Category: PUBLIC POLICY COMMENTS

The African American Alliance of CDFI CEOs (the Alliance) is pleased to submit comments regarding the development of a national strategy for financial inclusion. The Alliance is a national membership-based organization with a mission to empower Black communities by promoting economic stability, wellbeing, and wealth. Leveraging a network of 78 Black-led Community Development Financial Institutions (CDFIs), the Alliance is working towards establishing power and promoting equal economic opportunity for Black individuals, families, and communities across all 50 states.

The African American Alliance of CDFI CEOs (the Alliance) is pleased to submit comments regarding how the CDFI Fund may enhance and improve the Capital Magnet Fund (CMF). The Alliance is a national membership-based organization with a mission to empower Black communities by promoting economic stability, wellbeing, and wealth. Leveraging a network of 77 Black-led Community Development Financial Institutions (CDFIs), the Alliance is working towards establishing power and promoting equal economic opportunity for Black individuals, families, and communities across all 50 states.

The African American Alliance of CDFI CEOs (the Alliance) is pleased to submit this written statement for the record, addressing the current state of issues, problems, and proposed solutions relating to capital formation and inclusive economic growth by minority business enterprises (MBEs). The Alliance is a national membership-based organization with a mission to empower Black communities by promoting economic stability, well-being, and wealth. Leveraging a network of 77 Black-led Community Development Financial Institutions (CDFIs), the Alliance is working towards establishing power and promoting equal economic opportunity for Black individuals, families, and communities across all 50 states.

The African American Alliance of CDFI CEOs (the Alliance) is pleased to submit comments regarding the Community Development Entity Certification Application. The Alliance is a national membership-based organization with a mission to empower Black communities by promoting economic stability, wellbeing, and wealth. Leveraging a network of 77 Black-led Community Development Financial Institutions (CDFIs), the Alliance is working towards establishing power and promoting equal economic opportunity for Black individuals, families, and communities across all 50 states.

The African American Alliance of CDFI CEOs (the Alliance) is pleased to submit comments regarding the Community Development Financial Institutions Program (CDFI Program) and the Native American CDFI Assistance Program (NACA Program) Financial Assistance (FA) and Technical Assistance (TA) Applications, for the Fiscal Year (FY) 2023–FY 2025 funding rounds. The Alliance is a national membership-based organization with a mission to empower Black communities by promoting economic stability, wellbeing, and wealth. Leveraging a network of 77 Black-led Community Development Financial Institutions (CDFIs), the Alliance is working towards establishing power and promoting equal economic opportunity for Black individuals, families, and communities across all 50 states.

The African American Alliance of CDFI CEOs (the Alliance) is pleased to submit comments regarding the initial proposals from the Federal Interagency Technical Working Group on Race and Ethnicity Standards (Working Group) for revising OMB’s 1997 Statistical Policy Directive No. 15: Standards for Maintaining, Collecting, and Presenting Federal Data on Race and Ethnicity (SPD 15) 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 72 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.

The African American Alliance of CDFI CEOs (the Alliance) is pleased to submit comments in response to the Request for Information (RFI) on the Environmental and Climate Justice Block Grant Program (ECJ Program), created by the Inflation Reduction Act. (IRA). 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 70 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.

The African American Alliance of CDFI CEOs (the Alliance) is pleased to submit comments regarding proposed changes to the New Markets Tax Credit Program (NMTC Program) Transaction Level Report (TLR). 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 72 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.

In the almost quarter century since its establishment under the Community Renewal Tax Relief Act of 2000, the NMTC program has successfully revitalized some of the most economically vulnerable and underserved low-income urban and rural communities in the U.S. However, as the NMTC Program investments continue to evolve, so should the reporting and compliance requirements of Community Development Entities (CDEs) that receive NMTC allocations. For these reasons, the Alliance is pleased with CDFI Fund efforts to increase transparency and ensure better outcomes for the communities targeted by the program – specifically, as it relates to reporting on data points regarding fees and transaction costs as well as reporting on community outcomes.

The African American Alliance of CDFI CEOs (the Alliance) is pleased to provide the following in response to the CDFI Fund request for comments regarding the New Markets Tax Credit (NMTC Program) Allocation and Qualified Equity Investment and Tracking System (AQEI). 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 72 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.

The African American Alliance of CDFI CEOs (the Alliance) is pleased to provide the following in response to the Office of Management and Budget (OMB) request for a final round of comment on revisions to the Community Development Financial Institutions Fund’s (CDFI Fund’s) Annual Certification and Data Collection Report (ACR) and abbreviated Transaction Level Report (TLR). 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 72 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.