NCN News for the Week of August 8

NCN Submits Comments to the OCC regarding the Notice of Proposed Rulemaking to modernize the CRA

In early May, the three agencies tasked with regulating banking institutions’ compliance with the Community Reinvestment Act (CRA) jointly released their much-anticipated Interagency CRA Notice of Proposed Rulemaking (NPR) designed to strengthen and modernized the regulations governing the Act. To review the NPR, please click here.

Due to the historic nature of this NPR, NCN participated in several listening sessions and held two of its own to gather input from Native CDFI leaders to ensure their voice was included in the rule making process. NCN’s submitted comment can be viewed here.

NCN “Difference Makers” Interview Series:
Sean Winters and Alana Peterson

Last week, the Native CDFI Network released its latest edition of “Native CDFIs: Difference Makers for Indian Country,” an interview with Sean Winters, who serves as Executive Director of Chi Ishobak, Inc. Meaning “Big Cabbage” in the Pokagon Band of Potawatomi’s language, Chi Ishobak is a certified Native CDFI serving the Pokagon Potawatomi community and other Native people in Michigan and Indiana that was established to offer products and services to build capacity for tribal citizens in the areas of professional and personal finance.  To read the interview, please click here.

Coming this Thursday: “Difference Makers” sits down with Alana Peterson, who serves as Executive Director of Spruce Root, Inc., which serves 23 predominantly Native communities across southeast Alaska. A federally certified Native CDFI, Spruce Root provides local entrepreneurs with access to business development and financial resources in the form of loan capital, business coaching, workshops, and competitions.

To read the other interviews in NCN’s “Difference Makers” series, please click here.

Calendar Reminder: NCN Annual Policy and Capacity Building Summit

December 6-8, 2022

Native CDFI leaders, staff, and other interested stakeholders are encouraged to save December 6-8, 2022 on their calendars to attend the Native CDFI Network’s 2022 Annual Policy and Capacity Building Summit in Washington, D.C. The Summit will be held at the National Indian Gaming Association (NIGA) Conference Center near Capitol Hill, with lodging options within close walking distance of the event. The first day (December 6) will feature a capacity-building training for attendees. Stay tuned for more details!

Fostering thriving communities video still

Why is it so important to SAVE THE DATE to attend NCN’s Annual Policy and Capacity Building Summit on December 6-8, 2022! Watch NCN’s new three-minute video to find out! CLICK BELOW!

WATCH VIDEO HERE

Breaking News: Your input needed on the CDFI Equitable Recovery Program (ERP) eligibility requirements.

On June 23, 2022, the Community Development Financial Institutions Fund (CDFI Fund) announced the opening of the FY 2022 CDFI Equitable Recovery Program (ERP) round with the public release of a Notice of Funds Availability (NOFA). The NOFA set forth the deadline for submitting the FY 2022 CDFI ERP Application via the CDFI Fund’s Award Management Information System (AMIS) as 11:59 p.m. Eastern Time on September 23, 2022. For more information about the program and application click here.

To determine eligibility, a CDFI must first complete a Pre-Application Eligibility Questionnaire.

NCN is seeking your input on the two EPR eligibility criteria that include: 

  1. At least 30% of the prospective Applicant’s average annual Financial Products closed and Grants made (dollar volume and number of transactions) in the five most recent historic fiscal years must have been closed in ERP Eligible Geographies. To view a map of these eligible geographies, click here.
  2. The prospective Applicant must have audited financial statements for its two most recent historic fiscal years.

Click here to answer 5 questions about how your CDFI is affected by the ERP eligibility criteria. Please respond by 12:00pm ET, Friday, August 5th.

NCN News for the Week of August 1

U.S. Senate Announces Creation of Community Development Finance Caucus

Today, U.S. Senators Mark R. Warner (D-VA) and Mike Crapo (R-ID) announced the creation of the Senate Community Development Finance Caucus (CDFC), a bipartisan caucus dedicated to supporting the missions of Community Development Financial Institutions (CDFIs) and Minority Depository Institutions (MDIs) to scale their activities and fuel more lending in low- and moderate-income (LMI) communities.

The 14-member caucus is bipartisan and evenly divided between Democrats and Republicans including Sens. Amy Klobuchar (D-MN), Mike Braun (R-IN), Jon Ossoff (D-GA), Steve Daines (R-MT), Jack Reed (D-RI), Cindy Hyde-Smith (R-MS), Tina Smith (D-MN), Cynthia Lummis (R-WY), Chris Van Hollen (D-MD), Jerry Moran (R-KS), Rev. Raphael Warnock (D-GA), and Mike Rounds (R-SD).

CDFIs play a critical role in providing responsible and affordable credit to underserved communities. During the pandemic, CDFIs demonstrated their ability to deliver billions of dollars to underserved businesses through the Paycheck Protection Program (PPP), totaling approximately $34 billion.

On a bipartisan basis, Sen. Warner worked with Sen. Crapo, former Treasury Secretary Steven Mnuchin, and other colleagues to introduce the Jobs and Neighborhood Investment Act, which passed as part of the December 2020 COVID relief package. The bill made a historic $12 billion investment in CDFIs and MDIs, which included $3 billion for grant funding and $9 billion for tier-one capital investments in CDFIs and MDIs, which could be leveraged 10 to 1.

“CDFIs and MDIs play an essential role in providing access to capital in underserved communities. While Congress took significant steps to support community-based lenders over the last two years on a bipartisan basis, CDFIs continue to need more long-term patient capital, operating capital, and resources to modernize their systems and compete in an era of rapid financial innovation. I am happy to announce the creation of this caucus with Sen. Crapo to improve communication between industry and policymakers and continue working in a bipartisan fashion towards robust investments in CDFIs and MDIs,” said Sen. Warner.

“I have consistently heard positive news and success stories about CDFIs in Idaho and across the country, and their responsiveness to the small business community, particularly during these last few challenging years of the pandemic,” said Sen. Crapo. “Sen. Warner and I are proud to launch this caucus to educate members and staff about the important role CDFIs play in their communities, and to create a forum to share ideas and policy proposals that foster strong economic growth in local communities.

A summary deck describing the caucus can be found here. More information on the caucus can be found on its webpage here.

The Community Development Finance Caucus has the support of a number of organizations and financial institutions, including Native CDFI Network and individual Native CDFIs across the country.

“On behalf of the Native CDFI Network (NCN), NCN applauds the bipartisan effort of Sens. Crapo and Warner to establish a Community Development Finance Caucus within the United States Senate.  Community Development Finance Institutions (CDFIs) have proven to be an irreplaceable mechanism for channeling critically needed capital into low- and moderate-income communities. This is especially true in Indian Country, where Native communities have long experienced substantially higher rates of poverty and unemployment than mainstream America. They also face a unique set of challenges to economic growth, such as: poor/lacking physical, legal, and telecommunications infrastructure; limited access to affordable financial products and services for consumers, aspiring homeowners, and would-be entrepreneurs; and limited workforce development strategies to support Native people’s full participation in their local economies. NCN looks forward to the opportunity to have a Caucus that supports the work of CDFI’s,” said Pete Upton, Interim Executive Director of the Native CDFI Network.

“I would like to applaud the hard work from Sens. Crapo and Warner toward the development of the Community Development Finance Caucus. We are excited at the opportunity to have a caucus dedicated to the work and efforts of the many CDFI practitioners working on the ground every day,” said Ted Piccolo, Executive Director of the Northwest Native Development Fund.

Comments on the Community Reinvestment Act NPR Due This Friday

In early May, the three agencies tasked with regulating banking institutions’ compliance with the Community Reinvestment Act (CRA) jointly released their much-anticipated Interagency CRA Notice of Proposed Rulemaking (NPR) designed to strengthen and modernized the regulations governing the Act. Importantly, the NPR features a section specifically focused on Indian Country titled “Native Land Areas” (see pages 96-103, as well as two sections focused on CDFIs.

COMMENT PERIOD ENDS THIS FRIDAY, AUGUST 5, 2022: Native CDFIs, tribal governments, and other interested stakeholders have until this Friday, August 5 to submit formal comments on the NPR. To review the NPR and submit comments, please click here.

NCN “Difference Makers” Interview Series:
Lakota Vogel and Sean Winters

Last week, the Native CDFI Network released its latest edition of “Native CDFIs: Difference Makers for Indian Country,” an interview with Lakota Vogel, who serves as Executive Director of Four Bands Community Fund, Inc., a federally certified Native CDFI based on the Cheyenne River Sioux Reservation in South Dakota whose mission is to create economic opportunity by helping Native people build strong and sustainable small businesses and increase their financial capability to create assets and wealth. To read the interview, please click here.

Coming this Thursday: “Difference Makers” sits down with Sean Winters, who serves as Executive Director of Chi Ishobak, Inc. Meaning “Big Cabbage” in the Pokagon Band of Potawatomi’s language, Chi Ishobak is a certified Native CDFI serving the Pokagon Potawatomi community and other Native people in Michigan and Indiana that was established to offer products and services to build capacity for tribal citizens in the areas of professional and personal finance.

To read the other interviews in NCN’s “Difference Makers” series, please click here.

Invitation to Participate in the CDFI Fund’s New Markets Tax Credit Program Native Initiative Technical Workshops

The Community Development Financial Institutions Fund (CDFI Fund) recently launched the New Markets Tax Credit (NMTC) Native Initiative to increase NMTC investment in Federal Indian Reservations, Off-Reservation Trust Lands, Hawaiian Home Lands, and Alaska Native Village Statistical Areas, collectively referred to as NMTC Native Areas. We are writing to invite you to participate in the upcoming Technical Workshops.

The CDFI Fund announced the selection of a contractor, Big Water Consulting, to support this effort. In collaboration with the CDFI Fund, Big Water Consulting will host two Technical Workshops on the NMTC Program that are free of charge. These Technical Workshops will provide an overview of the NMTC Program and in-depth technical information on ways that your organization can participate in the NMTC Program.

Technical Workshop 1: Introduction to the NMTC Program

The first workshop will be held at the Embassy Suites in Denver, CO (1420 Stout St, Denver, CO 80202; (303) 592-1000; Embassy Suites Denver Downtown Convention Center Hotel (hilton.com)) on September 21 and 22, 2022. This workshop will introduce participants to the NMTC Program and assist them in determining if the NMTC Program can help them achieve their community and economic development goals. Among other topics, the workshop will detail the types of projects that are eligible for NMTC financing, how NMTC financing is structured, the roles of the various participants in an NMTC transaction, and ways the NMTC program can be used to invest in NMTC Native Areas.

This workshop is designed primarily for organizations with a limited knowledge of the NMTC Program. Participants will have an opportunity to hear from national NMTC Program experts and also from certified Community Development Entities (CDEs) that have successfully used the NMTC Program to invest in NMTC Native Areas.

Technical Workshop 2: How to Access and Use NMTCs for Community and Economic Development

The second workshop will be held in in early 2023, with the exact date and location still to be determined. This workshop will be more advanced and technical in nature. It is designed for organizations that have already been certified as a CDE, those that are considering CDE certification, and organizations that might be interested in applying for an NMTC Allocation. This workshop will provide a more in-depth discussion of how NMTC transactions are structured and discuss strategies for addressing the challenges associated with using the NMTC Program to invest in NMTC Native Areas. It will also provide participants with an understanding of using NMTCs as gap financing to enhance a business or a projects economic viability, along with the other types of capital needed to finance larger businesses or projects. Participants will learn about the NMTC application process, including the development of an NMTC business plan, technical information necessary to be competitive, and the compliance-related responsibilities associated with receiving an NMTC Allocation.

How to Participate

Representatives of Native organizations, including Tribal Entities, Alaskan Native Villages, Native Hawaiian communities, Native CDFIs, and Native CDEs are all eligible to participate in the Technical Workshops. As previously mentioned, the workshops will be free of charge and organizations are welcome to attend one or both. Please note that the workshops will also be streamed virtually. We are able to offer financial assistance, if needed, to help cover certain approved travel expenses. When you complete the Technical Workshop Intake Form, you will have an opportunity to indicate which workshop you are interested in attending and if your in-person attendance depends on the availability of financial assistance. We have a limited amount of funding to cover participant travel costs and therefore, will only consider providing financial assistance to cover approved travel expenses for one person per organization. If you are interested in attending one or both workshops, please click the link below and complete the Technical Workshop Intake Form. The information requested is critically important for us to determine demand and tailor the workshops to meet the needs of participants:

Intake Form – NMTC Workshop 1 (with skip logic) (ourcommunitydata.com)

Please share this invitation with individuals in your network who may be interested in participating in the Technical Workshops. Once registration is completed, Big Water will provide a weblink to participants who would like to reserve a room in the Embassy Suites hotel room block. If you have any questions, you are welcome to contact Holly Bolstad, Research Coordinator at Big Water Consulting, at (206) 466- 2065 or holly@bigwaterconsulting.net.

Breaking News: Save the Date (August 10) for Conference Call for CDFIs in an ACR-Related Cure Period

The Community Development Financial Institutions Fund (CDFI Fund) is holding an informational conference call for those Community Development Financial Institutions (CDFIs) that are currently in a Certification cure period related to the submission of a 2021 or 2022 Annual Certification and Data Collection Report (ACR).

The CDFI Fund recently announced that on October 1, 2022 it is implementing a blackout period for six months to prepare for the launch of the revised CDFI Certification Application and reporting requirements. During this time, CDFIs are required to maintain a state of good standing with respect to their CDF Certification status. CDFIs currently in a Certification cure period related to a 2021 or 2022 ACR Report Year submission are obligated to adhere to the specific deadlines and deliverables associated with that cure requirement. Failure to do so can result in a loss of Certification during the blackout period.

To assist CDFIs currently in a Certification cure period, or those awaiting a determination as to whether they will be placed in a cure period, the CDFI Fund is conducting a live conference call on August 10, 2022. The call will provide general information on how CDFIs can satisfy the terms of a cure and resolve Certification deficiencies during the coming CDFI Certification Application blackout period. The CDFI Fund strongly encourages the participation of a representative from any CDFI currently in a Certification cure period.

Please note, the conference call will cover general issues related to the process for resolving Certification-related cure issues. Organization-specific cure requirements will not be discussed during the conference call. Please submit an AMIS Service Request for individualized questions related to your organization’s particular cure obligations.

Conference Call Instructions

Date: August 10, 2022
Time: 3:00 pm to 4:00 pm Eastern Time 
Access Details:

  • Call-In: 800-779-1636
  • Audience Passcode: 2421115

Requests for reasonable accommodations under section 504 of the Rehabilitation Act should be directed to Jay Santiago at the CDFI Fund at 202-653-0300.

Additional Information

Reasonable Accommodations: Requests for reasonable accommodations under section 504 of the Rehabilitation Act should be directed to Jay Santiago at the CDFI Fund at 202-653-0300..

NCN News for the Week of July 25

Native CDFI Leaders’ Discussion:
The Community Reinvestment Act NPR
TODAY, July 25, 2:00 to 3:00 p.m. EDT

 

Today, the Native CDFI Network (NCN) will convene Native CDFI leaders from across the country to discuss the Interagency CRA Notice of Proposed Rulemaking (NPR) for the Community Reinvestment Act. This important conversation will inform NCN’s formulation of its formal comments on the NPR as well as the formal comments that individual Native CDFIs are strongly encouraged to submit. The NPR comment deadline is Friday, August 5, 2022. To review the NPR, the NPR Fact Sheet, and related materials, please click here.

The CRA was signed into law in 1977 to encourage depository institutions to help serve the credit needs of the communities in which they operate, in particular low- and moderate-income (LMI) areas and populations. The CRA also sought to deter discriminatory credit and lending practices against those populations, a practice commonly known as “redlining.” To date, however, the CRA has failed to achieve these goals when it comes to tribal nations and communities. The regulations governing the CRA have not been substantively updated since 1995, so this current process represents a key opportunity for Native CDFI leaders to advise the federal government about how the CRA regulations should be modernized to better serve Native nations and communities generally and Native CDFIs specifically.

REGISTER HERE
 

CFPB Extends Application Deadline for New Members on 2022 Advisory Committees

 

The Consumer Financial Protection Bureau (CFPB) has extended its application deadline to July 30, 2022 at 11:59 p.m. EDT for interested candidates to apply to serve on four CFPB advisory committees. CFPB’s advisory committees comprise a wide range of experts and stakeholders who provide input to the Director on a variety of consumer financial issues, as well as on the Bureau’s strategic research planning process and agenda. The advisory committees also allow CFPB to hear directly from small financial institutions.

Interested candidates can visit the Apply to serve on the advisory committees page for more information and for the application link. The advisory committees page has links to the charters and past public meeting videos, agendas, presentations, and minutes.

 

NCN “Difference Makers” Interview Series:
Julia Nemark and Lakota Vogel

 

Last week, the Native CDFI Network released its latest edition of “Native CDFIs: Difference Makers for Indian Country,” an interview with Julia Nelmark, who serves as President and CEO of Midwest Minnesota Community Development Corporation (MMCDC) and CEO of White Earth Investment Initiative (WEII), a MMCDC subsidiary. A federally certified Native CDFI, WEII helps create jobs and improve community life for the White Earth Nation and other Native communities across Minnesota through homebuyer education, individual homeownership advising, financial counseling, business and consumer lending, tax preparation support, and other efforts. To read the interview, please click here.

Coming this Thursday: “Difference Makers” sits down with Lakota Vogel, Executive Director of Four Bands Community Fund, Inc., a federally certified Native CDFI based on the Cheyenne River Sioux Reservation in South Dakota whose mission is to create economic opportunity by helping Native people build strong and sustainable small businesses and increase their financial capability to create assets and wealth.

To read the other interviews in NCN’s “Difference Makers” series, please click here.

 

CDFI Fund Extends Application Deadline for CDFI Equitable Recovery Program Funding

 

On June 23, 2022, the Community Development Financial Institutions Fund (CDFI Fund) announced the opening of the FY 2022 CDFI Equitable Recovery Program (ERP) round with the public release of a Notice of Funds Availability (NOFA). The NOFA set forth the deadline for submitting the FY 2022 CDFI ERP Application via the CDFI Fund’s Award Management Information System (AMIS) as 11:59 p.m. Eastern Time on August 23, 2022.

Meanwhile, on July 14, NCN hosted a webinar in which the CDFI Fund provided a detailed overview of the CDFI ERP program. To view a recording of this webinar, please click here. In addition to the deadline extensions, the CDFI Fund is also amending the NOFA to clarify eligibility requirements around audited financial statements. Loan funds, venture capital funds, and other Non-Regulated Institution Applicants are required to have audited financial statements for their two most recent historic fiscal years. However, if the audit for the Applicant’s most recent historic fiscal year is not complete as of the due date of the AMIS Application, the Applicant must have audited financial statements for its two historic fiscal years prior to its most recent historic fiscal year. Regulated Institution Applicants that file Call Reports to their regulator are exempt from the requirement to have audits.

Recently, the CDFI Fund announced it will be extending the upcoming deadline to submit CDFI ERP Applications in AMIS to September 22, 2022, at 11:59 p.m. ET. Additionally, the CDFI Fund will be extending the deadline to submit the OMB Standard Form-424 Mandatory via Grants.gov to August 18, 2022. This extension will provide organizations additional time to undertake a thorough review of the CDFI ERP Application requirements and prepare their Application submissions. The CDFI Fund continues to encourage all FY 2022 applicants to submit their CDFI ERP Applications as soon as possible to ensure a successful submission.

An additional webinar will be held to discuss updates to the Application FAQs, available new materials, and to take additional questions. The CDFI Fund will provide separate information on this upcoming webinar.

In addition to the deadline extensions, the CDFI Fund is also amending the NOFA to clarify eligibility requirements around audited financial statements. Loan funds, venture capital funds, and other Non-Regulated Institution Applicants are required to have audited financial statements for their two most recent historic fiscal years. However, if the audit for the Applicant’s most recent historic fiscal year is not complete as of the due date of the AMIS Application, the Applicant must have audited financial statements for its two historic fiscal years prior to its most recent historic fiscal year. Regulated Institution Applicants that file Call Reports to their regulator are exempt from the requirement to have audits.

The CDFI Fund is releasing updated deadlines in anticipation of the publication of an amended NOFA in the Federal Register on July 19, 2022.

The new deadlines are:

  • August 18, 2022 at 11:59 p.m. ET: Last day to submit OMB Standard Form-424 Mandatory (Application for Federal Assistance) (SF-424)
  • August 18, 2022 at 11:59 p.m. ET: Last day to enter Employer Identification Number (EIN) and Unique Entity Identifier (UEI) numbers in AMIS
  • September 20, 2022 at 05:00 p.m. ET: Last day to contact CDFI Fund with questions about the CDFI ERP
  • September 20, 2022 at 05:00 p.m. ET: Last day to contact CDFI Fund with questions about Compliance or CDFI Certification
  • September 22, 2022 at 05:00 p.m. ET: Last day to contact AMIS-IT Help Desk (regarding AMIS technical problems only)
  • September 22, 2022 at 11:59 p.m. ET: Last day to submit complete CDFI ERP Application Package

Updated Guidance

All of the guidance, application materials, reference documents, and webinar information for the FY 2022 CDFI ERP application round are available on the CDFI ERP page. The following materials have been added or updated on the CDFI Fund’s website since the Application release on June 23, 2022:

The CDFI Fund will continue to update the application materials section of the CDFI ERP webpage as needed throughout the application round. Please refer back to the CDFI Fund’s website for updates.

For more information about FY 2022 CDFI Equitable Recovery Program Application, please visit www.cdfifund.gov/erp. For questions related to CDFI ERP, please submit a Service Request through your AMIS account, by emailing erp@cdfi.treas.gov, or calling (202) 653-0421.

WATCH WEBINAR HERE

NCN Hosts Webinar Showcasing the Success of the Section 502 Home Loan Demonstration Project

On Thursday, July 21, 2022, NCN hosted U.S. Representative Sharice Davids and USDA-Rural Development Under Secretary Xochitl Torres Small, along with Native CDFI leaders from the South Dakota Native Homeownership Coalition that included Tawney Brunsch, Joanna Donohoe, Stephanie Provost, and Lakota Vogel, in a conversation about Section 502 and the home loan demonstration project. Roundtable guests shared their challenges and successes related to the demonstration project. U.S. Representative Davids and Under Secretary Torres Small also took questions from attendees about the project and how legislation introduced in Congress seeks to turn the project into a permanent program with adequate funding to help meet Indian Country’s mortgage lending capital needs.

An overview of the Native American Rural Homeownership Improvement Act of 2021 (S. 2092, H.R. 6331) that would provide permanent access to this source of mortgage lending can be downloaded here along with a copy of a letter template to request co-sponsorship from your state representatives.

A recording of the session in its entirety is below: