The purpose of the Community
Development Financial Institutions (CDFI) Bond Guarantee Program
(BG Program) is to support CDFI lending by providing Guarantees for
Bonds issued by Qualified Issuers as part of a Bond Issue for
Eligible Community or Economic Development Purposes.
Per the Final Interim Rule that
governs the CDFI BG Program, 12 C.F.R 1808.307(b), the BG Program
is responsible for the review and outcome analysis on the current
and proposed use of Bond Proceeds in underserved communities. The
increase in burden associated with this revision to the CDFI BG
Program information collections can primarily be attributed to the
addition of one collection to enhance the BG Program’s ability to
evaluate the use of Bond Proceeds. This additional collection is
the Tertiary Loan Monitoring Report. This additional information
collection increases the burden by 300 hours and the total
estimated annualized costs by $13,932.00. Additionally, the burden
has increase by 297 hours due to better estimates on the number of
respondents for the various compliance reports. The BP Program also
made revisions to the applications to enhance clarity and the
ability to more accurately assess applicants. The changes in the
Qualified Issuer Application include requests to have applicants
submit internal controls and policies and the most recent four
years of audited financial statements and management letters. The
changes in the Guarantee Application include requests to: submit
the application conflict of interest policies; the number and
average size of loans pledged as collateral to meet an
overcollateralization requirement; the proposed net interest margin
between the Bond Loan and the Secondary Loan interest rates; the
certification of any Affiliates of a Controlling CDFI entity;
explanation of how the Affiliate’s assets would be commingled in a
bankruptcy estate; permission from other Federal Credit programs if
a credit enhancement will be used from another Federal Credit
program; four years of audited financial statements; and management
letters for the Eligible CDFI and the third-party credit
enhancement entity. The total requested hours increases to 9,873
and the estimated annualized cost for all current and proposed
information collections under this OMB Control Number will be
$683,859.00.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.
Tertiary Loan Monitoring Report
1559-0044 - CDFI Bond Guarantee Program SS_FINAL.docx
Tertiary Loan Monitoring Report