[Senate Hearing 117-348]
[From the U.S. Government Publishing Office]



                                                        S. Hrg. 117-348


                  EXPLORING HOW COMMUNITY DEVELOPMENT
         FINANCIAL INSTITUTIONS SUPPORT UNDERSERVED COMMUNITIES

=======================================================================

                                HEARING

                               before the

                            SUBCOMMITTEE ON
           HOUSING, TRANSPORTATION, AND COMMUNITY DEVELOPMENT

                                 of the

                              COMMITTEE ON
                   BANKING,HOUSING,AND URBAN AFFAIRS
                          UNITED STATES SENATE

                    ONE HUNDRED SEVENTEENTH CONGRESS

                             SECOND SESSION

                                   ON

EXAMINING THE CHALLENGES FACED BY UNDERSERVED COMMUNITIES WHEN IT COMES 
             TO ACCESSING CAPITAL AND THE FINANCIAL SYSTEM

                               __________

                            JANUARY 5, 2022

                               __________

  Printed for the use of the Committee on Banking, Housing, and Urban 
                                Affairs





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                Available at: https: //www.govinfo.gov /

                               ______
                                 

                 U.S. GOVERNMENT PUBLISHING OFFICE

48-389 PDF                WASHINGTON : 2023















            COMMITTEE ON BANKING, HOUSING, AND URBAN AFFAIRS

                     SHERROD BROWN, Ohio, Chairman

JACK REED, Rhode Island              PATRICK J. TOOMEY, Pennsylvania
ROBERT MENENDEZ, New Jersey          RICHARD C. SHELBY, Alabama
JON TESTER, Montana                  MIKE CRAPO, Idaho
MARK R. WARNER, Virginia             TIM SCOTT, South Carolina
ELIZABETH WARREN, Massachusetts      MIKE ROUNDS, South Dakota
CHRIS VAN HOLLEN, Maryland           THOM TILLIS, North Carolina
CATHERINE CORTEZ MASTO, Nevada       JOHN KENNEDY, Louisiana
TINA SMITH, Minnesota                BILL HAGERTY, Tennessee
KYRSTEN SINEMA, Arizona              CYNTHIA LUMMIS, Wyoming
JON OSSOFF, Georgia                  JERRY MORAN, Kansas
RAPHAEL WARNOCK, Georgia             KEVIN CRAMER, North Dakota
                                     STEVE DAINES, Montana

                     Laura Swanson, Staff Director

                 Brad Grantz, Republican Staff Director

                      Cameron Ricker, Chief Clerk

                      Shelvin Simmons, IT Director

                        Pat Lally, Hearing Clerk

                                 ______

   Subcommittee on Housing, Transportation, and Community Development

                      TINA SMITH, Minnesota, Chair

          MIKE ROUNDS, South Dakota, Ranking Republican Member

JACK REED, Rhode Island              RICHARD C. SHELBY, Alabama
ROBERT MENENDEZ, New Jersey          MIKE CRAPO, Idaho
JON TESTER, Montana                  BILL HAGERTY, Tennessee
CATHERINE CORTEZ MASTO, Nevada       CYNTHIA LUMMIS, Wyoming
CHRIS VAN HOLLEN, Maryland           JERRY MORAN, Kansas
JON OSSOFF, Georgia                  KEVIN CRAMER, North Dakota
RAPHAEL WARNOCK, Georgia             STEVE DAINES, Montana

                Tim Everett, Subcommittee Staff Director

         Kathleen Gayle, Republican Subcommittee Staff Director

                                  (ii)












                            C O N T E N T S

                              ----------                              

                       WEDNESDAY, JANUARY 5, 2022

                                                                   Page

Opening statement of Chair Smith.................................     1

Opening statements, comments, or prepared statements of:
    Senator Rounds...............................................     3

                               WITNESSES

John Holdsclaw, IV, President, CDFI Coalition, Washington, D.C...     5
    Prepared statement...........................................    28
    Responses to written questions of:
        Chair Smith..............................................   134
        Senator Menendez.........................................   135
        Senator Warnock..........................................   136
Frank Altman, Founder and CEO, Community Reinvestment Fund, USA, 
  Minneapolis, Minnesota.........................................     6
    Prepared statement...........................................    33
    Responses to written questions of:
        Chair Smith..............................................   139
        Senator Menendez.........................................   152
        Senator Warnock..........................................   153
Lakota Vogel, Executive Director, Four Bands Community Fund, 
  Eagle Butte, South Dakota......................................     8
    Prepared statement...........................................   132
    Responses to written questions of:
        Chair Smith..............................................   156
        Senator Menendez.........................................   156
        Senator Warnock..........................................   156

              Additional Material Supplied for the Record

GAO Report: Federal Home Loan Banks..............................   157

                                 (iii)









 
                  EXPLORING HOW COMMUNITY DEVELOPMENT
         FINANCIAL INSTITUTIONS SUPPORT UNDERSERVED COMMUNITIES

                              ----------                              


                       WEDNESDAY, JANUARY 5, 2022

                               U.S. Senate,
  Committee on Banking, Housing, and Urban Affairs,
    Subcommittee on Housing, Transportation, and Community 
                                               Development,
                                                    Washington, DC.
    The Subcommittee met at 10 a.m., via Webex, Hon. Tina 
Smith, Chair of the Subcommittee, presiding.

             OPENING STATEMENT OF CHAIR TINA SMITH

    Chair Smith. Good morning. I call the Subcommittee on 
Housing, Transportation, and Community Development to order.
    Today, we are going to take a look at Community Development 
Financial Institutions or CDFIs. Our hearing will explore how 
the Federal Government can help support their innovative work 
and how we can work together to address some of the challenges 
faced by underserved communities when it comes to accessing 
capital and the financial system.
    The COVID-19 pandemic has not been the great equalizer. It 
has laid bare the disparities in our society that existed 
before the pandemic, and too often it is Black and Brown and 
indigenous families who have faced the most significant 
burdens.
    But the economic disparities did not start, as I said, 
during the pandemic. According to the Federal Reserve, as of 
2019, a typical Black family's net worth was just 15 percent of 
a typical White family's worth; a typical Hispanic family's net 
worth was about 19 percent of a White family's; and, the 
typical net worth for Native American families is also just a 
fraction of the typical White family's. While there are many 
causes for this great inequity, one factor is a lack of access 
to capital and to financial services for people of color, 
indigenous communities, and in small towns and rural places.
    When the CDFI Fund, the Federal agency that oversees CDFI 
programs, when it was established in 1994, there were about 80 
CDFIs. Today, there are more than a thousand, many with 
innovative models that were not even imagined when the CDFI 
Fund was first established, and they have played a critical 
role in bringing capital and financial services to a wide 
variety of underserved communities, from urban areas to small 
towns and rural places to tribal lands. For instance in 
Minnesota, the African Development Center helped fund two malls 
that have more than 450 African small businesses and over 500 
jobs.
    The Indian Land Company, the ILCC, Indian Land Capital 
Company, forgive me, made a loan of nearly $1 million to the 
Lower Sioux to allow them to expand their land by about 10 
percent. I appreciated the opportunity to visit with them last 
summer and learn about this project.
    And in 2018 I visited University Enterprise Labs, which was 
funded in part by Sunrise Banks, which is a certified CDFI, 
with support from the New Markets Tax Credit Program. Those 
funds have helped expand the cutting-edge life sciences 
incubator in an area that is currently shared by industrial 
uses and students on the border of St. Paul and Minneapolis.
    With their successful track record of reaching underserved 
communities, Congress has looked to CDFIs as effective 
community development organizations to implement programs. So 
here is just a few examples:
    In 2000, Congress enacted the New Markets Tax Credit, which 
provides tax incentives to allow CDFIs to work on economic 
development projects in economically distressed areas. That 
program has proven successful, and I am glad to be a supporter 
of bipartisan legislation from Senator Cardin and Senator Blunt 
to update and expand that tax credit.
    During the Great Recession, Senator Menendez offered 
legislation to establish the CDFI Bond Guarantee Program. The 
bond guarantee program provides stable, long-term sources of 
capital for CDFIs without any subsidy from taxpayers. Earlier 
this week, Senator Rounds and I introduced legislation to make 
that program permanent and to adjust some of its loan 
requirements to make it more accessible to smaller CDFIs who 
might want to participate. I am looking forward to hearing from 
our witnesses today about how our legislation could make a 
difference for community development.
    In 2020, Congress set aside $25 billion of PPP lending for 
CDFIs to distribute because CDFIs have relationships with many 
communities that banks and credit unions just were not able to 
reach. CDFIs made more than 100,000 PPP loans in the first 
months of that program, and that effort was critical to helping 
thousands of small businesses stay afloat.
    In addition, in the bipartisan, year-end funding package 
that we enacted at the end of 2020, Congress made an historic 
investment in CDFIs and Minority Depository Institutions, 
providing rapid relief grants. As a result of that program, 27 
Minnesota CDFIs received grants totaling $38 million, funds 
that will be invested in our State to support new lending and 
services. Senator Warner played an important role in getting 
this investment enacted, and I know that many of us supported 
the work that he has done. I look forward to hearing from our 
witnesses today about how that funding is making a difference 
in their communities.
    So before I turn to Senator Rounds, I would like to thank 
Mike for being such a good partner in planning and organizing 
this hearing. As you were saying at the beginning, this is a 
hearing where we tend to focus on what we can find agreement 
on, on where we can find common ground, and approach this from 
a perspective of solutions, and that is very important. I know 
that we have a shared interest in building strong communities 
in our States and around the country and especially in 
supporting economic development and access to capital in the 
indigenous communities that both of our States share.
    As I mentioned before, yesterday we joined together to 
introduce together legislation to update the CDFI Bond 
Guarantee Program to make it more available for smaller CDFIs. 
And we have also done legislation together to support access to 
mortgages for Native Americans in a partnership between CDFIs 
and the U.S. Department of Agriculture. So I am hopeful that 
today's hearing will help us identify additional areas where we 
can work together and pave a path to advancing these important 
pieces of legislation and others that we will hear about today.
    So, Senator Rounds, thank you so much for your partnership, 
and you are now recognized.

            OPENING STATEMENT OF SENATOR MIKE ROUNDS

    Senator Rounds. Thank you, Madam Chair, and let me 
reciprocate as well. I most certainly have appreciated the 
opportunity to work directly with you and your team. I think 
this is the way the legislative process should work, and I have 
appreciated your openness to having these discussions. And I 
look forward to additional legislation being an item that can 
be moved forward from this Subcommittee and perhaps actually 
making some very positive changes throughout the Midwest and 
hopefully across the rest of the country. So I thank you for 
your leadership, and I thank you for your interest in 
cooperating and in working together.
    I also want to thank our witnesses for taking the time to 
virtually attend today's hearing. I would especially like to 
thank Ms. Lakota Vogel, from my home State of South Dakota, for 
her willingness to testify. I look forward to hearing from all 
of you.
    Community Development Financial Institutions, or CDFIs, are 
critical in rural South Dakota as they provide services to the 
underserved communities that often fall through the cracks of 
our traditional financial systems. It is because of these 
institutions that many can buy their first home or launch a 
business that will bring much-needed jobs to a rural community.
    Today, however, I mainly want to focus my remarks on the 
impact Native CDFIs have on Native populations as well as the 
challenges which they still face. Native CDFIs are unique 
because they are anchored in local culture and are passionate 
about creating opportunities for long-term growth. As members 
of the community themselves, staff members know how to bridge 
the gap between cash economies and traditional financial 
products. They also play an important role in laying the 
groundwork for new investment in Native communities by 
providing access to capital financial assistance and literacy. 
This results in new Native-led businesses, opportunities for 
entrepreneurship, and additional jobs.
    Oftentimes, Native CDFIs are the first encounter Native 
families and individuals have with financial institutions. 
Because Native CDFIs serve a large unbanked population, they 
will often refer individuals to a local bank to open an 
account, many of whom are the first in their generation to do 
so and begin a journey toward financial stability.
    A recent study by the Minneapolis Fed found that trust 
between a borrower and a lender is critical for a successful 
loan. And since Native CDFIs design their services to include a 
cultural element, they can better build that trust. By 
providing financial workshops, training, and counseling that 
integrates cultural values in community-specific situations, 
Native CDFIs lead to more robust credit building.
    The Minneapolis Fed researchers also found that 
establishing Native CDFIs on or near reservations can improve 
individuals' credit outcomes. What is best for the 5,000-person 
town of Eagle Butte, South Dakota, is different from what is 
best for Native populations in the Black Hills of South Dakota. 
And since they are able to tailor their programs to their 
specific community, they find more success.
    The Minneapolis Fed reported that adding just one Native 
CDFI staff member per 1,000 residents leads, on average, to a 
45-point increase in the Equifax risk score of individuals who 
have low creditworthiness.
    Even though our Native CDFIs are able to be effective, they 
still face challenges. Adequate capital access continues to be 
a problem as demand in Native areas is outpacing supply. The 
Chair and I have worked on several pieces of legislation to try 
to increase access to this much-needed capital. Last year, we 
introduced the Native American Rural Homeownership Improvement 
Act, which would expand the USDA 502 lending pilot program, 
where USDA partnered with Native CDFIs to employ loans to 
eligible Native borrowers. Senator Smith and I also introduced 
legislation today that would lower the minimum bond offered by 
the CDFI Bond Guarantee Program from $100 million to $25 
million in order to increase access to smaller CDFIs, like 
Native CDFIs. These are just a few of the ways we have tried to 
address this problem, and I look forward to exploring this 
issue and others during this hearing.
    Again, we welcome all of you here today to our first 
Subcommittee hearing of 2022, and I look forward to hearing 
from our witnesses on Native CDFIs and traditional CDFIs.
    Thank you, and thank you, Madam Chair.
    Chair Smith. Thank you so much, Senator Rounds.
    I am now going to introduce our witnesses. I am so grateful 
to all of you for joining us today. I will introduce all three 
of you at once and then turn to each of you to make your 
opening statements.
    First, I would like to welcome John Holdsclaw, IV, as 
President of the CDFI Coalition and Executive Vice President of 
Strategic Initiatives at the National Cooperative Bank in 
Washington, DC, Welcome, Mr. Holdsclaw.
    I am delighted to welcome Frank Altman, who is the founder 
and CEO of Community Reinvestment Fund, USA, based in my 
hometown of Minneapolis, Minnesota. Welcome, Frank.
    And also, it is wonderful to have join us today Lakota 
Vogel, who is Executive Director of the Four Bands Community 
Fund in Eagle Butte, South Dakota. Welcome, Lakota, Ms. Vogel.
    Welcome to all of you for your willingness to speak with us 
today.
    And before you begin your opening statements, I have a few 
reminders. Once you start speaking, there will be a slight 
delay before you are displayed on the screen. And to minimize 
any background noise, please click the mute button until it is 
your turn to speak or to ask questions.
    You should all have one box on your screens labeled 
``clock'' that will show how much time you have remaining. For 
witnesses, you will have 5 minutes for your opening statements, 
and your full written statements will be made part of the 
record. For all Senators, the 5-minute clock applies for your 
questions. When you have about 30 seconds remaining for your 
statements or questions, you will hear a little bing, a little 
bell ring to remind you that your time is almost expired. It 
will ring again when your time has expired.
    And if there is any technology issue, we will move to the 
next witness or Senator until we get it resolved.
    To simplify the speaking order process for Senators, 
Senator Rounds and I have agreed to go by seniority for this 
hearing as we are fully virtual, and we will proceed first 
through Subcommittee Members by seniority and then turn to any 
non-Subcommittee Members in order of seniority who wish to ask 
questions.
    I will now turn to Mr. Holdsclaw for 5 minutes for your 
opening statement.

  STATEMENT OF JOHN HOLDSCLAW, IV, PRESIDENT, CDFI COALITION, 
                        WASHINGTON, D.C.

    Mr. Holdsclaw. Thank you, Chairwoman Smith, Senator Rounds, 
and Members of the Subcommittee. My name is John Holdsclaw, IV. 
I am the President of the CDFI Coalition and EVP of Strategic 
Initiatives at the National Cooperative Bank. Thank you for 
this opportunity today to testify on the CDFI Fund and the 
success of CDFIs in delivering financial services to 
underserved, low-income, urban, rural, and Native communities.
    The CDFI Coalition is a national membership organization 
made up of more than 150 organizations, including loan funds, 
community development banks, community development 
corporations, venture funds, microlenders, Native American 
organizations, and credit unions.
    The Fund was established in 1994 as a key policy apparatus 
for revitalizing disadvantaged communities, especially those 
hit very hard during the COVID pandemic. However, before the 
pandemic, low-income communities, rural, tribal, and 
communities of color faced significant obstacles in accessing 
financial services. Today, the Fund has more than 1,300 
certified CDFIs across the country, providing community 
development and lending services in all sizes and types of 
communities. These CDFIs leverage $12 in private capital for 
every dollar in Federal support.
    In fiscal year '22, the CDFI Fund financial assistance 
awards unleashed $39 billion loans and investments to 125,000 
businesses and millions of individuals. They financed 50,000 
units of affordable housing and thousands of nonprofits and 
facilities. Native CDFIs have made $1.6 billion in loans and 
investments.
    In regards to PPP, or the Paycheck Protection Plan, 
Congress established a set-aside. And according to SBA, through 
May of 2020, CDFIs, or community financial institutions 
including CDFIs, made 1.3 million PPP loans totaling $30 
billion or 21 percent of all the loans. The average loan size 
was $21,000 compared to $41,000 across all other lending 
classes. For example, 78 percent of all community financial 
institution PPP loans went to businesses requesting less than 
$250,000. Moreover, 15.7 percent of all of those community 
financial institutions-made loans were made to businesses in 
rural communities, closely keeping with the 16.6 percent of all 
the loans that went to rural businesses.
    So with the recent growth in the industry, it presents both 
opportunities and challenges. The Federal Government--and thank 
you--has made an unprecedented investment into CDFIs over the 
past several years with the hope of scaling the industry and 
expanding its impact. However, Congress and the CDFI Fund can 
do more to scale the CDFI movement while ensuring that 
certified CDFIs maintain their role as trusted, mission-driven 
lenders in underserved communities.
    The CDFI Coalition urges Congress to provide $1 billion in 
annual appropriations for CDFI assistance programs through the 
CDFI Fund. The CDFI Coalition urges Congress to invest more in 
CDFIs by increasing the annual authorization level to $1 
billion for the CDFI Fund. We believe that this will result in 
the financing of an additional 100,000 affordable housing 
units, thousands of loans and investments in childcare centers, 
health centers and community facilities, nearly 2 million 
consumer and home ownership loans, and hundreds of thousands of 
loans in investments in businesses in targeted areas.
    The CDFI Fund also strongly encourages Congress to build 
the administrative capacity of the Fund. To sustain the recent 
momentum and growth in the industry, Congress should provide 
additional resources to the agency to administer a growing 
portfolio of financial assistance awards, bonds, and tax 
credits.
    We also support the Bond Guarantee Improvement Act--thank 
you, Senator Smith, and thank you, and Senator Rounds--that was 
introduced yesterday. The permanent extension and other 
improvements contained in that legislation have the potential 
to further prompt revitalization in distressed and rural 
communities.
    All said, thank you again for the opportunity to be here 
today to talk about the impact of community financial 
institutions, Community Development Financial Institutions or 
CDFIs, and I welcome the opportunity to answer any questions 
that you may have. Thank you.
    Chair Smith. Thank you so much. Now we turn to Mr. Altman.

     STATEMENT OF FRANK ALTMAN, FOUNDER AND CEO, COMMUNITY 
         REINVESTMENT FUND, USA, MINNEAPOLIS, MINNESOTA

    Mr. Altman. Thank you, Chair Smith, Ranking Member Rounds, 
and distinguished Members of the Subcommittee. I am pleased to 
participate in this important hearing to discuss the role of 
CDFIs in supporting underserved communities.
    I am Frank Altman, CEO and cofounder of Community 
Reinvestment Fund. We are a national CDFI based in Minneapolis 
whose mission is to help improve lives and strengthen 
communities through innovative financial solutions. We were 
certified as a CDFI in 2009. However, we have been active as an 
organization since 1988. So we have been around for more than 
30 years working in these markets.
    CRF has been the beneficiary of six financial assistance 
awards and the rapid response grant. We have received $919.5 
million in New Markets Tax Credit allocations across--since the 
beginning of the NMTC program, and we have also issued $940 
million in bonds on behalf of 8 CDFIs as a qualified issuer for 
the CDFI Bond Guarantee Program. Since our founding, we have 
deployed more than $3.5 billion in financing in serving more 
than 2.3 million people, and we have made loans to small 
businesses in more than 1,000 mostly low-income communities in 
all 50 States and the District of Columbia, creating or 
preserving more than 156,000 jobs.
    Early on, in response to the need for liquidity for 
revolving loan funds and organizations that were lending in 
these communities, we created the first secondary market for 
community development loans and issued the first asset-backed 
securities collateralized by these assets. Our vision was to 
connect community-based lenders to private investors in the 
public capital markets, and we continue to work toward that 
effort.
    Over the years, we have funded more than 9,000 small 
business loans, two-thirds of which went to businesses owned by 
women or people of color. And our deep expertise in small 
business lending led us to obtain an SBA nonbank national 7(a) 
license, one of now three nonbank CDFIs offering this product 
nationally.
    Today, I want to focus my remarks particularly on the work 
that we have done both nationally and in Minnesota to reflect 
on what we have learned. CRF has a long history of partnering 
with other CDFIs. We have worked with more than 250 CDFIs and 
development finance agencies over the years, both nationally 
and in the Twin Cities.
    And in Minneapolis, more than a decade ago, we made more 
than 100 subordinate loans to support small businesses along 
Lake Street, Franklin Avenue, and primarily in the Phillips and 
Powderhorn Park neighborhoods. We did this in partnership with 
local banks and other CDFIs, and our joint efforts revitalized 
these neighborhoods, resulting in a 62 percent decline in crime 
from 1988 to 2009 and rising property values. This lending laid 
the foundation for a major redevelopment project, the Midtown 
Exchange, a former Sears distribution center, long vacant more 
than 10 years, with 2 million square feet, a very daunting 
project to redo. But working with the city and the strategy the 
city had for this development, CRF and two other CDFIs were 
able to provide tax credits from the New Markets Tax Credit 
Program to redevelop this building into a mixed use building, 
including the headquarters for Allina Health, the Allina 
Commons portion of this project, bringing the headquarters of a 
major nonprofit financial health care system into this very 
low-income neighborhood.
    And nearby, in the same neighborhood, we used New Markets 
Tax Credits to finance the Banyan Community, a few blocks from 
the Midtown Exchange. Banyan supports more than 150 children 
with early childhood education and childcare and after school 
programs in a very low-income community.
    Sadly, the murder of George Floyd erased much of the 
progress we made in the Powderhorn Park neighborhood, but we 
stand ready to be a supporter in rebuilding this area along 
Lake Street and others with funds that we are receiving and 
have received from the CDFI Fund and others.
    The pandemic has caused--oh, I am going to run way out of 
time. Sorry about this. I will get back to this in the question 
area, but thank you very much.
    Chair Smith. Thank you, Mr. Altman. We will have a chance 
to hear the rest of your comments, I am sure.
    Next, we will hear from Ms. Vogel.

   STATEMENT OF LAKOTA VOGEL, EXECUTIVE DIRECTOR, FOUR BANDS 
           COMMUNITY FUND, EAGLE BUTTE, SOUTH DAKOTA

    Ms. Vogel. Thank you, Chairwoman Smith, Ranking Member 
Rounds, and distinguished Members of the Subcommittee. I am 
honored to have been included as a voice in this important 
hearing, to share the successes and challenges of CDFIs serving 
underestimated communities across the Nation.
    My name is Lakota Vogel. I am an enrolled member of the 
Cheyenne River Sioux Tribe, born and raised on a ranch in South 
Dakota. I am the Executive Director of Four Bands Community 
Fund. It is a 22-year-old rural, Native CDFI that started by 
serving all residents of the Cheyenne River Sioux Reservation 
in north-central South Dakota and expanded in 2013 to serve 
Native entrepreneurs across the entire State. I am on the 
executive committee of the South Dakota Native Homeownership 
Coalition and a member of the Mountain Plains Regional Native 
CDFI Coalition.
    I am here today to share the perspective of on-the-ground 
leaders within the Native CDFI movement, which spans about 69 
separate organizations operating across 27 States. The core of 
our mission and purpose of our programming is aimed at leveling 
inequities stemming from an historic lack of investment and 
access to capital as well as noninclusive policies in the 
communities we serve.
    With over two decades of experience, Four Bands Community 
Fund has continuously improved our products and services to 
successfully deploy over $25 million across the State. We 
utilize an integrated approach in lending, which Ranking Member 
Rounds mentioned. It fuses relationship building and learning 
with loan products. Our suite of programs are designed to 
revive traditional culture and support self-sufficiency by 
focusing on two core areas: entrepreneurship, and consumer 
lending and home ownership.
    So within the entrepreneurship space, Four Bands offers a 
comprehensive business training program alongside of customized 
business coaching. We also have several products to help 
entrepreneurs access capital, up to $250,000, and they can use 
that capital for inventory, leasehold improvements, really any 
commercial purpose. We also operate a business incubator that 
provides physical space in addition to our entrepreneur 
programming for at least six businesses in the community of 
Eagle Butte, South Dakota.
    Our average business loan client is a female head of 
household who dreams of starting a business in the service 
industry that does not require a lot of startup capital. It 
could be like a restaurant, a daycare, a hair salon. In turn, 
these industries have a thin profit margin and have more 
difficulty accessing capital from financial institutions 
because of their small-dollar nature and small balance sheet.
    Four Bands has deployed over $200 million to the small 
business sector--I wish 200 million. Twenty million dollars to 
the small business sector, resulting in the creation and 
expansion of over 300 Native-owned businesses across the State. 
And we can proudly say, due to lots of innovation and partners 
like CRF and Frank Altman and resource stacking, we did not 
lose one small business during the pandemic across the State 
that was within our portfolio.
    The other core area we focus on is consumer and home 
ownership. So a unique challenge within our communities is 
invisible credit histories. We are fortunate to have four 
financial institutions serving the Cheyenne River Sioux 
Reservation, but only one of them, the credit union, reports to 
the credit bureaus. So we have generations of borrowers 
utilizing debt tools for decades at the local financial 
institutions, and they remain invisible. And it is not due to 
any individual borrower choices or behavior, but it is due to 
institutional decisions.
    Four Bands began reporting to the credit bureaus in 2010. 
Our foresight and community-mindedness has primed our market 
for home ownership. So as our balance sheet grew, we were 
finally able to offer mortgage products to our community in 
2019 in partnership with USDA as one of the pilot sites for the 
502 direct lending program. We were able to close 8 mortgages 
and spur the demand to close a total of 42 mortgages on 
Cheyenne River within 1.5 years.
    My recommendations today are simple. Advance the Native 
American Rural Homeownership Improvement Act. Thank you to 
Chairwoman Smith and Ranking Member Rounds for cosponsoring 
this legislation. Access to these funds should include all 
Native CDFIs across the Nation.
    The second recommendation I have is just increase the 
Native American CDFI Assistance appropriations to $50 million 
to meet the needs. Our program needs are increasing across the 
Nation, and the annual appropriations for NACA have remained 
stagnant since 2014.
    All this to say the tool, the Native CDFI tool, works; it 
is just chronically undercapitalized. We are part of the 
communities we serve. We run into our clients at the grocery 
store. We sit on the daycare board of directors, desperately 
trying to keep these vital programs running. And as Native CDFI 
staff and community members, we are woven into the fabric of 
the community in almost every aspect of our clients' financial 
lives. There is no comparison to sitting across from our 
clients at tax time, assessing their earnings for the year and 
planning for the future. We are the gentle nudge to savings 
accumulation and a sounding board for many of the financial 
decisions our families make.
    We believe how you perceive is how you proceed. We perceive 
opportunity because our success as Nation builders is 
intricately woven into the success of our neighbor.
    Thank you for this opportunity to testify.
    Chair Smith. Thank you so much, Ms. Vogel.
    I appreciate all of your testimony really so much.
    We are now going to turn to our first round of questions, 
and I will begin. So let me--I would like to first drill down a 
little bit onto the CDFI Bond Guarantee Program. We noted 
Senator Menendez, who is joining us today, worked on this back 
at the beginning, started this back at the beginning of the--
during the Great Recession. And yesterday, Senator Rounds and I 
introduced a bill that would reauthorize and update the Bond 
Guarantee Program. And as was mentioned in your testimony, our 
bill would reduce the program's loan size requirements so they 
could be more accessible to smaller CDFIs and for smaller 
community development projects.
    Mr. Altman, let me turn to you first. Could you share some 
examples with us of how the changes that Senator Rounds and I 
are proposing might help get more capital into the hands of 
smaller CDFIs and ultimately into the communities that they 
serve?
    Mr. Altman. Sure. Thank you, Chair Smith. The Bond 
Guarantee Program is a vital program in the CDFI toolbox. Yet, 
it has only been used by about 26 CDFIs, and the biggest 
barrier to utilization has been the need to either come 
together as a group to obtain a $100 million bond or to be a 
large organization that a balance sheet can support $100 
million in debt. And so that has limited the CDFI bond 
guarantee to really the largest CDFIs in the country. And in a 
few cases there have been groups of CDFIs that have come 
together, but it is very difficult because if one CDFI in a 
group decides it has to wait that can just make the program 
inaccessible for all the other CDFIs that are coming together. 
So by lowering the bond size to $25 million, we believe that 
many more CDFIs will be able to access this vital program.
    And why is it so vital? It provides very low-cost, long 
term debt to the balance sheets of CDFIs. So it is being used 
to match-fund long-term assets, particularly in affordable 
housing, daycare, and other facilities that need long-term 
financing. So it is a very, very powerful program if we can put 
it together in a slightly different way.
    Chair Smith. Thank you very much.
    Ms. Vogel, would you like to comment on this as well and 
how you can see this being advantageous to Native CDFIs?
    Ms. Vogel. You know, honestly, we support all of--the CDFI 
industry is great in that we all support one another, and I 
trust Frank and John and the work that they do with the 
advocacy. You know, as a person on the ground doing the work, 
it is nice to have the big brothers out there watching out for 
these things, and so we have been getting updates from them on 
passing this. So we definitely support the legislation that has 
been, you know, advanced by you and Ranking Member Rounds.
    So we are looking forward to learning more from CRF and the 
CDFI Coalition about how we can better utilize the program, but 
longer-term debt to match what is needed within our community, 
you know, sounds like a win to me.
    Chair Smith. Thank you so much. Let me ask you, stay with 
you, Ms. Vogel. Senator Rounds mentioned this, as did I, that 
he and I have introduced legislation to make permanent a 
program to expand access to mortgages in tribal communities. 
Our bill is based on a pilot that USDA has been conducting in 
South Dakota, in which they partner with Native CDFIs to make 
loans under the USDA's Section 502 mortgage lending program. 
And I know that you have been involved in this pilot program. 
Could you just talk a little bit with us about how the pilot 
program helped to serve the Cheyenne River Sioux and what you 
see as the community benefit of this strategy?
    Ms. Vogel. Yeah, as I mentioned before, there have not been 
any private mortgages on Cheyenne River Sioux Reservation for a 
very long time. If there are mortgages, it is wrapped into a 
small business loan or an ag loan or a personal loan, and so 
the USDA capital allowed us to develop a mortgage product for 
the market. And I hate to even say the word ``mortgage'' within 
my market because it spurred such a demand there where we have 
had a pipeline of over, you know, $18 million of demand for 
mortgage products.
    So the 502 product allowed us the longer term debt capital 
to begin serving the market and priming for home ownership. 
Without that, we would not have been able to deploy the 42 
mortgages that we have closed in the year and half that we have 
been operating the product.
    Chair Smith. Thank you so much.
    I really appreciate the partnership with Senator Rounds on 
this, and I think I will turn the questioning now to Senator 
Rounds.
    Senator Rounds. Thank you, Madam Chair.
    Ms. Vogel, I am going to continue with you for just a 
minute, and that is, as Senator Smith has indicated and has 
talked a little bit about, I really think it is important to 
talk about the USDA 502 pilot program and the reason why it was 
successful there at--you know, within north-central South 
Dakota.
    You are talking about a rural area, and you are talking 
about an area which is on the reservation, which means that a 
lot of the land is in tribal trust. And since it is in tribal 
trust, is that one of the reasons why we are really looking for 
a local understanding of what it means to be able to get a 
mortgage and how you actually get title to the land and so 
forth? Can you talk about that a little bit in terms of how 
critical this particular 502 lending program might impact other 
tribal trust land areas as well?
    Ms. Vogel. Yeah. I think it goes back to relationship 
lending and all CDFIs are based off of relationship lending. So 
while tribal trust has its complexities, it is really about the 
CDFIs walking alongside with their customers down to the BIA 
realty office to begin processing the paperwork. Instead of me 
remaining in my desk and sending my client, you know, down the 
path of where they should go next, we actually walk with them 
through that process. And so the relationships that we hold on 
the ground, taking donuts to the realty officer so they speed 
up the TSR certification process, it is all a little trick of 
the trade and the importance of us being here and understanding 
what it means to develop homes within our communities.
    So, yes, on-the-ground is important. Understanding how home 
ownership affects community development and ultimately economic 
development is important to that. Tribal trust is complex, but 
anybody can do it if you are willing to invest in your 
community.
    Senator Rounds. The Four Bands Community Fund, which is the 
name of your organization, tell me because I think there is a 
lot of folks out there that maybe do not understand how small 
we really are. How many folks actually work--how many lenders 
do you have? How many staff members do you have there?
    Ms. Vogel. I have eight staff members, nine including 
myself, but really just three that are working on the lending 
side. Because we offer the technical assistance and the program 
development, we have, you know, more team focusing on the 
education components within the community.
    Senator Rounds. We talked about first-generation 
individuals that are actually getting involved in financial 
institutions and lending. Can you share a little bit about the 
challenges of moving from a cash economy to one in which you 
have a relationship with a lender and the expertise and the 
walking through the steps of what you do for an individual 
member or family when they come in?
    Just an average family in terms of somebody on the res 
there, they are in the ag community or whatever, and they come 
in, and they are looking for a way to try to get into a home or 
to start a business. What do you find in terms of the 
challenges they face?
    Ms. Vogel. I mean, the first thing is just a lack of 
infrastructure. So you know, you have a daycare or a Head Start 
teacher, a cook, you know, a grandma that is caring for three 
children. She walks into the building and says, I want to buy a 
home for my--my goal is to retire and take care of my three 
grandchildren. And the first thing she does is find land to put 
the house on, and the hard part is getting electric, water, 
sewer, and things like that.
    So what we are asking individuals in rural economies to do 
is to develop piecemeal the infrastructure needed to grow the 
economies, and it is difficult for them because that is an 
outside cost of the loan-to-value. Generally the infrastructure 
improvements are not included in loan-to-value in traditional 
financial institutions. So CDFIs can adjust and view those as 
part of the loan-to-value.
    You know, it really is just that small town relationship 
building, but our average AGI is $27,000, which is, you know, 
half of what the State of South Dakota is earning. So a lot of 
our families are looking to be brought into the mainstream 
financial institutions, and that takes money and time. And that 
is what John Holdsclaw was advocating for, funding the CDFI 
Fund at the level that is needed so then the money can trickle 
out to us and support our administrative costs to provide the 
services that are needed within our communities. You know, it 
is all a part of the system.
    Senator Rounds. I am going to--no, that is OK. And I know I 
am going to run out of time, but I want to get to one more 
question for sure. Private companies, including larger banks, 
are partnering with CDFIs across the country to make a social 
impact on distressed communities or communities that have got, 
you know, first-generation borrowers. Ms. Vogel, could you 
discuss how larger, private financial institutions, like Wells 
Fargo in South Dakota, are partnering with Native CDFIs, like 
yours, to increase access to capital?
    Ms. Vogel. Yes. That was also mentioned in John's testimony 
of saying we leverage. Every dollar of Federal investment is 
leveraged, you know, at least 12 times with different 
investments. So we are going after different pots of funding 
through corporate investments like Wells Fargo to build back, 
you know, the business economies and community economies that 
we are operating within.
    Senator Rounds. Great. So you have a partner there, and 
this is an opportunity to perhaps get more of the private 
lenders actively involved where they literally do not find a 
path forward right now.
    Ms. Vogel. Right. And foundations. We have an historic lack 
of investment in philanthropy in the rural Native regions, and 
so we need philanthropy and corporations to step up.
    Senator Rounds. Thank you.
    Thank you, Madam Chair. And once again, thanks for putting 
together this particular Committee hearing today. I think this 
is really important and this is one area where we absolutely 
can make a difference. And this is bipartisan in nature, and I 
think, Chairwoman Smith, I really do appreciate your leadership 
on this and your interest in finding a path forward that really 
would make a difference in a lot of our rural areas.
    Chair Smith. Thank you so much, Senator Rounds. That is 
great.
    Our next--I will now turn to Senator Reed.
    Senator Reed. Well, thank you very much, Madam Chair and 
Senator Rounds also, to your leadership on this issue. It is 
vitally important and something that touches everywhere.
    Ms. Vogel, there are so many people that are unbanked or 
underbanked, and they are at the mercy many times of payday 
lenders. Can you share your experience with providing 
sustainable and affordable small-dollar loans to members of 
your community?
    Ms. Vogel. Yes, I can. Thank you, Senator. You know, Four 
Bands has been providing a credit builder loan at 11 percent 
interest for some time now, and we chose to have a lower 
interest rate to keep it affordable to the family. But we were 
involved in a State initiative to cap the interest rate in the 
State of South Dakota at 36 percent, which was successfully 
passed. And since then we have not seen payday lenders show up 
within the credit histories of our clients that come through, 
and they have successfully been able to access other products 
to meet that short-term cash need within the household. And it 
has helped us to have that capped interest rate and to not hurt 
the families.
    Senator Reed. Well, and it also indicates that you seem to 
be able to function and survive and prosper as well as 
commercial banks in the State with the 36 percent interest cap. 
Is that accurate?
    Ms. Vogel. Yes, it is, and it is a business decision. It is 
just like any other business decision. If you have a loss 
leader, which the credit builder product does not necessarily 
bring us the best income, but you have other products that can 
offset the cost for that administrative expense to offer the 
important product to the community.
    Senator Reed. As you know, under the Military Lending Act, 
which I was actively involved with, we established 36 percent 
interest on loans to servicemembers, and we have legislation 
now which would extend that to everyone. What impact would that 
have nationwide? I presume from your experience in South 
Dakota--it is very progressive, South Dakota--that it would not 
have an adverse impact.
    Ms. Vogel. I do not think it would have an adverse impact. 
I believe in American innovation, and I think that if you cap 
the interest rate it would keep products safe and affordable 
for the families that are the most vulnerable and there would 
be innovative products that would be released onto the market 
that could fit the need and, you know, fill the gap that was 
left, a void there.
    Senator Reed. Thank you very much, and thank you for your 
work, indeed, all of you for your great work.
    Mr. Holdsclaw, one of the impressions I had about the first 
round of PPP is that the big banks got there first, grabbed the 
money for their big clients, and small business men and women, 
particularly minority communities, found nothing. They were--in 
fact, I got calls, as I am sure my colleagues did, from many 
small businesses, restaurants, et cetera, who had had 
relationships with these banks for years, could not get 
anything out of them. And that is why, I think one of the 
reasons, the second time around we made sure CDFIs had a role 
in distributing the money. Can you talk about that?
    I think again you made a decisive impact on getting money 
to the rural areas where it is needed, to small business 
people. And leaving it to the big folks, we have not seen that. 
Can you comment, please?
    Mr. Holdsclaw. I sure can, Senator. Thank you for the 
question. True, there was a lot of disparity as related to the 
larger banks in the first tranche, and the Coalition took the 
position, as well as other trade associations across the 
industry, to give a pot of money for CDFIs.
    And I think what you saw was, as I mentioned in my 
testimony, those loan sizes went down way below the average. 
But also, too, you saw more Black and Brown borrowers. I know, 
for example, Self-Help Credit Union based in North Carolina, 63 
percent of all of their PPP loans went to businesses of color, 
owned by people of color.
    And so again, I think it was effective to give as an 
alternative to those larger banks. Not knocking banks. I do 
work for a bank. But that said, to give them that alternative 
to be able to access the PPP program, especially in those 
communities that were hardest hit, that were Black and Brown. 
So I am happy that we were able to advocate on that behalf, and 
I am happy that CDFIs were able to step up during that crucial 
time to support those businesses that necessarily did not get 
that in the first tranche.
    Senator Reed. Well, I think the lesson is that if we are 
doing support or assistance to small business that CDFI has to 
be a big part of it, that just turning the keys over to large 
institutions will not get the money to where it should be.
    Mr. Holdsclaw. I concur, Senator.
    Senator Reed. Again, thank you, Madam Chairwoman, and thank 
you, Ranking Member.
    Mr. Holdsclaw. Thank you.
    Chair Smith. Thank you, Senator Reed.
    We will now turn to Senator Daines.
    Senator Daines. Chairwoman Smith, thank you. I am excited 
for this Subcommittee hearing actually because the CDFIs have 
played a very big role in my home State of Montana. They 
continue to play a really vital role in supporting a lot of our 
underserved communities across our State. In fact, if you look 
at the numbers in Montana, CDFIs have invested more than $218 
million. If we look, that spans over about 4,000 loans. And 
CDFIs in my home State, like MoFi, which operate primarily in 
Montana, in Idaho, in Wyoming, they have got a really strong 
track record of boosting economic growth and, importantly, 
creating great jobs.
    I am particularly passionate about the New Markets Tax 
Credit, which provides tax credits for community development 
entities to make investments in our lower-income communities. 
In fact, we can point to a new YWCA in Missoula, which I 
happened to tour back in August of 2020. We have a new wellness 
center in the Fort Peck Indian Reservation.
    So consequently, I have really seen firsthand that the New 
Markets Tax Credit, it works. And I strongly support making it 
permanent and would reach out to my colleagues on both sides to 
suggest we work together to find permanence.
    Certainly one of the frustrating parts of Washington, DC, 
is the temporary nature of policies that are good policies. Let 
us make this one permanent, work together to that outcome.
    We recently, in Congress, extended the NMTC through 2025, 
which will provide much-needed certainty for all stakeholders 
who utilize and rely on this incentive. Congress has extended 
it so many times. At this point, I think we should agree, when 
it gets extended so many times, let us just make the temporary 
nature go away entirely and make it permanent.
    And so I have a question for the whole panel. The question 
is this: In your mind, what would be some of the benefits of 
making the credit permanent, and do you think that would make 
the credit even more effective? And, Mr. Holdsclaw, why don't 
you start off with your response to that?
    Mr. Holdsclaw. Thank you, Senator. You know, like you 
stated, in the State of Montana and across the country, the New 
Markets Tax Credit Program has proven to be vitally successful, 
and I think--and I could not concur with you more in regards to 
making it permanent because you see every year when people or 
CDFIs apply, or CDEs apply, for the program that it is already 
overprescribed. So the need is there, but again, I think it is 
a perfect example of a private public partnership to where 
those outside dollars can be combined with the expertise of the 
Community Development Entity to impact communities.
    And so, definitely strongly agree in making it permanent 
and increasing the allocation authority of the New Markets Tax 
Credit Program. The New Markets Tax Credit Coalition is doing 
some amazing work advocating on that behalf and one that I 
definitely appreciate your support.
    I want to defer to some of the other panelists if they have 
any response.
    Senator Daines. Mr. Holdsclaw, thank you.
    Mr. Altman or Ms. Vogel? Why don't I start with Ms. Vogel? 
Do you have a thought on that?
    Ms. Vogel. I will give my time to Mr. Altman. He has got 
the experience with New Markets Tax Credits.
    Senator Daines. Great. Mr. Altman.
    Mr. Altman. Thank you. Yes, I actually served as the first 
President of the New Markets Coalition back in the beginning of 
the program in 2000, and so we have been very, very involved 
over a long period of time to really make this program 
successful. It has never been plagued with scandal. It has been 
incredibly effective, and it should be made permanent. So I 
appreciate your statements there, Senator.
    Senator Daines. Mr. Altman, thank you.
    Mr. Altman. A couple of other points I would make----
    Senator Daines. Please.
    Mr. Altman. ----is that it should be indexed for inflation 
as part of its permanency. It should be made permanent now, 
when the opportunity is here. I know there has been some 
discussion about waiting until 2025, when this extension rolls 
up, but the need is now. It should be made permanent, and it 
should be widely available to CDEs.
    Senator Daines. Well, thank you.
    Ms. Vogel, I know you have spent a lot of time working in 
Indian Country. Anything, any thoughts you might want to share 
on what has worked and what has not worked to increase CDFI 
investment in Indian Country?
    Ms. Vogel. Well, just quickly on the New Markets Tax 
Credits, we do not have many investments into Indian Country 
with New Markets Tax Credits. A lot of us have tried to 
innovate and create different models to address that and access 
the New Markets Tax Credits, to get an allocation, and it has 
not worked successfully.
    So I would really encourage us all to take a deep look at 
what are the systemic issues going on with the program that are 
inhibiting investment into Indian Country, and that could take 
a team at the CDFI Fund. So I think there is just some eyes 
that need to be put on it and, you know, the way that we 
perceive things and taking a look at things. So we need to be 
involved in that as an advisory panel and taking a look at 
things.
    Senator Daines. Ms. Vogel, thank you. It is a very helpful 
comment. Appreciate the observation.
    Chairwoman Smith, thank you. I am out of time.
    Chair Smith. Thank you so much, Senator Daines.
    Now we will turn to Senator Menendez.
    Senator Menendez. Thank you, Madam Chair, to you and the 
Ranking Member for holding this hearing. Throughout the 
pandemic, we saw that minority and women-owned small businesses 
were hit particularly hard. At the same time, we saw the vast 
majority of funding under the Paycheck Protection Program go 
not to these businesses that were most affected but to 
predominantly White-owned businesses with preexisting 
relationships with banks. So I would like to ask Mr. Altman and 
Ms. Vogel, how did you CDFIs work to prioritize lending to the 
hardest hit small businesses, particularly minority and women-
owned businesses?
    Mr. Altman. I will start. This program really brought out 
the best in CDFIs. We were able to network with a number of 
CDFIs that did not have either business lending capacity or 
were not yet eligible in the first round. CRF, because we had a 
7(a) license, we were able to mount the PPP program from day 
one, and we linked together with organizations around the 
country that referred their borrowers to us so that we could 
make those loans. And we worked together. They would do a lot 
of the prep work with the borrowers, and then we did the final 
lending.
    And that led to $700 million in PPP loans originated by CRF 
through a network of 47 organizations, including Four Bands, 
and the median loan size of those business loans was $21,000. 
So we really were getting to the mom-and-pop companies, the 
very small businesses. And two-thirds of the loans that we 
made, where we had information on ethnic or racial 
characteristics, were made to businesses owned by people of 
color and/or women. So that is exactly, I think, the way that 
the CDFI industry was able to partner with others.
    And I should say that on the banking side, because the PPP 
program was so important, we were able to raise hundreds of 
millions of dollars in credit facilities from large banks to 
fund that PPP activity that we did in concert with many other 
organizations.
    Senator Menendez. Ms. Vogel.
    Ms. Vogel. Do you mind if I----
    Senator Menendez. No. Go right ahead.
    Ms. Vogel. OK. Thank you for that question. And I think 
that, you know, our experience was at first a lot of panic when 
we found out about the PPP program and the inability for us to 
access a lot of the funds for our borrowers. We had borrowers 
bringing all of the Federal programs--the EIDL, PPP--to us and 
saying, how do I get access to this? Our first instinct was to 
refer to financial institutions, and many of them were not 
serving borrowers that were outside of their portfolios at the 
beginning in these small banks.
    And so we had to, you know, scramble and find a partner. 
And thank goodness CRF had created this tool. And so we looked 
for partners alongside that were also giving us a little bit of 
a kickback because we spent a lot of time, administrative time, 
packaging the loans, working with the borrowers, getting their, 
you know, balance sheets straight to send off to the next 
level, and CRF was generous enough to offer something. Many of 
the other financial institutions just wanted us to send them 
borrowers without any sort of support back to the CDFI, which 
was very frustrating. So we are thankful for CRF and what they 
were able to do, and there were a few others out there that did 
the same.
    We were on the ground. We were trying to get the resources 
into the hands of the community members that needed it the most 
and successfully did it through partnerships like CRF.
    Senator Menendez. Great. Well, to support the important 
work CDFIs do in New Jersey and, for that fact, around the 
country, I led the effort to establish the CDFI Bond Guarantee 
Program over 10 years ago. That program allows CDFIs to access 
long-term, low-cost capital to jumpstart economic growth and 
community development, all at no cost to the taxpayers.
    Mr. Holdsclaw, you noted in your testimony that the program 
has supported $1.3 billion in affordable financing for 
community facilities, nonprofits, commercial real estate, other 
community development projects. Could you explain to the 
Committee in more detail how the program helps these projects 
actually come to life?
    Mr. Holdsclaw. Thank you, Senator, and thank you for your 
support of that 10 years ago. I think that, you know, the Bond 
Guarantee Program has provided again an opportunity for the 
folks who have received it always in the desire and access to 
garner more capital. So I think that it became a game changer 
from that standpoint of while we do want to encourage folks, or 
encourage the limits to come down to be able to expand it to 
more individuals, I just think that the way the program is 
structured just allowed more CDFIs, or the ones who have been 
able to access the program, just another avenue or another 
vehicle on top of the FA&TA programs that were already out 
there and already existed. So again, making that limit go down 
a little lower, to $25 million as opposed to $100 million, will 
only expand the net even more for other folks to be able to 
access that program.
    Senator Menendez. Madam Chair, I am out of time. Just one 
last question, would it be fair to say that if the CDFI bond 
program had not existed that some of these projects would not 
have taken off from the ground?
    Mr. Holdsclaw. Very fair to say. Very fair.
    Senator Menendez. All right. Thank you, Madam Chair. I have 
other questions. I will submit them for the record.
    Chair Smith. Thank you so much, Senator Menendez.
    Next up for questioning, unless Senator Tester is with us, 
which I think he is not, we will go to Senator Cortez Masto 
from Nevada.
    Senator Cortez Masto. Thank you. Thank you, Madam Chair. 
Thank you to both you and the Ranking Member for having this 
hearing. It is so important. I really appreciate the comments 
from the panel members today and all the good work that you are 
doing.
    But let me start with Mr. Holdsclaw and Mr. Altman. Let me 
talk a little bit about the Housing and Economic Recovery Act 
of 2008 and get your thoughts here. So we all know Congress 
allowed nondepository Community Development Financial 
Institutions to become members of the Federal Home Loan Banks. 
Mr. Holdsclaw, what has been the impact of providing a 
secondary market for CDFI loans through the Federal Home Loan 
Banks?
    Mr. Holdsclaw. Thank you, Senator. A great question. I 
think it is obvious to see that the number of CDFIs who have 
joined the Federal Home Loan Banks system has increased. When 
you look in 2011, you had 8. You look at 2021, you now have 67.
    So as we all know, that system exists to support housing 
opportunities and community development, much like CDFIs do as 
well. And so through this membership, as we talked about 
throughout this testimony, CDFIs are always on the lookout for 
affordable sources of capital, and I think that the Federal 
Home Loan Banks system has given our members or our industry 
the low cost, flexible, on-demand capital that they need 
through these advances. And I think that CDFIs are able to take 
this capital and use it as a funding source for mortgage 
products, for very low and low to moderate-income communities. 
And so I think that as the banks offer the letters of credit to 
CDFIs to help secure these additional obligations I think you 
are just going to see the numbers rise as the need or fight for 
capital is going to become more apparent as we move on.
    So with the CDFIs becoming the shareholders of the bank, 
they can also earn high yielding investments and can 
participate in all the various programs that the Federal Home 
Loan Banks system provides, like for example, the Federal Home 
Loan--the Federal Bank of New York has grant programs that 
support lending for disaster relief, affordable housing, and 
homebuyers. So I think, Senator, as time goes on, you are only 
going to see those numbers increase from 67 on up.
    Senator Cortez Masto. Yeah, no. I think that is great and 
that is a positive, and I think it is wonderful to hear the 
benefits from the change in the law. But I also know that, 
unfortunately, the law did not permit Community Development 
Financial Institutions to join as community financial 
institutions, and that has also had an impact.
    And so, Mr. Altman, I appreciate the Community Reinvestment 
Fund's support of a bill that I have introduced to allow CDFIs 
to pledge small business, small agriculture, and community 
development loans to receive advances from the Federal Home 
Loan Banks. So, Mr. Altman, how would the opportunity to pledge 
non- housing loans to the Federal Home Loan Banks affect your 
and other Community Development Financial Institutions?
    Mr. Altman. It would be very, very helpful. We have looked 
over time since this opportunity to become a member of the 
Federal Home Loan Banks, and we have decided that we could not 
because of the collateral requirements, just not having the 
right collateral to meet the standards of the bank or having 
the right kind of collateral to get a significant advance. So 
we have gone elsewhere for liquidity.
    Now that said, we have been supported outside of membership 
by investments made by the Federal Home Loan Bank of Chicago, 
and I know other Federal Home Loan Banks have looked at other 
ways to support CDFIs. But CDFI membership, I think, would be 
greatly enhanced by the bill that you have introduced.
    Senator Cortez Masto. Yeah, no. I appreciate that because I 
think my understanding is just in 2008 was a drafting error 
more than any opposition to allowing this to occur, and so I 
would encourage my colleagues to support my proposal to permit 
nondepository CDFIs to pledge the same collateral as other 
community financial institutions.
    And then to the Chairwoman, I would request permission to 
place into the record the 2015 GAO report, Federal Home Loan 
Banks: Collateral Requirements Discourage Some Community 
Development Financial Institutions from Seeking Membership.
    Chair Smith. Without objection, so ordered.
    Senator Cortez Masto. Thank you. And I know I only have so 
much time left, but here is the other thing that I am going to 
ask the panel members to help with. I think we all do--and this 
is a great opportunity here to see bipartisan work happening. 
We all support greater investments in Community Development 
Financial Institutions.
    Unfortunately, I am aware that these entities exist 
unevenly across the Nation. There is only one Treasury 
certified CDFI in Nevada. In the past 30 years, we have had 
only 8 awards to a Nevada-based CDFI. So my question, Mr. 
Holdsclaw, is: How can the CDFI Coalition assist the 
development of CDFIs in underserved States like Nevada, and 
what should we be considering? How do we bring more of those 
resources into a community that is underserved?
    Mr. Holdsclaw. Senator, I would say in the time I have 
left, obviously, advocate for more technical assistance dollars 
for emerging CDFIs in Nevada. Also, work to increase the small 
and emerging CDFI program or SECA. Then last, but not least, 
you know, there are webinars; there are other things that 
emerging CDFIs can do. And I know we as a coalition have a lot 
of western-based, rural CDFI members, and I am more than happy 
to talk to your staff, to bring folks together, and put you all 
in touch with them.
    Senator Cortez Masto. Thank you. And I am looking forward 
to that because I know about the technical assistance funds. 
They are just not reaching Nevada. So if there is a way that we 
can get your support and innovation ideas about how we do this 
and grow this in Nevada, I would be open to that.
    Thank you, everyone.
    Chair Smith. Thank you very much.
    Senator Van Hollen.
    Senator Van Hollen. Thank you, Madam Chair, and I want to 
thank you and Senator Rounds for bringing us together on this 
important hearing today. And to all the panelists, thank you 
for your input.
    Also, good to see my friend and colleague, Senator Warner, 
and it was good to work with him and others in providing that 
big bump-up to CDFIs as part of the bill we passed last 
December, and I do have a couple questions regarding the status 
of the rollout there.
    But first, I also serve on the appropriations committee, 
and I chair the subcommittee that oversees the appropriations 
through the Department of Treasury to CDFIs. And we have been 
working on a bipartisan basis to try to increase funding for 
CDFIs given the critical role they play in economic development 
at the community level. And, we have unveiled a proposed budget 
for this fiscal year that we are now in, for fiscal year 2022, 
that would increase the CDFI allocation by $90 million, take it 
to $360 million from the current amount of $270 million.
    So my first question to Mr. Holdsclaw is: Do you agree that 
CDFIs have the capacity to absorb this additional funding, and 
what would be consequences if we are not able to provide the 
additional funding, if we simply straight-line CDFI funding at 
current levels?
    Mr. Holdsclaw. Thank you, Senator. I do think--I think if 
COVID has proven nothing else in what CDFIs were able to do, 
that CDFIs can be the first line of financial defense for 
underserved communities across the country. So I do feel like--
and thank you for your support of the appropriations levels--
that CDFIs would be able to absorb that increased amount. I 
think that the performance during COVID has shown that.
    In regards to the second part of your question, obviously, 
all CDFIs worry and are concerned about access to capital and 
loan production and whatnot. I just feel like the need is so 
great that I would have a hard time finding what would be 
necessarily detrimental to those types of funds.
    Also, too, Senator, I do not know if you were here during 
my testimony, but I also talked about not only that money going 
to the CDFIs but also the Fund being able to have enough 
administrative support internally to deal with the demand of 
surge of applications for certified CDFIs going right now as 
well as the awarding of grants and allocation authority from 
last year. They are very short-staffed. But I think there is 
also a play there as well. CDFIs can get a lot of that money 
from an FA&TA standpoint. I think there is also, too, a desire 
from the Coalition's standpoint for us to support the CDFI Fund 
from an administrative standpoint.
    Senator Van Hollen. No, I appreciate that, and I think that 
is one of the things we would like to do and work with you and 
your members to make sure that we do that. We want to--
obviously, we have got to support the folks at Treasury who are 
administering the program and the folks in the field.
    So I referred to the December bill, the two big programs 
that are still in the process of implementation. There is the 
Emergency Capital Investment Program and the Emergency Support 
and Minority Lending Program. Based on the feedback you are 
hearing, are there any concerns with the rollout that we should 
be aware of at this particular point, or do things seem to be 
going smoothly, putting aside the issue with the fact that non 
depository institutions cannot participate? And I agree with my 
colleagues who would like to remedy that situation.
    Mr. Holdsclaw. Right. Well, from our membership, Senator, 
we are not hearing anything negative in regards to the rapid 
response.
    And then obviously, a couple weeks ago, the ECIP program, 
you know, when I would check in with some of the folks who were 
able to garner some of that money, I would hear things like, 
you know, transformational game changer again because--
especially from a lot of the minority deposit institutions that 
I reached out to. I had a conversation with the second oldest 
CEO of the second oldest Black bank in the country in Durham, 
North Carolina, and he just said, you know, it is unbelievable 
what that is going to allow him to be able to do.
    Senator Van Hollen. Great. No, I think this is something 
that, you know, we are all proud of the funds that were made 
available and look forward to working with you.
    My final question, Mr. Altman, relates to providing 
opportunity for more CDFIs to participate as lenders under the 
SBA programs. This was an issue that, you know, really came to 
a head I think during this pandemic in the PPP programs. We saw 
that CDFIs could be very important conduits for those funds, 
but we do not have enough CDFIs who are certified with SBA 
programs. What do you think we can and should be doing in that 
regard?
    Mr. Altman. Well, two things. I think more CDFIs ought to 
have access to the license that we have. There are only 14 of 
these national nonbank SBA 7(a) licenses, and only 3 CDFIs hold 
those at this point. It does allow us to be a national lender, 
which is important.
    Then the SBA also has been operating a pilot program called 
Community Advantage that allows CDFIs to make SBA-guaranteed 
loans up to $250,000. That program should be made permanent, 
and I believe there has been legislation introduced to make it 
permanent because it is a vital tool and many of the CDFIs who 
were part of that pilot program were able to access the PPP 
program very effectively.
    And I think there is another aspect to all this, and that 
is the role of technology in supporting the lending that CDFIs 
do. In the SBA world, SBA loan origination is a complicated 
process. And CRF has developed a platform called SPARK that 
CDFIs are now using to originate their SBA loans, but it is a 
very, very useful and forward-looking platform that--I think it 
is important for the CDFI world to be able to access technology 
platforms as banking is doing right now, and so that should be 
part of the SBA discussion as well.
    Senator Van Hollen. Thank you, and thank you, Madam Chair.
    Chair Smith. Thank you so much, Senator Van Hollen. I 
certainly so much appreciate your leadership on the 
appropriations subcommittee.
    And, Senator Warner, welcome to the Subcommittee. It is 
great to have you given your deep interest and commitment to 
supporting CDFIs. So thank you for being with us.
    Senator Warner. Well, thank you, Chair Smith, and I really 
appreciate the fact that you and Senator Rounds are holding 
this hearing and thank the panel. I think CDFIs--I think we 
have all--at least I, speaking personally, have come to much 
more fully understand the incredibly valuable role they play in 
our financial system and, frankly, the opportunity to expand 
that role.
    And I want to thank Senator Van Hollen for his work as an 
appropriator to make sure that we take this moment and continue 
to expand it. I am very proud of the fact that so many of us on 
this Committee, in a bipartisan way, work so hard to get that 
$12 billion, you know, that came out of the Jobs and 
Neighborhood Investment Act into the last COVID package.
    And I think, as Senator Van Hollen pointed out in his line 
of questioning, the rollout has been pretty darn good. You 
know, the grants went out the first round. The second round 
will come out later.
    The fact that we had close to--what was it? Almost $13 
billion of requests on the ECIP program--and so we were way 
over subscribed on that item--shows, I think, the capacity of 
this group of institutions obviously serving underserved 
communities.
    You know, I think we need to mark as well what Senator 
Cortez Masto talked about, how we expand this, the network of 
CDFIs in a much, much greater way.
    So I want to hit two or three points pretty quickly. First, 
I am going to start with Mr. Altman. I am really interested in 
this whole idea of can we take CDFI portfolios and securitize 
them. I think that is the next big step we need to move to. I 
have had conversations with the Fed.
    I know, Mr. Altman, that CRF, your entity, has done some 
securitizations in the past. I think, you know, what else 
should we able to do? What tools--do you need additional tools 
from Congress? Do we need to continue to nudge the Fed? How can 
we make, either on an individual basis or on an ability to 
aggregate, pools of loans from a variety of CDFIs into an 
easier securitization process?
    Mr. Altman. Thank you for that question. We actually did 
pioneer the use of securitization as a tool early on, and we 
have securitized through 21 different issues, securitized 
mostly small business and nonprofit loans but also close to 
$100 million in multifamily affordable housing loans. And those 
securities, at least the latter ones that we did, were large 
enough to be rated by Standard & Poor's, something that people 
said will never happen. And this was all done without any 
particular government support other than maintaining compliance 
with tax laws and so forth.
    After the crash, the market for securities just collapsed, 
and we had to move in a different direction. And then the 
accounting rules changed and required--even though 
securitizations are bankruptcy-remote, usually done through 
special purpose vehicles, it required the special purpose 
vehicles to come back onto the balance sheets of the issuer. So 
that made it virtually impossible for an organization like CRF 
to continue to securitize without having a much larger balance 
sheet. And so we moved to other tools because the balance sheet 
just was not there to support it from an accounting 
perspective, and I think that is one of the issues that needs 
to be examined.
    The second issue is securitization works the best when the 
assets that are being securitized are standardized. And CDFIs, 
in general--and we certainly came to the market recognizing 
this. CDFIs, in general, do their own thing, and the ability to 
create standardized products that can be fed into a security is 
still a challenge. But once we have standardized products--and 
I will use the PPP product as a prime example. That was a 
standardized product across the entire industry, and it became 
very liquid. And so CDFIs need to have the ability, if they 
want to securitize, to create products that are the same across 
different CDFIs, not that all their products are the same, but 
that the ones that they want to securitize can be put into 
facilities that are of like benefit.
    So those would be my basic comments.
    Senator Warner. We would like to keep working with you on 
this because we have had conversations with both the Fed on 
potentially creating SPVs and with private capital. And that is 
where I want to move my last question to, which is: How do we 
better leverage private capital?
    And I would like to hear from Mr. Holdsclaw as well on 
this, and the balance of the panel, because you know, private--
there is a lot of talk from private capital about wanting to 
get in. You know, I know some large entities, like Google, have 
been pretty creative in using their balance sheet. But I think 
that can help us on securitization. And I also want to make 
sure that--some of the CDFIs and MDIs, in particular, that are 
most in need could not meet all the requirements even to get 
the ECIP program. So is there also a way where some of this 
private capital that might be more at risk can help smaller and 
other entities?
    So I know my time is up, Madam Chair, but if I could have 
the panel answer on how we can better leverage private capital, 
I would love to hear from everybody, starting with Mr. 
Holdsclaw.
    Mr. Holdsclaw. Thank you, Senator, and thank you for your 
past support for CDFIs. I think that, you know, in the wake of 
the racial and social reckoning that we had last year coming 
from George Floyd, I think you saw this influx of private 
corporations coming together and making deposits into MDIs and 
others. I think that--as well as foundations.
    I think that I would say one way to increase it is to look 
at the smaller and emerging CDFIs again, to try to get some of 
those, like you said, those MDIs who are unable to do ECIP, to 
be able to get and foster those relationships between them as 
well because, again, we have this gap where some folks were 
unable to capitalize off of it and some were not--some were, 
and some were not.
    And so I think that just the continuing education and 
bringing folks together outside of some type of racial and 
social reckoning, to show that CDFIs are here. They are--you 
know, they are first responders from a financial standpoint. 
And educating other folks about the smaller and emerging ones, 
I think, will level the playing field from a private investment 
standpoint.
    Senator Warner. Others? I know my time is up, but I do not 
want to--I am not a Subcommittee Member. I do not want to 
overdo.
    I will go back to the Chair, but Madam Chair, I just--one 
of the things I hope the Subcommittee would look at as well--
you know, we know that Lael Brainard in her previous role was 
leading the efforts on CRA reform. I would love to get maybe 
for the record from the panel how we can use CRA reform to also 
help with CDFIs. And thank you and Senator Rounds so much for 
holding this hearing.
    Chair Smith. Thank you so much, Senator Warner, and I think 
those are all great, great issues to follow up on and look 
forward to continuing to work with you on this.
    Senator Warner. Thank you.
    Chair Smith. So I believe--unless I am mistaken and not 
seeing anybody, I believe that everybody who is interested has 
gone through their first round of questions. So let me turn to 
Senator Rounds.
    Senator Rounds, would you like to ask a second round of 
questions?
    Senator Rounds. At this time, I think I have had my 
questions answered, and it has actually been a very good 
Subcommittee hearing. I think we have had some very good 
participation by Members, not just of the Subcommittee, but 
other Members of the Banking Committee as well. I think this 
has been a good, informational meeting, and I think with regard 
to some new ideas and so forth it has been a very beneficial 
meeting. And I thank you, Madam Chair, and I would defer at 
this time.
    Chair Smith. Well, thank you. Thank you very much.
    I actually do have just a couple of follow-ups that I would 
like to ask the panel before we close, and so let me just get 
to those quickly. The first is this: You know, when the 
pandemic struck in 2020, a lot of State legislatures, including 
my State legislature, developed some economic relief packages 
for small businesses, and they turned to CDFIs. CDFIs stepped 
up to help in distributing these funds so that they got to 
traditionally underserved communities. And now I have heard 
that some of these CDFIs in Minnesota are facing challenges 
maintaining or getting certification because those emergency 
loans were outside of the narrow definition of their target 
market.
    And let me just ask--so let me just finish by saying the 
CDFI Fund at the Department of Treasury, which sets these 
rules, has provided some target market exemptions for PPP loans 
but has not done the same for these State-funded pandemic 
loans. Mr. Altman, I just want to turn to you about this. I am 
wondering if you have heard about this and if you have any 
recommendations or thoughts that we can take back to Treasury.
    Mr. Altman. Yes. Yes, it is a challenge. We are a national 
organization. There are several different ways the CDFI Fund 
permits target markets. Low-income targeted populations is one 
where you literally have to show that low income people 
directly were benefiting or by using proxies like being a 
resident of affordable multifamily housing and others.
    There is another one called Investment Areas, and that is a 
geography that has been established by the CDFI Fund based on 
certain characteristics of census tracts. Investment Areas tend 
to be limited and are held accountable by advisory committees. 
So for an organization that is national, like CRF is and 
several other CDFIs, it is impossible to have 50 advisory 
committees to be able to operate Investment Areas nationally. 
So we really advocate for a reform there to enable national 
Investment Areas under that target market test.
    And then there is other targeted markets which tend to be 
specific ethnic or racial groups that are target markets for 
CDFIs, and oftentimes the accountability mechanism there is 
also limiting. So accountability is very important. Oftentimes 
CDFIs use their boards as an accountability mechanism. That 
needs to be streamlined, I think.
    And then finally, this issue that you are raising, Senator, 
of CDFIs being asked to take up the sort of frontline effort, 
with them being restricted in where or to whom they can lend, 
is an issue. And I think during this period of recovery, after 
the pandemic, the CDFI Fund needs to provide some relief to 
CDFIs who might be lending for issue-related purposes but not 
necessarily inside of their target markets.
    Chair Smith. Mr. Holdsclaw, would you like to add to that? 
I am sure--I wonder if you have heard about this as well.
    Mr. Holdsclaw. I have heard about it, Senator, and again, 
probably if it is not corrected you are going to start to see 
more and more of this because you are having more States now 
that are developing programs that are CDFI-specific.
    I mean, one of the things that we have thought about at the 
Coalition is to try to get everybody on the same page, is to 
have a stakeholder meeting to renew the discussion on the 
proposed rule and also note that there are some, again, as 
Frank stated, some complications as it relates to the targeted 
market certification. And so we would like to be able to sit 
down in this stakeholder meeting and hash some of these things 
out and help the Fund as they start to deal with more and more 
of these issues.
    Chair Smith. Well, thank you. I look forward to working 
with you and everyone on that. I think this is a--this is 
something that we should be able to find a solution to.
    Last question I just want to highlight before I close is 
several of you in your testimony mentioned the role that CDFIs 
can help in expanding childcare businesses. This is such an 
important issue at a moment where we are seeing workforce 
shortages and we are seeing deep challenges in the childcare 
sector caused by the pandemic, really challenges that existed 
way before the pandemic. This seems to me to be a really 
important opportunity.
    So, Mr. Holdsclaw, let me just stay with you. Is there 
anything more that you would like to say just to highlight the 
important role that CDFIs can play in addressing this challenge 
of childcare shortages and childcare deserts?
    Mr. Holdsclaw. I would, Chairwoman, and you got me in my 
sweet spot as a proud Head Start child and having the 
opportunity to have visited parents in Community Action Head 
Start in Minnesota. I think that in my mind the childcare piece 
of what a lot of CDFIs do across the country is probably one of 
the most--least known about.
    You have got organizations like CEI in Maine that have a 
40-year track record of working with childcare facilities from 
a finance standpoint. But there is also a development services 
point here as well because CDFIs also have a mission in 
providing those development services, which is more or less 
them helping build the capacity for a childcare center that is 
trying to open early care and education.
    So I think that they play a great role, but it is one that 
we probably need to do a better job of highlighting. I would be 
happy to send over to the office any information that we have 
in regards to some of the programs that our members have from a 
childcare center standpoint, finance facility.
    Chair Smith. Thank you so much.
    And then, Ms. Vogel, I will close with you because I know 
that this is an issue that you are deeply committed and 
passionate about. Congratulations, by the way, on being a 
finalist for the Build Back Better Regional Challenge in this 
area. So would you like to say anything more about this?
    Ms. Vogel. Yeah. I think daycares are, you know, such an 
important and vital part of any economy, including the rural 
economies, and they are a hard business model to fund in the 
traditional way. And so CDFIs can step up in a role and create 
unique financial products to match the daycare model, you know, 
because it is a hybrid of almost a social program. And it is 
underfunded federally, so it definitely needs more Federal 
support for daycare centers across the Nation.
    But as far as what CDFIs can do, we can--if we can get 
access to more flexible capital to offer more patient capital, 
you know, lower interest rates, for these types of models, it 
will really help. And then as developers within our community, 
Four Banks is looking at, you know, building the buildings and 
then helping with the operations costs to offset the cost to 
the actual family member to make it more affordable to our 
community through the Build Back Better Regional Competition, 
hopefully. So thank you for this opportunity.
    Chair Smith. Thank you so much. Well, you are exactly 
right. It is a question of facilities and upgrading and 
improving facilities that we need to support more, as well as 
making the business model for childcare actually function for 
parents and for providers, where we have situations where, you 
know, providers are making, you know, not even enough to 
support their families at the same time that parents are priced 
out of childcare because it is so expensive. So there is many 
opportunities here.
    I want to just thank all of our panelists for a terrific 
discussion today about the opportunities that we have to 
support Community Development Financial Institutions.
    Senator Rounds, thank you so much again for the opportunity 
to work together. I think that we have heard a lot today about 
areas of bipartisan opportunity to come together, including the 
two bills that you and I are leading on, the Bond Guarantee 
Program and also the Section 502 Mortgage Lending Program, but 
other areas where we can find bipartisan agreement, including 
New Markets Tax Credits, and I hope also providing increased 
funding for CDFIs. So I look forward to continuing our work 
together on this.
    I want to thank everybody. Thanks to our witnesses for 
being here today and providing your testimony.
    And for Senators who wish to submit questions for the 
record, those questions are due 1 week from today, which will 
be Wednesday, January 12th.
    For our witnesses, you will have 45 days to respond to any 
questions for the record. Thank you again.
    And with that, our hearing is adjourned.
    [Whereupon, at 11:29 a.m., the hearing was adjourned.]
    [Prepared statements, responses to written questions, and 
additional material supplied for the record follow:]

                PREPARED STATEMENT OF JOHN HOLDSCLAW, IV
              President, CDFI Coalition, Washington, D.C.
                            January 5, 2022
    My name is John Holdsclaw, IV, President of the CDFI Coalition, and 
I am the Executive Vice President of Strategic Initiatives at the 
National Cooperative Bank, a leading financial institution dedicated to 
providing banking solutions to cooperatives, their members, and 
socially responsible organizations nationwide. Thank you for this 
opportunity to testify on the Community Development Financial 
Institutions Fund (CDFI) Fund and the success of CDFIs in delivering 
financial services to underserved low-income urban, rural, and tribal 
communities.
    About the CDFI Coalition The CDFI Coalition was formed in 1992 by a 
variety of nonprofit organizations and activists concerned about the 
persistent and pervasive lack of financing capital available in 
distressed urban neighborhoods and poor rural communities. Our 
Coalition is made up of more than 150 organizations--including loan 
funds, community development banks, community development corporations, 
venture funds, microlenders, Native American organizations, and credit 
unions--that are working to finance affordable housing, small 
businesses, and community facilities at the ground level.
About the CDFI Fund
    The Community Development Financial Institutions (CDFI) Fund was 
established within the Department of Treasury in the Riegle Community 
Development and Regulatory Improvement Act (P.L. 103-325) of 1994. The 
purpose of the agency is to ``promote economic revitalization and 
community development through investment in and assistance to community 
development financial institutions, including enhancing the liquidity 
of community development financial institutions.''
    The CDFI Fund administers the following core programs, and each 
program awards funds annually through an independent and competitive 
application process, including the Financial Assistance (FA), Technical 
Assistance (TA) Awards, The Native American CDFI Assistance (NACA) 
Program, The Bank Enterprise Award (BEA) Program, New Markets Tax 
Credit (NMTC) Program, Capital Magnet Fund, the CDFI Bond Guarantee 
Program, Economic Mobility Corps, and Small Dollar Loan Program.
The Challenges Facing Low-Income Communities and Populations
    Even before the pandemic, low-income communities and communities of 
color faced significant obstacles in accessing financial services, 
including mortgage, consumer, and business loans, financing for 
community facilities and affordable housing, and the patient, flexible 
capital needed to sustain a healthy economy. These are the communities 
CDFIs serve.
    One of the biggest challenges facing underserved communities and 
populations is the lack of existing assets. Indigenous people and 
people of color, in particular, have fewer assets to use to secure 
loans. For example, the median net worth of White families is nearly 
nine times greater than Black families, according to the Federal 
Reserve's 2019 Survey of Consumer Finances. Entrepreneurs of color are 
therefore less likely to self-finance a business or borrow funds from 
friends and family.
    With fewer resources to tap into, businesses in low-income 
communities tend to be smaller than businesses in more prosperous 
communities. The average business in a low-income community has 20 
percent fewer employees than businesses in other areas, according to a 
2017 report by the Small Business Administration.
    According to a working paper published in 2018 by the Richmond 
Federal Reserve, Black and Latino business owners are significantly 
more likely to be discouraged borrowers. \1\ Minority borrowers face 
more scrutiny and receive less assistance when applying for bank loans 
than their White urban counterparts.
---------------------------------------------------------------------------
     \1\ Financing Patterns and Credit Market Experiences: A Comparison 
by Race and Ethnicity for U.S. Employer Firms. Report by Alice Robb, 
Ph.D., for the Office of Advocacy, U.S. Small Business Administration, 
February, 2018.
---------------------------------------------------------------------------
    Small towns and farming communities also continue to be underserved 
by conventional lenders. The number of community banks in the United 
States has declined by an average of 300 per year over the past 30 
years, according to data from the Federal Deposit Insurance 
Corporation. During the Great Recession, when lending plummeted 
nationwide, in Appalachia, lending ``decreased to a greater extent, 
standing at 18 percent below national levels at the end of the 
recession . . . in the Region's economically distressed counties, 
lending was 56 percent below national levels. Further, growing 
disparities were found in lending to businesses with revenues of less 
than $1 million and in counties with limited access to non- credit card 
bank lending.'' \2\
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     \2\ ``Access to Capital and Credit in Appalachia and the Impact of 
the Financial Crisis and Recession on Commercial Lending and Finance in 
the Region''. July 2013, Josh Silver and Archana Pradhan, National 
Community Reinvestment Coalition; and Spencer M. Cowan, Woodstock 
Institute.
---------------------------------------------------------------------------
    Residents of Indian Country also face significant challenges in 
securing commercial credit, including significantly longer distances 
from brick-and-mortar financial institutions and poor and limited 
internet for mobile or online banking. This is compounded by a lack of 
equity resources, collateral, and credit history; experiences and 
perceptions among Native entrepreneurs that commercial bank financing 
is difficult to secure; and a lack of diversity in funding sources. \3\ 
According to an analysis of 2018 Census and Bureau of Labor data by the 
National Community Reinvestment Coalition, Native Communities 
experience the highest rates of unemployment (6.6 percent) and poverty 
(25.4 percent) among minority groups. \4\ Native CDFIs are often the 
only resources for financial products and services in tribal 
communities.
---------------------------------------------------------------------------
     \3\ Miriam Jorgensen and Randall K.Q. Akee. 2017. ``Access to 
Capital and Credit in Native Communities: A Data Review'', digital 
version. Tucson, AZ: Native Nations Institute.
     \4\ Dedrick Asante Muhammad, Rogelio Tec, and Kathy Ramirez, 
November 18, 2019. ``Racial Wealth Snapshot: American Indians/Native 
Americans''.
---------------------------------------------------------------------------
    A 2019 report by the Federal Reserve found that since the end of 
the last (great) recession, ``low-income neighborhoods have experienced 
larger declines in the number of banks and larger increases in the 
number of alternative financial services companies compared to higher-
income areas.''
    The COVID-19 crisis has exacerbated the already difficult 
situation. According to an April 2020 report by the Department of 
Health and Human Services, \5\ residents of low-income communities are 
more likely to work in professions at high risk of COVID infection: as 
``essential workers'' in public-facing retail or service sector jobs, 
as nurses, and as first responders. Excess deaths during the pandemic 
surged in low-income communities during the recent pandemic, and in 
particular, rural counties and tribal lands. For example, in Navajo 
County, AZ, more than 15 people out of 1,000 died in 2020, up more than 
40 percent from the annual average of 11 people per 1,000. \6\
---------------------------------------------------------------------------
     \5\ ``The Impact of the First Year of the COVID-19 Pandemic and 
Recession on Families With Low Incomes''. Amanda Benton, Erica Meade, 
and Alec Vandenberg for the Department of Health and Human Services. 
Sep 20, 2021.
     \6\ Amanda Montanez; Source: ``County-Level Estimates of Excess 
Mortality Associated With COVID-19 in the United States'', by Calvin A. 
Ackley, et al. Preprint posted May 5, 2021.
---------------------------------------------------------------------------
    After early pandemic relief funds were gobbled up by large 
companies in higher-income areas, Congress made an effort to ensure 
pandemic relief resources reached difficult to serve communities, and 
CDFIs were part of those successes, as I will discuss in a moment. With 
the Omicron outbreak underway, we must again think critically about how 
we can equitably direct resources to ensure recovery resources reach 
the areas of greatest need. CDFIs can once again play a part.
    About CDFIs and Their Mission CDFIs emerged to help address the 
challenges facing low-income communities and disadvantaged populations 
discussed earlier. They provide financial services in urban 
neighborhoods and rural areas underserved by traditional financial 
institutions, particularly those communities with high rates of poverty 
and unemployment. Certified CDFIs must target at least 60 percent of 
their financial products and services to low-income communities and 
populations.
    The CDFI industry has grown significantly since the advent of the 
CDFI Fund in 1994. Today, the CDFI Fund has certified 1,298 CDFIs 
across the country, providing vital community development lending 
services in all sizes and types of communities. Certified CDFIs include 
565 loan funds, 416 credit unions, 134 depository institution holding 
companies, 167 banks or thrifts, and 16 venture capital funds, located 
in rural and urban areas in all 50 States, the District of Columbia, 
Puerto Rico, and Guam.
    By leveraging over $12 in private capital to every $1 in Federal 
support, CDFIs are filling the critical missing lending gap encountered 
in many communities, creating jobs, improving housing and community 
facilities, building wealth, and creating economic opportunity.
Recent Impact
    The CDFI Fund administers a growing portfolio of programs designed 
to create jobs, build affordable housing, construct and support 
essential community facilities, provide financial counseling, and 
invest in neighborhood revitalization initiatives--all in distressed 
and underserved communities lacking access to traditional lending or 
banking institutions.
    The latest impact data from an independent audit by the Department 
of Treasury highlighted the impact of CDFI Fund programs in 2020.

    CDFI Fund Financial Assistance Award recipients unleashed 
        $39 billion in loans and investments to 125,000 businesses and 
        millions of individuals. They financed 50,000 affordable 
        housing units and thousands of nonprofits and community 
        facilities.

    Healthy Foods Financing award recipients financed 409 
        grocery stores, markets, and fresh food projects totaling over 
        4 million square feet.

    Native Assistance Program recipients helped Native CDFIs 
        originate $1.6 billion in loans and investments to nearly 2,500 
        businesses and tens of thousands of individuals.

    New Markets Tax Credit allocatees made $3.3 billion in 
        loans and investments to hundreds of projects in low-income 
        communities, creating nearly 13,000 permanent full-time jobs 
        and 23,000 construction jobs.

    Over the past 5 years, through 2020, Capital Magnet Fund 
        award recipients helped secure financing commitments for tens 
        of thousands of affordable housing units. Since 2013, the CDFI 
        Bond Program has supported $1.3 billion in affordable financing 
        for community facilities, nonprofits, commercial real estate, 
        and other community development projects.

    CDFI Fund financial assistance helped boost the capacity of 
        hundreds of CDFIs in 2020. The Small-Dollar Loan Program 
        enabled 52 CDFIs to increase their capacity to provide fair and 
        affordable loans in their communities and to help unbanked and 
        underbanked borrowers build their credit. The Economic Mobility 
        Corps, Bank Enterprise Awards, and CDFI Technical Assistance 
        programs all helped boost CDFI capacity to serve low-income 
        communities.

    Fiscal Year (FY) 2021 was the busiest year in the history of the 
CDFI Fund. Altogether, the CDFI Fund provided nearly $1.5 billion in 
monetary awards and loans, including $1.25 billion through the CDFI 
Rapid Response Program and over $180 million in technical and financial 
assistance awards. The Fund also committed to guaranteeing $100 million 
in bonds and allocated $5 billion in New Markets Tax Credits.
CDFIs and Pandemic Relief
    CDFIs played an essential role in helping stabilize and support 
vulnerable communities during the pandemic. America's low-income rural 
and urban communities have borne not just the health consequences but 
also the economic consequences of the pandemic. High unemployment rates 
and small business failure were primarily concentrated in the 
underserved communities where CDFIs work.
    During this unprecedented time in history, CDFIs answered the call 
of marginalized communities and small businesses through participation 
in the Paycheck Protection Program (PPP) and delivering innovative 
financial products and programs to provide loans and investments; 
capacity building; training and technical assistance services; and 
promoting development services efforts that bring credit and capital to 
individuals and communities.
    After the first round of PPP loans went overwhelmingly to 
sophisticated borrowers and well-connected businesses, Congress 
established a set-aside for future rounds for Community Financial 
Institutions (CFIs), which included CDFIs and other mission-based 
lenders. The effort succeeded. Community lenders reached underserved 
businesses with a much greater proportion of their PPP loans than 
conventional banks. According to the SBA, through May of 2021, CDFIs 
made 1.3 million PPP loans totaling over $30 billion or 21 percent of 
total loans. Their average loan size was $21,653 compared to $41,560 
across all lender classes, and nearly 40 percent of their loans reached 
business in low- and moderate-income communities, compared to 28 
percent across all lending sources.
    Additionally, CFI loans reached more small businesses. For example, 
78 percent of their PPP loans went to businesses requesting less than 
$250,000. Moreover, 15.7 percent of CFI-made loans were made to 
businesses in rural communities, closely keeping with the 16.6 percent 
of all loans (some $45.5 billion) that went to rural businesses.
    The 116th Congress made a substantial investment in CDFIs. 
Recognizing the critical role played by CDFIs in rural and urban 
communities across the country, The Consolidated Appropriations Act, 
2021 (P.L. 116-260) provided:

    $1.25 billion for CDFIs to provide technical and financial 
        services to communities and businesses hard hit by the 
        Coronavirus pandemic. In February, the CDFI Fund released the 
        application for the so-called Rapid Response Program (RR), and 
        in June 2021, it awarded grants to 850 certified CDFIs;

    $1.75 billion for CDFIs and Minority Depository 
        Institutions (MDIs) increase lending and investing activity 
        targeted to low-income and minority communities and 
        populations. We hope to see more information from the CDFI Fund 
        on this initiative soon; and

    $9 billion for the Emergency Capital Investment Program 
        (ECIP). ECIP was designed to provide capital to depository 
        institutions that are certified CDFI or MDIs. The Department of 
        the Treasury opened the application process for CDFI's and MDIs 
        in March 2021 and received over 200 applications totaling more 
        than $12 billion in requests. On December 14, Secretary Yellen 
        and Vice President Harris announced the deployment of $8.7 
        billion of direct investments in banks, credit unions, and 
        holding companies that are certified CDFIs or MDIs.

    As the economy slowly improves, the small businesses that survive 
will have a pressing need for the patient capital, particularly working 
capital, to get their businesses back on their feet. CDFIs could have 
done more if they had the capital and if more CDFIs had been approved 
as PPP lenders during the early days of the program and can do more 
going forward.
Looking to the Future
    The recent growth of the CDFI industry presents both opportunities 
and challenges. The Federal Government made an unprecedented investment 
into CDFIs over the past few years with the hope of further scaling the 
industry and expanding its impact. CDFIs' performance during the 
pandemic showed they have the capacity to deliver a high volume of 
financial products and services to communities and people outside the 
economic mainstream. However, Congress--and the CDFI Fund--can do more 
to scale the CDFI movement while ensuring that certified CDFIs maintain 
their role as trusted, mission-driven lenders in underserved 
communities.
Proposals
    $1 billion in annual appropriations for CDFI assistance programs 
through the CDFI Fund: The CDFI Coalition urges Congress to invest more 
in CDFIs by increasing the annual authorization to $1 billion for the 
CDFI Fund. The CDFI Coalition projects the following outcomes from $1 
billion in annual appropriations for the CDFI Fund:

    $12 billion in total investment in low-income communities, 
        over 100,000 affordable housing units created or preserved, 
        thousands of loans and investments in childcare centers, health 
        clinics, and community facilities, nearly two million consumer 
        and home ownership loans, and hundreds of thousands of loans 
        and investments in businesses in target markets.

    Strengthen the Bond Guarantee Program (BGP): Despite the unique 
benefits of the BGP, the program has not realized its full potential. 
Only 26 CDFIs have participated in the bond program and as Qualified 
Issuers, and many CDFIs, particularly smaller organizations, are not 
able to access this valuable source of long-term, fixed-rate financing. 
The CDFI Coalition agrees with CRF, USA's recommendations on 
strengthening the program by (1) reducing the minimum bond issuance 
from $100 million to $25 million and (2) increasing program efficiency 
and consistency by granting the BGP permanent authority.
    Build the administrative capacity of the CDFI Fund: To sustain the 
recent momentum and growth in the CDFI industry, Congress should 
support efforts to build the administrative capacity of the CDFI Fund. 
The previous Administration proposed four consecutive budgets aimed at 
dismantling the Fund. The agency needs more resources to administer a 
growing portfolio of financial assistance awards, bonds, and tax 
credit. The CDFI Fund needs more people and an investment in systems to 
administer its programs and authorities, to say nothing of compliance 
monitoring and providing technical assistance.
    Seek additional CDFI feedback on the certification process: With 
the additional administrative resources, the CDFI Fund can refocus on 
overhauling the certification process. The Fund released its draft 
certification rule for public comment in 2019 but delayed 
implementation of the rule due to the pandemic. The pandemic has 
drastically altered the situation in CDFIs' target markets.
    Since 2019, the CDFI industry has grown significantly in size and 
scope. Before proceeding with the certification rule crafted in 2019, 
the Coalition urges the CDFI Fund to convene stakeholder meetings with 
the CDFI industry. Many CDFIs--including CDFI loan funds--have used 
additional resources to expand their service areas. The certification 
rule proposed in 2019 may make it difficult for many established CDFIs 
to scale and serve more markets. This is particularly the case for 
CDFIs with a multistate footprint.
    The certification rule must also ensure CDFIs maintain their high 
standards for thoughtful lending and investment in their target 
markets. With more resources, the CDFI Fund can continue to monitor the 
performance of the expanding CDFI investment footprint and ensure that 
new entrants to the industry are providing affordable financial 
products and services in underserved communities.
    Update the Community Reinvestment Act: The Community Reinvestment 
Act has been a powerful tool in delivering financial services to 
historically disadvantaged populations. CDFIs rely on CRA to secure 
capital from private financial institutions, a key source of capital. 
Without CRA, today's CDFI industry would be a fraction of its current 
size and the scale of its lending and impact correspondingly reduced. 
Communities count on CDFIs, and CDFIs depend on CRA to secure capital. 
The Coalition was pleased that the Office of the Comptroller of the 
Currency withdrew the final rule for its misguided 2020 CRA overhaul 
earlier this year. We are encouraged by the willingness of the three 
regulatory agencies to work together on a CRA unified framework. While 
CRA has been generally successful, it is in need of an update and a 
tune-up. To meet CRA's requirements, banks invest in affordable 
housing, small businesses, and other community development activities 
that bring historically disadvantaged populations into the economic 
mainstream. However, as the recent pandemic and the protests of the 
summer of 2020 made clear, the legacy of discriminatory red-lining 
lives on in many communities of color where poverty and unemployment 
still outpace the national average and community infrastructure is 
inadequate. With the right data-driven reforms, CRA can be much more 
effective in delivering on its original promise for these communities.
    At a baseline, CRA modernization should result in a net increase in 
both the quantity and quality of financial products and services 
available in LMI areas. The burden is on Federal regulators to show--
with data and evidence--that their reform proposals can meet those 
baseline goals for reform. The Coalition believes a modernized CRA 
framework should meet the following five tests. Reforms should: (1) 
boost the voices and input of community groups in conducting CRA exams 
and developing CRA ratings; (2) generate additional investment in 
traditional community development activities in CRA deserts; (3) 
encourage thoughtful, high-impact investments significant benefits to 
low- to moderate-income (LMI) communities; (4) strengthen 
accountability for financial institutions; and (5) most importantly, 
ensure financial institutions are serving people of color and 
traditionally disadvantaged groups.
Conclusion
    The last Congress made a substantial bet on CDFIs as a conduit for 
delivering relief and revitalization to our hardest-hit communities and 
populations. Thus far, the bet has paid off. The CDFI industry is 
growing, serving more businesses and families, and delivering financial 
services to areas of persistent poverty and unemployment. Providing 
more resources through the CDFI Fund will ensure the continued growth 
of mission-driven financial services.
    Thank you for this opportunity to testify. I would be happy to 
respond to any questions.
                                 ______
                                 
                   PREPARED STATEMENT OF FRANK ALTMAN
    Founder and CEO, Community Reinvestment Fund, USA, Minneapolis, 
                               Minnesota
                            January 5, 2022

[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]


                                 ______
                                 
                   PREPARED STATEMENT OF LAKOTA VOGEL
   Executive Director, Four Bands Community Fund, Eagle Butte, South 
                                 Dakota
                            January 5, 2022
    Thank you Chairwoman Smith, Ranking Member Rounds, and 
distinguished Members of the Subcommittee I am honored to have been 
included as a voice in this important hearing to share the successes 
and challenges of CDFIs serving underestimated communities across the 
Nation.
    My name is Lakota Vogel. I am an enrolled member of the Cheyenne 
River Sioux Tribe, born and raised on a ranch in South Dakota. I am the 
Executive Director of Four Bands Community Fund, a 22 year old rural, 
Native CDFI that started by serving all residents of the Cheyenne River 
Sioux Reservation in north central South Dakota and expanded in 2013 to 
serve native entrepreneurs across the entire State. I am on the 
executive committee of the South Dakota Native Homeownership Coalition 
and a member of the Mountain Plains Regional Native CDFI Coalition.
    I am here today to share the perspective of on the ground leaders 
within the Native CDFI movement, which spans 69 separate organizations 
operating across 27 States. The core of our mission and purpose of our 
programming is aimed at leveling inequities stemming from a historic 
lack of investment and access to capital, as well as noninclusive 
policies, in the communities we serve.
    With two decades of experience, Four Bands has continuously 
improved our products and services to successfully deploy over $25 
million across the State. We utilize an integrated approach in lending 
which fuses relationship building and learning with loan products. Our 
suite of programs are designed to revive traditional culture that 
supports self-sufficiency by focusing on two core areas:

    Entrepreneurship--Four Bands offers a comprehensive 
        business training program, customized business coaching, and 
        several lending products to help entrepreneurs at various 
        stages of development start or expand a business. Our business 
        loans provide up to $250,000 in capital that can be used for 
        equipment and inventory purchases, working capital, acquisition 
        of land or buildings, construction of buildings, and/or 
        leasehold improvements for a commercial space. We also operate 
        a business incubator that provides physical space, in addition 
        to our entrepreneur programming, to six businesses. Our average 
        business loan client is a female head of household who dreams 
        of starting a business in the service industry that doesn't 
        require a lot of start up capital, such as a restaurant, day 
        care or a hair salon. In turn, these industries have a thin 
        profit margin and have more difficulty accessing capital from 
        financial institutions because of their small dollar nature and 
        small balance sheet. Four Bands has deployed over $20 million 
        to the small business sector resulting in the creation/
        expansion of over 300 native owned small businesses and we can 
        proudly say, due to lots of innovation, with partners like CRF, 
        and resource stacking, we did not lose one small business to 
        the pandemic across the State.

    Consumer and Home Ownership--A unique challenge within our 
        communities is invisible credit histories. We are fortunate to 
        have 4 financial institutions serving Cheyenne River, but only 
        1 of them, the Credit Union reports to the Credit Bureaus. So 
        we have generations of borrowers, utilizing debt tools for 
        decades at the local institutions who remain invisible not due 
        to the individual borrowers behaviors but due to institutional 
        decisions. Four Bands began reporting to the credit bureaus in 
        2010. Our foresight and community mindedness, has primed our 
        market for home ownership.

    As our balance sheet grew, we were finally able to offer mortgage 
products to our community in 2019 in partnership with USDA as 1 of the 
2 pilot sites for the 502 Direct Lending program. While we were able to 
close 8 mortgages with initial pilot, we spurred the demand and have 
since closed a total 42 mortgages on Cheyenne River within 1-and-a-half 
years.
    My recommendations today are simple:

  1.  Advance the Native American Rural Homeownership Improvement Act. 
        Thank you to Chairwoman Smith and Ranking Member Rounds for 
        cosponsoring this legislation. The pilot was an enormous 
        success and we've now built up a demand of over $7 million that 
        cannot be met within our community. Access to these funds 
        should include all Native CDFIs across the Nation.

  2.  Increase the Native American CDFI Assistance (NACA) 
        appropriations to $50M to meet the needs. Overall Government 
        spending has increased by 30 percent, and the CDFI Fund 
        appropriations have increased by 13.7 percent, but the annual 
        appropriations for NACA have remained stagnant since 2014 and 
        demand for service is increasing.

    All of this to say, the tool, the Native CDFI tool works, it's just 
chronically undercapitalized. We are part of the communities we serve. 
We run into our clients in the grocery store. We sit on the Daycare 
Board of Directors desperately trying to keep these vital programs 
running. As Native CDFI staff and community members, we are woven into 
the fabric of the community and almost every aspect of our clients 
financial lives. There's no comparison to sitting across from our 
clients at tax time, assessing their earnings for the year and planning 
for the future. We are the gentle nudge to savings accumulation and the 
sounding board for many of the financial decisions our families make. 
We believe ``how you perceive is how you proceed.'' We perceive 
opportunity because our success as Nation builders is intricately woven 
into the success of our neighbor.
    Thank you for this opportunity to testify.

         RESPONSES TO WRITTEN QUESTIONS OF CHAIR SMITH
                    FROM JOHN HOLDSCLAW, IV

Q.1. What steps, if any, should be taken to improve the 
diversity of leaders in the CDFI sector?

A.1. Community development initiatives succeed when 
organizations are representative the communities they serve. 
Congress should continue to support programs and initiatives 
that bolster the capacity of emerging CDFIs, many of which are 
led by people of color. Since FY 2004, the CDFI Fund has 
included a Small and Emerging CDFI (SECA) category as part of 
the FA award. The SECA category provides smaller levels of 
financial assistance to CDFIs with fewer assets or those in 
operation for fewer than three years. CDFIs use SECA awards for 
financing capital, loan loss reserves, capital reserves, 
financial services, or development services. In appropriations 
statutes, Congress typically waives the requirement for SECA 
award recipients to provide a ``match.''
    A 2014 study by the Carsey Institute found that SECA grants 
have been successful in building the organizational capacity of 
new and emerging CDFI loan funds. ``Assets and loans grow, 
earned income grows, as does personnel expense. The CDFI [Fund] 
investment strengthens these organizations and causes growth.'' 
\1\
---------------------------------------------------------------------------
     \1\ ``CDFIs Stepping Into the Breach: An Impact Evaluation'', 
2014, Carsey Institute for Public Policy University of New Hampshire.
---------------------------------------------------------------------------
    In FY 2021, the CDFI Fund made 68 SECA grants for a total 
of $19.9 million. Bolstering and creating permanent funding 
streams through programs like SECA for small and emerging CDFIs 
is one strategy to improve the diversity of leaders within the 
CDFI sector.

Q.2. What do you believe to be the biggest challenge to CDFI 
certification for prospective CDFIs?

A.2. Right now, the biggest challenge is that the CDFI Fund 
needs more staff and resources.
    As I testified, the economic consequences of the COVID-19 
pandemic on low-income communities and populations have been 
severe, and CDFIs have stepped up to provide financial products 
and services in economically distressed communities through the 
Paycheck Protection Program (PPP) and other programs. In the 
Consolidated Appropriations Act of 2020, Congress made a 
historic investment in CDFIs. The combination of continuing 
need to revitalize distressed communities, as well as the 
opportunity afforded by the greater appropriations, has 
increased the interest in the CDFI program and, consequently, 
in CDFI certification. There has been a great increase in the 
number of certified CDFIs. In 2017 there were some 700 
certified CDFIs, and in 2021, there are now more than 1,300.
    Appropriations to support the work of the Fund have not 
kept pace. In 2017, the CDFI Fund had 77 full-time employees 
(FTEs). The number actually fell to 70 in 2020. The budget 
request proposes to fund 89 positions in 2022.
    The CDFI Fund needs more staffing and improved technology 
to handle the growth in certified CDFIs over the last 5 years, 
in addition to the increased demand that has been developed by 
new organizations seeking to become certified CDFIs. The Fund 
needs to invest in an expanded and robust technical assistance 
program to assist existing certified CDFIs in implementing 
programs and to assist new organizations seeking certification 
on the details of certification policy and procedures.

Q.3. How has the CDFI Fund's guidance and technical assistance 
(e.g., webinars, meetings, user guides, etc.) been helpful to 
you? How do you believe the CDFI Fund can improve outreach and 
guidance?

A.3. The CDFI Fund can improve its technical assistance by 
providing on the ground technical assistance aimed at both 
existing organizations as well as those considering CDFI 
certification. Such an effort conducted by CDFI Fund employees, 
qualified technical assistance organizations or both should be 
aimed at program implementation and compliance issues for 
existing CDFIs and training and technical assistance on 
certification and related topics for those organizations 
considering seeking certification.
                                ------                                


               RESPONSES TO WRITTEN QUESTIONS OF
            SENATOR MENENDEZ FROM JOHN HOLDSCLAW, IV

Q.1. The Build Back Better Act currently being debated by 
Congress contains many crucial investments in community 
development. For instance, the House-passed version of the bill 
provides $2.2 billion dollars to eligible institutions, 
including CDFIs, to assist first-time, first-generation 
homebuyers. It also contains $3 billion dollars for these 
institutions for community facilities and other housing and 
civic infrastructure.
    Could you describe what kind of impact these programs could 
have in the communities your institution serves?

A.1. In addition to the $5.2 billion you mentioned, provisions 
within the House-passed Build Back Better (BBB) legislation 
included a substantial investment in Federal housing and 
community development programs totaling $17.5 billion, 
including $925 million at the CDFI Fund to establish the 
Housing Investment Fund, a new program authorization designed 
along the lines of the Capital Magnet Fund. Other programs that 
received substantial investments within the legislation include 
housing vouchers, public housing, HOME, CDBG, and new 
initiatives for community revitalization.
    CDFIs have a strong track record of financing community 
facilities and affordable housing. In 2020, according to data 
from the 2020 Annual Certification report, CDFIs provided 
nearly $6 billion in capital to health care facilities, 
schools, nonprofits, daycare centers, and other community 
facilities. They also provided $38 billion in financing for 
mortgages and home improvement loans.
    CDFI Program award recipients--who represent a mere 
fraction of all CDFI activity, financed nearly 50,000 units of 
affordable housing.
    CDFIs leverage $12 for every dollar in Federal assistance. 
The CDFI Coalition recently projected the impacts for $1 
billion in annual appropriations for the CDFI Fund (our FY 2022 
and FY 2023 request):

    $12 billion in total investment in low-income 
        communities, over 100,000 affordable housing units 
        created or preserved, thousands of loans and 
        investments in childcare centers, health clinics, and 
        community facilities, nearly two million consumer and 
        home ownership loans, and hundreds of thousands of 
        loans and investments in businesses in target markets.
                                ------                                


       RESPONSES TO WRITTEN QUESTIONS OF SENATOR WARNOCK
                    FROM JOHN HOLDSCLAW, IV

Q.1. What do you think we can do to make the process to 
becoming a CDFI more efficient for institutions that are 
qualified and want to become certified to be able to do so?

A.1. As indicated in my responses to Senator Tina Smith's 
questions, the CDFI Fund needs additional staff and resources 
to improve the efficiency of the CDFI Certification Process. On 
January 31, CDFI Fund Director Jodi Harris released a message 
outlining the agency's priorities and ongoing initiatives. 
Included within her message was an acknowledgment that while 
there had been a working agency policy for CDFI applications to 
be processed within 90 days of receipt, the CDFI Fund is now 
unable to keep to that timeline. Reports from applicants 
indicate that current wait times for certification now hovers 
between 6-10 months.
    There are four primary elements needed to help create a 
more efficient certification process. Certainly, increasing 
department staffing to adequately handle the volume and 
complexity of certification applications is in order. 
Additionally, direct case management and business hour access 
to a staff-answered helpline would offer a capacity for prompt 
responses and immediate assistance to certification applicants 
that is currently missing. Working in tandem with that 
approach, increasing investment in application Technical 
Assistance resources and detailed application guidance would 
facilitate greater application efficiency. Ultimately, the 
resources provided should work to ensure that the current 
application backlog decreases, the timeline for certification 
by agency staff gets back to within a 90-day processing window, 
and the CDFI Fund continues to maintain its high standards for 
CDFI certification.

Q.2. Would you please describe your experience working with the 
Paycheck Protection Program? How did your members leverage 
their experience as a CDFI to get the relief out to communities 
you serve?

A.2. When PPP was first enacted, all businesses and financial 
institutions were not treated equally. Large banks and 
businesses with established finance infrastructure were best 
equipped to leverage Federal pandemic resources. The 
communities, financial institutions, and businesses most at 
risk of collapse were the last in line for access to these 
resources.
    According to the SBA's COVID Relief Paycheck Protection 
Program Report (data as of 05/24/2021), Community Financial 
Institutions. \2\ approved 1,389,287 loans for more than $30.08 
billion of PPP funds. The average loan size was $21,653, and 
77.9 percent of these loans went to firms requesting less than 
$150,000 in PPP loans. 39.7 percent of funds went to businesses 
located within low- and moderate-income communities.
---------------------------------------------------------------------------
     \2\ Community Financial Institutions (CFIs) include four types of 
mission lenders--Minority Depository Institutions (MDIs), Small 
Business Administration (SBA) microlenders and Certified Development 
Corporations.
---------------------------------------------------------------------------
    During the disbursement of PPP loans, our members saw a 
record jump in public requests for information about how to 
access CDFIs within local communities. What the experience from 
PPP shows is that with additional resources, CDFIs have the 
capacity to provide a much greater level of financial products 
and services to low-income communities and populations.

Q.3. Have your members been able to utilize the CDFI Rapid 
Response Program, and has the program been effective?

A.3. The money from the Rapid Response Program (RRP) was 
awarded in June 2021. Subsequently, our members are just 
starting to see the results in their communities. The program 
was established to provide the necessary capital for CDFIs to 
respond to economic challenges created by the COVID-19 
pandemic, particularly in underserved communities, and those 
challenges remain to this day.
    Overall, 863 CDFIs were awarded $1.25 billion in RRP funds 
for distribution. The legislation directed at least $25 million 
to be awarded to benefit Native Communities. When the awards 
were released, the award recipients included 58 organizations 
that committed to direct their awards to investments in Native 
American, Native Alaskan, and Native Hawaiian communities; they 
received a total of $54.6 million in awards. In addition, 28 
organizations that primarily serve Puerto Rico received $47.3 
million in awards, and 90 minority depository institutions 
received a total of $133.9 million in awards.
    In terms of meeting the needs of small towns and rural 
America, 277 CDFIs serving small urban areas received $414 
million in awards, and 245 CDFIs serving rural users received 
$353 million in RRP awards.
    Given the high demand and general scramble to access 
initial pandemic-relief funds, such as Paycheck Protection 
Program loans, the ability to separately access additional 
pandemic-relief RRP funds has been beneficial for our member 
CDFIS. Given the effects of the Delta and Omicron variant waves 
in prolonging business recovery efforts from COVID-19, the 
availability of the RRP funds is extremely helpful for 
vulnerable businesses still attempting to manage the economic 
fallouts from the pandemic.

Q.4. The Build Back Better Act as passed by the House includes 
a new Community Restoration and Revitalization Fund (CRRF) 
program at the Department of Housing and Urban Development. I 
strongly support the CRRF proposal to advance place-based 
policies that could be scaled significantly such as those led 
by Purpose Built Communities, a national nonprofit founded in 
Atlanta, Georgia, after the successful revitalization of the 
East Lake neighborhood. Would you please speak to the potential 
impact of a program such as the CRRF to support community led 
development projects? Would you elaborate on the importance of 
including local community stakeholder in these development 
projects, and why strategies should be place-based?

A.4. Last fall, the CDFI Coalition joined with a coalition of 
Main Street advocates, parks and public space organizations, 
affordable housing developers and stakeholders, and other 
mission-based entities to support the creation of the Community 
Restoration and Revitalization Fund (CRRF) at HUD. 
Congressional support for investments in ``community-led 
redevelopment projects in distressed communities'' as part of 
the Build Back Better Framework reflects a critically important 
recognition that neighborhoods need a holistic ecosystem of 
resources to thrive.
    As community partners who have worked with urban, suburban, 
and rural communities for decades, we are aligned behind a 
common belief that robust civic infrastructure is essential to 
creating neighborhoods where people want to live, work, and 
play, as civic infrastructure are the places that boost our 
economy, increase our economic and environmental resiliency, 
support our health and well-being, and strengthen our 
democracy.
    The specific projects may vary between neighborhoods, but 
across the country, we see immense value in the community 
assets that serve as the connective tissue between people and 
places, particularly when they are located near housing that is 
affordable to households across the income scale.
    However, we have also worked for decades with communities 
that have received neither adequate nor equitable investment in 
this critical infrastructure. In these neighborhoods, 
segregation and concentrated poverty continue to entrench 
cycles of disadvantage that are proven to disproportionately 
impact Black, Latino, and other communities of color.

Q.5. Would you speak to strategies to target Federal 
investments to catalyze and accelerate holistic community 
revitalization, beyond just putting roofs over folks head? How 
can we leverage Federal dollars to ensure access to quality 
education, safe and affordable housing, as well as access to 
health care?

A.5. There are a variety of very effective Federal programs 
that provide discrete funding for specific activities. 
Community development tax credits support the construction of 
affordable housing, bond programs support new school 
construction, and grant programs support new and improved 
federally qualified health centers, to name a few examples. All 
of these initiatives can (and do) benefit from the 
participation of CDFIs.
    As flexible, mission-driven, community-based financial 
institutions, CDFIs are attuned and responsive to a broad range 
of community needs. They have a track record of mobilizing $12 
in capital for every dollar of Federal support and putting 
those resources to work in support of affordable housing, small 
business loans, and the improvement of social services. To 
ensure community development programs meet the needs of 
distressed and underserved communities, we urge Congress to 
consider set-asides for CDFIs when crafting new initiatives. 
The CFI (and CDFI) set-asides in PPP helped deliver more 
support to the hardest-hit communities. Recent legislation in 
the House to expand access to childcare and early childhood 
education would set aside as much as 15 percent for CDFIs to 
serve as intermediaries and technical assistance providers, and 
several States have set aside funding through the CARES Act and 
ARPA for CDFIs for this purpose. \3\
---------------------------------------------------------------------------
     \3\ ``Capitalizing on the Capabilities of Child Care Resource and 
Referral Agencies and Community Development Financial Institutions To 
Stabilize and Increase the Supply of High-Quality Child Care''. https:/
/info.childcareaware.org/hubfs/2021-CCRR%20and%20CDFI%20
Intermediaries%20PaperFINAL-1.pdf
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                                ------                                


         RESPONSES TO WRITTEN QUESTIONS OF CHAIR SMITH
                       FROM FRANK ALTMAN

Q.1. Please describe the role of a qualified issuer in the CDFI 
Bond Guarantee program. How does a qualified issuer interact 
with other CDFIs? What role do they play in facilitating 
financing?

A.1. The Qualified Issuer (QI) has a multifaceted role in the 
CDFI Bond Guarantee program (BGP). In the initial stage when a 
CDFI(s) is looking for resources, the QI serves as the 
ambassador for the BGP, explaining and educating prospective 
participants about the program, the nature of the capital 
available, eligibility, as well as how and when the funds must 
be deployed.
    If the CDFI is deemed to be a ``good fit'' for the program, 
the QI transitions to serving as a ``mission-driven advisor 
providing technical compliance and structuring services.'' In 
this stage, the QI assists certified CDFIs in their effort to 
access the BGP which provides fixed-rate, 30 year fully 
amortizing debt provided by the Federal Financing Bank--the 
sole investor in bonds issued through this program. As a 
``mission-driven'' advisor providing technical compliance and 
structuring services, the QI assesses the creditworthiness of 
the eligible CDFI to confirm its ability and willingness to 
repay the bond obligation. As part of this process, the QI will 
evaluate the lending, disbursing, servicing, and monitoring 
capabilities of the CDFI. The QI will then prepare and submit a 
guarantee application to the CDFI Fund on behalf of the 
eligible CDFI. It will also prepare and submit a term sheet. 
During this period, the QI facilitates an ongoing review, 
presentation, and negotiation of terms with the bondholder 
(Federal Financing Bank) and the Guarantor (Treasury Department 
as represented by the CDFI Fund program staff). Assuming the 
guarantee application is approved, the QI is listed as the 
lender of record and issues the bond. Throughout this process, 
the QI is providing technical assistance to the eligible 
CDFI(s) on how to best leverage the bond funds to support its 
lending activities most effectively. This involves actively 
engaging with and listening to the eligible CDFI(s) to design 
and develop financial structures that meet the credit needs of 
the borrowing CDFI(s).
    Once the bond has been issued, the QI takes on the role of 
``program administrator'' managing, monitoring, and guiding the 
CDFI(s) as they utilize the Bond Loan funds. Servicing 
oversight is a key function performed by the QI staff 
facilitating draw-downs on Bond Loan funds for the 
participating CDFI(s). They also offer technical assistance 
with respect to pricing strategy and optional redemption of 
Bond Loan funds. As program administrator, the QI provides 
oversight and guidance to the CDFI participant(s) assisting 
with compliance, reporting, receiving, and reviewing each 
Secondary Loan Certification. The QI is responsible for 
enforcing the terms and requirements of the Bond Trust 
Indenture and Bond Loan Agreement as well as the Agreement to 
Guarantee. Collateral and credit enhancements are reviewed by 
the QI staff on an ongoing basis. Agency administrative fees 
are paid by the QI pursuant to a predefined payment plan. The 
QI also submits all required reports and additional 
documentation as requested by the CDFI Fund in a commercially 
reasonable fashion.
    In summary, the QI is responsible for sourcing, 
structuring, evaluating, and closing of Bond Loans with 
eligible CDFIs. Through the sales process, the QI assesses the 
capacity of the eligible CDFI(s) to lend and key capabilities 
required to meet the standards and expectations associated with 
a Federal credit program. Each QI maintains a robust front-end 
process to source, review, approve, and negotiate terms for a 
wide variety of CDFIs seeking to access the Bond program. The 
QI also provides ongoing support on technical matters such as 
strategies for accessing the debt, structuring, and utilizing 
program funds, and troubleshooting issues that arise over the 
term of the bond. Thus the QI's role is to build the capacity 
of eligible CDFIs to use the Bond Loan funds most effectively 
to support their financing activities in underserved 
communities.

Q.2. Please describe how the Bond Guarantee program has been 
used for childcare facilities.

A.2. The Bond Guarantee program has been used to support 
childcare facilities. According to the Office of the Inspector 
General, Department of the Treasury, Audit of the Community 
Development Financial Institutions Fund's Financial Statements 
for Fiscal Years 2021 and 2020, December 15, 2021, $13 million 
has been disbursed since inception of the Bond Guarantee 
program for childcare facilities with another $30 million in 
proposed disbursements. One organization on whose behalf CRF 
has issued guaranteed bonds is the Low Income Investment Fund 
(LIIF), a preeminent CDFI. LIIF provided the following examples 
of how they have used bond guarantee resources to finance 
childcare facilities.
    The Low Income Investment Fund (LIIF), a national nonprofit 
CDFI loan fund and a leading CDFI in the early care and 
education finance space, has used BGP for three childcare 
facilities since 2016. Each of these projects reflects a unique 
and flexible use of the program, including helping childcare 
providers purchase the facility they previously rented and 
helping a developer finance a mixed-use development in which a 
childcare provider was a tenant.

    Mission Child Care Consortium, Inc. (San Francisco, 
        CA). Mission Child Care Consortium, Inc. (MCCCI) has 
        provided subsidized childcare in San Francisco for over 
        35 years. In 2017, LIIF provided a $3.5 million loan to 
        purchase the building that MCCCI had been leasing since 
        1985. The purchase price (and appraisal) was $5.6 
        million, and the remaining balance was covered by a 
        combination of grants and cash equity. This allowed 
        MCCCI to replace their $312,000 annual lease with a 
        $267,000 annual mortgage payment, alleviating some 
        financial pressure on the organization. MCCCI intended 
        to raise funds over the 10-year term of the loan to 
        make periodic unscheduled principal reductions to the 
        outstanding balance to be refinanced at maturity. They 
        have now reduced the principal balance to $2.4 million.

    St. Nicks Alliance/Small Steps Daycare (East 
        Williamsburg, Brooklyn, NY). LIIF provided $13.5 
        million in total financing to help preserve a community 
        facility in East Williamsburg, Brooklyn that had been a 
        staple of the community for over 40 years, providing 
        both childcare and a senior center to low-income 
        residents. In 2013, a new owner purchased the property 
        with the intent of evicting the center operator and 
        redeveloping the site as luxury condominiums, even 
        going as far as serving the center staff with a 30-day 
        eviction notice on Christmas Eve. After a lengthy legal 
        and PR battle, armed with support from the community 
        and local elected officials, SNA succeeded in securing 
        an agreement to purchase the property directly from the 
        owner. LIIF provided a $7.47 million acquisition loan 
        to SNA Ainslie LLC, an affiliate of St. Nick's Alliance 
        (SNA), to help bridge grant funding that local elected 
        officials had designated for the project. LIIF then 
        provided $4 million in permanent financing for the 
        project in the form of a 25-year loan through BGP. LIIF 
        was able to make this BGP loan because it is a program 
        of a strong multiservice nonprofit with the balance 
        sheet to support the long-term debt service obligations 
        even though the childcare center may encounter 
        volatility in its operating revenues over the years.

    Cooper Gardens-Tender Tots Child Care (Bronx, NY). 
        LIIF provided $9 million loan to L&M Development 
        Partners, Inc., to finance the multitenant commercial 
        component of a mixed use affordable housing property in 
        which one of the tenants was a childcare center. The 
        commercial component of the project was too large to be 
        included within the housing financing, so BGP was a 
        good option that helped the developer secure the 
        construction financing. The developer had the strength 
        and wherewithal to carry the project to completion, 
        which took several years. LIIF's BGP loan provided 
        long-term predictability to the developer at a 
        competitive rate, which will help keep rents to the 
        commercial tenants--including the childcare center--for 
        many years.

    In addition to using BGP for childcare facilities, LIIF 
completed a $10 million New Markets Tax Credit (NMTC) structure 
in partnership with the City of San Francisco's Office of Early 
Care and Education to enable financing for multiple childcare 
centers. Mission Neighborhood Center (MNC) leased a commercial 
space in a new construction building (which included three 
commercial spaces and 157 units of affordable housing) and 
needed financing to build out the 8,150 square foot space. The 
combination of grant funding and $2.44 million in NMTC subsidy 
brought the interest rate down to 1.28 percent with annual debt 
service of $30,000. Although not applicable to this project, a 
potential use of BGP for other childcare facilities financed 
using NMTC would be converting the NMTC financing to permanent 
financing through BGP, thereby allowing the provider to access 
long-term, low-cost, fixed-rate financing at the end of the 7-
year NMTC period.

Q.3. What effects would the CDFI Bond Guarantee Program 
Improvement Act have on the program and on CDFIs' ability to 
raise capital? How would it impact childcare facilities?

A.3. CRF believes the CDFI Fund Bond Guarantee Program 
Improvement Act would expand the ability of CDFIs to raise 
capital and to provide additional support for childcare 
facilities. LIIF, a CDFI on whose behalf CRF has issued Bond 
funds provided the response below.
    The CDFI Bond Guarantee Program Improvement Act would have 
a positive impact on the program and would increase CDFIs' 
ability to direct BGP resources to childcare facilities. First, 
permanently authorizing BGP will provide much-needed certainty 
and clarity about the program's ongoing ability to serve as a 
reliable resource to CDFIs and our borrowers. Certainty and 
reliability are critical ingredients to successful financing 
across all asset classes, including childcare, and can motivate 
further innovation. Second, reducing the minimum loan size to 
$25 million will also help increase smaller CDFIs' access to 
the program, many of whom likely have existing relationships 
with local childcare providers who could benefit from BGP 
financing.
    While the CDFI Bond Guarantee Program Improvement Act would 
have a positive impact on CDFIs working to finance childcare 
facilities, the most urgent and critically needed form of 
assistance for childcare facilities is additional grant 
capital. The childcare business model itself is economically 
tenuous. Even with childcare costs already out of reach for 
most households, staffing demands, nontraditional hours, and 
other unique expenses required to care for young children means 
that it costs more to operate a childcare program than most 
tuition payments can cover. The childcare sector overall has 
been historically underfunded, so what little operating 
subsidies that are available to childcare providers often help 
them simply break even.
    There is also no dedicated source of Federal funding to 
acquire, construct and renovate childcare facilities, meaning 
that providers must be incredibly innovative in finding 
flexible sources of affordable capital to meet their facility's 
needs. Most childcare providers are unable to access 
traditional financing sources to cover costly acquisition, 
renovation, or construction costs associated with improving 
their facility or opening and expanding into a new space. Many 
CDFIs, including LIIF, have been working for decades to cobble 
together various resources from State and local governments, 
philanthropy, and private sources to help providers meet their 
facility needs. Given the challenging economics in the 
industry, the vast majority of providers are unable to 
accommodate or sustain debt financing, and instead rely on 
grant capital and other forms of forgivable loans.
    The National Children's Facilities Network (NCFN), which 
LIIF cochairs, is a Network of more than 60 CDFIs, financial 
and technical assistance intermediaries, and other childcare 
stakeholders focused on elevating the importance of high-
quality childcare facilities and strong business models. NCFN 
strongly supports Federal funding to establish a dedicated 
source of capital to acquire, construct and renovate childcare 
facilities, with a set-aside of resources for CDFIs and other 
intermediaries to offer critical technical assistance and 
capacity building support. This model has been proposed in 
Assistant Speaker Katherine Clark's Child Care is 
Infrastructure Act (H.R. 1911), as well as included in an early 
version of the House Ways and Means Committee's Build Back 
Better Act.

Q.4. Why do you believe that secondary markets are needed for 
CDFI small business lending?

A.4. When I cofounded Community Reinvestment Fund, USA (CRF) in 
1988, there were scores of community-based revolving loan funds 
(RLFs) in cities, neighborhoods and small towns throughout 
Minnesota that were lending money for business and economic 
development from a variety of funds. All of these RLFs relied 
on repayments from borrowers to recapitalize their funds for 
future lending. The slow rate at which these RLFs received cash 
repayments often caused them to run out of cash sufficient to 
make more loans. Very few of these RLFs were capable of raising 
cash by borrowing, so they were unable to respond to local 
needs in a reliable and consistent manner. CRF was created to 
provide liquidity to RLFs (precursors to CDFIs) and public 
economic development agencies by allowing them to sell their 
loans and use the cash to make new loans. This secondary market 
greatly increased the velocity of dollars in the RLFs and 
reduced their need to seek government or philanthropic grants. 
CRF served as an aggregator of loans from local RLFs and 
ultimately transformed the loan pool into investable securities 
through the process of asset securitization.
    Secondary markets would be extremely helpful for CDFI small 
business lenders because they will provide liquidity through 
the purchase of loan assets, thereby alleviating the lending 
constraints imposed by the size of their balance sheets. An 
active secondary market will enable CDFIs to significantly 
expand their lending volumes without overleveraging their 
balance sheets. And it will provide safe, responsible lending 
products for small businesses. Having a secondary market would 
therefore allow CDFIs to free up space on their balance sheet 
when they reach a point where they need to raise additional 
equity to maintain a prudent leverage ratio (equity as a 
percent of assets).
    Two critical infrastructure components are needed to do 
this at scale: First, CDFIs need access to a large-scale and 
liquid secondary market where they can sell their loans on an 
ongoing basis. The secondary market for the guaranteed portion 
of SBA 7(a) loans offers a good example of an effective 
secondary market for small business loans. Second, secondary 
market intermediaries need access to warehouse facilities to 
enable them to aggregate loans for securitization. The larger 
the pool of aggregated loans, the lower the risk to investors 
through asset diversification. Larger pools are also more cost 
efficient and ultimately deliver better pricing to CDFIs.
    Periods of financial stress, such as the Great Recession 
and the COVID-19 pandemic, demonstrated the critical role CDFIs 
played providing a lifeline to struggling small and BIPOC-owned 
businesses that did not have an existing relationship with a 
commercial bank by offering Paycheck Protection Program (PPP) 
and other types of relief loans. They soon exhausted their 
existing lending capital and would not have been able to make 
more PPP loans without the Federal Reserve System's Paycheck 
Protection Program Liquidity Facility (PPPLF) which extended 
credit to eligible financial institutions (including CDFIs) 
taking the loans as collateral at face value. While the PPPLF 
was a secured financing vehicle rather than an asset-purchase 
vehicle, it showed that the Federal Reserve could play a direct 
role in supporting CDFI liquidity needs to continue lending 
during the crisis.
    The lessons of the PPPLF provide policymakers with a road 
map of how to help CDFIs increase their impact and reach 
underserved BIPOC, rural and Tribal communities. Specifically, 
policies that foster the development of secondary markets for 
small business loans, as well as other types of CDFI loans, are 
an essential component of a well-functioning financial system 
that incorporates liquidity mechanisms to support the smooth 
flow of credit to customers by providing an outlet for these 
assets. Furthermore, funding facilities offering a ready source 
of cash, like a discount window for CDFIs, would ensure these 
institutions have the financial resources to expand their 
lending to meet the credit needs of their clients. Both the 
ability to sell assets through secondary markets and accessing 
cash through funding facilities are vital if CDFIs are to reach 
scale and deliver meaningful impact. CRF is encouraged by the 
Senate Banking Subcommittee's interest in exploring how to 
promote the development of secondary markets for CDFI loans and 
welcomes the opportunity to offer additional input on potential 
legislative proposals.

Q.5. Please describe the current state of the secondary market 
for, and securitization of, CDFI loans.

A.5. At present, there is no formal or established secondary 
market for and/or securitization of CDFI loans. The Riegle 
Community Development and Regulatory Improvement Act of 1994 
(P.L. 103-325; Sept. 23, 1994), which authorized the CDFI Fund 
and its programs, envisioned a role for secondary markets to 
provide liquidity for CDFI lenders and their loans. Section 113 
(12 U.S.C. 4712) authorizes the CDFI Fund to ``provide 
assistance for the purpose of providing capital to 
organizations to purchase loans or otherwise enhance the 
liquidity of community development financial institutions'' if 
such organizations meet specific requirements. However, 
Congress never appropriated funding for Section 113 (12 U.S.C. 
4712) and therefore, it has never been implemented. This 
section needs to be modernized or updated to provide a platform 
for piloting the CDFI Fund's role in stimulating secondary 
markets for CDFI loans.
    Prior to the Great Recession, CRF's business model was to 
operate a secondary market for community development loans. We 
aggregated these loans on our balance sheet using a warehouse 
line of credit provided by a bank. Once we had purchased a 
predetermined volume of loans, we issued asset-backed 
securities collateralized by these community development loans. 
However, due to changes in the market, we have not engaged in 
this activity since that time. As noted above, there is a well-
developed secondary market for government guaranteed SBA 7(a) 
loans that is available to CDFIs on a limited basis. As one of 
three CDFIs operating a Small Business Lending Company, CRF 
offers the regular SBA 7(a) loan product and frequently sells 
the guaranteed portion of these loans into the secondary 
market. More than 100 CDFIs are approved to participate in the 
SBA's Community Advantage (CA) Pilot Program which offers a 
scaled-down version of the 7(a) product capped at $250,000 and 
with more flexible pricing. Some, but not all, CA lenders are 
approved to sell the guaranteed portion of their loans into the 
secondary market. While the CA loan product is a useful tool, 
it is a pilot program that has not been made permanent at this 
time.
    While CDFI loans are not currently widely securitized, \1\ 
there are one-off securitizations of these assets, such as the 
recent $297 million offering by The Change Company, which was 
collateralized by residential loans originated by this CDFI. In 
the absence of a formal secondary market for CDFI loans, assets 
most likely to be securitized are those that exhibit a high 
degree of standardization, a common set of underwriting 
criteria and a well-established track record of being 
securitized, such as residential mortgages. Small business 
loans, on the other hand, do not typically share a common set 
of underwriting criteria, especially those originated by CDFIs, 
making them more difficult to securitize.
---------------------------------------------------------------------------
     \1\ Wikipedia defines Securitization as the financial practice of 
pooling various types of contractual debt such as residential 
mortgages, commercial mortgages, auto loans or credit card debt 
obligations (or other nondebt assets which generate receivables) and 
selling their related cash flows to third party investors as 
securities, which may be described as bonds, pass-through securities, 
or collateralized debt obligations (CDOs). Investors are repaid from 
the principal and interest cash flows collected from the underlying 
debt and redistributed through the capital structure of the new 
financing. Securities backed by mortgage receivables are called 
mortgage-backed securities (MBS), while those backed by other types of 
receivables are asset-backed securities (ABS).
---------------------------------------------------------------------------
    In response to the pandemic, CRF in collaboration with 
other CDFIs developed and administered a series of Recovery 
Funds using limited liability companies (LLCs) and off-balance 
sheet structures such as Special Purpose Vehicles (SPVs) to 
purchase loans from CDFIs that make small-balance business 
emergency loans. Over the last 24 months, these Recovery Funds 
have deployed $250 million and have purchased over 5,000 loans 
from CDFIs with an average loan size between $40,000 to 
$70,000. Providing these smaller loans is a specialty for many 
CDFIs who reach smaller businesses owned by socially and 
economically disadvantaged persons or businesses located in 
low-to-moderate income communities.
    CRF and its partners established Recovery Funds in New 
York, Chicago, Washington, and California with a first-loss 
loss reserve of State and/or local funds. CRF helped establish 
a similar regional Recovery Fund covering 13 southeastern 
States with a privately funded loan loss reserve. We recently 
launched a similar fund in Minnesota which has credit 
enhancement from private funders. The off-balance sheet pooled 
loan structures serve the same purpose as a secondary market 
for CDFI lenders. CDFIs originating loans can sell up to 95 
percent of qualifying small-balance loans to the pooled vehicle 
thereby obtaining funds to continue making more loans.
    These pooled vehicles are the first step toward 
securitization and are critical because they free up space on 
CDFIs' balance sheets, thereby allowing the CDFIs to engage in 
additional lending. They have also been instrumental in 
introducing CDFIs to the practice of originating a standard 
loan product that can be purchased by the SPV and which 
provides improved liquidity. The next step is to take the 
pooled loan fund and use its assets to issue securities backed 
by the business loan cash flows and sell them to investors. Our 
research suggests that between $200-$250 million is the volume 
of loans needed to make a securitized transaction economically 
feasible so we have demonstrated that these pooled loan 
structures can reach the required scale.

Q.6. What reforms do you believe should be made to the market 
for CDFI loans, what impacts would they have, and what role 
should Congress play in reforms?

A.6. Through CRF's role in several Recovery Funds, including 
the Chicago Resiliency Fund, the California Rebuilding Fund, 
the New York Forward Fund, Southern Opportunity and Resilience 
Fund (SOAR), the Washington Flex Fund and the Minnesota 
Inclusive Growth Fund, that utilize an SPV structure, we have 
found that several aspects of this structure have laid the 
groundwork for providing a source of liquidity for CDFIs and 
paving the way to securitize small business loans. For example, 
the following criteria have made these Recovery Funds 
successful: (1) a standardized loan product with common 
eligibility criteria and terms; (2) a reasonable risk retention 
requirement mandating CDFI retain a portion of the loans they 
sell to the SPV; (3) the ability of the CDFIs to service or 
sub-service the loans they sell (i.e., retain servicing 
rights); (4) a common technology platform that matches small 
business borrowers with CDFIs offering appropriate loan or 
credit products; (5) a fund structure that brings private 
sector capital from impact lenders to support the purchase/
acquisition of CDFI loans (or portions thereof); (6) access to 
coordinated, well-resourced business advisory services; (7) and 
a robust marketing strategy.
    SPV structures, like the Recovery Funds, using Federal 
resources (such as those authorized in Section 113 of the 
Riegle Community Development and Regulatory Improvement Act of 
1994) in a subordinate position to private capital (at the 
bottom of the capital stack), enables a scalable approach to 
aggregating and securitizing small business loans. However, we 
recommend a number of changes or modifications to Section 113 
[12 U.S.C. 4712] including (but not limited to): (1) include 
language to explicitly allow capital assistance to be used to 
raise resources to purchase loans from CDFIs; (2) reduce or 
eliminate the match requirement given magnitude of capital 
assistance awards; (3) eliminate the limitation on other 
assistance a capital assistance awardee may receive from the 
CDFI Fund; (4) reiterate that a capital assistance awardee need 
not be a CDFI; (5) increase the amount of capital assistance to 
at least $20 million per awardee; (6) provide exemptions from 
relevant Federal securities registration requirements (e.g., 
Securities Act, Investment Company Act, and Investment Advisor 
Acts), the taxable mortgage pool rule when securitizing CDFI 
mortgages, as well as risk retention rules when securitizing 
loans originated by CDFIs (or provide alternative way to meet 
the risk retention requirement). Minimum requirements for 
organizations seeking capital assistance as well as selection 
criteria should also be reviewed and modified as needed for 
this unique role and scale of activity. Finally, there are 
accounting and tax rule changes regarding consolidation and tax 
exemption that present challenges to the securitization of CDFI 
loans that would need to be addressed but may be beyond the 
scope of Congress and a legislative solution.
    In addition, modifications to the Treasury Department's 
guidance for the SSBCI program in which CDFIs will play an 
important role could stimulate the development of secondary 
markets and securitization structures for CDFI loans. The SSBCI 
program offers a unique opportunity to utilize pooled loan 
structures to provide liquidity for CDFIs. Under Treasury 
policy guidance, an entity such as a CDFI must bear 20 percent 
or more of the risk of loss in any loan transaction and may not 
pool the risk of loss with other loans. The SSBCI rules require 
the losses on each loan backed by SSBCI funds to be reconciled 
and administered individually. (U.S. Department of the Treasury 
State Small Business Credit Initiative Frequently Asked 
Questions, p.3) A lender can economically administer the 
calculation of loan losses transaction-by-transaction when the 
lender is making relatively few loans of a significant size. 
However, this requirement is costly for a loan portfolio 
consisting of many small-balance loans which is precisely the 
case for CRF's Recovery Funds. Treasury's rule raises the 
administrative cost of operating a pooled loan fund, which is 
the key to the success of these Recovery Funds. Furthermore, 
Treasury's SSBCI requirements prevent CDFIs from using SSBCI 
dollars as first-loss capital at the bottom of the capital 
stack unless these funds are pari passu or matched on a one-to-
one basis with private sector capital. As noted above, the SPV 
model can also advance the securitization of CDFI small 
business loans by aggregating loans until a reasonable volume 
has been acquired and they can be packaged into asset-backed 
securities. Modifications to Treasury's guidance could 
significantly improve the SPV model for both CDFIs originating 
and selling loans into this aggregation structure and for the 
eventual securitization of these assets. We hope such changes 
will be implemented.
    In terms of impacts, creating an ongoing source of 
liquidity through an SPV structure or something akin to the 
Paycheck Protection Program Liquidity Facility (PPPLF) at the 
Federal Reserve would allow CDFIs to significantly increase 
their lending activities by allowing them to pledge their loans 
and receive cash to continue to lend. However, CDFIs remain 
constrained by their balance sheets as they must raise 
additional equity to meet funders' requirements and protect 
against risk of loss associated with the loans on their balance 
sheets. Secondary markets using securitization of these loans 
provide CDFIs with a solution to both their balance sheet 
constraints and their need for liquidity without having to 
raise additional equity in a short time period.
    This would allow for more capital and credit to flow to 
small businesses especially, BIPOC-owned small businesses as 
well as those in low-income communities, rural areas, and 
Indian Country. Securitization of these loans would be the 
final step in reaching the capital markets where institutional 
and impact investors could invest in securities backed by these 
loans.
    Congress has a significant role to play in advancing 
policies that facilitate the development of secondary markets 
for CDFI small business and other loans, by providing resources 
to support research and innovation, removing legislative 
obstacles to aggregating and securitizing these assets, and 
convening experts to further this effort. Congress should also 
consider support for resources that build the capacity of CDFIs 
including, but not limited to, funding for the evaluation and 
adoption of technology that increases organizational efficiency 
and customer experience, and development of common platforms 
and tools that are accessible to all CDFIs. Finally, data 
collection and reporting remain a key challenge for CDFIs and 
impedes the ability to securitize CDFI loans. More and better 
data on CDFI loans would help rating agencies and investors 
better evaluate the true risk associated with these loans.

Q.7. What are the technology needs of CDFIs, and should 
Congress consider supporting technology investments?

A.7. CDFIs have significant technology needs to bring 
efficiency and scale to their operations. For example, CDFI 
small business lenders are looking for technology to assist 
them with customer acquisition, loan origination, loan 
servicing and portfolio monitoring, among other needs. CDFIs 
need assistance in evaluating, adopting, and on-boarding new 
technology systems. As an industry, CDFIs could reduce the 
costs of technology systems by agreeing to standardize their 
products and processes through a coordinated approach. CDFIs 
also need resources to invest more in software development and 
staff with the requisite technology skills. Could Federal funds 
be used to support a centralized technology/innovation hub that 
attracts the talent to build tools that all CDFIs can access? 
Relying on individual CDFIs to do this on their own impedes the 
industry's ability to scale and creates redundancy for small 
organizations that have limited R&D budgets.
    Congress should provide funding for CDFIs to adopt and/or 
upgrade their technology systems. It is incredibly hard for 
CDFIs to raise grant funds for infrastructure investments, yet 
funders are willing to provide more capital for loans. If CDFIs 
could implement efficient technology systems, they would be 
able to lend capital to their customers and communities more 
effectively and compete with online or fintech lenders who may 
offer predatory or abusive loan products.
    CRF has developed two technology solutions or platforms to 
ensure that small businesses are able to access safe, 
appropriate credit products and that CDFIs have the tools they 
need to serve their small business customers. Our 
Connect2Capital platform (C2C) is a marketplace where small 
business owners can be matched with credit products offered by 
CDFIs and similar responsible, mission-driven lenders that meet 
their needs. As of January 2022, $250 million in loans funded 
by CRF's partners has been facilitated by C2C, 74 percent of 
C2C loans have gone to businesses owned by Black Indigenous and 
other People of Color, women, members of the LGBTQ+ community, 
and/or Veterans. We also developed a software solution, known 
as SPARK, which provides a streamlined, seamless process to 
originate small business loans. Not only does SPARK allow 
lenders to quickly originate SBA and other business loans, but 
it also offers a user-friendly customer experience meeting 
businesses where they are. Increasingly, entrepreneurs are 
seeking loans online, and CDFIs must be able to offer them a 
competitive product and process that they can access over the 
internet or through a mobile device.
    When the CDFI Fund was established, the framers did not 
envision the technology needs of CDFIs in the future. We 
strongly believe Congress should support funding for 
technology.
    Furthermore, CDFIs (like CRF) that provide technology 
resources, such as C2C and SPARK, should be permitted to count 
these platforms as Development Services, a requirement for CDFI 
certification and which the Fund defines as `` . . . activities 
that promote community development and are integral to the 
Applicant's provision of Financial Products and Financial 
Services. Such services shall prepare or assist current or 
potential borrowers or investees to utilize the Financial 
Products or Financial Services of the Applicant.'' (CDFI Fund, 
Department of the Treasury, Revised Interim Rule, Federal 
Register, December 13, 2005, link) Including technology 
resources and platforms as Development Services would allow the 
Congress to fund these activities and enhance the ability of 
CDFIs to meet their primary mission of community development 
and significantly scale of their impact. CDFIs should be 
encouraged to innovate and build the robust ecosystem in which 
they conduct their lending activities. Technology tools 
exemplify the kind of innovation Congress should be fostering.

Q.8. What steps, if any, should be taken to improve the 
diversity of leaders in the CDFI sector?

A.8. CDFI leaders must reflect the communities and people they 
serve. Therefore, intentional efforts must be made to recruit 
BIPOC leaders as well as BIPOC staff at all levels of CDFI 
organizations. There is a transition taking place among leaders 
who created CDFIs 25 years ago and this provides a valuable 
opportunity to bring more diverse leadership to our industry.
    At CRF, we have taken specific steps to diversify our 
senior leadership and our staff with the opportunity for 
succession. Our board is majority minority, and this model of 
diversification will be replicated across all levels of the 
organization. We believe this approach will help bring more 
diverse leaders to the top of the organization. With a 
substantial number of CDFI loan fund founders moving on, we 
expect to see more BIPOC leaders at the helm of these 
organizations and sitting on their boards. The recent $9 
billion under the Emergency Capital Investment Program (ECIP) 
will strengthen the balance sheets of CDFI depository 
institutions and further enhance diverse leadership and lending 
in sector.

Q.9. What do you believe to be the biggest challenge to CDFI 
certification for prospective CDFIs?

A.9. As detailed in our written testimony, there are several 
challenges to CDFI certification for both prospective and 
existing CDFIs.

  A.  Navigating and understanding the certification process, 
        requirements, technical language, and technology 
        systems can be daunting especially for a small or new 
        organization whose staff lacks prior knowledge of the 
        CDFI regulatory framework and how it evolved. This 
        challenge is exacerbated by two related factors--
        limited CDFI Fund staff resources due to underfunding 
        and the long delays in processing and approving 
        certification applications. The CDFI Fund recently 
        issued two communications detailing their staff and 
        workload challenges as well as the steps they are 
        taking to address these problems; (See https://
        www.cdfifund.gov/node/1012651 and https://
        www.cdfifund.gov/impact/435). While some of these steps 
        are encouraging, such as restructuring the Office of 
        Certification, Compliance Monitoring and Evaluation 
        into two departments, the statement in the January 31, 
        2022, communication that ``The CDFI Fund will 
        automatically reject any incomplete or inaccurate 
        application'' raises concerns. The pandemic has imposed 
        enormous burdens on the Fund staff, however without the 
        definition of what constitutes an incomplete or 
        inaccurate application, it is possible that applicants 
        unfamiliar with the certification regulations and 
        guidance and without the ability to hire a consultant 
        may inadvertently submit an application with errors 
        that is automatically rejected. Applicants are limited 
        to making email ``service requests'' to the Fund's help 
        desk and/or attending monthly Certification Conference 
        calls. These options may work well for simple, 
        straightforward questions however, they do not lend 
        themselves to complicated or nuanced issues that 
        applicants may encounter. Resources should be provided 
        to the Fund to offer a robust call center or help desk 
        with staff who have deep knowledge about the details 
        and intricacies of CDFI certification.

  B.  Target Market designation and expansion present 
        significant challenges for existing CDFIs, especially 
        as the world has changed dramatically since the Fund 
        was established in 1994. As described in our written 
        testimony for the January 5th hearing, the advent of 
        technology in delivering credit to small business 
        owners has altered the financial services landscape 
        forever. If CDFIs are to compete and offer safe credit 
        products to entrepreneurs, they must be able to meet 
        their customers where they are in terms of geography 
        and ease of user experience. CDFIs need to be able 
        offer their loan products across larger geographic 
        areas, including on a nationwide scale, and they need 
        to deliver their products through technology channels 
        that provide quick response times and a streamlined 
        underwriting and approval process. The experience of 
        making Paycheck Protection Program (PPP) loans provided 
        a clear illustration of the kind of lending CDFIs will 
        be called upon to do in the future. The CDFI Fund needs 
        to provide a process by which existing CDFIs can expand 
        or modify their approved Target Markets without having 
        to re-apply for certification. This is burdensome for 
        both the CDFI and the Fund staff. In addition, CDFIs 
        that have the capacity to serve Investment Areas (IA) 
        across the country should be granted a National IA 
        Target Market to which they are accountable through a 
        governing or advisory board.

  C.  CDFIs are seeking guidance and leadership from the CDFI 
        Fund in the area of Target Market verification. As 
        stipulated in guidance, CDFIs must direct 60 percent of 
        their lending (by volume and dollar amount) to their 
        approved Target Markets. To confirm that they are 
        meeting this requirement, CDFIs use the Fund's mapping 
        service to determine if a loan is located in an IA 
        which the CDFI has been approved to serve. However, for 
        CDFIs with Low Income Targeted Population (LITP) Target 
        Markets, it is unclear what types of verification 
        methods they can use to qualify or demonstrate that 
        their loans are serving this type of Target Market. In 
        the absence of clear guidance, CDFIs have relied on 
        proxies (such as the Low-Income Housing Tax Credit, 
        eligibility for Medicaid, and free and reduced 
        lunches), to verify that loans are serving low-income 
        people as well as developing their own verification 
        methods, particularly for loans to small businesses 
        where the owner is not a low-income individual, but the 
        business is providing employment to low-income people. 
        In a Notice and Request for Public Comment published in 
        the Federal Register on May 7, 2020, the CDFI Fund 
        proposed a default proxy method using a Census Block 
        Group geocoder (which has not yet been made available) 
        to determine if loans may be designated as LITP. 
        Without the ability to test this new geocoder, CDFIs 
        are very concerned that requiring them to use this 
        method could invalidate past loans or restrict their 
        ability to serve small businesses or consumers who 
        otherwise would qualify under their current 
        verification methods. We have called upon the Fund to 
        establish a process by which CDFIs can present their 
        existing verification methods for approval by the Fund 
        to ensure they can continue to serve low-income 
        customers who may fall outside this new geocoding 
        system, especially those in rural or sparsely populated 
        areas.

  D.  Lastly, as CDFIs are becoming larger and more 
        sophisticated, they are establishing holding company 
        structures with affiliates and subsidiaries. Having to 
        certify each and every affiliate or subsidiary 
        separately is both time consuming and labor intensive. 
        A more holistic approach to certifying affiliates and 
        subsidiaries would streamline the process for 
        applicants as well as for Fund staff. One issue that 
        should be addressed as part of certifying affiliates 
        and subsidiaries is the requirement that they must 
        already have made or be making loans in a requested 
        Target Market. This requirement makes it difficult for 
        a new entity to be certified in a timely fashion. This 
        ``catch 22'' makes it harder for the affiliate to begin 
        lending or investing activities and therefore 
        certification must be anticipated well in advance 
        (perhaps a year or more). Creating a prospective rather 
        than a retrospective approach to certifying affiliates 
        and subsidiaries of existing CDFIs that need to launch 
        their lending or investing activities quickly would be 
        enormously beneficial. The certification requirements 
        for Bond Guarantee Program participants offer an 
        example of how this could be done. In the BGP, the CDFI 
        Fund permits a CDFI's Affiliate to rely on the 
        Controlling CDFI's activity or track record to meet the 
        financing entity requirement for participation as an 
        Eligible CDFI under the CDFI Bond Guarantee Program. 
        This approach could serve as a model for more broadly 
        certifying affiliates and subsidiaries of existing 
        CDFIs.

Q.10. How has the CDFI Fund's guidance and technical assistance 
(e.g., webinars, meetings, user guides, etc.) been helpful to 
you? How do you believe the CDFI Fund can improve outreach and 
guidance?

A.10. Yes, these convenings and materials have been helpful but 
are not sufficient. More technical assistance is needed. Often 
a new organization seeking to become certified or an existing 
CDFI with a question or a concern needs to have a conversation 
with Fund staff about a technical or nuanced issue. We 
understand the CDFI Fund staff have been stretched thin while 
designing, managing, and deploying an enormous amount of 
funding over the past 2 years. Nonetheless, we are concerned 
that if there are no options for directly engaging with Fund 
staff other than through a service request (email 
communication) then many CDFIs will not be able to access the 
information, oral guidance, and advice they need to participate 
in CDFI Fund programs. This would be a step backward as the 
hallmark of the CDFI industry has been the ability to interact, 
support, and learn from the staff at the Fund and thus advance 
its mission.
                                ------                                


               RESPONSES TO WRITTEN QUESTIONS OF
               SENATOR MENENDEZ FROM FRANK ALTMAN

Q.1. The Build Back Better Act currently being debated by 
Congress contains many crucial investments in community 
development. For instance, the House-passed version of the bill 
provides $2.2 billion dollars to eligible institutions, 
including CDFIs, to assist first-time, first generation 
homebuyers. It also contains $3 billion dollars for these 
institutions for community facilities and other housing and 
civic infrastructure.
    Could you describe what kind of impact these programs could 
have in the communities your institution serves?

A.1. As a Qualified Issuer (QI) in the CDFI Bond Guarantee 
Program (BGP), we would welcome these resources for the 
communities we serve directly and through the BGP and New 
Markets Tax Credit (NMTC) programs. The NMTC program is 
routinely oversubscribed due to the highly competitive nature 
of the program. When we receive allocations, there are so many 
worthy projects, and we are only able to fund a small fraction 
of the potential pipeline. Similarly, the CDFIs on whose behalf 
we issue bonds under the BGP--are on the front lines providing 
resources to underserved communities and have limited sources 
of long-term, patient funding. They must make difficult 
decisions between which projects to fund and which ones they 
are not able to support. More resources such as the $2.2 
billion in the House passed version of the Build Back Better 
bill would allow CDFIs to have multiple sources of funding to 
address the financing needs in urban, rural, and Native 
communities ravage by the pandemic and looking to build their 
community and civic infrastructure.
    One example of a program that assisted first-time, first-
generation homebuyers and would have benefited from capital 
like that which would be available under the Build Back Better 
Act (BBA) is the Detroit Home Mortgage Program (DHM). This 
program, which CRF helped to launched in 2016, was a 
collaborative effort between local banks, foundations, CDFIs, 
the City of Detroit, and community organizations to address 
financial gaps in appraisals so that borrowers could afford to 
buy, renovate, and live in a home in the City of Detroit. DHM 
was designed as a temporary market intervention to increase the 
number of mortgages throughout the city by laying the 
groundwork for real, negotiated appraisals in real estate 
transactions. DHM served as a catalyst by allowing buyers and 
sellers to negotiate low appraisals to determine the true value 
of the home. As a result, neighborhoods throughout the City of 
Detroit saw increases in the availability of mortgages.
    If risk capital, such as what would be provided through the 
BBA, had been available in 2016, DHM could have launched much 
faster and on a larger scale. As of October 2021, the program 
closed 244 mortgages and spurred at least another 144 in other 
lending from our originating partners. Detroit has seen 
mortgage market growth every year since the inception of DHM. 
Mortgage lending in the city is almost back to prefinancial 
crash levels with realtors reporting a total of 2,180 mortgages 
which is very close to being a healthy market again. The last 
time there were more than 2,000 mortgages in Detroit was 2007. 
With borrowers choosing where to live, DHM reached more than 
half of all the neighborhoods in Detroit, providing a 
catalyzing effect for increased lending throughout the city. 
DHM's impact has also been sustained during the COVID-19 
pandemic, which is very important to know that there will be a 
lasting effect on the city. There have been no defaults for any 
of the mortgages that are in the DHM fund. While DHM had its 
intended impact, there are many postindustrial cities that 
could benefit from a similar program if capital was available 
to support this type of intervention allowing many more 
families to become homeowners and revitalizing cities like 
Detroit.
    The $3 billion dollars available to institutions, like 
CDFIs, for community facilities and other housing and civic 
infrastructure would complement and augment existing financing 
tools and programs, such as the NMTC and the Bond Guarantee 
programs. The latter, as we noted in our written testimony, has 
been challenging for smaller and medium-sized CDFIs to access 
due to the $100 million minimum bond threshold requirement. 
This funding from BBA would help CDFIs reach smaller projects 
that often are not cost effective. Having access to resources 
like this could be catalytic attracting private sector 
financing and stimulating neighborhood revitalization through 
the development and rehabilitation of community facilities as 
well as other critical infrastructure projects.
                                ------                                


       RESPONSES TO WRITTEN QUESTIONS OF SENATOR WARNOCK
                       FROM FRANK ALTMAN

Q.1. Would you please describe your experience working with the 
Paycheck Protection Program? How did your members leverage 
their experience as a CDFI to get the relief out to communities 
you serve?

A.1. CRF was proud to support small businesses during the 
pandemic by delivering Paycheck Protection Program (PPP) loans 
to underserved borrowers across the country. We leveraged two 
proprietary technology platforms: (1) Connect2Capital (C2C) 
which matches small business borrowers with an appropriate loan 
product (in this case, the PPP loan) and SPARK, a software 
solution that allows lenders to originate loans (including a 
customized process for PPP loans) based on the characteristics 
of the credit product. CRF worked closely with more than 47 
CDFI and community-based partners nationwide to ensure that 
their small business customers and nonprofit organizations, 
particularly small and economically disadvantaged, businesses 
and those that are BIPOC-owned, were able to obtain a PPP loan. 
Many of these borrowers were very small and were not being 
served by banks. Through CRF's national network of community-
based partners, our technology platforms, and our dedicated 
staff, we were able to make nearly 4,500 loans and for a total 
of $700 million with a median loan size of just $21,000. Most 
importantly, these loans helped to save more than 68,000 jobs.

Q.2. What do you believe is driving the gap of CDFI investments 
between urban and rural communities? What are the long-term 
benefits of making sure rural counties are receiving their fair 
share of CDFI investments?

A.2. It is unclear what is driving the gap of CDFI investments 
between urban and rural communities, but we need to ensure all 
communities receive a fair share of resources. CDFIs are not 
present in all communities. In addition, it may be more costly 
to serve rural communities as it is critical to build trusted 
relationships with local partners (such as a development 
finance agency) or be present in the community. Rural 
ecosystems are different from those in urban communities. 
Nonetheless rural areas can be better served as evidenced by 
the New Markets Tax Credit program where 20 percent of the 
investments must be made in rural communities. In some cases, 
NMTC investments in rural communities have exceeded this level.
    Early in our history, CRF undertook a rural initiative 
across 14 States to provide access to capital to businesses and 
nonprofits thousands of local communities. It was a significant 
effort, and an essential aspect was having a strong partner, in 
this case the foundation of U.S. West, then a major 
telecommunications firm serving this region. More private-
public partnerships could increase CDFI investments in rural 
counties.
    In terms of CRF's current lending activities, we serve 
rural areas through several channels. With our small business 
products (including both SBA 7(a) and non-SBA loans), 18 
percent of our total dollar volume and 16 percent of the total 
number of loans have been made to businesses in rural areas 
since 2012. Using New Markets Tax Credits, 36 percent of the 
dollar amount and 29 percent of the number of financings have 
been directed to rural businesses. We also originated $700 
million in Paycheck Protection Program (PPP) loans of which 10 
percent of the dollar amount and 17 percent of the total number 
of loans went to organizations in rural areas.
    To specifically address the gap in CDFI investments in 
rural areas, CRF recently launched a joint venture with Conduit 
Capital, a leading impact investment firm to create RuralWorks, 
a Rural Business Investment Company (RBIC, license pending), 
with the mission to increase economic mobility, generate 
community wealth, and build a more equitable and resilient 
rural economy. RuralWorks provides integrated capital to 
growth-oriented businesses operating in rural communities. By 
creatively engaging a range of local and national resources and 
partners, RuralWorks creates value and outcomes rooted in local 
people, places, and businesses.

Q.3. Minority-owned CDFI Fund awardees are experiencing asset 
growth at a slower pace than their peers, with little to no 
progress on closing the asset gap. What do you believe is 
driving this gap and how are communities that your organization 
serves hurt by its persistence?

A.3. Lack of access to equity capital is one factor that may be 
driving the gap in asset growth minority-owned CDFI Fund 
awardees are experiencing when compared to awardees that are 
not minority owned. To address this gap, Congress provided $9 
billion through The Emergency Capital Investment Program (ECIP) 
as part of the Consolidated Appropriations Act of 2021. This 
program targeted funding to CDFIs and Minority Depository 
Institutions (MDIs) by providing loans, grants, and forbearance 
for small businesses, minority-owned businesses, and consumers, 
especially in low-income and underserved communities, that may 
be disproportionately impacted by the economic effects of the 
COVID-19 pandemic. Treasury set aside $2 billion for CDFIs and 
MDIs with less than $500 million in assets and an additional $2 
billion for CDFIs and MDIs with less than $2 billion in assets.

Q.4. Would you speak to strategies to target Federal 
investments to catalyze and accelerate holistic community 
revitalization, beyond just putting roofs over folks' head? How 
can we leverage Federal dollars to ensure access to quality 
education, safe and affordable housing, as well as access to 
health care?

A.4. This is an important topic and in our view, this is 
exactly what the Build Back Better legislation was intended to 
do--stimulate holistic revitalization across all the key 
elements that make up the social determinants of health by 
providing funding for affordable housing, early childhood 
education, more affordable post-secondary education (in an 
earlier version of the bill), addressing the dangers of climate 
change, reducing the high cost of prescription drugs and 
hearing aids, as well as other resources that will improve the 
quality of life for residents of distressed areas. The 
bipartisan Infrastructure Bill that Congress passed will 
improve the built environment by repairing our aging roads and 
bridges as well as bringing broadband and internet access to 
communities across the country that lack connectivity. These 
two key legislative initiatives (understanding that the future 
of the Build Back Better bill is uncertain) are the blueprint 
for an effective strategy for targeting Federal investments 
that could successfully catalyze and accelerate holistic and 
mutually reinforcing community revitalization particularly in 
underserved and communities of color.
                                ------                                


         RESPONSES TO WRITTEN QUESTIONS OF CHAIR SMITH
                       FROM LAKOTA VOGEL

Q.1. What steps, if any, should be taken to improve the 
diversity of leaders in the CDFI sector?

A.1. Response not received in time for publication.

Q.2. What do you believe to be the biggest challenge to CDFI 
certification for prospective CDFIs?

A.2. Response not received in time for publication.

Q.3. How has the CDFI Fund's guidance and technical assistance 
(e.g., webinars, meetings, user guides, etc.) been helpful to 
you? How do you believe the CDFI Fund can improve outreach and 
guidance?

A.3. Response not received in time for publication.
                                ------                                


               RESPONSES TO WRITTEN QUESTIONS OF
               SENATOR MENENDEZ FROM LAKOTA VOGEL

Q.1. The Build Back Better Act currently being debated by 
Congress contains many crucial investments in community 
development. For instance, the House-passed version of the bill 
provides $2.2 billion dollars to eligible institutions, 
including CDFIs, to assist first-time, first-generation 
homebuyers. It also contains $3 billion dollars for these 
institutions for community facilities and other housing and 
civic infrastructure.
    Could you describe what kind of impact these programs could 
have in the communities your institution serves?

A.1. Response not received in time for publication.
                                ------                                


       RESPONSES TO WRITTEN QUESTIONS OF SENATOR WARNOCK
                       FROM LAKOTA VOGEL

Q.1. Your organization is unique in both geography and the 
population being served. What challenges do you face on a day-
to-day serving your community, and where are you finding 
success?

A.1. Response not received in time for publication.

Q.2. What types of challenges has your organization experiences 
accessing CDFI Fund awards or other assistance from the CDFI 
Fund? What further resources from the Fund do you think would 
enable you to better serve your community?

A.2. Response not received in time for publication.

Q.3. Would you speak to strategies to target Federal 
investments to catalyze and accelerate holistic community 
revitalization, beyond just putting roofs over folks head? How 
can we leverage Federal dollars to ensure access to quality 
education, safe and affordable housing, as well as access to 
health care?

A.3. Response not received in time for publication.
                  GAO REPORT: FEDERAL HOME LOAN BANKS

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