CDFI Program and NMTC Program Annual Report including CIIS

FY 2013
Allocatee Institution Level Report
Instructions
CIIS 11.0
August 23, 2013

TABLE OF CONTENTS
GENERAL INFORMATION ABOUT THE INSTITUTION LEVEL REPORT (ILR) ......................... 1
REPORTING PERIOD ...................................................................................................................... 1
CIIS REQUIRES RESPONSES TO ALL QUESTIONS ............................................................................ 1
COMPLETING TABLES..................................................................................................................... 1
FINANCIAL STATEMENTS ................................................................................................................ 3
DATA CLEANSING .......................................................................................................................... 3
CERTIFY THE ILR........................................................................................................................... 4
CIIS HELP DESK ........................................................................................................................... 5
ORGANIZATION CONFIRMATION ................................................................................................ 6
ALLOCATION PROFILE CONFIRMATION ............................................................................................ 6
CONFIRMATION OF MYCDFIFUND ORGANIZATION PROFILE ............................................. 7
I ORGANIZATIONAL INFORMATION............................................................................................ 8
A. BASIC INFORMATION .................................................................................................................. 8
B. ORGANIZATIONAL STRUCTURE / AFFILIATION .............................................................................. 8
C. GEOGRAPHIES FINANCED DURING THE REPORTING PERIOD ........................................................ 9
D. HUMAN RESOURCES DEDICATED TO THE ALLOCATEE'S NMTC PROGRAM ................................... 9
II FINANCIAL POSITION .............................................................................................................. 11
A. LENDING/INVESTING POOL ....................................................................................................... 11
B. ADDITIONAL FUNDS LEVERAGED BY THE ORGANIZATION............................................................ 18
C. QLICI COMMITMENTS ............................................................................................................. 19
D. REPORTING PERIOD SUMMARY FINANCIAL INFORMATION .......................................................... 19
III LOAN PURCHASES ................................................................................................................. 20
IV FINANCIAL COUNSELING AND OTHER SERVICES (FCOS) .............................................. 22
V BETTER RATES & TERMS ...................................................................................................... 23
VI IMPACTS .................................................................................................................................. 24
VII DATA COLLECTION SYSTEMS............................................................................................. 24
VIII CREDIT REPORTING AGENCIES USED ............................................................................. 25
IX ILR FEEDBACK........................................................................................................................ 25
X IRS COMPLIANCE QUESTIONS .............................................................................................. 25

FY 2013 Allocatee Institution Level Report Instructions

FY 2013 Allocatee Institution Level Report
Instructions
GENERAL INFORMATION ABOUT THE INSTITUTION LEVEL
REPORT (ILR)
Reporting Period
The reporting period for the FY 2013 ILR is the Organization's fiscal year ending in
2013. Unless otherwise noted, all questions in this ILR refer to the reporting period.

CIIS Requires Responses to All Questions
Your Organization must provide a response in every “active” data field in order to submit
the ILR. Data fields that are not required are “grayed out” on the screen. When a User
leaves a page, CIIS provides a notice identifying required responses that are missing.
CIIS also provides a summary Status Page to verify the completion of each ILR section.
When appropriate, CIIS will allow “Don’t Know” and/or “Not Applicable” as a valid
response. If applicable, these options will appear in a dropdown menu or radio button.
Don’t Know: Use “Don’t Know” when the question is valid for the Organization,
but the answer is unknown or unavailable. For example, if the Organization
provides technical assistance but does not track the number of clients, “Don’t
Know” is the appropriate response.
Not Applicable: Use “Not Applicable” when the question is not valid or not
applicable to the Organization. Please do not use “Not Applicable” for a “$0” or
“0” response. For example, if the Organization purchases loans, but did not
purchase any loans during the reporting period, the number of loans purchased
is “0.” However, if the Organization does not purchase loans at all, then the
number of loans purchased is “Not Applicable.” Furthermore, “Not Applicable”
does NOT mean unavailable. (Use “Don’t Know” for unavailable.)

Completing Tables
Tables are used for questions where the number of responses may differ for each
Organization. For example, in the Non-QEI Investment Capital Table, a User completes
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one row for each capital source that is applicable to that User’s Organization. General
Table functionality is described here.
Add Row: Click the "Add Row" button to add a new row to the Table. For each
row, CIIS will provide a pop-up data dialog box. After completing the data dialog
box for the specific row, click the "Add" button within the data dialog box to add
the new responses to the Table OR click the "Cancel" button to delete the
responses.
Modify Row: Select the row to be modified by clicking the radio button in the left
column of the Table. You may only modify one row at a time. Click the "Update
Row" button to re-open the data dialog box. Enter any changes in the data
dialog box and click the "Update" button to update the Table with the new
responses OR click the "Cancel" button to leave the data unmodified.
Delete Row(s): Select the row(s) to be deleted by clicking the radio buttons in
the left column of the Table. Click the "Delete Row" or “Delete Rows” button to
remove the row(s) from the Table.
Complete Table: CIIS determines that a Table is complete when the User clicks
the “Please Check Here to Confirm that the Table is Complete” check box that
accompanies each Table. If your Organization does not have any information to
enter into a Table, click the check box and skip to the next question.
Users Must Complete Tables: The Fund will not consider the ILR to be complete if the
check box is clicked on an empty Table when the Organization has information that
should have been included in the table. During the cleansing process, the Fund will reopen the ILR and ask the Organization to complete the Table and re-submit the ILR.
The Fund will not consider the ILR submitted until all applicable Tables are complete.
Managing Pop-Ups: The pop-up data dialog boxes open as new windows. If you
“lose” the data dialog box on your screen prior to clicking “Add,” “Update,” or “Cancel,”
please check whether the window is “hidden” behind other windows or programs.

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Financial Statements
You must submit the FY 2013 Financial Statements used to complete the ILR to the
Fund. FY 2013 is your fiscal year ending in 2013.
Submitting Financial Statements:
•
Attach an electronic file to the CIIS submission (“Financial Statements” on CIIS
Home Page Menu) OR
•
Fax to the Fund at (202) 622-7754.

Data Cleansing
The Fund reviews and “cleanses” all ILRs after they are submitted. Cleansing is the
process of comparing the ILR data to the Organization’s year-end Financial Statements
including related notes and other questions within CIIS. It is important that each
Organization enter data that is supported by these sources. During the cleansing
process, the CIIS Help Desk will contact the Organization with any questions about the
ILR submission. At a later date, the Fund’s Certification, Compliance Monitoring and
Evaluation (CCME) Unit may contact the Organization with questions related to
compliance with Assistance Agreement performance measure targets.
Your ILR is not final until your Organization’s Financial Statements have been received
and the ILR has been cleansed.

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USE NOTES: CIIS provides a Notes field for each ILR question. Users may enter and
edit notes by clicking the Notes icon ( ) next to the appropriate field. Please use the
Notes field to explain financial entries that are not clearly identified in the Organization’s
Financial Statements and related notes. Also use the Notes field to explain other
responses that you believe the Fund may question. The Notes are a great help to both
the Fund and the Organization during the cleansing process.

Certify the ILR
The User must Certify the ILR upon completion.
CIIS has a single Certification process for the ILR and TLR. Users will be able to Certify
the ILR when:
• The ILR is complete. (On the CIIS Home Page, select “ILR” menu
“ILR Status” to
check for completion.)
• The TLR (if applicable) is complete.
- All loans, investments, and advance purchase commitments made by the Allocatee
and any Sub-Allocatee(s) funded by Qualified Equity Investments (QEIs) that were
outstanding at any time during the reporting period are Pre-Certified.
In order to certify and submit the ILR, all “active” questions must be complete. Users
may review the ILR completeness by selecting “ILR Status” from the “ILR” Tab on the
CIIS Home Page.
On the certification page, the Fund will request permission to release your
Organization’s data publicly as follows:
The CDFI Fund plans to release CIIS ILR and TLR data to the public. The Fund will not
release data that is only collected for Compliance purposes. To protect the privacy of
your borrowers/investees, the Fund will NOT release the identities of your
borrowers/investees. The Fund seeks your permission to release your CDE’s identity
with its ILR and TLR. If you do not provide such consent, the Fund will release your
organization's ILR and TLR, but will not release your organization’s name or any other
data that can be used to identify your organization.
a. Do you give the CDFI Fund permission to release your organization’s identity when
it releases your organization’s ILR data for this and previous reporting periods? (YES
/ NO)
b. Do you give the CDFI Fund permission to release your organization’s identity when
it releases your organization’s TLR data for this and previous reporting periods? (YES
/ NO / My organization has not completed a TLR)
When the ILR and TLR, if applicable are complete:
• Select the “Certify” tab on the CIIS Home Page.

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•
•
•
•
•

Confirm that the ILR and TLR (if applicable) are marked as complete.
Respond to the ILR and TLR Release questions.
Select “Next” button
Read Certification Statement and select appropriate checkbox to agree with the
statement.
Select “Certify CIIS Reports” button.

CIIS Help Desk
Phone Number: (703) 373-1516
Fax Number: (703) 236-2399
E-Mail: [email protected]

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ORGANIZATION CONFIRMATION
Allocation Profile Confirmation
Award Control Number / QEI Confirmation: In order to enter the ILR, Users must
confirm the Allocatee’s Award Control Number(s) and all Qualified Equity Investment
Identifiers (QEI IDs) for QEIs that were issued by the Allocatee and any SubAllocatee(s) prior to the end of the current Reporting Period.
The accuracy of this information is critical for completing the ILR. If any
inaccuracies exist, please LOG OFF CIIS immediately and remedy the errors
before continuing.
Correcting Fiscal Year End Date in myCDFIFund:
• Log on to myCDFIFund Organization Account.
• Select “Help” tab.
• Select “How do I update my Organization FYE” link.
• Download and complete the Organization FYE change form.
• Fax the completed form per instructions.
• The Organization will be notified when the request is complete.
Adding QEIs:
• If a QEI that the Allocatee or Sub-Allocatee issued prior to the reporting period
end date is not listed under the corresponding Allocation, add the additional QEIs
in the Allocation Tracking System (ATS).
Correcting Award Control Number:
• If any errors exist in the Award Control Number(s) or QEI information listed,
contact the Fund at [email protected]. Please reference the ATS Instructions
Manual for details on requesting changes to finalized QEIs from the Fund.
Updates should appear in CIIS on the following business day. You may continue
the ILR only AFTER the updated information appears in CIIS. If you proceed
before then, your ILR may be invalid.

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CONFIRMATION OF MYCDFIFUND ORGANIZATION PROFILE
In order to enter the ILR, Users must confirm the following data fields provided from
their Organization’s myCDFIFund Profile. Any errors must be corrected in myCDFIFund
prior to entering the ILR.
The profile information represents the Allocatee. The profile information does not
represent Parent organizations, Sub-Allocatees, or other affiliated organizations.
(1) Date of Organization’s Fiscal Year End:
(2) Organization's Type:
(3) Organizational Structure:
(4) Year of Organization’s Incorporation:
(5) Year Organization Began Financing Activities:
** If the information is INCORRECT or BLANK, the data must be corrected prior to
entering CIIS.
Correcting Organization Profile data in myCDFIFund (except INCORRECT Fiscal Year
End Date – See Below):
• Log on to Organization’s myCDFIFund account.
• Select “Organization Profile” from left menu and sub-menu.
• Select the information from the dropdown menus.
• Changes to myCDFIFund will appear in CIIS on the next business day.
Correcting Fiscal Year End (FYE) Date in myCDFIFund:
• Log on to myCDFIFund Organization Account.
• Select “Help” tab.
• Select “How do I update my Organization FYE” link.
• Download and complete the Organization FYE change form.
• Fax the completed form per instructions.

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•

The Organization will be notified when the request is complete.

I ORGANIZATIONAL INFORMATION
A. Basic Information
Contact Information
This section displays information that the Fund currently has on file for the Allocatee in
the myCDFIFund organization profile.
• Street Address
• City
• State
• Zip
• Website Address (if available)
** If the information is INCORRECT or BLANK, please correct the data in
myCDFIFund. You may continue to complete the ILR PRIOR to the updates
appearing in CIIS

1) Name of Person Responsible for Completing the ILR
Enter the name of the person from the Organization who is primarily responsible for
completing the ILR. This individual will be contacted if the Fund requires clarification or
explanations during the data cleansing process.

2) Telephone Number of Person Responsible (including Extension if
applicable)
Enter the telephone number of the person entered in Q.1.

3) Email Address of Person Responsible
Enter the email address of the person entered in Q.1. Use all lower case letters, unless
the address is case sensitive.
• CIIS may pre-fill the response. If the pre-filled information is incorrect, enter the
correct information.

B. Organizational Structure / Affiliation
4) Is the Organization a "Faith-Based" Organization?
Select whether the Allocatee and/or any of its Sub-Allocatees are faith-based
Organizations.

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5) Did any QLICIs Made During the Reporting Period Finance or Provide
Services to any Religious Institution(s) or Faith-based Organization(s)?
Select whether any Qualified Low Income Community Investments (QLICIs) financed or
provided services to any religious institutions or faith-based Organizations during the
reporting period. This question pertains to the Allocatee, any Sub-Allocatees, and any
CDE investees.

6) Has or Does the Organization Intend to Use Any Other Tax Credit
Programs in Conjunction With Its NMTC Program Strategy?
Select whether the Allocatee and/or Sub-Allocatees have used, or intend to use, any of
the following programs in conjunction with its NMTC program strategy.
• Historic Tax Credit
• Empowerment Zone, Enterprise Community, or Renewal Community Tax Credits
• Other Federal Tax Credit Program
o Name of Other Federal Tax Credit Program
• State Tax Credit Program
o Name of Other State Tax Credit Program
• Local Tax Credit Program

C. Geographies Financed During the Reporting Period
Select whether the Allocatee and/or Sub-Allocatees used QEI proceeds to provide
financing in the geographic areas listed during the reporting period.

7) Which of the Following Geographic Areas were Financed by the
Allocatee's QEI Proceeds During the Reporting Period?
•
•
•
•
•
•
•
•

Appalachia
Colonias
Hot Zones
Lower Mississippi Delta
Native American Areas
Rural Areas
Major Urban Area
Minor Urban Area

D. Human Resources Dedicated to the Allocatee's NMTC Program
For each category, enter the Organization's full-time equivalent (FTE) resource
allocation at the reporting period end.
• Include the resources of the Allocatee, the Parent, any Sub-Allocatees, and any other
organizations that support the Allocatee’s NMTC strategy.
• Include all full- and part-time employees.
• Include contractors, consultants, and volunteers that perform ongoing operations.
• Exclude temporary employees.
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• Exclude professional services conducted outside of the office by third parties such as
accounting, bookkeeping, and legal counsel.
One FTE is a 35-hour or more work-week. In calculating the number of FTEs, part-time
employees should be combined.
Example (1): Two part-time employees that each work 17.5 hours per week should be
combined to count as one FTE. (17.5 hours X 2 = 35 hours)
Example (2): If a full-time loan officer spends 28 hours per week on lending activities
and 7 hours per week providing training, this person would count as .80 (=28/35 or
80%) FTEs Dedicated to Lending/Investing activities and .20 (=7/35 or 20%) FTEs
Dedicated to Development Services.

8) FTEs Dedicated to Lending/Investing
Enter the Organization's total FTEs dedicated to loan/investment underwriting and
outreach, loan administration, servicing, and collections at the reporting period end.

9) FTEs Dedicated to FCOS
Enter the Organization's total FTEs dedicated to Financial Counseling and Other
Services (FCOS) at the reporting period end.

10) FTEs Dedicated to Administration and Other Activities
Enter the Organization's total FTEs dedicated to any activities not covered in the
categories above, including finance, compliance management, human resources,
fundraising, policy, administration, and other overall management at the reporting period
end.

11) Total FTEs
CIIS will calculate and display the Total FTEs.

12) Consultant/Contractor FTEs
Enter the number of consultant/contractor FTEs included in Q. 11 Total FTEs.
Review the FTE numbers for accuracy. The Fund will determine the Organization’s
Total Employee FTEs by subtracting the Consultant/Contractor (Q.12) FTEs from Total
FTEs (Q.11).
Review the FTE numbers for accuracy. The Fund will determine the Organization’s
Total Employee FTEs by subtracting the Consultant/Contractor (Q.12) FTEs from Total
FTEs (Q.11).

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II FINANCIAL POSITION
For venture capital funds, all financial questions pertain to the investing entity(ies), not
the managing entity, unless otherwise noted.

A. Lending/Investing Pool
13) QEI Distribution Table
Purpose and Overview
Use the QEI Distribution Table to describe how the Allocatee and/or Sub-Allocatee(s)
used each QEI. The Table provides a snapshot of the Organization’s actual QLICI
investments as of the end of the reporting period.
Include actual QEI usage only. In previous versions of CIIS, the Fund collected actual
and projected QEI usages. Beginning with FY 2006, the Fund will collect actual QEI
usage only.
The information in the QEI Distribution Table is NOT used to measure the
Allocatee’s compliance with Section 3.2 of the Allocation Agreement. The Table
provides an overview of QEI use for analysis of the NMTC program as well as prepopulated data for the following ILR Tables: Q.14) Non-QEI Investment Capital Table;
Q.15) Investment Capital Summary Table; Q.20) Loan Purchase Table; and Q.23) QEIs
Used for FCOS Table.
QEIs
Each row of the Table represents one QEI that the Allocatee or Sub-Allocatee finalized
in ATS.
RQIs
Allocatees that have received repayments from prior QLICIs and have closed
reinvestment QLICIs should adhere to the following instructions to report such
transactions. Allocatees can create a Reinvestment Qualified Equity Investment (RQI)
ID for each allocation in ATS. The RQI represents the aggregate amount of repayments
received from prior QLICIs as of the reporting period end date.
There is one row in the table for the RQI. Allocatees should complete the QEI
Distribution Table for an RQI as if it were a QEI.
Table Layout: Each row of the Table represents one QEI that the Allocatee or SubAllocatee finalized in ATS. The twelve Table columns are divided into four sections:
1. QEI Identifier Data contains four data points that are pre-filled with information
the Organization finalized in ATS (Award Control Number, QEI ID, QEI Date, and
QEI Amount);
2. QLICI Usage contains four data points for the QLICI types (QALICB, Loans and
Investments in Other CDEs, Loan Purchases, and FCOS);

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3. Other Eligible Usages contains three data points for non-QLICI uses of QEI funds
(Operations, Reserves for Additional Investments in Existing QLICIs, and
Reserves for Loan Losses); and
4. Original Term of QEI contains one data point.
The table is a snapshot at the reporting period end. As a result, the list of QEIs that
appears in the Table may remain the same from year-to-year, while the QLICI Usage
and Other Eligible Usages may change from year-to-year.
Completing the Table:
There are two options for completing the table:
(1) Manual Data Entry
(2) Excel Download/Upload (Explained below)
Excel Download/Upload
• Select the “Download Excel” option to download the QEI Distribution Table in
Excel
• Select “Save” to save the Excel file (Please note the file location)
• Modify the Excel file and save (Do NOT add or delete columns/rows)
• Select “Upload Excel”
• Select the data file path; and
• Select “Upload Excel data” button
Download Prior Year Excel
• Select the “Download Prior Year Excel” option to download an Excel spreadsheet
that contains past responses to the QEI Distribution Table.
- Downloaded data will populate in an Excel file which is generated in the
current reporting year's format. Users should save this file to their computer
before making any updates to the data.
- Users may upload changes to the data for current year’s submission.
Validating the Excel file in CIIS
• After the Excel file is uploaded, CIIS will validate each row and column in the
transmission.
• If the transmission contains any errors, CIIS will generate an error report on
screen that specifies the errors.
• The Organization will need to resubmit data to make the corrections.
Make sure to rename the file if downloading the Excel file more than once. This will
prevent you from overwriting previous versions of the file.

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(1) EXPLANATION OF QEI IDENTIFIER DATA POINTS
The following four data points are pre-filled by CIIS based on the QEIs that the
Organization finalized in ATS, and are verified by the User prior to entering the ILR. If
there are errors in any of these data points, LOG OFF CIIS and contact the Fund to edit
the Organization’s finalized QEI data. Please refer to the ATS Instructions Manual for
information about requesting such edits from the Fund.

Data Point

Explanation

Award Control
Number
QEI ID

CIIS will prefill the Allocatee’s Award Control Number(s) for each
QEI.
This unique identifier is assigned to each QEI that the
Organization finalized in ATS. For each QEI finalized prior to the
end of the reporting period, CIIS will pre-fill its QEI identifier into
one row of the Table.
CIIS will pre-fill the date the QEI was issued based upon the
information the Organization finalized in ATS.
CIIS will pre-fill the Amount of QEI at Original Issue for each QEI
based upon the information the Organization finalized in ATS.

QEI Date
QEI Amount

(2) EXPLANATION OF THE QLICI USAGES DATA POINTS
The amounts the User enters in these four columns should sum to the amount of actual
QLICIs the Organization made by the end of the reporting period.
Do not include Advance Commitment Loan Purchases as Loan Purchase QLICIs.
Advance Commitment Loan Purchases should be treated as QALICBs.

Data Point

Explanation

QALICB Loans and Investments

For each QEI, enter the dollar amount of the
proceeds that were used to make loans and
investments in QALICBs as of the reporting period
end (include advance commitment loan purchases)
Include loans and investments made to both real
estate and non-real estate QALICBs. If the
Organization did not use the QEI to make QALICB
loans or investments, enter zero.
For each QEI, enter the dollar amount of the
proceeds that were used to make loans and
investments in other CDEs as of the reporting
period end.
If the Organization did not use the QEI to make
loans or investments to other CDEs, enter zero.
For each QEI, enter the dollar amount of the

Loans and Investments in Other
CDEs

Loan Purchases from Other

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Data Point

Explanation

CDEs

proceeds that were used to purchase loans from
other CDEs, as of the reporting period end.
If the Organization did not use the QEI to purchase
loans from other CDEs, enter zero.
For each QEI, enter the dollar amount of the
proceeds that were spent on FCOS as of the
reporting period end.
If the Organization did not use the QEI for FCOS,
enter zero.

FCOS

(3) EXPLANATION OF THE OTHER ELIGIBLE USAGES DATA POINTS
Data Point

Explanation

Operations

For each QEI, enter the total amount of the
proceeds spent on Operations during the reporting
period.
This amount should not exceed the 15% that the
Organization may use toward Other Activities, per
the “Substantially All” requirement.
For each QEI, enter the amount of the proceeds
that the Organization has set aside for additional
investment in existing QLICIs at the reporting
period end. This amount, summed with “Reserves
for Loan Losses,” should not exceed the amount of
reserves that the Organization is permitted to
establish pursuant to the IRS regulations (i.e., 5%
of the QEI proceeds).
For each QEI, enter the amount of the proceeds
that the Organization set aside for loan losses in
existing QLICIs at the reporting period end. This
amount, summed with “Reserves for Additional
Investment in Existing QLICIs,” should not exceed
the amount of reserves that the Organization is
permitted to establish pursuant to the IRS
regulations (i.e., 5% of the QEI proceeds).

Reserves for Additional
Investment in Existing QLICIs

Reserves for Loan Losses

(4) EXPLANATION OF ORIGINAL TERM DATA POINT
Data Point

Explanation

Original Term of QEI (months)

For each QEI, enter the term of the QEI at original
issue, in months. This amount should be equal to,

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or greater than, the 7-year tax credit period (i.e., 84
months) during which the QEI must remain with
the CDE.

14) Non-QEI Investment Capital Table
•

•
•

Use the Non-QEI Investment Capital Table to identify the sources of funds, if
any, which make up the Allocatee and/or Sub-Allocatee(s) Non-QEI
lending/investing pool that is intended to supplement NMTC-funded projects.
Include both idle capital available to loan or invest as well as deployed capital.
Include only capital that is reflected on the Organization’s Balance Sheet.
For venture capital funds, record all paid in capital. Committed capital will be
reported separately in Q.16.

Please note, “Non-QEI” does not include NMTC’s “Leverage Model”
investments and debt.
Completing the Table: Use one row in the Table for each distinct capital source with
the same interest rate and term. CIIS will calculate the weighted average interest rate
and remaining term and display it in Q.15 Investment Capital Summary Table.
Organizations with multiple sources of non-QEI loan/investment capital: If your
Organization has three or more investments from a single Source of Capital and Type of

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Capital, you may calculate the weighted average interest rate and weighted average
remaining term for these investments, and enter them in a single row.

Notes for Completing the Table:
• Net Assets (Type of Capital): All, or a portion, of an Organization’s Net Assets is
usually used for Investment Capital. Typically, this includes all Permanently Restricted
Net Assets, and may include all, or a portion, of Unrestricted Net Assets. If the
Organization’s Financial Statements include a line item for “Net Assets Restricted for
Lending/Investing,” include a row for Net Assets in the Investment Capital Table.
• Internal Funds (Source of Capital): Use “Internal Funds” as the Source of Capital for
for-profit and credit union retained earnings. For non-profits, use “Internal Funds” as the
Source of Capital for net assets derived from earned income and any net assets whose
source cannot be identified. The Type of Capital for all “Internal Funds” is “Net Assets Other OR Retained Earnings.”
• Example: Two years ago, the Organization received a $100,000 grant from the ABC
Foundation. If the Organization did not track the grant separately, and therefore cannot
distinguish its balance from other net assets, then it should be categorized as "Net
Assets - Other OR Retained Earnings." If the Organization did track the grant
separately and knows the balance, then it should be categorized as "Net Assets Grants."
• Debt - EQ2 (Type of Capital): If debt is not identified as an Equity Equivalent
Investment (EQ2) in the Organization’s Financial Statements, it is most likely not an
EQ2 and should be categorized in CIIS as Debt - Other. An EQ2 must be a loan to a
CDFI that meets the following characteristics:
1. At the end of the initial term, the loan must have a definite rolling maturity date
that is automatically extended on an annual bases if the CDFI borrower
continues to be financially sound and carry out a community development
mission.
2. Periodic payments of interest and/principal may only be made out of the CDFI
borrower’s available cash flow after satisfying all other obligations.
3. Failure to pay principal or interest (except at maturity) will not automatically result
in a default of the loan agreement.
4. The loan must be subordinated to all other debt except for the equity-equivalent
like loans.

Explanation of Data Points
Data Point

Explanation

Source of Capital

For each row, select the Source of Capital:
• Bank or other Regulated Financial Institution
• CDFI Intermediary
• Corporation-Real Estate Developer or Investment Company
• Corporation-Utility company
• Corporation-Other
• Government-Federal - CDFI Fund

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Data Point

Explanation
•
•
•
•
•
•
•
•
•
•
•
•
•

Type of Capital

Amount

Interest Rate

Remaining Term
(in months)

Government-Federal - Other Sources
Government - State or Local
Government Sponsored Entity (GSE)
Individuals
Internal Funds
Non Depository Financial Institution - Insurance company
Non Depository Financial Institution - Investment bank
Non Depository Financial Institution - Pension Fund
Non Depository Financial Institution - Venture fund
Philanthropic Organization - Foundation
Philanthropic Organization - Other
Religious Institution
Other
For each row, select the Type of Capital:
• Deposits
• Debt-Secondary Capital (Credit Union Only)
• Debt-EQ2
• Debt-Other
• Equity-Non-QEI
• Net Assets-Grants
• Net Assets-Other OR Retained Earnings
For each row, enter the Amount of lending/investing capital
remaining at the reporting period end. For loans, enter the
outstanding principal balance as it appears in the Balance Sheet
or Statement of Financial Position.
For each row, if the Type of Capital is Debt, enter the Interest
Rate. If the Interest Rate is variable, provide the Interest Rate in
effect at the reporting period end. If the Type of Capital is
Deposits, the User may either enter the weighted average
interest of all deposits OR select Not Applicable. If the Type of
Capital is Equity, Net Assets, or Debt–EQ2, CIIS will pre-fill the
Interest Rate as Not Applicable.
For each row, if the Type of Capital is Debt, enter the Remaining
Term (in months) at the reporting period end. If the Type of
Capital is Deposits, the User may either enter the Remaining
Term (in months) OR select Not Applicable. If the Type of
Capital is Equity, Net Assets, or Debt–EQ2, CIIS will pre-fill the
Remaining Term as Not Applicable.

15) Investment Capital Summary Table
CIIS will calculate and display the Investment Capital Summary Table based on
information entered in the QEI Distribution Table and Non-QEI Investment Capital
Table.

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Review the Investment Capital Summary Table for accuracy. Compare the
Investment Capital Summary Table to the Organization’s Financial Statements. If any
information is incorrect, modify the data as appropriate to meet the following 4
conditions.
Total Investment Capital >= Gross Loans Receivable and Equity Investments
(as reported in the Organization’s Financial Statements)
Total Equity <= Shareholder’s Equity (for-profit Organizations) OR Total Equity (nonprofit Organizations)
(as reported in the Organization’s Financial Statements)
Total Debt <= Total Liabilities
(as reported in the Organization’s Financial Statements)
Total Net Assets <= Total Net Assets (as reported in the Organization’s Balance
Sheet)

16) Off-Balance Sheet Resources Committed to the Organization for NMTCRelated Lending/Investing.
Enter the amount of any additional non-QEI lending and investing funds that have been
committed to the Allocatee and/or Sub-Allocatee(s) for the NMTC strategy, but that do
not appear on the Balance Sheet.
• Include grants, equity, debt, and any undrawn lines of credit the Allocatee and/or
Sub-Allocatee(s) expect to use for lending/investing.
• Exclude commitments that are based on verbal or conditional agreements.
• For venture capital funds, include all committed capital.
Off-Balance Sheet Resources are most likely reported in the Notes section of the
Organization’s Financial Statements under such headings as “Commitment and
Contingency and Other Disclosures,” “Notes Payable,” or “Loans Payable.” They may
also be found in the “Management Discussion and Analysis” section. If the amount
reported is not explained in the Financial Statements, provide an explanation for the
entry in the CIIS Notes field.

B. Additional Funds Leveraged by the Organization
17) Additional Funds the Organization Was Able to Attract Because of Its
QEIs.
Enter the total non-QEI investments the Allocatee, Parent, and any Sub-Allocatees
attracted during the reporting period as a result of QEI investments.
• Include only the funds that appear on Balance Sheet.
Example (1): Include any dollars the Organization was able to obtain in additional debt
due to its equity position being improved by QEIs.
Example (2): Include any grants the Organization was able to obtain to cover operating
expenses related to its NMTC program.

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C. QLICI Commitments
18) Total Financing Committed for QLICIs (Except FCOS) at Reporting
Period End
Enter the amount of financing the Allocatee and/or Sub-Allocatee(s) have committed for
QLICIs that have not yet been disbursed, but for which the organization(s) have
reserved cash, cash equivalents, or other assets to fund at a later date OR select Don’t
Know or Not Applicable.
• Include undisbursed portions of originated loans.
• Include provisionally and conditionally approved amounts.
• Exclude guarantees or lease obligations.
• Exclude commitments to affiliates, subsidiaries, and other related organizations.
If the amount reported is not explained in the Notes to the Financial Statements, provide
an explanation for the entry in the CIIS Notes field.

D. Reporting Period Summary Financial Information
19) Non-QEI Contributions
Enter any Non-QEI Contributions available to cover the Allocatees’ NMTC strategy
operating expenses during the reporting period. Use one row in the Table for each type
of contribution.
• Include unrestricted operating grants and contributions unless reported previously in
the Non-QEI Investment Capital Table.
• Include net assets released from restriction during the reporting period if they are
available to cover NMTC strategy operating expenses. NOTE: Exclude net assets
released from restriction if you know that the original source was earned income
• Include the value of in-kind contributions, in-kind donations, and donated services that
are included in the Organization’s Financial Statements.
• Exclude equity or grants, contributions, and donations to be used for lending/investing
capital.
• Exclude temporarily restricted grants intended for future operating periods.
• Exclude grants that will be passed through to other organizations.

EXPLANATION OF DATA POINTS
Data Point
Type of Contributor

Explanation
•
•
•
•
•
•
•

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For each row, select the Type of Contributor:
Bank or other Regulated Financial Institution
CDFI Intermediary
Corporation - Real Estate Developer or Investment
Company
Corporation - Utility company
Corporation - Other
Government-Federal - CDFI Fund

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Data Point

Explanation
•
•
•
•
•
•
•
•
•
•
•
•

Amount

Government-Federal - Other Sources
Government - State or Local
Government Sponsored Entity (GSE)
Individuals
Non Depository Financial Institution - Insurance company
Non Depository Financial Institution - Investment bank
Non Depository Financial Institution - Pension Fund
Non Depository Financial Institution - Venture fund
Philanthropic Organization - Foundation
Philanthropic Organization - Other
Religious Institution
Other
For each row, enter the Amount available for the reporting period
operating expenses.

III LOAN PURCHASES
This section captures information about loans purchased during the reporting period by
the Allocatee and/or Sub-Allocatee(s). If the Organization used non-QEI funds to cover
any portion of a loan purchase, identify these amounts.
If applicable, responses to this question will be used to confirm the Allocatee’s
compliance with its Allocation Agreement.

20) Loan Purchase Table
The Loan Purchase Table captures information on any loans the Organization has
purchased during the reporting period. Use one row in the Table for each distinct loan
purchase event.
Do not include Advance Commitment Loan Purchases in the Loan Purchase
Table. Advance Commitment Loan Purchases should be treated as QALICBs and
included in the Transaction Level Report (TLR).

EXPLANATION OF DATA POINTS – TABLE A
Data Point

Explanation

Purchase #
Purchase Date

System assigned value.
For each row, enter the month, day, and year of the loan
purchase event.
Seller Organization For each row, enter the certification control number of the CDE
from which the Organization purchased the loans.
Total $ Paid
For each row, this amount will pre-fill from Table B. An
explanation of Table B follows.

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Total # Loans
Presale Book
Value

For each row, enter the total number of loans for the purchase.
For each row, enter the Presale Book Value for the loan
purchased.

EXPLANATION OF DATA POINTS – TABLE B
Access Table B by first clicking “Add Row” to open the Table A dialog box described
above and then clicking “Add Row” again to access Table B for the data points that
follow. The User must complete Table B data points for each row in Table A.

Data Point

Explanation

Source of Funds

For each row in Table A, select the QEI(s) that funded the
purchase from the dropdown menu provided OR select non-QEI.
QEIs will only appear if the User indicated in the QEI Distribution
Table that proceeds are available for loan purchasing. If the QEI
that funded the purchase does not appear in the dropdown
menu, return to the QEI Distribution Table to correctly identify
which QEIs were used to purchase loans from other CDEs.
For each row in Table A and each QEI identified, enter the actual
amount of the QEI used for the particular loan purchase. The
User will not be able to enter an amount that exceeds the
amount of this QEI that is available for loan purchase activities,
as identified in the QEI Distribution Table.

Actual $ Used

21) Sector Breakouts for All Loans Purchased
Enter the Amount paid and Number of loans purchased reported in Q.20 for the
following sectors:
• Real Estate Business
• Non-Real Estate Business
• Other/Unknown Loans
Verify: that the Sector Breakout totals match the Q. 20 Loan Purchase Table Totals.
Q. 21 Total Amount Paid in Sector Breakouts = Q.20 Total Amount of Loans
Purchased
Q. 21 Total Number of Loans in Sector Breakouts = Q.20 Total Number Loans
Purchased

22) Did the Organization require each of the CDEs from which it purchased
loans to reinvest at least the designated percent of the proceeds (the
percentage indicted in the Allocation Agreement) of such loan sales in the
form of QLICIs?
Select whether the Allocatee and/or Sub-Allocatee(s) required each of the CDEs from
which it purchased loans to reinvest at least the designated percent of the proceeds (the

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percentage indicated in the Allocation Agreement) of such loan sales in the form of
QLICIs OR select Not Applicable.
If applicable, responses to this question will be used to confirm the Allocatee’s
compliance with its Allocation Agreement.

IV FINANCIAL COUNSELING AND OTHER SERVICES (FCOS)
Enter any FCOS offered by the Allocatee, Parent, and/or Sub-Allocatee(s) during the
reporting period.
• Include group-based training refers to a group forum, such as a workshop.
• Include one-on-one technical assistance is customized to an entrepreneur or business.
If applicable, responses to this section will be used to confirm the Allocatee’s
compliance with its Allocation Agreement.

23) QEIs Used for FCOS Table
Use this Table to identify all QEIs Used for FCOS during the reporting period. Use one
row in the Table for each QEI used for FCOS.

EXPLANATION OF DATA POINTS
Data Point

Explanation

QEI

For each row, select a QEI that funded FCOS. QEIs will
only appear if the User indicated in the QEI Distribution
Table that proceeds are available for FCOS. If any
QEIs that funded the FCOS do not appear in the
dropdown menu, return to the QEI Distribution Table to
correctly identify which QEIs were used for FCOS.
For each QEI, CIIS will display the Amount set aside for
FCOS from the information provided in the QEI
Distribution Table.
For each QEI, enter the Amount Used for FCOS during
the reporting period. For each QEI, the User will not be
able to enter an amount that exceeds the Amount set
aside for FCOS in the QEI Distribution Table.

Amount Set Aside for
FCOS
Amount Used for FCOS
During Reporting Period

FCOS Provided Using QEI Funds

24) Entrepreneurs and Businesses Receiving Group-Based Training
(Number of Clients/Hours)
Enter the Total Number of Clients Receiving and Hours Provided of Group-Based
Training during the reporting period OR select Don't Know. Count each client once
even if they have participated in training services on multiple occasions.
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25) Entrepreneurs and Businesses Receiving One-on-One Technical
Assistance (Number of Clients/Hours)
Enter the Total Number of Clients Receiving and Hours Provided of One-on-One
Technical Assistance during the reporting period OR select Don't Know. Count each
client once even if they have received technical Assistance on multiple occasions.

26) Amount of Non-QEIs Used for FCOS, If Any
Enter the amount of non-QEI dollars, if any, used for FCOS during the reporting period
OR select Don't Know.
FCOS Provided Using Non-QEI Funds

27) Entrepreneurs and Businesses Receiving Group-Based Training
(Number of Clients/Hours)
Enter the Total Number of Clients Receiving and Hours Provided of Group-Based
Training during the reporting period OR select Don't Know. Count each client once
even if they have participated in training services on multiple occasions.

28) Entrepreneurs and Businesses Receiving One-on-One Technical
Assistance (Number of Clients/Hours)
Enter the Total Number of Clients Receiving and Hours Provided of One-on-One
Technical Assistance during the reporting period OR select Don't Know. Count each
client once even if they have received technical Assistance on multiple occasions.

V BETTER RATES & TERMS
29) What is the Allocatee's Comparable for Determining Better Rates &
Terms?
Please select the comparable type of organization(s) the Allocatee uses when indicating
that it has provided Better Rates & Terms on QEI-funded loans/investments. In other
words, if the Allocatee states that a loan in the TLR has a below market interest rate,
which type of organization(s) did the Allocatee use to determine market rate?
a) CDE’s Non-NMTC transaction
b) CDE’s Parent/Affiliate
c) Banks
d) Other

30) Allocatees Comparables Comments
If applicable, enter comments regarding comparables used.

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VI IMPACTS
31) Lending/Investing with Other CDEs
Please briefly describe the Organization’s lending/investing activities with other CDEs, if
any. In other words, if the Organization is lending/investing in the same projects as
other CDEs or if the Organization has a relationship with other CDEs please describe
those relationships.

32) Lending/Investing with Certified CDFIs
Please briefly describe the Organization’s lending/investing activities with Certified
Community Development Financial Institutions (CDFIs), if any. In other words, if the
Organization is lending/investing in the same projects as Certified CDFIs or if the
Organization has a relationship with Certified CDFIs please describe those
relationships.

VII DATA COLLECTION SYSTEMS
33) Loan Portfolio Software
Select the software used by the Organization to track loan and investment data such as
original amount, principal outstanding, loan terms, and status.

34) Borrower Characteristics Software
Select the software used by the Organization to track borrower information such as
contact information, gender, race, credit scores, and other characteristics.

35) Community Development Impact Software
Select the software used by the Organization to track impact data such as affordable
housing units constructed, jobs created, jobs retained, and other community impact
outputs.
For Q.33 - 35, select from the following list:
• CDeSolution
• Customized Database Created with Access
• Customized Database Created with Another Program
• DownHome Loan Manager
• Excel
• Fed Comp
• Grants Management System
• IMPLAN
• LoanBase
• Loan Ledger
• Manual or Paper Based System Only
• Portfol Software

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•
•
•
•
•
•

Nortridge
Notesmith
Nstep
TEA (The Exceptional Assistant)
Trakker – Loan Servicing Software
Other

Other
If the Organization selects “Other” for the community impact software, enter the name of
the software used.

VIII CREDIT REPORTING AGENCIES USED
36) Credit Scores
Select whether the Organization collects credit scores.

37) Reporting Agency
If the Organization collects credit scores, select “yes” or “no” for each option to identify
the credit reporting agency(ies) used by the Organization:
• Equifax
• Experian
• TransUnion

IX ILR FEEDBACK
38) Success Story
Please briefly describe any transactions, product innovations, partnerships, new
investor relationships, or other events that you believe exemplify the important role of
CDEs in creating community development impact.

39) Comments
Please comment on any difficulties the Organization had in completing the ILR or any
suggestions for improving it.

X IRS COMPLIANCE QUESTIONS
You have completed the ILR. You are now entering the Internal Revenue Service (IRS)
Compliance Survey. If you have questions about the contents of the IRS Compliance
Survey, please contact:
Peter Radjenovich
[email protected]
(312) 566-4051

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1. For each Qualified Equity Investment received during the fiscal year have
you notified the investor that their investment qualifies for the New Markets
Tax Credit?
2. At any time during the fiscal year did the total dollar amount of QEIs
received exceed the amount of the NMTC allocation awarded by the CDFI
Fund?
2a. If yes, what was the amount of QEIs received that exceeded the amount
authorized in the Allocation Agreement?
3. During the fiscal year was there a recapture event, as described in 26 CFR
#1.45D-1T(e)(2) that was not corrected in accordance with the IRS regulations?

3a. If yes, complete the following chart for each QEI subject to recapture.
Data Point

Explanation

QEI
Date Recapture was Triggered
Reason for Recapture

Auto-populate QEI Identifier from ATS

Amount Subject to Recapture
Did you inform the appropriate investors
of the recapture event?

-Cease to be a CDE
-Failed Substantially All
-Redeemed QEI
-More than one reason
$
YES/NO

4. For QLICIs made during the fiscal year, was each QLICI made within 12
months of originally receiving the QEI in accordance with the IRS regulations
including allowable corrections?
4a. If no, what was the aggregate dollar amount of QLICIs not made within
the required timeframe?
4b. If not applicable, include explanation in Question 11 narrative box.
5. Did you receive any principal repayments on a QLICI (equity or debt), for
which these amounts were not reinvested that resulted in the organization
failing the substantially-all requirement?

5a. If yes, what was the aggregate dollar amount of QLICI repayments not
reinvested within the required timeframe?

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6. For any QLICIs that you made during the fiscal year to Qualified Active
Low-Income Community Businesses, did the businesses qualify as
QALICBs (per 26 CFR §1.45D-1T(d)(4)) at the time of the initial investment?
6a. If NO, please describe below:
7. If you invested in or lent to other CDEs, did you ensure that these
entities:
7a. Were in fact certified as CDEs by the CDFI Fund?
7b. Invested the funds received into eligible QALICBs?
8. If you purchased loans from other CDEs, did those loans meet the loan
purchasing criteria (per 26 CFR §1.45D-1T(d)(1)(ii))?
9. Did you establish reserves in accordance with 26 CFR §1.45D-1T(d)(3)?
9a. If yes, what was the aggregate amount of reserves established?
10. Did you use the direct tracing or safe harbor method for determining
substantially all?
Data Point

Explanation

Name of CDE

Name of Allocatee from Allocation Agreement
OR
Name of Subsidiary CDE from Allocation
Agreement
Direct Tracing/Safe Harbor/Not Applicable

Substantially All Methodology
Used

11. Please use the narrative box below to provide any further information
regarding your responses to Questions 1-10 of this IRS compliance survey.

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