Form CDFI-0016 Conflict of Interest Package for CDFI Fund Non-Federal R

DEPARTMENT OF THE TREASURY

Community Development Financial Institutions Fund

Conflict of Interest Package for CDFI
Fund Non-Federal Readers
CDFI-0016

CONFLICT OF INTEREST POLICY FOR COMMUNITY DEVELOPMENT
FINANCIAL INSTITUTIONS (CDFI) FUND READERS
Consistent with the Federal Acquisition Regulations provisions on conflicts of interest, the Community
Development Financial Institutions (CDFI) Fund has applied, and will continue to apply, a conflict of
interest policy with respect to its contract readers that avoids a reader’s participation in the evaluation or
process of selection of applications where such participation creates a conflict of interest or an appearance
of a conflict of interest.
This policy document memorializes the standards by which the CDFI Fund will determine whether a
conflict of interest or an appearance of a conflict of interest will prevent outside (non-federal
government employee) readers, hired on contract, from being assigned particular applications and
applies to all outside readers participating in the evaluation or process of selection for an award of any
application to the CDFI Fund. The role of outside readers in any CDFI Fund award process is such
that outside readers will not make decisions about whether an applicant is eligible for, or receives, an
award.
A reader will be considered to have a conflict of interest or an appearance of a conflict of interest with
respect to an application if the reader, his or her spouse, parent, dependent child or member of his or
her household:
1. serves, or in the last year has served, as an officer, director, trustee, partner, agent,
attorney, consultant, contractor, or employee of or receives the primary source of his or her
income from that applicant or any parent, subsidiary or affiliate organization of that
applicant;
2. is negotiating, or has an arrangement concerning, prospective employment (or other similar
association) with that applicant or any parent, subsidiary or affiliate organization of that
applicant;
3. has a financial interest in the CDFI Fund's action with respect to the application which
would if held by a government employee, constitute a “financial interest” within the
meaning of 18 U.S.C. section 208. (Such “financial interests” arise from, but are not
limited to, receipt of salaries or fees paid by, and interests in equity or other securities
issued by, the applicant or any parent, subsidiary or affiliate organization of the applicant);
4. has provided assistance to the applicant in the preparation of its application or otherwise
facilitated the submission of the application; or
5. serves, or has served, during the preparation of the application or the pendency of the
CDFI Fund award process in which the application is being considered, as an officer,
director, trustee, partner, agent, attorney, consultant, contractor or employee of or receives
the primary source of his or her income from an entity that either (1) has provided
assistance in the preparation of the application or otherwise facilitated the submission of

CDFI-0016

the application or (2) has a financial interest in the CDFI Fund's action with respect to the
application.
The Director of the CDFI Fund may determine, in consultation with appropriate ethics officials, that a
reader who has a conflict of interest or an appearance of a conflict of interest with respect to a particular
application should not be assigned other applications as well. Factors to be considered in making such
determinations include: the nature of the conflict or appearance of conflict; the importance of the reader’s
role in reviewing such other applications; the nature of such other applications; the relationship, if any, of
such other applications to the application presenting the conflict or the appearance of a conflict; and the
difficulty of assigning such applications to a different reader.
All readers must submit a resume, complete and sign a conflict of interest certification form, a reader
conflict of interest report form, and a nondisclosure certification form prior to being assigned to
review any applications.
If, at any time during a CDFI Fund award process, a reader learns that he or she might have a conflict
of interest or an appearance of a conflict of interest with respect to an application involved in such
process, he or she must inform the Legal Counsel to the CDFI Fund immediately. A reader shall also
inform the Legal Counsel of the CDFI Fund, if at any time during the CDFI Fund award process, he
or she cannot objectively evaluate an application for any reason.

CDFI-0016

Conflict of Interest Certification for
Community Development Financial Institutions (CDFI) Fund Readers
I, the undersigned reader of an application(s) to the Community Development Financial Institutions (CDFI) Fund, hereby
certify that, except as described on Schedule A attached hereto, I do not have a conflict of interest and that my particular
circumstances are not likely to create the appearance of a conflict of interest with respect to any application in a CDFI
Fund award process in which I am a participant. For purposes of this certification, I recognize that I shall be considered to
have a conflict of interest or an appearance of a conflict of interest with respect to an application if I, my spouse, parent,
dependent child or any member of my household;
1.

serves, or in the last year has served, as an officer, director, trustee, partner, agent, attorney, consultant,
contractor, or employee of or receives the primary source of his or her income from that applicant or any
parent, subsidiary or affiliate organization of that applicant;

2.

is negotiating, or has an arrangement concerning, prospective employment (or other similar association) with
that applicant or any parent, subsidiary or affiliate organization of that applicant;

3.

has a financial interest in the CDFI Fund's action with respect to the application which would, if held by a
government employee, constitute a “financial interest” within the meaning of 18 U.S.C. section 208. (Such
“financial interests” arise from, but are not limited to, receipt of salaries or fees paid by, and interests in
equity or other securities issued by, the applicant or any parent, subsidiary or affiliate organization of the
applicant);

4.

has provided assistance to the applicant in the preparation of its application or otherwise facilitated the
submission of the application; or

5.

serves, or has served, during the preparation of the application or the pendency of the CDFI Fund award
process in which the application is being considered, as an officer, director, trustee, partner, agent, attorney,
consultant, contractor or employee of or receives the primary source of his or her income from an entity that
either (1) has provided assistance in the preparation of the application or otherwise facilitated the submission
of the application or (2) has a financial interest in the CDFI Fund's action with respect to the application.

I recognize that this certification is a continuing representation. I acknowledge that it is in effect at all times until I have
completed all of the work to be performed by me in connection with my review of applications to the CDFI Fund.
If, at any time during a CDFI Fund award process, I learn that I might have a conflict of interest or an appearance of a
conflict of interest with respect to an application involved in the process, I shall inform the Legal Counsel of the CDFI
Fund immediately. I shall also inform the Legal Counsel of the CDFI Fund if, at any time during the CDFI Fund award
process, I believe that I cannot objectively evaluate an application for any reason.

_____________________________________
Signature of Reader

________________________
Date

________________________________
Printed or Typed Name of Reader

CDFI-0016

SCHEDULE A
Check here if NONE of the items below are applicable.
1.
I, my spouse, parent, dependent child or a member of my household serves, or in the last year has
served, as an officer, director, trustee, partner, agent, attorney, consultant, contractor, or employee of or receives the
primary source of his or her income from the following applicant(s), or parent, subsidiary or affiliate organization of the
applicant(s).
_______________________________________________________________________________________________________
_______________________________________________________________________________________________________
_______________________________________________________________________________________________________
_______________________________________________________________________________________________________
2.
I, my spouse, parent, dependent child or a member of my household is negotiating, or has an arrangement
concerning, prospective employment (or other similar association) with the following applicant(s), or parent, subsidiary or
affiliate organization of the applicant(s).
_______________________________________________________________________________________________________
_______________________________________________________________________________________________________
_______________________________________________________________________________________________________
_______________________________________________________________________________________________________
3.
I, my spouse, parent, dependent child or a member of my household has a financial interest in the CDFI Fund's
action with respect to the following application(s) which would, if held by a government employee, constitute a "financial
interest" within the meaning of 18 U.S.C. section 208. (Such "financial interests" arise from, but are not limited to, receipt
of salaries or fees paid by, and interests in equity or other securities issued by, the applicant(s) or any parent, subsidiary or
affiliate organization of the applicant(s).)
_______________________________________________________________________________________________________
_______________________________________________________________________________________________________
_______________________________________________________________________________________________________
_______________________________________________________________________________________________________
4.
I, my spouse, parent, dependent child or a member of my household has provided assistance to the following
applicant(s) in the preparation of the application(s) or otherwise facilitated the submission of the application(s).
_______________________________________________________________________________________________________
_______________________________________________________________________________________________________
_______________________________________________________________________________________________________
_______________________________________________________________________________________________________
5.
I, my spouse, parent, dependent child or a member of my household serves, or has served, during the preparation
of the following application(s) or the pendency of the CDFl Fund award process in which the following application(s) is
being considered, as an officer, director, trustee, partner, agent, attorney, consultant, contractor or employee of or receives
the primary source of his or her income from an entity that either (1) has provided assistance in the preparation of the
following application(s) or otherwise facilitated the submission of the following application(s) or (2) has a financial
interest in the CDFI Fund's action with respect to the following application(s).
_______________________________________________________________________________________________________
_______________________________________________________________________________________________________
_______________________________________________________________________________________________________
_______________________________________________________________________________________________________

____________________________________________
Signature of Reader
Date

____________________________________
Printed or Typed Name of Reader

CDFI-0016

Reader Conflict of Interest Report
CDFI Fund FY 2007 Financial Assistance Component
Print Name: _________________________
Signature: ___________________________
Date: _______________________________
The following organizations have applied for assistance under the 2007 Financial Assistance Component of the CDFI Program.
This list is confidential and should be treated accordingly. As a reader, please put a check next to those organizations with which
you have a conflict of interest.
Check here if you do NOT have a conflict of interest with any of the organizations listed below.
No.

Organization

1 AAFE Community Development Fund
2 ACCION Texas, Inc.
3 ACCION USA
4 African Development Center
5 Albany Community Together, Inc.
6 Alternatives Federal Credit Union
7 Appalachian Community Enterprises
8 ASI Federal Credit Union
9 Azteca Community Loan Fund
10 BAC Funding Consortium, Inc.
11 Bethex Federal Credit Union
12 Black Business Investment Fund of Central Florida, Inc.
13 Blue Water Community Development Fund
14 Boston Community Loan Fund
15 Brooklyn Cooperative Federal Credit Union
16 Business Loan Fund of the Palm Beaches, Inc., The
17 Capital Fund Services, Inc.
18 Carter Federal Credit Union
19 Ceda Community Development Fund
20 Ceiba Housing and Economic Development Corporation
21 Chattanooga Neighborhood Enterprise, Inc.
22 Chicago Community Loan Fund
23 Cincinnati Development Fund
24 City National Bancshares Corporation
25 Coastal Enterprises, Inc.
26 Colorado Housing Enterprises, LLC
27 Columbus Compact Corporation
28 Columbus Housing Initiative
29 Communicating Arts CU
30 Community Capitol of Maryland, Inc.

State

Check if
conflict

NY
TX
MA
MN
GA
NY
GA
LA
TX
FL
NY
FL
MI
MA
NY
FL
MI
LA
IL
PR
TN
IL
OH
NJ
ME
CO
OH
GA
MI
MD

CDFI-0016

Reader Conflict of Interest Report
CDFI Fund FY 2007 Financial Assistance Component
Print Name: _________________________
Signature: ___________________________
Date: _______________________________
The following organizations have applied for assistance under the 2007 Financial Assistance Component of the CDFI Program.
This list is confidential and should be treated accordingly. As a reader, please put a check next to those organizations with which
you have a conflict of interest.
Check here if you do NOT have a conflict of interest with any of the organizations listed below.
No. Organization
31 Community Development & Improvement Corporation
32 Community Development Bank, FSB
33 Community Development Capital
34 Community Development Resources
35 Community Development Venture Capital Alliance
36 Community First Fund
37 Community Loan Fund of Southwestern Pennsylvania, Inc.
38 Community Neighborhood Housing Services
39 Cooperative Fund of New England
40 Cornerstone, Inc.
41 Corporation for Supportive Housing
42 Delta Foundation, Inc.
43 economic opportunities fund
44 El Futuro Credit Union
45 Enterprise Community Loan Fund, Inc.
46 Faith Based Federal Credit Union
47 First Bank of the Delta, N.A.
48 First Combined Community Federal Credit Union
49 First Independence National Bank of Detroit
50 Florida Community Loan Fund, Inc.
51 Forward Community Investments
52 Franklin Bancorp Inc., d.b.a. Sunrise Community Banks
53 Funding Partners for Housing Solutions
54 Gateway Community Development Credit Union
55 Great Rivers Community Capital
56 Greater New Haven Community Loan Fund, Inc.
57 Hope Community Credit Union
58 Hopi Credit Association
59 Housing Assistance Council
60 Illinois Facilities Fund, The

State

Check if
conflict

SC
MN
LA
NE
NY
PA
PA
MN
MA
DC
NY
MS
PA
CA
MD
CA
AR
MD
MI
FL
WI
MN
CO
NC
MO
CT
MS
AZ
DC
IL

CDFI-0016

Reader Conflict of Interest Report
CDFI Fund FY 2007 Financial Assistance Component
Print Name: _________________________
Signature: ___________________________
Date: _______________________________
The following organizations have applied for assistance under the 2007 Financial Assistance Component of the CDFI Program.
This list is confidential and should be treated accordingly. As a reader, please put a check next to those organizations with which
you have a conflict of interest.

Check here if you do NOT have a conflict of interest with any of the organizations listed below.
No.

Organization

61 Impact Seven, Inc.
62 Indianapolis Neighborhood Housing Partnership, Inc.
63 Intermountain Community Capital Corporation
64 Iowa Able Foundation
65 La Fuerza Unida Community Development Corporation
66 Latino Community Credit Union
67 Lawrence EDC
68 Legacy Redevelopment Corporation
69 Lenders for Community Development
70 Liberty Bank and Trust Company
71 Local Enterprise Assistance Fund
72 Local Initiatives Support Corporation
73 Los Angeles Community Reinvestment Committee d.b.a

State

Check if
conflict

WI
IN
UT
IA
NY
NC
MA
WI
CA
LA
MA
NY
CA

CFRC
74 Low Income Investment Fund
75 Lowcountry Housing Trust
76 Manchester NHS, Inc.
77 Miami-Dade Neighborhood Housing Services
78 Michigan Housing Trust Fund
79 MicroBusiness Development Corporation
80 Mile High Housing Fund, Inc.
81 Montana Community Development Corporation
82 Murex Investments, Inc.
83 National Federation of Community Development Credit

CA
SC
NH
FL
MI
CO
CO
MT
PA
NY

Unions
84 National Housing Trust Community Development Fund
85 Nebraska Microenterprise Partnership Fund
86 Neigborhood Housing Services Lending, Inc.
87 Neighborhood Assets
88 Neighborhood Development Center, Inc.
89 Neighborhood Economic Development Corporation
90 Neighborhood Housing Services of Chicago, Inc.

DC
NE
ID
WA
MN
AZ
IL

CDFI-0016

Reader Conflict of Interest Report
CDFI Fund FY 2007 Financial Assistance Component
Print Name: _________________________
Signature: ___________________________
Date: _______________________________
The following organizations have applied for assistance under the 2007 Financial Assistance Component of the CDFI Program.
This list is confidential and should be treated accordingly. As a reader, please put a check next to those organizations with which
you have a conflict of interest.
Check here if you do NOT have a conflict of interest with any of the organizations listed below.
No.

Organization

91 Neighborhood Housing Services of Duluth, Inc.
92 Network for Oregon Affordable Housing
93 New Hampshire Community Loan Fund, Inc.
94 Nonprofit Finance Fund
95 Northcountry Cooperative Development Fund, Inc.
96 Northeast Economic Development, Inc.
97 Northeast South Dakota Economic Corporation (NESDEC)
98 Northern California Community Loan Fund
99 Ohio Capital Finance Corporation
100 Pacific Community Ventures, Inc.
101 Partners for the Common Good
102 People's Community Partnership Federal Credit Union
103 Progress Fund, The
104 RCAP Solutions Financial Services, LLC
105 Reinvestment Fund, Inc., The
106 Richmond Economic Development Corporation
107 Rising Tide Community Loan Fund
108 Rural Community Assistance Corporation
109 Rural Opportunities Enterprise Center, Inc.
110 San Luis Obispo County Housin g Trust Fund
111 School Workers Federal Credit Union
112 Seattle Economic Development Fund d/b/a Community

State

Check if
conflict

MN
OR
NH
NY
MN
NE
SD
CA
OH
CA
DC
CA
PA
MA
PA
VA
PA
CA
NY
CA
NC
WA

Capital
113 Seedco Financial Services
114 Self-Help Credit Union
115 Sephardic Angel Fund
116 South Dakota Rural Enterprise, Inc.
117 Southwest Virginia Community Development Financing,

NY
NC
NY
SD
VA

Incorporated
118 Springfield Neighborhood Housing Services, Inc.
119 Syracuse Cooperative Federal Credit Union
120 The Housing Fund, Inc.

MA
NY
TN

CDFI-0016

Reader Conflict of Interest Report
CDFI Fund FY 2007 Financial Assistance Component
Print Name: _________________________
Signature: ___________________________
Date: _______________________________
The following organizations have applied for assistance under the 2007 Financial Assistance Component of the CDFI
Program. This list is confidential and should be treated accordingly. As a reader, please put a check next to those
organizations with which you have a conflict of interest.

Check here if you do NOT have a conflict of interest with any of the organizations listed below.
No.
121
122
123
124
125
126
127
128
129
130

Organization

Trenton Business Assistance Corporation
Tulsa Economic Development Corporation
United Bank and Trust Company
University Financial Corporation
Valley Small Business Development Corporation
Vermont Community Loan Fund, Inc.
Virgnia Community Capital, Inc.
Washington Area Housing Trust Fund
Washington Assoc. of Minority Entrepreneurs Inc.
West River Foundation for Economic and Community
Development
131 West Texas Credit Union
132 Western Massachusetts Enterprise Fund Inc.
133 Wisconsin Women's Business Initiative Corporation
134 WomenVenture

State

Check if conflict

NJ
OK
LA
MN
CA
VT
VA
DC
WA
SD
TX
MA
WI
MN

CDFI-0016

NONDISCLOSURE CERTIFICATION FOR
COMMUNITY DEVELOPMENT FINANCIAL INSTITUTIONS (CDFI) FUND
READERS
By signature of this document, the undersigned certifies to the following: All information made available to the
undersigned for purposes of reviewing applications to the Community Development Financial Institutions Fund
(the “Fund”) (including the names of and total number of applicants), or any such information which otherwise
comes into the possession of the undersigned during the review of said applications, and any such information
developed by the undersigned during such review, shall be used only for the express purpose of completing
such review or otherwise assisting the Fund to accomplish its purposes, and shall not be disclosed to any other
individual or firm outside of the United States Government. Further, all discussions connected with reviewing
applications to the Fund and all evaluations of said applications including, without limitation, any comments,
advice or recommendations given by any reader with respect to any application, shall not be disclosed to any
individual or firm not participating in such review and/or evaluations.

_____________________________________
Signature of Reader

_______________________________
Date

__________________________________
Printed or Typed Name of Reader

CDFI-0016

PRIVACY ACT NOTICE FOR:
CONFLICT OF INTEREST PACKAGE FOR NON-FEDERAL READERS

This information is provided pursuant to Public Law 93-579 (Privacy Act of 1974), December 31, 1974, for contractors
being considered as readers of applications submitted to the Department of the Treasury’s Community Development
Financial Institutions Fund (Fund). The completion of this package is mandatory for all contractors to be selected as
readers. Failure to fully complete this package will result in contractors being rejected from consideration as a reader.

Authority
12 U.S.C. § 4703(c); and 48 C.F.R. Subpart 9.5.

Purpose and Uses
This information is used by appropriate reviewing officials to determine whether or not a contractor’s financial interest, or
that of the contractor’s spouse, parent, dependent child, or member of household, may result in a conflict, or apparent
conflict of interest with the individual’s duties and responsibilities as a contractor evaluating applications.

Paperwork Reduction Act Notice
This conflict of interest package is used by the Community Development Financial Institutions Fund to determine whether
or not a contractor’s financial interest, or that of the contractor’s spouse, parent, dependent child, or member of household,
may result in a conflict, or apparent conflict of interest with the individual’s duties and responsibilities as a contractor
evaluating applications. The completion of this package is mandatory for all contractors to be selected as readers. (12
U.S.C. § 4703(c); 12 U.S.C. § 4712(b)). Contractors are not required to respond to this collection of information unless it
displays a currently valid OMB number. Generally, information submitted in response to this package shall be maintained
to insure confidentiality as required by 5 U.S.C. § 552(a), except to the extent that disclosure of such information is
permitted pursuant to 5 U.S.C. § 552(a). The estimated average burden associated with this collection of information is 45
minutes. Comments concerning the accuracy of this burden estimate and suggestions for reducing this burden should be
directed to the Department of the Treasury, Community Development Financial Institutions Fund, 601 13th Street, N.W.,
Suite 200 South, Washington, DC 20005.
OMB Approval No. 1559-0011
CDFI–0016

CDFI-0016