Our Position

Community Development Financial Institutions


  • ICBA opposes the CDFI Fund’s proposed revisions to the Certification Application and the Annual Certification, as the proposed changes would likely harm existing CDFI banks and significantly deter interest from new CDFI applicants.
  • ICBA supports increasing funding for the CDFI Fund, proceeds of which are used to help CDFI banks continue to innovate and help their communities.
  • ICBA supports the creation of a legal and regulatory framework that promotes CDFI status among community banks and provides more opportunities for community banks to benefit from this special designation, such an automated or streamlined application for community banks located in low-income areas.
  • Community Reinvestment Act exams of CDFIs should account for information that is already provided to the CDFI Fund through the application and annual certification process. Requiring a CDFI bank to provide similar information to two federal agencies is redundant and unnecessary.
  • Grant proceeds from the CDFI Fund should be tax-free for CDFI banks, just as they are for CDFIs in other industries.


CDFIs are specialized financial institutions that provide financial products and services to populations and businesses located in underserved markets. These institutions have community development missions and a reputation for lending responsibly in low-income communities. Community banks comprise over 20 percent of the CDFIs in the nation.

Before designation as a CDFI, banks must apply to the CDFI Fund for certification. Among other requirements, a bank must demonstrate a primary mission of community development, serve one or more target markets, provide development services to borrowers in conjunction with financing activities, and maintain accountability to its target market.

The CDFI Fund has proposed revisions to its application and annual certification. Among other provisions, the changes would set an arbitrary APR cap on CDFI loans, prohibit balloon mortgages, and disqualify certain forms of critical Development Services.

Staff Contact

Michael Emancipator

Senior Vice President and Senior Regulatory Counsel

Washington, DC