noted in comments to the CDFI Fund that the changes would inappropriately exclude “large swaths” of mission-focused credit unions.
“Specifically, we strongly believe that the proposed changes will significantly undermine the efforts of CDFIs to meet the needs of borrowers in low-income and distressed communities,” CUNA previously wrote. “In addition, the scope of the proposed changes is broad enough that we believe implementing those changes through the PRA was procedurally inappropriate and did not allow for sufficient consideration of stakeholder feedback.”