CUNA provided suggestions to improve the efficiency of the Greenhouse Gas Reduction Fund (GGRF) in comments filed with the Environmental Protection Agency (EPA) Friday. CUNA also called on the EPA to provide clarity regarding credit union participation in the GGRF and requested a meeting with the EPA on the topic.
The letter notes CUNA’s concern that the proposed method of severing direct and indirect investment into separate funds would be wasteful and “significantly hinder” the goal of serving low-income and disadvantaged communities.
“If the EPA’s goal is to ensure that these Funds are deployed effectively and efficiently, it should approach this holistically – allow capacity-building indirect investment to be bundled with funds for direct investment in qualified projects through a single entity,” the letter reads. “This would result in the least amount of waste and excess cost to borrowers. It would also create the most sustainable structure for entities that will ultimately deliver the benefits of these Funds to the communities intended to be served.”
CUNA notes that credit unions—particularly Community Development Financial Institution certified credit unions (CDCUs) and minority depository institution-certified credit unions—are “ideally suited” to meet the GGRF’s core objective.
“Credit unions have a demonstrated history of working collaboratively to develop products and deliver services at a scale that achieves exceptional regulatory performance, public trust, and accountability,” the letter reads. “Credit unions and CDCUs already operate under existing federal and state regulatory structures that allow the EPA to be sure of the integrity of the use of those funds.”
Publication of the formal Notices of Funding Opportunities are expected as early as June, according to the GGRF’s implementation framework.