Federal Community Investment Program Opportunities and Challenges

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.