Proposed Changes to the New Markets Tax Credit (NMTC) Transaction Level Report (TLR)

April 10, 2023

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.