NMTC Program Allocation Application (Business & Non-Profit)

NEW MARKETS TAX CREDIT ALLOCATION
APPLICATION TEMPLATE
The Community Development Institutions Fund (CDFI Fund) is publishing this New Markets Tax Credit
(NMTC) Allocation Application Template (Application Template) in conjunction with the Notice for Public
Comment on proposed and/or continuing information collection, as required by the Paperwork Reduction
Act (PRA) of 1995, 44 U.S.C. 3506(c)(2)(A). This Application Template is provided for the purposes of
soliciting comments on the appropriateness of the information collected in the Application. The NMTC
Allocation Application is an online form submitted through the CDFI Fund’s Award Management
Information System (AMIS).
The NMTC Program was established by Congress in 2000 to spur new or increased investments into
operating businesses and real estate projects located in Low-Income Communities. The NMTC Program
attracts investment capital to Low-Income Communities by permitting individual and corporate investors to
receive a tax credit against their Federal income tax return in exchange for making equity investments in
specialized financial institutions called Community Development Entities (CDEs). The credit totals 39
percent of the original investment amount and is claimed over a period of seven years (five percent for
each of the first three years, and six percent for each of the remaining four years). The investment in the
CDE cannot be redeemed before the end of the seven-year period.
New or substantially revised questions compared with the CY 2020 NMTC Allocation Application are
highlighted in yellow to indicate substantial changes.

NMTC Allocation Application Template for Public Comment - April 2021

TABLE OF CONTENTS
Applicant Instructions ....................................................................................................................... ii
Assurances and Certifications .......................................................................................................... iv
Applicant Information ...................................................................................................................... 1
Signature Page ................................................................................................................................. 9
Part I: Business Strategy ................................................................................................................. 11
Part II: Community Outcomes ........................................................................................................ 29
Part III: Management Capacity ....................................................................................................... 37
Part IV: Capitalization Strategy ....................................................................................................... 46
Part V: Information Regarding Previous Awards............................................................................. 52
Exhibit A: Projected Activities......................................................................................................... 56
Exhibit B: Track Record of Activities ............................................................................................... 63
Exhibit C: Staff and Board Qualifications ........................................................................................ 69
Exhibit D: Asset Management and Income & Operating Expenses ................................................. 72
Exhibit E: Investor Strategy ............................................................................................................ 79
Glossary of Terms .......................................................................................................................... 83

NMTC Allocation Application Template for Public Comment - April 2021
i

APPLICANT INSTRUCTIONS


Read the relevant New Markets Tax Credit (NMTC) Program publications prior to completing the
Allocation Application. For information on the calendar year (CY{YEAR} NMTC Program
allocation round (this Round), read the Notice of Allocation Availability (NOAA) and the
Community Development Financial Institutions Fund’s (the CDFI Fund’s) document titled “NMTC
Allocation Application Frequently Asked Questions” (FAQ). For tax related information on the
NMTC Program, read the final regulations issued by the Internal Revenue Service (26 CFR
1.45D-1) and related guidance. For information on Community Development Entity (CDE)
certification, read the CDFI Fund’s document titled “CDE Certification Q&A Document.” All of
these documents are available on the CDFI Fund’s website at www.cdfifund.gov. The CDFI
Fund’s Q&A Document is periodically updated, so continue to check the website on a regular
basis.



Consult the Glossary of Terms when completing the Allocation Application. All terms and phrases
that are in Capitalized Italics in the Allocation Application are defined in the Glossary of Terms.
Capitalized terms and phrases that are not italicized are the titles of documents on the CDFI
Fund’s website, pick-list options in the electronic application, or titles of sections of this Allocation
Application.



A Subsidiary CDE cannot submit an Allocation Application.



If the Applicant has not been certified as a CDE by the CDFI Fund, it must submit its CDE
Certification Application through the CDFI Fund’s Awards Management Information System
(AMIS) on or before the CDE Certification deadline specified in the NOAA. The CDE
Certification Application is available on the CDFI Fund’s website at www.cdfifund.gov.
Organizations whose CDE Certification Applications are not submitted in AMIS in a timely
fashion will be considered ineligible for NMTC Allocations in this Round of the Program.

NOTE: The CDFI Fund cannot process a CDE Certification Application unless each entity seeking
certification as a CDE: (a) is a legal entity, and is a domestic corporation or partnership for federal
tax purposes; and (b) has a valid and distinct Employer Identification Number (EIN). Applicants or
Subsidiary Applicants that have applied for, but not yet received, an EIN as of the date of the
Authorized Representative’s signature on the Allocation Application will not be accepted. For more
information on EINs and applying for an EIN, refer to the CDE Certification Q&A Document on the
CDFI Fund’s website at www.cdfifund.gov.



Carefully read the Allocation Application and the NOAA to determine whether the Applicant has
the requisite eligibility, capacity, experience, and skills to compete for and administer an NMTC
Allocation, execute the proposed business strategy and achieve the proposed community
outcomes. Be sure also to review carefully the Assurances and Certifications provided in this
document. By signing this Allocation Application, the Applicant is certifying to the truth,
completeness, and correctness of this Allocation Application, including the items listed in the
Assurances and Certifications.



If the CDFI Fund determines that any portion of the Allocation Application is incorrect in any
material respect, the CDFI Fund reserves the right, in its sole discretion, to reject the Allocation
Application.

NMTC Allocation Application Template for Public Comment - April 2021
ii



As the Applicant prepares the Allocation Application, assume that the CDFI Fund’s Allocation
Application reviewers are learning about the organization for the first time, even if the
organization has previously submitted an application to the CDFI Fund under this or any of the
other CDFI Fund programs.



A newly formed entity that does not have a track record of raising capital or offering products and
services may reference the activities of its Controlling Entity in certain areas of the Allocation
Application. However, a start-up may not reference the activities of individuals, including
Principals or board members, to demonstrate such track record. The activities and experiences of
individuals may be addressed in the Management Capacity section.



The term Applicant refers to the CDE applying for an NMTC Allocation as well as any other
Subsidiary entities, whether already formed or in the process of formation, which may receive a
transfer of all or a part of an NMTC Allocation from the Applicant. To the extent practicable, the
Applicant may respond to each question in this Allocation Application collectively on behalf of all
such entities. If responses vary for separate entities, be sure to clearly articulate which entity is
being referenced in the narrative and tables.



Be sure to keep each narrative brief: Please note that each narrative text response has a
maximum character length, which, depending on font size, will range from about 1/3 of a page to
about 2 pages). These character maximums include spaces, punctuation, and special characters.
All text that exceeds the maximum set for a narrative text response (which is noted at the end of
each question) will be truncated at the character limit.

DO NOT SUBMIT THIS ALLOCATION APPLICATION


Use the electronic application: This version of the Allocation Application is a read-only version.
Any organization interested in applying for an NMTC Allocation from the CDFI Fund is expected
to submit an electronic Allocation Application. Applicants may access the electronic Allocation
Application as soon as it is made available by logging in through AMIS on the CDFI Fund's
website at amis.cdfifund.gov. Applicants who have not already done so are encouraged to
register a user account through AMIS as soon as possible. Please contact the CDFI Fund's IT
Help Desk at (202) 653-0422 or [email protected] if you are having problems registering
under AMIS. The electronic Allocation Application must be received no later than the
application submission deadline specified in the NOAA. Complete instructions regarding the
electronic submission requirements will be posted on the CDFI Fund's website at
www.cdfifund.gov when the online Allocation Application is made available.



All Applicants must complete and save all responses to the Application Registration section
of the NMTC Allocation Application in AMIS by 5pm ET on the Application Registration
deadline specified in the NOAA in order to submit the remaining sections of the Allocation
Application. To complete the Application Registration, Applicants must provide a response to
each question in this section, select “Yes” to lock its responses, and press the save button. AMIS
will not allow additional edits to the Application Registration once it has been completed and
saved. Once the Application Registration deadline passes, AMIS will not allow the creation of any
new CY {YEAR} NMTC Allocation Applications. Additionally, Applicants will not be permitted to
submit CY {YEAR} NMTC Allocation Applications if the Application Registration section of those
Applications remains incomplete and unsaved after the Application Registration deadline. Please
see the CY {YEAR} NMTC Program Allocation Application Frequently Asked Questions document
(Q. 14 and 15) and the AMIS User instructions (Section 6.2) for more details on completing the
Application Registration section.



Required Investor Letters (if applicable): Applicants completing Table E3 are required to submit
Commitment letters or letters of interest from investors per the NOTE for Exhibit E. Please upload

NMTC Allocation Application Template for Public Comment - April 2021
iii

these documents electronically through the Applicant’s AMIS account. In doing so, an Applicant is
also validating the following information: name of investor, dollar amount of equity sought or
obtained (or dollar amount of debt, in the case of an investor partnership using debt capital),
status of the investment request (e.g., funds received, Commitment of funds, Letter of
Interest/Intent). For examples of acceptable documentation for the required information, refer to
the CDFI Fund’s NMTC Allocation Application FAQ Document. Applicants that do not complete
Table E3 should not submit investor letters.


Submitting Required Documents and Controlling Entity Signature Page: All Applicants
designating a Controlling Entity will be required to upload the Controlling Entity Signature Page
and other documents (Assurances and Certifications narrative (if applicable), investor letters (if
applicable) and organizational charts) electronically through their AMIS accounts. An Applicant
will be instructed on how to upload the aforementioned Signature Page and other documents
(i.e., attachments) at the time the Applicant submits its Allocation Application. All attachments
must be uploaded by the application and attachment deadline specified in the NOAA. If the
attachments are not received by the applicable deadline, they will not be given consideration as
part of the review process. Only those attachments requested by the CDFI Fund will be
considered as part of the review process. Furthermore, the CDFI Fund will not accept any
revisions or amendments to an application or the attachments once they have been
submitted for review.



Part V - Information Regarding Previous Awards: All Applicants are required to complete Part V of
the Allocation Application. Applicants that have not received previous NMTC Allocations or that
have not received other CDFI Fund Awards (i.e. FA-TA, CMF, BEA will simply need to respond
“Yes” to Questions 41 and 42 and respond “No” to Question 43. Applicants that have not made
QEIs into previous Allocatees or assumed Control of previous Allocatees should respond “No” to
Question 44. Please note that Part V is not scored as part of the Phase I review process, and is
only considered if the Applicant is ranked highly enough to proceed to Phase II of the application
review process.



Each Applicant should expect that if it receives an NMTC Allocation, information provided in this
Allocation Application will be used to determine the terms of an Allocation Agreement.



The contents of this Allocation Application are consistent with the Internal Revenue Code Section
45D and the NMTC Program Income Tax Regulations. In the event of any inconsistency between
the contents of this Allocation Application and the Internal Revenue Code Section 45D or the
NMTC Program Income Tax Regulations, the provisions of the Internal Revenue Code Section
45D and the NMTC Program Income Tax Regulations shall govern.

NOTE: If you have programmatic or technology-related questions about the Allocation Application,
you may contact the CDFI Fund by submitting an AMIS service request. In the Service Request
form, select “NMTC Program” as the Program. Use of AMIS Service Requests is the best method
to submit and track your request. Additionally, you can call (202) 653-0422 or e-mail
[email protected] for information technology assistance.
The CDFI Fund will provide programmatic and information technology support related to the
Allocation Application between 9:00 am and 5:00 pm, Eastern Time, through [DATE]. The CDFI
Fund will not respond to phone calls or e-mails concerning an Allocation Application
submitted after 5:00 pm, Eastern Time, on [DATE], until after the Allocation Application
submission deadline specified in the NOAA.

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iv

ASSURANCES AND CERTIFICATIONS
Generally, the Applicant must provide the Assurances and Certifications below in order to apply for an
NMTC Allocation.

A. General Certifications
With regard to the General Certifications (below):


If the Applicant is unable to provide General Certifications numbered 1 through 9; the Applicant is
ineligible to apply for an NMTC Allocation.



If the Applicant is unable to provide General Certifications numbered 10 through 17; the Applicant
must provide a written explanation in the text box provided in the electronic Allocation Application.
The CDFI Fund will consider the explanation provided and determine, in its sole discretion,
whether the Applicant is eligible to apply for an NMTC Allocation.

Please select “True,” “False,” or “Not Applicable” to each certification. By selecting “True” the Applicant is
certifying that the corresponding statement is true. By selecting “False” the Applicant is certifying that the
corresponding statement is not true. By selecting “Not Applicable” the Applicant is certifying that the
corresponding statement is not applicable to their application.
Note: Where the Applicant is unable to answer “True” to one or more of the statements in items 10
through 17 of the General Certifications, the Applicant must submit a written explanation with this
Allocation Application that clearly identifies the item number(s) and corresponding statement(s) it is
unable to certify. The written explanation should also identify the applicable specific entity and/or
individual by name. If the Applicant submits a written statement in response to items 12(c), 12(e), 13(c),
14(c) or 15(c), it should identify and summarize the litigation or regulatory matters typically disclosed in
the applicable entity’s annual SEC filings for 2017 and 2018, 2019 and quarterly for 2020.
As the Authorized Representative of the Applicant, I hereby assure and certify that:
1.

The Applicant is duly organized and validly existing under the laws of the jurisdiction in which it
was incorporated or otherwise established.
True______

2.

The Applicant has the legal authority to apply for an NMTC Allocation, and the institutional,
managerial, and financial capability to ensure proper use of such allocation as described in this
Allocation Application and in accordance with IRC §45D and the NMTC Program Income Tax
Regulations, and all applicable Department of the Treasury regulations and guidance documents.
True______

3.

False______

False______

The Applicant’s governing body (e.g., Board of Directors) has by proper resolution or similar
action authorized the signing and filing of this Allocation Application, including all understandings

NMTC Allocation Application Template for Public Comment - April 2021
v

and assurances contained herein, and directed and authorized me as the Authorized
Representative of the Applicant to act in connection with this Allocation Application and to provide
such additional information as may be required.
True______
4.

The Applicant will give the Department of the Treasury, the Comptroller General of the United
States, and if appropriate, the State of the Applicant’s incorporation, through any Authorized
Representative, access to and the right to examine all records, books, papers, or documents
related to the provision of an NMTC Allocation; and will establish a proper accounting system in
accordance with generally accepted accounting standards; Office of Management and Budget
(OMB) regulations, guidelines, and circulars; and Department of the Treasury regulations and
directives.
True______

5.

False______

The Applicant will comply with all applicable requirements of all other Federal laws, executive
orders, regulations, and policies governing the NMTC Program.
True______

9.

False______

The Applicant will comply, as applicable and appropriate, with the requirements of OMB Circulars
and any regulations and circulars which are later promulgated to supplement or replace them,
including standards for fund control and accountability.
True______

8.

False______

The Applicant will comply with all applicable requirements of the Community Renewal Tax Relief
Act of 2000 (26 U.S.C. 45D), and as amended, regulations implementing the NMTC Program and
all other applicable Department of the Treasury regulations, guidance, and implementing
procedures (and any regulations or procedures which are later promulgated to supplement or
replace them).
True______

7.

False______

The Applicant will establish safeguards to prohibit employees from using their positions for
purposes that constitute or present personal or organizational conflicts of interest, or personal
gain, either real or perceived.
True______

6.

False______

False______

The Applicant has not knowingly and willfully made or used a document or writing containing any
false, fictitious, or fraudulent statement or entry as part of this Allocation Application or any
related document, correspondence, or communication. The Applicant and its Authorized
Representative are aware that, under 18 U.S.C. 1001, whoever knowingly and willfully makes or
uses such document or writing shall be fined or imprisoned for not more than five years, or both.

NMTC Allocation Application Template for Public Comment - April 2021
vi

True______
10.

False______

The Applicant and its Affiliates have never filed for bankruptcy.
True______

False______

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #10. (Maximum Response Length: 1,000 Characters)

11.

The following entities are not federally regulated financial institutions currently under any
Enforcement Action from any federal regulator.

Applicant
Controlling Entity
Affiliate

True
_______
_______
_______

False
_______
_______
_______

Not Applicable
_______

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #11. (Maximum Response Length: 1,000 Characters)

12.

Certifications for the Controlling Entity:
(a) The Controlling Entity has not within a three-year period preceding the date of this Allocation
Application been indicted, charged with or convicted of, or had a civil judgment rendered
against it for commission of fraud or a criminal offense;
True______

False______

Not Applicable______

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #12(a). (Maximum Response Length: 1,000
Characters)

(b) The Controlling Entity has not within a three-year period preceding the date of this Allocation
Application been indicted, charged with or convicted of, or had a civil judgment rendered
against it for violation of Federal or State antitrust statutes or commission of embezzlement,

NMTC Allocation Application Template for Public Comment - April 2021
vii

theft, forgery, bribery, falsification or destruction of records, making false statements, or
receiving stolen property;
True______

False______

Not Applicable______

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #12(b). (Maximum Response Length: 1,000
Characters)

(c) The Controlling Entity is not presently indicted for or otherwise criminally or civilly charged by
a governmental entity (Federal, State, or local) with commission of any of the offenses
enumerated in paragraphs 14(a) and 14(b) of this certification;
True______

False______

Not Applicable______

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #12(c). (Maximum Response Length: 1,000
Characters)

(d) The Controlling Entity has not within the three-year period preceding the date of this
Allocation Application been the subject of any formal investigation or disciplinary proceeding
by a government agency, regulatory body, or professional association in connection with any
matter which may have a material adverse effect on the Applicant or its financial condition or
the Applicant’s ability to carry out the authorized uses of an NMTC Allocation; or
True______

False______

Not Applicable______

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #12(d). (Maximum Response Length: 1,000
Characters)

(e) The Controlling Entity has not within the three-year period preceding the date of this
Allocation Application been found liable in any civil legal action involving creditor’s claims of
greater than $500,000.
True______

False______

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viii

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #12(e). (Maximum Response Length: 1,000
Characters)

13.

Certifications for the Applicant:
(a) The Applicant has not within a three-year period preceding the date of this Allocation
Application been convicted of or had a civil judgment rendered against it for commission of
fraud or a criminal offense;
True______

False______

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #13(a). (Maximum Response Length: 1,000
Characters)

(b) The Applicant has not within a three-year period preceding the date of this Allocation
Application been convicted of or had a civil judgment rendered against it for violation of
Federal or State antitrust statutes or commission of embezzlement, theft, forgery, bribery,
falsification or destruction of records, making false statements, or receiving stolen property;
True______

False______

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #13(b). (Maximum Response Length: 1,000
Characters)

(c) The Applicant has not within the three-year period preceding the date of this Allocation
Application been found liable in any civil legal action involving creditor’s claims of greater
than $500,000.
True______

False______

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ix

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #13(c). (Maximum Response Length: 1,000
Characters)

14.

The following individuals or entities of the Applicant:
(a) have not within a three-year period preceding the date of this Allocation Application been
convicted of or had a civil judgment rendered against him/her for commission of fraud or a
criminal offense.

Officers
Directors
Majority Owners
Key Employees

True
_____
_____
_____
_____

False
_____
_____
_____
_____

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #14(a). (Maximum Response Length: 1,000
Characters)

(b) have not within a three-year period preceding the date of this Allocation Application been
convicted of or had a civil judgment rendered against it for violation of Federal or State
antitrust statutes or commission of embezzlement, theft, forgery, bribery, falsification or
destruction of records, making false statements, or receiving stolen property.

Officers
Directors
Majority Owners
Key Employees

True
_____
_____
_____
_____

False
_____
_____
_____
_____

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #14(b). (Maximum Response Length: 1,000
Characters)

NMTC Allocation Application Template for Public Comment - April 2021
x

(c) have not within the three-year period preceding the date of this Allocation Application been
found liable in any civil legal action involving creditor’s claims of greater than $500,000.
True
_____
_____
_____
_____

Officers
Directors
Majority Owners
Key Employees

False
_____
_____
_____
_____

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #14(c). (Maximum Response Length: 1,000
Characters)

15.

Certifications for the Applicant:
(a) The Applicant has not within a three-year period preceding the date of this Allocation
Application been indicted for or charged with the commission of fraud or a criminal offense;
True______

False______

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #15(a). (Maximum Response Length: 1,000
Characters)

(b) The Applicant has not within a three-year period preceding the date of this Allocation
Application been indicted for or charged with the violation of Federal or State antitrust
statutes or commission of embezzlement, theft, forgery, bribery, falsification or destruction of
records, making false statements, or receiving stolen property;
True______

False______

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #15(b). (Maximum Response Length: 1,000
Characters)

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xi

(c) The Applicant is not presently indicted for or otherwise criminally or civilly charged by a
governmental entity (Federal, State, or local) with commission of any of the offenses
enumerated in paragraphs 15(a) and 15(b) of this certification;
True______

False______

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #15(c). (Maximum Response Length: 1,000
Characters)

(d) The Applicant has not within the three-year period preceding the date of this Allocation
Application been the subject of any formal investigation or disciplinary proceeding by a
government agency, regulatory body, or professional association in connection with any
matter which may have a material adverse effect on the Applicant or its financial condition or
the Applicant’s ability to carry out the authorized uses of an NMTC Allocation.
True______

False______

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #15(d). (Maximum Response Length: 1,000
Characters)

(e) The following entities have not within the three-year period preceding the date of this
Allocation Application been the subject of any formal investigation by the Internal Revenue
Service related to any NMTC transactions or activities.
Applicant
Affiliate

True______
True______

False______
False______

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #15(e). (Maximum Response Length: 1,000
Characters)

16.

The following individuals or entities of the Applicant:
(a) have not within a three-year period preceding the date of this Allocation Application been
indicted for or charged with the commission of fraud or a criminal offense;

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xii

Officers
Directors
Majority Owners
Key Employees

True
_____
_____
_____
_____

False
_____
_____
_____
_____

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #16(a). (Maximum Response Length: 1,000
Characters)

(b) have not within a three-year period preceding the date of this Allocation Application been
indicted for or charged with the violation of Federal or State antitrust statutes or commission
of embezzlement, theft, forgery, bribery, falsification or destruction of records, making false
statements, or receiving stolen property;

Officers
Directors
Majority Owners
Key Employees

True
_____
_____
_____
_____

False
_____
_____
_____
_____

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #16(b). (Maximum Response Length: 1,000
Characters)

(c) are not presently indicted for or otherwise criminally or civilly charged by a governmental
entity (Federal, State, or local) with commission of any of the offenses enumerated in
paragraphs 16(a) and 16(b) of this certification;

Officers
Directors
Majority Owners
Key Employees

True
_____
_____
_____
_____

False
_____
_____
_____
_____

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #16(c). (Maximum Response Length: 1,000
Characters)

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xiii

(d) have not within the three-year period preceding the date of this Allocation Application been
the subject of any formal investigation or disciplinary proceeding by a government agency,
regulatory body, or professional association in connection with any matter which may have a
material adverse effect on the Applicant or its financial condition or the Applicant’s ability to
carry out the authorized uses of an NMTC Allocation.
True
_____
_____
_____
_____

Officers
Directors
Majority Owners
Key Employees

False
_____
_____
_____
_____

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #16(d). (Maximum Response Length: 1,000
Characters)

17.

The Applicant has never been delinquent on amounts due to the Internal Revenue Service or on
any debts owed to Federal, State, or local government.
True______

False______

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #17. (Maximum Response Length: 1,000 Characters)

B. Certification Regarding Debarment, Suspension, and Other
Responsibility Matters — Primary Covered Transactions


This Certification is a material representation of fact upon which reliance is placed when the CDFI
Fund enters into an Allocation Agreement with the Applicant. If it is later determined that the Applicant
knowingly rendered an erroneous or false Certification, the CDFI Fund may terminate, in its sole
discretion, the Allocation Agreement for cause or default.

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xiv



The Applicant must provide immediate written notice to the CDFI Fund if at any time the Applicant
learns that this Certification was erroneous or false when submitted or has become erroneous or false
by reason of changed circumstances.



The terms “covered transactions,” “debarred,” “suspended,” “ineligible,” “lower tier covered
transaction,” “participant,” “person,” “primary covered transaction,” “Principal,” “proposal,” and
“voluntarily excluded,” as used in this Certification, have the meanings set out in the Definitions and
Coverage sections of the rules implementing Executive Order 12549. The Applicant may contact the
CDFI Fund for assistance in obtaining a copy of those regulations (31 CFR Part 19).



The Applicant agrees that, by submitting this Allocation Application, should the proposed covered
transaction be entered into, it shall not knowingly enter into any lower tier covered transaction with a
person who is proposed for debarment under 48 CFR part 9, subpart 9.4, debarred, suspended,
declared ineligible, or voluntarily excluded from participation in this covered transaction, unless
authorized by the CDFI Fund.



The Applicant further agrees that, by submitting this Allocation Application, it will include the
Certification titled “Certification Regarding Debarment, Suspension, Ineligibility, and Voluntary
Exclusion-Lower Tier Covered Transaction,” to be provided by the CDFI Fund, without modification, in
all lower tier covered transactions and in all solicitations for lower tier covered transactions (see 31
CFR part 19, Appendix B).



A participant in a covered transaction may rely upon a certification of a prospective participant in a
lower tier covered transaction that it is not proposed for debarment under 48 CFR part 9, subpart 9.4,
debarred, suspended, ineligible, or voluntarily excluded from the covered transaction, unless it knows
that the certification is erroneous or false. A participant may decide the method and frequency by
which it determines the eligibility of its Principals. Each participant may, but is not required to, check
the List of Parties Excluded from Federal Procurement and Non-procurement Programs. See
www.sam.gov for more information.



Nothing contained in the foregoing shall be construed to require establishment of a system of records
in order to render in good faith the Certification hereby required. The knowledge and information of a
participant is not required to exceed that which is normally possessed by a prudent person in the
ordinary course of business dealings.



Except for transactions authorized under paragraph 4 above, if a participant in a covered transaction
knowingly enters into a lower tier covered transaction with a person who is proposed for debarment
under 48 CFR part 9, subpart 9.4, suspended, debarred, ineligible, or voluntarily excluded from
participation in this transaction, in addition to other remedies available to the Federal Government,
the CDFI Fund may terminate, in its sole discretion, the Allocation Agreement for cause or default.

WITH REGARD TO THE CERTIFICATION REGARDING DEBARMENT, SUSPENSION, AND OTHER
RESPONSIBILITY MATTERS (BELOW):


If the Applicant is unable to provide any of the Certifications in section B below; the Applicant
must submit a written explanation after each statement it is unable to certify in its Allocation
Application. The CDFI Fund will consider the explanation provided and determine, in its sole
discretion, whether the Applicant is eligible to apply for an NMTC Allocation.



If the Applicant fails to furnish either the Certification or a written explanation, the Applicant is not
eligible to apply for an NMTC Allocation.

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xv

The prospective primary participant (the Applicant) certifies to the best of its knowledge and belief
the following:
1.

are not presently debarred, suspended, proposed for debarment, declared ineligible, or voluntarily
excluded from covered transactions by any Federal department or agency;
Applicant
Principals

True______
True______

False______
False______

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #1. (Maximum Response Length: 1,000 Characters)

2.

have not within a three-year period preceding this Allocation Application been convicted of or had
a civil judgment rendered against them for:
(a) commission of fraud or a criminal offense in connection with obtaining, attempting to obtain, or
performing a public (Federal, State, or local) transaction or contract under a public transaction;
Applicant
Principals

True______
True______

False______
False______

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #2(a). (Maximum Response Length: 1,000
Characters)

(b) violation of Federal or State antitrust statutes or commission of embezzlement, theft, forgery,
bribery, falsification or destruction of records, making false statements, or receiving stolen
property;
Applicant
Principals

True______
True______

False______
False______

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #2(b). (Maximum Response Length: 1,000
Characters)

3.

are not presently indicted for or otherwise criminally or civilly charged by a governmental entity
(Federal, State, or local) with commission of any of the offenses enumerated in paragraph (2)(b)
of this certification;

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xvi

Applicant
Principals

True______
True______

False______
False______

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #3. (Maximum Response Length: 1,000 Characters)

4.

have not within a three-year period preceding this Allocation Application had one or more public
transactions (Federal, State, or local) terminated for cause or default.
Applicant
Principals

True______
True______

False______
False______

If false is selected, the Applicant must provide an explanation in the text box below for why it is
unable to certify the statement in Question #4. (Maximum Response Length: 1,000 Characters)

NOTE: Where the Applicant is unable to certify to one or more of the statements above Regarding
Debarment, Suspension, and Other Responsibility Matters – Primary Covered Transactions, the Applicant
must submit a written explanation after each statement it is unable to certify in its Allocation Application
that clearly identifies the applicable specific entity and/or individual by name.

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xvii

Supplemental Certification
Applicants unable to select “True” for a statement(s) in General Certifications 10 through 17 and
statement(s) one through four in the Certification Regarding Debarment, Suspension, and Other
Responsibility Matters — Primary Covered Transactions must “Agree” to the statement below before
submitting their Allocation Application.
The Applicant hereby certifies based upon reasonable information and after due inquiry, there are no
matters previously disclosed by the Applicant in the CY [YEAR] New Markets Tax Credit (NMTC)
Program Application and Written Explanation; any other litigation or Enforcement Actions currently in
effect with regard to the Applicant, its Affiliates, its Controlling Entity, or any of its managed Subsidiary
CDEs; or any ongoing obligations or restrictions resulting from any litigation or Enforcement Actions with
regard to the Applicant, its Affiliates, its Controlling Entity, or any of its managed Subsidiary CDEs; that
will have a material adverse effect on the Applicant, its financial condition or ability to carry out the
authorized uses of a CY [YEAR] NMTC Program allocation, should the Applicant be successful in the CY
[YEAR] round.
Agreed ______
NOTE: The Supplemental Certification is not applicable for Applicants that selected “True” for
each statement in the Assurances and Certifications related to this NMTC Allocation Application.

APPLICANT INFORMATION
1. Applicant NMTC Allocation Request
Total dollar amount of NMTC Allocation requested in this Allocation Application: $_____________
2. Applicant Information1:
(a) Applicant Name:

________________________________________________________

(b) Applicant Employer Identification Number:

_____________________________________

(c) Structure of the Applicant:
Is the Applicant a For-profit or Non-profit entity? ___ For-profit
Check all that apply:
____ Credit Union
____ Small Business Investment
Company/Specialized Small Business
Investment Company
____ CDFI
____ Publicly Traded Company
____ New Market Venture Capital Company

___ Non-profit

____ Government-Controlled Entity
____ Faith-Based Institution
____ Thrift, Bank or Bank Holding Company
____ Real Estate Development Company
____ Series of Funds

(d) Is the Applicant Minority-owned or Minority-controlled? ____ Yes _____ No
(e) Is the Applicant Native American-owned or Native American-controlled? ____ Yes _____ No
(f) Applicant’s date of incorporation or formation (month/day/year): _______________
(g) Applicant’s total assets as of the date of this Allocation Application: $_________
(h) Applicant’s fiscal year end (month/day) (update in AMIS): ________
(i) Does the Applicant have any Affiliates that are applying for an NMTC Allocation in this Round?
(check one): ___ Yes ___ No

1

For the purposes of Questions #2-6 in this Applicant Information section, the term Applicant shall only apply to the
entity applying for a NMTC Allocation, and not to Subsidiary entities that may receive a transfer of all or part of a
NMTC Allocation.
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1

NOTE: The answer to question 2(i) must be “No.” An Applicant and its Affiliates may collectively
submit only one application for an NMTC Allocation under this Round of the NMTC Program. If
separate Allocation Applications are received from multiple Affiliated entities, the CDFI Fund
reserves the right to reject all such applications. Likewise, Subsidiary CDEs are ineligible to submit
an Allocation Application.
For the purposes of this requirement, in addition to assessing whether Applicants meet the
definition of the term “Affiliate” found in the Glossary of Terms at the end of this Allocation
Application, the CDFI Fund will consider, among other things: (i) whether different Applicants have
the same individual(s), including the Authorized Representative, staff, board members and/or
consultants, involved in day-to-day management, operations and/or investment responsibilities; (ii)
whether Applicants have business strategies and/or proposed activities that are so similar or so
closely related that, in fact or effect, may be viewed as a single entity; and/or (iii) whether the
applications submitted by separate Applicants contain significant narrative, textual or other
similarities such that they may, in fact or effect, be viewed as the substantially identical
applications. In such cases, the CDFI Fund will reject all applications received from such entities.
For more information regarding these requirements, please review the NOAA and Allocation
Application FAQ Document on the CDFI Fund’s website at www.cdfifund.gov. If you have questions
about whether two entities are Affiliated, you should contact the CDFI Fund within a week of the
NMTC Allocation Application release date.

3. Controlling Entity Information:
Is the Applicant designating a Controlling Entity? ____ Yes _____ No

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2

NOTE: A CDE may only designate one organization as a Controlling Entity. This entity must meet
the definition of Controlling Entity set forth in the Glossary of Terms of this Allocation Application.
Individuals cannot be deemed to be Controlling Entities.
Applicants may use this Controlling Entity to assist in demonstrating an organizational track record
and in completing the related exhibits. An Applicant may identify the parent organization or the
company of its parent (i.e. “grandparent”) as its Controlling Entity to demonstrate an organizational
track record, provided that the relationship between the “grandparent” and the Applicant conforms
to the CDFI Fund’s definition of a Controlling Entity.
Should the Applicant receive an NMTC Allocation in this Round, the designated Controlling Entity
will need to continue in that capacity throughout the term of the Allocation Agreement and
for any future Allocation Agreements with the CDFI Fund, should the Applicant apply and
receive an allocation in a future round. Any Applicant that receives an NMTC Allocation in
this Round must designate the same Controlling Entity as designated in this Allocation
Application in any Allocation Applications for future rounds.
Applicants that received an NMTC Allocation in the CY2014 round or later rounds are expected to
maintain the Controlling Entity stated in their Allocation Agreement in Question #3(a). Please see
the Application FAQ for further guidance and information about exceptions to the above in the case
of mergers, acquisitions, bankruptcy or similar legal actions the Controlling Entity may undertake.
NOTE: The Controlling Entity Representative is required to affirm, through submission of a
Signature Page, that it is indeed the Controlling Entity of the Applicant and supports the Applicant’s
Allocation Application.

a) Controlling Entity Name:____________________________________________________
b) Controlling Entity Employer Identification Number:
_________________________________
c) Controlling Entity Mailing Address (provide nine-digit zip code):

d) Structure of the Controlling Entity:
Is the Controlling Entity a For-profit or Non-profit entity? ___ For-profit
Check all that apply:
____ Credit Union
____ Small Business Investment
Company/Specialized Small Business
Investment Company
____ CDFI
____ Publicly Traded Company
____ New Market Venture Capital Company

___ Non-profit

____ Government-Controlled Entity
____ Faith-Based Institution
____ Thrift, Bank or Bank Holding Company
____ Real Estate Development Company
____ Series of Funds

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3

e) Is the Controlling Entity Minority-owned or Minority-controlled? _____ Yes _____ No

f)

Is the Controlling Entity Native American-owned or Native American-controlled?
____ Yes _____ No

g) Total assets of Controlling Entity: $________________

4. Applicant Mailing Information:
Mailing address (provide nine-digit zip code):

Address for overnight deliveries (if different from mailing address, include nine-digit zip code):

NOTE: Representatives of the Applicant and Controlling Entity (if applicable), should not provide
private, personal contact information in response to Question #5. Only official, public contact
information should be provided.

NOTE: Only the AMIS user designated as the Authorized Representative in Question #5a will be
eligible to sign the Allocation Application.
The Application Contact Person is the individual that the CDFI Fund may contact—jointly with the
Authorized Representative—during the course of the Allocation Application review with questions
or requests for additional information regarding the Allocation Application. It is strongly
recommended that the Application Contact Person listed is someone other than the Applicant
Authorized Representative.
Should the Applicant be selected to receive an NMTC Allocation, the CDFI Fund reserves the right
to publish the Applicant’s response to select questions in the Applicant Information and Business
Strategy sections, including Public Contact Person information provided in Question #5c.

5. Applicant and Controlling Entity Contact Information
5a – Applicant Contact Information
(a) Applicant Authorized Representative Information:
Name, title, and mailing address, if different from Applicant:

NMTC Allocation Application Template for Public Comment - April 2021
4

Telephone number:
E-mail address:

(b) Application Contact Person Information:
Name, title, and mailing address, if different from Applicant:

Telephone number:
E-mail address:

(c) Public Contact Person Information:
Name, title, and mailing address, if different from Applicant:

Telephone number:
E-mail address:

5b – Controlling Entity Contact Information
(a) Controlling Entity Representative Information:
Name, title, and mailing address:

Telephone number:
E-mail address:

6. CDE Certification Information:
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5

(a) Has the Applicant already been certified as a CDE by the CDFI Fund or submitted a CDE
Certification Application by the deadline in the NOAA?
___ Yes, CDE Certification Control Number: _____________________________
___ No
Subsidiary CDEs are ineligible to submit Allocation Applications.
(b) By the stated deadline in the NOAA, is the Applicant filing a service area amendment in
connection with this application?
____ Yes

____ No

NOTE: An Applicant’s CDE Certification Application must be submitted through AMIS no later than
5pm Eastern Time on the date of the CDE Certification deadline specified in the NOAA to be
considered for an NMTC Allocation in this Round. The CDE Certification Application is available on
the CDFI Fund’s website at www.cdfifund.gov. The CDFI Fund cannot process a CDE Certification
Application unless each entity seeking certification as a CDE: a) is a legal entity and is a domestic
corporation or partnership for federal tax purposes; and b) has a valid and distinct EIN.CDE
service area amendment requests will not be considered for purposes of this application
unless filed by the deadline stated in this Round’s NOAA.

7. Identify the type of service area that the Applicant will serve. The service area identified here must be
identical to the service area identified by the Applicant in its CDE Certification Application approved
by the CDFI Fund:
National service area
Multi-state service area
Statewide (or territory-wide) service area
Local service area (e.g., neighborhoods, cities, a county or contiguous counties, or
metropolitan areas) within a state or territory

NOTE: The CDFI Fund will use the most recently approved CDE certification service area
information for Applicants with a Multi-state, Statewide or Local service area. This includes any
service area amendments submitted by the Applicant that adhere to criteria in the NOAA.
NOTE: If an Applicant would like to focus its investments in this Allocation Application on a subset
of its certified service area, it may discuss this in the narrative response to Question #17.

8. If the Applicant has a national service area, please identify at least one state and up to six additional
states for which you expect to receive the largest amount of projected Qualified Low-Income
Community Investments (QLICIs).
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6

State(s):

9. Estimate the percentage of activities, by dollar amount that will be directed to each of the following
markets. The total percentage should add up to 100 percent of the NMTC Allocation amount.

% Major urban areas (Counties in metropolitan area with a population
equal to or greater than 1 million, including both central city and
surrounding suburbs)
% Minor urban areas (Counties in metropolitan area with a population less than 1
million, including both central city and surrounding suburbs)
% Non-metropolitan Counties

10. Please indicate the Applicant’s predominant anticipated financing activity (check only one):
____ Operating Business financing
____ Real Estate financing: (check only one accompanying sub-category)
____ Retail

____ Office Space

____ Industrial/Manufacturing

____ For-sale housing

____ Community Facilities

____ Mixed-use (housing, commercial, or retail)

____ Other Real Estate Financing: _________________
____ Financing of other CDEs
____ Loan purchase from other CDEs
____ Financial Counseling and Other Services
11. Executive Summary:
Provide a summary of the Applicant’s business strategy including the following: (Maximum
Response Length: 3,000 characters)
 A brief summary of the Applicant’s service area, including the specific needs or challenges
that it intends to address with NMTCs.
 A brief summary of how the Applicant’s overall community development strategy and
NMTC investments will address the specific needs or challenges identified.

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7

NOTE: Note that Question #11 is meant to be a brief summary of the Applicant’s overall business
strategy, thus it is not necessary to provide a detailed discussion of items that will be specifically
covered in detail in other parts of the Business Strategy section. Applicants may discuss the
strategy of the Controlling Entity if one has been identified.

12. Estimate how long this Allocation Application form took to complete: ________ hours

NOTE: For the purpose of estimating hours, Applicants should focus only on the amount of time it
took to complete the questions asked in this application. Other activities that are carried out in the
normal course of business and are only indirectly related to the completion of this application (e.g.,
securing investor Commitments; developing a business strategy or marketing plan; etc.) should not
be included in this estimation. In the electronic on-line application form, you will not be able to
answer this question until all other application questions are complete. You must answer
this question in order to complete and submit the on-line application.

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8

SIGNATURE PAGE

NOTE: The Authorized Representative is required to sign the Allocation Application in AMIS. DO
NOT SUBMIT THIS SIGNATURE PAGE ALONG WITH YOUR APPLICATION. The Authorized
Representative is required to select a checkbox in AMIS that will represent the signature for the
Allocation Application. The text below is a sample of the signature language the Authorized
Representative will attest to in AMIS. Applicants can refer to the Electronic Application Instructions
for additional guidance on how the Authorized Representative electronically signs the Allocation
Application.

By selecting the checked box: I hereby consent to conducting this transaction by electronic means, and I hereby agree
that I have executed an electronic process that constitutes, and provides the CDFI Fund with, my electronic signature,
which shall be treated as an original signature and as having signed this Application, just the same as a pen-andpaper signature; I hereby acknowledge that all information contained in this Application and any attachments or
supplements thereto will be subject to disclosure pursuant to the Freedom of Information Act (FOIA) 5 USC 552, et
seq.; I hereby certify that all of the information that the Applicant has provided in this Application is true, correct, and
complete to the best of my information, knowledge and belief; I hereby certify that the execution and submission of this
Application has been duly authorized by the governing body of the Applicant; and hereby certify that I am aware that
any false, fictitious, or fraudulent statements or claims may subject me to criminal, civil, or administrative penalties.
(U.S. Code, title 218, Section 1001).

Authorized Representative Signature ___________________
Signature Checkbox:
Authorized Representative Title: ____________________
Date: ______________

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9

NOTE: If the Applicant has a Controlling Entity, the Controlling Entity Representative is required to
print and sign the Controlling Entity Signature Page and upload it as an attachment to the
Allocation Application in AMIS. Applicants should refer to the Electronic Application instructions for
guidance on how to print and upload the Controlling Entity Representative Signature Page. Below
is a sample of the format and signature language the Controlling Entity Representative will attest to
in AMIS. DO NOT SUBMIT THIS SIGNATURE PAGE ALONG WITH YOUR APPLICATION.

Controlling Entity’s Certification
[YEAR] NMTC Allocation Application
Applicant Name:
Control Number:
By signing this Allocation Application:


I hereby certify that all of the information that the Applicant has provided in this Allocation
Application and in the Assurances and Certifications in support of this Allocation Application is
true, correct, and complete to the best of my knowledge, information and belief. The execution and
submission of this Allocation Application has been duly authorized by the governing body of the
Applicant.



I hereby acknowledge that all information contained in this application and any attachments or
supplements thereto will be subject to disclosure pursuant to the Freedom of Information Act
(FOIA) 5 USC 552, et seq.



I hereby certify that the Controlling Entity is indeed the Controlling Entity of the Applicant and
supports this Allocation Application.

Controlling Entity Name:
____________________________________________
Controlling Entity Representative Name:
_____________________________________________
Controlling Entity Representative Title (Print)
_____________________________________________
Controlling Entity Representative Signature:
_____________________________________________
Date:
_____________________________________________

NMTC Allocation Application Template for Public Comment - April 2021
10

PART I: BUSINESS STRATEGY
Information in Part I is scored during the Phase I stage of the Application review. Total Maximum Points for
Part I: 25 points, plus up to 10 additional “priority points” available under sub-sections B and E.
Information provided in this section will also be evaluated during the Phase II stage of the Application
review. For more information on the NMTC Allocation Application review process, please consult the
NOAA.

NOTE: An Applicant will score well in this section to the extent it can articulate, with specificity, its
strategy to use an NMTC Allocation and can describe a strong, relevant track record, including a
track record of serving LICs. Included in this section is the ability to earn “priority points” for meeting
the statutory priorities of: 1) investing in Unrelated entities; and/or 2) demonstrating a track record
of serving Disadvantaged Businesses or Disadvantaged Communities. Refer to the NOAA for
further information on the statutory priorities.

A. Products, Services, and Investment Criteria
NOTE: For the purposes of completing the Business Strategy section and all relevant exhibits, Real
Estate Activities refers to the development (including construction of new facilities and
rehabilitation/enhancement of existing facilities), acquisition, management, or leasing of real estate.
Non-Real Estate Activities refer to all other types of business activities.
NOTE: An Applicant will score well under the Products, Services, and Investment Criteria subsection to the extent that it clearly describes its financial products and will deploy debt or equity
capital, or offer products and services that feature more favorable rates, terms, structuring and nontraditional features when compared with market offerings. Please note, these criteria do not apply
for an Applicant who intends to use its NMTC Allocation to pursue Financial Counseling and Other
Services (FCOS) as their sole line of business.

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11

NOTE: The NOAA states, “As a condition of eligibility for this Allocation Round, the Applicant will
not be permitted to use the proceeds of Qualified Equity Investments (QEIs) to make Qualified
Low-Income Community Investments (QLICIs) in Qualified Active Low-Income Community
Businesses (QALICBs) where QLICI proceeds are used, in whole or in part, to repay or refinance a
debt or equity provider whose capital was used to fund the QEI, or are used to repay or refinance
any Affiliate of such a debt or equity provider, except where: (i) the QLICI proceeds are used to
repay or refinance documented reasonable expenditures that are directly attributable to the
qualified business of the QALICB, and such reasonable expenditures were incurred no more than
24 months prior to the QLICI closing date; or (ii) no more than five percent of the total QLICI
proceeds from the QEI are used to repay or refinance documented reasonable expenditures that
are directly attributable to the qualified business of the QALICB. Refinance includes transferring
cash or property, directly or indirectly, to the debt or equity provider or an Affiliate of the debt or
equity provider.”
If the Applicant selects “No” to Question #13(a), then the Applicant will not be eligible to submit this
NMTC Allocation Application. If the Applicant selects “Yes” to Question #13(a), the Applicant will be
held to this commitment as a condition of its Allocation Agreement. For additional information,
please see the NMTC Compliance & Monitoring Frequently Asked Questions.

13. QLICI Uses and Activities
(a) Will the Applicant commit that it will not permit the use of the proceeds of QEIs to make any QLICIs in
QALICBs where QLICI proceeds are used to repay or refinance any debt or equity provider or a party
related to any debt or equity provider whose capital was used to fund the QEI except where: (i) the
QLICI proceeds are used to repay documented reasonable expenditures that are directly attributable
to the qualified business of the QALICB, and such reasonable expenditures were made no more than
24 months prior to the QLICI closing date; or (ii) no more than five percent of the QLICI proceeds are
used to repay or refinance prior investment in the QALICB? Refinance includes transferring cash or
property directly to any debt or equity provider or indirectly to a party related to any debt or equity
provider.
____ Yes

____ No

(b) Please indicate the activity types of QLICIs in which the Applicant intends to engage (check all that
apply), and what percentage of allocations (by dollar amount) will be used for each activity type.
(Percentages for (i)-(iv) should add up to 100 percent):
(i) ___ % Investments in, or loans to, Qualified Active Low-Income Businesses (QALICB).
Loans/investments will be used to finance: (these three percentages should add up to 100
percent by dollar amount)
____ %

Non-Real Estate Activities

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12

____ %

Real Estate Activities where the real estate will be owned (either
directly or through an Affiliate) and principally occupied by an
Operating Business.

____ %

Real Estate Activities where the real estate will be principally
leased to third-party tenants or sold to a third-party.

(ii) ___ % Investments in, or loans to, other CDEs.
Please indicate the percentage of each activity (by dollar amount) in which the final
recipient CDEs intend to engage, using the proceeds of the NMTC investments provided
by the Applicant. Percentages should add up to 100 percent.
% Origination of loans, investment of capital, or equity to QALICBs
% Financial Counseling and Other Services
(iii) ___ % Purchases of loans from other CDEs.
(iv) ___ % Financial Counseling and Other Services.
In conjunction with financing (check, if applicable)
As a discrete line of business (check, if applicable)
14. Products, rates and terms that the Applicant intends to offer:
NOTE: If an Applicant intends to utilize its requested NMTC Allocation to engage solely in either the
purchase of loans from other CDEs or in the provision of FCOS, and not in the origination of loans
or equity, it should skip Questions #14 and #15.
NOTE: The Applicant should base expected percentage of Allocation on the Applicant’s intended
strategy. Expected percentages of Allocation will not be subject to reporting or be considered in
measuring compliance with the Allocation Agreement.

(a) Indicate the number of financial products the Applicant intends to offer with capital raised from an
NMTC Allocation. A financial product may consist of one or more financial notes. Applicants may
describe up to three separate financial products.
Financial Product
Number

Financial Product Name

Expected Percentage of
Allocation (must add up to
100%)

Financial Product 1
Financial Product 2
Financial Product 3

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13

NOTE: If the Applicant indicates it will be providing more than one financial product in Question
#14(a), the Applicant should provide a distinct and unique narrative description for each financial
product. Applicants that use the same narrative text for different financial products will not be
scored as favorably. To the extent the Applicant indicates a range of offerings within an item listed
above (e.g., interest rates from 100 basis points (bps) to 500 bps below market), it should describe
what circumstances would dictate the specific rates or terms, and how often the best rates and
terms would be offered.
NOTE: For each product, the Applicant should clearly discuss how the product is structured as well
as benefits this structure provides to borrowers/investees. A financial product structured with
multiple financial notes (e.g., an A and B note, or an A, B, and C note, etc.) must be described as
one financial product. In this case, the rates and terms of the financial notes should be discussed
on a blended basis. For additional guidance on calculating blended interest rates, see the
Application FAQ. The individual financial notes should not be listed as separate products unless
they will also be offered on a stand-alone basis. Applicants will not be scored as favorably if they do
not follow these instructions.
NOTE: The sheer number of financial products selected by the Applicant in Question 14(a) has no
effect on the scoring of the Allocation Application.
NOTE: The Applicant may discuss other flexible or non-traditional features of its financial products
in Q.14(b). Only the non-traditional and flexible features listed below are subject to reporting and
only these features will be considered in measuring compliance with the Allocation Agreement.

(b) For each financial product selected in Question 14(a), provide a narrative that addresses the
following elements:





Indicate whether the product is debt, equity, or some combination of the two. If debt,
describe if it will have any equity equivalent features (e.g. convertible debt, debt with
warrants, etc.) and which of the following flexible or non-traditional features the Applicant
intends to include as part of the financial product:
o Below market interest rates (or rate of return in the case of Equity Investments)
o Lower than standard origination fees
o Longer than standard period of interest-only loan payments
o Higher than standard loan-to-value ratio
o Longer than standard amortization period
o More flexible borrower credit standards
o Non-traditional forms of collateral
o Lower than standard debt service coverage ratio
o Subordination
Include a brief description of the rates and terms that will be offered with its NMTC financial
product and explain how these rates and terms compare with what is typically offered by the
Applicant (or its Controlling Entity) and in the Applicant’s service area.
Provide an example of how the product will be used (alone or in conjunction with non-NMTC
capital) to finance a projected NMTC investment identified in Question 17.
(Maximum Response Length: 5,000 characters)

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(c) For an Applicant that indicated under Question #13(b) that it intends to finance other CDEs,
describe the strategy by which the Applicant will ensure that those CDEs will pass along the
NMTC benefits to their QALICB borrowers in the form of more favorable rates or terms. Provide an
example of how the QLICI in a recipient CDE will be used (alone or in conjunction with non-NMTC
capital) to finance a projected investment identified in Table A5 and will result in more favorable
rates and terms. (Maximum Response Length: 3,000 characters)

15. Choose one of the following options. (check only one)
The Applicant will commit that 100 percent of its QLICIs will:
___ (a) be provided in the form of equity; equity-equivalent financing; debt with interest rates
at least 50 percent below market; or debt that otherwise satisfies at least 5 indicia of
flexible or non-traditional rates and terms, as listed in Question 14.
___ (b) be provided in the form of equity; equity-equivalent financing; debt with interest rates
at least 33 percent below market; or debt that otherwise satisfies at least 4 indicia of
flexible or non-traditional rates and terms, as listed in Question 14.
___ (c) be provided in the form of equity; equity-equivalent financing; debt with interest rates
at least 25 percent below market; or debt that otherwise satisfies at least 3 indicia of
flexible or non-traditional rates and terms, as listed in Question 14.
___ (d) be provided in the form of equity; equity-equivalent financing; debt with interest rates
at least 15 percent below market; or debt that otherwise satisfies at least 2 indicia of
flexible or non-traditional rates and terms, as listed in Question 14.
___ (e) None of the above.
___ (f)

Not Applicable. The Applicant indicated that it will not make loans/investments to
QALICBs in the Question 13(b)(i).

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NOTE: Applicants will score better to the extent they commit to provide equity or equity-equivalent
financing; interest rate reductions on their debt; and/or a higher number of flexible/non-traditional
rates and terms. An Applicant may meet this commitment by meeting one or more of the criteria
listed above. Applicants will not be guaranteed a higher score simply by offering products with a
minimal interest rate. An Applicant that checks one of the options a-d in Question #15 above
should be aware that this commitment will be a condition of its Allocation Agreement with
the CDFI Fund.
Please refer to the Application FAQ document for guidance on how to calculate below market
interest rates.

16. For an Applicant that indicated under Question #13(c) above that it plans to purchase qualifying loans
from other CDEs:
(a) Will the Applicant require the CDE from which it purchases loans to reinvest all or a portion of
the proceeds from the loan sales in QLICIs?
___ Yes ___ No
If yes, identify the percentage: _____%; and briefly describe the Applicant’s mechanisms for
enforcing this requirement:
(Maximum Response Length: 2,000 characters)

NOTE: An Applicant purchasing loans from other CDEs generally will not score favorably in the
Business Strategy section unless it indicates, in Question #16(a), that it will require the CDE from
which it purchases loans to reinvest at least 85 percent of the proceeds from the loan sales in
QLICIs. The higher the percentage identified in Question #16(a), the better the Applicant will score
under the Business Strategy section. However, if the Applicant receives an NMTC Allocation, it
will be required to meet the percentage identified above, and such requirement will be a
term of its Allocation Agreement.

(b) Describe the extent to which the Applicant intends to purchase loans that include rates, terms
and/or with conditions that would not be possible without the benefit of an NMTC Allocation.
(Maximum Response Length: 2,000 characters)

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B. Projected Business Activities
NOTE: Projected activities should be consistent with an Applicant’s request for an NMTC Allocation
and the QLICI activities selected in Question 13(b). An Applicant that has a set of clearly-defined
potential business activities and that can demonstrate an effective strategy for locating qualifying
loans/investments in businesses and/or other eligible QLICI activities will score well under this subsection.

NOTE: An Applicant must provide sample transactions in Table A5 with total QLICI needs
equivalent to the Applicant’s NMTC Allocation request in Question #1. These sample transactions
should be representative of the types of projects that will be undertaken with an NMTC Allocation. If
an Applicant intends to invest in a variety of business types (e.g. community facilities, retail,
industrial, etc.) and activity types (e.g. loans to QALICBs, investments in CDEs, loan purchases
from CDEs, etc.), it should provide a sample project for each business type in Table A5. An
Applicant should also indicate whether pipeline transactions may involve multiple CDEs.
NOTE: It is not expected that the Applicant will invest in all of the listed projects. In the event an
Applicant receives an allocation, the CDFI Fund recognizes that the Applicant may invest in
projects not included in Question #17 and Table A5. Note, however, the CDFI Fund expects
investments not presented in Question #17 and Table A5 will be clearly consistent with the
Applicant’s business strategy.
NOTE: Where the Applicant anticipates investment in a small dollar loan fund (equal to or less than
$4MM) and/or a revolving loan or equity fund, in most cases the "Small Dollar and/or Revolving
Loan Fund” should be described as a single investment for the purposes of Table A5. Generally it
is not necessary in Table A5 to separately identify all of the pipeline investments that could be
financed under that fund. Additional guidance on describing revolving loan funds in Question 17
and Table A5 will be provided in the Application FAQ document.

17. Projected NMTC Investments
(a) Complete Tables A1-A4, as applicable, according to the types of QLICI activities in which the
Applicant intends to engage.
(b) Complete Table A5 for each QALICB or NMTC activity to be financed using the Applicant’s
requested NMTC Allocation in Question #1.
(c) Please provide a narrative describing the Applicant’s planned investments, including:


The total number of businesses or CDEs already identified, including the total dollar amount of
NMTC financing (e.g. QEI and QLICI amount) to be provided. Total QEI needs should be
equivalent to the Applicant’s allocation request in Question #1; be sure to indicate what portion
of the Applicant’s pipeline falls into different business types (e.g. community facilities, retail,

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industrial, etc.) and activity types (e.g. loans to QALICBs, investments in CDEs, loan
purchases from CDEs, etc.).


Describe the factors that inform the Applicant’s investment strategy, including
borrower/investee selection criteria, the capital needs of its borrowers/investees, range of
dollar amounts of proposed NMTC investments, etc.
(Maximum Response Length: 8000 characters)

18. Describe the due diligence that the Applicant will conduct to determine, prior to making a QLICI, a
QALICB’s ability to remain financially viable and operational during the NMTC compliance period and
through a successful exit of the QLICI.


Please describe any documents that will be required from borrowers/investees.



Please describe the types of analysis that will be performed on projected NMTC investments
to make this determination.
(Response Length: 3000 characters)

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19. Innovative Investments
NOTE: Question #19 will not be evaluated and scored in Phase I of Allocation Application reviews.
Therefore, this question will not be used to determine whether an Applicant scored highly enough
to receive consideration for an NMTC Allocation. The response to this question will be considered
in Phase II of the Allocation Application reviews and may affect the size of the Applicant’s NMTC
Allocation (along with other evaluation criteria as discussed in the NOAA). For more information on
the Allocation Application review process, please see the NMTC Program Application Presentation
Slides on the NMTC page of the CDFI Fund’s website and the NOAA.
NOTE: If selecting the innovative QLICIs option, note that no particular activity is preferred over
another. Applicants are required to provide the percentage of total QLICIs to be used for each
innovative investment type. If the Applicant receives an NMTC Allocation, it may be required to
meet the percentage identified in Question #18 and such requirement may be a term of its
Allocation Agreement. The CDFI Fund will only consider the activities listed in Question 18 as
innovative investments of an NMTC Allocation.
NOTE: If the Applicant proposes to pursue innovative QLICIs by investing in states that have
historically received fewer dollars of QLICIs, the Applicant should refer to the Application FAQ to
find the list of 10 states (plus Puerto Rico) that have received the least QLICI investments through
FY 2017, based on AMIS Compliance and Performance Reporting System (ACPR) reporting data.

Please indicate the percentage of total QLICIs to be used for each of the following innovative
investments:

%

Investing in Unrelated CDEs that do not have NMTC Allocations;

%

Investing in Unrelated Minority-owned or controlled or Native American-owned or
controlled CDEs that do not have NMTC Allocations;

%

Investing in states identified by the CDFI Fund as having received fewer dollars of
QLICIs historically;

%

Providing QLICIs where the total QLICIs received by the QALICB are $4 million or
less;

%

Making QLICIs with an original term less than or equal to 60 months;

%

Providing QLICIs for non-Real Estate Activities, such as working capital, inventory
or equipment purchase; and

%

Investing in Federal Indian Reservations, Off-Reservation Trust Lands, Hawaiian
Home Lands, and Alaska Native Village Statistical Areas.

If the Applicant entered a percentage above, discuss the Applicant’s strategy to deploy QLICIs for the
innovative investment type(s) selected above. The Applicant should reference sample transactions
from Question #17c and Table A5, as well as its track record of similar activities in the past.
(Maximum Response Length: 5,000 characters)

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C. Prior Performance
NOTE: An Applicant that can demonstrate (either on its own or through its Controlling Entity) a
strong, successful track record of providing products, services, or FCOS similar to those that it
intends to provide with QEI proceeds will score well under this sub-section. Only the organizational
track record of the Applicant or the Controlling Entity may be referenced. The track record of the
Controlling Entity must include the financing activities (loans and Equity Investments) of all
Subsidiaries of the Controlling Entity, including the Applicant if the Applicant is a Subsidiary of the
Controlling Entity. The track record of the Applicant must include the financing activities of all
Subsidiaries of the Applicant. The track records of staff, Principals, board members and other
management individuals are not relevant for this sub-section. There will be an opportunity to
discuss individual qualifications in the Management Capacity section of this application.

20. Track Record (Tables B1-B3)
Does the Applicant, or its Controlling Entity, have a track record of directly providing or otherwise
facilitating loans or Equity investments to Real Estate and Operating Businesses (excluding Restricted
NMTC Business Activities), loans or Equity investments to CDEs, or purchasing loans from CDEs
which correspond to the activities in Question #13 and described in Question #17?
____ Yes (complete Questions #20(a) and (b))

____ No

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NOTE: The NMTC Program authorizing statute requires the CDFI Fund to give priority to any
Applicant that has a track record of successfully providing capital or technical assistance to
Disadvantaged Businesses or Disadvantaged Communities. An Applicant may receive up to five
“priority points” for demonstrating such a track record. Responses to Question #20 and Question
#21 as well as Exhibit B, are used to determine the amount of “priority points.” Only the
organizational track record of the Applicant or the Controlling Entity may be referenced. Do not
refer to the track record of individuals (e.g., staff, Principals, consultants) associated with the
Applicant or its Controlling Entity.
NOTE: The Applicant may reference, in the Tables in Exhibit B and in the narratives in Question
#20(b) and Question #21(b) (if applicable), loans or Equity Investments that the Applicant (or its
Controlling Entity) has itself financed and for which it has capital at risk (direct
financing/investment). Only loans or Equity Investments may be included in the Tables in Exhibit B
and in the narratives in Question #20(b) and Question #21(b). Grants provided by the Applicant or
Controlling Entity may not be included. Please note that capital provided to non-profit businesses
that are not in the form of a loan will be considered grants and should not be referenced in
Question #20, Question #21 or included in Exhibit B. For additional details on completing Exhibit B,
please refer to the NMTC Application FAQ document.
NOTE: An Applicant that demonstrates a longer track record of providing similar direct
financing/investments or FCOS to entities that are not Affiliates (either on its own or through its
Controlling Entity) will generally score higher in this section than an Applicant that demonstrates a
shorter track record of direct financing/investments or FCOS. An Applicant (either on its own or
through its Controlling Entity) will score lower in this section if its track record is comprised primarily
or exclusively providing indirect financing/investments, and/or a track record of primarily or
exclusively financing Affiliates.
NOTE: If an Applicant intends to utilize its NMTC Allocation to engage in the provision of FCOS as
a discrete line of business (as indicated in Question #13), it must include the following in its
narrative response to Question #20(b): (1) the number of businesses/entrepreneurs to which the
Applicant has provided counseling or other services in the last five years; and (2) the percentage of
those businesses/entrepreneurs that were located in Low-Income Communities. This information
will be used to evaluate the Applicant’s eligibility to receive “priority points” for demonstrating a
track record of successfully providing capital or technical assistance to Disadvantaged Businesses
or Disadvantaged Communities.
Please note that if an Applicant intends to use its NMTC Allocation to engage in the provision of
FCOS as its sole line of business, and not in the purchase or origination of loans or Equity
Investments, it does not need to complete Tables B1-B4.
NOTE: Tables B1-B3 will stay hidden in AMIS unless you select a “yes” response for the related
sub-question for Q. 20 (ex. track record of directly providing or otherwise facilitating loans or Equity
investments to Real Estate and Operating Businesses (excluding Restricted NMTC Business
Activities), loans or Equity investments to CDEs, etc.).

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(a) Complete Tables B1-B3, as applicable, based on the Applicant’s selections in Question 13.
(b) Provide a narrative discussion of the organization’s track record relevant to each type of activity
selected (including FCOS) in Question #13, referencing data included in Tables B1-B3, as
appropriate. Applicants that intend to use the NMTC Allocation to make loans to or investments in
QALICBs should describe the similarity between their track record and the types of businesses to
which they plan to provide QLICIs. (Maximum Response Length: 10,000 characters)


Be as specific as possible with respect to the uses of past financing (e.g. construction, new
equipment purchase, etc.). Also indicate which activities were undertaken by the Applicant,
as opposed to its Controlling Entity (including its Subsidiaries).



If an Applicant submit its Controlling Entity’s track record for Exhibit B, be sure to indicate
the dollar amounts that refer to the Applicant’s track record versus the Controlling Entity’s
(including its Subsidiaries) track record of direct financing (i.e., its own capital at risk). Also
discuss the Applicant’s versus the Controlling Entity’s track record of indirect financing (e.g.,
loan packaging, project development, etc.). Also, indicate the extent (including the number
and dollar amount) that loans or investments were made to Affiliates of the Applicant or its
Controlling Entity.



Focus the discussion specifically on the Applicant’s or its Controlling Entity’s experience
targeting Disadvantaged Businesses or Disadvantaged Communities.

(c) Provide the overall number of years that the Applicant or its Controlling Entity has provided
capital or technical assistance to Disadvantaged Businesses or Disadvantaged Communities.
(Maximum response limit: 3 numbers)

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21. Track Record (Table B4)
NOTE: See the Application FAQ for additional guidance on the types of “Financing/Investment
Activities that would not qualify as QLICI Activities.”

(a) Complete Table B4, if applicable. Does the Applicant, or Controlling Entity, have a track record of
successfully providing loans, Equity Investments, and/or financial counseling that do not directly
correspond to the selections in Question #13 (e.g. Restricted NMTC Activities, loans and/or
investments in NMTC investment funds or non-CDE financial institutions, personal or consumer
loans, and residential mortgages) but are similar to the proposed NMTC activities?
____ Yes

____ No

(b) Referencing Table B4 as appropriate, describe the Applicant’s, or Controlling Entity’s, track record
over the past five years of successfully providing the loans or Equity Investments and financial
counseling included in Table B4 and how these activities are similar to the proposed NMTC
activities:
(Maximum Response Length: 5,000 characters)

(c) Provide the overall number of years that the Applicant’s or its Controlling Entity has provided
capital or technical assistance to Disadvantaged Businesses or Disadvantaged Communities.
(Maximum response limit: 3 numbers)

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D. Non-Metropolitan Counties
NOTE: Question #22 will not be evaluated and scored in Phase I of Allocation Application reviews.
Therefore, this question is not used to determine whether an Applicant scored highly enough to
receive consideration for an NMTC Allocation. The response to this question will be considered in
Phase II of the Allocation Application reviews and may affect the size of the Applicant’s NMTC
Allocation (along with other evaluation criteria as discussed in the NOAA). For more information on
the Allocation Application review process, please see the NMTC Application Roadmap
Presentation on the NMTC page of the CDFI Fund’s website and the NOAA.
NOTE: As provided for in Section 102(b)(6) of the Tax Relief and Health Care Act of 2006 (Pub. L.
109-432), and described further in the NOAA and the FAQ document that accompanies this
application, the CDFI Fund has established the goal that: (i) 20 percent of all QLICIs made by
Allocatees under this Round are invested in Non-Metropolitan Counties; and (ii) a proportionate
number of Rural CDEs (as defined in the NOAA) receive allocation awards.
Applicants are therefore required to provide two target estimates below: (1) a minimum percentage
of QLICIs the Applicant is willing to commit to provide to Non-Metropolitan Counties; and (2) the
maximum percentage of QLICIs that the Applicant is willing to commit to providing to NonMetropolitan Counties. At the discretion of the CDFI Fund, the Applicant may be required to deploy
a percentage of its allocation at or above the minimum indicated in Question #22(b), but not more
than the maximum percentage indicated in Question #22(c); and such requirement shall become a
condition of its Allocation Agreement with the CDFI Fund.
NOTE: An Applicant that presents a minimum of a three-year track record of direct financing in
Exhibit B, responds “Yes” to Question #22(a) (including an appropriate supporting narrative), and
commits to a figure of 50 percent or greater in response to Question #22(c) may be deemed to be a
“Rural CDE”, and may be eligible to receive special consideration for an NMTC Allocation in
accordance with the process outlined in the NOAA. For more information, see the Application FAQ.
An Applicant may receive a larger NMTC Allocation than would otherwise be the case, regardless
of designation as a Rural CDE, if it: (i) makes a minimum commitment of 20 percent or greater in
response to Question #22(b); (ii) has a track record of providing direct financing in NonMetropolitan Counties and a strong strategy for deploying NMTC investments in these
communities; and (iii) is ranked highly enough to be considered for an NMTC Allocation.
In accordance with the NOAA for this round, in the event the CDFI Fund adds additional Rural
CDEs to the Allocatee pool in order to achieve the targeted percentage of investment in NonMetropolitan Counties, a formula reduction will be applied as uniformly as possible, to the allocation
amount for all Allocatees in the pool that have not committed to investing a minimum of 20 percent
of their QLICIs in Non-Metropolitan Counties.

22. Non-Metropolitan Counties
(a) Have at least 50 percent of the Applicant’s (or Controlling Entity’s) total direct financing dollars
over the past five years, as shown in Exhibit B, been directed to Non-Metropolitan Counties?
______ Yes

______ No

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(b) Provide the number of years (ranging from 0-6) that the Applicant’s or its Controlling Entity has
provided direct financing/investment dollars to Non-Metropolitan Counties, as shown in Exhibit B.

(c) What is the minimum percentage of QLICIs that the Applicant is willing to commit to deploy in NonMetropolitan Counties?
______%
(d) What is the maximum percentage of QLICIs that the Applicant is willing to commit to deploy in
Non-Metropolitan Counties?
(Note: this value must be equal to or greater than the value for Question #22(b)).
______ %
(e) If the response to Question #22(c) above is greater than zero percent, referencing Exhibit B, briefly
describe the Applicant’s (or its Controlling Entity’s) five-year direct financing track record in NonMetropolitan Counties in Tables B1-B3 and Table B4. Specifically, describe the types of projects
and the dollar amounts that the Applicant (or its Controlling Entity) provided directly to projects
located in Non-Metropolitan Counties. See the Application FAQ.
(Maximum Response Length: 2,000 characters)

NOTE: Applicants can and should list specific Non-Metropolitan transactions in response to
Question #17 and Table A5. These transactions should be referenced in response to Question
#22(e) as necessary to explain the Applicant’s strategy for deploying QLICIs in Non-Metropolitan
Counties.

(f) If the response to Question #22(c) above is greater than zero percent, and only to the extent not
discussed elsewhere in the application, discuss the Applicant’s strategy for deploying QLICIs in
Non-Metropolitan Counties.
(Maximum Response Length: 5,000 characters)


Indicate the number and dollar amount of transactions that have already been identified in
Non-Metropolitan Counties, for which underwriting is completed or underway.



Reference sample transactions in the Applicant’s Non-Metropolitan pipeline included in
Table A5.



Discuss the key challenges the Applicant anticipates it will have providing QLICIs in NonMetropolitan Counties and how the Applicant proposes to overcome those challenges.

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E. Investments in Unrelated Entities
NOTE: The NMTC Program legislation requires the CDFI Fund to give priority to Applicants that
intend to use “substantially all” of their QEI proceeds to make investments in one or more
businesses in which persons Unrelated to the Applicant hold the majority equity interest. An
Applicant that answers “Yes” to Question #23 will be awarded five additional points. An Applicant
that receives priority points under this sub-section will be required, in its Allocation Agreement, to
invest substantially all of its QEI proceeds in Unrelated entities. Please refer to the NMTC
Allocation Application FAQ document for more information about what is considered an Unrelated
entity transaction.

23. Does the Applicant intend to use substantially all of the proceeds of its QEIs to make QLICIs in one or
more businesses in which persons Unrelated to the Applicant hold the majority equity interest?

____ Yes ____ No
24. Notable Relationships

NOTE: Question #24 will not be evaluated and scored in Phase I of Allocation Application reviews.
Therefore, this question will not be used to determine whether an Applicant scored highly enough
to receive consideration for an NMTC Allocation.
NOTE: If the Applicant describes instances where the Applicant, Affiliates, or personnel will receive
financial benefits from the QALICBs financed, the Applicant will be evaluated favorably in Phase II
if it demonstrates that these relationships would provide clear benefits (e.g. cost savings, lower
lease rates or fees) for unaffiliated end-users (e.g., QALICBs, tenant businesses, or residents) in
Low Income Communities (LICs).
NOTE: The Applicant does not need to answer “Yes” to items (a)-(e) below if the financial benefits
are derived solely due to the Applicant or its Affiliates serving as a leverage debt lender for a QLICI
or providing an equity QLICI.

Describe any potential situations in which the Applicant, its Affiliates (including the Controlling Entity)
or its personnel (including governing or advisory board members, consultants, etc.) involved in
identifying NMTC investments or making investment decisions on behalf of the Applicant will also
receive financial benefits from the QALICBs, Affiliates of QALICBs, QEI investors, and/or other
participants in the transactions resulting in the Applicant’s QLICIs..
(a) Will the Applicant, its Affiliates or its personnel own more than a one percent interest in the
QALICB?
____Yes ____ No

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If “Yes” was selected, describe such situations, including the individuals (and their respective
organizations) involved in identifying NMTC investments or making investment decisions. Also
describe the source and amount of any financial benefit to the Applicant, its Affiliates, or personnel
(including governing or advisory board members, consultants, etc.). Provide an example and
quantify how such relationships will create cost savings for QALICBs and/or benefits to unaffiliated
end-users, such as tenant businesses, or residents of Low-Income Communities. (Maximum
Response Length: 2,000 characters).

(b) Will the Applicant, its Affiliates or its personnel be lessees at property developed with the QLICI?
____Yes ____ No
If “Yes” was selected, describe such situations, including the individuals (and their respective
organizations) involved in identifying NMTC investments or making investment decisions. Also
describe the source and amount of any financial benefit to the Applicant, its Affiliates, or personnel
(including governing or advisory board members, consultants, etc.). Provide an example and
quantify how such relationships will create cost savings for QALICBs and/or benefits to unaffiliated
end-users, such as tenant businesses, or residents of Low-Income Communities. (Maximum
Response Length: 2,000 characters).

(c) Will the Applicant, its Affiliates or its personnel be a party to a business transaction financed with
the QLICIs?
____Yes ____ No
If “Yes” was selected, describe such situations, including the individuals (and their respective
organizations) involved in identifying NMTC investments or making investment decisions. Also
describe the source and amount of any financial benefit to the Applicant, its Affiliates, or personnel
(including governing or advisory board members, consultants, etc.). Indicate if the Applicant has a
conflict of interest policy and describe how it applies to such situations. Provide an example and
quantify how such relationships will create cost savings for QALICBs and/or benefits to unaffiliated
end-users, such as tenant businesses, or residents of Low-Income Communities. (Maximum
Response Length: 2,000 characters).

(d) Will the Applicant, its Affiliates or its personnel (including governing or advisory board members,
consultants, etc.) provide professional services (project development, real estate agent, property
manager, general contractor, etc.) or capital outside of the QLICI for the QALICB, including

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Affiliates of the QALICB and/or other participants in the transactions resulting in the Applicant’s
QLICIs?
____Yes ____ No
If “Yes” was selected, described the fees for such professional services. Are the services and/or
products required to be provided by the Applicant as a condition of receiving the QLICI? Explain
how rates and fees for products and/or services to QALICBs compare with what is typically offered
by the Applicant (or its Controlling Entity) and by other providers in the Applicant’s service area.
Provide a specific example and quantify how such relationships will create cost savings for
QALICBs and/or benefits to unaffiliated end-users, such as tenant businesses, or residents of
Low-Income Communities. (Maximum Response Length: 2,000 characters)

(e) Are there other financial benefits that the Applicant, its Affiliates or its personnel may receive, but
are not included in items (a)-(d) above?
____Yes ____ No
If “Yes” was selected, describe such situations, including the individuals (and their respective
organizations) involved in identifying NMTC investments or making investment decisions. Also
describe the source and amount of any financial benefit to the Applicant, its Affiliates, or personnel
(including governing or advisory board members, consultants, etc.). Provide an example and
quantify how such relationships will create cost savings for QALICBs and/or benefits to unaffiliated
end-users, such as tenant businesses, or residents of Low-Income Communities. (Maximum
Response Length: 2,000 characters).

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28

PART II: COMMUNITY OUTCOMES
Information in Part II is scored during the Phase I stage of the Application review. Total Maximum Points
for Part II: 25 points. Information provided in this section will also be evaluated during the Phase II stage of
the Application review. For more information on the NMTC Allocation Application review process, please
consult the NOAA.

NOTE: The CDFI Fund will review the extent to which the Applicant’s strategy will have positive
community outcomes. An Applicant will generally score well under this section to the extent that:
(a) it is working in particularly economically distressed or otherwise underserved communities;
(b) it shows that its projected financing activities will generate demonstrable community
outcomes; and
(c) it demonstrates meaningful engagement with community stakeholders when vetting
potential NMTC investments.
NOTE: The CDFI Fund does not expect that each and every investment will be in an area identified
in Question #25.

A. Targeting the Use of QLICIs
25. Identify all of the areas to be served by the Applicant (check all that apply):

1. ____

[SEVERE DISTRESS] Census tracts with poverty rates greater than 30 percent; OR
Census tracts with, if located within a non-Metropolitan Area, have a median family
income that does not exceed 60 percent of statewide median family income, or, if
located within a Metropolitan Area, have a median family income that does not exceed
60 percent of the greater of the statewide median family income or the Metropolitan
Area median family income; OR Census tracts with unemployment rates at least 1.5
times the national average.

2. _____

[NON-METROPOLITAN COUNTIES] Qualifying census tracts that are located in
counties not contained within a Metropolitan Statistical Area (MSA), as defined in OMB
Bulletin No. 15–01 (Update of Statistical Area Definitions and Guidance on Their Uses)
and applied to the 2010 census tracts.

3. ____

[TARGETED POPULATIONS] As permitted by IRS and related CDFI Fund guidance
materials, projects serving Targeted Populations to the extent that: (a) such projects are
60 percent owned by Low-Income Persons (LIPs); or (b) at least 60 percent of
employees are LIPs; or (c) at least 60 percent of the QALICBs’ gross income is derived
from sales, rentals, services, or other transactions to customers who are LIPs..

4. ____

[25% POVERTY/70% MEDIAN FAMILY INCOME/1.25 UNEMPLOYMENT RATE]
Census tracts with one of the following: (i) poverty rates greater than 25 percent; or (ii) if
located within a non-Metropolitan Area, median family income that does not exceed 70
percent of statewide median family income, or, if located within a Metropolitan Area,

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29

median family income that does not exceed 70 percent of the greater of the statewide
median family income or the Metropolitan Area median family income; or (iii)
unemployment rates at least 1.25 times the national average.
5. ____

[HUB ZONES] Small Business Administration (SBA) Designated Hub Zones to the
extent QLICIs will support businesses that obtain HUB Zone certification by the SBA.

6. ____

[BROWNFIELDS SITES] as defined under 42 U.S.C. 9601 (39).

7. ____

[HOPE VI REDEVELOPMENT] Areas encompassed by a HOPE VI redevelopment
plan.

8. ____

[FEDERAL NATIVE AREAS] Federally Designated Indian Reservations, OffReservation Trust Lands or Alaskan Native Village Statistical Areas, or Hawaiian Home
Lands.

9. ____

[ARC AND/OR DRA AREAS] Areas designated as distressed by the Appalachian
Regional Commission or Delta Regional Authority.

10. ____

[COLONIAS AREAS] as designated by the U.S. Department of Housing and Urban
Development.

11. ____

[FEDERAL MEDICALLY UNDERSERVED AREAS] Federally designated medically
underserved areas, to the extent QLICI activities will support health related services.

12. ____

[FEDERAL/STATE/LOCAL ZONES] Federally designated Opportunity Zones, Promise
Zones, Base Realignment and Closure areas, State Enterprise zone programs, or other
similar state/local programs targeted towards particularly economically distressed
communities.

13. ____

[FEMA DISASTER AREAS] Counties for which the Federal Emergency Management
Agency (FEMA) has: issued a “major disaster declaration” and made a determination
that such County is eligible for both “individual and public assistance”; provided that the
initial investment will be made within 36 months of the disaster declaration.

14. ____

[HEALTHY FOODS FINANCING INITIATIVE (HFFI) DESIGNATED FOOD DESERTS]
Census tracts identified as Food Deserts under the HFFI definition (USDA-ERS), to the
extent QLICI activities will increase access to healthy food.

(a) Will the Applicant commit to providing at least 85 percent of its QLICIs (in terms of aggregate
dollar amounts) in areas that are either: (1) characterized by at least one of items 1-3 on the above
list for each QLICI; or (2) characterized by at least two of items 4-14 on the above list for each
QLICI?
_____Yes
_____No

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NOTE: An Applicant that checks “Yes” to Question #25(a) above will generally score more
favorably. If the Applicant receives an NMTC Allocation, it will be required to meet the percentage
figure identified above, and such requirement will be a term of its Allocation Agreement.

(b) Discuss how the Applicant will target QLICIs to areas marked by the specific indicators of higher
distress selected in Question #25(a). In particular, please describe the criteria used to prioritize QLICIs,
assuming the Applicant has greater investment opportunities than available Allocation Authority.
(Maximum Response Length: 3,000 characters)

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B. Community Outcomes – Prior Performance and Projections
NOTE: An Applicant may score higher to the extent that its projected activities will generate clear
and well supported outcomes for the Low Income Communities and/or Low Income Persons
affected, the CDFI Fund’s assessment is not simply based on the sheer number of outcomes
selected in Question #26.
NOTE: For purposes of the NMTC Application, a community outcome is a benefit to the LIC,
including LIC residents or Low Income Persons, as a direct result of an Applicant’s loans or
investments referenced in Exhibit A (Projected Activities) and Exhibit B (Track Record) of this
Application.
NOTE: An Applicant will score well in this sub-section to the extent that:
(a) It (or its Controlling Entity) has a track record of producing quantitative community
outcomes similar to those expected to be achieved;
(b) Its projected community outcomes are supported by clear and sound methods and
metrics for each outcome selected;
(c) The projected community outcomes are highly likely to result from the proposed financing
activities described in Question #17;
(d) The projected community outcomes will clearly benefit Low-Income Persons and
residents of Low-Income Communities (LICs). Note that the location in a LIC in and of
itself is not sufficient to demonstrate benefit to LIC residents/LIPs.
NOTE: If an Applicant selects a Community Outcome in Table A5 (row n), then the Applicant is
expected to complete the narrative section for the selected Community Outcome in Question #26a.
NOTE: If an Applicant selects one Job related outcome will result from their QLICI activity, then a
narrative response is required for all three Job related outcomes.

26. Community Outcomes
(a) Select the outcome(s) the Applicant expects to achieve as a result of the projected QEIs described
the Business Strategy section. Select all that apply and for each outcome selected, please:


Quantify the Applicant’s projected community outcomes;



Considering the Applicant’s planned NMTC financing/investments described in Question #17
and listed in Table A5, explain how the Applicant quantified the potential outcomes that
would result from receiving an NMTC Allocation;



Describe and quantify (to the extent possible) the Applicant’s track record of achieving each
selected outcome through past financings/investments. Discuss how the track record of
achieving outcomes compares with projected outcomes.
(Maximum Response Length: 5,000 characters except for 6,000 characters for 5.
Community Goods and Services)

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1.

____

JOB CREATION/RETENTION. Quantify, as best as possible, the number of direct jobs
(either in the aggregate or on average for each project financed) that will be created or
retained through the Applicant’s planned QEIs. Be sure to discuss both temporary jobs
(e.g., construction) and permanent jobs.

2.

____

QUALITY JOBS. Quantify (e.g., provide the number and/or percentage of total jobs) and
discuss the extent to which jobs created or retained by the Applicant’s planned QEIs
represent quality jobs. Quality jobs are jobs that provide living wages (e.g., the minimum
hourly wage necessary for an individual to meet basic needs, including housing, nutrition,
daily living expenses and other incidentals such as clothing, for an extended period of time)
and/or employment benefits (e.g., health insurance, retirement benefits, employee stock
ownership, etc.). Also, discuss the extent to which jobs created through the Applicant’s
QEIs will provide opportunities for training and advancement (particularly for low-skilled
workers). Quantify and describe how temporary and permanent jobs will meet the
Applicant’s criteria for quality jobs.

3.

____

ACCESSIBLE JOBS. Quantify (e.g., provide the number and/or percentage of total jobs)
and discuss the extent to which the jobs created or retained by the Applicant’s planned
QEIs will be targeted and/or available to Low-Income Persons, residents of LICs, people
with lower levels of formal education, and people who face other barriers to employment
(e.g., longer term unemployed, displaced workers, ex-convicts, limited language
proficiency, etc.). Quantify and describe how temporary and permanent jobs will meet the
Applicant’s criteria for accessible jobs.

4.

____

COMMERCIAL GOODS OR SERVICES TO LOW-INCOME COMMUNITIES. Quantify
(e.g., number of residents of Low-Income Communities or Low-Income Persons expected
to be served, square footage built, lower rents provided to tenant businesses, etc.) and
describe the extent to which the Applicant’s planned QEIs will result in the provision of and
access to commercial goods or services to residents of Low-Income Communities or LowIncome Persons, the types of commercial goods and services (e.g., access to retail,
grocery stores, farmer’s markets, restaurants, or pharmacies, etc.) expected to be
provided, and how they will benefit residents of Low-Income Communities or Low-Income
Persons.

5.

____

COMMUNITY GOODS OR SERVICES TO LOW-INCOME COMMUNITIES. Quantify (e.g.
number of people served, square footage built, lower rents provided to tenant businesses,
etc.) and describe the extent to which the Applicant’s planned QEIs will result in the
provision of and access to high quality community goods or services for residents of LowIncome Communities or Low-Income Persons (e.g., food pantries, healthcare, social
services, educational, cultural, etc.).

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6.

____

FINANCING MINORITY BUSINESSES. Quantify and describe the extent to which the
Applicant’s planned QEIs will finance Minority-owned or Minority-controlled CDEs or
businesses, including (in the case of Real Estate Activities) developers, project-sponsors,
tenant businesses, or contractors/subcontractors that are Minority-Owned or MinorityControlled.

7.

____

FINANCING NATIVE AMERICAN BUSINESSES. Quantify and describe the extent to
which the Applicant’s planned QEIs will finance Native American-owned or Native
American-controlled CDEs or businesses, including (in the case of Real Estate Activities)
developers, project-sponsors, tenant businesses, or contractors/subcontractors that are
Native American-Owned or Native American-Controlled.

8.

____

HOUSING UNITS. Quantify (e.g. number of units, percent of affordable units) and describe
the extent to which the Applicant will provide housing opportunities for Low-Income
Persons or residents of Low-Income Communities; the extent to which housing will be
offered in areas of high affordable housing need, including communities with high
concentrations of vacancies or foreclosures or communities where housing costs are high;
and/or the extent to which the housing development adheres to principles of “smart
growth”, including transit-oriented development.

9.

____

ENVIRONMENTALLY SUSTAINABLE OUTCOMES. Quantify (e.g. amount of reduced
energy or water use by QALICB, amount of reduced energy costs by end users, etc.) and
describe the extent to which the Applicant will finance projects which remediate
environmental contamination (including addressing environmental health in Low-Income
Communities); meet Leadership in Energy & Environmental Design (LEED) certification or
similar green building standards; and/or directly support the production or distribution of
renewable energy resources (e.g., biomass, hydro, geothermal, solar, wind, etc.).

(b) Describe the Applicant’s track record of establishing and monitoring community outcomes, if the
Applicant has a track record. Describe how the Applicant will track and document the community
outcomes QALICBs are expected to achieve as a result of the Applicant’s QLICIs. (Maximum
Response Length: 5,000 characters)

NOTE: An Applicant that describes a thorough track record of establishing and documenting past
community outcomes and a methodology for tracking future community outcomes will score higher
on this question.

27. Community Accountability and Involvement

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34

NOTE: All CDEs are required to maintain accountability to Low-Income Communities. An Applicant
that can articulate meaningful involvement in Low-Income Communities and with a variety of LowIncome Community stakeholders, as well as a track record of community engagement (either
directly or through its Controlling Entity) will be evaluated favorably under this question.

(a) Complete Table C1. Please describe the Applicant’s process for evaluating the community
benefits of potential QLICIs and the extent to which the Applicant’s Advisory Board, Low-Income
Persons, and/or residents of Low Income Communities participate in this process. Be sure to
discuss:


The Applicant’s process for determining if a proposed investment aligns with Low-Income
Community priorities and how this process affects investment decisions.



The number and percentage of Low-Income Community representatives on the Applicant’s
Advisory and/or Governing Board.



The role, formal or otherwise, these individuals play in setting investments parameters,
formulating the Applicant’s pipeline of investments, and approving the Applicant’s
investment decisions. Provide examples where possible.
(Maximum Response Length: 5,000 characters)

(b) Discuss the extent of the Applicant’s (or Controlling Entity’s) track record of project-specific
community engagement related to past investment decisions. Please note that simply consulting
with the Advisory Board is not an example of community engagement. Provide 2– 3 examples.
(Maximum Response Length: 3,000 characters)

(c) Discuss the extent of the Applicant’s (or Controlling Entity’s) track record of making investments in
projects that were part of a broader community or economic development strategy (e.g.,
neighborhood revitalization plan, county or state economic development plans, etc.). Provide 2– 3
examples. (Maximum Response Length: 3,000 characters)

(d) Discuss the portion of the Applicant’s planned NMTC financings/investments described in
Question #17 that are part of a broader community or economic development strategy (e.g.,
neighborhood revitalization plan, county or state economic development plans, local strategies to
remediate environmental contamination or reduce greenhouse gases, etc.). Please describe how
one or more of the Applicant’s planned QLICIs will contribute to the goals of such strategies or
initiatives. (Maximum Response Length: 3,000 characters)

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NMTC Allocation Application Template for Public Comment - April 2021
36

PART III: MANAGEMENT CAPACITY
Information in Part III is not scored during the Phase I stage of the Application review. Information provided
in this section will be evaluated during the Phase II stage of the Application review. For more information
on the NMTC Allocation Application review process, please consult the NOAA.
28. Organizational Chart and Key Personnel
(a) Submit organizational chart(s) that depict the following:


The Applicant’s relationship to its Controlling Entity as well as any Affiliate, Subsidiary
entities, or any entities with an ownership interest in the Applicant (if applicable); and



The Applicant’s staffing structure (including names of key personnel that will have
responsibilities managing an NMTC Allocation), including names of Applicant’s Advisory
Board and Governing Board members, key board committees, and consultants; and



the Controlling Entity, names of Controlling Entity’s Governing Board members, and names
of staff members shared with Affiliates, including Controlling Entity

NOTE: Be sure to refer to the Applicant Instructions (page ii) for information regarding the
submission of these documents. All attachments must be submitted electronic through the
Applicant’s AMIS account. An organizational chart is a required document and failure to provide the
required information may negatively impact the evaluation of the Allocation Application.

(b) Complete Table C2. Identify the Applicant’s (and Controlling Entity’s) personnel, including
consultants and board members (if applicable) that will have a key role in:


Providing QLICIs– identifying and underwriting transactions; structuring NMTC loans and
Equity Investments; and/or providing FCOS;



Raising Capital from Investors – including raising tax credit equity and leveraged debt if the
Applicant will use the leveraged investment model;



Asset and Risk Management; and



NMTC Program Compliance.

NOTE: Be sure to identify any and all consultants that will have a key role in assisting the Applicant in
managing an NMTC line of business, including consultants who assisted in preparing the Allocation
Application.
NOTE: The CDFI Fund will only review the first 15 individuals listed in Table C2.

29. Providing QLICIs:
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37

NOTE: The CDFI Fund expects the Applicant’s personnel to have relevant experience in the types
of activities the Applicant intends to pursue with its NMTC Allocation – particularly in situations
where the Applicant (or its Controlling Entity) lacks prior organizational performance in providing
loans or Equity Investments and related functions (e.g. monitoring loan repayments or dividend
payments, managing disbursement of construction draws, etc.).
An Applicant will be evaluated more favorably under this sub-section if it can also demonstrate that
its personnel have experience identifying borrowers or investees in LICs: evaluating business to
determine long-term sustainability; and structuring QLICIs or providing FCOS that meet the needs
of LIC borrowers/investees.

(a) Referencing information from Table C2 as necessary, describe the current roles and
responsibilities of the Applicant’s (and Controlling Entity’s) key personnel (including staff,
Governing or Advisory board members, and consultants) in:




Identifying borrowers or investees and evaluating the business’ financial viability during
the NMTC compliance period;
Structuring its current loans and/or Equity and providing Financial Counseling and Other
Services (if applicable).
Please indicate the percentage of work currently performed by consultants, internal staff,
and board members on the activities referenced in this question.

(Maximum Response Length: 5,000 characters)

(b) Describe how the Applicant will manage the addition of NMTC financing activities into its current
portfolio of activities, specifically:
 If the roles and responsibilities described in Q. 29(a) will change, be sure to describe such
changes;
 Indicate the percentage of work to be performed by consultants, internal staff, and/or
board members; and
 Whether additional staff (or consultants) will need to be hired. (Maximum Response
Length: 2,000 characters)

(c) Based on the activities in Exhibit B, describe the types of due diligence that the Applicant (or its
Controlling Entity) conducted when determining whether to provide financing or investment
(including typically required documents from borrowers/investees and the criteria for determining
the businesses’ financial viability). (Maximum Response Length: 2,000 characters)

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30. Asset and Risk Management Experience:

NOTE: Each Applicant must demonstrate that it has the capacity and relevant experience to
manage the types of assets it intends to invest in with the requested NMTC Allocation, as well as
monitor the QALICB’s use of NMTC proceeds (e.g., construction, equipment purchase, etc.) and
control associated risks (e.g., loan repayments, cash distributions to the investment fund, leverage
lenders, etc.)
NOTE: An Applicant will be evaluated favorably under this sub-section if it has experienced
personnel and appropriate procedures and systems in place to successfully manage a loan and/or
investment portfolio, including informational and performance aspects of administering such assets
or pools of similar assets.

(a) Describe the current roles and responsibilities of the Applicant’s (and Controlling Entity’s) key
personnel, consultants and board members in managing the assets to be financed with an NMTC
Allocation and associated risks. The Applicant should reference personnel’s prior experience from
Table C2 as necessary. Be sure to indicate the percentage of work completed or expected to be
completed by consultants, internal staff, and board members.
(Maximum Response Length: 5,000 characters)

(b) Describe how the Applicant will manage the addition of NMTC assets into its current portfolio of
assets, including whether additional staff (including consultants, third-party firms, or other CDEs)
will need to be hired and whether any of the roles and responsibilities of the Applicant’s (and
Controlling Entity’s) key personnel, consultants and board members described in Question 30(a)
would change. (Maximum Response Length: 2,000 characters)

(c) For each major product line, describe how the Applicant (or Controlling Entity) monitors financial
assets.


Explain how the organization will ensure that QLICI proceeds are used to finance the assets
for which they are intended and identifies borrowers at greater risk (e.g., risk rating system
for a loan portfolio, QALICB reporting, etc.) and how the Applicant responds when assets
are at greater risk.



Indicate if the Applicant (or Controlling Entity) has written asset management and collection
policies and whether it has ever deviated from those policies in the past five years and, if so,
why.



Address the Applicant's strategy for minimizing defaults and managing delinquencies to
mitigate against write-downs or write-offs going forward.
(Maximum Response Length 5,000 characters)

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(d) For the Applicant (or Controlling Entity), complete Table D1 (Investment Portfolio) and discuss the
Applicant’s (or Controlling Entity’s) delinquency rate(s) as of the Allocation Application release
date for each major asset class as well as its default rate (write-offs) over the past three years for
each major asset class. Also:


Describe the trends in delinquencies, write-offs, and defaults as shown in Table D1.



Explain the reasons for any negative results such as an increase or unusual spikes in
delinquencies or write-offs that have occurred.



Describe the measures the Applicant (or its Controlling Entity) has taken to address
delinquencies, including loan restructurings, and write-offs.



If the Applicant, or its Controlling Entity, is a regulated financial institution, please compare
delinquency and default rates with the appropriate peer group.
(Maximum Response Length: 7,500 characters)

NOTE: Delinquency rate means the percentage of loan payments and mandatory dividend
payments, on a dollar basis, that were 90 days past due (i.e., the combined dollar amount of
principal, interest and mandatory dividend payments, 90 days or more past due divided by the total
dollar amount of loans and Equity Investments outstanding).

(e) Discuss any delinquent, defaulted, or impaired loans or Equity Investments from prior NMTC
investments in the last ten years, specifically:



Provide the total value of each investment, its respective allocation year, as well as the
total number of days delinquent and the amount of charged offs.
Discuss the Applicant’s strategies for managing these troubled investments, including any
work-out strategies (e.g. restructuring, forbearance agreements, etc.), as well as any
administrative changes implemented to minimize future delinquencies and writeoffs.(Maximum Response Length: 5,000 characters)

31. Program Compliance Experience:

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40

NOTE: Each Allocatee must have the capacity to remain in compliance with NMTC Program
requirements. An Applicant will be evaluated favorably in this sub-section to the extent that it can:
1) demonstrate experience with similar regulatory compliance requirements, including compliance
under other tax credit programs; and 2) articulate a specific strategy for ensuring that its NMTCrelated investments will qualify at the time of investment and throughout the seven-year credit
period.

(a) Describe the current and planned roles and responsibilities of the Applicant’s (and Controlling
Entity’s) key personnel, consultants and board members in managing the Applicant’s regulatory
and tax compliance. The Applicant should reference information from Table C2 as necessary. Be
sure to indicate the percentage of work completed or expected to be completed by consultants,
internal staff, and board members. (Maximum Response Length: 3,000 characters)

(b) Discuss how the Applicant’s (or Controlling Entity’s) systems and procedures (e.g., portfolio
monitoring, reporting, investment/re-investment strategies) will ensure ongoing compliance with
NMTC Program requirements. Specifically, be sure to indicate how the Applicant will ensure that:
(Maximum Response Length: 10,000 characters)


At least 85 percent of the proceeds of the QEIs are invested in QLICIs in accordance with
the NMTC Program Income Tax Regulations. If the Applicant is providing loans or
investments to another CDE, how will it ensure that the secondary CDE fulfills its investment
requirements?



The businesses that the Applicant invests in are QALICBs, in accordance with the NMTC
Program Income Tax Regulations. If purchasing a portfolio of loans, how will the Applicant
ensure that it purchases loans that are QLICIs?



Payments of, or for, capital, equity, or principal by its borrowers or investees are re-invested
into QLICIs within applicable reinvestment periods. If providing loans to or investments in
another CDE, how will it ensure that the secondary CDE fulfills its re-investment
requirements?

32. CRA and Regulatory Information
(a) If the Applicant, its Controlling Entity, or any of its Affiliates is an insured financial institution that
receives Community Reinvestment Act (CRA) ratings from regulators, has the organization
received CRA ratings within the past five years?
____Yes

____ No

____ Not Applicable

If yes to Question #32a, and the most recent CRA rating is less than “Outstanding”, please describe:
i.
the conditions or circumstances that led to the rating;

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41

ii.
iii.

the steps the institution is taking to achieve an “Outstanding” rating; and
the role that NMTC activities are expected to play in helping the institution to achieve an
“Outstanding” rating.
(Maximum Response Length: 2,000 characters)

(b) Is the Applicant, Controlling Entity, or any Affiliate a federally-regulated thrift, bank, bank holding
company, or credit union (Y/N)?” If “Y” is selected, please complete the following chart Q. 32c,
below:
____Yes

____ No

____ Not Applicable

(c) Regulated Entity Information:

Record
No.

Regulated Entity (ex.
Affiliate, Controlling
Entity, Applicant)

Organizatio
n Name

Is this
entity a
Holding
Company?

State

City

Federal
Regulator

FDIC/NCUA/FRB
Cert. #

33. Financial Health:
Answer the following questions regarding the Applicant’s (or the Controlling Entity’s) financial health.
Indicate if the responses are (check one):
____ For the Applicant (if it has incurred operating expenses).
____ For the Controlling Entity (if the Applicant has not yet incurred operating expenses).
____ Not applicable (neither the Applicant nor the Controlling Entity has incurred operating
expenses).
(a) Have the financial statements for the last complete fiscal year been independently audited or is an
audit underway? ___ Yes
___ No
Please provide fiscal year end date for the last completed independent audit (mm/dd/yyyy). If no
audit has been completed or is underway for the last complete fiscal year, please explain why and
what steps the Applicant, or its Controlling Entity, is taking to obtain audited financials in the future:
(Maximum Response Length: 2,000 characters)

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(b) If “Yes”, have any of the Applicant’s, and its Controlling Entity’s, completed audits within the past
three years (or, if shorter, for the period from inception) indicated any of the following:
1. An opinion other than unqualified?
2. A going-concern paragraph?
3. Repeated findings of reportable conditions?
4. Material weaknesses in internal controls?

___ Yes
___ Yes
___ Yes
___ Yes

___ No
___ No
___ No
___ No

If “Yes” to any of the above, indicate the fiscal years of the occurrences and describe the
circumstances and corrective action(s) being taken: (Maximum Response Length: 2,000
characters)

(c) Have the Applicant’s, and its Controlling Entity’s financial statements shown positive net income
(or if a non-profit, positive change in net assets) for each of the last three years, or if in business
for less than three years, for the period of time it has operated?
____ Yes

____ No

If “No”, please explain the circumstances, indicate the fiscal year in which this occurred, and
describe the corrective action being taken:
(Maximum Response Length: 2,000 characters)

(d) Is the Applicant (and Controlling Entity) aware of any non-compliance issues cited since the
issuance of its most recent audited financial statements or Management’s Annual Report on
Internal Controls Over Financial Reporting?
____ Yes

____ No

If “Yes”, please explain the circumstances and describe the corrective action being taken:
(Maximum Response Length: 2,000 characters)

(e) If the Applicant identified a Controlling Entity in Question #3, please indicate if the Controlling
Entity will provide financial support to address any operating deficit (e.g. full support, partial
support) and under what circumstances. (Maximum Response Length: 1,000 characters)

34. Fee Structure
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43

a. Complete Table D2: Based on the projections in Exhibit A, provide an itemized list of the
individual fees that represent the Fee Structure the Applicant anticipates will typically
apply to the proposed NMTC investments and result in compensation to the Applicant (or
Controlling Entity), Affiliates, Subsidiary CDEs, or unaffiliated third-parties.


In Table D2, Applicants must disclose all fees for each proposed financial product
listed in Question #14(a), regardless of the expected source and/or recipient.

b. Description of Table D2: In the narrative below, for each Financial Product described in
Question 14, explain how the Applicant determined that Fee Structure and Average Fee
Percentage are appropriate for the investment strategy described in this Allocation
Application. (Maximum Response Length: 4,000 characters)

c.



Provide a brief description of any and all fees, payments, loans, or other
remuneration (type, usage), whether paid or directed to the CDE, a CDE Affiliate, or
other third parties, and describe the timing of such fees in relation to the QEI. For
example, indicate whether the fee will be reserved, charged when the Applicant
commits to an NMTC investment, charged prior to, during or after the compliance
period; retained from Investment Fund proceeds, paid from the QEI proceeds, paid
from QLICI proceeds, or retained from the tax credit equity at the end of the NMTC
compliance period.



Applicants that plan to charge exit fees must quantify the amount and describe the
circumstances that determine when such fees will be charged as well as the
frequency these events will occur.



Applicants that plan to retain all or a portion of the tax credit equity at the end of the
NMTC compliance period must quantify the amount as well as describe the
circumstances and frequency.

Complete Table D3 based on the projected activities reflected in Exhibit A and fees
described in Q. 34(a) and Table D2. Based on the projections in Table D3:


Describe the Applicant’s projected sources of income and expense(s) associated
with administering the Applicant’s NMTC line of business and how the Applicant
will be able to sustain this line of business, consistent with its overall business
strategy, including its timeline for making investments.



QLICI interest and dividend payments should be described as income. If all or a
portion of the QLICI interest or dividend payments will be passed through the
investment fund to investors or leverage lenders, then describe those payments as
an off-setting expense.



If the Applicant will use existing resources (e.g., accumulated cash balances), thirdparties as a source of operating income (e.g., grants or loans), or in-kind
contributions (e.g. use of personnel, back office systems), describe the Applicant’s
progress in securing firm commitments;

NMTC Allocation Application Template for Public Comment - April 2021
44



Explain how the Applicant would address any operating deficit. (e.g., income or
loan from Affiliates or alternate sources, reduce scope of activities, use reserves,
etc.).

(Maximum Response Length: 5,000 characters)

NOTE: The narrative response in Question #34(f) should clearly describe the assumptions and
calculations used to derive each income and expense line from Table D3 in a way that CDFI Fund
staff will be able to easily understand, quantify, and evaluate. The Applicant should indicate
whether it is using cash or accrual methods of accounting. Table D3 should be completed using the
Applicant’s fiscal year indicated in Question #2(h) (see the Application FAQ).
NOTE: If the Applicant has engaged (or intends to engage) any third-parties (e.g., consulting firms)
that will receive any NMTC related income from the Applicant, QEI proceeds, QALICBs, or
investors, the Applicant must disclose, describe and include this compensation as an offsetting
income and expense of the Applicant in Table D3. It must also be clearly described in the response
to Question #34(f) below.

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45

PART IV: CAPITALIZATION STRATEGY
Information in Part IV is not scored during the Phase I stage of the Application review. Information provided
in this section will be evaluated during the Phase II stage of the Application review. For more information
on the NMTC Allocation Application review process, please consult the NOAA.

A. Investor Strategy
NOTE: An Applicant that demonstrates a track record of raising capital from investors (including
market rate capital) consistent with the Allocation request and, if applicable, a high level of investor
Commitment will be evaluated favorably under this sub-section.
If an Applicant is seeking investments from investors that have not yet provided capital, the
Applicant may be evaluated favorably if it presents a strong strategy for raising capital from such
investors.

35. Complete Table E1 and describe the track record of the Applicant (or its Controlling Entity) raising
capital from third-party sources, particularly equity capital at market or near-market rates. Be sure to
distinguish between raising capital from profit-motivated investors; from government or philanthropic
sources of capital; or using tax credits as an incentive. Applicants may also discuss the experience of
key personnel, consultants, and board members in raising capital. Reference information provided in
Table C2 as appropriate.
(Maximum Response Length: 5,000 characters)

NOTE: While Table E1 must contain data only of the Applicant (or its Controlling Entity) and the
track record of the Applicant (or its Controlling Entity) must be discussed in Question #36, the
Applicant may refer in Question #36 to the qualifications and five-year capital-raising track record of
individuals (e.g., staff, Principals, consultants) listed in Table C1 for organizations other than the
Applicant (or its Controlling Entity).

36. Investment Partnerships
(a) Does the Applicant intend to secure investments from partnership entities that will leverage nonEquity Investments (e.g., debt, grant dollars) from outside of the partnership to increase the tax
credit yield for members of the partnership? (Please note: Applicants planning to use the leverage
model to raise QEIs for all or a portion of their allocation should select “Yes” below).
_____Yes

_____ No

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46

(b) If Yes, provide the percentage of equity versus non-equity investments for all such investor
partnerships based on the Applicant’s requested NMTC Allocation.
___________% Equity Investments
___________% Non-Equity Investments
37. Investment Strategy
(a) Has the Applicant or its Affiliates, either directly or through subsidiary CDE(s), received QEIs from
investors in amounts equal to or greater than the Allocation request in Question #1 between
January 1, 2015 and the release date for the NMTC Allocation Application (specified in the NMTC
Application FAQ document)?
_____Yes, complete Table E2 and Question #36(c).
_____ No, complete Question #36(b).
.

TIP: Applicants (or Affiliates) who have received QEIs from investors in amounts equal to or greater
than the Allocation request in Question #1 between January 1, 2015 and the release date for the
NMTC Allocation Application (specified in the NMTC FAQ document) are required to complete
Table E2. See the FAQ document (Capitalization Strategy Section) for additional details.
However, Applicants (or Affiliates) that have received QEIs in amounts less than the Allocation
request in Question #1 between January 1, 2015 and the release date for the NMTC Allocation
Application are required to complete Table E3 and should not complete Table E2. If the Applicant
provided investor letters as evidence of its ability to raise capital, then the Applicant should respond
to Question #36(c). If the Applicant did not provide investor letters, it should respond to Question
#36(d). See the FAQ document (Capitalization Strategy Section) for additional details.
TIP: All Applicants that respond “Yes” to Question #36(b) are required to submit, along with their
applications, documentation demonstrating proof of investor interest (e.g., Commitment letters;
Letters of Interest/Intent). Investor letters should identify whether the investor will make a direct
investment in the CDE or into a partnership.
Applicants that answer Yes to Question #35(a) and complete Table E3 are required to submit,
along with their applications, documentation demonstrating proof of the interest of the equity
investors and debt providers (e.g., letter indicating intent of equity or debt investor to provide capital
to the partnership entity that will provide the QEI to the Applicant). Be sure to follow the directions
in the Applicant Instructions section for information regarding the submission of these documents.
If the Applicant answered “Yes” to Question #35(a) and plans to source non-Equity Investments
from sources that are specific to particular QALICBs, the Applicant should discuss this strategy in
the response to Question #36(c) to the extent that it may invest in QALICBs that have not yet been
identified at the time of the Allocation Application.

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47

(b) If “No” to Question #36(a) above, has the Applicant provided investor Commitments or Letters of
Intent/Interest for investors listed in Table E3?
_____Yes, complete Table E3 and Question #36(c).
_____ No, complete Question #36(d).
(c) If the Applicant responded “Yes” to Question #36(a) or Question #36(b), discuss the extent to
which the Applicant may raise capital from equity and/or debt investors not listed in Table E2 or
E3.
 Applicants that intend to raise QEIs using the leverage structure must also describe potential
sources of leveraged debt related to their planned NMTC investments (described in
Question #17), including the percentage of leverage debt that is anticipated to be sourced
from the QALICB or Affiliates of the QALICB.
 If Table B1 includes non-NMTC direct loans/investments deployed by the Applicant or
Controlling Entity, describe the three largest sources of capital used for such
loans/investments and the types of businesses financed.
(Maximum Response Length: 5,000 characters)

(d) If the Applicant responded “No” to Question #36(a) and Question #36(b) above, discuss the
Applicant’s strategy for securing NMTC investor Commitments:


The Applicant’s strategy for identifying additional equity investors or non-equity providers
(i.e., leveraged debt), including the extent to which the Applicant will be utilizing community
alliances or strategic partners to raise investment capital and/or whether leverage debt will
be sourced from the QALICB or Affiliates of the QALICB.



The Applicant’s timeline for securing investments from equity investors and/or leveraged
debt if the Applicant answered yes to Question #35(a) and, any risks that may preclude the
Applicant from closing such investments, and how the Applicant is mitigating such risks.



If the Applicant is using a third-party investment banker to raise capital, describe whether a
contract is in place, the terms (actual or proposed) of the contract, and the progress to date
that the banker has made in securing Commitments from investors. Do NOT list these
investment bankers in Table E3.
(Maximum Response Length: 8,000 characters)

38. Please respond to the following questions:

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48

(a) Will one or more of the Applicant’s current or prospective investor(s) originate or otherwise identify
transactions in which the Applicant will invest?
____ Yes

_____ No

(b) Will the Applicant receive any QEIs from Affiliates?
_____ Yes _____ No

(c) If the answer to (a) or (b) is yes, provide narrative detailing:


The name of each such equity investor or non-equity provider;



The role of each equity investor or non-equity provider with respect to locating, underwriting,
and structuring each investment;



Whether each equity investor or non-equity provider offers similar products or services
already; and



If applicable, the extent to which the Applicant will offer products with more favorable rates or
terms than those currently offered by the equity investor or non-equity provider and/or will
target its activities to areas of greater economic distress than those currently targeted by the
equity investor or non-equity provider.(Maximum Response Length: 2,000 characters)

NOTE: If the Applicant has obtained or plans to obtain investments from organizations that also will
identify or originate transactions for the Applicant or organizations that are Affiliated with the
Applicant, it will be evaluated favorably if: a) the Applicant’s transactions are more targeted to areas
of greater economic distress than those areas that investors are already reaching with their
investments or loan originations; or b) the Applicant’s products and services are offered with more
favorable rates or terms than those offered by the investor.

39. Distribution of Benefits:

NOTE: The CDFI Fund expects Applicants to quantify this information and to be able to
demonstrate that there is appropriate sharing between the investor, CDE, and borrowers/investees.

(a) Quantify as best you can, for each anticipated investment type, how economic benefits of the QEI
will be apportioned amongst:
i.

the investors (equity and leverage debt sources), through economic returns (e.g. interest
income, investor IRR);

NMTC Allocation Application Template for Public Comment - April 2021
49

ii.
iii.
iv.

the Applicant (or its Subsidiaries/Affiliates), through economic returns (including fees).
the QALICB investees/borrowers, through lower costs of capital;
if applicable, the unaffiliated end-users through lower costs (e.g., lower tenant lease rates).
(Maximum Response Length: 5,000 characters)

(b) To the extent there may be any tax credit equity remaining at the end of the seven-year credit
period, be sure to address how the residual value will be apportioned amongst investors, QALICBs
(and/or QALICB Affiliate), the Applicant and/or its Affiliates. Address any terms or conditions the
QALICB must meet as a term of the distribution.
(Maximum Response Length: 3,000 characters)

(c) If the Applicant generates a profit from its overall NMTC activities, discuss how this profit will be
used (e.g., dollar amount or percentage of profit that will be distributed to investors or
shareholders, support additional NMTC or non-NMTC Low-Income Community investments,
support other activities of the Applicant or Affiliates, etc.). (Maximum Response Length: 2,000
characters)

(d) If at least one proposed investment will involve two or more unaffiliated CDEs, please describe the
total number of co-investments with other CDEs. Please describe the factors that lead to coinvesting with other CDEs and benefits to the QALICB and/or unaffiliated end-users.
(Maximum Response Length: 2000 characters)

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50

B. Sources and Uses of Capital
NOTE: In this sub-section, the CDFI Fund seeks to understand both how efficiently the Applicant
will use QEI proceeds and how well it is leveraging other sources of financing in conjunction with
the activities undertaken with its QEI proceeds. An Applicant that intends to invest/re-invest more
than 85 percent of its QEI proceeds in QLICIs will be evaluated more favorably, provided that the
Applicant can reasonably demonstrate that it has other mechanisms in place to support its costs of
operations.

40. Will more than 85 percent of the QEI proceeds be invested/re-invested in QLICIs?
____ Yes ____ No

If yes, what percentage: ______%.

NOTE: An Applicant that indicates in Question #41 “yes” and provides a percentage greater than
85 percent will be required to meet the percentage identified above, and such requirement will be a
term of its Allocation Agreement.

41. Minimum Request Amounts
Is there an absolute minimum amount below which the Applicant would be unwilling to accept an
NMTC Allocation?
_____ Yes _____ No
If Yes, provide the amount $_______. Describe how this amount was determined. Be sure to address
why the Applicant could not administer a smaller award:
(Maximum Response Length: 1,000 characters)

NOTE: At the conclusion of the CDFI Fund’s review process, if the Applicant is recommended to
receive less than the minimum amount of allocation authority identified in Question #41, the CDFI
Fund will not provide an NMTC Allocation to the Applicant. An Applicant with a high minimum
allocation request will need to demonstrate that it can raise and deploy the NMTC Allocation
requested in a timely manner; that it will likely achieve significant community impacts or production
innovations; and that it could not successfully implement its business strategy without this minimum
allocation amount.

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51

PART V: INFORMATION REGARDING PREVIOUS
AWARDS
Information in Part V is not scored during the Phase I stage of the Application review. Information provided
in this section will be evaluated during the Phase II stage of the Application review. For more information
on the NMTC Allocation Application review process, please consult the NOAA.
42. CDFI Fund Award Status:
Has the Applicant and/or any of its Affiliates previously received a financial award (not including an
NMTC Allocation) from the CDFI Fund?
If Yes, please ensure that the award(s) is listed in the table. If an Affiliate of the Applicant has received a
financial award and it is not listed in the table, please return to the Applicant’s Organization Profile in AMIS
and ensure that the Affiliate is listed in the Affiliate section. Please see the NMTC Allocation Application AMIS Navigation Guide (Section 6.0) on how to associate Affiliates with your AMIS Organization Profile.
You must select Yes to the question below for this sub-section to be marked as complete.
Name of Award Recipient:
Award control number:
Total award amount:
Is the Award information complete?
____ Yes

____ No

43. NMTC Allocation Status:
Has the Applicant and/or any of its Affiliates received an NMTC Allocation from the CDFI Fund in a
prior allocation round?
If Yes, please ensure that the allocation(s) is listed in the table. If an Affiliate of the Applicant has
received an NMTC Allocation and it is not listed in the table, please return to the Applicant’s
Organization Profile in AMIS and ensure that the Affiliate is listed in the Affiliate section. Please see
the NMTC Allocation Application - AMIS Navigation Guide (Section 6.0) on how to associate Affiliates
with your AMIS Organization Profile. You must select Yes to the question below for this sub-section to
be marked as complete.
Is the Award information complete?
____ Yes

____ No

NMTC Allocation Application Template for Public Comment - April 2021
52

NOTE: Receipt of a prior award or allocation through any of the CDFI Fund's programs will not
affect the likelihood of an Applicant receiving an NMTC Allocation in this round. The CDFI Fund will
examine the compliance status of Applicants (or their Affiliates) that have previously received CDFI
Fund awards or allocations.
NOTE: The CDFI Fund will review transaction-level data submitted by Applicants that are prior
year Allocatees through the Community Investment Impact System (CIIS) and may seek additional
information from Applicants to determine whether activities and the QLICIs made were consistent
with the transactions and activities proposed in the relevant prior-year Allocation Application(s).

Name of Allocatee:
Award control number:
Total allocation amount:

44. If the Applicant answered Yes to Question #43, briefly explain the current status of its previous
allocation award(s). Be sure to address:
(a) If the Applicant has made QLICIs, describe the types of transactions that have been financed
to date. The Applicant must discuss the projects that received the largest QLICIs in each of
the Applicant’s three most recent Allocations, as of the Allocation Application release date. (If
a single project received the QLICIs from more than one of the past three awards, see the
FAQ Document (Information Regarding Previous Awards Section) for more details). If the
Applicant has received less than three Allocations, it should discuss the three projects that
received the largest investments in the last five years. See Application FAQ for additional
guidance.
For each project identified, describe how NMTC proceeds were used, including:


How the CDE ensured that the NMTCs allocated did not exceed the amount necessary to
assure project feasibility.



Efforts to secure alternative sources of capital in the marketplace in order to complete the
project.



Any community outcomes or benefits that were generated as a result of the transaction.



The source(s) and amount(s) of leveraged debt from all sources (including the percentage of
leverage sources derived from the QALICB, Affiliates of the QALICB and/or Project Sponsor),
if any.



Any investment-related fees and third-party expenses paid by the QALICB or the QALICB’s
Affiliates that were paid either to the Applicant, its Affiliates, QEI investors or directly to any
other parties in connection with consideration or receipt of the QLICI investment(s) (e.g., CDE
upfront and on-going fees, fees and expenses associated with leverage debt, accounting,
legal, on-going asset management, loan servicing, back-end fees, etc.).
(Maximum Response Length: 10,000 characters)

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53

(b) If the Applicant co-invested in a project(s) with two or more unaffiliated CDEs, explain what actions
the CDE took to control expenses paid by QALICBs and investors (e.g., Co-investing CDEs used
one set of documents, shared professional expenses, etc.).
(Maximum Response Length: 3,000 characters)

(c) Discuss whether the activities undertaken with the NMTC dollars were consistent (with respect to
product offerings; QALICB type; fees and markets served; etc.) with the business strategy
presented in the relevant Allocation Application. If the activities were not consistent with the
relevant Allocation Application, describe the inconsistencies.
(Maximum Response Length: 3,000 characters)

(d) To the extent the Applicant’s past transactions have been structured to allow QALICBs to acquire
a portion of QLICIs through a put/call option at the end of the seven-year credit period, please
quantify the value of the investment acquired by the QALICBs at the end of the seven-year credit
period both as a dollar amount and as a percentage of total QLICIs.
(Maximum Response Length: 2,000 characters)

(e) Discuss whether the activities undertaken with the NMTC dollars were consistent with the Notable
Relationships presented in the relevant Allocation Application. If the activities were not consistent
with the relevant Allocation Application, describe the inconsistencies. (Maximum Response
Length: 2,000 characters)

NOTE: Applicants and/or any Affiliates that have shared Control of a CDE (or Subsidiary of a CDE)
that is a prior round Allocatee should answer “Yes” to Question #45 and provide requested
responses.
NOTE: Applicants providing responses to Question #45 need only make one entry per Allocatee,
per award for which the Applicant has provided QEIs regardless of the number of individual QEIs
made to that Allocatee under a single award. For example, if an Applicant has made 10 QEIs in
Allocatee X under its second round allocation, then the Applicant would provide the aggregate
amount of those 10 QEIs in its response to Question #45.

45. Has the Applicant and/or any of its Affiliates assumed Control (not resulting from unwinding of a
transaction) of one or more CDEs (or Subsidiary CDEs) that received an NMTC Allocation in a prior
round?
____ Yes ____ No

NMTC Allocation Application Template for Public Comment - April 2021
54

If yes, list the allocation(s) and total QEIs invested per allocation in the table. Only include those CDEs (or
Subsidiary CDEs) where the Allocatee and/or any of its Affiliates assumed Control not resulting from the
unwinding of a transaction. The Applicant may use additional space as necessary.
Name of Allocatee:
Award control number:
Total QEI amount invested:
Name of Allocatee:
Award control number:
Total QEI amount invested:

NMTC Allocation Application Template for Public Comment - April 2021
55

EXHIBIT A: PROJECTED ACTIVITIES
Instructions for Exhibit A: All Applicants must complete the tables in Exhibit A based on the QLICI activities checked in Question #13 (b).
Tables A1-A4 should be consistent with the information provided in Question #13(b). All Applicant entries into Table A5 must align with
selections made in Question #13 (b) and the narrative provided in Question #17.

NOTE for Exhibit A:
1) If the Applicant intends to transfer all or part of its NMTC Allocation to its Subsidiaries, combine the activities of the Applicant and its
Subsidiaries. Only include those activities to be carried out by the Applicant and its Subsidiaries relating to equity raised with NMTCs.
2) Only include amounts the Applicant (or its Subsidiaries) will itself originate (e.g., do not include participation amounts that will be
originated by third-parties). The Applicant may separately discuss amounts it will leverage or facilitate in the narrative to Question #17,
but should clearly distinguish these amounts. The Applicant can enter the amount of non-NMTC financing included in the total project
cost in row h of Table A5.
3) The data included in the Tables A1 – A4, in the aggregate, should not exceed the Applicant’s total allocation request unless the Applicant
intends to invest interest, dividends, or other profits received from QEI proceeds into additional QLICIs. If the Applicant is pursuing such a
strategy of reinvestment, it should be further described in the narrative to Question #17, and listed separately in lines 5-8 of Tables A1
and A2; lines 5-6 of Table A3; and line 4 of Table A4. Do not consolidate reinvestment data into lines 1-4 in A1-A3 and lines 1-3 in
A4, where the Applicant should only discuss original QLICIs.
4) Only include investment activities explained in Question #17 in Table A5. Applicants must enter zero or greater for rows (f), (g), (h), and
(i). Applicants should check the options that most closely align with the intended financing for rows (n), (o) and (p). The CDFI Fund does
not have a preference for one selection over another selection.
5) Applicants intending to use their NMTC Allocation for a Small Dollar and/or Revolving Loan/Equity fund (row m) are required to report the
transactions in one aggregate entry in Table A5.

CDFI FUND | NMTC Program Allocation Application

56

TABLE A1: PROJECTED QLICI LOANS/INVESTMENTS TO QALICBS (ESTIMATED)
Calendar Year(s)
1

Total # transactions to be financed

2

Total $ amount of financing

2022

2023

2024

2025

2026

Total

$

$

$

$

$

$

3

$ Amount of financing (debt)

$

$

$

$

$

$

4

$ Amount of financing (equity)

$

$

$

$

$

$

5

Total # of reinvestment transactions

6

Total $ amount of reinvested financing

$

$

$

$

$

$

7

$ Amount of reinvested financing (debt)

$

$

$

$

$

$

8

$ Amount of reinvested financing (equity)

$

$

$

$

$

$

CDFI FUND | NMTC Program Allocation Application

57

TABLE A2: PROJECTED QLICI LOANS/INVESTMENTS IN OTHER CDES (ESTIMATED)
Calendar Year(s)
1

Total # transactions to be financed

2

Total $ amount of financing

2022

2023

2024

2025

2026

Total

$

$

$

$

$

$

3

$ Amount of financing (debt)

$

$

$

$

$

$

4

$ Amount of financing (equity)

$

$

$

$

$

$

5

Total # of reinvestment transactions

6

Total $ amount of reinvested financing

$

$

$

$

$

$

7

$ Amount of reinvested financing (debt)

$

$

$

$

$

$

8

$ Amount of reinvested financing (equity)

$

$

$

$

$

$

TABLE A3: PROJECTED QLICI LOAN PURCHASES FROM OTHER CDES (ESTIMATED)
Calendar Year(s)
1

Total # selling CDEs

2

Total # of loan portfolios purchased

3

Total # of loans purchased

4

Total $ amount of loan purchases

5

Total # of loans purchased via reinvested financing

6

Total $ amount of loans purchased via reinvested
financing

CDFI FUND | NMTC Program Allocation Application

2022

2023

2024

2025

2026

Total

$

$

$

$

$

$

$

$

$

$

$

$

58

TABLE A4: PROJECTED FINANCIAL COUNCILING AND OTHER SERVICES TO BUSINESSES AND ENTREPRENEURS IN LOWINCOME COMMUNITIES (ESTIMATED)
Calendar Year(s)

2022

2023

2024

2025

2026

Total

1

Total # of businesses/entrepreneurs served through
counseling or other services

2

Total estimated hours spent counseling or providing
other services per year

3

Total $ amount to be spent on counseling or providing
other services

$

$

$

$

$

$

4

Total $ amount of reinvestment to be spent on
counseling or providing other services

$

$

$

$

$

$

CDFI FUND | NMTC Program Allocation Application

59

Instructions for Table A5: Applicants must complete Table A5 in its entirety for each sample transaction it plans to make investments in, or
loans to, QALICBs or other CDEs with its requested NMTC Allocation. The sum of the Total Applicant QEIs (row g) for all transactions listed
in Table A5 must correspond to the total amount of NMTC Allocation requested in Question #1 (Except if, Purchases of loans from other
CDEs or FCOS is selected in Question #13). When completing Table A5:
a)
b)
c)
d)
e)
f)
g)
h)
i)
j)
k)
l)
m)
n)
o)

Applicants should provide a description of the transaction which links to the narrative transaction description in Question #17.
Applicants should provide the city and state where the QALICB will be located.
Provide the census tract if the exact location of the QALICB has been determined.
Applicants should identify if the transaction is located in a Non-Metropolitan County census tract.
Applicants must select the timeframe which the QLICI is expected to close.
Applicants must enter the Total Projects Costs, which include NMTC and non-NMTC related financing.
Applicants must enter the amount of QEI it intends to invest into the QALICB with its requested allocation.
Applicants must enter the amount of QLICIs it intends to invest into the QALICB with its requested allocation
Applicants must enter the total amount of non-NMTC financing needed to support the QALICB.
Applicants must enter the total amount of investments it expects CDEs Unrelated to the Applicant to provide.
Applicant should provide the total number of CDE(s) Unrelated to the Applicant expected to co-invest with.
Applicant should indicate whether the transaction is an Investment in, or loan to, a QALICB, or an Investment in, or loan to, a CDE,
Applicants must identify if the transaction will be used for Small Dollar and/or Revolving Loan Fund.
Applicants must select all business types that apply. If “other” is selected, please provide brief explanation in (a).
Applicants must select all planned uses of financing by the QALICB or CDE. If “other” is selected, please provide brief explanation in
(a).
p) Applicants must select all target community outcomes that apply for the transaction and align with those community outcomes
selected in Question #26.
Rows n through p, Applicants must select each option that applies to the transaction.

TABLE A5: PROPOSED TRANSACTIONS
Transaction #1
(a) Business Name and Description

(500 characters) Note: For guidance on completing this narrative, please see the NMTC Application FAQ Document.

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60

TABLE A5: PROPOSED TRANSACTIONS
(b) Address

City [Text]
State [Picklist]

(c) Census Tract (required only if
discrete project pipeline is selected;
Census Tract number not required
for Multi-tract projects)

(11 digit number)
(Single-Tract or Multi-Tract)

(d) Located in a Non-Metropolitan
County?

[Yes/No]

(e) Projected QLICI Closing Date

[Drop Down: 2022, 2023, 2024, 2025, 2026, 2027]

(f) Total Project Costs

$

(g) Total Applicant QEI

$

(h) Total Applicant QLICIs

$

(i) Total Non-QLICI Sources

$

(j) Total QEIs from unaffiliated CDEs

$

(k) Total number of unaffiliated
CDE(s) anticipated
(l) Activity Type

[Drop Down: Investment in, or loan to, QALICB, Investments in, or loans to, other CDEs]

(m) Small Dollar and/or Revolving
Loan Fund

[Yes/No]

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61

TABLE A5: PROPOSED TRANSACTIONS
[Check all that apply]

(n) Business Type

(o) What are the planned uses of
financing by the QALICB or CDE?

(p) Targeted Community Outcomes

-Cultural
-Education
-Healthcare
-Multi-Service Community Organization
-For-sale Housing

[Check all that apply]
-Acquisition
-Construction
-Rehabilitation
-Working Capital
[Check all the apply]
-Job Related
-Commercial Goods or Services to Low-Income
Communities

CDFI FUND | NMTC Program Allocation Application

-Hospitality/Tourism
-Manufacturing/Industrial
-Mixed-use real estate
-Office space
-Retail
-Utilities/Infrastructure
-Other _________________

-Leasehold Improvements/Buildouts
-Equipment Purchase and Installation
-Inventory Purchase
-Other _____________________
-Community Goods or Services to Low-Income Communities
-Financing Minority Businesses
- Financing Native Businesses
- Housing Units

62

EXHIBIT B: TRACK RECORD OF ACTIVITIES
Instructions for Exhibit B: Applicants must complete the Tables B1-B3 in Exhibit B for the Applicant’s (or Controlling Entity’s) track record of
loans and/or equity investments to Real Estate and Operating Businesses (excluding Restricted NMTC Business Activities), loans or Equity
investments to CDEs, or purchasing loans from CDEs. Applicants must complete Table B4 for any loans/investments that do not directly
correspond to the activities in Question #13 (e.g. Restricted NMTC Business Activities, loans and/or investments in NMTC investment funds
or non-CDE financial institutions, personal or consumer loans, and residential mortgages). If the Applicant’s or the Controlling Entity’s track
record includes the provision of grants to entities, including real estate, Operating Businesses, and/or CDEs, do not include these activities in
Tables B1-B4 or discuss in the narratives for Questions #19 or #20.
When completing a given table, for each annual column, Applicants should report on the totality of historical loans and equity investments for
the period 2016-2021 YTD. Please be aware of the allowable financing activities for each table in Exhibit B. All types of business lending,
except for Restricted NMTC Business Activities, should be listed in Tables B1-B3, regardless of the size of the investment or geographic
location of the investment. Similarly, the Applicant’s track record of Financial Counseling and Other Services (FCOS) provided to businesses
should be described in the narrative response to Question 19. Per the 2021 Allocation Application glossary, FCOS is advice provided by a
CDE relating to the organization or operation of a trade or business. See 26 CFR 1.45D-1(d) (7) for more guidance. In the columns “Total to
DBCs (2016-2021),” Applicants should report the amount of their overall loans or Equity Investment that are directed to Disadvantaged
Businesses and/or Disadvantaged Communities.
An Applicant must provide information for the years referenced in the Tables or for as many years as the Applicant (or Controlling Entity) has
been in operation, if it has been in operation for fewer than five years. An Applicant, at its discretion, may choose to rely upon the track record
of its Controlling Entity. In order to list the track record of the Controlling Entity in Exhibit B, the Applicant must designate a
Controlling Entity in Question #3. If the Applicant chooses to complete the tables in Exhibit B with information from the Controlling
Entity, it must also use the Controlling Entity for populating Table D1 and Table E1.

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63

NOTE for Exhibit B, Tables 1-4:
1) Where indicated in Table B1, enter the dollar amount of debt financing provided by the Applicant (or Controlling Entity) in row 2a. In row
2b, enter the dollar amount of equity financing provided by the Applicant (or Controlling Entity). Enter all financing from other sources
(excluding grant dollars) in row 3. Row 2 will automatically calculate based on your entries in rows 2a and 2b. The Applicant may discuss
in Question #20 any role the Applicant (or Controlling Entity) played in leveraging or facilitating financing for which it did not provide direct
financing.
2) Grants provided by the Applicant (or Controlling Entity) must be excluded from Tables B1 – B4. Equity investments into non-profit
organizations are considered grants (per the definition of Equity Investment in the application glossary).
3) Do not include tax credit equity raised as QEIs from investors in Table B1 or Table B2. Row 2(b) in Table B1 should only include equity
financing provided to Real Estate and Operating Businesses (excluding NMTC Restricted Business Activities). Row 4 in Table B2 should
only include equity financing provided to other CDEs.
4) For the purpose of completing Tables B1-B4, the Applicant must choose to either use its own track record or that of its Controlling Entity.
If the Applicant chooses to use its own track record it must include, in the aggregate, the financing track record of all Subsidiaries of the
Applicant and may not include any of the Controlling Entity’s activities. However, if the information in Tables B1-B4 reflects the activities
of the Controlling Entity, the information must include, in the aggregate, the financing track record of all Subsidiaries of the Controlling
Entity, including the Applicant if the Applicant is a Subsidiary of the Controlling Entity. The Applicant must discuss track records of both
the Applicant and Controlling Entity in the narrative to Questions #20 or #21 (as applicable). The narrative should clearly distinguish
between the track records of each entity.
5) The Applicant must distinguish between direct financing provided by the Applicant or its Controlling Entity, as entered in Table B1, row 2
and Table B4, row 1 and indirect financing (financing provided by third-party sources), entered in Table B1, row 3 and Table B4, row 2.
Applicants should not enter the same data in more than one row.
6) Tables B1-B4 should be mutually exclusive. Applicants should not enter the same data in more than one Table in Exhibit B.
7) In the Column titled “2021 Year to Date (YTD),” the Applicant can only enter information on activities closed by the Applicant or
Controlling Entity on or before the release date of the Allocation Application (specified in the NMTC FAQ Document). The Applicant may
not enter information on activities planned or projected to close after the Allocation Application release date, including issued QEIs that
have not resulted in QLICIs closed by the release date of the Allocation Application. For additional details on completing Exhibit B, please
refer to the NMTC Application FAQ document.

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64

The Tables in Exhibit B reflect the activities of (check one):

____Applicant

_____Controlling Entity

TABLE B1: TRACK RECORD OF LOANS/EQUITY INVESTMENTS TO REAL ESTATE AND OPERATING BUSINESSES
(EXCLUDING RESTRICTED NMTC BUSINESS ACTIVITIES)

Calendar Year(s)
1
2

3

2
3

2016

2017

2018

2019

2020

2021
YTD

Totals
(20162021)

Totals to
DBCs2 (20162021)

Totals to
Non-Metro
Counties3
(20162021)

Total # businesses financed
Total $ amount of direct
financing provided by the
Applicant to Real Estate
Activities and Operating
Businesses

$

$

$

$

$

$

$

$

$

(a) $ Amount of debt financing
provided by Applicant

$

$

$

$

$

$

$

$

$

(b) $ Amount of equity
financing provided by
Applicant

$

$

$

$

$

$

$

$

$

$ Amount of financing
provided by other sources
(including QALICB owner
equity) to Real Estate
Activities and Operating
Businesses

$

$

$

$

$

$

$

$

$

Disadvantaged Businesses and Communities, see Glossary for a full definition.
Non-Metropolitan Counties, see Glossary for a full definition.

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65

TABLE B2: TRACK RECORD OF LOANS/EQUITY INVESTMENTS TO OTHER CDES

Calendar Year(s)

2016

2017

2018

2019

Totals
(20162021)

2021
YTD

2020

Totals to
DBCs
(2016-2021)

Totals to
Non-Metro
Counties
(20162021)

1

Total # CDEs
financed

2

Total $ amount
of financing

$

$

$

$

$

$

$

$

$

3

$ Amount of
financing (debt)

$

$

$

$

$

$

$

$

$

4

$ Amount of
financing
(equity)

$

$

$

$

$

$

$

$

$

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66

TABLE B3: TRACK RECORD OF LOAN PURCHASES FROM OTHER CDES

Calendar Year(s)

1
2

2016

2017

2018

2019

2021
YTD

2020

Totals to
DBCs
(20162021)

Totals
(20162021)

Totals to
Non-Metro
Counties
(20162021)

Total # of loans
purchased
Total $ amount
of loans
purchased

$

$

$

CDFI FUND | NMTC Program Allocation Application

$

$

$

$

$

67

$

TABLE B4: TRACK RECORD OF LOANS/EQUITY INVESTMENTS THAT DO NOT DIRECTLY CORRESPOND
TO THE SELECTIONS IN QUESTION #13 (E.G. RESTRICTED NMTC ACTIVITIES, LOANS OR INVESTMENTS
IN NMTC INVESTMENT FUNDS, NON-CDE FINANCIAL INSTITUTIONS OR INVESTMENT FUNDS,
PERSONAL OR CONSUMER LOANS, AND RESIDENTIAL MORTGAGES)

2

Totals to
DBCs
(2016-2021)

(2016-2021)

2016

2017

2018

2019

2020

2021
YTD

Total $ amount of direct
financing provided by the
Applicant

$

$

$

$

$

$

$

$

$

$ Amount of financing
provided by other sources
(including QALICB owner
equity)

$

$

$

$

$

$

$

$

$

Calendar Year(s)
1.

Totals
(20162021)

Totals to
Non-Metro
Counties

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68

EXHIBIT C: STAFF AND BOARD QUALIFICATIONS
Instructions for Tables C1 and C2: The Applicant should complete Table C1 and Table C2 in their entirety. Please note that Table C2
allows the Applicant to identify key personnel that have experience in multiple management areas. Applicants should be sure to discuss key
personnel’s experience specific to Low-Income Communities, where relevant. Applicants are to list no more than 15 individuals in Table C2.
The CDFI Fund will only evaluate the initial 15 individuals listed in Table C2. For each narrative response in Questions #29-#31 and their
corresponding sub-sections, reference and discuss the combined management experience of all individuals listed in Table C2 as it relates to
the Applicant’s management capacity in that given area. An Applicant must also identify any consultant(s) contracted to write either portions
or the entirety of their Allocation Application.

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69

TABLE C1: LOW-INCOME COMMUNITY ACCOUNTABILITY
Board
Member
Name

Firm

Title at
Firm

Advisory or
Governing
Board
Member?

Yrs. on
Board

Description of the Individual’s
Qualifications as an LIC
representative, including related LIC
community affiliations or experiences.

Indicate how the individual is
Representative of Low-Income
Communities?

__ Advisory

__ Resident

__ Governing

__ Small business owner

__ Both

__ Employee or board member of a nonAffiliated community-based or charitable
organization

Description should focus on the
representative’s years and depth of experience
serving, working, living in, or operating a
business in LICs.
(Maximum Response Length: 2000
characters)

__ Religious leader whose congregation is
based in a Low-Income Community
__ Employee of a governmental agency or
department that principally serves LowIncome Communities
__ An elected official (or works for one)
whose constituency is comprised
principally of residents of Low-Income
Communities
__ Other (specify):________________

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70

TABLE C2: MANAGEMENT CAPACITY

Name

Firm

Title at
Firm

Type of activity with Applicant
in each Capacity
(Check all that apply)
__ NMTC Application
Preparation/Review

Yrs. with (or
years
providing
services to)
the Applicant

Position with Applicant
(Check all that apply)

__ Governing board (GB) chair

__ Capital-raising

__ GB member on loan/investment
committee

__ Capital deployment

__ Other GB member

__ Sourcing or loan underwriting

__ Advisory board member

__ Asset management

__ Executive Director or equivalent

__ Loan servicing

__ Chief Financial Officer or equivalent

__ NMTC Program compliance

__ Dir. of Lending/investing or equivalent

__ Provision of services to QALICBs
/ residents (including FCOS)

__ Other key management

__ Community Outreach

__ Compliance Officer

__ Legal services

__ Other finance staff

__ Other (specify): _____________

__ Contracted consultant

__ Loan/investment Officer or equivalent

__ Other (specify):______________

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71

Description of
Individuals
Qualifications
Description of
Individual’s
qualifications should
include years of
relevant experience
and how this
experience is similar to
the individual’s role in
managing the
Applicant’s NMTC
program. (Maximum
Response Length:
2000 characters)

EXHIBIT D: ASSET MANAGEMENT AND INCOME & OPERATING
EXPENSES
Instructions for Table D1: Table D1 should closely reflect the direct financing indicated in Exhibit B. For each of the fiscal years, indicate the
total number and dollar amount of loans and Equity Investments that are referenced in Question 19, Question 20 and Exhibit B as part of your
track record and is outstanding to both real estate and Operating Businesses. For each fiscal year end, report in rows 4 and 9 the percentage
of loans and mandatory dividend payments, on a dollar basis, that were 90 days past due (e.g., the combined dollar amount of principal,
mandatory dividend, and interest payments 90 days or more past due / the total dollar amount of loans and Equity Investments outstanding at
fiscal year-end). In rows 5 and 10, enter the total dollar amount of capital from loans and Equity Investments written off during the fiscal year
(e.g., total dollar value of loans and/or Equity Investments written off less capital recovered).
If the Applicant (or Controlling Entity) has not made loans to either real estate or Operating Businesses, check the corresponding “N/A” box. If
the Applicant (or Controlling Entity) has no delinquencies at the end of a particular fiscal year, indicate “0” in lines 4 and 9, as appropriate. If
the Applicant (or Controlling Entity) has had no write offs of loans and/or equity during a particular fiscal year, indicate “0” in lines 5 and 10, as
appropriate.
Even if the Applicant has experienced zero delinquencies and write-offs in the past three years, it still needs to complete Table D1. In this
case, the Applicant should simply list the number and dollar amount of loans & equity investments outstanding at each fiscal year end and
enter “0” for the delinquency rates and write-offs. Applicants should not select “N/A” for Table D1 in this scenario.
If the Applicant chooses to complete any table in Exhibit A with information from the Controlling Entity, it must do so for all Tables
where Controlling Entity is an option, including Table D1. If the Applicant completes Table D1 for the Applicant, the information must
include, in the aggregate, the financing track record of all Subsidiaries of the Applicant and may not include any of the Controlling Entity’s
activities. However, if the Applicant completes Table D1 for the Controlling Entity, the information must include, in the aggregate, the
financing track record of all Subsidiaries of the Controlling Entity, including the Applicant if the Applicant is a Subsidiary of the Controlling
Entity.

The information in Table D1 reflects the activities of (check one): ____Applicant _____Controlling Entity
TABLE D1: INVESTMENT PORTFOLIO
Year 1
Fiscal Year(s)
1.
2.

Operating Businesses Loans & Equity Investments Delinquent or written-off  N/A
# of loans & Equity Investments outstanding

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72

Year 2

Year 3

TABLE D1: INVESTMENT PORTFOLIO
Year 1

Year 2

Year 3

Fiscal Year(s)
3.
4.
5.
6.
7.
8.
9.
10.

Total $ Amount of loans & Equity Investments outstanding
Delinquency rate associated with operating businesses
Total $ amount of write-offs of loans & Equity Investments to operating
businesses
Real Estate Loans & Equity Investments Delinquent or written-off  N/A
# of loans & Equity Investments outstanding
Total $ amount of loans & Equity Investments outstanding
Delinquency rate associated with real estate
Total $ amount of write-offs of loans & Equity Investments to real estate

CDFI FUND | NMTC Program Allocation Application

$
____%

$
____%

$
____%

$

$

$

$
____%
$

$
____%
$

$
____%
$

73

Instructions for Table D2: Based on the proposed transactions listed in Question #17 and Table A5, provide an itemized list of the individual fees that
represent the Fee Structure the Applicant anticipates will typically apply to investments closed with the requested NMTC Allocation and result in compensation
to the Applicant (or Controlling Entity), an Affiliate or an unaffiliated third-party. Applicants should report the Fee Structure for every financial product listed in
Question #14(a) that the Applicant intends to offer with capital raised from an NMTC Allocation. Applicants must disclose any and all fees, regardless of the
expected source and recipient, when in the NMTC investment lifecycle the fee is expected to be charged, and where in relation to the QEI it is expected to be
charged. Applicants must not include transaction costs such as legal, financial modeling/projections, audit, tax preparation, and accounting expenses that are
not part of the Applicant’s fee structure. Applicants should assume that they will receive the full amount of the requested NMTC Allocation and fund each of the
proposed transactions listed in Question #17 and Table A5.
1. Select 'Type' based on the time in the NMTC investment lifecycle the fee is expected to be charged:
a. Select ‘Upfront Fee’ for any fee that is expected to be charged before or at the time the QLICI is closed. This category includes but is not limited
to, fees such as origination, placement, sub-allocation or syndication fees. Applicants should note this includes any fee that will be charged before
the QEI is made. An ‘Upfront Fee’ is a one-time charge and not recurring.
b. Select ‘Ongoing Fee’ for any fee that is expected to be charged after the QLICI is closed and during the seven year compliance period. This
category includes but is not limited to, fees such as asset management fees, interest income that will be received, etc. An ‘Ongoing Fee’ is a not
a one-time charge and is recurring--which means that it is expected to be charged more than once in a row.
c. Select ‘Backend Fee’ for any fee that is expected to be charged at the end of or after the seven year compliance period. This category includes
but is not limited to, fees such as backend, exit, or success fees. A ‘Backend Fee’ is a one-time charge and not recurring.
2. Select the ‘Source (Payer)’ to indicate the entity responsible for paying the fee. The options include:
a. Investor or Investor Affiliate – Compensation and profits charged to investors.
b. QALICB or QALICB Affiliate fees – Compensation and profits charged to borrowers through fees.
c. QALICB or QALICB Affiliate interest – Compensation and profits charged to borrowers through interest, Ordinary interest or dividend payments
passed through to investors or leverage lenders should not be included.
d. Other – Compensation and profits charged to any other party to the transaction.
3. Select the ‘Recipient (Payee)’ to indicate the entity that will receive the fee. The options include:
a. Applicant or Applicant Affiliate – Compensation and profits received by the Applicant CDE and/or Affiliates including the Controlling Entity and
Subsidiary CDEs.
b. Investor or Investor Affiliate – Compensation and profits received by the Investor or Investor Affiliate.

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74

c.

Unaffiliated Third-Party – Compensation and profits received by entities Unrelated to the Applicant. Applicants should not select this option to report
transaction costs such as legal financial modeling/projections, audit, tax preparation, and accounting expenses associated with closing an NMTC
transaction.

4. Complete the ‘Amount in Percent’ field:
a. Applicants should provide the best estimate of the ‘Amount in Percent’ of the requested NMTC Allocation, on average, that is expected to be
charged for all of the proposed transactions listed in Question #17 and Table A5. Percentages must be entered with two decimal places (i.e. 1.00).
b. For an Ongoing Fee, Applicants should report the total, in the aggregate, that will be charged over the seven year compliance period.
5. Applicants are required to enter a brief description of the fee in the ‘Description’ field. Additionally, Applicants who selected ‘Other’ for the ‘Type’, ‘Source
(Payer)’, and/or ‘Recipient (Payee)’ must describe their selection(s) in the ‘Description’ field.
6. The 'Average Fee Percentage' is calculated automatically and is the total of the 'Amount in Percent' fields entered by the Applicant for each fee in the table.

TABLE D2 – FEE STRUCTURE
Financial
Product 1

Type

Source (Payer)

Recipient (Payee)

Amount in
Percent

Description of the fee (Required).

(% of Allocation)
Upfront Fee,
Ongoing Fee,
Backend Fee,
Other.

Investor or Investor
Affiliate,
QALICB or QALICB
Affiliate fee, QALICB or
QALICB Affiliate interest,
Other.

Average Fee Percentage

CDFI FUND | NMTC Program Allocation Application

Applicant or Applicant
Affiliate,
Unaffiliated Third-Party,
Investor or
Investor Affiliate.

0.00%

Additional information to explain the
fee. If ‘Other’ is selected, the Applicant
must provide an explanation using this
space. (Maximum Response Length: 50
characters)

0.00%

75

TABLE D2 – FEE STRUCTURE
Financial
Product 2

Type

Source (Payer)

Recipient (Payee)

Amount in
Percent

Description of the fee (Required).

(% of Allocation)
Upfront Fee,
Ongoing Fee,
Backend Fee,
Other.

Investor or Investor
Affiliate,
QALICB or QALICB
Affiliate fee, QALICB or
QALICB Affiliate interest,
Other.

Applicant or Applicant
Affiliate,
Unaffiliated Third-Party,
Investor or
Investor Affiliate.

Average Fee Percentage

0.00%

Additional information to explain the
fee. If ‘Other’ is selected, the Applicant
must provide an explanation using this
space. (Maximum Response Length: 50
characters)

0.00%

TABLE D2 – FEE STRUCTURE
Financial
Product 3

Type

Source (Payer)

Recipient (Payee)

Amount in
Percent

Description of the fee (Required).

(% of Allocation)
Upfront Fee,
Ongoing Fee,
Backend Fee,
Other.

Investor or Investor
Affiliate,
QALICB or QALICB
Affiliate fee, QALICB or
QALICB Affiliate interest,
Other.

Average Fee Percentage

CDFI FUND | NMTC Program Allocation Application

Applicant or Applicant
Affiliate,
Unaffiliated Third-Party,
Investor or
Investor Affiliate.

0.00%

Additional information to explain the
fee. If ‘Other’ is selected, the Applicant
must provide an explanation using this
space. (Maximum Response Length: 50
characters)

0.00%

76

Instructions for Table D3: All Applicants must complete Table D3. Applicants should ensure that data entered into Table D3 takes into
consideration the projected loans and investments listed in Exhibit A: Projected Activities. Applicants should assume that NMTC Allocation
awards will be made in mid {YEAR}. Applicants must provide an explanation of Table D3 in response to Question #33(e). The information in
Table D3 must reflect the projected income and operating expense of the Applicant.
1. When entering income data by source, the Applicant must include any and all fees and other sources of compensation that the Applicant
and/or its Affiliates will charge:
a. Investors (including investment partnership funds, if using the leverage structure). Be sure to include any income generated prior
to the QEI being made, any QEI proceeds retained by the Applicant, Controlling Entity or its Subsidiary CDEs;
b. QALICBs (i.e. borrowers/investees) fees and other sources of compensation paid directly to the CDE, including interest income;
c. Affiliates, including the Controlling Entity or Subsidiary CDEs; and
d. Other sources of revenue, including grants, contributions, consulting, other line(s) of business, etc.
2. When entering expenses:
a. Fixed Expenses are expenses incurred by Applicant that are unlikely to vary regardless of the amount of the NMTC Allocation
award or size and number of QLICIs considered or made. For example, staff, facilities, Board/Insurance, CDE audit, etc.
b. Variable Expenses are all other expenses incurred by the Applicant, including compliance, accounting, tax returns, sub-CDE
audits, loan servicing, etc.
3. Data should be stated in dollars by fiscal year, starting with the fiscal year 2022.

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77

TABLE D3: INCOME AND OPERATING EXPENSES
Fiscal Year
2022

2023

2024

2025

2026

2027

2028

After 2028

1. Income by source:
(a) Investor(s)
(b) QALICBs or Affiliates
(c) CDE’s Affiliates
(d) Other Sources
Total Income

$

$

$

$

$

$

$

$

Total Expenses

$

$

$

$

$

$

$

$

Profit/(Loss)

$

$

$

$

$

$

$

$

2. Expenses:
(a) Fixed
(b) Variable

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78

EXHIBIT E: INVESTOR STRATEGY
NOTE for Exhibit E:
1) In Table E1, an Applicant may, at its discretion, rely upon the track record of its Controlling Entity. In order to list the track record of the
Controlling Entity in Table E1, the Applicant must designate a Controlling Entity in Question #3. If the information reflects the
Controlling Entity, it must include in aggregate the track record of all Subsidiaries of the Controlling Entity, including the Applicant. If the
Applicant chooses to complete one table with information from the Controlling Entity, it must do so for all Tables where
Controlling Entity is an option. If the Applicant chooses to complete Table E1 for the Applicant, the information must include, in the
aggregate, the financing track record of all Subsidiaries of the Applicant and may not include any of the Controlling Entity’s activities.
However, if the Applicant chooses to complete Table E1 for the Controlling Entity, the information must include, in the aggregate, the
financing track record of all Subsidiaries of the Controlling Entity, including the Applicant if the Applicant is a Subsidiary of the Controlling
Entity.
2) In Table E1, in the Column titled “2021 Year to Date (YTD),” the Applicant can only enter information on capital raised by the Applicant or
Controlling Entity on or before the release date of the Allocation Application. The Applicant may not enter information on capital
projected to be raised after the Application release date.
3) Complete Table E2, if the Applicant (or Affiliates) received QEIs from investors in equal to or greater than the Allocation requested in
Question #1, between January 1, 2016 and the release date for the NMTC Allocation Application specified in the NMTC Application FAQ
document.
4) Complete Table E3, if the Applicant (or Affiliates) received QEIs from investors in amounts less than the Allocation requested in Question
#1, between January 1, 2016 and the release date for the NMTC Allocation Application. Applicants completing Table E3 are required to
submit, along with their applications, documentation demonstrating proof of investor interest (e.g., proof of QEI issuance; Commitment
letters; Letters of Interest/Intent). For examples of acceptable documentation for the required information, refer to the CDFI Fund’s NMTC
Allocation Application FAQ Document. Be sure to refer to the Electronic Application Instructions for information regarding the submission
of these documents.

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TABLE E1: TRACK RECORD OF RAISING CAPITAL FROM INVESTORS
This table reflect the activities of (check one):

_____Applicant

Calendar Year(s)

1
2

_____Controlling Entity

2016

1

Total # of investments

2

Total $ amount of investments

2017

2018

2019

2020

2021 YTD

Total

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

grants1

3

Total # of

4

Total $ amount of grants2
loans1

5

Total # of below market rate

6

Total $ amount of below market rate loans2
loans1

7

Total # of market rate

8

Total $ amount of market rate loans2
Investments1

9

Total # of Equity

10

Total $ amount of Equity Investments 2

Values should be a subset of Line 1.
Values should be a subset of Line 2.

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Instructions for Table E2:
1) In the first column, Applicants should only list the names of the investors that have provided capital to fund QEIs received by the
Applicant (or a Subsidiary CDE). If the Applicant has used the leveraged structure to receive QEIs from investment funds or
partnerships, it should provide the names of the equity and non-equity (e.g. debt, grant dollars) investors who provided the upper-tier
capital to the investment fund or partnership. It must not provide the name of the investment funds or partnerships. All investments
received from individual investors should be aggregated and listed under the name “Individual Investors.” Do not list the names of
individuals in Table E2.
2) Only enter information on QEIs raised on or before the release date of the NMTC Allocation Application (specified in the NMTC
Application FAQ document). The Applicant may not enter information on planned QEIs or QEIs projected to close.
3) In the third column, indicate whether the investment was provided as a direct QEI or if it was provided to an investment fund or
partnership that in turn made the QEI.
4) In the fourth column, indicate whether the investor was an Affiliate of the Applicant or Controlling Entity.
5) In the fifth column, indicate whether the investor was an Affiliate of the QALICB that received QLICI(s) with QEI proceeds.
6) In the sixth column, provide the total aggregate dollar amount of investment provided by the identified investor between January 1,
2016 and the release date of the NMTC Allocation Application.

TABLE E2: RECENT QEI INVESTORS FOR PREVIOUS ALLOCATEES

Name of Investor

Type of
Investment2

Using Leverage
Structure?

Affiliate of the
Applicant or
Controlling Entity?

Affiliate of the
QALICB or
Project Sponsor?

Total Funding Provided
from 2016-2021

1
Yes/No
Yes/No
Yes/No
$
2
Yes/No
Yes/No
Yes/No
$
3
Yes/No
Yes/No
Yes/No
$
4
Yes/No
Yes/No
Yes/No
$
TOTAL
N/A
N/A
N/A
N/A
$
5
1 If the Applicant received investments from individuals (rather than organizations), please enter these investments, in the aggregate, as provided
by “Individual Investors.”
2 Debt, equity, both debt and equity, or grant.

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Instructions for Table E3: In Table E3, Applicants should only list the names of actual or prospective investors that have provided Equity
Investments (in accordance with applicable IRS rulings regarding the issuance of QEIs prior to notification of an allocation), Commitments, or
Letters of Interest/Intent in connection with a potential NMTC Allocation. To the extent an Applicant has or intends to secure investments from
partnership entities that will leverage non-Equity Investments (e.g., debt, grant dollars), such investments should be separately reported
under “Type of Investment”. If an Applicant plans to engage an investment banker (or other third-party) to raise equity capital on the
Applicant’s behalf, DO NOT INCLUDE such third-party organizations in this table.

TABLE E3: IDENTIFICATION OF INVESTMENTS AND INVESTOR COMMITMENTS

Name of
Investor

Type of
Investment1

Using
Leverage
Structure?

Affiliate of
the
Applicant?

Previous
Investor?2

Total Funding
Provided from 20162021 (if previous
investor)

Dollar
Amount
Sought

Status of
Request3

1
Yes/No
Yes/No
Yes/No
$
$
2
Yes/No
Yes/No
Yes/No
$
$
3
Yes/No
Yes/No
Yes/No
$
$
4
Yes/No
Yes/No
Yes/No
$
$
TOTAL
N/A
N/A
N/A
N/A
$
$
N/A
5
1 Debt, equity, both debt and equity, or grant.
2 A previous investor is any investor that has invested in the Applicant, its Controlling Entity, or any Subsidiary entities since 2016.
3 Funds have been received; investor provided Commitment; investor issued Letter of Interest/Intent.

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Estimated or
Actual Date
for Receipt
of Funds

N/A

GLOSSARY OF TERMS
Affiliate

Any legal entity that Controls, is Controlled by, or is under common
Control with, the Applicant.

Alaska Native Village
Statistical Areas

Areas that represent the more densely settled portion of Alaska
Native Villages (ANVs). The ANVs constitute associations, bands,
clans, communities, groups, tribes, or villages recognized pursuant
to the Alaska Native Claims Settlement Act of 1971 (Public Law 92203).

Allocatee

An Applicant that receives an NMTC Allocation.

Allocation Agreement

An agreement to be entered into by the CDFI Fund and a CDE,
relating to the NMTC Allocation, pursuant to IRC §45D(f)(2).

Allocation Application

The application form, issued by the CDFI Fund pursuant to a Notice
of Allocation Availability (NOAA), to be completed and submitted by
an Applicant in order to be considered for an NMTC Allocation.

Applicant

Any legal entity that is applying to the CDFI Fund for the receipt of
an NMTC Allocation. This term includes any Subsidiary of the
Applicant, which may receive a transfer of all or part of an NMTC
Allocation from the Applicant.

Application Contact Person

The individual that the CDFI Fund may contact during the course of
the Allocation Application review with questions or requests for
additional information regarding the Allocation Application.

Assistance Agreement

A written agreement between the CDFI Fund and an entity receiving
assistance under the CDFI Program and Native American CDFI
Assistance (NACA) Program, specifying the terms and conditions of
assistance including, without limitation, performance and financial
soundness goals, if applicable. See 12 CFR §1805.104(f).

Authorized Representative

An officer, or other individual, who has the actual authority of the
Governing Board (or equivalent) to sign for and make
representations on behalf of the Applicant. This person will also be
the primary point of contact for the Applicant.

CDE Certification Application

The application form, issued by the CDFI Fund, to be completed and
submitted by an entity in order to be certified as a CDE.

Commitment

A document in which an investor commits to make an investment in
the Applicant in a specified amount and on specified terms.

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Community Development
Entity (CDE)

Under IRC §45D(c)(1), any domestic corporation or partnership if:
(1) The primary mission of the entity is serving, or providing
investment capital for, Low-Income Communities or LowIncome Persons;
(2) The entity maintains accountability to residents of LowIncome Communities through their representation on any
governing board of the entity or on any advisory board to the
entity; and
(3) The entity is certified by the CDFI Fund as a CDE.
Specialized Small Business Investment Companies
(SSBICs) and Community Development Financial
Institutions (CDFIs) are deemed to be CDEs in the manner
set forth in Guidance published by the CDFI Fund (66
Federal Register 65806, December 20, 2001).

Community Development
Financial Institution (CDFI)

An entity that has been certified by the CDFI Fund as meeting the
criteria set forth in section 103 of the Community Development
Banking and Financial Institutions Act of 1994 (12 U.S.C. 4702). For
further details, refer to the CDFI Program regulations set forth at 12
CFR 1805.201.

AMIS Compliance and
Performance Reporting
System (ACPR)

A web-based data collection system that CDFIs and CDEs will use
to submit their Institution-Level Reports and Transaction-Level
Reports to the CDFI Fund.

Control

For purposes of this application is defined as:
(1) Ownership, control, or power to vote more than 50 percent
of the outstanding shares of any class of voting securities of
any entity, directly or indirectly or acting through one or
more other persons; or
(2) Control in any manner over the election of a majority of the
directors, trustees, or general partners (or individuals
exercising similar functions) of any other entity; or
(3) Power to exercise, directly or indirectly, a controlling
influence over the management policies or investment
decisions of another entity, as determined by the CDFI
Fund.

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Controlling Entity

A Controlling Entity is an Entity that Controls the CDE as follows:
a. For-profit CDEs:
(i) ownership, control, or power to vote more than 50 percent
of the outstanding shares of any class of voting securities
of the CDE at the time of Application and throughout the
term of the Allocation Agreement (if the CDE is selected
to receive an Allocation); and
(ii) Control in any manner over the election of a majority of
the directors, trustees, or general partners (or individuals
exercising similar functions) of the CDE, including Control
over the appointment and removal of the CDE’s
Executive management team (e.g. CEO, COO, CFO);
and
(iii) Approval authority over the management policies and
investment decisions of the CDE.
b. Not-for-profit CDEs:
(i) Control in any manner over the election of a majority of
the directors, trustees, or general partners (or individuals
exercising similar functions) of the CDE at the time of
Application and throughout the term of the Allocation
Agreement (if the CDE is selected to receive an Allocation)
and
(ii) Control in any manner over the election of a majority of
the directors, trustees, or general partners (or individuals
exercising similar functions) of the CDE, including Control
over the appointment and removal of the CDE’s Executive
management team (e.g. CEO, COO, CFO); and
(iii) approval authority over the management policies and
investment decisions of the CDE.

Controlling Entity
Representative

An officer, or other individual, who has the actual authority to sign for
and make representations on behalf of the Controlling Entity. This
person will also be the primary point of contact for the Controlling
Entity, should the CDFI Fund need to confirm representations made
about the relationship between the Applicant and Controlling Entity.

Disadvantaged Business

A business that is (a) located in a Low-Income Community; (b) LowIncome Person-owned or -controlled; or (c) Minority-owned or controlled or Native American-owned or -controlled and lacks access
to loans or equity investments

Disadvantaged Community

This term has the same meaning as a Low-Income Community.

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Enforcement Action

An action or administrative order, including but not limited to,
consent order, cease and desist order, PCA directive, safety and
soundness order, agreement, memorandum of understanding,
commitment letter, taken by a federal regulator or agency (e.g.,
FDIC, OCC, NCUA, FRB, CFPB) when a regulated financial
institution is found to be in an unsatisfactory condition (e.g. violations
of laws, rules or regulations, final orders or conditions imposed in
writing; unsafe or unsound practices; and for breach of fiduciary duty
by institution-Affiliated parties).

Equity Equivalent Loan

A loan that has certain equity-like provisions, including required
principal and interest payments only from cash flow and a flexible
maturity date. Note that the definition of this term under the CDFI
Program and NMTC Program is more flexible than the definition of
the same term under the Bank Enterprise Award (BEA) Program.

Equity Investment

Under IRC §45D(b)(6) and the NMTC Program Income Tax
Regulations, Equity Investment means any stock (other than
nonqualified preferred stock as defined in IRC §351(g)(2)) in an
entity that is a corporation and any capital interest in an entity that is
a partnership.

Federal Indian Reservation

Area of land reserved for a tribe or tribes under treaty or other
agreement with the United States, executive order, or federal statute
or administrative action as permanent tribal homelands, and where
the federal government holds title to the land in trust on behalf of the
tribe.

Financial Counseling and
Other Services (FCOS)

Advice provided by a CDE relating to the organization or operation
of a trade or business. See 26 CFR 1.45D-1(d)(7).

Food Desert

A low-income census tract where a substantial number or share of
residents has low access to a supermarket or large grocery store.
Census tracts qualify as Food Deserts if they meet low-income and
low-access thresholds established by the USDA and can be found
using the Food Access Research Atlas at
http://www.ers.usda.gov/data-products/food-access-researchatlas.aspx

FTE

A full time equivalent (FTE) is at least a 35-hour work week.

Hawaiian Home Lands

Areas held in trust for Native Hawaiians by the state of Hawaii,
pursuant to the Hawaiian Homes Commission Act of 1920, as
amended.

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Letter of Interest/Intent

A document in which an investor expresses a preliminary interest in
making an investment in the Applicant.

Low-Income Community
(LIC)

Under IRC §45D(e)(1), any population census tract if:
(1) The poverty rate for such tract is at least 20 percent, or
(2) (a) In the case of a tract not located within a metropolitan
area, the median family income for such tract does not
exceed 80 percent of statewide median family income, or (b)
in the case of a tract located within a metropolitan area, the
median family income for such tract does not exceed 80
percent of the greater of statewide median family income or
the metropolitan area median family income.
With respect to IRC §45D(e)(1)(B), possession-wide median family
income shall be used (in lieu of statewide income) in assessing the
status of census tracts located within a possession of the United
States.
Under IRC §45D(e)(2), Targeted Populations will also be treated as
Low-Income Communities. See IRS Notice 2006-60.
Under IRC §45D(e)(3), in the case of an area that is not tracted for
population census tracts, the equivalent county divisions (as defined
by the Bureau of the Census for purposes of determining poverty
areas) shall be used for purposes of defining poverty rates and
median family incomes. See IRC §45D(e) for additional criteria.

Low-Income Person

Any individual having an income, adjusted for family size, of not
more than:
(1) For metropolitan areas, 80 percent of the area median
family income; and
(2) For non-metropolitan areas, the greater of (a) 80 percent of
the area median family income or (b) 80 percent of the
statewide non-metropolitan area median family income.

Low-Income Person-owned
or
Low-Income Personcontrolled

For-profit entity: A for-profit entity that has at least 51 percent of its
equity ownership (or the equivalent in limited liability companies)
interest being owned by one or more Low-Income Person.
Not-for-profit entity: A not-for-profit entity with at least 51 percent of
its Board of Directors (i.e. Governing Board) comprised of individuals
who are Low-Income Persons.

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Minority-owned or Minoritycontrolled

A Minority-owned or Minority-controlled entity is a:
a. Minority-owned for-profit entity: A for-profit entity that is not a
MDI and that has at least 51 percent of its equity ownership
(or the equivalent in limited liability companies) interest
being owned by individuals who identify themselves as
Asian, Black or African American, , Hispanic or Latino, or
Native Hawaiian or Other Pacific Islander;
b. Minority-controlled not-for-profit entity: A not-for-profit entity
with at least 51 percent of its Board of Directors (i.e.
Governing Board) comprised of individuals who identify
themselves as Asian, Black or African American, Hispanic or
Latino, or Native Hawaiian or Other Pacific Islander; or
c.

Minority Depository Institution (MDIs): An entity that is
designated by the FDIC as a Minority Depository Institution.

The CDFI Fund will rely on the categories established by the 1997
Office of Management and Budget (OMB) standards to define Asian,
Black or African American, Hispanic or Latino, and Native Hawaiian
or Other Pacific Islander.
Native American

Native American-owned or
Native American-controlled

For the purpose of the NMTC Program this term shall include,
members of Tribal entities recognized by the U.S. Department of the
Interior, Bureau of Indian Affairs (BIA); and individuals having origins
in any of the original peoples of Hawaii.
For-profit entity: A for-profit entity, including an MDI, that has at least
51 percent of its equity ownership (or the equivalent in limited liability
companies) interest being owned by individuals who are Native
American.
Not-for-profit entity: A not-for-profit entity with at least 51 percent of
its Board of Directors (i.e. Governing Board) comprised of individuals
who are Native American.

New Markets Venture Capital
Company (NMVCC)

An entity designated as a NMVCC by the Small Business
Administration under the New Markets Venture Capital Company
Program. See 13 CFR 108.10 for more information.

Non-Metropolitan Counties

Counties not contained within a Metropolitan Statistical Area, as
such term is defined in OMB Bulletin No. 15–01 (Update of
Statistical Area Definitions and Guidance on Their Uses) and applied
to the 2010 census tracts.

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Notice of Allocation
Availability (NOAA)

A document published by the CDFI Fund in the Federal Register that
provides specific guidance on how a CDE may apply for an NMTC
Allocation, the competitive procedure through which such allocations
will be made, and the actions that will be taken by the CDFI Fund to
ensure that proper allocations are made to appropriate entities. The
NOAA published in conjunction with the Allocation Application will
only apply to this Allocation Round.

NMTC Allocation

An allocation of tax credit authority pursuant to the New Markets Tax
Credit Program.

NMTC Program Income Tax
Regulations

The regulations promulgated by the Internal Revenue Service which
provide guidance for taxpayers claiming the New Markets Tax Credit
under IRC §45D. See 26 CFR 1.45D-1 for more information.

Off-reservation Trust Lands

Areas for which the United States holds title in trust for the benefit of
a tribe that is located outside the boundaries of a Federal Indian
Reservation but is always associated with a specific federally
recognized reservation and/or tribal government.

Operating Business

Any business whose predominant business activity (i.e. activity that
generates more than 50 percent of the business’ gross income)
does not include the development (including construction of new
facilities and rehabilitation/enhancement of existing facilities),
management, or leasing of real estate.

Principal

As defined by 31 C.F.R. Part 19.995. Principal means—(a) An
officer, director, owner, partner, principal investigator, or other
person within a participant with management or supervisory
responsibilities related to a covered transaction; or(b) A consultant
or other person, whether or not employed by the participant or paid
with Federal funds, who—(1) Is in a position to handle Federal
funds;(2) Is in a position to influence or control the use of those
funds; or,(3) Occupies a technical or professional position capable of
substantially influencing the development or outcome of an activity
required to perform the covered transaction.

Project Sponsor

An entity that owns or Controls the QALICB.

Public Contact Person

The individual that will field public inquiries (i.e. from potential
QALICBs) if the Applicant is selected to receive an NMTC Allocation.
This contact information will be published as part of the Award
Announcement for the NMTC Allocation round and available to the
public in the CDFI Fund’s monthly QEI Issuance Report.

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Qualified Active Low-Income
Community Business
(QALICB)

Under IRC §45D(d)(2), any corporation (including a non-profit
corporation) or partnership if for any taxable year:
(1) At least 50 percent of total gross income of such entity is
derived from the active conduct of a qualified business
within any Low-Income Community;
(2) A substantial portion of the use of the tangible property of
such entity (whether owned or leased) is within any LowIncome Community;
(3) A substantial portion of the services performed for such
entity by its employees are performed in any Low-Income
Community;
(4) Less than 5 percent of the average of the aggregate
unadjusted bases of the property of such entity is
attributable to collectibles (as defined in IRC §408(m)(2))
other than collectibles that are held primarily for sale to
customers in the ordinary course of such business; and
(5) Less than 5 percent of the average of the aggregate
unadjusted bases of the property of such entity is
attributable to nonqualified financial property (as defined in
IRC §1397C(e)).
Please refer to the NMTC Program Income Tax Regulations at 26
CFR 1.45D-1(d)(4) for more information.

Qualified Equity Investment
(QEI)

Under IRC §45D(b)(1), any Equity Investment in a CDE if:
(1) Such investment is acquired by the investor at its original
issue (directly or through an underwriter) solely in exchange
for cash;
(2) Substantially all of such cash is used by the CDE to make
QLICIs; and
(3) The investment is designated for purposes of IRC §45D by
the CDE as a QEI. QEI also includes an Equity Investment
purchased from a prior holder, to the extent provided in IRC
§45D(b)(4).
QEI does not include any Equity Investment issued by a CDE more
than five years after the date the CDE receives an NMTC Allocation.
Please refer to the NMTC Program Income Tax Regulations at 26
CFR 1.45D-1(c) and related Internal Revenue Service notices for
more information.

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Qualified Low-Income
Community Investments
(QLICI)

Under IRC §45D(d)(1), a QLICI is:
(1) Any capital or Equity Investment in, or loan to, any QALICB
(as defined in IRC§45D(d)(2));
(2) The purchase from a CDE of any loan made by such entity
that is a QLICI;
(3) Financial Counseling and Other Services to businesses
located in, and residents of, Low-Income Communities; and
(4) Any Equity Investment in, or loan to, any CDE.
Please refer to the NMTC Program Income Tax Regulations at 26
CFR 1.45D-1(d)(1) for more information.

Real Estate Activities

Restricted NMTC Business
Activities

Refers to the development (including construction of new facilities
and rehabilitation/enhancement of existing facilities), acquisition,
management or leasing of real estate by a business.
1. Certain businesses that engage in the rental of real property,
if:
a. The property is residential rental property as defined by
IRC §168(e)(2)(A), or
b. There are not substantial improvements on the property,
or
c. A lessee of the real property is an excluded business as
described in 2(b) below.
2. Specific businesses and activities excluded under Treasury
Regulation §1.45D-1(d)(5)(ii) and listed below:
a. Trades or businesses consisting predominantly of the
development or holding of intangibles for sale or license.
b. Trades or businesses consisting of the operation of any
private or commercial golf course, country club, massage
parlor, hot tub facility, suntan facility, race track or other
facility used for gambling, or any store for which the
principle business is the sale of alcoholic beverages for
consumption off the premises.
Farming (within the meaning of IRC §2032A(e)(5)(A) or (B)) if, as of
the close of the taxable year of the taxpayer conducting such trade
or business, the sum of the aggregate unadjusted basis (or, if
greater, the fair market value) of the assets owned by the taxpayer
that are used in such trade or business, and the aggregate value of
the assets leased by the taxpayer that are used in such trade or
business, exceeds $500,000. Two or more trades or businesses will
be treated as a single trade or business under rules similar to the
rules of IRC §52(a) and (b).

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Rural CDE

A Rural CDE is one that has a track record of at least three years of
direct financing experience, has dedicated at least 50 percent of its
direct financing dollars to Non-Metropolitan Counties over the past
five years, and has committed that at least 50 percent of its NMTC
financing dollars with this Allocation will be deployed in such areas.
Non-Metropolitan Counties are counties not contained within a
Metropolitan Statistical Area, as such term is defined in OMB
Bulletin No. 15–01 (Update of Statistical Area Definitions and
Guidance on Their Uses) and applied using 2010 census tracts.

Small Business Investment
Company (SBIC)

An entity defined in 15 USC 662(3).

Specialized Small Business
Investment Company
(SSBIC)

An entity defined in IRC §1044(c)(3).

Subsidiary

Any legal entity that is owned or Controlled directly or indirectly by
an Applicant. This term includes series funds, which are separate
investment funds Controlled by an Applicant.

Targeted Population

As defined in 12 U.S.C. 4702(20) and 12 C.F.R. 1805.201, the term
“targeted population” means individuals, or an identifiable group of
individuals, including an Indian Tribe, who (A) are Low-Income
Persons; or (B) otherwise lack adequate access to loans or
investments.

Unrelated

Persons who are not related within the meaning of IRC §267(b) or
IRC §707(b)(1).

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