The African American Alliance of CDFI CEOs is closely reviewing the CDFI Fund’s proposed changes to the CDFI Certification Application, including the proposed elimination of race/ethnicity-based Other Targeted Populations as eligible Target Markets.
For CDFIs currently relying on African American OTP, this change could require institutions to establish that their existing lending qualifies through another Target Market, including Low-Income Targeted Populations or Investment Areas. The Fund is contemplating a one-year transition period for affected CDFIs.
The Alliance is working with its member institutions to understand the full impact of the proposal, including what the elimination of race/ethnicity-based OTPs would mean for Black-led CDFIs and, if the Fund proceeds with the change, what affected institutions would need to maintain certification. What we learn from members will shape the Alliance’s formal comments to the CDFI Fund, due November 30.
Certification readiness is core Alliance work. Through our CDFI Certification Readiness Accelerator, the Alliance has guided Black-led CDFIs through certification and recertification. It will continue to support members through whatever changes lie ahead.
The Alliance will remain actively engaged throughout the comment period. Its goal is a certification framework that continues to recognize the institutions reaching the communities the CDFI program was created to serve.
