Category: PUBLIC POLICY COMMENTS

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.

On November 7, 2022, Volume 87, No. 214 of the Federal Register contained a Notice of Proposed Rulemaking on Small Business Lending Company (SBLC) Moratorium Rescission and Removal of the Requirement for a Loan Authorization (87 FR 66963).1 The proposed rule, if implemented, will lift the moratorium on licensing new Small Business Lending Companies (SBLCs), add a new type of entity called a Mission-Based SBLC, and remove the requirement for a Loan Authorization.

The African American Alliance of CDFI CEOs (the Alliance) is pleased to provide the following comments in response to the Proposed Rulemaking, 87 FR 66963. 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.

On October 26, 2022 Volume 87, No. 206 of the Federal Register contained a Notice of Proposed Rulemaking on Affiliation and Lending Criteria for the SBA Business Loan Programs (87 FR 64724). The purpose of the proposed Rule is to streamline and modernize regulations on lending criteria and loan conditions for the 7(a) and 504 loan programs to better help meet the needs of America’s small businesses, create jobs, assist with recovery from the COVID-19 pandemic, and grow the economy.

The African American Alliance of CDFI CEOs (the Alliance) is pleased to provide the following comments in response to the Proposed Rulemaking, 87 FR 64724. 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.

Thank you for the opportunity to comment on the Notice and Request for Information on Federal Community Investment Program Opportunities and Challenges (87 FR 60236).

The African American Alliance of CDFI CEOs (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 Alliance supports the Interagency Community Investment Committee’s (ICIC) goal of promoting economic conditions and systems that reduce racial disparities and produce stronger economic outcomes for all communities. Our comments offer feedback as to how community investment programs can more efficiently and effectively utilize Black-led Community Development Financial Institutions (CDFIs) to expand access to critical capital and financial resources for historically underserved communities.

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 revised Community Development Financial Institution (CDFI) Certification Application. 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 Alliance applauds the Fund’s effort to address the concerns of many CDFIs and CDFI member organizations during the 2020 comment period. By making changes to the CDFI Certification Application it holds future organizations wishing to obtain the CDFI designation accountable. The Alliance is aligned with many of the Fund’s suggested changes to the application and would like to provide comments and recommendations on collecting race and demographic data on CDFI leadership, the primary mission test where responsible financing criteria is clearly laid out for potential CDFI applicants, the target markets section regarding geographic areas and adjustment of the financial products threshold and the accountability section for governing and advisory boards. The Alliance believes the Certification Application changes will help those CDFIs with the highest levels of service delivery stay accountable to the minority and underserved populations that they serve.

The Community Builders of Color Coalition (the Coalition) is pleased to provide the following comments in response to the U.S. Environmental Protection Agency (EPA) request for feedback regarding implementation of the Greenhouse Gas Reduction Fund (GHGRF). The Coalition is a group of 9 organizations that are committed to helping historically underserved communities achieve social, economic and climate justice through community development.

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.

On behalf of the member of the African American Alliance of CDFI CEOs (the Alliance), we respectfully submit the following comments in response to the Department of the Treasury (Treasury) request for comments on how Treasury can use its authorities to fund technical assistance (TA) to very-small businesses (VSBs) and business enterprises owned and controlled by socially and economically disadvantaged individuals (SEDI-owned businesses applying to State Small Business Credit Initiative (SSBCI) credit and investment programs.

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.

As financial leaders directly serving diverse communities, the African American Alliance of Community Development Financial Institutions (CDFI) CEOs (the Alliance) is a membership- driven intermediary organization of 67 Black-led CDFIs, which aims to build the capacity of member organizations, expand access to capital for member organizations, and build power in Black communities by challenging and influencing financial sectors to operate more equitably. Our 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. Currently, 10 Alliance members are Federal Home Loan Bank (FHLB) members, and this letter highlights the challenges and operational issues hose members face as they navigate the FHLB System. Additionally, we provide recommendations for increasing program access and usefulness for our members and other non-depository CDFIs across the country.

The African American Alliance of CDFI CEOs (the Alliance) appreciates the opportunity to comment on Docket ID OCC-2022-0002, the “Notice of Proposed Rulemaking on Reforming the Community Reinvestment Act Regulatory Framework,” the most comprehensive update to the CRA regulation and exams since 1995. As financial leaders directly serving diverse communities, the Alliance is a membership-driven intermediary organization of over 64 Black-led CDFIs 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 it was enacted in 1977, CRA has been one of the most impactful federal policies for affordable housing and community development financing. Between 2009 and 2020, banks have made more than $2.58 trillion in home loans to low- and moderate-income (LMI) borrowers or in LMI census tracts and $856 billion in loans to small businesses with revenues under $1 million.1 The latest CRA regulatory proposal builds upon this progress and the Alliance believes the following reforms will be instrumental in meeting the CRA’s goal of meeting the credit needs of LMI communities.