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CDFI Annual Compliance, Certification, & Reporting Obligations

Are you the Authorized Representative of either a Certified Community Development Financial Institution (CDFI) or an organization that has received a Community Development Financial Institutions Fund (CDFI Fund) Award and/or Allocation?

If so, to maintain your organization’s CDFI Certification status, you must submit the Annual Certification and Data Collection Report (ACR). Additionally, to ensure compliance with your Award, Assistance and/or Allocation Agreement(s) you must complete and submit the annual report(s) specified in these agreement(s).

Failure to file required annual compliance and Certification reports or advise the CDFI Fund of certain Material Events may result in default and/or noncompliance with your organization’s Award, Assistance and/or Allocation Agreement(s), or termination of your CDFI Certification.

The due dates to submit annual compliance report(s) vary by fiscal year end date and type of award, as well as by the specific terms within each organization’s individual Award, Assistance and/or Allocation Agreement(s). The due date for Certified CDFIs to submit the ACR also varies by fiscal year end date. This reminder is specifically for organizations with Award, Assistance and/or Allocation Agreements, as well as ACRs, which have an upcoming report(s) due by December 31, 2023.

The CDFI Fund recently released its revised CDFI Certification Application, ACR and Transaction Level Report. The CDFI Fund will resume accepting Certification Applications for non-certified organizations only in its Awards Management Information System (AMIS) on December 20, 2023. Currently Certified CDFIs are still required to submit an ACR in accordance with their existing ACR reporting schedule as listed in AMIS, to maintain their Certification status. Organizations are encouraged to review the revised Certification Application, ACR and TLR information on the CDFI Fund’s website to understand the scope of changes and new process requirements.

How to Check Your Report Date
How to check:

  • CDFI Fund Recipients and/or Allocatees: The due date(s) for your organization’s required report(s) can be found in the Award, Assistance and/or Allocation Agreement(s) on the Reporting Schedule in AMIS. Please review the Agreement(s) applicable to your organization to check if you are required to report at this time and for additional information about annual reporting requirements.
  • All Certified CDFIs:  The due date(s) for your organization’s Annual Certification and Data Collection Report can be found in the ACR Reporting Schedule in AMIS. Please review the ACR Reporting Schedule in AMIS to check if you are required to report at this time.

Extension for CDFI/NACA/RRP and NMTC Transaction Level Report Due Dates
All CDFI/NACA/RRP Award Recipients and NMTC Allocatees with a TLR due date between 8/31/2023 and 12/31/2023 have a new due date of 1/31/2024. The due date was changed so that the CDFI Fund could implement changes in AMIS to the CDFI/NACA/RRP TLR and NMTC Allocatee TLR.

At this time, the Organization Name Look-up Capability in AMIS for the TLRs is disabled until the CDFI Fund completes its deployment later this year of new features to the TLR for the CDFI, NACA, RRP, and NMTC programs. Users may still access the geocoding Import and Template download at the bottom of the TLR page in AMIS. If you have any questions, please submit an AMIS service request with “TLR Upload Lockout” as the subject heading. The CDFI Fund will send out an email once the TLRs have fully reopened in AMIS.

Annual Certification and Data Collection Report Deadline Reminder
Unless directed otherwise by the CDFI Fund, all Certified CDFIs are required to submit ACRs on an annual basis. Currently Certified CDFIs must submit their ACRs, in AMIS, within 90 days after their organization’s fiscal year end date using the current version of the ACR.

For the 2024 reporting cycle, all Certified CDFIs, regardless of their date of Certification, will be required to submit an ACR. Currently Certified CDFIs will NOT lose their Certification or be placed into a cure period as long as they submit accurate analysis or responses to the 2024 ACR. However, an organization may have its Certification terminated if they fail to submit their 2024 ACR by the required deadline. Submission of the ACR on an annual basis is a requirement of CDFI Certification.

The AMIS ACR Reporting Schedule displays the due date for the ACR based on the organization’s fiscal year end. The ACR Reporting Schedule section is located at the bottom of the Certification Related page in AMIS. Additional information on the AMIS Reporting Schedule can be found in the AMIS Training Manual – Annual Certification and Data Collection Report available on the CDFI Fund’s website. Be sure to check that your organization’s fiscal year end is correct on your AMIS Organizational Detail Page.

EXTENSION: CDFIs with a fiscal year end of September 30th are typically required to submit the ACR by December 31, 2023. The CDFI Fund has granted an extension to January 31, 2024, for the 2024 Report Year only. The AMIS ACR Reporting Schedule should display this extension.

On December 7, 2023, the CDFI Fund released a revised version of the ACR form which aligns with the revised Certification Application. At this time, the revised version of the ACR is not operational in AMIS. The revised version of the ACR will be used when a new Certification Applicant completes the revised Certification Application and becomes a Certified CDFI and/or a currently Certified CDFI completes the revised Certification Application and retains its CDFI Certification.

Failure to file the required ACR by the due date will result in a loss of status as a Certified CDFI and may lead to additional sanctions for CDFIs that are program Recipients. Currently Certified CDFIs are those organizations that have CDFI Certification status as of the date the revised CDFI Certification Application opens in AMIS on December 20, 2023.

Advise the CDFI Fund of Material Events
As specified in the terms of your organization’s Award, Assistance and/or Allocation Agreement(s), please remember that your organization is required to advise the CDFI Fund of an occurrence of a Material Event, which should be submitted via a Service Request initiated in your organization’s AMIS account. Please refer to the link titled “Material Events” under the “For More Information” section below to access updated guidance documents for submitting the Certification of Material Events Form.

CDFI Fund Recipients with active awards/allocations are required to submit a Material Events form (including all supporting documentation) within 30 days or as specified in their Award, Assistance and/or Allocation Agreements, of the occurrence of a material event.

The CDFI Fund is reminding all Certified CDFIs, Certified CDEs, as well as program Recipients and/or Allocatees to review their recent organizational history to determine if a Material Events form should be submitted. Certified CDFIs that do not have an Award, Assistance and/or Allocation Agreement should report changes in their organization’s fiscal year end through the AMIS Service Request portal.

Submission of Audit Confirmation Requests
Hard copy submissions of CDFI audit confirmation requests for information should no longer be mailed to the CDFI Fund. CDFI Recipient auditors should now submit all audit confirmation requests via email to FMAuditConfirmations@cdfi.treas.gov. This includes but is not limited to verifications, validations, and confirmation of balances of financial assistance received from the CDFI Fund.

The CDFI Fund will respond to all audit confirmation requests by email, only. As such, requests must include an email address and instructions of where the CDFI Fund should deliver the requested information. Questions regarding the process for submitting audit confirmation requests can also be submitted via email at FMAuditConfirmations@cdfi.treas.gov.

Updates for CDFI Program Healthy Food Financing Initiative-Financial Assistance Award Recipients
All CDFI Program Healthy Food Financing Initiative-Financial Assistance Recipients (HFFI) are now required to enter aggregate HFFI data in their Performance Progress Report (PPR), just as they enter aggregate data for the other deployment performance goals. Keep in mind, HFFI Recipients must continue to enter individual HFFI data in the CDFI Transaction Level Report (TLR).

For More Information
The CDFI Fund has developed training materials to help users better navigate AMIS. All AMIS training manuals and information can be found on the AMIS Training Materials page at https://amis.cdfifund.gov/Training. Information and instructions on submitting annual compliance and certification reports, as well as Material Events forms can be found on the CDFI Fund’s website at the following links:

If you have questions about the annual compliance and certification reports, or Material Events please submit a Service Request via your organization’s AMIS account. For more information about the CDFI Fund and its programs, please visit www.cdfifund.gov.

Access the ‘Compliance Hotline’
Your League-member benefits include the Compliance Hotline — providing exclusive access to dedicated compliance experts:

Using the above phone number and email address, you can gain access to a knowledgeable team that’s ready to address all your credit union’s compliance inquiries — promptly and efficiently. With the Compliance Hotline, you can proactively respond to impromptu questions and issues by getting clarity and insight on technical topics that normally slow you down. We want to help you unlock the full potential of your League membership by leveraging the resources and support you need to navigate the complex world of compliance effortlessly. We’re ALWAYS just a phone call or email away!

Additionally, other League-member compliance resources include:

  • ViClarity
  • CU PolicyPro
  • ComplySight
  • InfoSight
  • CU Store
  • Record Retention Guide
  • GRC Technology Solutions

For more information, email Lisa Quaranta.

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