news.cuna.org/articles/123403-cuna-publishes-analysis-of-updated-cdfi-certification-application
Staff training key to mitigating compliance risk

CUNA publishes analysis of updated CDFI Certification Application

December 11, 2023

CUNA Senior Director of Advocacy and Counsel Elizabeth Sullivan posted initial analysis of the Community Development Financial Institution (CDFI Certification Application on CUNA’s Compliance Community. While it will take weeks to dig into the complete details, Sullivan notes that the application changes appear to be ultimately positive.

Credit unions about being unable to certify or inappropriately excluded appears to have been addressed, and CUNA do not anticipate significant numbers of credit unions being unable to certify as, as it was concerned with the proposed certification.

Sullivan’s post examines changes in the application, including addressing credit unions’ most important asks:

  • Broadening the definition of "development services" to better recognize the effectiveness of coaching, online training, youth programs, and other services offered by credit unions; and
  • Altering the Financial Interest Policy to ensure that officers of credit union governing boards who hold loans in the credit union are not excluded from serving as a source of accountability.
  • A longer timeframe to review and execute the CDFI Certification Agreement;
  • Some guidance on what overdraft and insufficient funds fees the Fund considers irresponsible;
  • Defining mortgages in a limited way that preserves a lot of credit union flexibility;
  • Recognizing that staff and not just executives of mission-driven organizations that serve a target market are appropriate sources of accountability to CDFI credit unions.  

She also notes areas of continuing concern, breaks down deadlines and the grace period, and links to all materials provided by the CDFI Fund.

Credit unions that are currently CDFI certified have until Dec. 20, 2024 to apply for recertification under the new application. Credit unions not currently certified can apply as soon as AMIS reopens CDFI Certification Application on Dec. 20, 2023.

The Fund will conduct a webinar Dec. 13at 1:30 p.m. ET to discuss the live application.