CDFI Certification Application/OMB Control Number: 1559-0028

December 5, 2022

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.