According to Moore, NAFCU asked CDFI officials to do the following:

Defer to an applicant's functional regulator regarding what products should and should not be offered to consumers.
Provide all credit unions parity with banks and exempt them from completing the financing entity section of the new application, as well as exempting affiliates from demonstrating primary mission requirements.

CUNA recommended the following:

Establish a reasonable pathway for CDFIs to retain certification following a merger.
Amend the responsible financing practices required to avoid excluding credit unions offering PALs and responsible balloon payment or nonconforming mortgage loans.
Exclude regulated depositories from the Fund's financial interest policy so accountable credit union board members are not prohibited from obtaining loans at the credit union.
Reduce the reliance on communication via service requests in the Awards Management Information System.
Memorialize more formal due process including reasonable notice, an appeals process and an ombuds office.
Align reporting deadlines and streamlining/combining forms where appropriate.

In an editorial published in CU Times on Sept. 15, CUNA President/CEO Jim Nussle wrote, "The mission of the CDFI Fund is of upmost importance to credit unions, which strive to promote financial well-being for all and advance the communities they serve, and the Fund itself must be protected and strengthened. Bureaucratic paperwork issues are no reason to deprive distressed communities billions in capital, yet that's what we're seeing.

Instant Insights /

CU Leaders Call for Transparency in New CDFI Certification Process

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