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pdfAppendix A. CY 2021-23 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
1
3/1/2021
Blooming
Ventures
Elaine DiPietro
General
Application
IT
Enhancement
Allow Applicant to
have rich text format
to bold, underline, and
add bullets in narrative
response
2
3/1/2021
Self-Help
Venture Fund
Amanda Frazier
Wong
Community
Outcomes
Question 26
Application
Add "financing multiservice community
org" as a new
community outcome
category
3
3/1/2021
Self-Help
Venture Fund
Amanda Frazier
Wong
Application
Information
Question 3
Review
Process
Provide priority points
to Applicants who
have nonprofit or CDFI
Controlling Entities
The CDFI Fund will
consider additional
enhancements to
AMIS functionality in
future application
rounds.
This comment would
not reduce burden in
completing the
NMTC Program
Application and is not
necessary for the
CDFI Fund's
evaluation.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
4
3/1/2021
NMTC Working
Group
Brad Elphick
Application
Information
Question 3
Guidance
Clarify if the parent
company is considered
a Controlling Entity. If
CE's track record is not
used, should CDE
answer "yes" in Q3?
5
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Application
Information
Question 9
Application
Remove
"major/minor" urban
areas
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
The CDFI Fund is
retaining the current
definitions. This
information is
necessary for
publication on the
CDFI Fund website.
6
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Application
Information
Question 9
Application
7
3/1/2021
African
American
Alliance of CDFI
CEOs, Chicago
Community
Loan Fund
Donna
Gambrell, Calvin
Holmes
Application
Instructions
Question 3
Application
Replace answer option
"Real estate financing"
with "business
primarily engaged in
Real Estate Activities"
to better align with
glossary; move subcategories from Q10 to
Q13(b)
Add question "Is the
Controlling Entity a
Minority Depository
Institution?"
2
The CDFI Fund is
retaining the current
definitions. This
information is
necessary for
publication on the
CDFI Fund website.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
#
Date of
Comment
8
3/1/2021
9
3/1/2021
Organization
U.S. Bancorp
Community
Development
Corporation
(USBCDC), New
Markets Tax
Credit Coalition,
NMTC Working
Group, LISC,
Enterprise,
African
American
Alliance of CDFI
CEOs, Chicago
Community
Loan Fund,
Blooming
Ventures
NMTC Working
Group
Author Name
Section
Category
Topic
Comment
Zachary Boyers,
Robert Rapoza,
Brad Elphick,
Matthew
Josephs,
Chimeka
Gladney, Donna
Gambrell, Calvin
Holmes, Elaine
DiPietro
Application
Instructions
CDE
Certification
Deadline
Review
Process
Remove requirement
for applicants to be
certified as a CDE at
the time the NOAA is
published.
Brad Elphick
Business
Strategy
Question 18
Due Diligence
(New)
Application
Remove "and after" in
"a QALICB’s ability to
remain financially
viable and operational
during and after the
NMTC compliance
period.”
3
NMTC Response
future policy
decisions.
The CDFI Fund has
decided to remove
this eligibility
requirement and
revert to the current
process of allowing
applicants
approximately two
weeks after the
publication of the
NOAA to apply for
CDE certification.
The CDFI Fund
revised this question
based on public
comments.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
10
3/1/2021
NMTC Working
Group
Brad Elphick
Business
Strategy
Question 19
Application
Allow at least 2000
character limit per
additional innovative
use(s) in addition to
current 5000 limit
11
3/1/2021
NMTC Working
Group
Brad Elphick
Business
Strategy
Question 20(b)
Application
12
3/1/2021
NMTC Working
Group
Brad Elphick
Community
Outcomes
Question 25(a)
Application
Clarify third bullet in
Q20(b) if the three
largest sources of
capital on the CE's
balance sheet if they
deploy non-NMTC
loans or would CE be
considered one of
three largest capital
sources of capital?
Revert commitment of
% QLICI to 75%,
instead of proposed
85%
This comment would
not reduce burden in
completing the
NMTC Program
Application and is not
necessary for the
CDFI Fund's
evaluation.
The CDFI Fund
revised this question
based on public
comments.
13
3/1/2021
NMTC Working
Group
Brad Elphick
Community
Outcomes
Question 26
Application
4
Quantify community
outcomes on total
dollar QEI instead of
QLICI
The CDFI Fund is
retaining the
threshold of 85%, as
proposed.
The CDFI Fund
revised this question
based on public
comments.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
14
3/1/2021
NMTC Working
Group
Brad Elphick
Community
Outcomes
Question
26(a)(2)
Guidance
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
15
3/1/2021
NMTC Working
Group
Brad Elphick
Community
Outcomes
Question
26(a)(3)
Application
Clarify whether
Applicant can use its
own definition or use
the application's
definition, FAQ#81
states Applicant
should clearly define a
"Quality Job"
Change "limited
language proficiency"
to "limited English
language proficiency"
16
3/1/2021
NMTC Working
Group
Brad Elphick
Community
Outcomes
Question
26(a)(5)
Community
Goods and
Services
Application
Remove requirement
to provide third party
metrics
The CDFI Fund is
maintaining the
current requirements
for this question,
which is necessary
for the application
evaluation.
17
3/1/2021
NMTC Working
Group
Brad Elphick
Capitalization
Strategy
Question 37(c )
Guidance
Claritfy whether
percentage of leverage
debt anticipated to be
sourced from the
Investment Fund
means only the
leverage loan or
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
5
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
instead source debt
for the leverage loan.
18
3/1/2021
NMTC Working
Group
Brad Elphick
Information
Regarding
Previous
Awards
Question 44
Application
Clarify whether 5th
bullet includes any
QALICB consultant
fees
The CDFI Fund
revised this question
based on public
comments.
19
3/1/2021
NMTC Working
Group
Brad Elphick
Exhibits
Table A5
Application
Clarify whether
outcome in Table A5
should be selected if
Applicant isn't
responding to
outcomes in Q26
The CDFI Fund
revised this question
based on public
comments.
20
3/1/2021
NMTC Working
Group
Brad Elphick
Exhibits
Table D2
Application
Clarify if QLICI loan
interest should be
reported if it will be
collected and
distributed to
Investment Fund to
pay leverage loan
interest or report only
if it's above what is
needed for leverage
loan
The CDFI Fund
revised this question
based on public
comments.
6
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
21
3/1/2021
NMTC Working
Group
Brad Elphick
Exhibits
Table D2
Application
Increase character
limit from 50 to at
least 100 for
"Description of the
Fee"
22
3/1/2021
NMTC Working
Group
Brad Elphick
Glossary of
Terms
Minority-owned
or Minoritycontrolled
Application
Propose edits of
definition to expand
beyond 51%
ownership
23
3/1/2021
NMTC Working
Group, Self-Help
Venture Fund
Brad Elphick,
Amanda Frazier
Wong
Community
Outcomes
Question 26
Application
Add "small business
and nonprofit support"
as a new community
outcome category
This comment would
not reduce burden in
completing the
NMTC Program
Application and is not
necessary for the
CDFI Fund's
evaluation.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
This comment would
not reduce burden in
completing the
NMTC Program
Application and is not
necessary for the
CDFI Fund's
evaluation.
7
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
24
3/1/2021
Self-Help
Venture Fund
Amanda Frazier
Wong
General
Phase 1 review
Review
Process
Engage NMTC experts
and/or CDFI Fund staff
to conduct Phase 1
review
25
3/1/2021
NMTC Working
Group,
Blooming
Ventures LLC
Brad Elphick,
Elaine DiPietro
Business
Strategy
Question 20(c),
21(c), 22©
Guidance
26
3/1/2021
NMTC Working
Group,
Blooming
Ventures LLC
Brad Elphick,
Elaine DiPietro
Management
Capacity
Question 34
Fees
Guidance
Clarify if years
requested are years
when financing was
made, or cumulative
years financing has
been provided; clarify
minimal threshold
defined by "has
served", if investments
occurred in 2018,
2018, 2020, is the
answer 3 or 5 years
Clarify instructions so
Applicants state what
happens to reserve
held but not used
during compliance
period
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
8
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
27
3/1/2021
Brad Elphick,
Merrill
Hoopengardner,
Elaine DiPietro
Exhibits
Table A5
Application
Change "Total QLICIs
from unaffiliated
CDEs" into "Estimated
Total QEIs from
unaffiliated CDEs"
under Part J
The CDFI Fund
revised this question
based on public
comments.
28
3/1/2021
NMTC Working
Group, National
Trust
Community
Investment
Corporation,
Blooming
Ventures LLC
Self-Help
Venture Fund
Amanda Frazier
Wong
General
Phase 1 review
Review
Process
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
29
3/1/2021
Self-Help
Venture Fund
Amanda Frazier
Wong
General
Review Process
Review
Process
Release training
procedures and
documents to
Applicants; clarify how
Applicants are
assigned; review and
analyze whether score
variations result from
reviewer tendencies;
train external
reviewers on different
types of CDEs applying
Review all five sections
in Phase 1, or delay
scoring and ranking
applications until all
sections are scored
9
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
30
3/1/2021
Enterprise
Community
Partner
Chimeka
Gladney
Business
Strategy
Question 24
Application
Add text to end of 3rd
Note: "or providing an
equity QLICI"
The CDFI Fund
revised this question
based on public
comments.
31
3/1/2021
Enterprise
Community
Partner
Chimeka
Gladney
Community
Outcomes
Question 26
Guidance
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
32
3/1/2021
Self-Help
Venture Fund
Amanda Frazier
Wong
General
Phase 2 review
Review
Process
33
2/11/2021
Opportunity
Fund
Chris Huang
Business
Strategy
Question 24
Application
Provide examples of
"clear and sound"
methods and metrics
per 3rd note listed
under B. Community
Outcomes,
immediately prior to
Q26
Communicate to the
Applicant if any point
reductions, reordering
or other negative
action; if allocations
not awarded if
recommended amount
is lower than
Applicant's minimum
acceptable amount;
Selecting Official's
decision to reverse or
deviate from panel's
recommendation
Clarify in 2nd note that
"Applicant will be
evaluated favorably" in
Phase 2
10
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
The CDFI Fund
revised this question
based on public
comments.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
34
2/11/2021
Opportunity
Fund
Chris Huang
Community
Outcomes
Question 26
Review
Process
Re-evaluate scoring of
Q26 so applicants with
the most quantity of
outcomes receive the
highest scores
35
3/1/2021
Self-Help
Venture Fund
Amanda Frazier
Wong
General
Review Process
Review
Process
Include a broader
point range to mitigate
score clusters
36
3/1/2021
NMTC Working
Group,
Enterprise
Community
Partners
Brad Elphick,
Chimeka
Gladney
General
Reporting
Requirements
Review
Process
Request QEI/QLICI
deployment deadline
for 2021 round be
announced at the
same time as 2020
awards; delay QLICI
deadline by 6 months
due to COVID
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
11
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
37
3/1/2021
Enterprise
Community
Partner
Chimeka
Gladney
General
Recordings of
CDFI Fund
presentations
Customer
service
Make recordings of
CDFI Fund
presentations
available for all
applicants as a
reference
The CDFI Fund will
consider changes in
future application
rounds.
38
3/1/2021
PNC Bank
David Gibson
Business
Strategy
Question 13(b)
Guidance
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
39
3/1/2021
PNC Bank, New
Markets Tax
Credit Coalition
David Gibson,
Robert Rapoza
Business
Strategy
Question 19
Application
Add note and adjust
scoring instructions for
Phase 1 reviewers to
specify that Applicants
are not expected to
have a track record to
invest in or lend to
other CDEs
Modify or create
additional "Innovative
Investment" type to
specify “unrelated
minority-owned or
minority-controlled or
Native American
owned
or Native Americancontrolled CDEs that
do not have NMTC
allocations.”
12
The CDFI Fund added
a new Innovative
Activity in Q.19 based
on public comments.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
40
3/1/2021
Enterprise
Community
Partner
Chimeka
Gladney
General
Application
materials
Customer
Service
Release FAQs at the
same time as the
Application
The CDFI Fund will
consider changes in
future application
rounds.
41
3/1/2021
Chimeka
Gladney,
Kendra Key.
David Gibson,
Donna
Gambrell,
General
Racial Equity
Review
Process
Increase amount of
allocation awarded to
and managed by
minority-owned or
controlled CDEs,
create a set-aside
42
3/1/2021
Enterprise
Community
Partner, Hope
Enterprise
Corporation,
PNC Bank,
African
American
Alliance of CDFI
CEO
NAFOA
Dante Desiderio
General
Native Initiative
Review
Process
Reduce scores in the
next funding round
when CDEs do not
fulfill commitment in
Q19 and Q25
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
13
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
43
3/1/2021
African
American
Alliance of CDFI
CEOs,
Advantage
Capital, Chicago
Community
Loan Fund
Donna
Gambrell,
Jonathan
Goldstein,
Calvin Holmes
Glossary of
Terms
MinorityOwned or
Minoritycontrolled
Application
Add suggested text to
"for-profit" and "notfor-profit entity": "i.e.,
the daily operations
are controlled by and
under the direction of
designated
minority group
members."
44
2/24/2021
Blooming
Ventures LLC
Elaine DiPietro
Exhibits
Table B1
Guidance
45
2/24/2021
Blooming
Ventures LLC
Elaine DiPietro
Exhibits
Table B1
Guidance
Clarify if Row includes
other sources for same
QALICBs (indirect
financing) AND indirect
financing provided by
the Applicant (nonNMTC), recommend
adding 4th row to
separate the two
Provide guidance for
CDEs making business
loans/working capital
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
14
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
46
2/24/2021
Blooming
Ventures LLC
Elaine DiPietro
Business
Strategy
Question 20(c ),
21(c )
Application
Is listing both
disadvantaged
businesses and
disadvantaged
communities
necessary since the
definition changed
The CDFI Fund
revised this definition
based on public
comments.
47
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Exhibits
Table D2
Application
Update wording to
"upfront fee" charged
"before or at the time
of QLICI closing or QEI
funding"
The CDFI Fund
revised this question
based on public
comments.
48
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Exhibits
Table D2
Guidance
Clarify whether
expenses for
application writer or
other consultants
count as expenses
under Table D2, part
3(d)
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
49
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Exhibits
Table D2
Guidance
Clarify if the same
table can be used for
multiple financial
products if they use
the same fee structure
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
15
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
50
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Management
Capacity
Question 34
Fees
Application
The CDFI Fund
revised this question
based on public
comments.
51
3/1/2021
NAFOA
Dante Desiderio
General
Native Initiative
Application
Clarify if fees include
interest income to the
extent it's retained by
CDE for "ongoing fee",
not that CDE include
both interest income
and "expense" of
distribution to the
investor
Give Applicants extra
credit for partnering
with organizations that
primarily serve Indian
Country
52
3/1/2021
NAFOA
Dante Desiderio
General
Native Initiative
Review
Process
Utilize reviewers that
understand challenges
of and capabilities
investing in tribal
communities
53
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Business
Strategy
Question 20(b)
Application
Remove second bullet,
instead add a chart
showing Applicant's
direct/indirect
financing
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
The CDFI Fund will
consider changes in
future application
rounds.
16
The CDFI Fund added
a new Innovative
Activity in Q.19 based
on public comments.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
54
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Business
Strategy
Question 20(b)
Guidance
Clarify in application,
instead of FAQ, if an
Applicant can discuss
their full track record
or only 5 yrs in Exhibit
B, recommend last 7
yrs
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
55
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Business
Strategy
Question 21 or
22€
Application
Remove "Restricted
NMTC Activities" from
Q21 since the heading
for Table B4 was
changed
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
56
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Business
Strategy
Question 20(b)
Application
Clarify why "or" in 4th
bullet is emphasized
The CDFI Fund
revised this question
based on public
comments.
57
3/1/2021
Blooming
Ventures
Elaine DiPietro
Business
Strategy
Question 14
Application
Change question to
focus on the
flexible/more
favorable market
terms are important,
or how the two
impacts the QALICB,
product description
would be required
only if it's not common
A/B loan structure
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
17
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
58
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
FAQ
FAQ #86
Guidance
Clarify what should be
included when
discussing impact from
portion of the project
financed by QLICI
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
59
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
FAQ
FAQ #6
Guidance
Correct reference from
Q30(c) to Q30(d) since
it relates to Table D1
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
60
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Business
Strategy
Question 17(d)
Guidance
Clarify if CDFI Fund has
preference for CDEs to
specialize by project
type, geography, etc to
inform investment
strategies
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
61
3/1/2021
African
American
Alliance of CDFI
CEOs, Chicago
Community
Loan Fund,
National
Bankers
Association
Donna
Gambrell, Calvin
Holmes, Robert
James II,
General
Emerging CDEs
Review
Process
Preserve at least 40%
allocation for
"Emerging Qualified
CDEs", add definition
to glossary (<$150M
assets, <=five
allocations), add
provisions for
Applicants to self-
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
18
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
identify as "Emerging
Qualified CDE", add
instructions in Q2,
compete against other
"Emerging Qualified
CDEs" in its own pool
future policy
decisions.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
The CDFI Fund will
consider additional
enhancements to
AMIS functionality in
future application
rounds.
62
3/1/2021
African
American
Alliance of CDFI
CEOs, Chicago
Community
Loan Fund,
National
Bankers
Association
Donna
Gambrell, Calvin
Holmes, Robert
James II,
General
Review Process
Review
Process
Amend scoring process
that favor larger more
tenured Applicants,
where less tenured
"Emerging CDEs"
63
3/1/2021
Blooming
Ventures
Elaine DiPietro
General
Allocation
Agreement
IT
Enhancement
Provide alternatives to
hardcopy signatures
from Controlling Entity
Authorized
Representatives
19
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
64
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Business
Strategy
Question 17(c)
Application
The CDFI Fund will
consider changes in
future application
rounds.
65
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Business
Strategy
Question 17
Application
66
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Exhibits
Table A1-A4
Application
Change answer format
to a chart including:
total # of
businesses/CDEs, total
QEI/QLICI financing to
be provided by
applicant, % of
category for business
types, % of activity
types
In 3rd note
immediately prior to
Q17, clarify if "clearly
consistent" with
business strategy
related to business
types or overall
strategy of community
outcomes
Clarify whether the
table asks for QEIs or
QLICIs, recommend
QEI so it's consistent
with Q1
20
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
67
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Exhibits
Table A5
Guidance
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
68
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Exhibits
Table A5
Guidance
Clarify language for
Part A where "links to
narrative description
in Q17" contradicts
FAQ specifying not
including detailed
project descriptions in
Q17
Provide guidance for
Part B where small
deal/revolving loan
fund are in multiple
locations
69
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Exhibits
Table A5
Guidance
Provide guidance for
Part C for census tract
where location has not
been determined
70
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Capitalization
Strategy
Question 38
Guidance
Clarify what's meant
by investors
identifying
transactions or if
there's a min
threshold that would
or would not be
considered investor
"originating or
21
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
otherwise identifying"
transactions
71
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Capitalization
Strategy
Question 39
Guidance
Clarify whether a CDE
that receives a QEI
funded in part with
leverage from an
affiliate should select
"yes"
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
72
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Exhibits
Table A5
Application
Remove Part I since all
applicants must
answer "investment in
QALICB"
The CDFI Fund
revised this question
based on public
comments.
73
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Information
Regarding
Previous
Awards
Question 44(e)
Application
Move Q24 to Part III or
IV, or combine Q24
with Q44(e)
74
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Information
Regarding
Previous
Awards
Question 45
Guidance
Edit wording since
allocatee must retain
control of the
CDE/sub-CDE
This comment would
not reduce burden in
completing the
NMTC Program
Application and is not
necessary for the
CDFI Fund's
evaluation.
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
22
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
75
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Information
Regarding
Previous
Awards
Question 45
IT
Enhancement
Reduce burden by
saving info year to
year or reported out of
AMIS
76
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Information
Regarding
Previous
Awards
Question 44(b)
Application
Combine this question
with other questions
about co-investing or
remove question
The CDFI Fund will
consider additional
enhancements to
AMIS functionality in
future application
rounds.
The CDFI Fund
revised this question
based on public
comments.
77
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Exhibits
Table C1/C2
Guidance
Should board
members be listed in
both charts if they
provide management
support
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
78
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Exhibits
Table C2
Application
Where should
applicant discuss
application writer?
This information may
be collected in the
"other" option in
Table C2
23
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
79
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Exhibits
Table C1/C2
Review
Process
Allow Applicant to
have more options in
being accountable to
LICs
80
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Exhibits
Table C1/C2
Guidance
Should Applicant
notify the CDFI Fund if
board members
change since the
submission of the
Application
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
81
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Exhibits
Table C2
Application
Add "application
consultant" under
"type of activity", add
"asset manager" under
"position with
applicant"
24
This information may
be collected in the
"other" option in
Table C2
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
82
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Exhibits
Table A5
Guidance
Clarify definition of
mixed-use real estate
as multiple uses in one
building like mixed
tenants, or
commercial/residential
under Part N
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
83
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Exhibits
Table A5
Guidance
Clarify if food related
business fall under
"retail" in Part N
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
84
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Business
Strategy
Question 17
Guidance
In 4th note
immediately prior to
Q17, clarify if guidance
for "Small
Dollar/Revolving Loan
Fund" applies to all
scenarios of small
dollar QLICIs, revolving
loan funds, and combo
of both
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
25
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
85
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Management
Capacity
General
Guidance
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
86
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Community
Outcomes
Question 26
Guidance
Clarify dates and time
frames for question
and tables (app
release date in Q30(d)
vs tables with FYE,
Q30e pertain to
Applicant's entire
operating history or
within past 3 years
In part A of 3rd note,
"quantities" should be
explained and
compared to the track
record but not
expected to be
consistent
87
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Community
Outcomes
Question 26
Guidance
Incorporate guidance
from FAQ on how to
provide info with other
CDEs/multi-CDE
investments; how info
ties back to Exhibit B
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
88
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Community
Outcomes
Question 26
Guidance
Clarify how impact
from small
loans/revolving loan
funds are discussed
when investments are
not identified
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
26
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
89
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Community
Outcomes
Question 26
Guidance
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
90
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Community
Outcomes
Question
26(a)(1),
26(a)(2),
26(a)(3)
Application
Provide guidance on
how metrics are
assessed, if metrics are
just reported, or
should be analyzed to
support quantity
and/or quality of
outcomes
Combine three job
categories with higher
character limit
91
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Business
Strategy
Question 24
Application
Clarify how the info is
used since the first
note states it is not
used to consider
whether an Applicant
is scored highly
enough for allocation
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
92
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
Business
Strategy
Question 24
Guidance
In 3rd note, provide
guidance for CDFIs or
lenders that may make
loans to the same or
affiliate borrowers
through affiliates of
Applicant in normal
course of business
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
27
The CDFI Fund is
maintaining the
current requirements
for this question,
which is necessary
for the application
evaluation.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
93
3/1/2021
Zachary Boyers,
Robert Rapoza,
Brad Elphick,
Chimeka
Gladney, Donna
Gambrell, Calvin
Holmes, Robert
James II
Business
Strategy
Question 20
and 21
Review
Process
Remove restriction to
discuss experience of
individual(s) who
worked with
Disadvantaged
Businesses or
Disadvantaged
Communities to
establish track record
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
94
3/1/2021
U.S. Bancorp
Community
Development
Corporation
(USBCDC), New
Markets Tax
Credit Coalition,
NMTC Working
Group,
Enterprise
Community
Partners,
African
American
Alliance of CDFI
CEOs, Chicago
Community
Loan Fund,
National
Bankers
Association
Michigan
Community
Capital, OFN,
Forward
Community
Investments,
Cinnaire
Eric Hanna,
Mary Scott
Hardwick, Tracy
Hubbard, Peter
Giles
General
Review Process
Review
Process
Add a fee-related
question to the
Business Strategy for
Phase 1 review,
incorporate weighting
of fee-related
responses prior to final
ranking of applicants
for awards
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
28
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
95
3/1/2021
Michigan
Community
Capital, New
Markets Tax
Credit Coalition,
OFN, NMTC
Working Group,
Eric Hanna,
Robert Rapoza,
Mary Scott
Hardwick, Chris
Huang, Brad
Elphick
Business
Strategy
Question 17(c)
Application
96
3/1/2021
Michigan
Community
Capital, New
Markets Tax
Credit Coalition.
OFN,
Opportunity
Fund, NMTC
Working Group,
LISC, Craft3, SZ
Consulting,
National Trust
Community
Investment
Corporation,
Florida
Community
Loan Fund,
Blooming
Venture LLC
Eric Hanna,
Robert Rapoza,
Mary Scott
Hardwick, Chris
Huang, Brad
Elphick,
Matthew
Josephs, Maggie
Kirby Weiland,
Sean
Zielenbach,
Merrill
Hoopengardner,
Ignacio Esteban,
Elaine DiPietro
Business
Strategy
Question 18
Due Diligence
(New)
Application
Restore bullet to the
instructions: “The
Applicant’s strategy
for identifying
potential borrowers,
investees, or other
customers in LowIncome Communities”
Remove Question 18
and incorporate
forward-looking
question to Question
29(c ), Q29(a) or 28(b)
This comment would
not reduce burden in
completing the
NMTC Program
Application and is not
necessary for the
CDFI Fund's
evaluation.
The CDFI Fund
revised this question
based on public
comments.
29
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
97
2/23/2021
Michigan
Community
Capital, Forward
Community
Investments,
Cinnaire
Eric Hanna,
Tracy Hubbard,
Peter Giles
FAQ
FAQ #106
Guidance
Update FAQ #106 to
report required
donations by QALICB
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
98
2/23/2021
Michigan
Community
Capital, Forward
Community
Investments,
Cinnaire
Eric Hanna,
Tracy Hubbard,
Peter Giles
Management
Capacity
Question 34
Fees
Regulation
Require all applicants
charge upfront fees at
the sub-CDE or QALICB
instead of at the
Investment Fund level
99
3/1/2021
Blooming
Ventures LLC
Elaine DiPietro
General
Phase 1 Review
Review
Process
Move questions not
scored in Phase 1 to
later sections (i.e. Q19,
Q21, Q24, etc)
100
3/1/2021
Native CDFI
Network
Jackson Brossy
General
Native Initiative
Review
Process
Establish a NMTC
Native American
program
This comment is
related to IRS
regulations. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
30
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
101
3/1/2021
Native CDFI
Network
Jackson Brossy
General
Native Initiative
Regulation
Clearly state that a
tribal government can
own a QALICB
102
3/1/2021
Advantage
Capital
Jonathan
Goldstein
Glossary of
Terms
MinorityOwned or
Minoritycontrolled
Application
Add suggested text to
"for-profit" and "notfor-profit entity": 30%
ownership
103
3/1/2021
Community
Development
Bankers
Association
Jeannine
Jacokes
Management
Capacity
Question 29(c)
Application
Remove Question
29(c) which duplicates
Question 18
31
NMTC Response
raised in making
future policy
decisions.
This comment is
related to IRS
regulations. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
The CDFI Fund
revised this question
based on public
comments.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
104
3/1/2021
Community
Development
Bankers
Association
Jeannine
Jacokes
Management
Capacity
Question 29,
30, 31
Application
Remove requirement
to estimate
percentages of work to
be performed by
consultants, staff
and/or board member
The CDFI Fund is
maintaining the
current requirements
for this question,
which is necessary
for the application
evaluation.
105
3/1/2021
Community
Development
Bankers
Association
Jeannine
Jacokes
Community
Outcomes
Question 25(a)
Application
Support increasing
commitment to areas
of higher distress from
75% to 85%
The CDFI Fund is
retaining the
threshold of 85%, as
proposed.
106
3/1/2021
Native CDFI
Network
Jackson Brossy
General
Native Initiative
Review
Process
Provide same access to
allocations to groups
offering smaller loans
afforded to those
making larger loans
107
3/1/2021
Community
Development
Bankers
Association, SZ
Consulting
Jeannine
Jacokes, Sean
Zielenbach
Business
Strategy
Question 20(b)
and 21(c)
Application
Revise fourth bullet of
Q20(b) and 21(c) to
require discussion
experience of both
Applicant and
Controlling Entity in
serving DBCs
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
32
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
108
3/1/2021
Community
Development
Bankers
Association
Jeannine
Jacokes
General
Regulated
Entities
Guidance
Discuss NMTC
eligibility
considerations so
regulated banks and
credit unions can make
informed decision
about applying
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
109
3/1/2021
Community
Development
Bankers
Association,
NMTC Working
Group, Craft3,
SZ Consulting,
Jeannine
Jacokes, Brad
Elphick, Maggie
Kirby Weiland,
Sean
Zielenbach,
Community
Outcomes
Question
26(a)(2) and
26(a)(3)
Guidance
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
110
3/1/2021
Community
Development
Bankers
Association,
NMTC Working
Group, LISC,
Self-Help
Venture Fund,
Enterprise
Community
Partners,
Renaissance
Community
Loan Fund,
National Trust
Community
Jeannine
Jacokes, Brad
Elphick.
Matthew
Josephs,
Amanda Frazier
Wong, Chimeka
Gladney,
Kimberly
LaRosa, Merrill
Hoopengardner,
Elaine DiPetro
Post Award
Limit required
description of quality
and accessibility of
jobs to permanent
positions only,
description of
temporary positions
should be optional
Increase transparency
of post-award
feedback with details
of scores and
reviewers' comments,
the CDFI Fund's
priorities; prove exact
scores, score broken
down by section,
overall rankings,
number of priority
points earned, the
score cut-off, scores
given by each reviewer
to all applicants;
Customer
service
33
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Investment
Corporation,
Blooming
Ventures LLC
111
3/1/2021
112
3/1/2021
113
3/1/2021
Comment
NMTC Response
provide debriefings to
all applicants
Community
Development
Bankers
Association,
Michigan
Community
Capital, Craft3,
SZ Consulting
Community
Development
Bankers
Association,
Self-Help
Venture Fund,
SZ Consulting
Jeannine
Jacokes, Eric
Hanna, Maggie
Kirby Weiland,
Sean Zielenbach
Community
Outcomes
Question
26(a)(7)
Application
Expand question from
minority/Native to all
black, Indigenous, and
People of Color into a
single question
Jeannine
Jacokes,
Amanda Frazier
Wong, Sean
Zielenbach
General
Lower
Allocation
Amounts
Review
Process
Award allocations to
all CDEs that score in
the highest tier by
lowering allocation
awards
Community
Development
Bankers
Association,
Craft3, SZ
Consulting
Jeannine
Jacokes, Maggie
Kirby Weiland,
Sean Zielenbach
Business
Strategy
Question 17(c)
Application
Clarify question by
asking Applicants to
discuss its social
investment criteria,
provide guidance and
make sure there's
sufficient character
limits
34
The CDFI Fund will
use the definitions as
proposed and cited
to the Office of
Management and
Budget and the
Bureau of Indian
Affairs.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
The CDFI Fund
revised Question 12
based on public
comments.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
114
3/1/2021
Jeannine
Jacokes,
Matthew
Josephs, Sean
Zielenbach,
Elaine DiPietro
Business
Strategy
Question 20(b)
Application
Delete third bullet in
Q20(b), instead
request this
information by
narrowing focus of
Q14(b) or check back
in Table B1
The CDFI Fund
revised this question
based on public
comments.
115
3/1/2021
Community
Development
Bankers
Association,
LISC, SZ
Consulting,
Blooming
Ventures LLC
Community
Development
Bankers
Association, SZ
Consulting
Jeannine
Jacokes, Sean
Zielenbach
Information
Regarding
Previous
Awards
Question 44
Application
The CDFI Fund will
consider changes in
future application
rounds.
116
3/1/2021
Community
Development
Bankers
Association, SZ
Consulting,
Jeannine
Jacokes, Sean
Zielenbach
Community
Outcomes
Add new
question
Application
Adding table for
essential info:
description of projects,
its need for NMTCs,
size of allocation,
projects' impact to
date, QEI and QLICI
amounts, fees and
source of leverage
debt
Add question on an
Applicant's overall
community
development strategy
and how NMTC fit into
that plan.
35
The CDFI Fund
revised Question 12
based on public
comments.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
117
3/1/2021
Community
Development
Bankers
Association, SZ
Consulting,
Jeannine
Jacokes, Sean
Zielenbach
Community
Outcomes
Question
26(a)(2)
Application
Amend definition of
quality jobs to those
with a living wage and
employment benefits,
instead of current
definition of "and/or"
118
3/1/2021
Community
Development
Bankers
Association, SZ
Consulting,
Jeannine
Jacokes, Sean
Zielenbach
Business
Strategy
Review
Process
Edit the application
and review process to
focus on QALCB types
and characteristics,
instead of pipeline
projects
119
3/1/2021
Community
Development
Bankers
Association, SZ
Consulting,
Jeannine
Jacokes, Sean
Zielenbach
Business
Strategy
Application
Revise second bullet to
permit new Applicants
to discuss due
diligence for nonNMTC projects
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
The CDFI Fund
revised this question
based on public
comments.
Question 18
36
#
Date of
Comment
Organization
Author Name
Section
Category
120
3/1/2021
Community
Development
Bankers
Association, SZ
Consulting,
Craft3
Jeannine
Jacokes, Sean
Zielenbach,
Maggie Kirby
Weiland
General
121
3/1/2021
Community
Development
Bankers
Association,
Craft3
Jeannine
Jacokes. Maggie
Kirby Weiland
Community
Outcomes
Question
26(a)(3)
Application
122
3/1/2021
Corporation for
Supportive
Housing
Jill Steen
Community
Outcomes
Question
26(a)(8)
Housing
Application
Permit applicants to
discuss Low Income
Housing Tax Credits
financing housing
where NMTCs finance
the commercial
portion
123
3/1/2021
Advantage
Capital
Jonathan
Goldstein
Business
Strategy
General
Review
Process
Ensure reviews
emphasize track
record over pipeline
projects
37
Topic
Comment
NMTC Response
Customer
service
Recommend CDFI
Fund publish an
analysis of fees
currently being
charged for greater
transparency allowing
applicants to
benchmark themselves
Amend definition of
accessible jobs as
"and/or" instead of
current definition of
"and"
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
124
3/1/2021
Advantage
Capital
Jonathan
Goldstein
Business
Strategy
Question 19
Application
Restore question
about "how CDEs were
increasing volume of
investments, taking
more risk and pursuing
innovative strategies"
125
3/1/2021
Advantage
Capital
Jonathan
Goldstein
Business
Strategy
Question 19
Application
Add "use (or non-use)
of affiliate leverage" as
an innovative activity
126
3/1/2021
Community
Development
Bankers
Association,
Hope Enterprise
Corporation, SZ
Consulting
Jeannine
Jacokes, Kendra
Kay, Sean
Zielenbach
General
Caps on
allocation
awards
Review
Process
Institute a 3 yr
$150/200M cap for
any applicant
38
NMTC Response
evaluate the issues
raised in making
future policy
decisions.
This comment would
not reduce burden in
completing the
NMTC Program
Application and is not
necessary for the
CDFI Fund's
evaluation.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
127
3/1/2021
Advantage
Capital
Jonathan
Goldstein
General
CDE
Certification
Deadline
Review
Process
Have a fixed deadline
for CDE certification
Applications for new
CDE Applicants
128
2/24/2021
Kahlil Gross,
Sean
Zielenbach,
Jonathan
Goldstein,
Rodney
Cawston, Harry
Pickernell
Glossary of
Terms
Disadvantaged
Business
Application
Add "(c ) a Minorityowned or controlled
business or nonprofit"
to the definition of a
"Disadvantaged
Business"' add
veterans, ex-offenders,
or businesses located
in non-metro census
tracts
129
3/1/2021
City First Bank,
SZ Consulting,
Advantage
Capital,
Confederated
Tribes of the
Colville
Reservation,
Confederated
Tribes of the
Chehalis
Reservation
Advantage
Capital
The CDFI Fund has
decided to remove
this eligibility
requirement and
revert to the current
process of allowing
applicants
approximately two
weeks after the
publication of the
NOAA to apply for
CDE certification.
The CDFI Fund
revised this question
based on public
comments.
Jonathan
Goldstein
General
Phase 1 review
Review
Process
Use external reviewers
to determine
"qualified" and
"unqualified"
applicants instead of
using their review to
determine scoring rank
39
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
future policy
decisions.
130
3/1/2021
Hope Enterprise
Corporation
Kendra Key
General
MinorityOwned or
Minoritycontrolled
Review
Process
Conduct an in-depth
assessment of
application and scoring
to identify areas where
racial disparities may
be perpetuated
131
3/1/2021
Hope Enterprise
Corporation
Kendra Key
General
MinorityOwned or
Minoritycontrolled
Review
Process
Create incentives for
experienced CDEs to
work with new and/or
Minority-led CDEs to
gain experience
132
3/1/2021
Homeownership
Alliance
Kristin Siglin
Community
Outcomes
Question 26
Review
Process
Allow for
documentation of
broader impacts on
neighborhoods
40
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
The CDFI Fund added
a new Innovative
Activity in Q.19 based
on public comments.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
133
3/1/2021
Hope Enterprise
Corporation
Kendra Key
General
MinorityOwned or
Minoritycontrolled
Customer
service
Provide public data on
Minority-led CDE
certifications, awards,
and applicants
The CDFI Fund will
consider changes in
future application
rounds.
134
3/1/2021
Homeownership
Alliance
Kristin Siglin
General
Definition of
"affordable"
home sales
Guidance
Make sure NMTC
guidance stays attuned
to Qualified Mortgages
as FHA and CFPB's
policy evolves
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
135
3/1/2021
Homeownership
Alliance
Kristin Siglin
AMIS
Data
Reporting
and
Compliance
Provide a data point to
document final
corrected home
developed and sold to
low income people
This comment is
related to Allocatee
reporting/compliance
and will be
considered in the
future.
136
3/1/2021
Homeownership
Alliance
Kristin Siglin
AMIS
Data
Reporting
and
Compliance
Enable the user the
ability to change home
addresses
This comment is
related to Allocatee
reporting/compliance
and will be
considered in the
future.
41
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
137
3/1/2021
Homeownership
Alliance
Kristin Siglin
General
Rule when
QALICB don't
know or don't
control
Homebuyer's
debt to income
ratio
Reporting
and
Compliance
Lower requirements of
home sales price 95%
of HUD area median
sales price
This comment is
related to Allocatee
reporting/compliance
and will be
considered in the
future.
138
3/1/2021
Craft3
Maggie Kirby
Weiland
General
Application
materials
Application
Provide clear guidance
within application (or
separate document)
assuming the CDFI
Fund is proposing to
remove "tips" from
instructions
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
139
3/1/2021
Craft3
Maggie Kirby
Weiland
General
Question 24
Application
Support moving Q24
from Phase 1 to Phase
2 Review Process
The CDFI Fund
revised this question
based on public
comments.
140
3/1/2021
OFN
Mary Scott
Hardwick
General
Priority Points
Review
Process
Add priority points for
applicants
demonstrating
accountability to LICs
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
42
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
141
3/1/2021
OFN
Mary Scott
Hardwick
General
Certification
CDE
Certification
Require NMTC
Advisory Boards to
equitably represent
the communities that
CDEs serve
142
3/1/2021
OFN, Forward
Community
Investments
Mary Scott
Hardwick, Tracy
Hubbard
General
MinorityOwned or
Minoritycontrolled
Review
Process
Create permanent
ongoing TA with
annual funding for
training and TA grants
for new and emerging
minority-controlled
CDEs
143
3/1/2021
LISC
Matthew
Josephs
Capitalization
Strategy
Question 39
Application
Move Q39 Distribution
of Benefits from Part
IV to Part I; score a
CDE's ability to provide
majority of benefits in
Phase 1; revise
question so Applicants
disclose total benefits
they receive from
transactions
43
NMTC Response
future policy
decisions.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
144
3/1/2021
LISC
Matthew
Josephs
Capitalization
Strategy
Question 40
Application
Add a question where
CDE commits to a max
all-in fee, move Q40 to
Part III replacing Q34
145
3/1/2021
LISC, Chicago
Community
Loan Fund
Matthew
Josephs, Calvin
Holmes
Business
Strategy
Question 14
Application
146
3/1/2021
LISC, Chicago
Community
Loan Fund
Matthew
Josephs, Calvin
Holmes
Business
Strategy
Question 20
and 21
Review
Process
Add Yes/No subquestion if CDE
intends to provide a
debt product using a
leveraged structure, if
yes Applicants are only
required to describe
its rates and terms not
product
Bifurcate each
question's 5 priority
points into 3 for
Applicant's track
record, and 2 for
Controlling
Entity/parent company
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
The CDFI Fund is
maintaining the
current requirements
for this question,
which is necessary
for the application
44
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
147
3/1/2021
LISC, National
Trust
Community
Investment
Corporation
Matthew
Josephs, Merrill
Hoopengardner
Management
Capacity
Question 30(d),
30(e )
Application
Responses would not
be required for CDEs
with delinquency rate
less than 5% or total
write-off less than 3%
The CDFI Fund is
maintaining the
current requirements
for this question,
which is necessary
for the application
148
3/1/2021
LISC, National
Trust
Community
Investment
Corporation
Matthew
Josephs, Merrill
Hoopengardner
Management
Capacity,
Capitalization
Strategy
Question 29(a),
30(a), 30(c),
31(a), 31(b),
Q35, Q37
Application
Responses would not
be required for
"established" CDEs
with no significant
changes in personnel
or policy
The CDFI Fund is
maintaining the
current requirements
for this question,
which is necessary
for the application
149
3/1/2021
OFN, Forward
Community
Investments,
Cinnaire,
Michigan
Community
Capital
Mary Scott
Hardwick, Tracy
Hubbard, Peter
Giles, Eric
Hanna
General
Controlling
Entity
Review
Process
Add question to
discuss mission focus
of Controlling Entities
into Phase 1 review,
give preference to
mission-driven orgs
150
3/1/2021
LISC, National
Bankers
Association
Matthew
Josephs, Robert
James II
General
CDEs partnering
as Applicants
Review
Process
Allow new CDEs to
partner with
"established" CDEs by
hiring CDEs are service
providers, commit to
co-invest; allow new
CDEs to utilize their
partnering CDEs' track
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
45
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
record for priority
points
future policy
decisions.
151
3/1/2021
National Trust
Community
Investment
Corporation
Merrill
Hoopengardner
Community
Outcomes
Question 26
Guidance
Provide transparency
about how methods
and metrics are
evaluated
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
152
3/1/2021
National Trust
Community
Investment
Corporation
Merrill
Hoopengardner
Management
Capacity
Question 29(c)
Application
Increase character
limit from 2000 to
3000
153
3/1/2021
Kandiyo
Consulting;
Brownfield
Revitalization,
LLC; Scarlet Oak
Capital Impact;
(no affiliation);
Community
Development
Bankers
Association;
New Markets
Tax Credit
Coalition, OFN,
Michael Krause,
Bret Batchelder,
Rohit Kejriwal,
John Mazzarino,
Jeannine
Jacokes, Robert
Rapoza, Mary
Scott Hardwick,
Brad Elphick,
Amanda Frazier
Wong, Chimeka
Gladney,
Maggie Kirby
Weiland, Sean
Community
Outcomes
former
Question
25(a)(10)
Environmentally
Sustainable
Outcomes
Application
Restore
Environmentally
Sustainable Outcomes
in evaluating NMTC
projects and
applications; simplify
to focus on benefits
for LICs; add storm
water mgmt.
This comment would
not reduce burden in
completing the
NMTC Program
Application and is not
necessary for the
CDFI Fund's
evaluation.
Revised based on
public comments.
The CDFI Fund has
reverted to the
previous
Environmentally
Sustainable
Outcomes question
and will consider
additional guidance.
46
#
Date of
Comment
154
3/1/2021
155
3/1/2021
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
NMTC Working
Group, Self-Help
Venture Fund,
Enterprise
Community
Partners, Craft3,
SZ Consulting,
National Trust
Community
Investment
Corporation,
Maya CDE, Rose
Urban Green
Fund, Michigan
Community
Capital, MidCity Community
CDE, OFN,
Popular
Community
Development
Maya CDE. Rose
Urban Green
Fund,
Community
Development
Bankers
Association,
New , Popular
Community
Development
Markets Tax
Zielenbach,
Merrill
Hoopengardner
Moctesuma
Esparza,
Jonathan Rose,
Eric Hanna, Lois
Fried, Scott
Hardwick,
Natalia Guzman
Community
Outcomes
Question
26(a)(6)
Financing
Minority
Businesses
Guidance
The CDFI Fund
revised this question
based on public
comments.
Moctesuma
Esparza,
Jonathan Rose,
Jeannine
Jacokes, Robert
Rapoza, Mary
Scott Hardwick,
Anna Bovaird
Nevins, Maggie
Kirby Weiland,
Sean
Community
Outcomes
former
Question 27
"Additional
Investment"
Application
Add to guidance and
FAQ to include
investments into or
loans purchases from
Minority CDEs, and
number of minority
residents served or
employed, tenants
that are minorityowned or controlled
Restore question on
"Additional
Investment" with
extended track record
over 7 to 10 year
period, make the
question optional,
discuss examples but
not accept IMPLAN
estimates for this
question, or create
47
This comment would
not reduce burden in
completing the
NMTC Program
Application and is not
necessary for the
CDFI Fund's
evaluation.
#
156
Date of
Comment
3/1/2021
Organization
Author Name
Credit Coalition,
PIDC
Community
Capital, Craft3,
SZ Consulting,
Mid-City
Community
CDE, National
Trust
Community
Investment
Corporation
Maya CDE. Rose
Urban Green
Fund,
Community
Development
Bankers
Association,
New Markets
Tax Credit ,
Popular
Community
Development
Coalition, OFN,
LISC, PIDC
Community
Capital,
Enterprise
Community
Partners, MidCity Community
Zielenbach, Lois
Fried, Natalia
Guzman, Merrill
Hoopengardner
Moctesuma
Esparza,
Jonathan Rose,
Jeannine
Jacokes, Robert
Rapoza, Mary
Scott Hardwick,
Matthew
Josephs, Anna
Bovaird Nevins,
Chimeka
Gladney, Lois
Fried, Natalia
Guzman, Merrill
Hoopengardner,
Elaine DiPietro
Section
Category
Topic
Comment
NMTC Response
"Additional
Investment" outcome
in Q26(a)
Business
Strategy
Question 17(d)
48
Application
Eliminate this question
or add guidance or
FAQ question to clarify
an Applicant's
participation in multi
CDE transactions will
not affect their
likelihood of securing
an award
The CDFI Fund
revised this question
based on public
comments.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
Moctesuma
Esparza,
Jonathan Rose,
Lois Fried
FAQ
FAQ #53
Guidance
Clarify FAQ #53 to
eliminate the
restriction on
Applicants that receive
investment or loans
from other CDEs that
disallows Applicants
from applying for a
NMTC award; and the
restriction on
Applicants from
investing in, lending
to, or purchasing loans
from a CDE if that CDE
has received a NMTC
award in the last 3years.
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
CDE, National
Trust
Community
Investment
Corporation,
Blooming
Ventures LLC
157
3/1/2021
Maya CDE. Rose
Urban Green
Fund, Mid-City
Community CDE
49
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
158
3/1/2021
Maya CDE. Rose
Urban Green
Fund, Mid-City
Community
CDE, Popular
Community
Development
Moctesuma
Esparza,
Jonathan Rose,
Lois Fried,
Natalia Guzman
Community
Outcomes
new outcome
under Question
26(a) Womenowned or
controlled
businesses
Application
Add a new outcome
similar to "Financing
Minority Businesses"
for "Financing
Women-Owned or
Controlled Businesses"
159
3/1/2021
Maya CDE. Rose
Urban Green
Fund, Mid-City
Community
CDE, Popular
Community
Development
Moctesuma
Esparza,
Jonathan Rose,
Lois Fried,
Natalia Guzman
Business
Strategy
Question 20
and Exhibit B
Business
Strategy
Application
Add a standalone table
to capture Financial
Counseling and Other
Services (FCOS)
160
3/1/2021
Maya CDE. Rose
Urban Green
Fund, Mid-City
Community
CDE, Popular
Community
Capital, PNC
Bank
Moctesuma
Esparza,
Jonathan Rose,
Lois Fried,
Natalia
Guzman, David
Gibson
Business
Strategy
Question 19
Application
Update the Innovative
Investments question
to include as
innovative activities
investments, loans to,
or purchases of loans
from CDEs/Minorityowned CDEs/Nativeowned CDEs
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
The CDFI Fund added
a new Innovative
Activity in Q.19 based
on public comments.
50
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
161
3/1/2021
Moctesuma
Esparza,
Jonathan Rose,
Rohit Kejriwal,
Robert Rapoza,
Brad Elphick,
Anna Bovaird
Nevins,
Chimeka
Gladney, Lois
Fried, Natalia
Guzman, Merrill
Hoopengardner,
Ignacio Esteban
Community
Outcomes
former
Question
25(a)(8) Flexible
Lease Rates
Outcomes
Application
Restore question on
"Flexible Lease Rates";
expand outcome to
other flexible criteria
such as lower security
deposit, landlord paid
improvements, more
flexible lease terms,
etc
The CDFI Fund made
revisions to Question
26(a)(4) and
Question 26(a)(5) to
ensure lower rents to
tenant businesses
may be described
and evaluated with
other similar
outcomes.
162
3/1/2021
Maya CDE. Rose
Urban Green
Fund, Scarlet
Oak Capital
Impact, New
Markets Tax
Credit Coalition,
NMTC Working
Group, PIDC
Community
Capital,
Enterprise
Community
Partners, MidCity Community
CDE, National
Trust
Community
Investment
Corporation,
Florida
Community
Loan Fund
Maya CDE, Rose
Urban Green
Fund, U.S.
Bancorp
Community
Development
Corporation
(USBCDC),
Travois, NMTC
Moctesuma
Esparza,
Jonathan Rose,
Zachary Boyers,
Phil Glynn, Brad
Elphick,
Matthew
Josephs, Anna
Bovaird Nevins,
Glossary of
Terms
Disadvantaged
Business
Application
Restore “(c) a business
that has inadequate
access to investment
capital” to the
definition of a
"Disadvantaged
Business"
The CDFI Fund
revised this definition
based on public
comments.
51
#
Date of
Comment
Organization
Author Name
Working Group,
LISC, PIDC
Community
Capital,
Enterprise
Community
Partners, MidCity Community
CDE, Popular
Community
Development,
African
American
Alliance of CDFI
CEOs,
Advantage
Capital,
Confederated
Tribes of the
Colville
Reservation,
Confederated
Tribes of the
Chehalis
Reservation,
Chicago
Community
Loan Fund
Chimeka
Gladney, Lois
Fried, Natalia
Guzman, Donna
Gambrell,
Jonathan
Goldstein,
Rodney
Cawston, Harry
Pickernell,
Calvin Holmes
Section
Category
52
Topic
Comment
NMTC Response
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
163
3/1/2021
Maya CDE, MidCity Community
CDE, Popular
Community
Development
Moctesuma
Esparza, Lois
Fried, Natalia
Guzman
Business
Strategy
Section C Prior
Performance
Review
Process
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
164
2/16/2021
BrightBridge
Capital
Monica Blanton
AMIS
Data
Reporting
and
Compliance
165
2/16/2021
BrightBridge
Capital
Monica Blanton
AMIS
Data
Reporting
and
Compliance
Expand the first Note
in “Section C. Prior
Performance” to add
that during the
evaluation period
certain non-QLICI like
direct track
record in Table B4 is
evaluated and scored
the same as an
Applicant’s direct track
record of
investments included
in Table B1
If an SPE was set up for
NMTC structure
purposes and is
renting back to an
operating business,
should this be the SPE
date or operating
business date?
Report all project
impact, not just by
project type
53
This comment is
related to Allocatee
reporting/compliance
and will be
considered in the
future.
This comment is
related to Allocatee
reporting/compliance
and will be
considered in the
future.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
166
2/16/2021
BrightBridge
Capital
Monica Blanton
AMIS
Data
Reporting
and
Compliance
Eliminate loan loss
reserve data point
This comment is
related to Allocatee
reporting/compliance
and will be
considered in the
future.
167
2/16/2021
BrightBridge
Capital
Monica Blanton
AMIS
Data
Reporting
and
Compliance
Can AMIS auto fill
some geographic data
points (ie poverty rate,
unemployment, nonmetro, etc)?
This comment is
related to Allocatee
reporting/compliance
and will be
considered in the
future.
168
3/1/2021
National Trust
Community
Investment
Corporation
Merrill
Hoopengardner
General
Review
Process
Require all Applicants
to submit Part I and II,
only Applicants that
move onto Phase 2 will
submit the remainder
of the Application
The CDFI Fund is
maintaining the
current requirements
for this question,
which is necessary
for the application
evaluation.
169
2/16/2021
BrightBridge
Capital
Monica Blanton
CIMS4
Reporting
and
Compliance
Flag for specific
address must be
placed manually
This comment is
related to the CDFI
Fund mapping
system and will be
considered in the
future.
54
#
Date of
Comment
Organization
Author Name
Section
170
2/16/2021
BrightBridge
Capital
Monica Blanton
CIMS4
171
3/1/2021
Popular
Community
Development
Natalia Guzman
Community
Outcomes
172
2/22/2021
Travois,
Confederated
Tribes of the
Colville
Reservation,
Confederated
Tribes of the
Chehalis
Reservation
Phil Glynn,
Rodney
Cawston, Harry
Pickernell
173
2/22/2021
Travois, Alaska
Growth Capital,
Confederated
Tribes of the
Colville
Reservation,
Confederated
Tribes of the
Phil Glynn, Taka
Tsukada,
Rodney
Cawston, Harry
Pickernell
Category
Topic
Comment
NMTC Response
Reporting
and
Compliance
Not able to print the
distress or qualifying
characteristics of the
geocoded location
This comment is
related to the CDFI
Fund mapping
system and will be
considered in the
future.
Question
26(a)(6)
Financing
Minority
Businesses
Guidance
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
Business
Strategy
Question 20
Application
Expand guidance and
FAQ to encourage and
measure investments
benefiting majority
minority Low-Income
Communities and
impacts on minority
Low-Income People
Propose text edit to
3rd note of Q20:
"unless can clearly
demonstrate it
employs the same
process for sourcing
transactions, …"
Community
Outcomes
Question
26(a)(7)
Application
55
Support the addition
of "Financing Native
American Businesses"
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
The CDFI Fund
revised this question
based on public
comments.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
Chehalis
Reservation
174
2/16/2021
BrightBridge
Capital
Monica Blanton
General
FEMA
designation
lookback period
Reporting
and
Compliance
Extend FEMA
designation lookback
period to more than
24 months
175
3/1/2021
National
Bankers
Association
Robert James II
General
Application
Review
Process
Broaden review to
include impact of
capital reinvested,
provide points for
Applicants willing to
reinvest fee revenue
176
3/1/2021
National
Bankers
Association
Robert James II
Business
Strategy
General
Review
Process
Remove requirement
for Applicants to have
transactional
experience in a
particular type of
projects (ie. Healthy
food or healthcare)
56
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
177
3/1/2021
New Markets
Tax Credit
Coalition
Robert Rapoza
Glossary of
Terms
Disadvantaged
Business
Application
The CDFI Fund
revised this definition
based on public
comments.
178
3/1/2021
National
Bankers
Association
Robert James II
General
CDEs partnering
as Applicants
Review
Process
Revert to original
definition of
"Disadvantaged
Business", or modify
definition to proposed
text
Place limits on repeat
Allocatees that refuse
to partner with MDIs
or minority CDEs
179
3/1/2021
New Markets
Tax Credit
Coalition
Robert Rapoza
Business
Strategy
Question 17(c)
Application
Add character limits
from 8,000 to 10,000
180
3/1/2021
New Markets
Tax Credit
Coalition
Robert Rapoza
Business
Strategy
Question 17(c)
Application
Expand second bullet
to discuss how
pipeline projects fit
into the strategy and
goals
57
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
This comment would
not reduce burden in
completing the
NMTC Program
Application and is not
necessary for the
CDFI Fund's
evaluation.
The CDFI Fund
revised Question 12
based on public
comments.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
181
3/1/2021
New Markets
Tax Credit
Coalition
Robert Rapoza
Community
Outcomes
Third party
metrics
Guidance
Remove third-party
metrics requirement
for environmental
sustainability, healthy
foods, etc
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
182
3/1/2021
New Markets
Tax Credit
Coalition, NMTC
Working Group,
Robert Rapoza,
Brad Elphick
Business
Strategy
Question 20
and Exhibit B
Application
Focus question or limit
discussion of
Controlling Entity to a
discrete division for
applicants with large
Controlling Entities
The CDFI Fund is
maintaining the
current requirements
for this question,
which is necessary
for the application
evaluation.
183
3/1/2021
New Markets
Tax Credit
Coalition, NMTC
Working Group,
Robert Rapoza,
Brad Elphick
Management
Capacity
Question 34
Fees
Application
Clearly state fees
imposed after the
seven year compliance
period should also be
included
The CDFI Fund
revised this question
based on public
comments.
184
3/1/2021
New Markets
Tax Credit
Coalition, NMTC
Working Group,
Robert Rapoza,
Brad Elphick
Glossary of
Terms
Controlling
Entity
Guidance
Consider how to
grand-father in the
new definition with
existing allocatees who
met the old definition
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
58
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
185
3/1/2021
Robert Rapoza,
Brad Elphick,
Chimeka
Gladney, Calvin
Holmes
Business
Strategy
Question 18
Application
Remove second bullet
due to potential
burden and lack of
meaningful info,
incorporate into
Q29(c)
The CDFI Fund
revised this question
based on public
comments.
186
3/1/2021
Robert Rapoza,
Brad Elphick,
Donna
Gambrell, Calvin
Holmes
AMIS
Glossary of
Terms
IT
Enhancement
Add enhancement to
electronic application
so definition from
glossary of terms is
displayed when
Applicant hovers over
the term
The CDFI Fund will
consider additional
enhancements to
AMIS functionality in
future application
rounds.
187
3/1/2021
New Markets
Tax Credit
Coalition, NMTC
Working Group,
Enterprise
Community
Partners,
Chicago
Community
Loan Fund
New Markets
Tax Credit
Coalition, NMTC
Working Group,
African
American
Alliance of CDFI
CEOs, Chicago
Community
Loan Fund
New Markets
Tax Credit
Coalition
Robert Rapoza
General
NOAA
Customer
service
Give 90 days of
advance notice prior
to release of NOAA
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
59
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
188
3/1/2021
New Markets
Tax Credit
Coalition, NMTC
Working Group,
Blooming
Ventures
Robert Rapoza,
Brad Elphick,
Elaine DiPietro
Business
Strategy
Question 17(c)
Application
The CDFI Fund
revised this question
based on public
comments.
189
3/1/2021
Robert Rapoza,
Brad Elphick,
Eric Hanna,
Merrill
Hoopengardner
Community
Outcomes
Question
26(a)(8)
Housing
Guidance
190
3/1/2021
New Markets
Tax Credit
Coalition, NMTC
Working Group,
Michigan
Community
Capital, National
Trust
Community
Investment
Corporation
New Markets
Tax Credit
Coalition, NMTC
Working Group,
National Trust
Community
Investment
Corporation
Remove wording
"minimum and
maximum" dollar
amounts of
proposed NMTC
investments" or add
clarification to how
Applicants can provide
meaningful answer
Expand definition of
affordable units to
include workforce
housing or "nationally
occurring affordable
housing" at 80-100%
AMI
Robert Rapoza,
Brad Elphick,
Merrill
Hoopengardner
Glossary of
Terms
Controlling
Entity
Application
Clarify definition
whether sub-bullet A
or B, as well as C and D
are needed
The CDFI Fund
revised this definition
based on public
comments.
60
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
191
3/1/2021
New Markets
Tax Credit
Coalition, NMTC
Working Group,
National
Bankers
Association
Robert Rapoza,
Brad Elphick,
Robert James II
Glossary of
Terms
Enforcement
Action
Application
Amend definition to
"an formal action or
admin order"
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
192
3/1/2021
Robert Rapoza,
Brad Elphick,
Tracy Hubbard,
Eric Hanna,
Peter Giles
Management
Capacity
Question 34
Fees
Application
Clarify instructions on
whether fees are
contingent or
conditional
The CDFI Fund
revised this question
based on public
comments.
193
3/1/2021
New Markets
Tax Credit
Coalition, NMTC
Working Group,
Forward
Community
Investments,
Michigan
Community
Capital, Cinnaire
New Markets
Tax Credit
Coalition,
Opportunity
Fund, Enterprise
Community
Partners
Robert Rapoza,
Chris Huang,
Chimeka
Gladney
Community
Outcomes
Question 26
Guidance
Provide a list of
specific sources and
metrics for project
types and community
outcomes, provide
several detailed
examples for each
community outcome
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
61
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
194
3/1/2021
Robert Rapoza,
Chris Huang,
Matthew
Josephs, Calvin
Holmes
Community
Outcomes
Question 26
Application
Increase current 5000
character limit,
especially increase to
10,000 character limit
for Q26(a)(5)
community goods and
services
The CDFI Fund
revised this question
based on public
comments.
195
3/1/2021
New Markets
Tax Credit
Coalition,
Opportunity
Fund, LISC,
Chicago
Community
Loan Fund
New Markets
Tax Credit
Coalition,
Blooming
Ventures LLC
Robert Rapoza,
Elaine DiPietro
Management
Capacity
Question 33(e)
Application
Remove part E of Q33,
seems to duplicate
Q34(c)
The CDFI Fund is
maintaining the
current requirements
for this question,
which is necessary
for the application
evaluation.
196
3/1/2021
New Markets
Tax Credit
Coalition,
Michigan
Community
Capital,
Advantage
Capital
Robert Rapoza,
Eric Hanna,
Jonathan
Goldstein
Community
Outcomes
former
Question 27
"Additional
Investment"
Application
This comment would
not reduce burden in
completing the
NMTC Program
Application and is not
necessary for the
CDFI Fund's
evaluation.
197
3/1/2021
New Markets
Tax Credit
Coalition,
Florida
Community
Loan Fund
Robert Rapoza,
Ignacio Esteban
Business
Strategy
Question 24
Application
Increase character
limit of Q27(c ) and
Q27(d) from 3000 to
5000 to allow for more
context now missing
from removal of
question on
"Additional
Investment"
Suggest text edits and
clarification for related
notes
62
The CDFI Fund
revised this question
based on public
comments.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
198
3/1/2021
New Markets
Tax Credit
Coalition,
Florida
Community
Loan Fund
Robert Rapoza,
Ignacio Esteban
Community
Outcomes
Question 26
Guidance
Consider how
applicants might
better describe multicomponent projects
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
199
3/1/2021
New Markets
Tax Credit
Coalition,
Ignacio Esteban
Robert Rapoza,
Ignacio Esteban
Management
Capacity
Question 34(b)
Application
Suggest text edits and
clarification for first
bullet
The CDFI Fund
revised this question
based on public
comments.
200
3/1/2021
New Markets
Tax Credit
Coalition,
Corporation for
Supportive
Housing,
National Trust
Community
Investment
Corporation,
Florida
Community
Loan Fund
Robert Rapoza,
Jill Steen,
Merrill
Hoopengardner,
Ignacio Esteban
Community
Outcomes
Question 26
Application
Add "other" to as a
new community
outcomes category
This comment would
not reduce burden in
completing the
NMTC Program
Application and is not
necessary for the
CDFI Fund's
evaluation.
63
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
201
3/1/2021
New Markets
Tax Credit
Coalition, Craft3
Robert Rapoza,
Maggie Kirby
Weiland
Business
Strategy
Question 20(b)
Application
Clarify meaning and
intent of Q20(b) 3rd
bullet, seems to
overlap with Section 4
Raising Capital
The CDFI Fund
revised this question
based on public
comments.
202
3/1/2021
New Markets
Tax Credit
Coalition, OFN,
NMTC Working
Group
Robert Rapoza,
Mary Scott
Hardwick, Brad
Elphick
Community
Outcomes
Former
Question
26(a)(14)
Application
Restore question for
Healthy Food
Financing; add food
bank and pantries to
examples
203
3/1/2021
New Markets
Tax Credit
Coalition, OFN,
NMTC Working
Group, Forward
Community
Investments,
Cinnaire
Robert Rapoza,
Mary Scott
Hardwick, Brad
Elphick, Tracy
Hubbard, Peter
Giles
Management
Capacity
Question 34
Fees
Guidance
Add instructions to
clarify how Applicants
will use exit fees
and/or all or part of
equity redeployed in
LICs
The CDFI Fund made
revisions to Question
26(a)(4) and
Question 26(a)(5) to
ensure Healthy Food
Financing activities
may be described
and evaluated with
other similar
outcomes.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
64
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
204
3/1/2021
New Markets
Tax Credit
Coalition,
National Trust
Community
Investment
Corporation
Robert Rapoza,
Merrill
Hoopengardner
Business
Strategy
Question 19
Application
Add an open-ended
"Other Innovative
Uses" option
205
3/1/2021
Rodney
Cawston, Harry
Pickernell
Glossary of
Terms
Disadvantaged
Business
Application
Include "a nonprofit
with a board that is
comprised of 51% of
more of Low-Income
Persons" under part B
"Owned by a LowIncome Person"
206
2/24/2021
Confederated
Tribes of the
Colville
Reservation,
Confederated
Tribes of the
Chehalis
Reservation
SZ Consulting
This comment would
not reduce burden in
completing the
NMTC Program
Application and is not
necessary for the
CDFI Fund's
evaluation.
The CDFI Fund
revised this definition
based on public
comments.
Sean Zielenbach
General
Review Process
Review
Process
Change scoring
weights of Phase 1 and
2 to align more closely
with CDFI Fund's policy
priorities
65
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
207
2/24/2021
SZ Consulting
Sean Zielenbach
Business
Strategy
Question 21 or
22(e)
Review
Process
Permit applicants to
discuss relevant
activity occurring more
than five years ago
208
3/1/2021
New Markets
Tax Credit
Coalition, NMTC
Working Group,
Blooming
Ventures
Robert Rapoza,
Brad Elphick,
Elaine DiPietro
General
Customer
service
Merge NOAA,
Application and FAQs
into one application
document. Incorporate
FAQs into application
as notes
The CDFI Fund is
maintaining the
current requirements
for this question,
which is necessary
for the application
evaluation.
The CDFI Fund will
consider changes in
future application
rounds.
209
2/24/2021
SZ Consulting
Sean Zielenbach
Exhibits
Table A5
Guidance
Add 3 short narratives
similar to CMF: 1) brief
description,
2)importance of
project/business, 3)
why it needs NMTC
financing
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
210
2/24/2021
SZ Consulting
Sean Zielenbach
Business
Strategy
Question 17(d)
Application
Propose refocusing
question on whether
Applicant intends to
co-invest, in what
situations, and
whether it has certain
CDE partners in mind
The CDFI Fund
revised this question
based on public
comments.
66
#
Date of
Comment
Organization
Author Name
Section
Category
Topic
Comment
NMTC Response
211
2/24/2021
SZ Consulting
Sean Zielenbach
Glossary of
Terms
Disadvantaged
Business
Application
Add "owned or
controlled" in addition
to "owned"
212
3/1/2021
Alaska Grown
Capital
Taka Tsukada
Community
Outcomes
Question
26(a)(4)
Guidance
Add "broadband
internet,
environmental
infrastructure and
utilities" as examples
of commercial goods
and services
The CDFI Fund
revised this definition
based on public
comments.
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
213
3/1/2021
Forward
Community
Investments,
Cinnarie
Tracy Hubbard,
Peter Giles
Community
Outcomes
Question
26(a)(5)
Community
Goods and
Services
Guidance
214
3/1/2021
U.S. Bancorp
Community
Development
Corporation
(USBCDC), New
Markets Tax
Credit Coalition
Zachary Boyers,
Robert Rapoza
Community
Outcomes
Question 26
Application
Update instructions
and guidance for
applicants who invest
in diverse variety of
non-profit sponsored
community facilities
discussing track record
and third-party metrics
Expand instructions or
add question to allow
indirect community
outcomes resulting
from loans or
investments from
Exhibit A and B
67
The CDFI Fund will
consider providing
additional guidance
based on this
comment in future
NMTC application
rounds.
This comment is not
related to burden in
completing the
NMTC Program
Application. The CDFI
Fund will continue to
evaluate the issues
raised in making
future policy
decisions.
| File Type | application/pdf |
| Author | Leung, Karen |
| File Modified | 2021-05-10 |
| File Created | 2021-05-10 |