CDFI Fund should simplify report requirements, align deadlines

November 28, 2022

CUNA joined other community development organizations in a letter to Treasury’s Community Development Financial Institutions (CDFI) Fund calling simplified reporting requirements. The comments were sent in response to a request for feedback on the CDFI Fund’s Performance Progress Report, Financial Statement Audit Report, and Uses of Award Report forms.

“We encourage the CDFI Fund to take this opportunity to simplify its reporting requirements by combining similar forms into a single report and aligning reporting deadlines for reports that use the same underlying data,” the letter reads. “These three reports comprise a meaningful portion of the compliance requirements for CDFIs that participate in the CDFI Fund Technical and Financial Assistance, Rapid Response, Bank Enterprise Award, Native American Assistance, and Small Dollar Loan Programs.

The separate reporting deadlines needed for three discrete reports create confusion and add to the reporting burden of CDFI awardees. A few adjustments to the formats and reporting deadlines would reduce the reporting burden and support CDFIs in their efforts to provide timely and accurate data to the CDFI Fund,” it adds. ‘

The organizations note the Use of Award Report and Performance Progress Report are “both aggregate reports and should be combined into a single grant compliance summary report” that details how CDFIs used their awards and shows their progress toward performance goals.

“The current reporting deadline for the Performance Progress Report does not allow sufficient time for a full review of the previous year’s lending data and can result in CDFIs filing Performance Progress Reports that are not consistent with their Transaction Level Reports,” the letter reads. “This leads to anxiety among CDFI staff and less accurate data for the CDFI Fund.”