Summary Application Comments

Author	Topic	Sub-Topic	Q(s) #	Comments	Resolution
Cornerstone Group	Burden	Time		The amount of time required to effectively and thoroughly complete the Application far exceeds the 175 hours estimated by the Fund.	Comment not accepted. The time to complete estimate is based on the median of the self-reported completion times from the previous year's applicants. This number has actually been reduced to 170 hours for the 2007 application, as this was the median of the response times reported by the 2006 applicants. This particular commentator may have been an outlier.
Costal Enterprises Inc.	Burden	Time		The Application process requires a very large effort requiring substantially more staff time and thirds-party cost than may be necessary.	No action necessary. The commentator is making an observation, not suggesting a specific change. The application is necessarily rigorous -- as it must be in a program where applicants can apply for awards as large as $150 million. Nonetheless, the CDFI Fund engages a process after each allocation application round to review the entire application, and makes every effort possible to limit the length of the application and the effort required to just what is minimally required. Additionally, the CDFI Fund has engaged this process of soliciting public comments for just that purpose of ensuring an efficient application. The median resopnse time actually decreased from 175 hours to 170 hours in the past two application rounds.
Opportunity Finance Network	Enhance Info Collected	Accountability of boards improvement		Putting teeth into the "accountability" requirements for Boards and Advisory Boards of community development entities (CDE)s	No action necessary. The commentator is referring to requirement contained in the CDE certification application, not the Allocation Application. That being said, there is already a question (#41) in the management capacity section solely dedicated to the accountability of the Applicant CDEs to the communities in which they conduct their activities. This question was strengthened significantly in the 2006 round application.
Costal Enterprises Inc.	Enhance Info Collected	Change to Section Structure		An executive summary in each of the four major Application sections would be helpful to applicants to have an opportunity to present their over all plan and useful to reviewers to have a context for the details provided in the remaining questions.	Comment partially accepted. While the CDFI Fund deemed a narrative executive summary at the beginning of each major section generally redundant and unnecessary, the CDFI Fund did agree that it would be useful to include an executive summary in the Business Strategy section of the 2007 Application.
Cornerstone Group	Enhance Info Collected	Charts		The online charts are excessively time consuming. It would be more efficient to permit the uploading of Excel charts.	Comment not accepted. While allowing Applicant's to upload charts could be slightly (though not significantly) more time efficient for the applicant, it would make it difficult if not impossible to automatically validate the format and the accuracy of such data across the various tables. It is critical that this data come to the Fund validated and internally consistent.
Novogradac	Enhance Info Collected	Clarification of existing question	Q26	One of the sub-sections of Q. 26 inquires about an applicant's intention to reinvest interest, dividends, or other profits received from QEI proceeds. We request clarification as to what interest, dividends or other profits the Fund is referring to. Is the questions referring to interest income earned on QEIs invested in the applicant that have yet to be deployed as a QLICI? or is the question referring to interest, dividends or other profits earned on QLICIs financed by QEIs?	Comment accepted. Changed "QEI proceeds" to "QLICI" in old Q26, which is now Q25.
Cornerstone Group	Enhance Info Collected	Discrepancies between on-line and hardcopy	Q14	The formatting of question 14 differed between the “hardcopy” and the actual online application. For instance, the hardcopy requested the selection of all descriptions that apply, but the only version permitted the selection of only one choice.	No action necessary. The commentator description of the formatting of Q14 is incorrect. Q14 in both the hardcopy and online versions of the Application the instruction is to choose only one option, which is the correct format.
Costal Enterprises Inc.	Enhance Info Collected	Discrepancies between on-line and hardcopy		There are many questions that have information requested that is not obvious until a potential applicant can use a live application that allows for "click-through" to test to see if any additional parts of the question are then reveled.	No action necessary. The commentator is making an observation, not suggesting a specific change. This online application is structured this way to show each Applicant only the questions it must answer, and that way not burdening and confusing Applicants with wading through questions they do not need to answer. The CDFI Fund makes every effort to minimize the time between the release of the paper and online versions of the Application, but a gap is sometimes unavoidable. Generally, applicants will have at least 75 days with the paper application, including 45 days with the electronic application -- plenty of time to "plug and play" as necessary before submitting the final version to the Fund.
Novogradac & Coastal Enterprises Inc.	Enhance Info Collected	Formating	Q18(b)	We believe that requiring the applicant to indicate how each borrower will qualify for each feature is not practical and is burdensome as it assumes or implies that there is a specific criterion in place for each loan term. We request the Fund to remove the requirement that each narrative be distinct and unique.	Comment not accepted. The CDFI Fund has found through past experience, that it must require distinct narratives for each specific flexible or non-traditional product or feature to elicit full and comprehensive narrative discussion for each product or feature proposed by the Applicants. The requirement will remain for the 2007 application.
Costal Enterprises Inc.	Enhance Info Collected	Formating	Q26	It would be very helpful if applicants had the ability to input the representative projects into either a chart format or use an Excel spreadsheet. This would make this critical portion much easier and faster as well as more readable for the reviewers.	Comment not accepted. In prior applications, the CDFI Fund provided a table for Applicants, that had indicated a general pipeline of transactions in Q23, to input their potential transactions. However, the CDFI Fund eliminated that Table, as it found that data in that format not very useful (applicants tended to input transactions in the table and not discuss them). The current format, which encorages narrative discussion, will be retained.
Costal Enterprises Inc.	Enhance Info Collected	Formating	Q44	It would be very helpful for previous NMTC awardees if there was some way to link the data in the CDFI’s existing database to the application so that such data as the individual project Award Control Numbers and amounts could be more easily input with less chance of making input errors.	TBD. The CDFI Fund will investigate the technical and security feasibility of providing this feature with the 2007 Application.
Costal Enterprises Inc.	Enhance Info Collected	Formating	Qs 17 & 18	We suggest combining the questions into just one, since they are somewhat redundant with one another. We recommend that Q 17 be worded so that the information requests in Q18 can be easily outlined and incorporated in just one part.	Comment partially accepted. As outlined in the response to the comments regarding Q18(b) specifically, the CDFI Fund has deemed it important to require Applicant's to provide distinct and unique narrative discussions of each product and product feature. However, Q17 (Q15 in the 2007 Application) will be modified to clearly request that the Applicant provide a response in the form of an executive summary, and to not repeat there information that is requested and discussed in detail in other Business Strategy section questions, thereby eliminating the temptation to provide redundant information in different question responses.
Cornerstone Group	Enhance Info Collected	Formating		The online application should allow bold, underline, italics, etc.	TBD. The CDFI Fund will investigate the technical feasibility of providing this feature with the 2007 Application.
Novogradac	Enhance Info Collected	Investor Leverage Model	Q50	If an applicant checks yes to Q.50 in the application, only the investment partnership that will directly provide the QEIs to the applicant are to be listed in Table E1, even if it is a to be formed entity. Our concern is if an entity does not exist, how can it be required to issue a commitment letter? We recommend that the Fund modify the requirement so that investors and lenders would provide their commitment letter to the applicant and indicate in the commitment letter that the investor/lender understood that the applicant was applying for an allocation and that their commitment to provided financing would be created by the applicant upon receipt of an allocation.	Comment partially accepted. The CDFI Fund already requires Applicant's to attach letters from the upper-tier investors in a leveraged investment partnership. Obviously, the CDFI Fund understands that an unformed entity cannot issue letters, and does not require it. The CDFI Fund requires that the Applicant not enter these upper-tier investors on Table E1, but rather discuss them in detail in Q50 (Q49 in the 2007 Application). The CDFI Fund will modify the language in the TIPs to Q49 and Table E1 to more clearly instruct the Applicants as to how to enter data on Table E1 and in the narrative of Q49. For investment partnerships that do yet exist, the Applicant's will be directed to enter a generic placeholder name for the partnership in Table E1.
Costal Enterprises Inc.	Enhance Info Collected	New Criteria - All Sections		Each section should ask for specific data related to any such applicants’ previous NMTC experience, so reviewers could then take into account the applicant’s previous NMTC track record. This would allow an applicant to show how an additional award will enhance its program capacity, in-place org infrastructure, and existing NMTC community development partner network.	Comment not accepted. The commenter did not provide a compelling argument for changing the way the CDFI Fund asks for information regarding Applicant NMTC track records. The 2007 Application has, as have its predecessors, questions in each sections that ask for information regarding Application track records, and for prior allocatee's is it appropriate and required to discuss past NMTC activities in these questions. No action or response required.
Costal Enterprises Inc.	Enhance Info Collected	New Criteria - Busines Strategy & Community Impact		In the Strategy and Impact sections, consider a place to discuss beneficial impacts derived from the NMTC by allocatees that underwrite projects in a way that assesses environmental sustainability benefits, as well as more traditional economic and community (social equity) benefits.	Comment accepted. The CDFI Fund has added an item in Q33(a) for Applicant's to specifically indicate if they propose to "create environmentally sustainable outcomes".
Opportunity Finance Network & Novogradac	Enhance Info Collected	New Criteria - Business Strategy		The CDE has a track record of putting its own capital at risk in the market in which it would use a NMTC Allocation, or a similar market. Using this criterion would help measure an applicant's CDE commitment to bringing capital to qualified communities and building permanent, rather than short-term, deal-related, presence there.	No action necessary. There is already ample opportunity in the Application to discuss the Applicant track records of putting their own capital at risk. No action or response required.
Opportunity Finance Network	Enhance Info Collected	New Criteria - Business Strategy		The CDE has a track record of "trailblazing" projects that are the first to bring new investment into opportunities that other miss and would likely use its NMTC allocation for the same kinds of projects. This criterion would allocate NMTCs to CDEs that have proven ability to enter the New markets for which the program is named.	No action necessary. There is already ample opportunity in the Application to discuss, and get credit for, Applicant track records of "trailblazing" in Q20(c) and Q21(c). No action or response required.
Costal Enterprises Inc.	Enhance Info Collected	New Criteria - Capitalization Strategy	Q56	We suggest that a more meaningful question for the CDFI fund and application reviewers might be worded along the lines of "How are Applicant's fees and fee structure facilitating the maximization of the positive impacts for Low-Income people being derived from the NMTC program?"	Comment accepted. The CDFI Fund has added a sub-question bullet point to illicit this information in Q56 (Q55 in the 2007 Application.
Costal Enterprises Inc.	Enhance Info Collected	New Criteria - Community Impact	Q29	We believe the limitation for QALICBs to actually become SBA HUB Zone-certified should be dropped and additional criteria addressing the need soft rural areas should be added.	Comment partially accepted. The CDFI Fund is not re-introducing SBA Hub Zones as an item on the Q29. This was included in the early rounds of the program, but this designation was not sufficiently narrow to limit it to areas of higher distress. Instead, in an effort to target more rural communities, the CDFI Fund did add certain programs administered by the Department of Agriculture to the list in Q. 29.
Costal Enterprises Inc.	Enhance Info Collected	New Criteria - Community Impact	Q33	We suggest that this section be worded to allow for more qualitative indicators that often tell more about the real-world impacts than the numbers might represent.	No action necessary. There is already plenty of room in Q33 to discuss impacts in qualitative terms. The question specifically asks the Applicant to also be sure to include quantification of the impacts. Without such instruction, Applicant's tend to not attempt to estimate the quantitative impacts resulting from their activities. No action or response required.
Costal Enterprises Inc.	Enhance Info Collected	New Criteria - Community Impact	Q54	We suggest adding a bullet that asks for information on the qualitative economic benefits shared amongst the various entities noted.	No action necessary. The question is fundamentally a quantitative question. There is opportunity to discuss qualitative economic benefits in the Community Impact section. No action or response required.
Opportunity Finance Network	Enhance Info Collected	New Criteria - Community Impact		Awarding "priority points" in the community impact section of the application to CDEs with a strong focus on and track record of stimulating new investment.	Comment not accepted. The CDFI Fund only provides priority points for two areas: track record of serving disadvantaged businesses and communities; and commitment for making investments in unrelated entities. Both of these are mandated by statute. The CDFI Fund has chosen not to include exta-statutory priority points. That being said, Q49 in the Capitalization Strategy section already specifically addresses the Applicants' focus on bringing new investors to community development investing.
Opportunity Finance Network	Enhance Info Collected	New Criteria - Community Impact		The CDE's projects would create jobs to be filled by residents of the low-income community and/or provide space for locally-owned, minority or women owned businesses or nonprofit tenants, demonstrating true commitment to the residents of the community.	No action necessary. Q33 in the Community Impact section already asks and evaluates these questions. No action or response required.
Novogradac	Enhance Info Collected	New Criteria - Priority Points		We also believe the amount of priority points given for the statutory preferences in IRC 45D (f)(2) are too high compared with the total points in the Business strategy section. We recommend that the points be lowered to 5 total for applicants that satisfy either statutory preference rather than 5 points each.	Comment not accepted. The commenter appears to not fully understand the Allocation Application scoring. The Priority Points are not a part of the Business Strategy section, thus the total points of priority points relative to the total point of the Business Strategy section is irrelevant. For final ranking of applications purposes, only half of the total Priority Points are added to the Business Strategy and Community Impact section scores, thus seemingly mitigating the commenter's concern. Additionally, because the priorities are statutorily mandated, the CDFI Fund would not be able to implement the commenter's suggestion that priority points be given for one or the other of the priority categories. No action or response is required.
Novogradac	Enhance Info Collected	Redundancy amoung application questions	Qs 9, 32, 33 & 57	We believe that the following questions are redundant and could be combined or removed: Q. 9 and 57 ask for the same information about the Applicant's intention to transfer any portion of its NMTC allocation to one or more subsidiary entities. Q. 32 and Q. 33 Economic Impacts: the second bullet point of Q. 32 and Q. 33(a) appear to be asking the same info about quantifying the projected results of the impacts achieved by the QLICIs described earlier.	Comment partically accepted. The CDFI Fund concurs that Q9 and Q57 are redundant and has eliminated Q9 for the 2007 Application. The second bullet point from Q32 and Q33(a), however, are quite different. Q32 asks the Applicant to discuss ALL job creation/retention resulting from its NMTC activities, while Q33(a) asks specifically what subset of those jobs will be directed to low-income persons or the residents of low-income communities. No action or response required.
Novogradac	Enhance Info Collected	Revise predom. financing activity categories	Q14	We believe the choices given for the Applicant to indicate its predominant financing activity are limiting and don't fit every business category. We recommend the Fund add an activity listed as other that the applicant can clarify if it has an activity that doesn't fall into one of the categories provided.	Comment partially accepted. The CDFI Fund holds that by limiting the number and specificity of categories in Q12 it obtains, while more generalized, a more useful, meaningful and comparable data set. However, the CDFI Fund did add one sub-category under Real Estate Financing for Hospitality. No further action or response required.
Costal Enterprises Inc.	Enhance Info Collected	Targeted Populations	Q22'c	We feel it is essential to capture the true original intent and mission of the NMTC program to include "Disadvantage People" in the target entities being served	No action necessary. This comment pertains to the Targeted Populations regulations, and related guidance, that are to be issued by the IRS and the CDFI Fund, respectively.
Costal Enterprises Inc.	Enhance Info Collected	Targeted Populations		General suggestion: Make sure the program elements targeting areas of higher distress are compatible with the targeted populations rules. This may mean that the targeted populations provisions should be allowed to override the targeted areas provision.	Comment accepted. An item for Targeted Populations has been added to the list of areas of higher distress in Q29.
Novogradac	Enhance Info Collected	Track Record - Exhibit A	Qs 22, 23 & Exhibit A	Q. 22 and Q. 23 We recommend that the CDFI Fund allow applicants that do not have a track record of QLICI activities to complete Exhibit A for their loans or equity investments that would not qualify as QLICI but are similar to the proposed NMTC activities. We also recommend allowing applicants to complete the tables in Exhibit A for which the applicant had not directly made equity investments or originated loans themselves. We further recommend the table be modified to include an additional checkbox for the applicant to make the distinction between activities for which the applicant had originated or for which it had capital at risk.	Comment not accepted. To limit confusion and obtain the clearest responses to Applicant track record questions, the CDFI Fund specifically limited the data entered into Exhibit A to QLICI type activities, and direct all other track record activities to be described and discussed in the narrative to Q23 (Q21 in the 2007 Application). The CDFI Fund has also been very clear that just because an Applicant is unable to enter data in Exhibit A, it can still receive an excellent score for its track record. Additionally, there is ample opportunity in Q22 and Q23 to discuss the Applicant's track record of investment where its own capital was at risk. No action or response required.
Opportunity Finance Network	N/A	"Mission Driven" Organization definition		The Fund's public relations and allocatee materials should not include municipal organizations as "mission driven" along with CDFIs and related entities, as public and municipal CDEs have distinctly different goals and accountabilities.	No action necessary. This comment is a policy issue and not an application issue. But that being said, the Fund does separately release data on the municipal organizations, so that any party interested in separating that information from the general data about "mission driven" organizations can certainly do so as part of their own analysis and reporting.
Costal Enterprises Inc.	N/A	% of QEIS in QLICIs		We favor changing the 85% rule provisions to allow for expanded reserves and allowances for debt repayment in the case of QLICIs in small and medium enterprises as a way of stimulating the use of the NMTC program for the needs or such small and medium ventures. Specifically, we believe the 85% rule should be lowered to 65% in this area (small and medium enterprise loans or investments only). In all cases, we recommend disconnecting the subject of original QEI investment from re-investment and have the % to which an applicant commits in this regard apply only to the initial placement of its capital.	Comment partially accepted. The first comment (changing the 85% rule) relates to the IRS regulations, not the CDFI Funds' application. The CDFI Fund concurs with the second comment (regarding initial placement of capital), and though not relevant to the application, this point will be conveyed in the companion guidance document to the Allocation Agreement.
Kitsap County NMTC Facilitators	N/A	CIIS and TLR		We would like to suggest that the Agency fill in information contained in the prior year's CIIS report so that the CDE does not have to re-answer all the questions. Also, it would be helpful if the TLR program were to allow of the user to print out the "in progress" TLR report via PDF.	No action necessary. This comment is a CIIS/TLR issue and not an application issue. No action or response is required.
Novogradac	N/A	Clarification of existing question	Q55	It is unclear whether an applicant is required to meet the % of QEIs it designated in Q. 55 for future reinvestment of QLICIs. For example, if an applicant's designated percent in 100, to require the applicant to reinvest 100 of any return of capital is unnecessarily burdensome and may not be possible depending on the amount and the types of available investments. This requirement if causing transactions that require amortization of a loan to be infeasible and preventing viable transactions form closing. We recommend that if an applicant receives scheduled periodic payments that are returns of principal, the aggregate principal payments received are considered to be continually invested up to an amount that is not more than 15% of the QEIs received.	Comment accepted. Though not an application issue as much as an Allocation Agreement issue, the CDFI Fund concurs and will update the companion Q&A document to reflect this position.
Novogradac	N/A	Common Enterprise		We suggest changing the wording of the applicable paragraphs in the NOAA and in Q&A to the following: "This prohibition, however, will not apply when an investor: (I) makes QEIs in one or more Allocatees (or Subsidiary allocatees) from the same allocation round or any prior rounds; (ii) was not an Affiliate of, or a member of a common enterprise with, any of the Allocatees (or Subsidiary Allocatees) prior to making the QEIs except if said status arises solely form making or having made QEIs on the terms described in the clause (iii) hereof; and (iii) has and/or obtains Control of such Allocatees or ( Subsidiary allocatees) solely through common ownership and/or control of their management and/or investment decisions rotated to QEIs described in clause (i) hereof.	TBD. This comment is an issue that will be taken under advisement as the 2007 NOAA is drafted.
Novogradac	N/A	Controlling Entity information	Qs 3, 25 & 30	Q. 3, Q. 30, and Q. 25 we recommend that the NMTC Allocation Application provide for either management or investment control, not both, consistent with the 2005 Allocation Agreement Q&A. In addition, the requirement that the Controlling Entity currently control the Applicant retroactively imposes a requirement on Applicants who received allocations in prior rounds where this did not apply. We request that the requirement not be applied retroactively.	Comment not accepted. The CDFI Fund had to tighten its rules when it learned that some organizations had idenified "Controlling Entities" that only had nominal or cursory controls over their oprations.
Novogradac	N/A	Investments in unrelated businesses	Q28	Q. 28 We recommend that the related entity test be performed before the CDE makes its initial related party equity QLICI in a QALICB. We would like to further clarify that by before we mean before the initial QLICI is made but after the QEI investor is admitted into the CDE. We believe that the statutory requirements in IRC 45D (f)(2)(B) would allow this.	TBD. This is not an application issue, per se. It is an interpretation issue. The CDFI Fund will continue to take this under advisment and will provide any re-interpretation of this provision in the companion Q&A document that accompanies the application.
Novogradac	N/A	Scoring and Debriefing letters		We believe that the Fund should provide more detailed information related to the scoring process and its preferences in the Application or NAA. We recommend a debriefind letter that includes the score received for each section and overall rankings be sent to each applicant rather than only being sent to Applicant's that did not receive an allocation.	No action necessary. This comment is a debriefing issue, not an application issue.
Kitsap County NMTC Facilitators	N/A	TLR		Allow the CDE to attach a Word document, or allow the CDE to inset comments into the TLR regarding the impact of the NMTC project	No action necessary. This comment is a CIIS issue, not an application issue.
Kitsap County NMTC Facilitators	N/A	TLR Reporting Cost		The cost of operation required to provide the information requested by the Fund per NMTC project of $500. If recommendations are implemented then we estimate that it would reduce the cost of operations for us to $300.	No action necessary. This comment is a CIIS/TLR issue and not an application issue. No action or response is required.
Costal Enterprises Inc.	Necessity of Info	Elimination of Question	Q59	We suggest that this question be eliminated. If the CDFI Fund is interested in funding an allocatee, the best practice would appear to be to contact the potential applicant to negotiate a different amount.	Comment not accepted. The CDFI Fund deems this to be a useful question and reasonable question. Applicant's should have a strong understanding of their proposed NMTC program, such that they would know at what level it becomes economically or otherwise infeasible. It is impractical to negotiate this point, and could lead the Fund to charges of inconsistency among applicants.
Cornerstone Group	Necessity of Info	Impact Projection Methodologies and Assumptions	Qs 31, 32, 33	Certain questions on the Application require information that is not truly calculable, and require significant guesswork. Community Impact Section Q 31-33 require methodology and assumptions used to determine the fields. While important, the lack of definitive standard invites pipe dreaming and puffery. [Chris - the respondent doesn't seem to understand that we are looking not for specific pre-determined "methodologies and assumptions", but rather, we simple need to see the methodologies and assumptions they used.]	No action necessary. The respondent doesn't appear to fully understand the Community Impact questions 31-33. While calculating community impacts can be challenging and somewhat inexact (requiring some estimation), the CDFI Fund deems it critical that Applicant's make an effort to describe and quantify their proposed community impacts. Specific pre-determined methodologies and assumptions are not required, but rather the CDFI Fund simply requires that the Applicant describe and explain the methodologies and assumptions that they have used. The questions will be retained. No action or response is required.
Novogradac	Necessity of Info	Impact Projection Methodologies and Assumptions	Qs 31, 32, 33	We recommend that the Fund identify acceptable standards for calculating community impact. These standards would help Applicants more properly calculate the community impact and the Fund would receive applications with more comparable calculations.	Comment not accepted. The diversity of business strategies, product types, and geographies make it impossible to proscribe a common set of methodologies and assumptions for calculating community impacts. The methodologies and assumptions used for calculating community impacts are not compared across applications, but rather methodologies and assumptions are evaluated based on their reasonableness in the context of the individual application.
Cornerstone Group	Solutions to Burden	Submission Process		On the deadline due to the influx of applications, please embed in the process a waiver- or exception- for the period of time that the applicant is unable to access due to the technical glitches such as overloaded systems.	No action necessary. The CDFI Fund already has in place a process for examining late application submissions for technical issues. That being said, applicants are also warned in several places not to wait until the last hours to submit their applications, as that's when traffic is the heaviest.