CDFI Fund Proposes Sweeping Certification Form Revisions, Seeks Public Comment by Nov. 30

Three Simultaneous Comment Requests

The Community Development Financial Institutions Fund (CDFI Fund) at the Department of the Treasury has published three concurrent notices requesting public comment under the Paperwork Reduction Act of 1995, all carrying a unified deadline: written comments must be received on or before November 30, 2026, to be assured of consideration. The three collections at issue are the CDFI Certification Application (OMB Control Number 1559-0028), the Annual Certification and Data Collection Report (ACR) and abbreviated Transaction Level Report (TLR) (OMB Control Number 1559-0046), and the Uses of Award Report Form (OMB Control Number 1559-0032). All forms are submitted through the CDFI Fund's Awards Management Information System (AMIS).

What CDFIs Are and Why Certification Matters

As the notices describe, a certified CDFI is a specialized financial institution that works in markets underserved by traditional financial institutions, providing financial products and services in economically distressed target markets — including mortgage financing for low-income and first-time homebuyers and not-for-profit developers, flexible underwriting and risk capital for community facilities, and commercial loans and investments to small start-up or expanding businesses in low-income areas. CDFIs include regulated institutions such as community development banks and credit unions, and non-regulated institutions such as loan and venture capital funds. CDFI certification, conferred by the CDFI Fund, is a requirement for accessing Financial Assistance awards through the CDFI Program, the Native American CDFI Assistance Program (NACA Program), and the Small Dollar Loan Program (SDL Program), as well as bond guarantees through the CDFI Bond Guarantee Program and certain benefits under the Bank Enterprise Award Program (BEA Program). Certification is also a prerequisite for bank eligibility under the Capital Magnet Fund Program. The CDFI Fund is authorized by the Riegle Community Development Banking and Financial Institutions Act of 1994 (Pub. L. 103-325, 12 U.S.C. 4701 et seq.), with certification regulations at 12 CFR 1805.201. Since 1997, the universe of Certified CDFIs has grown from 196 to nearly 1,300 organizations, with nearly $437 billion in total assets and headquarters in all fifty states, the District of Columbia, Guam, and Puerto Rico.

Certification Application: Proposed Policy Changes

The proposed revisions to the CDFI Certification Application represent substantive policy changes, not merely technical updates. According to the notice, in December 2023 the CDFI Fund released a revised version of the Certification Application — the culmination of an effort begun in January 2017 to ensure certification policies continue to meet statutory and regulatory requirements, remain responsive to the evolving CDFI industry, and protect government resources. Now that the CDFI Fund has reviewed close to 1,400 CDFI Certification Applications submitted under that revised version, it is seeking comment on further changes the notice states are designed to align CDFI Certification with the Administration's executive orders and efforts to reduce waste, fraud, and abuse within federal programs.

The most significant proposed changes concern Target Market eligibility. The notice states that "Other Targeted Population—African American," "Other Targeted Population—Hispanic," "Other Targeted Population—Other Pacific Islander," "Other Targeted Population—Filipino," and "Other Targeted Population—Vietnamese" will no longer be eligible Target Market types. More broadly, the CDFI Fund states it will no longer allow any Other Targeted Population (OTP) Target Market types based on the race and/or ethnicity of the borrower — a policy change that extends to any Section Zero Application submission proposing a new Target Market type.

The notice also states that the current certification requirement linking accountability to board representation will be revised: rather than requiring that an entity maintain accountability to each component of its CDFI Certification Market through board representation, accountability will instead be measured through Target Market activity. As a result, the updated Certification Application will no longer include a separate "Accountability" section or the separate subsection on "Native Communities Accountability" in the Native American CDFI Designation section. Additionally, the subsection on "Board and Executive Staff Demographic Information" will be eliminated except for two questions on the total size of governing leadership members and total size of Executive Staff. New questions are being added to the Basic Information section to assess the applicant's and any relevant affiliate's past administrative proceedings history and compliance in other federal award programs.

ACR and Abbreviated TLR: Aligned Changes

The proposed changes to the ACR and abbreviated TLR mirror those in the Certification Application. The notices state that the ACR will eliminate references to the same race- and ethnicity-based Other Targeted Population categories being removed from the Application. The Abbreviated TLR will no longer include data fields collecting information about minority status or sex of the business owner, nor fields related to climate-centered financing. The ACR's "Board and Executive Staff Demographic Information" subsection will similarly be eliminated except for the two governing leadership and executive staff size questions. The "Accountability" section and the "Native American TM Accountability Attestation" question related to board accountability will also be removed from the ACR. Several questions are being added to the ACR to assess changes in administrative proceedings history and compliance in other federal award programs for certified CDFIs and relevant affiliates. The CDFI Fund states it anticipates the overall effect of these changes will be a net reduction in burden to Certified CDFIs and CDFI Certification Applicants.

Uses of Award Report: Extension Without Change

The third notice covers the Uses of Award Report Form, submitted annually by recipients of the BEA Program, CDFI Program, NACA Program, and SDL Program — due three months after the Period of Performance end date (for BEA Program) or fiscal year end (for CDFI, NACA, and SDL Programs). Unlike the other two collections, the CDFI Fund proposes no significant content change to this form, characterizing the action as an extension without change of a currently approved collection. According to the notice, the estimated number of respondents is 1,114, with an estimated total of 2,228 annual responses, an estimated annual time per respondent of 0.75 hours, and estimated total annual burden hours of 1,671 hours. The report is used to determine recipient compliance with performance goals in their Award or Assistance Agreement and to demonstrate how award funds are expended.

What to Watch

All three comment periods close November 30, 2026. The CDFI Fund states that comments submitted in response to these notices will be summarized and/or included in requests for Office of Management and Budget (OMB) approval, will become a matter of public record, and may be published on the CDFI Fund website. Capitalized terms in the notices are defined in the regulations governing the CDFI Program at 12 CFR 1805.104.

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