TACOMA, Wash.–CU Strategic Planning has sent an extensive comment letter to the Treasury Department’s CDFI Fund related to its certification application process.
The letter notes the CDFI Fund has indicated an interest in maintaining five policy objectives: 1) protection of the CDFI brand, 2) supporting the growth and reach of CDFIs, 3) fostering a diversity of CDFI types, activities and geographies, 4) minimizing administrative burden on CDFIs while maintaining data quality and collection methods, and 5) promoting efficiency within the department.
But while each of those policy objectives is “understandable and even laudable,” CU Strategic Planning told the Fund its proposal “sacrifices” some policy objectives, particularly policy objective number four, which seeks to minimize administrative burden, as a result of its efforts to achieve other policy objectives.
‘Stepping Back’
“Stepping back from these policy objectives, we believe the public policy objectives that resulted in the creation of the CDFI credential encourages organizations with a community development mission to apply for CDFI certification,” CU Strategic Planning said. “This credential should be protected, but shouldn’t be protected to exclude a broad diversity of CDFI types. Diversity among CDFIs should be encouraged to meet the unique and varied needs of low income people and communities throughout the United States. In protecting the CDFI brand and promoting efficiency, we believe the CDFI Fund will make it difficult to achieve this diversity.
‘Seriously Consider These Changes’
“We believe that the broader public policy could be achieved by giving the CDFI Fund the flexibility needed to identify those organizations with a calling focused on community development, rather than bright line definitions that could exclude organizations with a mission and heart for community development,” the letter continues. “We encourage the CDFI Fund to seriously consider these concerns because the changes proposed by the CDFI Fund will have a dramatic impact on credit unions currently certified as CDFIs. In a recent meeting of our clients, about one-third of participants reported that they would consider ending their certification status if these changes go into effect as written. Some of these clients have received significant Equitable
Recovery Program or Emergency Capital Investment Program awards important for the nation’s post-pandemic economic recovery.”
The full comment letter can be found here.
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