Overview of proposed change: The CDFI Fund’s notice proposes to eliminate the board accountability provisions that CDFIs currently are required to satisfy for certification by the Fund. As the Fund explains,


“The CDFI Fund will revise the current CDFI Certification requirement that in order to be certified as a CDFI, an entity must maintain accountability to each component of its CDFI Certification Market through board representation to instead replace board representation with Target Market activity. As a result, the updated version of the CDFI Certification Application will no longer have a separate ‘‘Accountability’’ section or the separate subsection on ‘‘NATIVE COMMUNITIES ACCOUNTABILITY’’ in the Native American CDFI Designation section. Accountability will instead be measured through the Target Market lending activity section of the CDFI Certification Application.”


As a reminder, under the current CDFI Certification Application process, (1) a minimum of one-third of a CDFI’s board members must be representative of its Target Market, and (2) for Native CDFIs, one-half of those board members who are accountable must be OTP Native.

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1. Enter your name: (Required.)

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2. Your Position Title: (Required.)

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3. Organization's/Tribe's Name: (Required.)

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4. Based on the explanation provided above, which one of the following three options does your Native CDFI support? (Required.)

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5. Optional – Do you have additional thoughts to share about the CDFI Fund’s proposed change and why you chose the answer you did? If so, please enter them below.

NCN thanks you for your response, and it will share its comment letter with Native CDFIs once it has been finalized and submitted to the CDFI Fund.

If you have any questions about the proposed CDFI Certification changes or this survey, please contact NCN CEO Pete Upton at (308) 850-0303 or Lisa Wagner of Bluestem Consulting, Inc. at (307) 620-5300.

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