WASHINGTON, DC (March 10, 2017) —
Good afternoon,
Attached please find NAFCU Senior Regulatory Affairs Counsel Michael Emancipator’s letter to the Community Development Financial Institution (CDFI) regarding CDFI certification.
In the letter, Emancipator wrote, “As the Fund reviews its application and reporting requirements, NAFCU urges it to closely consider the difference between regulated and unregulated entities, and the already thorough reporting requirements with which credit unions comply.” “Credit unions are subject to numerous consumer protection provisions in the Federal Credit Union Act, including a usury ceiling, a prohibition on prepayment penalties, and a limit on the amount of loans that can be originated to small business members.
“Credit unions are required to cure any deficiencies that might be found. Even when the examiner is not on-site, federally-insured credit unions are required to submit Call Report data to NCUA every quarter. As NCUA is in the process of updating the content of the call report, and modernizing the data input mechanisms, NAFCU recommends that the Fund collaborate with NCUA and seek out ways it could leverage data already provided in the Call Report.”
Emancipator also noted that CDFI-certified credit unions account for more than half of the assets held by all CDFIs.
Credit unions that have NCUA’s low-income designation share many of the qualifications required for CDFI certification. A credit union must be CDFI-certified to apply for the fund’s grants.
If you would like more information on this matter or would like to speak about this with a NAFCU expert, please let me know.
NAFCU Comment on CDFI Fund RFI.pdf
Thank you.
Falen Taylor
Communications Coordinator
National Association of Federally-Insured Credit Unions
Phone: 703-842-2235
ftaylor@nafcu.org
The National Association of Federally-Insured Credit Unions is the only national trade association focusing exclusively on federal issues affecting the nation’s federally-insured credit unions. NAFCU membership is direct and provides credit unions with the best in federal advocacy, education and compliance assistance. For more information on NAFCU, go to www.nafcu.org or @NAFCU on Twitter.
