CDFI-2022-0001: Minority Lending Institution Designation Criteria

The African American Alliance of CDFI CEOs (the Alliance) is pleased to provide the following comments in response to the CDFI Fund’s (the Fund) request for information regarding the criteria to designate a certified Community Development Financial Institution (CDFI) a Minority Lending Institution (MLI). The Alliance is a membership-driven intermediary organization that aims to: build the capacity of member organizations; build bridges to economic stability, well- being, and wealth for Black individuals, families, and communities; and build power in Black communities by challenging and influencing financial sectors to operate more equitably. Since launching in 2018, the Alliance has established a network of 69 CEOs of Black-led Community Development Financial Institutions (CDFIs), which includes loan funds, credit unions, and venture capital funds. Alliance members reach historically underserved communities in all 50 states by providing financial services in the small business, affordable housing, and commercial real estate development sectors.