Qualification Process to use the Streamlined CDFI Certification Application

Overview

In 2016, the NCUA and the Community Development Financial Institutions Fund developed a joint initiative to streamline the qualification and application process for low-income credit unions interested in obtaining the CDFI certification.1 The NCUA’s Office of Credit Union Resources and Expansion (CURE) administers this streamlined qualification process.

Through the CDFI Fund, the Treasury Department recognizes specialized financial institutions serving low-income communities that meet a specific set of requirements.2 CDFI-certified credit unions have access to a variety of opportunities. For example, a CDFI-certified credit union may apply for technical assistance and competitive financial awards, up to $125,000 and $2 million respectively. These awards enable a credit union 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 —that enhance its capacity to provide underserved communities with access to safe, higher quality financial services. CDFI certification can also benefit credit unions through other indirect awards and programs.

Before a credit union can use the streamlined process, the NCUA must analyze various financial performance indicators, including a credit union’s lending activities, to determine whether the credit union is a strong candidate to use the streamlined CDFI certification application. To participate in the qualification process, credit unions must provide the NCUA with a defined set of loan information to analyze. If the results of the credit union’s analysis satisfy the qualification criteria, then the credit union will be allowed to use the streamlined certification application. The NCUA will provide qualified credit unions with the necessary information to complete and submit the streamlined certification application to the CDFI Fund. The CDFI Fund, not the NCUA, determines whether to grant CDFI certification.

This program guide provides information and instructions for the process of determining whether a credit union qualifies for the streamlined application process.

Qualification Process Intake Periods

Credit unions interested in participating in this initiative may take part when an intake period is open. Each credit union may only participate once a year. The intake periods for the calendar year 2021 are:

Table 1. 2021 Intake Periods

Period # Start Date* End Date*
1 Sunday, January 24 Saturday, April 3 (CLOSED)
2 Sunday, September 12 Friday, October 15

*Each Intake Period will start at 9 a.m. Eastern and close at 11:59 p.m. Eastern.

Initiative Phases

The steps involved with each phase of the initiative follow a linear path that includes action steps to be completed by the credit union, the NCUA, and the CDFI Fund. The initiative consists of two phases.

The first phase is the qualification process, and the second phase is the streamlined certification application process with the CDFI Fund. The specific action steps along each phase are explained in Tables 2 and 3.

  1. Qualification Process: The NCUA determines whether a credit union is qualified to use the streamlined certification application.
  2. Streamlined Certification Application Process: The CDFI Fund determines whether a credit union will receive the CDFI certification.

Credit unions that qualify to use the streamlined certification application in Phase 1 will proceed to Phase 2.

Credit unions that do not qualify in Phase 1 to use the streamlined certification application should explore using the standard application. Non-qualified credit unions may participate in the qualification process during the next calendar year.

Table 2: Phase 1 – Qualification Process

Step Credit Union Actions NCUA Actions
Announcement of the CDFI Certification Intake Round N/A The NCUA formally announces the program intake periods and publishes the CDFI Certification Program Guide.
Review Program Guide Interested credit unions will review the instructions in the program guide to participate in the qualification process. N/A
Consolidate Loan Data and Submit it with the Participation Form Credit unions will submit the required data along with a Participation Form to the NCUA. N/A
Analyze the Submission N/A The NCUA will analyze the credit union's loan data, products and services, and other indicators from the submission to determine the credit union's qualification status.
Notice of Analysis Results and Qualification Status N/A When the analysis has been completed, the NCUA notifies credit unions whether they qualify to use the streamlined certification application.

Table 3: Phase 2 – Streamlined Certification Application Process

Step Credit Union Actions CDFI Fund Actions
Retrieve Documentation Provided by NCUA Qualified credit unions will retrieve documentation from the NCUA. N/A
Complete and Submit Streamlined CDFI Certification Application through AMIS After retrieving the documentation, credit unions then complete and submit the streamlined certification application through the CDFI Fund’s Awards Management Information System (AMIS). N/A
CDFI Review of the Streamlined CDFI Certification Application N/A The CDFI Fund will begin processing and reviewing a credit union’s application for streamlined certification.
Notice of CDFI Certification Determination N/A When the application review is complete, the CDFI Fund will determine the credit union’s certification status and will notify the credit union of its decision.

 

Program Details

Specific details about this program will be explained in this section, including eligibility and general requirements, data requirements, loan analysis, and the results of the loan analysis.

Eligibility and General Requirements

  1. Who is eligible to participate?
    There are several threshold requirements for a credit union to meet to participate in this qualification process:
    • Is federally insured through the NCUA;
    • Has a low-income designation granted by the NCUA or a similar state designation confirmed by the NCUA; and
    • Provides at least one of the following programs and services to its members:
      • Financial counseling;
      • Financial education;
      • Financial literacy workshops;
      • In-school branches; or
      • A first-time homebuyer program.
  2. Do I need to contact my examiner to participate?
    No. Contacting your examiner is not required. However, the NCUA encourages you to communicate your plans to participate in this program with your examiner because there is a component of the loan analysis that relies on validated information from the 5300 Call Report.3
  3. What other actions do I need to take to participate in the program?
    To participate in the qualification process, credit unions should complete and submit the following items to the NCUA during one of the program intake periods:

Data Requirements

  1. What type of data do I need to provide to the NCUA?
    A credit union should be prepared to submit two types of data during the qualification process: its organization information and its loan information.

    Organization Information: Basic and easy-to-find information that must be provided through the Participation Form:
    1. Type of products and services offered by the credit union, and
    2. The names of members on the credit union’s Board of Directors.

    Loan Information: A defined set of loan details about all the credit union’s 2020 loan originations.
    1. Credit unions should provide the NCUA with a loan file that includes all loans that were originated during the previous calendar year (January 1 through December 31, 2020).
    2. The loan file only needs to include details about the loan components listed in Table 4. All personal identifiable information (PII) of members should be removed.
    3. The total number and dollar amount of loans in your file should be comparable to the total number and dollar amount of loans granted year-to-date in your 5300 Call Report for the period ending December 31, 2020.
      • If there are any significant differences (+/- 5 percent), please provide an explanation describing the differences in the Participation Form. Failure to do so may result in delays or rejection of the request.

    Table 4 details the information require in the loan file.

    Table 4. Required Loan Data Details
    Field Name Field Description
    Mailing Street Address Member’s address of record. Do not submit a P.O. Box address, as the analysis tool will reject it. A member’s physical address is required. Format examples are: “123 Main Street.”
    City City associated with the mailing street address.
    State State associated with the mailing street address.
    Zip Code Zip code associated with the mailing street address. Do not include a hyphen if the four-digit extension is included.
    Date of Loan Date the loan was originally granted. Format date as MM/DD/YYYY
    Loan Amount Dollar amount advanced to the member.4
  2. How should I prepare the loan file and what is the required format to submit it?
    The loan file should be prepared according to the data layout as shown in the examples in Table 5. The layout for the loan file is similar to the layout of the “AIRES loan file” that a credit union provides during an examination. The main difference is that the loan file for this analysis should only include six of the data fields. In addition, the loan file must be submitted in the Excel spreadsheet format (.xls or .xlsx). If you need assistance preparing your loan file in this format, please use CURE’s loan file template.5

    Table 5. Data Layout for Loan File
    Mailing Address City State Zip Code Date of Loan Loan Amount
    1775 Duke Street Alexandria VA 22314 3/15/2020 500.00
    1234 Duke Street Arlington VA 22314 6/10/2020 450.00
  3. How should I submit the loan file to the NCUA?
    Credit unions should upload their loan files into the Participation Form within the CyberGrants system. To ensure the security of your data, the NCUA will not accept files submitted outside of CyberGrants.
  4. How long does it take to complete the Participation Form?
    On average, it takes about 15 to 30 minutes to complete the Participation Form.
  5. How will the NCUA use the personal identifiable information (PII) of my members?
    Credit unions should remove all PII from the loan file. The NCUA will not perform a loan analysis for credit unions that submit loan files with PII data. Credit unions are responsible for removing and discarding all data in the loan file that is not listed in Tables 4 and 5.

Loan Analysis

  1. How will the NCUA use the data in the loan file?
    The NCUA will run a series of analyses on the credit union’s loan file. The data in the file will be geocoded so the NCUA can determine whether your credit union’s aggregate loan activity in eligible Target Market counties satisfies the qualification criteria to use the streamlined certification application. For purposes of this joint initiative, the CDFI Fund defines eligible Target Markets as one or more Investment Areas (IA) and/or Low-Income Targeted Populations (LITP).6
  2. How does this loan analysis work?
    The primary function completed during the loan analysis is the geocode analysis (also referred to as Target Market analysis). The geocode analysis is the leading indicator of a credit union’s likelihood to obtain the CDFI certification through the streamlined application. This is why it is important to follow the instructions provided in the Data Requirements subsection when preparing the loan file. The loan analysis tool will not properly geocode any loan transactions with a P.O. Box number listed as the mailing address. Providing a physical address with the corresponding city, state, and zip code will ensure that the geocode analysis precisely depicts your credit union’s loan activity in eligible Target Markets.

Results of the Loan Analysis

  1. What do the results of the loan analysis mean?
    The results of the loan analysis only measure a credit union’s suitability to use the streamlined certification application. They do not measure whether your credit union is suitable for the CDFI certification because the standard certification application allows credit unions to choose a broader range of Target Market options.
  2. What is the qualification criterion for the loan analysis results?
    At least 60 percent of a credit union’s loan originations (both the number of loans and dollar amount) should be directed to eligible Target Market counties to satisfy the qualification criteria.
  3. How and when will credit unions be notified of their qualification status?
    The NCUA will notify credit unions about whether they qualify to use the streamlined process or not by email. A summary of the credit union’s loan analysis results will be included in the email. CURE will aim to send the notifications within four weeks of the intake period end date. CURE may notify credit unions of their qualification status earlier or later than that, depending on the circumstances.

 

Participation Form Instructions

This section provides step-by-step instructions to complete the Participation Form and submit the loan file.

  1. Access the Participation Form - Qualification Process for the Streamlined CDFI Certification. The electronic form will be available on the homepage once you sign on.
  2. Prepare the loan file in accordance with the data layout in Table 5. The loan file should only include loans originated in the calendar year ending December 31, 2020.
  3. Compare the loan file to the Call Report for the year ending December 31, 2020.  Explain any variance between the number and dollar amount of loans in these two documents.
  4. Select the financial education programs and services that your credit union provides to members. This should be consistent with your most recent Credit Union Online Profile.
  5. Provide the names of all the Board Members for your credit union.
  6. The applicant should certify that the credit union consents to an analysis of the credit union's loans by the NCUA for the Qualification Process to use the Streamlined CDFI Certification Application.
  7. Review and submit the Participation Form by October 15, 2021.

You will receive an automated message by email that confirms the Participation Form has been successfully submitted. If you have any issues, please contact CURECDFI@ncua.gov.

The NCUA will return the Participation Form if any components, such as the loan file, are incomplete or contains errors. The NCUA will provide further instruction on how to correct these issues and resubmit.

The NCUA will notify the credit union of the final status of its application, whether the credit union qualifies for the streamlined process or not, by email from CURECDFI@ncua.gov.

 

Next Steps for NCUA Qualified Credit Unions

Receiving qualification from the NCUA does not grant the credit union CDFI certification. Qualified credit unions are eligible to apply for CDFI Certification through the CDFI Fund’s Streamlined Certification application.

To apply for CDFI Certification, qualified credit unions must complete the following activities:

  1. Sign into CyberGrants to access the Streamlined CDFI Certification Documentation.
  2. Find the 2021 Qualification Process Intake Period #2 - Data Summary and select “View.”
  3. Access the NCUA’s Data Summary and Loan Analysis documents. Both files must be submitted with your application. These files will be required when you apply for CDFI Certification.
  4. Download the instructions to submit a Streamlined Certification application. The instructions will outline how to complete and submit your application to the CDFI Fund. Please read and follow the instructions. The instructions can be obtained on the CDFI Fund’s Certification Program webpage.

The Streamlined CDFI Certification App Status Update will be available in CyberGrants the day after the qualification letter is sent by the NCUA. This report helps the NCUA learn about your experiences using the Participation Form and plans for applying for CDFI Certification. This optional report is due 90 days after the qualification letter is sent by the NCUA.

Qualified credit unions that fail to apply for certification from the CDFI Fund within six months of qualification may be disqualified and will need to reapply in the future.

 

Contact Us

If you have any questions regarding the qualification process for the Streamlined CDFI Certification application, contact us at CURECDFI@ncua.gov.


Footnotes


1 Joint Initiative Press Release: https://www.ncua.gov/newsroom/Pages/news-2016-jan-community-development-financial-institutions.aspx

2 CDFI Certification Eligibility Requirements: https://www.cdfifund.gov/programs-training/certification/cdfi/Pages/default.aspx

3 The NCUA will use unvalidated 5300 Call Report data during intake period 1 to expedite the 2021 qualification process for the streamlined CDFI certification.

4 For the number of loans, count each line of credit as a single loan granted if one or more advances were made on that line year-to-date, even if it is an existing line of credit approved in a previous year. For all other loans, report each new loan or refinanced loan as a loan granted. The dollar amount should include all new advances on lines of credit and all balances which were refinanced.

5 CURE’s Loan File Template: https://www.cybergrants.com/ncua/cdfi/Loan.File.Submission.Template.xlsx

6 Eligible Target Market counties only include the areas where a credit union has an office branch and the bordering counties to those branches.

Last modified on
08/24/21