2013-14 NMTC App - Justification for Change

Non-substantive Change Justification Memo
Community Development Financial Institutions Fund
New Markets Tax Credit Program 2013 Application
OMB Paperwork Reduction Act No.1559-0016
The Community Development Financial Institutions Fund (CDFI Fund) requests PRA clearance
of the New Markets Tax Credit application form by July 8, 2013 so that the application can be
released to the public on July 15, 2013. The CDFI Fund requests approval of the document
based on the changes being non-substantive and non-material. The CDFI Fund will combine two
rounds of funding (2013 and 2014) using this application. While not impacting the application form
itself, because program applicants would otherwise have to fill out two separate 2013 and 2014
applications, we can report that the public burden is cut in half over the two year period.
The PRA number for this application was renewed on March 29, 2011 with an expiration date of
March 31, 2014. The CDFI Fund limited changes to reflect updated deadlines and data
collection periods and instructions, clarified question wording, and “tips”. There is one new subquestion element added, related to an IRS rule regulatory change - “TD 9600”. The new question is
simply an additional sub-question (#13(b)) that requires entering two percentage estimates regarding
projected investments in real estate businesses. Previously applicants did not need to break out this
information to this level. This does not require any additional record keeping and should not have a
material impact on the burden of completing the application, given that applicants previously needed
to report the overall percentage of investments that would go to real estate businesses. Further, only
applicants that plan to invest in real estate project need to provide this information.
Reflecting the limited changes that are proposed, the application includes forty-five questions
and incorporates several exhibits that were approved last year. Applicants submit this
application via an electronic form so that the CDFI Fund can evaluate applicants for New Market
Tax Credit allocation awards. The CDFI Fund collects this information once per funding round.
The annual requirements for completing the application and updated deadlines are
communicated via a Notice of Allocation Availability published in the Federal Register and
through various agency outreach materials posted on the CDFI Fund website.
In summary, the application represents a non-substantive, non-material change from the prior
year. We appreciate your prompt approval, so that we may make the application available to the
public on schedule. We would be happy to discuss any questions or concerns you may have.