Response to Public Comments

Performance Progress Report and Financial Statement Audit Report Public Comment Table_221227.xlsx

Annual Compliance Reports

Response to Public Comments

OMB: 1559-0050

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Date of Comment Author Name Author Position Organization File Name Category Comment OCME Office Response
11/25/2022 Community Development Bankers Association
Credit Union National Association (CUNA);
Inclusiv; and
The CDFI Coalition
Representing CDFI Fund Stakeholders Community Development Bankers Association
Credit Union National Association (CUNA);
Inclusiv; and
The CDFI Coalition
221125 _Inclusiv Burden Recommended Uses of Award and Performance Progress Report be combined into a single grant compliance summary report that details how CDFIs used their awards and shows their progress toward performance goals. Unable to accommodate request at this time. Comment will be addressed when the CDFI Fund completes work with data contractor to determine feasibility.
11/25/2022 Community Development Bankers Association
Credit Union National Association (CUNA);
Inclusiv; and
The CDFI Coalition
Representing CDFI Fund Stakeholders Community Development Bankers Association
Credit Union National Association (CUNA);
Inclusiv; and
The CDFI Coalition
221125_Inclusiv Burden Recommended all reports including the Financial Statement Audit Report, align deadlines with the Transaction Level Report due date, 180 days after fiscal year end, to ensure CDFIs have all the data needed to report their performance accurately across all forms. The current reporting deadlines do not allow sufficient time for a full review of the previous year’s lending data and can result in CDFIs filing Performance Progress Reports that are not consistent with their Transaction Level Reports. Unable to accommodate request at this time. Comment will be addressed when the CDFI Fund completes work with data contractor to determine feasibility.
11/22/2022 Sones & White Consulting LLC Members Sones & White Consulting LLC 221122-Sones&WhiteConsulting LLC Burden Recommended automatic close out of an award if a
submitted PPR shows that awardee meets its final benchmark early and all other
compliance reports are submitted in that year. This would cut down the compliance reporting
burden for the next year for both the awardee and the CDFI Fund as they review all submitted
reports.
This is already an option for CDFI Fund Recipients. They just need to request that the award be closed out early.
11/22/2022 Sones & White Consulting LLC Members Sones & White Consulting LLC 221122-Sones&WhiteConsulting LLC Burden Recommendation to waive the Financial Statement Audit Report requirement for regulated institutions since A-133 Audits and Financial Statement Audits are not required by the assistance agreements for banks and bank holding companies. The CDFI Fund requires Financial Statement Audit Reports submissions from all Award Recipients in accordance with their Assistance Agreements. Regulated entitles may indicate submission of financial data to their Regulator during submission of Financial Statement Audit Report.
11/22/2022 Sones & White Consulting LLC Members Sones & White Consulting LLC 221122_Sones White Consulting LLC Compliment Expressed their overall compliments re: the Uses of Award Report. N/A
11/22/2022 Sones & White Consulting LLC Members Sones & White Consulting LLC 221122_Sones White Consulting LLC Compliment They believe the form has practical and appropriate utility. N/A
11/22/2022 Sones & White Consulting LLC Members Sones & White Consulting LLC 221122_Sones White Consulting LLC Compliment They believe the form is not too burdensome to prepare and submit. N/A
























































































































































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