Comment Matrix

Comment Number	Date of Comment	Author Name	Author Position	Organization	File Name	Category	Comment	CDFI Fund's Response
1	4/8/2022	Lenwood V. Long, Sr.	President/CEO	African American Alliance of CDFI CEOs	AAA_Commnets_Material Events Form_04.08.2022	Timing	The Alliance supports the proposed revision to increase the period within which a material event must be reported from 20 days to 30 days, as this affords greater flexibility for our member CDFIs to report material events.	The requirement to report a Material Event within 30 days has been instituted as the standard for new programs, including the CDFI Fund's Bond Guarantee Program.
2	4/8/2022	Lenwood V. Long, Sr.	President/CEO	African American Alliance of CDFI CEOs	AAA_Commnets_Material Events Form_04.08.2022	Not Applicable	The costs to maintain and effectively meet the reporting requirements is a barrier to the CDFI Bond Guarantee Program.	Comment on this topic was not solicited as part of the renewal of the Certification of Material Event Form. This comment will be shared with the CDFI Fund's Bond Guarantee Program for future consideration.
3	4/8/2022	Ben Sones & Everett White	Member	Sones & White Consulting, LLC.	Certification of Material Events Comment Letter_Sones White Consulting	Duplicative	Reporting on key staff changes, merger/acquisitions or a new Authorized Representatives via a Certification of Material Event form is duplicative.	The Certification of Material Event form is the initial communication to the CDFI Fund that triggers action whereby specific guidance is conveyed from the CDFI Fund to the affected organization.
4	4/8/2022	Ben Sones & Everett White	Member	Sones & White Consulting, LLC.	Certification of Material Events Comment Letter_Sones White Consulting	Burden	The provision of biographies and resumes for changes to key personnel are unnecessary.	New guidance has been disseminated whereby the biographies and resumes are no longer required when key personnel changes occur.
5	4/8/2022	Ben Sones & Everett White	Member	Sones & White Consulting, LLC.	Certification of Material Events Comment Letter_Sones White Consulting	Burden	The requirement of a signature is time-consuming for some organizations.	The signature of an Authorized Representative is deemed necessary to ensure management is aware of the Material Event and is cognizant of the potential consequences.
6	4/8/2022	Ben Sones & Everett White	Member	Sones & White Consulting, LLC.	Certification of Material Events Comment Letter_Sones White Consulting	Timing	An extension of the 30-day window to 90 days would be helpful.	The requirement to report a Material Event within 30 days has been instituted as the standard for new programs. The CDFI Fund believes a longer period could negatively affect its ability to proactively address reported issues in a timely manner.
7	4/8/2022	Ben Sones & Everett White	Member	Sones & White Consulting, LLC.	Certification of Material Events Comment Letter_Sones White Consulting	Burden	Establishing, tracking and monitoring obligation for the CDFI, including the need to have procedures and controls in place for capturing all Material Events is burdensome for CDFIs, and these requirements should be narrowly tailored to capture only those events that are truly material.	The CDFI Fund expects organizations to have processes in place to comply with an award agreement, including reporting on Material Events.
8	4/8/2022	Ben Sones & Everett White	Member	Sones & White Consulting, LLC.	Certification of Material Events Comment Letter_Sones White Consulting	Burden	The collection of information should be tailored to those events that have a direct bearing on program eligibility and compliance.	The Certification of Material Event Form is organized by events that are specific to individual programs and reflect those events deemed significant in compliance and certification matters.
9	4/8/2022	Ben Sones & Everett White	Member	Sones & White Consulting, LLC.	Certification of Material Events Comment Letter_Sones White Consulting	Burden	An online form with no physical signature requirement should be implemented.	As the CDFI Fund transitions to an online completion of the form, this issue will be addressed. The current form allows for the electronic signature of any individual authorized on behalf of the organization’s governing body.
10	4/8/2022	Ben Sones & Everett White	Member	Sones & White Consulting, LLC.	Certification of Material Events Comment Letter_Sones White Consulting	Ease of Use	The current process of filling out the PDF, receiving the authorized representative’s signature, creating a Service Request, and uploading the CME file, is tedious. If the authorized representative could log into AMIS and submit the form directly, this would greatly expedite the process.	As the CDFI Fund transitions to an online completion of the form, this issue will be implemented.
11	4/8/2022	Ben Sones & Everett White	Member	Sones & White Consulting, LLC.	Certification of Material Events Comment Letter_Sones White Consulting	Ease of Use	Recommend the ability to add a “Point of Contact” to the CME form if it could be completed online.	As the CDFI Fund transitions to an online completion of the form, this issue will be implemented. The current form provides for this.
12	4/8/2022	Ben Sones & Everett White	Member	Sones & White Consulting, LLC.	Certification of Material Events Comment Letter_Sones White Consulting	Ease of Use	In the current state, when submitting a Material Events Form via Service Request, the user must select the program impacted by the form. Many of clients have multiple awards in differing programs, so the must submit the same from multiple times in different Service Requests selecting different programs.	As the CDFI Fund transitions to an online completion of the form, this issue will be reassessed.