CDFI Fund: Request for Public Comment – CDFI Program, NACA Program and NMTC Program Annual Reports

The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995. Currently, the Community Development Financial Institutions Fund (CDFI Fund), U.S. Department of the Treasury, is soliciting comments concerning the Community Development Financial Institutions CDFI Program (CDFI Program), and Native American CDFI Assistance Program (NACA Program) and New Markets Tax Credit Program (NMTC Program) Annual Report, including the Awards Management and Information System (AMIS) Compliance and Performance Reporting (ACPR).

The principal changes to the data collection system is the replacement of the Community Investment Impact System (CIIS) with the AMIS system for reporting and the reduced burden for CDFI Program  and NACA Program Recipients due to the elimination of the Institutional Level Report (ILR) and reductions in the Transaction Level Report (TLR). Slight efficiency gains are also described for NMTC Program Allocatees, which reduces the average reporting burden. 

A CDFI Program and NACA Program Recipient must submit an Annual Report that is comprised of several sections that depend on the program and the type of award. The specific components that comprise a Recipient’s Annual Report are set forth in the Assistance Agreement that the Recipient enters into with the CDFI Fund in order to receive a CDFI Program or NACA Program award. 

The current CDFI Program reporting requirements can be found in the Assistance Agreement templates located on the CDFI Program page of CDFI Fund web site, here. The current NACA Program reporting requirements can be found in the Assistance Agreement templates located on the Native Initiatives page of the CDFI Fund web site, here.

NMTC Program Allocatees must submit an Annual Report that is comprised of: (i) A financial statement that has been audited by an independent certified public accountant; (ii) an ILR (including the IRS Compliance Questions section), if the Allocatee has issued any Qualified Equity Investments; and (iii) a TLR if the Allocatee has issued any Qualified Low-Income Community Investments in the form of loans or investments. The components that comprise an Allocatee’s Annual Report are set forth in the Allocation Agreement that the Allocatee enters into with the CDFI Fund in order to receive a NMTC Program allocation. These requirements can be found in the Allocation Agreement templates located on the NMTC Program page of the CDFI Fund web site, here.

Data collection guidance documents for the CDFI and NACA Programs, as well as NMTC Program reporting are located on the AMIS Compliance and Performance Reporting page of the CDFI Fund web site, here.

Comments are invited on all aspects of the information collections, but commentators may wish to focus particular attention on: (a) The cost for CDFIs and CDEs to operate and maintain the services/systems required to provide the required information; (b) ways to enhance the quality, utility, and clarity of the information to be collected; (c) whether the collection of information is necessary for the proper evaluation of the effectiveness and impact of the CDFI Fund’s programs, including whether the information has practical utility; (d) the accuracy of the CDFI Fund’s estimate of the burden of the collection of information; (e) ways to minimize the burden of the collection of information including through the use of technology, such as software for internal accounting and geocoding to capture geographic detail while streamlining and aggregating TLR reporting for upload to AMIS, and; (f) what methods might be used to improve the data quality, internal accounting and efficiency of reporting transactions for serving other targeted populations.

Comments must be submitted in writing by 60 days after the date of publication of the Federal Register notice via email to Greg Bischak, Program Manager for Financial Strategies and Research, CDFI Fund, at CDFI-FinancialStrategiesandResearch@cdfi.treas.gov.

Please note that later in 2020 the CDFI Fund plans to publish a Request for Public Comment to solicit feedback on proposed additions and revisions to CDFI Program, NACA Program and NMTC Program TLRs and estimates on reporting burdens, which are not contained in this notice.

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