Community Development Financial Institutions July 1, 2022
(CDFI) Fund: Overview and Programs
Donald J. Marples
As communities face a variety of economic challenges, some may look to local banks and
Specialist in Public Finance
financial institutions for solutions that address the specific development needs of low-income and
distressed communities. Community development financial institutions (CDFIs) provide financial
Darryl E. Getter
products and services, such as mortgage financing for homebuyers and not-for-profit developers;
Specialist in Financial
underwriting and risk capital for community facilities; technical assistance; and commercial loans
Economics
and investments to small, start-up, or expanding businesses. CDFIs include regulated institutions,
such as community development banks and credit unions, and nonregulated institutions, such as
loan and venture capital funds.
The Community Development Financial Institutions Fund (Fund), an agency within the Department of the Treasury,
administers several programs that encourage the role of CDFIs and similar organizations in community development. Nearly
1,000 financial institutions located throughout all 50 states and the District of Columbia are eligible for the Fund’s programs
to provide financial and technical assistance to meet the needs of businesses, homebuyers, community developers, and
investors in distressed communities. In addition, the Fund certifies entities and designates areas that are eligible for the New
Markets Tax Credit.
This report begins by describing the Fund’s history, its current appropriations, and each of its programs. A description of the
Fund’s process of certifying certain financial institutions to be eligible for the Fund’s program awards follows. The next
section provides an overview of each program’s purpose, use of award proceeds, eligibility criteria, and relevant issues for
Congress. The final section analyzes congressional concerns about duplicative programs and program effectiveness.
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Community Development Financial Institutions (CDFI) Fund: Overview and Programs
Contents
Introduction ..................................................................................................................................... 1
Legislative Origins and Current Structure ................................................................................ 2
Budget ....................................................................................................................................... 3
Entity Certification .......................................................................................................................... 4
Certified Community Development Financial Institutions ....................................................... 4
Certified Community Development Entities (CDEs) ................................................................ 6
CDFI Fund Programs: General Purpose .......................................................................................... 6
CDFI Monetary Awards ............................................................................................................ 6
Native American CDFI Assistance ..................................................................................... 8
Small and Emerging CDFI Assistance ................................................................................ 9
New Markets Tax Credit ........................................................................................................... 9
Bank Enterprise Award ............................................................................................................ 10
Bond Guarantee Program ......................................................................................................... 11
Small Dollar Loan Program ..................................................................................................... 11
Capital Magnet Fund ............................................................................................................... 12
CDFI COVID-19 Responses ................................................................................................... 12
CDFI Rapid Response Program ........................................................................................ 12
CDFI Equitable Recovery Program .................................................................................. 12
CDFI Fund Programs: Specific Purposes ...................................................................................... 13
The Healthy Food Financing Initiative ................................................................................... 13
Persistent Poverty Counties ..................................................................................................... 13
Disability Fund ........................................................................................................................ 14
Economic Mobility Corps ....................................................................................................... 14
Policy Considerations .................................................................................................................... 14
Figures
Figure 1. Certified CDFIs, by Location ........................................................................................... 5
Tables
Table 1. Community Development Financial Institutions (CDFI) Fund Programs
Funding, FY2016 to FY2023 (Requested) ................................................................................... 3
Contacts
Author Information ........................................................................................................................ 16
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Community Development Financial Institutions (CDFI) Fund: Overview and Programs
Introduction
The Community Development Financial Institutions Fund (CDFI Fund or Fund) was created by
the Riegle Community Development Regulatory Improvement Act of 1994 (P.L. 103-325)1 to
promote economic development in distressed urban and rural communities, particularly through
certifying and supporting community development financial institutions (CDFIs).2 The CDFI
Fund, now an agency within the Department of the Treasury, is authorized to certify banks, credit
unions, nonprofit loan funds, microloan funds, and (for-profit and nonprofit) venture capital funds
as designated CDFIs. Financial institutions that wish to become CDFIs must meet specified
eligibility criteria, such as demonstrating that their primary mission is to promote community
development by serving economically distressed people and places.3 CDFIs work in market
niches in both rural and urban communities that are difficult for traditional financial institutions
to serve.4 CDFIs can be regulated institutions, such as community development banks and credit
unions, as well as nonregulated institutions, such as loan and venture capital funds.
After receiving certification, CDFIs are eligible to receive financial awards and other assistance
from the Fund.5 CDFIs subsequently provide a range of financial products and services in
economically distressed markets, such as mortgage financing for low-income and first-time
homebuyers and not-for-profit developers, flexible underwriting and capital for needed
community facilities, technical assistance, and commercial loans and investments to small start-
up or expanding businesses in low-income areas.6
Some stakeholders are concerned that a shortage of capital from CDFIs will reduce opportunities
for new entrepreneurs to establish a business, existing businesses to expand and hire new
workers, and consumers to acquire the credit they need to buy or make improvements to a
property. Others believe that these goals can be better served through other public policy or
private means given that many of the Fund’s programs and other federal programs (e.g., Small
Business Administration capital access programs) have similar missions.7 However, the costs paid
by targeted beneficiaries for greater capital access may vary by delivery channel. Other federal
programs may face more pricing restrictions compared to CDFIs, which may be able to charge
their customers somewhat more for the elevated financial risk they tend to pose. In other words,
1 See U.S. Department of the Treasury, “Community Development Financial Institutions Fund,” at
https://www.cdfifund.gov/about.
2 See Federal Reserve Bank of Richmond,
Community Development Financial Institutions: A Unique Partnership for
Banks, Special Issue 2011, pp. 1-7, at https://www.richmondfed.org/~/media/richmondfedorg/
community_development/resource_centers/cdfi/pdf/cdfi-special-2011.pdf.
3 For more information, see U.S. Department of the Treasury, CDFI Fund, “CDFI Certification,” at
https://www.cdfifund.gov/programs-training/certification/cdfi.
4 Janet L. Yellen, Chair of the Federal Reserve Board of Governors, “Welcoming Remarks,” Speech at Community
Banking in the 21st Century Fifth Annual Community Banking Research and Policy Conference cosponsored by the
Federal Reserve System and Conference of State Bank Supervisors, Federal Reserve Bank of St. Louis, St. Louis, MO,
October 4, 2017, at https://www.federalreserve.gov/newsevents/speech/yellen20171004a.htm.
5 Office of the Comptroller of the Currency (OCC),
Bank Partnerships With Community Development Financial
Institutions and Benefits of CDFI Certification, September 2019, https://www.occ.gov/publications-and-resources/
publications/community-affairs/community-developments-fact-sheets/pub-fact-sheet-bank-partnerships-with-cdfis.pdf.
6 In this report,
capital will be used interchangeably with
funds or
funding primarily in the form of loans rather than in
the form of an equity investment.
7 For more information on Small Business Administration capital access programs, see CRS Report RL33243,
Small
Business Administration: A Primer on Programs and Funding, by Robert Jay Dilger, R. Corinne Blackford, and
Anthony A. Cilluffo.
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while various programs may have overlapping objectives, differences in the delivery of benefits
may allow for some or very little of the costs or risks to be shared with taxpayers. For this reason,
determining the extent of substitutability and complementarity among the Fund and other federal
programs may be challenging.
This report begins by describing the Fund’s history and its current appropriations. Next, the report
presents an overview of the various programs the Fund administers to achieve its mission. The
final section of the report analyzes selected policy considerations of congressional interest
regarding the Fund and the effective use of federal resources to promote economic development.
Legislative Origins and Current Structure
The CDFI Fund was established by the Riegle Community Development and Regulatory
Improvement Act of 1994 (P.L. 103-325) with a mission to expand economic opportunity for
underserved people and communities by supporting the growth and capacity of a national
network of community development lenders, investors, and financial service providers. The
legislation intended to improve the supply of capital, credit, private investment, and development
services in economically distressed areas. In proposing the Fund, President Clinton stated that “by
ensuring greater access to capital and credit, we will tap the entrepreneurial energy of America’s
poorest communities and enable individuals and communities to become self-sufficient.”8
Although the Riegle Act created the Fund as a wholly owned, independent government
corporation, a supplemental appropriations bill moved the Fund into the Department of the
Treasury (Treasury) in 1995.9 The Fund was moved within Treasury due to its focus on financial
institutions and because other financial regulatory agencies (e.g., Office of the Comptroller of the
Currency) were already located within the agency.10 The Fund is a component of the programs of
the Under Secretary’s Office of Domestic Finance, and it is directly under the Assistant Secretary
for Financial Institutions.11
The Fund is headed by a director who is appointed by the Secretary of the Treasury and not
subject to Senate confirmation. Initially, the director served a maximum three-year term.
However, the Fund was led by approximately 10 directors in its first 15 years. To bring greater
stability to the Fund’s leadership, the Secretary of the Treasury made the director’s position into a
career appointment in 2010, meaning there are no limits on the length of the director’s term. Jodie
Harris has been director of the Fund since January 2019.12
8 U.S. Congress, House Committee on Banking, Finance, and Urban Affairs,
Proposed Legislation: The Community
Development Banking and Financial Institutions Act of 1993, Message from the President, 103rd Cong., 1st sess., July
15, 1993, H.Doc. 103-118.
9 The Emergency Supplemental Appropriations for Additional Disaster Assistance, for Anti-terrorism Initiatives, for
Assistance in the Recovery from the Tragedy that Occurred at Oklahoma City, and Rescissions Act, 1995 (P.L. 104-
19).
10 See Lehn Benjamin, Julia Sass Rubin, and Sean Zielenbach, “Community Development Financial Institutions:
Current Issues and Future Prospects,” paper presented at Board of Governors of the Federal Reserve System’s
Community Affairs Research Conference,
Sustainable Community Development: What Works, What Doesn't, and Why,
March 28, 2003, p. 7, at http://www.federalreserve.gov/communityaffairs/national/CA_Conf_SusCommDev/pdf/
zeilenbachsean.pdf.
11 U.S. Department of the Treasury, “Organizational Structure,” at https://home.treasury.gov/about/general-
information/organizational-chart.
12 Community Development Financial Institutions Fund, “Message from CDFI Fund Director Jodie Harris,” press
release, January 31, 2019, https://www.cdfifund.gov/news/335.
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By statute, the Fund also has a 15-member Community Development Advisory Board. The board
members include the Secretaries of Agriculture, Commerce, Housing and Urban Development
(HUD), Interior, and the Treasury; the Administrator of the Small Business Administration
(SBA); and nine private citizens appointed by the President. The advisory board’s function is to
advise the director of the Fund on policies regarding the Fund’s activities. The advisory board is
not allowed, by law, to advise the Fund on the granting or denial of any particular applications for
monetary or nonmonetary awards.
Although the Fund is organized within Treasury’s Office of Domestic Finance, in recent years
Congress has provided the Fund with its own budget authority line in annual financial services
appropriations bills.13 These appropriations go toward the Fund’s administration, programs, and
program awards. The Fund’s appropriations cover administration of approvals for allocations of
the New Markets Tax Credit (NMTC); however, the actual tax credit is awarded through the
Internal Revenue Code, not through the Fund’s appropriations.
Budget
As shown i
n Table 1, the Fund’s total expected budget authority for FY2021 was $270.0 million.
Of this total, 61% ($165.0 million) was appropriated for the Fund’s core CDFI financial and
technical assistance programs; 11% ($29.0 million) was appropriated for administration of the
Fund’s programs, including the NMTC; 10% ($26.0 million) was appropriated for the Bank
Enterprise Award (BEA) program; and the remaining 19% ($50.0 million) was appropriated for
set-asides for other specific programs.
Table 1. Community Development Financial Institutions (CDFI) Fund
Programs Funding, FY2016 to FY2023 (Requested)
(in millions of dollars)
FY21
FY22
Budget
(Operating (Annualized
FY23
Activity
FY16
FY17
FY18 FY19
FY20
Plan)
CR)
(Request)
CDFI Program
153.4
161.5
160.0
160.0
165.5
165.0
165.0
215.4
Administration
23.6
26.0
27.0
27.0
28.5
29.0
29.0
35.0
Healthy Food
22.0
22.0
22.0
22.0
22.0
23.0
23.0
23.0
Financing
Initiative (HFFI)
Bank Enterprise
19.0
23.0
25.0
25.0
25.0
26.0
26.0
26.0
Award (BEA)
Program
Native American
15.5
15.5
16.0
16.0
16.0
16.5
16.5
21.5
CDFI Assistance
(NACA)
Total Budget
233.5
233.1
250.0 250.0
262.0
270.0
270.0
331.4
Authority
Sources: U.S Department of the Treasury, Community Development Financial Institutions Fund FY2023
Congressional Justification for Appropriations and Annual Performance Plan, at https://home.treasury.gov/system/
files/266/12.-CDFI-FY-2023-CJ.pdf; U.S Department of the Treasury, Community Development Financial
Institutions Fund FY2020 Congressional Justification for Appropriations and Annual Performance Plan, at
13 During the Clinton Administration, funding was provided through the annual Veterans Affairs-HUD-Independent
agencies appropriations act.
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https://home.treasury.gov/system/files/266/11.-CDFI-FY-2020-CJ.pdf; and U.S Department of the Treasury,
Community Development Financial Institutions Fund FY2018 Congressional Justification for Appropriations and
Annual Performance Plan, at https://home.treasury.gov/system/files/266/11.-CDFI-FY-2018-CJ.pdf.
Note: Total budget authority numbers do not add up to program totals because programs that were not
reported during the entire time period were omitted from the table.
In the FY2023 budget request, the Administration requested an additional $50.4 million to
increase the amount of financial assistance (FA) and technical assistance (TA) awards14 and $5.0
million to be directed toward Native American communities. An additional $6.0 million in
administration funding was requested to increase compliance, data collection, and IT systems
development.
Entity Certification
To be eligible for certain CDFI Fund-related programs, an organization must be certified as a
CDFI or Community Development Entity (CDE). CDFIs are eligible for CDFI Program FA and
TA. CDEs are eligible for the NMTC.
Certified Community Development Financial Institutions
Community Development Financial Institution certification is a designation overseen by the
CDFI Fund. CDFIs include regulated institutions such as community development banks and
credit unions, and nonregulated institutions like loan and venture capital funds. By building the
capacity of a nationwide network of CDFIs, the CDFI Fund works to empower low-income and
underserved people and communities to expand economic opportunity.
Types of CDFIs
Community development intermediaries facilitate various revitalization activities between large investors and a
defined population of community development corporations, CDFIs, or nonprofit organizations.
Depository institutions consist of for-profit community development banks and nonprofit community
development credit unions. Depositories offer a range of consumer and institutional savings, checking, and
lending services. These CDFIs have primary prudential regulators because their deposits are federal y
insured.
Loan funds are nonregulated, nonprofit institutions that focus on one or more aspects of capital access
and community development, such as small business lending, home mortgage financing, and community
facilities development financing.
Community development venture capital funds are for-profit or nonprofit institutions that deliver equity
capital to businesses in distressed communities.
Source: Federal Reserve Bank of Richmond, “Community Development Financial Institutions: A Unique
Partnership for Banks,” Community Development Special Issue, 2011, https://www.richmondfed.org/~/media/
richmondfedorg/community_development/resource_centers/cdfi/pdf/cdfi-special-2011.pdf.
An applicant eligible for CDFI certification must be a legal entity; have a primary mission of
promoting community development; maintain accountability to and provide financial and
educational products or services to targeted communities or other targeted populations that have
historically lacked adequate access to capital; and be a nongovernment entity and not under the
control of any government entity (except tribal governments).15
14 For more information on these award types, see the
“CDFI Monetary Awards” section.
15 U.S. Government Accountability Office (GAO),
Community Development Financial Institutions and New Markets
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Certified CDFIs are eligible to apply for awards through a variety of programs offered by the
CDFI Fund.16 These awards enable CDFIs to finance a wide range of activities—including
mortgage lending for first-time homebuyers, flexible underwriting for community facilities, and
commercial loans for businesses in low-income areas. Through varying strategies, each CDFI
contributes to the cultivation of a healthy and stable local economy.
Figure 1. Certified CDFIs, by Location
Source: Community Development Financial Institutions Fund, at https://www.cdfifund.gov/programs-training/
certification/cdfi/Pages/default.aspx.
As of November 17, 2021, there were 1,271 certified CDFIs.17 As shown i
n Figure 1, at least one
CDFI is located in each of the 50 states, the District of Columbia, Guam, and Puerto Rico.
Mississippi, California, and New York each contain more certified CDFIs than any remaining
U.S. state or territory. Of the 1,271 certified CDFIs, 564 (44%) are loan funds, 389 (31%) are
credit unions, 168 (13%) are banks or thrifts, 134 (11%) are depository institution holding
Tax Credit Programs in Metropolitan and Nonmetropolitan Areas, GAO-12-547R, April 26, 2012, p. 4, at
http://www.gao.gov/products/GAO-12-547R.
16 An organization that does not meet each of the certification eligibility requirements at the time of application for
technical assistance is still eligible to apply for and receive technical assistance. This may occur if the Fund determines
that the organization’s application materials provide a realistic course of action to ensure that it will meet each of the
certification requirements within two years of entering into an assistance agreement with the Fund.
17 For a list of these certified CDFIs with their contact information, see CDFI Fund, “CDFI Certification,” at
https://www.cdfifund.gov/programs-training/certification/cdfi.
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companies, and 16 (1%) are venture capital funds. Of the 1,271 certified CDFIs, 70 (6%) are
certified Native American CDFIs.
Certified Community Development Entities (CDEs)
Community Development Entity (CDE) certification is another designation administered by the
CDFI Fund. A CDE can be either a for-profit or a not-for-profit entity that acts as an intermediary
vehicle for the provision of loans, investments, or financial counseling in a low-income
community (LIC). The primary benefit of CDE certification is eligibility to apply for a New
Markets Tax Credit (NMTC) allocation.18
An applicant eligible for CDE certification must be a legal entity and a domestic corporation or
partnership for federal tax purposes; have a primary mission of serving or providing investment
capital to low-income communities or low-income individuals and target at least 60% of activities
to these groups; and maintain accountability to low-income communities through representation
on a governing or advisory board. As of July 31, 2012, there were 5,780 certified CDEs
(including their subsidiaries) located throughout the 50 states, the District of Columbia, Puerto
Rico, and the U.S. Virgin Islands.19
CDFI Fund Programs: General Purpose
Throughout the 1980s and early 1990s, geographically targeted community development policies
were a feature of federal policy debates.20 The CDFI Fund’s statutory mission, therefore, was
designed to increase economic opportunity and promote community development investments in
low-income and distressed communities in the United States. All of the Fund’s numerous
programs use geographically targeted incentives to increase community development in
underserved and distressed communities where certain types of economic activity might not
otherwise occur. For example, the Fund’s programs encourage qualified entities to provide
financial and technical assistance to meet the needs of local businesses, potential homebuyers,
community developers, and potential investors in low-income and distressed communities. The
Fund’s range of incentives includes equity investment in program awardees, tax credits, grants,
loans, and deposits and credit union shares in insured CDFIs and state-insured credit unions.21
This section presents summaries of the Fund’s primary programs.
CDFI Monetary Awards
The Community Development Banking and Financial Institutions Act of 1994, included in the
Riegle Community Development and Regulatory Improvement Act of 1994 (P.L. 103-325),
authorized the Fund’s core CDFI program. The CDFI program provides two types of monetary
awards, financial assistance (FA) and technical assistance (TA). These awards are given to CDFIs
18 NMTC allocations can only be used by a for-profit CDE. If NMTCs are awarded to a not-for-profit CDE, the CDE
must transfer the NMTCs to a for-profit CDE prior to signing an allocation agreement.
19 The Fund has not updated its public counts of certified community development entities (CDEs) since this date and
has removed the spreadsheet of certified CDEs from its website.
20 For a historical analysis of these debates, see the discussion section of CRS Report R41268,
Small Business
Administration HUBZone Program, by Robert Jay Dilger and R. Corinne Blackford
21 12 C.F.R. §1805.401.
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to build their capacity to serve low-income people and populations that lack access to affordable
financial products and services and are located in a distressed community.22
A CDFI must be certified or be in the process
The CDFI Program’s
of being certified by the Fund before it is
Definition of a Distressed Community
eligible for an FA award. Both certified and
A contiguous area located within a unit of general
noncertified CDFIs are eligible to apply for
local government that has a population, as
TA awards. Applicants that are not yet
determined by the most recent census data
certified must submit a separate certification
available, of at least 4,000, if any portion of the
application to be considered for an FA award
area is located within a metropolitan area with a
population of at least 50,000; has a population of
during a funding round.23 If a noncertified
at least 1,000 in any other case; or is located
organization receives a TA award, then the
entirely within an Indian reservation.
organization must obtain certification within
At least 30% of the eligible residents have incomes
two years.
that are less than the national poverty level, as
published by the U.S. Bureau of the Census in the
The Fund awards grants for several types of
most recent decennial census for which data are
FA purposes. Maximum amounts for FY2022
available; the unemployment rate is at least 1.5
range from $300,000 to $5 million, depending
times greater than the national average, as
on the FA component.24 A CDFI may use an
determined by the U.S. Bureau of Labor Statistics’
(BLS’s) most recent data, including estimates of
FA award for lending, investing, enhancing
unemployment developed using the BLS’s Census
liquidity, or other means of financing.25
Share calculation method.
The Fund also awards grants for TA awards,
Such additional requirements as may be specified
with a maximum amount of $125,000 for
by the Fund in the applicable notice of funds
availability.
FY2022. TA awards are intended to build a
Source: 12 C.F.R. §1806.401(b).
CDFI’s technical capacity to provide
affordable financial products and services to
low-income communities and families. TA grants may be used for a variety of purposes,
including purchasing equipment, materials, or supplies; procuring for consulting or contracting
services; paying the salaries and benefits of certain personnel; training staff or board members;
and conducting other activities deemed appropriate by the Fund.26
FA and TA awards are both generally subject to two restrictions. First, the Fund typically requires
an applicant to demonstrate that it can match award funds with those from other sources. With
regard to FA awards, the Fund is authorized to make awards to applicants in a
like form to the
22 Regulations pertaining to the CDFI Fund’s financial assistance (FA) and technical assistance (TA) are located in 12
C.F.R. §§1805.300-1805.303.
23 In evaluating and selecting applicants for awards, the Fund evaluates the applicant’s likelihood of meeting its goals
as described in a required comprehensive business plan. The Fund also considers the applicant’s prior history of
servicing distressed communities, operational capacity, financial track record, and other attributes. 12 C.F.R.
§1805.701.
24 U.S. Department of the Treasury, “Notice of Funds Availability (NOFA) Inviting Applications for Financial
Assistance (FA) Awards or Technical Assistance (TA) Grants Under the Community Development Financial
Institutions Program (CDFI Program) Fiscal Year (FY) 2022 Funding Round,” 87
Federal Register 8085-8107,
February 11, 2022.
25 A listing of permissible uses includes commercial facilities that promote revitalization, community stability, or job
creation or retention; businesses that provide jobs to, are owned by, or enhance the availability of products and services
to low-income individuals; housing that is principally affordable to low-income persons, with some exceptions; the
provision of consumer loans; and other businesses or activities as requested by the applicant and deemed appropriate by
the Fund. 12 C.F.R. §1805.301.
26 12 C.F.R. §1805.303.
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matching funds secured by the awardee.27 For example, the Fund can only match a nonfederal
grant with an FA grant—not a loan. Second, the Fund generally limits any one entity or its
affiliates from receiving more than $5 million in awards from the Fund within a three-year
period.28
The Fund awarded 248 organizations FA awards and 174 organizations TA awards totaling $188.5
million in FY2021.29 The recipient organizations were headquartered in 43 states, Puerto Rico,
and the District of Columbia.
Native American CDFI Assistance
The Native American CDFI Assistance (NACA) component of the CDFI program originated in
the Riegle Act of 1994. The Riegle Act mandated that the CDFI Fund conduct a study of lending
and investment practices on Indian reservations. The study was directed to identify and determine
the impact of private-financing barriers on Native American populations.30 Since the November
2001 release of the Native American Lending Study, the Fund certifies Native CDFIs and
provides assistance through the CDFI program’s authority. These programs are designed to
reduce barriers that prevent access to credit, capital, and financial services in Native American,
Alaska Native, and Native Hawaiian communities (collectively referred to as Native
Communities).31
Under the NACA component of the CDFI program, the Fund receives a separate appropriation
and issues FA and TA awards to organizations with the primary mission of increasing access to
capital in Native Communities.32 In addition, the NACA component provides TA grants to
certified Native CDFIs, emerging Native CDFIs, and sponsoring entities (see below). TA awards
may be used by the recipient to become certified as a Native CDFI or to create a new Native
CDFI.
A CDFI must be certified by the Fund as one of three types of entities to become eligible for
NACA’s FA and TA awards:33
certified Native CDFIs, which are organizations that direct at least 50% of their
activities toward serving Native Communities;
emerging Native CDFIs, which are organizations that demonstrate to the
satisfaction of the Fund that they have a plan to achieve Native CDFI
certification within a reasonable timeframe; or
27 12 C.F.R. §1805.501.
28 12 C.F.R. §1805.402(a). However, an entity and its affiliates may receive up to $8.75 million in awards from the
Fund within a three-year period if the entity serves an area in which there are no other applicants for awards. These
exceptions to the $5 million cap are detailed in 12 C.F.R. §§1805.402(b)-(c).
29 CDFI Fund,
CDFI Program Award Book FY2021, at https://www.cdfifund.gov/sites/cdfi/files/2021-12/
Final_2021_CDFI_Award_Book_v2.pdf.
30 P.L. 103-325, §117(c).
31 For the results of this study, see CDFI Fund,
The Report of the Native American Lending Study, November 2001, at
https://www.cdfifund.gov/sites/cdfi/files/documents/2001_nacta_lending_study.pdf.
32 In the CFDI application materials, the CDFI Fund defines native communities as “Native American, Alaska Native
and Native Hawaiian peoples or communities.” For more information, see https://www.cdfifund.gov/sites/cdfi/files/
documents/cdfi-cert-app-supplemental-guidance-and-tips-12_2018_508c-final.pdf.
33 CDFI Fund, “Native American Initiatives Program,” at https://www.cdfifund.gov/programs-training/Programs/
native-initiatives/Pages/default.aspx.
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s
ponsoring entities, which are organizations (typically tribes or tribal entities)
that pledge to create separate legal entities that will eventually become certified
as Native CDFIs.
Figure 1 identifies the locations of Certified Native CDFIs by state. Hawaii, Oklahoma, and
South Dakota each contain more certified Native CDFIs than any of the remaining 47 U.S. states.
Small and Emerging CDFI Assistance
The Small and Emerging CDFI Assistance (SECA) component of the CDFI program is designed
to assist small or emerging CDFIs. SECA provides the same type of FA and TA awards as the
general CDFI program. It distinguishes small or emerging CDFIs from other CDFIs using two
eligibility criteria, as announced in the annual notice of funds availability.34 Since FY2009, the
Fund’s appropriations have waived the matching funds requirement under the general CDFI
program for SECA FA applicants.35 Awards provided through the SECA application are subject to
caps. For FY2022, these caps included $700,000 for general FA funds and $125,000 for TA funds
for capacity-building activities.36 In FY2021, the SECA component made 68 awards totaling
$19.9 million.37
New Markets Tax Credit
The New Markets Tax Credit (NMTC) program was authorized by the Community Renewal Tax
Relief Act of 2000 (P.L. 106-554) to provide a tax incentive to stimulate stable private-sector
investment in low-income communities (LICs).38 Although the NMTC is a part of the Internal
Revenue Code, the competitively awarded NMTCs are administered by the CDFI Fund. All
CDEs are eligible to submit applications for NMTCs to the CDFI Fund, where they are evaluated
across four areas: the CDE’s (1) business strategy to invest in low-income communities, (2)
capitalization strategy to raise equity from investors, (3) management capacity, and (4) expected
impact on jobs and economic growth in low-income communities where investments are made.
After the Fund ranks the qualified applicants, the available NMTCs are allocated until exhausted.
As of January 2022, 17 rounds of NMTC Allocations have been completed with $66 billion
awarded, of which $60.8 billion has been invested.39
The CDFI Fund contracted with an independent third party to evaluate the NMTC. Although
activities consistent with achieving the CDFI’s goals were identified, the study was unable to
directly attribute those achievements to the NMTC program.40 The CDFI Fund has not contracted
for similar evaluations of its other programs.
34 Eligibility for SECA is limited to CDFIs that have been in operation no more than three years and have assets
below
thresholds based on the type of institution.
35Department of the Treasury, “Notice of Funds Availability (NOFA) inviting Applications for the fiscal year (FY)
2022 Funding Round of the Small Dollar Loan Program (SDL Program),” 87
Federal Register 30001-30017, May 17,
2022.
36 Ibid.
37 Community Development Financial Institutions Fund,
CDFI Fund Award Book - FY 2021,
https://www.cdfifund.gov/sites/cdfi/files/2021-12/Final_2021_CDFI_Award_Book_v2.pdf.
38 For additional information on the NMTC, see CRS Report RL34402,
New Markets Tax Credit: An Introduction, by
Donald J. Marples and Sean Lowry.
39 Community Development Financial Institutions Fund,
NMTC Qualified Equity Investment Report, January 3, 2022,
https://www.cdfifund.gov/sites/cdfi/files/2022-01/NMTC_QEI_Issuance_Report_January_2022_1.pdf.
40 Martin D. Abravanel et al.,
New Markets Tax Credit (NMTC) Program Evaluation: Final Report, prepared for U.S.
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Community Development Financial Institutions (CDFI) Fund: Overview and Programs
Bank Enterprise Award
The Bank Enterprise Award (BEA) was originally authorized by the Bank Enterprise Act of 1991
in the Agriculture, Rural Development, Food and Drug Administration, and Related Agencies
Appropriations Act, 1992 (P.L. 102-142). Prior to the CDFI Fund’s creation, the BEA was
administered by the Comptroller of the Currency and the Federal Deposit Insurance Corporation
(FDIC). Section 114 of the Riegle Community Development and Regulatory Improvement Act of
1994 (P.L. 103-325) moved the BEA under the Fund’s operations.
The Fund’s BEA program provides formula-based grants to FDIC-insured banks and thrifts to
expand investments in CDFIs and to increase lending, investment, and service activities within
economically distressed communities. The Fund evaluates how an applicant’s lending,
investment, and service activities may have increased relative to a baseline of similar, qualified
activities conducted by the applicant in the previous application cycle. BEA rewards are
retrospective, awarding applicants for activities they have already completed, in contrast to the
Fund’s primary CDFI program, which typically awards applicants based on their future plans.41
The BEA formula-based grants are based on the following three categories:
CDFI-related activities, such as equity investments (e.g., grants, stock purchases,
purchases of partnership interests, or limited liability company membership
interests), equity-like loans, and support activities (e.g., loans, deposits, or
technical assistance), to certified CDFIs.
Distressed community financing activities, such as loans or investments for home
mortgages, housing development, home improvement, commercial real estate
development, small businesses, and education financing in distressed
communities.
Service activities, such as financial transaction services (e.g., check-cashing or
money order services, electronic transfer accounts, and individual development
accounts).42
FDIC-insured financial institutions that are dedicated to financing and supporting economic
development in qualified communities are eligible for the BEA. No applicant may receive a BEA
if it has (1) an application pending for assistance under the current round of the awards under the
CDFI program; (2) been awarded assistance from the Fund under the CDFI program within the
12-month period prior to the date the Fund selects the applicant to receive a BEA; or (3) ever
received assistance under the CDFI program for the same activities for which it is seeking a
BEA.43 Applicants may apply for both a CDFI program award and a BEA program award in a
Department of the Treasury Community Development Financial Institutions (CDFI) Fund, Urban Institute, April 2013,
https://www.cdfifund.gov/sites/cdfi/files/documents/nmtc-program-evaluation-final-report.pdf pdf.
41 The CDFI Fund publishes a more in-depth account of its Bank Enterprise Award (BEA) application evaluation
process regularly in the program’s notice of funds availability. For example, see U.S. Department of the Treasury,
“Community Development Financial Institutions Fund - Funding Opportunity Title: Notice of Funds Availability
(NOFA) Inviting Applications for the Fiscal Year (FY) 2017 Funding Round of the Bank Enterprise Award Program
(BEA Program),” 82
Federal Register 45663-45674, September 29, 2017.
42 12 C.F.R. §1806.101(3)(c).
43 12 C.F.R. §1805.102, and see U.S. Department of the Treasury, “Community Development Financial Institutions
Fund - Funding Opportunity Title: Notice of Funds Availability (NOFA) Inviting Applications for the Fiscal Year (FY)
2017 Funding Round of the Bank Enterprise Award Program (BEA Program),” 82
Federal Register 45663-45674,
September 29, 2017.
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given year; however, receiving a CDFI program award removes an applicant from eligibility for a
BEA in the same year.44 In FY2021, 158 depository institutions received $26.0 million in BEA
program awards in 23 states and the District of Columbia.45
Bond Guarantee Program
The CDFI Fund’s Bond Guarantee Program was authorized by The Small Business Jobs Act of
2010 (P.L. 111-240).46 The program is designed to provide long-term, “patient” capital to CDFIs
at below-market rates.47 Through the program, CDFIs (or their designees) issue bonds that are
guaranteed by the Treasury and use the proceeds to make investments for eligible community or
economic development purposes. Treasury guarantees up to 10 bonds per year, each at a
minimum of $100 million.48 The total of all bonds guaranteed cannot exceed $1 billion per year.
Each bond is fully guaranteed by the United States and offered at a cost equivalent to the current
Treasury rates for comparable maturities. The bonds cannot exceed a maturity of 30 years, are
taxable, and do not qualify for Community Reinvestment Act (CRA) credit.49
Authorized uses of the loans financed may include a variety of financial activities that constitute
community or economic development in low-income or underserved areas (e.g., the provision of
basic financial services, housing that is principally affordable to low-income individuals, and
businesses that provide jobs for low-income people or are owned by low-income individuals).50
By legislative design, the Bond Guarantee Program is a zero-subsidy credit program and does not
require annual appropriations funding. Because the bonds will be guaranteed by the United
States, in accordance with federal credit policy, the Federal Financing Bank (FFB), a U.S.
government corporation under Treasury’s general supervision and direction, will purchase the
bonds issued by qualified issuers.51 Qualified issuers will lend the bond proceeds to eligible
CDFIs. The FFB finances obligations that are fully guaranteed by the United States, such as the
bonds or notes issued by CDFIs under the CDFI Bond Guarantee program.
Small Dollar Loan Program
The Small Dollar Loan Program (SDL) was authorized by the Dodd-Frank Wall Street Reform
and Consumer Protection Act (P.L. 111-203). The SDL Program was created to help certified
44 U.S. Department of the Treasury, “Community Development Financial Institutions Fund - Funding Opportunity
Title: Notice of Funds Availability (NOFA) Inviting Applications for the Fiscal Year (FY) 2017 Funding Round of the
Bank Enterprise Award Program (BEA Program),” 82
Federal Register 45663-45674, September 29, 2017.
45 CDFI Fund,
Bank Enterprise Award Program Award Book FY2021, at https://www.cdfifund.gov/sites/cdfi/files/
2022-04/2021_BEA_Award_Book_03252022_FINAL.pdf.
46 Laws pertaining to the CDFI Fund’s Bond Guarantee program are located in 12 U.S.C. §4713a.
47
Patient capital refers to an investment in which the investor has little expectation of earning a short-term return in
anticipation of earning more substantial returns in the longer run.
48 CDFI Fund, “CDFI Bond Guarantee Program,” at https://www.cdfifund.gov/programs-training/Programs/cdfi-bond/
Pages/default.aspx.
49 CDFI Fund, “CDFI Bond Guarantee Program,” at https://www.cdfifund.gov/programs-training/Programs/cdfi-bond/
Pages/default.aspx. For more information about the Community Reinvestment Act, see CRS Report R43661,
The
Effectiveness of the Community Reinvestment Act, by Darryl E. Getter.
50 CDFI Fund, “CDFI Bond Guarantee Program,” at https://www.cdfifund.gov/programs-training/Programs/cdfi-bond/
Pages/default.aspx.
51 Catalog of Federal Domestic Assistance, “Community Development Financial Institutions Bond Guarantee
Program,” at https://sam.gov/fal/8e094fbdbf47443f9227df6ebec0b8c6/view.
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Community Development Financial Institutions (CDFI) Fund: Overview and Programs
CDFIs expand consumer access to mainstream financial institutions and provide alternatives to
high-cost small-dollar loans. The program was also created to help unbanked and underbanked
populations build credit and access affordable capital. The first round of SDL awards to 52 CDFIs
totaling $10.8 million were announced on September 23, 2021.52 The recipient CDFIs are
headquartered in 30 states, the District of Columbia, and Puerto Rico.
Capital Magnet Fund
The Capital Magnet Fund (CMF) was established by the Housing and Economic Recovery Act
(HERA) of 2008 (P.L. 110-289). The CMF is intended to encourage CDFIs and other nonprofits
to expand financing for the development, rehabilitation, and purchase of affordable housing and
other related economic development projects in distressed communities. Through the CMF, the
CDFI Fund provides competitively awarded grants to CDFIs and qualified nonprofit housing
organizations. The awardees can use the award funds to create financing tools, such as loan loss
reserves, loan funds, risk-sharing loans, and loan guarantees that result in housing and community
development investment of at least 10 times the size of the award.
Two types of organizations are eligible to apply for a CMF award. An organization applying for a
CMF award must either (1) be certified as a CDFI by the Fund; or (2) be a nonprofit organization
having as one of its principal purposes the development or management of affordable housing. In
FY2020, 48 organizations received CMF awards totaling $175.4 million in awards.53
CDFI COVID-19 Responses
The Consolidated Appropriations Act, 2021 (P.L. 116-260) included $3 billion for the CDFI Fund
to provide emergency support, through two direct grant programs, to communities negatively
affected by the COVID-19 pandemic.
CDFI Rapid Response Program
The CDFI Rapid Response Program was authorized to provide $1.25 billion in grants to deliver
immediate assistance in communities impacted by the COVID-19 pandemic through an expedited
application and review process. On June 15, 2021, Treasury announced awards to 863 CDFIs for
the entire $1.25 billion authorization.54 The recipient CDFIs are headquartered in 48 states, the
District of Columbia, Guam, and Puerto Rico, and 58 are organizations that committed to direct
their awards to investments in Native American, Native Alaskan, and Native Hawaiian
communities.
CDFI Equitable Recovery Program
The CDFI Equitable Recovery Program (ERP) was authorized to provide $1.73 billion in grants
for CDFIs to enhance their response to the economic impacts of the COVID-19 pandemic. The
CDFI grants were intended to expand lending, grant making (by CDFIs), and investment activity
52 U.S. Department of the Treasury, “U.S. Treasury Announces Inaugural Round of Small Dollar Loan Program
Awards,” press release, September 23, 2021, https://www.cdfifund.gov/node/1004946.
53 CDFI Fund,
Capital Magnet Fund Award Book FY 2020, at https://www.cdfifund.gov/sites/cdfi/files/2021-04/
FY_2020_CMF_Award_Book_022221.pdf.
54 U.S. Department of the Treasury, “U.S. Treasury Awards $1.25 Billion to Support Economic Relief in Communities
Affected by COVID-19,” press release, June 15, 2021, https://www.cdfifund.gov/news/420.
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Community Development Financial Institutions (CDFI) Fund: Overview and Programs
in low- or moderate-income communities and to borrowers (including minorities) who had
significant unmet capital or financial service needs and were disproportionately impacted by the
COVID-19 pandemic. The CDFI ERP FY2022 funding round opened on June 23, 2022.55
CDFI Fund Programs: Specific Purposes
Rather than providing financial support to a CDFI to use at its discretion for mission goals, the
CDFI Fund also provides awards for specific initiatives.
The Healthy Food Financing Initiative
The Healthy Food Financing Initiative (HFFI) has roots in 2010 with an announcement of federal
efforts to improve access to healthy food in underserved urban and rural areas.56 The HFFI is part
of a multiagency effort to combat food deserts.57 It aims to expand the supply and demand for
nutritious foods, including increasing the distribution of agricultural products, developing and
equipping grocery stores, and strengthening producer-to-consumer relationships. Through its role
in the HFFI, the CDFI Fund provides grants for organizations serving low-income neighborhoods
with limited access to affordable and nutritious food, by way of CDFIs. Since 2015, the HFFI has
made 84 awards totaling $155.1 million to CDFIs in 18 states.58 In FY2021, 10 CDFIs received
$23 million in HFFI awards.59
Persistent Poverty Counties
The CDFI Fund has adopted administrative procedures to ensure that at least 10% of funds
designated for its BEA are used to support persistent poverty counties (PPCs).60 PPCs are defined
as any county, including county equivalent areas in Puerto Rico, that has had 20% or more of its
population living in poverty over the past 30 years, or any other territory or possession of the
United States that has had 20% or more of its population living in poverty over the past 30 years,
as measured by the U.S. Census Bureau.61 PPCs do not need to be located in a CDFI’s approved
target market, but only qualified activities that occur in areas determined by the CDFI Fund to be
55 CDFI Fund, “Notice of Funds Availability (NOFA) inviting Applications for grants under the CDFI Equitable
Recovery Program (CDFI ERP),” 87
Federal Register 37912-37927, June 24, 2022.
56 See U.S. Department of Treasury, “Obama Administration Details Healthy Food Financing Initiative,” press release,
February 19, 2010, https://home.treasury.gov/news/press-releases/tg555.
57 Other agencies involved in the HHFI include the U.S. Department of Treasury, U.S. Department of Agriculture, and
U.S. Department of Health and Human Services.
58 Community Development Financial Institutions Fund,
Searchable Awards Database, https://www.cdfifund.gov/
awards/state-awards.
59 Community Development Financial Institutions Fund,
CDFI Fund Award Book - FY 2021,
https://www.cdfifund.gov/sites/cdfi/files/2021-12/Final_2021_CDFI_Award_Book_v2.pdf.
60 See CDFI Fund,
Expanding Opportunity: The CDFI Fund’s FY 2019 Year In Review, at https://www.cdfifund.gov/
sites/cdfi/files/documents/cdfi_annual-report-2019_final-3.30.20_508_final.pdf.
61 Specifically, the data from U.S. Census Bureau include the decennial census, the American Community Survey, and
the Island Areas Decennial Census. For more information, see CDFI Fund, “Persistent Poverty Counties—CDFI Fund,”
at https://view.officeapps.live.com/op/view.aspx?src=
https%3A%2F%2Fwww.cdfifund.gov%2Fsites%2Fcdfi%2Ffiles%2F2021-
05%2F12_FY21_CDFI_NACA_Persistent_Poverty_Counties_2011_2015_ACS_and_Island_Areas_Decennial_Census
.xlsx.
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Community Development Financial Institutions (CDFI) Fund: Overview and Programs
distressed communities will count toward eligibility for a BEA award.62 In FY2021, 125 CDFIs
received $18.6 million in FA awards and 57 CDFIs received $7.1 million in TA awards targeted
toward PPCs.63
Disability Fund
The CDFI Fund initiated a capacity-building program to expand credit and other financial
services to people with disabilities, including people with autism, veterans, elderly people, and
people who may generally be impaired from working.64 Disabilities may increase the difficulty of
maintaining gainful employment, thus increasing the difficulty of qualifying for financial loan
products provided by traditional financial institutions. In FY2021, 14 CDFIs received $6 million
in Disability Fund awards.65
Economic Mobility Corps
The Economic Mobility Corps (EMC) is a joint initiative of the CDFI Fund and AmeriCorps, an
independent federal agency that encourages citizens to serve as volunteers in communities,
particularly to help those who are elderly, are poor, or face challenging disadvantages.66 The EMC
program is designed to enhance the capacity of CDFIs to provide financial literacy, financial
planning, budgeting, saving, and other financial counseling activities.67 EMC volunteers will
receive training in financial counseling and financial literacy and then be placed in various CDFIs
to assist residents in specific markets. Any organization—not limited to CDFIs—can apply for
EMC awards to facilitate placement of AmeriCorps service volunteers in a CDFI.
Policy Considerations
Members of Congress concerned about the size or efficient management of federal budgetary
resources have long-standing interest in identifying duplicative federal programs. CDFI Fund
programs, similar to many federal programs and initiatives, are generally aimed at expanding
access to capital in distressed communities that have historically lacked access to the capital
needed to spur economic development and provide alternatives to predatory lending.68 In 2011,
62 See CDFI Fund,
Bank Enterprise Award Program 2020 CIMS User Instructions, at https://www.cdfifund.gov/sites/
cdfi/files/documents/7.-fy-2020-bea-program-application-cims-instructions.pdf.
63 Community Development Financial Institutions Fund,
CDFI Fund Award Book - FY 2021,
https://www.cdfifund.gov/sites/cdfi/files/2021-12/Final_2021_CDFI_Award_Book_v2.pdf.
64 See CDFI Fund, “Access for All: Expanding CDFI Market Impact in the Disability Community,” at
https://www.cdfifund.gov/programs-training/training-ta/access-for-all; and CDFI Fund, “Expanding the Capacity of
CDFIs to Serve People with Disabilities,” presented at
The CDFI Fund’s Capacity Building Initiative, Access for All:
Expanding CDFI Capacity in the Disability Community, December 4-5, 2019, at https://www.cdfifund.gov/sites/cdfi/
files/documents/in-person-workshop-training-presentation.pdf.
65 Community Development Financial Institutions Fund,
CDFI Fund Award Book - FY 2021,
https://www.cdfifund.gov/sites/cdfi/files/2021-12/Final_2021_CDFI_Award_Book_v2.pdf.
66 See CDFI Fund, “Apply Now for $1.9 Million in FY 2022 Economic Mobility Corps Funding,” press release,
September 24, 2021, at https://www.cdfifund.gov/node/1004951; and AmeriCorps, “AmeriCorps and CDFI Fund
Launch Economic Mobility Corps,” press release, August 11, 2021, at https://americorps.gov/newsroom/press-release/
americorps-cdfi-fund-launch-economic-mobility-corps. See CRS Report RL33931,
The Corporation for National and
Community Service: Overview of Programs and Funding, by Joselynn H. Fountain and Abigail R. Overbay.
67 For more information, see CRS Report R46941,
Financial Literacy and Financial Education Policy Issues, by
Cheryl R. Cooper.
68 U.S. Congress, House Committee on Financial Services, Community Development Financial Institutions (CDFIs):
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GAO identified economic development programs where effectiveness may be compromised due
to overlap and arguably insufficient coordination.69 The potential for duplication may be seen by
the existence of at least 130 economic development programs overseen by over 20 offices and
agencies, including the Fund, with some examples listed below.70
The Community Development Block Grant program, administered by the
Department of Housing and Urban Development (HUD), allocates federal
assistance to state and local governments, as well as to eligible CDFIs, to support
neighborhood revitalization and community and economic development efforts.71
The Federal Home Loan Bank System provides grants on a competitive basis to
membership institutions, which may include CDFIs, to support the acquisition,
construction, or rehabilitation of affordable rental housing as well as to support
single-family housing needs for veterans and those with disabilities.72
Certain SBA programs for small business (e.g., HUBZone program, technical
assistance grant programs) overlap with Fund programs.73
The Fund’s retrospective BEA program arguably has similarities to government
guarantee programs, which typically reimburse lenders for some or all of the
losses associated with higher-risk mission lending, administered by numerous
federal agencies (e.g., HUD, USDA, SBA, Bureau of Indian Affairs) and certain
federally related government sponsored enterprises. After receiving awards from
the Fund, CDFIs may also originate loans that meet the eligibility requirements
for various federal guarantees and be reimbursed for losses.
Some of the direct lending programs that USDA, SBA, the Bureau of Indian
Affairs, and the Farm Credit System administer may overlap with certain Fund
programs.74 Furthermore, the SBA’s 504 Loan program provides long-term,
fixed-rate financing, which is also provided by the Fund’s Bond Guarantee
Program.75
Although various Fund programs are duplicative with other federal programs in terms of their
stated purpose, pricing differences could differentiate them. For example, rather than price for the
Their Unique Role and Challenges Serving Lower-Income, Underserved, and Minority Communities, 111th Cong., 2nd
sess., March 9, 2010, H.Rept. 111-106; and U.S. Congress, Senate Committee on Indian Affairs, Predatory Lending in
Indian Country, 110th Cong., 2nd sess., June 5, 2008, S.Rept. 110-484.
69 U.S. Government Accountability Office,
Opportunities to Reduce Potential Duplication in Government Programs,
Save Tax Dollars, and Enhance Revenue, GAO-11-318SP, May 1, 2011, https://www.gao.gov/assets/gao-11-318sp.pdf.
70 See CRS In Focus IF11794,
Federal Resources for State and Local Economic Development, by Julie M. Lawhorn.
71 For more information, see CRS Report R43520,
Community Development Block Grants and Related Programs: A
Primer, by Joseph V. Jaroscak; and CRS In Focus IF11749,
The Indian Community Development Block Grant
(ICDBG) Program: An Overview, by Joseph V. Jaroscak.
72 See CRS Report R46499,
The Federal Home Loan Bank (FHLB) System and Selected Policy Issues, by Darryl E.
Getter.
73 See CRS Report R41268,
Small Business Administration HUBZone Program, by Robert Jay Dilger and R. Corinne
Blackford; and CRS Report R41057,
Small Business Administration Microloan Program, by Robert Jay Dilger and
Anthony A. Cilluffo.
74 See CRS Report R46914,
An Overview of Rural Credit Markets, coordinated by Andrew P. Scott; and Farm Credit
Administration, Regulator of the Farm Credit System,
2020 Annual Report, at https://www.fca.gov/template-fca/about/
2020AnnualReport.pdf
75 See CRS Report R41184,
Small Business Administration 504/CDC Loan Guaranty Program, by Robert Jay Dilger
and Anthony A. Cilluffo.
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Community Development Financial Institutions (CDFI) Fund: Overview and Programs
above-normal risks, some federal agencies that directly offer financial loans and guarantees must
follow statutory price-setting rules, which arguably may not fully cover the higher default risk
posed by higher-risk borrowers.76 By contrast, CDFIs may have greater flexibility to charge
higher interest rates and fees, thus generating additional revenue that can be used to offset losses
associated with higher loan delinquencies and charge-off rates. For this reason, if Congress were
to consider the extent of duplication among development programs provided by the Fund and
other federal agencies, Members may also wish to consider how risk-based pricing is
implemented by CDFIs compared to other federal programs to see if this practice results in
significant benefit and cost differences for both underserved individuals and taxpayers.
In addition to concerns about duplication of federal programs, Members of Congress have a long-
standing interest in understanding the effectiveness of federal programs. A common challenge in
conducting formal evaluations is that the enacting legislation may not state a specific program
goal, define what would constitute success, or require data collection that may be necessary to aid
in future evaluations.77 If Congress were to consider the effectiveness of programs provided by
the Fund, Members may want to clearly articulate the purpose of the program and specific
measures for success.
Author Information
Donald J. Marples
Darryl E. Getter
Specialist in Public Finance
Specialist in Financial Economics
Disclaimer
This document was prepared by the Congressional Research Service (CRS). CRS serves as nonpartisan
shared staff to congressional committees and Members of Congress. It operates solely at the behest of and
under the direction of Congress. Information in a CRS Report should not be relied upon for purposes other
than public understanding of information that has been provided by CRS to Members of Congress in
connection with CRS’s institutional role. CRS Reports, as a work of the United States Government, are not
subject to copyright protection in the United States. Any CRS Report may be reproduced and distributed in
its entirety without permission from CRS. However, as a CRS Report may include copyrighted images or
material from a third party, you may need to obtain the permission of the copyright holder if you wish to
copy or otherwise use copyrighted material.
76 For examples, see CRS Report R46963,
SBA Disaster Loan Interest Rates: Overview and Policy Options, by Bruce
R. Lindsay et al.; and CRS Report RS20530,
FHA-Insured Home Loans: An Overview, by Katie Jones.
77 Martin D. Abravanel et al.,
New Markets Tax Credit (NMTC) Program Evaluation: Final Report, prepared for U.S.
Department of the Treasury Community Development Financial Institutions (CDFI) Fund, Urban Institute, April 2013,
https://www.cdfifund.gov/sites/cdfi/files/documents/nmtc-program-evaluation-final-report.pdf.
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