2 Qualified Issuer Application

F Y 2021 A P P L I C AT I O N

TM

E N T o f t he

TR

EA

U. S
.

AR
EP

RY
SU

Q UA L I F I E D
ISSUER
A P P L I C AT I O N

D

CDFI BOND GUAR ANTEE PROGR AM

ni

WWW.CDFIFUND.GOV/BOND

De

io
n

mu

sF
un

d

Com
ty

vel
op m

ent Fina

In
n cial

sti

tu

t

Introduction

Under the CDFI Bond Guarantee Program, an entity that wishes to be designated by the CDFI
Fund as a Qualified Issuer must submit a Qualified Issuer Application.
The Applicant must provide all required information in its Qualified Issuer Application to
establish that it meets all criteria for designation as a Qualified Issuer and can carry out all
Qualified Issuer responsibilities and requirements. Such responsibilities and requirements
include, but are not limited to, information that demonstrates that the Applicant has the
appropriate expertise, capacity, and experience and is qualified to make, administer and service
Bond Loans for Eligible Purposes. After receipt of a Qualified Issuer Application, the CDFI Fund
may request additional, clarifying, confirming or supplemental information on the materials
submitted as part of the Qualified Issuer Application. In order to be considered for the issuance
of a Guarantee in fiscal year (FY) 2021, Qualified Issuer Applications must be submitted through
the CDFI Fund’s Award Management Information System (AMIS) by 11:59 p.m. EST on April 26,
2021. Please be aware that Information Technology (IT) support will end at 5:00 p.m. EST that
day.
Please note: the Applicant must currently meet the criteria established in the regulations that
govern the program, set forth at 12 C.F.R. 1808 (the Regulations) to be deemed a Qualified
Issuer. Applications that are forward-looking or speculate as to the eventual acquisition of the
required capabilities and criteria are unlikely to be approved.
In order to understand the CDFI Bond Guarantee Program and the roles and responsibilities of
the Qualified Issuer, interested parties should review and become familiar with the Regulations.
In addition, Applicants should review and become familiar with the Notice of Guarantee
Availability (NOGA), published with respect to FY 2021 Qualified Issuer Applications and
Guarantee Applications. The Regulations and the NOGA are found on the CDFI Fund’s website.
Capitalized terms in the Qualified Issuer Application are defined in the Regulations.
For purposes of the Qualified Issuer Application, the term “Applicant” refers to the applicant
organization as well as any Affiliates and third-party entities (i.e., the proposed Program
Administrator and the proposed Servicer) that seek to participate in performing the duties of the
Qualified Issuer during the term of a Bond.

Applications will be submitted via the the CDFI Fund’s Awards Management Information System
(AMIS). This document provides the format, document organization, naming conventions, and
description of requested documentation for the Applicant to be submitted as part of the Qualified
Issuer Application. The Qualified Issuer Application must follow the standardized naming
convention for individual files as well as the file organization detailed below. In addition, certain
information must be provided with respect to at least one Certified CDFI, which must attest that
it has designated the Applicant to serve as Qualified Issuer on its behalf.
Under the Paperwork Reduction Act (44 U.S.C. chapter 35), an agency may not conduct or
sponsor a collection of information, and an individual is not required to respond to a collection of
information, unless it displays a valid Office of Management and Budget (OMB) control number.
Pursuant to the Paperwork Reduction Act, the Qualified Issuer Application has been assigned
the following control number: 1559-0044.

Application Requirements
Page 1

To be deemed complete, the Qualified Issuer Application must include information for each of
the sections 1 through 8 as set forth below. The Applicant must provide a narrative addressing
the requirements of Sections 3 using the guidelines provided in this document, as well as
additional supporting documentation as is necessary or appropriate. Please note that the
requirements of the narrative portion of the application are in addition to any supporting
documentation or separate requirements of the Qualified Issuer Application. Detailed
instructions for uploading additional evidence or attachments for each section of the Qualified
Issuer Application are described below.

Document Format

Documentation should be submitted in Microsoft Word, unprotected Microsoft Excel, Adobe PDF,
or other mediums as appropriate. Narratives must be submitted in Microsoft Word format in singlespaced, 12 point Arial or Times New Roman font. Please follow the file naming conventions
and descriptions listed in this document.

Missing or Not Applicable Documentation

If a specific document is not applicable or otherwise not available, the Applicant must submit a
placeholder file stating that the requested document is “Not Applicable,” “Not Performed,” or
“None” in place of the file, as appropriate. The Applicant must also include a brief description
of why such document is not applicable, not performed, or not available. The placeholder
file must retain the naming convention of the respective file it was meant to replace. A document
must be submitted for each item on the checklist. See Figure 1 for an example.

Figure 1: Sample Documentation Stating Not Applicable

Document Organization and Submission

All Qualified Issuer Applications must be submitted via the CDFI Fund’s Awards Management
Information System (AMIS), and all documents must be uploaded according to the file structure
specified in each section. An organization applying to become a Qualified Issuer must create an
Page 2

AMIS account, register, and assign at least one (1) user. As AMIS is the CDFI Fund’s primary
means of communication with applicants with regard to its programs, each such entity must make
sure that it updates the contact information in its AMIS account before any Application is
submitted. For more information on AMIS, please visit the AMIS Landing Page at
https://amis.cdfifund.gov/. Once completed, the Applicant can login to its account and choose
“Qualified Issuer Application” from the list of possible applications.
Carefully follow the instructions found on AMIS, as contained in the ‘User Guide for Applications
to the CDFI Bond Guarantee Program (For External Users)’ published along with this Application
document, and upload the application documents following the naming conventions and
descriptions listed below. Applications shall be submitted via AMIS, and all documents must be
uploaded according to the specified file structure.

Figure 2: Screenshot of AMIS File Upload Interface
(Qualified Issuer Application)

NOTE: AMIS cannot accept files larger than 25 megabytes. If any file is larger than 25MB,
please adjust the file size and upload multiple documents to fulfill the requested document
requirement (multiple files may be submitted at the same time for each file requirement).
Page 3

The Qualified Issuer Application process is completed by reading the Attestation located on the
AMIS system regarding the accuracy of the information being submitted, and submitting an
electronic “Signature Page.” After submitting the Signature Page, the Applicant will not be able
to make any edits to the application materials unless granted express permission and requested
to do so by the CDFI Fund. Once the Signature Page has been submitted, the Applicant should
print a copy of the Submission Status Page, which will include a Control Number, and retain this
for its records. The Authorized Representative or Application Point of Contact will receive email
correspondence from the system regarding the application status.
The Control Number follows the format ##-BQI-#####.
Applicants who require assistance or have any questions, should call (202)-653-0421 and select
Option 5, or email [email protected]

Page 4

Qualified Issuer Application Checklist
Section Document
QI-1

Checklist

QI-2

Organizational Documents
A. SF-424 (with Certifications and Assurances) signed
by Qualified Issuer applicant
B. SF-424 (with Certifications and Assurances) signed
by proposed Program Administrator, if third-party
C. SF-424 (with Certifications and Assurances) signed
by proposed Servicer, if third-party
D. SF-424 (with Certifications and Assurances) signed
by Certified CDFI(s), as applicable
E. Notice designating Qualified Issuer signed by
Certified CDFI, if applicable
F. EIN/TIN letter from IRS, as applicable
G. Articles of Incorporation
H. By-Laws
I. Licenses
J. Errors and omissions insurance certificate
Narrative Discussion

QI-3

A.
B.
C.
D.
E.
F.
QI-4

Format
PDF

PDF (All)

Word
(All)

Organization Capability – Bond Issuance
A.
B.
C.
D.
E.

QI-5

Organization Capability – Qualified Issuer
Organization Capability- Program Administrator
Organization Capability- Servicer
Strategic Alignment
Management and Staffing
Financial Strength

Included

Servicer’s most recent SSAE16 or similar review
Independent reports
Information Technology systems documentation
Internal controls and policies
Credit, Underwriting, and Servicing Policies

PDF (All)

Strategic Alignment
A. Strategic or Operational Plan
B. Conflicts of Interest policies
C. Ethics policies

PDF (All)

Page 5

Section Document
QI-6
Management and Staffing
A. Overall Organizational Structure (Entities
Affiliates)
B. Organizational Chart (Positions)
C. Management or operating agreement
D. Resumes of Key Management and Personnel
E. Staffing Data
QI-7

Included
and

PDF
PDF
PDF
PDF
Excel

Financial Strength
A. Identification of Appropriate Federal Banking Agency
or Appropriate State Agency
B. Three (3) year history of financing transactions
C. Three (3) year history of earned revenues
D. Current loan covenants and three (3) year history of
compliance with covenants
E. Portfolio Quality Report
F. Three (3) year history of Off-Balance Sheet Activities
G. Four (4) years of audited financial statements and
management letters
H. Most recent interim financial statements
I. Current Year’s Approved Budget or Projected Budget
if the Board has not yet approved it (Unregulated
Institutions)
J. Three (3) year financial projections (Unregulated
Institutions)

QI-8

Format

Excel
Excel
Excel
Excel
Excel
Excel
PDF
PDF
PDF
Excel

Cash Flows and Pricing Structure
A. Sample Bond Issue cash flow model
B. Sample Proposed Sources and Uses of Funds
C. Pricing Structure

Excel
(All)

Page 6

Documentation Checklist Contents

The following sections provide descriptions and naming conventions for the requested
documentation for the Qualified Issuer Application. Please note that, to provide consistency
among all Qualified Issuer Applications, each item has a specific naming convention that must be
followed.
QI-1: Checklist
Item
QI-1: Checklist

Discussion
The Applicant must submit the Qualified
Issuer (QI) Application Checklist as part
of the application materials via AMIS.
Print out the preceding two (2) pages,
scan, and submit.

QI-2: Organizational Documents
Item

Description

A. QI Contact
Information

This may consist of only a single
scanned copy of the Standard Form 424
(SF-424) with the following sections filled
out:
•
•
•
•
•
•
•
•
•

Format
PDF

Naming Convention
QI-1-Checklist

Format

Naming
Convention
QI-2A-QI SF-424

PDF,
SF-424

Applicant legal name
Employer/Taxpayer Identification
Number (EIN/TIN)
DUNS number
Mailing address, including 9-digit
zip code
Contact name, email address,
and telephone number
Contact position/title
Authorized Representative name,
email address, and telephone
number
Authorized Representative
position/title
Signature

The entity must initial the Federal
Assurances and Certifications for the SF424.

B. Program
Administrator
Contact
Information

If the role of Program Administrator is PDF,
being performed by an entity other than SF-424
the applicant to be a Qualified Issuer, a
SF-424 and associated documents must
be provided for each entity

QI-2B-PA SF-424

Page 7

Item

Description

Format

C. Servicer
Contact
Information

If the role of Servicer is being performed
by an entity other than the applicant to be
a Qualified Issuer, a SF-424 and
associated documents must be provided
for each entity.

PDF,
SF-424

Naming
Convention
QI-2C-Servicer SF424

D. Certified
CDFI Contact
Information

A SF-424 and associated documents
must be provided for at least one
Certified CDFI that is designating the
applicant to be a Qualified Issuer on its
behalf, if applicable.

PDF,
SF-424

QI-2D-CDFI SF424

E. Notice
Designating
Qualified Issuer

A notice by at least one Certified CDFI
designating the Qualified Issuer to issue
Bonds on its behalf, if applicable. Note:
this designation is akin to a
“nomination” and is not binding.

PDF,
Example
Format
provided
by CDFI
Fund

QI-2E-Designation

F. EIN/TIN

Provide a copy of the proof of EIN/TIN
from the IRS.

PDF

QI-2F-IRS Letter

G. Articles of
Incorporation

Provide a copy of the Qualified Issuer’s
Articles of Incorporation.

PDF

QI-2G-Articles

H. By-Laws

Provide a copy of the Qualified Issuer’s
by-laws.

PDF

QI-2H-ByLaws

I. Licenses

A document identifying licenses required
by the Appropriate Federal Banking
Agency or Appropriate State Agency that
govern the Applicant, if applicable.

PDF

QI-2I-Licenses

J. Errors and
omissions
(E&O)
insurance
certificate of
coverage

A document displaying the certificate of
coverage for Errors and Omissions
insurance.

PDF

QI-2J-Insurance

Page 8

QI-3: Narrative Discussion
Item

Description

3A- Qualified
Issuer
Organizational
Capacity for
Bond Issuance

Describe the Applicant’s capabilities to
serve as a Qualified Issuer and its ability
to deploy bond Proceeds and Bond Loan
proceeds. This description of capabilities
must demonstrate that the Applicants
has the appropriate expertise, capacity,
and experience to originate, underwrite,
service, and administer loan portfolios
that serve Eligible Purposes and are
targeted toward Low-Income Areas and
Underserved Rural Areas.

Format
Word

Naming
Convention
QI-3
Narrative

The character limit for this topic is 15,000
characters.
3B-Program
Administrator
Organizational
Capability

Provide information to demonstrate the
respective capability, expertise and
experience of the entity serving in the
role of the Program Administrator.
Applicants should specifically address
the proposed Program Administrator’s
management and organization, loan
servicing, and financial capability.
Applicants should also specifically
address the duties of the Program
Administrator as enumerated in
1808.606(b) of the Regulations.

Word

QI-3Narrative

Word

QI-3Narrative

The character limit for this topic is 15,000
characters.
3C- Servicer
Organizational
Capability

Provide information to demonstrate the
respective capability, expertise and
experience of the entity serving in the
role of the Servicer. Applicants should
specifically address the proposed
Servicer’s management and
organization, loan servicing, and financial
capability. Applicants should also
specifically address the duties of the
Servicer as enumerated in 1808.606(c)
of the Regulations.
The character limit for this topic is 15,000
characters.

Page 9

Item

Description

3D- Strategic
Alignment
Narrative

Summarize the Applicant’s overall
strategy, experience with the CDFI
Industry, and alignment with the CDFI
Bond Guarantee Program’s goals. How
does the Bond Guarantee Program fit
into the Applicant’s overall strategy?

Format
Word

Naming
Convention
QI-3Narrative

The character limit for this topic is 12,000
characters.
3EManagement
and Staffing
Narrative

Describe the Applicant’s overall
management, staffing history, and
projected needs with regards to fulfilling
the roles of the Qualified Issuer, Program
Administrator, and Servicer functions.
Provide relevant information for any thirdparty entities that will carry out these
activities.

Word

QI-3Narrative

Word

QI-3Narrative

The character limit for this topics is
12,000 characters.
3F- Financial
Strength
Narrative

Provide information that demonstrates
the Applicant’s financial strength,
stability, and capacity to fulfill the roles of
the Qualified Issuer, Program
Administrator, and Servicer functions. If
any third-party entities will carry out
these activities, please provide the
relevant financial information for each
organization.
The character limit for this topics is
12,000 characters.

QI-4: Organizational Capacity for Bond Issuance
Item

Discussion

Format

A. Most recent
Statements on
Standards for
Attestation
Engagements
16 (SSAE 16),
and, if available,
any third party
rating history

A copy of the most recent Statements on
Standards for Attestation Engagements
16 (SSAE 16) for the Servicer. Include, if
available, any third party rating reports
relevant to servicing.

PDF

Naming
Convention
QI-4A-SSAE16

Page 10

Item

Discussion

Format

B. Independent
Reports

If a third-party is proposed to perform the
role of the Program Administrator or
Servicer, provide the most independent
report of the third-party organization.
Each report should have a separate file.
Documentation describing the IT system
environment of the Applicant, in relation
to program administration, servicing, and
monitoring. Include any backup or
disaster plans, as well as any written
documents relating to information
technology policies and procedures.
Include comparable documentation for
third-party Servicers or Program
Administrators, if any.
Documentation of internal controls as
well as procedures for documenting
management decisions, and retention of
documents relating to loan servicing and
administration. Include comparable
documentation for third-party Servicers
or Program Administrators, if any.
Documentation of credit, underwriting,
and servicing policies and procedures.
Include comparable documentation for
third-party Servicers or Program
Administrators, if any.

PDF

C. IT
Environment
documentation

D. Internal
Control and
Policies

E. Credit,
Underwriting,
and Servicing
Policies

Naming
Convention
QI-4B-Report Name
where “Report
Name” is the title of
the report.

PDF

QI-4C-IT
Environment

PDF

QI-4D-Controls and
Documentation

PDF

QI-4E-Policies and
Procedures

Page 11

QI-5: Strategic Alignment
Item
Description
A. Strategic or
Provide a copy of the Applicant’s
Operational
strategic, business, or operational
Plan
plan.

Format
PDF

Naming Convention
QI-5A-Strategic Plan

B. Conflicts of
Interest

A document identifying any actual
or potential conflicts of interest an
Applicant would have in
performing as a Qualified Issuer.
As applicable, include the
interests of the Applicant’s parent,
subsidiary, and affiliate
companies. The Applicant must
also describe the specific steps it
would take to avoid, mitigate, or
neutralize any such conflicts.

PDF

QI-5B-COI

C. Ethics
Policies

A document identifying the
Applicant’s ethics and compliance
policies including any procedures,
training materials, and audit
practices designed to detect and
prevent violations of Federal and
state laws and conflicts of
interest. If the Applicant has a risk
or compliance officer, provide a
description of the person’s
responsibilities and an
assessment of whether the
person operates independently
from the Applicant’s decisionmakers who manage the Bond
Issues.

PDF

QI-5C-Ethics

QI-6: Management and Staffing
Item
Description
A.
Provide a scanned copy of the
Organizational
Applicant’s network of affiliates or
Structure Guide subsidiaries which indicates the
relationship between the entities (i.e.,
ownership, control, etc.). Include a
similar file for the third-party Servicer
or Program Administrator, if any.

Format
PDF

Naming Convention
QI-6A-Organizational
Structure

Page 12

Item
B.
Organizational
Chart

C. Management
or Operating
Agreement

D. Resumes of
Key
Management
and Personnel

Description
Provide a scanned copy of the
management hierarchy down to
individual or manager level, as
appropriate to the Applicant. Both
individual names and titles should be
indicated as well as any vacancies.
Include the management hierarchy of
third party Servicers, or Program
Administrators, if any.
If the Qualified Issuer is managed by
a separate organization, a scanned
copy of the signed Management
Agreement should be included. If
there is only a letter of intent, provide
a scanned copy of the letter. If not
appropriate, then place “None” in
place of the file name in the Table of
Contents.

Format
PDF

Naming Convention
QI-6b-Org Chart

PDF

QI-6C-Management
Agreement

Resumes, job descriptions, and
hire/ascension data down to the
manager or senior level, as
appropriate.

PDF

QI-6D-Resumes

Excel

QI-6E-Staffing Data

Include the above for third-party
Servicers and Program
Administrators, if applicable.
E. Staffing Data

Provide an excel table indicating key
statistics for the Applicant, such as
retention, average tenure, and other
relevant factors. For the managers
identified in the section above,
indicate whether the individuals have
any outside employment or serve on
other board memberships. Include
contingencies, key man insurance,
and any succession planning data as
appropriate.

Page 13

QI-7: Financial Strength
Item
Description

Format

Naming
Convention
QI-7A-Regulator

A. Appropriate
Federal
Banking
Agency or
Appropriate
State Agency

List any Appropriate Federal Banking
Agency or Appropriate State Agency which
oversees the operations of the Applicant.
Please indicate the identifying number by
which the organization’s call report or similar
financial data can be retrieved from its
regulator.

Excel

B. Financing
Transactions

Provide sufficient instances of transactions
for the most recent three (3) years indicating
whether the Applicant is a financing entity for
transactions with a cumulative value of $100
million. Include the type and dollar value of
transactions.

Excel

QI-7BTransactions

C. Earned
Revenues

List the sources, dollar value, and
percentage of the applicant’s earned
revenues for the past three (3) years.

Excel

QI-7C-Revenues

D. Lenders’
Covenants
Compliance
Report

A listing of all financial and operating
performance covenants with lenders
showing an indication of actual versus
prescribed levels for the past three (3) years.
Any violations of covenants should be
accompanied by a discussion of remediation
actions and waivers if provided.

Excel

QI-7D-Covenant
Compliance

E. Portfolio
Quality Report

Provide summary statistics about the
organization’s portfolio quality for the past
three (3) years. List all loans approved
during this time period that have exceeded
30 days past due, are an exception to
underwriting standards, or have been subject
to a special servicing action. Identify any
loans that have been purchased from
another lender or acquired from a subsidiary
during this time period.

Excel

QI-7E-Portfolio
Quality

F. Off-Balance
Sheet
Contingencies

Provide a report for the past three (3) years
showing all off-balance sheet contingencies.
For current contingencies, include the
amount and an estimate of the chances for
the contingency resulting in a formal liability.

Excel

QI-7FContingencies

Page 14

Item

Description

Format

G. Most Recent
Four (4) Years
Audited
Financial
Statements and
Management
Letters

The four (4) most recent financial audits
should be submitted as separate files. Note,
the financial statements should be prepared
by an independent accounting firm and in
accordance with generally accepted
accounting principles. Also note that each
year should be scanned separately and the
notes to the audits for each year and
management letters should be included. If
appropriate, the statement should show
consolidating schedules as an attachment or
supplemental information.

PDF

Naming
Convention
QI-7GYYYYMMDD
Audit” where the
YYYY is the fourdigit year of the
statement, the MM
is the two-digit
month and the DD
is the two-digit
day. For example:
“QI-7G-20191231
Audit”

If a newer audited financial statement
becomes available during the application
review period, the Qualified Issuer must
notify the CDFI Fund in a timely manner and
provide the updated information.
Provide comparable financial statements for
third-party Servicers and Program
Administrators, if any.
H. Most Recent
Interim
Financial
Statements

Provide the most recent interim financial
statement, whether audited or internally
prepared.

PDF

QI-7: Financial Strength (Unregulated Organizations Only)
Item
Description
Format
I. Current
The approved budget for the current fiscal PDF
Fiscal Year’s
year should be submitted, if applicable.
Approved
The budget should contain a comparison
Budget
of current results (i.e.variance report) to
that budget and any approved
modifications to the budget. If a budget
has not yet been approved by the Board of
Directors, provide reasonable estimates
and the basis for such estimates.

QI-7H-Interim
FinancialYYYYMMDD. For
example: “QI-7HInterim Financial20200930”

Naming Convention
QI-7I-Budget

Page 15

Item
J. Financial
Projections

Description
Provide three (3) years of forward looking
estimates for the Applicant’s statement of
financial position and activities. Indicate all
major assumptions underlying the
projections.

Format
Excel

QI-8: Cash Flows and Pricing Structure
Item
Description
A. Sample
Bond Issue
cash flow model

The Applicant should provide a working cash
flow model of a sample Bond Issue if the
Applicant is not submitting this Qualified
Issuer Application concurrently with a
Guarantee Application. If submitted
concurrently with a Guarantee Application,
please include a copy of the actual cash flow
model.

Format
Excel

Naming Convention
QI-7J-Projections

Naming
Convention
QI-8A-Sample
Cash Flow

The cash flow model should track the flow of
funds through the Qualified Issuer and
Eligible CDFIs and through the term of the
sample Bond Issue. This financial model
should include disbursement and
repayments for Bonds, Bond Loans, and
Secondary Loans, as well as associated
interest, fees, and other costs. The cash flow
model should also demonstrate an
understanding of the mechanics of the
Relending Fund, if utilized.
The cash flow should reflect expected
upfront and ongoing costs and revenues
associated with Qualified Issuer activities
under the CDFI Bond Guarantee Program.
B. Sample
Proposed
Sources and
Uses of Funds

If this Qualified Issuer Application is not
submitted concurrently with a Guarantee
Application, the Applicant should provide a
consolidated chart that details the specific
uses and timing of disbursement of a sample
Bond Issue.

Excel,
QI-8B-Sample
Example Sources and
Template Uses
provided
by CDFI
Fund

Page 16

Item

Description

Format

C. Pricing
Structure for
Bond Issuance,
Servicing, and
Program
Administration

Provide a table describing the level of effort
and pricing related to the all-in costs of
submitting a Guarantee Application, Bond
issuance, servicing, and program
administration. The Applicant should
represent the Bond Issuance Fees as a
percentage (in basis points) of the aggregate
principal amount of the Bond Issue and the
costs for servicing and program
administration in terms of basis point
additions to the interest rate of a Bond Issue.

Excel

Naming
Convention
QI-8C-Issuance
Costs

All fees shall be paid for by Eligible CDFIs
participating in the Bond Guarantee
Program, and in no instance shall program
participants have recourse to the CDFI Fund
for any debts or liabilities arising from their
participation. Although the pricing structure
and fees shall be decided by negotiation
between market participants, the CDFI Fund
will review a potential Qualified Issuer’s
pricing structure for soundness with proper
implementation of the CDFI Bond Guarantee
Program.

Page 17