NMTC Program Allocation Application (Business & Non-Profit)

New Markets Tax Credit (NMTC) Program Application

1559-0016 NMTC Allocation Application Template CY24

NMTC Program Allocation Application (Business & Non-Profit)

OMB: 1559-0016

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NMTC Allocation Application Template for Public Comment – July 2024

NEW MARKETS TAX CREDIT ALLOCATION
APPLICATION TEMPLATE
The Community Development Institutions Fund (CDFI Fund) is publishing this New Markets Tax Credit
(NMTC) Allocation Application Template (Application Template) in conjunction with the Notice for Public
Comment on proposed and/or continuing information collection, as required by the Paperwork Reduction
Act (PRA) of 1995, 44 U.S.C. 3506(c)(2)(A). This Application Template is provided for the purposes of
soliciting comments on the appropriateness of the information collected in the Application. The NMTC
Allocation Application is an online form submitted through the CDFI Fund’s Awards Management
Information System (AMIS).
The NMTC Program was established by Congress in 2000 to spur new or increased investments into
operating businesses and real estate projects located in Low-Income Communities. The NMTC Program
attracts investment capital to Low-Income Communities by permitting individual and corporate investors to
receive a tax credit against their federal income tax return in exchange for making equity investments in
specialized financial institutions called Community Development Entities (CDEs). The credit totals 39% of
the original investment amount and is claimed over a period of seven years (five percent for each of the
first three years, and six percent for each of the remaining four years). The investment in the CDE cannot
be redeemed before the end of the seven-year period.
New or substantially revised questions compared with the Calendar Year 2023 NMTC Allocation
Application are highlighted in yellow to indicate substantial changes.

NMTC Allocation Application Template for Public Comment – July 2024

TABLE OF CONTENTS
Applicant Instructions .................................................................................................................. ii
NMTC Application Registration ................................................................................................... vi
Application Materials.................................................................................................................. 1
Assurances and Certifications ..................................................................................................... 2
Part I: Business Strategy ............................................................................................................28
Part II: Community Outcomes ....................................................................................................52
Part III: Management Capacity ...................................................................................................63
Part IV: Capitalization strategy ...................................................................................................80
Exhibit A: Projected Activities ....................................................................................................94
Exhibit B: Track Record of Activities ......................................................................................... 101
Exhibit C: Staff and Board Qualifications .................................................................................. 107
Exhibit D: Asset Management / Income & Operating Expenses ................................................ 110
Exhibit E: Investor Strategy ...................................................................................................... 117
Glossary of Terms .................................................................................................................... 118
Appendix A: Attestation and Submission .................................................................................. 129
Appendix B: Controlling Entity Certification ............................................................................. 130

NMTC Allocation Application Template for Public Comment – July 2024

APPLICANT INSTRUCTIONS
•

Read the relevant New Markets Tax Credit (NMTC) Program publications prior to completing the
Allocation Application. For information on the calendar year (CY) 2024 NMTC Program allocation
round (this Round), read the Notice of Allocation Availability (NOAA) and the Community
Development Financial Institutions Fund’s (the CDFI Fund’s) document titled “NMTC Allocation
Application Frequently Asked Questions” (FAQ). For tax related information on the NMTC Program,
read the final regulations issued by the Internal Revenue Service (26 CFR 1.45D-1) and related
guidance. For information on Community Development Entity (CDE) certification, read the CDFI
Fund’s document titled “CDE Certification Q&A Document.” All of these documents are available on
the CDFI Fund’s website at www.cdfifund.gov. The CDFI Fund’s Q&A Document is periodically
updated, so continue to check the website on a regular basis.

•

Consult the Glossary of Terms when completing the Allocation Application. All terms and phrases that
are in Capitalized Italics in the Allocation Application are defined in the Glossary of Terms. The
Glossary of Terms is no longer included in the electronic application. Capitalized terms and phrases
that are not italicized are the titles of documents on the CDFI Fund’s website, pick-list options in the
electronic application, or titles of sections of this Allocation Application.

•

A Subsidiary CDE cannot submit an Allocation Application.

•

The CDFI Fund will only consider an Allocation Application as eligible for an NMTC Allocation in this
round if the Applicant is certified as a CDE as of the Federal Register publication date of the NOAA.

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

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

•

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

•

As the Applicant prepares the Allocation Application, assume that the CDFI Fund’s Allocation
Application reviewers are learning about the organization for the first time, even if the organization
ii

NMTC Allocation Application Template for Public Comment – July 2024

has previously submitted an application to the CDFI Fund under this or any of the other CDFI Fund
programs.
•

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

•

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

•

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

•

The CDFI Fund updated the title and format of this document so that it is consistent in appearance
with the applications used by other CDFI Fund administered programs. This document includes all of
the same content from the previous version of the Allocation Application only now it’s in tabular form.
This includes the Allocation Application questions as well as the guidance, instructions and notes for
Applicants to use when completing the electronic Allocation Application in the Awards Management
Information System (AMIS).

•

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

•

All Applicants must complete and save all responses to the Application Registration section of
the NMTC Allocation Application in AMIS by 5 pm ET on the Application Registration deadline
specified in the NOAA in order to submit the remaining sections of the Allocation Application.
To complete the Application Registration, Applicants must provide a response to each question in this
section, select “Yes” to lock its responses, and press the save button. AMIS will not allow additional
edits to the Application Registration once it has been completed and saved. Once the Application
Registration deadline passes, AMIS will not allow the creation of any new CY 2024 NMTC Allocation
iii

NMTC Allocation Application Template for Public Comment – July 2024

Applications. Additionally, Applicants will not be permitted to submit CY 2024 NMTC Allocation
Applications if the Application Registration section of those Applications remains incomplete and
unsaved after the Application Registration deadline. Please see the CY 2024 NMTC Program
Allocation Application Frequently Asked Questions document and the CY 2024 NMTC Program AMIS
Navigation Guide (Section 6.2) for more details on completing the Application Registration section.
•

Required Investor Letters (if applicable): Applicants completing Table E1 are required to submit
Commitment letters or letters of interest from investors per the NOTE for Exhibit E. Please upload
these documents electronically through the Applicant’s AMIS account. In doing so, an Applicant is
also validating the following information: name of investor, dollar amount of equity sought or obtained
(or dollar amount of debt, in the case of an investor partnership using debt capital), status of the
investment request (e.g., funds received, Commitment of funds, Letter of Interest/Intent). For
examples of acceptable documentation for the required information, refer to the CDFI Fund’s NMTC
Allocation Application FAQ Document. Applicants that do not complete Table E1 should not submit
investor letters.

•

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

•

Part V - Information Regarding Previous Awards: All Applicants are required to complete Part V of the
Allocation Application. Applicants that have not received previous NMTC Allocations or that have not
received other CDFI Fund Awards (i.e., FA-TA, CMF, BEA will simply need to respond Yes” to
Questions 42 and 43 and respond “No” to Question 45. Applicants that have not made QEIs into
previous Allocatees or assumed Control of previous Allocatees should respond “No” to Question 45
Please note that Part V is not scored as part of the Phase I review process, and is only considered if
the Applicant is ranked highly enough to proceed to Phase II of the Application review process.

•

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

•

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

NMTC Allocation Application Template for Public Comment – July 2024

NOTE: If you have programmatic or technology-related questions about the Allocation Application,
you may contact the CDFI Fund by submitting an AMIS service request. In the Service Request form,
select “NMTC Program” as the Program. Use of AMIS Service Requests is the best method to submit
and track your request. Additionally, you can call (202) 653-0422 or e-mail [email protected] for
information technology assistance.
The CDFI Fund will provide programmatic and information technology support related to the
Allocation Application Monday through Friday between 9:00 am and 5:00 pm, Eastern Time until
through the last day to contact the CDFI Fund which is specified in Table 1 of the NOAA. The CDFI
Fund will not respond to service requests, phone calls or e-mails concerning an Allocation
Application submitted during the final two business days before the Application Deadline until
after the Allocation Application submission deadline specified in Table 1 of the NOAA.

NMTC Allocation Application Template for Public Comment – July 2024

NMTC APPLICATION REGISTRATION
All Applicants must complete and save all responses to the Application Registration section of the NMTC Allocation Application in AMIS by 5 pm ET on the
Application Registration deadline specified in the NOAA in order to submit the remaining sections of the Allocation Application.
To complete the Application Registration, Applicants must provide a response to each question in this section, select “Yes” to lock its responses, and press the save
button. AMIS will not allow additional edits to the Application Registration once it has been completed and saved. Once the Application Registration deadline passes,
AMIS will not allow the creation of any new CY 2024 NMTC Allocation Applications. Additionally, Applicants will not be permitted to submit CY 2024 NMTC Allocation
Applications if the Application Registration section of those Applications remains incomplete and unsaved after the Application Registration deadline. Please see the
CY 2024 NMTC Program Allocation Application Frequently Asked Questions document and the CY 2024 NMTC Program AMIS Navigation Guide (Section 6.2) for
more details on completing the Application Registration section.
Section
Applicant 1
Information

Question
1(a) Applicant Name

1(b) Applicant Employer
Identification Number
1(c)

Is the Applicant a domestic
corporation or partnership
for federal tax purposes?

1(d) Applicant’s date of
incorporation or formation
(month/day/year)

Response

Question Notes

Field Type

Applicant Name
displays

This field is prepopulated from the Organization profile and
locked. To make any changes, please update the
Organization profile in AMIS.

Prepopulated

Applicant Employer
Identification Number
displays

This field is prepopulated from the Organization profile and
locked. To make any changes, please update the
Organization profile in AMIS.

Prepopulated

☐ Domestic
Corporation

If the Applicant is not a domestic corporation or partnership for
federal tax purposes, it is not eligible to apply for an NMTC
Allocation.

Dropdown
Menu

This field is prepopulated from the Organization profile and
locked. To make any changes, please update the
Organization profile in AMIS.

Prepopulated

☐ Domestic
Partnership
Applicants date of
incorporation or
formation displays

1(e) Applicant’s fiscal year end
(month/day)

In this Applicant Information section, the term Applicant shall only apply to the entity applying for a NMTC Allocation, and not to Subsidiary entities that may receive a transfer of
all or part of a NMTC Allocation.
vi

NMTC Allocation Application Template for Public Comment – July 2024

Section

Controlling
Entity
Information

Question

Response

Question Notes

Field Type

Fiscal Year End Month

Applicant’s Fiscal Year
End Month displays

This field is prepopulated from the Organization profile and
locked. To make any changes, please update the
Organization profile in AMIS.

Prepopulated

Fiscal Year End Day

Applicant’s Fiscal Year
End Day displays

This field is prepopulated from the Organization profile and
locked. To make any changes, please update the
Organization profile in AMIS.

Prepopulated

☐ Yes

Dropdown
Menu

2(a) Would the Applicant like to
designate a Controlling
Entity?

☐ No

Applicants may use this Controlling Entity to assist in
demonstrating an organizational track record and in
completing the related exhibits. An Applicant may identify the
parent organization or the company of its parent (i.e.,
“grandparent”) as its Controlling Entity to demonstrate an
organizational track record, provided that the relationship
between the “grandparent” and the Applicant conforms to the
CDFI Fund’s definition of a Controlling Entity.
Should the Applicant receive an NMTC Allocation in this
Round, the designated Controlling Entity will need to continue
in that capacity throughout the term of the Allocation
Agreement and for any future Allocation Agreements with the
CDFI Fund, should the Applicant apply and receive an
allocation in a future round. Any Applicant that receives an
NMTC Allocation in this Round must designate the same
Controlling Entity as designated in this Allocation Application
in any Allocation Applications for future rounds.
Applicants that received an NMTC Allocation in the CY 2013
round or later rounds are expected to maintain the Controlling
Entity stated in their Allocation Agreement in Question 3(a).
Please see the Application FAQ for further guidance and
information.

vii

NMTC Allocation Application Template for Public Comment – July 2024

Section

Question

Response

Question Notes

Field Type

The Controlling Entity Representative is required to affirm,
through submission of a Signature Page, that it is indeed the
Controlling Entity of the Applicant and supports the Applicant’s
Allocation Application.
2(b) Controlling Entity Name:

Text Entry

Text box
Maximum
Response
Length: 100
characters

2(c) Controlling Entity Employer
Identification Number:

Applicant
Mailing
Information

Text Entry

Text box
Maximum
Response
Length: 10
characters

3(a) Applicant Mailing Address
Address

Applicant’s Address
displays

City

Applicant’s City
displays

This field is prepopulated from the Organization profile and
locked. To make any changes, please update the
Organization profile in AMIS.

Prepopulated

State

Applicant’s State
displays

This field is prepopulated from the Organization profile and
locked. To make any changes, please update the
Organization profile in AMIS.

Prepopulated

Nine-Digit Zip Code

Applicant’s Nine-Digit
Zip Code displays

This field is prepopulated from the Organization profile and
locked. To make any changes, please update the
Organization profile in AMIS.

Prepopulated

viii

NMTC Allocation Application Template for Public Comment – July 2024

Section
Applicant
Shipping
Information

Question

Response

Question Notes

Field Type

3(b) Applicant Shipping Address

Prepopulated

This field is prepopulated from the Organization profile and
locked. To make any changes, please update the
Organization profile in AMIS.

Prepopulated

Address

Applicant’s Address
displays

City

Applicant’s City
displays

This field is prepopulated from the Organization profile and
locked. To make any changes, please update the
Organization profile in AMIS.

Prepopulated

State

Applicant’s State
displays

This field is prepopulated from the Organization profile and
locked. To make any changes, please update the
Organization profile in AMIS.

Prepopulated

Nine-Digit Zip Code

Applicant’s Nine-Digit
Zip Code displays

This field is prepopulated from the Organization profile and
locked. To make any changes, please update the
Organization profile in AMIS.

Prepopulated

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

Applicant
Contact
Information

Should the Applicant be selected to receive an NMTC
Allocation, the CDFI Fund reserves the right to publish the
Applicant’s response to select questions in the Applicant
Information and Business Strategy sections, including Public
Contact Person information provided in this question.
4(a) Applicant Authorized
Representative Information
Designate an Authorized
Representative for this
Application

Text Entry

Only the AMIS user designated as the Authorized
Representative in Question 5(a) will be eligible to sign the
Allocation Application.

Search
Records

NMTC Allocation Application Template for Public Comment – July 2024

Section

Question

Response

Question Notes

Field Type

AMIS record displays
the following fields:

Once Authorized Representative is identified, the AMIS record
for that person will appear.

AMIS record
displays

Text Entry

The Application Contact Person is the individual that the CDFI
Fund may contact—jointly with the Authorized
Representative—during the course of the Allocation
Application review with questions or requests for additional
information regarding the Allocation Application. It is strongly
recommended that the Application Contact Person listed is
someone other than the Applicant Authorized Representative.

Search
Records

AMIS record displays
the following fields:

Once Authorized Representative is identified, the AMIS record
for that person will appear.

AMIS record
displays

1.
2.
3.
4.

Title
Mailing Street
Mailing City
Mailing
State/Province
5. Mailing Zip/Postal
Code
6. Business Phone
7. Email

4(b) Application Contact Person
Information

1.
2.
3.
4.

Title
Mailing Street
Mailing City
Mailing
State/Province
5. Mailing Zip/Postal
Code
6. Business Phone
7. Email

NMTC Allocation Application Template for Public Comment – July 2024

Section
CDE
Certification
Information:

Prior CDFI
Award
Information

Question

Response

Question Notes

Field Type

5(a) Is the Applicant certified as
a CDE by the CDFI Fund as
of the Federal Register
publication date of the
NOAA?

☐ Yes

The CDFI Fund will only consider an Allocation Application as
eligible for an NMTC Allocation in this round if the Applicant is
certified as a CDE as of the Federal Register publication date
of the NOAA.

Dropdown
Menu

5(b) By the stated deadline in
the NOAA, is the Applicant
filing a service area
amendment in connection
with this application?

☐ Yes

☐ No

☐ Yes

Is the prior CDFI Award
information complete?

☐ No

Dropdown
Menu

Please review your prior awardee data table (Question 42) for
accuracy. Select "Yes" when you have confirmed that the data
in this table is accurate.

Dropdown
Menu

If you have not received a prior award from the CDFI Fund,
select “Yes”.
7.

Is the prior NMTC Allocation
information complete?

☐ Yes

☐ No

Please review your prior awardee data table (Question 43) for
accuracy. Select “Yes” when you have confirmed that the data
in this table is accurate.

Dropdown
Menu

If you have not received a prior award from the CDFI Fund,
select "Yes".
Application
Registration
Submission

Select “Yes - I want to Lock and
Save my Application Registration”
in the field below to lock and save
your NMTC Application
Registration responses.

Yes - I want to Lock
and Save my
Application
Registration

Yes - I want to Lock and Save my
Application Registration

Check Box

You must complete all the fields in this section, select “Yes - I
want to Lock and Save my Application Registration” in the field
below, and click the “Save” button to successfully submit your
NMTC Application Registration.

Dropdown
Menu

Check Box

NMTC Allocation Application Template for Public Comment – July 2024

APPLICATION MATERIALS
In this section of the electronic NMTC Application in AMIS a link has been provided to the NMTC Apply
page of the CDFI Fund’s website. Applicants should use this link to access the CY 2024 Application
materials. Applicants are required to confirm in AMIS that they have reviewed the Application Materials in
order to submit the electronic NMTC Application in AMIS.

Application Materials
1. CY 2024 Notice of Allocation Authority
2. CY 2024 NMTC Application
3. CY 2024 Electronic Application Instructions
4. CY 2024 Application FAQs
Question
Confirmation
of
Application
Materials

Question Text

Response

Question Notes

Field Type

Has the Applicant read
the application materials
that provide guidance in
completing the NMTC
Application?

☐ Yes

The Applicant must read
the Application Materials
and confirm with a ‘Yes’
before starting the NMTC
Application.

Dropdown
Menu

☐ No

NMTC Allocation Application Template for Public Comment – July 2024

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

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

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

•

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

Please select “True,” “False,” or “Not Applicable” to each certification. By selecting “True” the Applicant is
certifying that the corresponding statement is true. By selecting “False” the Applicant is certifying that the
corresponding statement is not true. By selecting “Not Applicable” the Applicant is certifying that the
corresponding statement is not applicable to its Application.
Instructions: Where the Applicant is unable to answer “True” to one or more of the statements in items
10 through 17 of the General Certifications, the Applicant must submit a written explanation with this
Allocation Application that clearly identifies the item number(s) and corresponding statement(s) it is
unable to certify. The written explanation should also identify the applicable specific entity and/or
individual by name. If the Applicant submits a written statement in response to items 12(c), 12(e), 13(c),
14(c) or 15(c), it should identify and summarize the litigation or regulatory matters typically disclosed in
the applicable entity’s annual SEC filings for 2020, 2021, 2022 and quarterly for 2023.
As the Authorized Representative of the Applicant, I hereby assure and certify that:
1.

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

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

False______

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

NMTC Allocation Application Template for Public Comment – July 2024

the Applicant to act in connection with this Allocation Application and to provide such additional
information as may be required.
True______
4.

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

False______

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

False______

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

False______

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

False______

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

False______

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

False______
3

NMTC Allocation Application Template for Public Comment – July 2024

10.

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

False______

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

11.

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

Applicant
Controlling Entity
Affiliate

True
_______
_______
_______

False
_______
_______
_______

Not Applicable
_______

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

12.

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

False______

Not Applicable______

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

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

False______

Not Applicable______

NMTC Allocation Application Template for Public Comment – July 2024

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

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

False______

Not Applicable______

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

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

False______

Not Applicable______

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

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

False______

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

NMTC Allocation Application Template for Public Comment – July 2024

13.

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

False______

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

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

False______

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

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

False______

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

14.

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

NMTC Allocation Application Template for Public Comment – July 2024

Officers
Directors
Majority Owners
Key Employees

True
_____
_____
_____
_____

False
_____
_____
_____
_____

N/A

_____

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

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

Officers
Directors
Majority Owners
Key Employees

True
_____
_____
_____
_____

False
_____
_____
_____
_____

N/A

_____

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

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

Officers
Directors
Majority Owners
Key Employees

True
_____
_____
_____
_____

False
_____
_____
_____
_____

N/A

_____

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

NMTC Allocation Application Template for Public Comment – July 2024

15.

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

False______

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

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

False______

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

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

False______

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

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

False______

NMTC Allocation Application Template for Public Comment – July 2024

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

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

True______
True______

False______
False______

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

16.

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

Officers
Directors
Majority Owners
Key Employees

True
_____
_____
_____
_____

False
_____
_____
_____
_____

N/A

_____

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

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

Officers
Directors
Majority Owners
Key Employees

True
_____
_____
_____
_____

False
_____
_____
_____
_____

N/A

_____

NMTC Allocation Application Template for Public Comment – July 2024

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

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

Officers
Directors
Majority Owners
Key Employees

False
_____
_____
_____
_____

N/A

_____

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

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

Officers
Directors
Majority Owners
Key Employees

False
_____
_____
_____
_____

N/A

_____

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

17.

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

False______

NMTC Allocation Application Template for Public Comment – July 2024

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

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

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

•

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

•

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

•

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

•

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

•

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

•

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

•

Except for transactions authorized under paragraph 4 above, if a participant in a covered transaction
knowingly enters into a lower tier covered transaction with a person who is proposed for debarment
under 48 CFR part 9, subpart 9.4, suspended, debarred, ineligible, or voluntarily excluded from

NMTC Allocation Application Template for Public Comment – July 2024

participation in this transaction, in addition to other remedies available to the Federal Government,
the CDFI Fund may terminate, in its sole discretion, the Allocation Agreement for cause or default.

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

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

•

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

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

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

True______
True______

False______
False______

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

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

True______
True______

False______
False______

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

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

True______
True______

False______
False______

NMTC Allocation Application Template for Public Comment – July 2024

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

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

True______
True______

False______
False______

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

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

True______
True______

False______
False______

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

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

NMTC Allocation Application Template for Public Comment – July 2024

Supplemental Certification
Applicants unable to select “True” for a statement(s) in General Certifications 10 through 17 and
statement(s) one through four in the Certification Regarding Debarment, Suspension, and Other
Responsibility Matters — Primary Covered Transactions must “Agree” to the statement below before
submitting their Allocation Application.
The Applicant hereby certifies based upon reasonable information and after due inquiry, there are no
matters previously disclosed by the Applicant in the CY 2024 New Markets Tax Credit (NMTC) Program
Application and Written Explanation; any other litigation or Enforcement Actions currently in effect with
regard to the Applicant, its Affiliates, its Controlling Entity, or any of its managed Subsidiary CDEs; or any
ongoing obligations or restrictions resulting from any litigation or Enforcement Actions with regard to the
Applicant, its Affiliates, its Controlling Entity, or any of its managed Subsidiary CDEs; that will have a
material adverse effect on the Applicant, its financial condition or ability to carry out the authorized uses of
a CY 2024 NMTC Program allocation, should the Applicant be successful in the CY 2024 round.
Instructions: The Supplemental Certification is not applicable for Applicants that selected “True” for
each statement in the Assurances and Certifications related to this NMTC Allocation Application.

Section
Supplemental
Certification

Question

Response

Question Notes

Did the
Applicant
respond with a
‘False’ to any
statements in
Question 10
through 17?

☐ Yes

This field is prepopulated from the
Dropdown
Organization profile and locked. To
Menu
make any changes, please update the
Organization profile in AMIS.

☐ No

Field Type

NMTC Allocation Application Template for Public Comment – July 2024

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

Question

Question Text

Response

Question Notes

Field Type

1. Applicant
NMTC
Allocation
Request

Total dollar amount of NMTC
Allocation requested in this
Allocation Application:

$_____

2. Applicant 2
Information

(a) Applicant Name:

Applicant Name
displays

This field is prepopulated from the Organization profile and
locked. To make any changes, please update the
Organization profile in AMIS.

Prepopulated

(b) Applicant Employer
Identification Number:

Applicant Employer
Identification Number
displays

This field is prepopulated from the Organization profile and
locked. To make any changes, please update the
Organization profile in AMIS.

Prepopulated

NumericalDollar Amount

For the purposes of Questions 2-6 in this Applicant Information section, the term Applicant shall only apply to the entity applying for a NMTC Allocation, and not to
Subsidiary entities that may receive a transfer of all or part of a NMTC Allocation.
15

NMTC Allocation Application Template for Public Comment – July 2024

Question

Question Text

Response

☐ For-Profit

Is the Applicant a For-profit
or Non-profit entity?*

☐ Non-Profit

Select all that apply:

☐ Credit Union

☐ Small Business
Investment
Company /
Specialized Small
Business
Investment
Company

Question Notes

Field Type
Dropdown
Menu

Hold the control button to make multiple selections from the
list.

Dropdown
Menu

☐ CDFI

☐ Publicly Traded
Company
☐ New Market
Venture Capital
Company
☐ GovernmentControlled Entity
☐ Faith-Based
Institution
☐ Thrift, Bank or
Bank Holding
Company
☐ Real Estate
Development
Company
☐ Series of Funds

☐ None of the above
16

NMTC Allocation Application Template for Public Comment – July 2024

Question

Question Text

Response

(d) Is the Applicant Minorityowned or Minoritycontrolled?

☐ Yes

(e) Is the Applicant a domestic
corporation or partnership for
federal tax purposes?

Question Notes

Dropdown
Menu

☐ No

☐ Domestic
Corporation
☐ Domestic
Partnership

If the Applicant is not a domestic corporation or partnership
for federal tax purposes, it is not eligible to apply for an
NMTC Allocation).

☐ No

(g) Applicant’s date of
incorporation or formation
(month/day/year):

Applicant’s date of
incorporation or
formation displays

(h) Applicant’s total assets as of
the date of this Allocation
Application:

$_____

Prepopulated

This field is locked. This is an Application Registration
question that cannot be changed after the Application
Registration has been submitted.

☐ Yes

(f) Is the Applicant Native
American-owned or Native
American-controlled?

Field Type

Dropdown
Menu
This field is locked. This is an Application Registration
question that cannot be changed after the Application
Registration has been submitted.

Prepopulated

NumericalDollar Amount

(i) Applicant’s fiscal year end
(month/day):
Applicant’s Fiscal Year End
Month:

Applicant’s Fiscal
Year End Month
displays

This field is locked. This is an Application Registration
question that cannot be changed after the Application
Registration has been submitted.

Prepopulated

Applicant’s Fiscal Year End Day:

Applicant’s Fiscal
Year End Day
displays

This field is locked. This is an Application Registration
question that cannot be changed after the Application
Registration has been submitted.

Prepopulated

(j) Does the Applicant have any
Affiliates that are applying for

☐ Yes
☐ No

Dropdown
Menu

NMTC Allocation Application Template for Public Comment – July 2024

Question

Question Text

Response

Question Notes

Field Type

☐ Yes

This field is locked. This is an Application Registration
question that cannot be changed after the Application
Registration has been submitted.

Prepopulated

an NMTC Allocation in this
Round?
3. Controlling
Entity
Information

Is the Applicant designating a
Controlling Entity?

☐ No

A CDE may only designate one organization as a
Controlling Entity. This entity must meet the definition of
Controlling Entity set forth in the Glossary of Terms of this
Allocation Application. Individuals cannot be deemed to be
Controlling Entities.
Applicants may use this Controlling Entity to assist in
demonstrating an organizational track record and in
completing the related exhibits. An Applicant may identify
the parent organization or the company of its parent (i.e.,
“grandparent”) as its Controlling Entity to demonstrate an
organizational track record, provided that the relationship
between the “grandparent” and the Applicant conforms to
the CDFI Fund’s definition of a Controlling Entity.
Should the Applicant receive an NMTC Allocation in this
Round, the designated Controlling Entity will need to
continue in that capacity throughout the term of the
Allocation Agreement and for any future Allocation
Agreements with the CDFI Fund, should the Applicant
apply and receive an allocation in a future round. Any
Applicant that receives an NMTC Allocation in this Round
must designate the same Controlling Entity as designated
in this Allocation Application in any Allocation Applications
for future rounds.
Applicants that received an NMTC Allocation in the CY
2013 round or later rounds are expected to maintain the
Controlling Entity stated in their Allocation Agreement in
Question 3(a). Please see the Application FAQ for further
guidance and information.
The Controlling Entity Representative is required to affirm,
through submission of a Signature Page, that it is indeed
18

NMTC Allocation Application Template for Public Comment – July 2024

Question

Question Text

Response

Question Notes

Field Type

the Controlling Entity of the Applicant and supports the
Applicant’s Allocation Application.
(a) Controlling Entity Name:

Controlling Entity
Name displays

This field is locked. This is an Application Registration
question that cannot be changed after the Application
Registration has been submitted.

Prepopulated

(b) Controlling Entity Employer
Identification Number:

Controlling Entity
Employer
Identification Number
displays

This field is locked. This is an Application Registration
question that cannot be changed after the Application
Registration has been submitted.

Prepopulated

Text Entry

Text box
Maximum
Response
Length: 100
characters

City:

Text Entry

Text box
Maximum
Response
Length: 100
characters

State:

Select State from List

Dropdown
Menu

Nine-Digit Zip Code:

Text Entry

Text box
Maximum
Response
Length: 10
characters

NMTC Allocation Application Template for Public Comment – July 2024

Question

Question Text

Response

(d) Structure of the Controlling
Entity:

☐ For-Profit

Is the Controlling Entity a
For-profit or Non-profit
entity?*
Structure of the Controlling
Entity (check all that apply):

Question Notes

Dropdown
Menu

☐ Non-Profit

☐ Credit Union

☐ Small Business
Investment
Company /
Specialized Small
Business
Investment
Company

Field Type

Hold the control button to make multiple selections from the
list.

Dropdown
Menu

☐ CDFI

NMTC Allocation Application Template for Public Comment – July 2024

Question

Question Text

Response

Question Notes

Field Type

☐ None of the above
(e) Is the Controlling Entity
Minority-owned or Minoritycontrolled?
(f) Is the Controlling Entity
Native American-owned or
Native American-controlled?
(g) Total assets of Controlling
Entity:

Dropdown
Menu

☐ Yes

Dropdown
Menu

$_____

NumericalDollar Amount

☐ No

☐ Applicant

The response to this question will prepopulate the noted
tables with either Applicant or Controlling Entity based on
which is selected.

Dropdown
Menu

Address:

Applicant’s Address
displays

This field is locked. This is an Application Registration
question that cannot be changed after the Application
Registration has been submitted.

Prepopulated

City:

Applicant’s City
displays

This field is locked. This is an Application Registration
question that cannot be changed after the Application
Registration has been submitted.

Prepopulated

State:

Applicant’s State
displays

This field is locked. This is an Application Registration
question that cannot be changed after the Application
Registration has been submitted.

Prepopulated

Nine-Digit Zip Code:

Applicant’s Nine-Digit
Zip Code displays

This field is locked. This is an Application Registration
question that cannot be changed after the Application
Registration has been submitted.

Prepopulated

Please select the track
record of either the Applicant
or Controlling Entity to
complete all tables in Exhibit
B and Table D1.
4. Applicant
Mailing
Information

☐ Yes

☐ Controlling Entity

Applicant Mailing address:

NMTC Allocation Application Template for Public Comment – July 2024

Question

Question Text

Response

Question Notes

Field Type

Address:

Applicant’s Address
displays

This field is locked. This is an Application Registration
question that cannot be changed after the Application
Registration has been submitted.

Prepopulated

City:

Applicant’s City
displays

This field is locked. This is an Application Registration
question that cannot be changed after the Application
Registration has been submitted.

Prepopulated

State:

Applicant’s State
displays

This field is locked. This is an Application Registration
question that cannot be changed after the Application
Registration has been submitted.

Prepopulated

Nine-Digit Zip Code:

Applicant’s Nine-Digit
Zip Code displays

This field is locked. This is an Application Registration
question that cannot be changed after the Application
Registration has been submitted.

Prepopulated

Address Shipping Address:

5(a)Applicant
Contact
Information

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

Applicant Contact Information

Should the Applicant be selected to receive an NMTC
Allocation, the CDFI Fund reserves the right to publish the
Applicant’s response to select questions in the Applicant
Information and Business Strategy sections, including
Public Contact Person information provided in Question
5(c).
(a) Applicant Authorized
Representative Information:
Designate an Authorized
Representative for this
Application

Applicant Authorized
Representative Name
Displays

This field is locked. This is an Application Registration
question that cannot be changed after the Application
Registration has been submitted.

Prepopulated

Only the AMIS user designated as the Authorized
Representative in Question 5(a) will be eligible to sign the
Allocation Application.

NMTC Allocation Application Template for Public Comment – July 2024

Question

Question Text

Response

Question Notes

Field Type

(b) Application Contact Person
Information:

Application Contact
Person Name
Displays

This field is locked. This is an Application Registration
question that cannot be changed after the Application
Registration has been submitted.

Prepopulated

The Application Contact Person is the individual that the
CDFI Fund may contact—jointly with the Authorized
Representative—during the course of the Allocation
Application review with questions or requests for additional
information regarding the Allocation Application. It is
strongly recommended that the Application Contact Person
listed is someone other than the Applicant Authorized
Representative.
(c) Public Contact Person
Information:

Text Entry
AMIS record displays
the following fields:

Search
Records
Once Public Contact Person is identified, the AMIS record
for that person will appear.

AMIS record
displays

1.
2.
3.
4.

Title
Mailing Street
Mailing City
Mailing
State/Province
5. Mailing Zip/Postal
Code
6. Business Phone
7. Email

5(b) Controlling
Entity
Contact
Information

(a) Controlling Entity
Representative Name:

Text Entry

(b) Controlling Entity
Representative Information:

AMIS record displays
the following fields:
1.
2.
3.
4.

Search
Records
Once Controlling Entity Representative is identified, the
AMIS record for that person will appear.

Title
Mailing Street
Mailing City
Mailing
State/Province
23

NMTC Allocation Application Template for Public Comment – July 2024

Question

Question Text

Response

Question Notes

Field Type

This field is locked. This is an Application Registration
question that cannot be changed after the Application
Registration has been submitted.

Prepopulated

5. Mailing Zip/Postal
Code
6. Business Phone
7. Email
6. CDE
Certification
Information

(a) Is the Applicant certified as a
CDE by the CDFI Fund as of
the Federal Register
publication date of the
NOAA?

If Yes, provide CDE
Certification Number:
(b) By the stated deadline in the
NOAA, is the Applicant filing
a service area amendment in
connection with this
application?
7. Service Area

Identify the type of service area
that the Applicant will serve. The
service area identified here must
be identical to the service area
identified by the Applicant in its
CDE Certification Application
approved by the CDFI Fund:

☐ Yes
☐ No

The CDFI Fund will only consider an Allocation Application
as eligible for an NMTC Allocation in this round if the
Applicant is certified as a CDE as of the Federal Register
publication date of the NOAA.
CDE Certification
Control Number
Displays

This field is prepopulated from the AMIS Profile and locked.
To make any changes, please update the AMIS Profile.

Prepopulated

☐ Yes

This field is prepopulated from the AMIS Profile and locked.
To make any changes, please update the AMIS Profile.

Prepopulated

☐ National service
area

The service area identified here must be identical to the
service area identified by the Applicant in its CDE
Certification Application approved by the CDFI Fund:

Dropdown
Menu

☐ No

☐ Multi-state service
area
☐ Statewide (or
territory-wide)
service area
☐ Local service area
(e.g.,
neighborhoods,
cities, a county or
contiguous

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

NMTC Allocation Application Template for Public Comment – July 2024

Question

Question Text

Response

Question Notes

Field Type

☐ Yes

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

Dropdown
Menu

States

Dropdown Menu

Hold down the 'Control' key to make multiple selections
from the list.

Dropdown
Menu

Estimate the percentage of
activities, by dollar amount that
will be directed to each of the
following markets.

_____ % Major urban
areas (Counties in
Metropolitan Area
with a population
equal to or greater
than 1 million,
including both central
city and surrounding
suburbs)

The total percentage should add up to 100% of the NMTC
Allocation

NumericalPercentage

Check only one.

Dropdown
Menu

counties) within a
state or territory
8. Geographic
Area

9. Urban or Rural
Focus

Did the Applicant select 'National
service area' in Question 7?

☐ No

_____ % Minor urban
areas (Counties in
Metropolitan Area
with a population less
than 1 million,
including both central
city and surrounding
suburbs)
_____ % NonMetropolitan
Counties
10. Predominant
Financing
Activity

Please indicate the Applicant’s
predominant anticipated
financing activity:

☐ Operating
Business financing
☐ Real Estate
financing: (check
only one

NMTC Allocation Application Template for Public Comment – July 2024

Question

Question Text

Response

Question Notes

Field Type

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

Text box

accompanying
sub-category)
☐ Retail
☐ Office Space

☐ Industrial or
Manufacturing
☐ Community
Facilities
☐ Mixed-use
(housing,
commercial, or
retail)
☐ Other Real
Estate
Financing:
☐ Financing of other
CDEs
☐ Loan purchase
from other CDEs
☐ Financial
Counseling and
Other Services
11. Executive
Summary

Provide a brief summary of the
Applicant’s overall community
development strategy and how
NMTC investments will be used
to address the specific needs or
challenges identified.

Text Entry

Maximum
Response
Length: 2,000
characters

NMTC Allocation Application Template for Public Comment – July 2024

Question

Question Text

Response

Question Notes

12. Time to
Complete

Estimate how long this Allocation
Application form took to
complete:

Text Entry

For the purpose of estimating hours, Applicant should focus
only on the amount of time it took to complete the
questions asked in this Application. Other activities that are
carried out in the normal course of business and are only
indirectly related to the completion of this Application (e.g.,
securing investor Commitments; developing a business
strategy or marketing plan; etc.) should not be included in
this estimation. This information is not scored or considered
in the evaluation of applications.

Field Type
Numerical

In the electronic on-line Application form, you will not
be able to answer this question until all other
Application questions are complete. You must answer
this question in order to complete and submit the online Application.

NMTC Allocation Application Template for Public Comment – July 2024

PART I: BUSINESS STRATEGY
Information in Part I is scored during the Phase I stage of the Application review. Total Maximum Points for Part I: 25 points, plus up to 10 additional
“priority points” available under sub-sections B and E. Information provided in this section will also be evaluated during the Phase II stage of the
Application review. For more information on the NMTC Allocation Application review process, please consult the NOAA.
NOTE: An Applicant will score well in this section to the extent it can articulate, with specificity, its strategy to use an NMTC Allocation and can describe a
strong, relevant track record, including a track record of serving LICs. Included in this section is the ability to earn “priority points” for meeting the statutory
priorities of: 1) investing in Unrelated entities; and/or 2) demonstrating a track record of serving Disadvantaged Businesses or Disadvantaged Communities.
Refer to the NOAA for further information on the statutory priorities.

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

NOTE: The NOAA states, “As a condition of eligibility for this Allocation Round, the Applicant will not be permitted to use the proceeds of Qualified Equity
Investments (QEIs) to make Qualified Low-Income Community Investments (QLICIs) in Qualified Active Low-Income Community Businesses (QALICBs)
where QLICI proceeds are used, in whole or in part, to repay or refinance a debt or equity provider whose capital was used to fund the QEI, or are used to
repay or refinance any Affiliate of such a debt or equity provider, except where: (i) the QLICI proceeds are used to repay or refinance documented reasonable
expenditures that are directly attributable to the qualified business of the QALICB, and such reasonable expenditures were incurred no more than 24 months
prior to the QLICI closing date; or (ii) no more than 5% of the total QLICI proceeds from the QEI are used to repay or refinance documented reasonable
expenditures that are directly attributable to the qualified business of the QALICB. Refinance includes transferring cash or property, directly or indirectly, to
the debt or equity provider or an Affiliate of the debt or equity provider.”
28

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

13. (a) QLICI
Uses and
Activities

Will the Applicant commit that it
will not permit the use of the
proceeds of QEIs to make any
QLICIs in QALICBs where QLICI
proceeds are used to repay or
refinance any debt or equity
provider or a party related to any
debt or equity provider whose
capital was used to fund the QEI
except where: (i) the QLICI
proceeds are used to repay
documented reasonable
expenditures that are directly
attributable to the qualified
business of the QALICB, and
such reasonable expenditures
were made no more than 24
months prior to the QLICI closing
date; or (ii) no more than 5% of
the QLICI proceeds are used to
repay or refinance prior
investment in the QALICB?
Refinance includes transferring
cash or property directly to any
debt or equity provider or
indirectly to a party related to
any debt or equity provider.

Response
 Yes
 No

Question Notes

Field Type

If the Applicant selects “No” to Question 13(a),
then the Applicant will not be eligible to submit this
NMTC Allocation Application. If the Applicant
selects “Yes” to Question 13(a), the Applicant will
be held to this commitment as a condition of its
Allocation Agreement. For additional information,
please see the NMTC Compliance & Monitoring
Frequently Asked Questions.

Dropdown Menu

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

Question Notes

Field Type

13. (b) (i-iv)
Table QLICI Uses
and
Activities

Please indicate the activity types
of QLICIs in which the Applicant
intends to engage (check all that
apply), and what percentage of
allocations (by dollar amount)
will be used for each activity
type. (Percentages for (i)-(iv)
should add up to 100%):

(i) _____ % Percent
Investments in, or loans to,
Qualified Active Low-Income
Businesses (QALICB)

Loans / investments will be used to finance:
(these three percentages should add up to 100%
by dollar amount)

Numerical Percentage

(ii) _____ % Percent
Investments in, or loans to,
other CDEs.
(iii) _____ % Percent
Purchases of loans from other
CDEs.
(iv) _____ % Percent
Financial Counseling and
Other Services.

13. (b) (i-iv)
Detailed

i. Will the Applicant make
investments in, or loans to,
Qualified Active Low-Income
Businesses (QALICBs)?

 Yes
 No

_____ % Non-Real Estate
Activities

(i) Table A1 and Table A5 will be visible if the
percentage exceeds zero.
(ii) Table A2, Table A5, and Question 14c will be
visible if the percentage exceeds zero.
(iii) Table A3 and Question 16 will be visible if the
percentage exceeds zero.
(iv) Table A4 will be visible if the percentage
exceeds zero.

Based on the percentages entered into the table
for Question 13(b) in the previous sub-section,
complete the following questions by answering
“Yes” to the types of QLICIs where
the Applicant indicated greater than zero
percent. If the Applicant does not plan to use its
allocation for a particular type of QLICI activity,
the Applicant should answer “No.”

Dropdown Menu

The total of all three must equal 100%.

Numerical Percentage

_____ % Real Estate
Activities where the real estate
will be owned (either directly or
through an Affiliate) and
principally occupied by an
Operating Business
_____ % Real Estate
Activities where the real estate
will be principally leased to
third-party tenants or sold to a
third party
30

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

ii. Will the Applicant make
investments in, or loans to,
Qualified Active Low-Income
Businesses (QALICBs)?

 Yes

Question Notes

Field Type
Dropdown Menu

 No
_____ % Enter percentage for
origination of loans,
investment of capital, or equity
to QALICBs

The total of both must equal 100%.

Numerical Percentage

_____ % Enter percentage for
Financial Counseling and
Other Services
iii. Will the Applicant purchase
loans from other CDEs?*

 Yes

iv. Will the
Applicant provide Financial
Counseling and Other
Services?*

 Yes

Dropdown Menu

 No
Dropdown Menu

 No
How will the proposed
Financial Counseling and
Other Services be provided?

Dropdown Menu

 In conjunction with financing
 As a discrete line of
business
14. Products,
rates and
terms that
the
Applicant
intends to
offer

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

□ 1 FP
□ 2 FPs
□ 3 FPs

If an Applicant intends to utilize its requested
NMTC Allocation to engage solely in either the
purchase of loans from other CDEs or in the
provision of FCOS, and not in the origination of
loans or equity, it should skip Questions 14 and
15.

Check box

If the Applicant indicates it will be providing more
than one financial product in Question 14(a), the
Applicant should provide a distinct and unique
narrative description for each financial product.
31

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

Question Notes

Field Type

Applicants that use the same narrative text for
different financial products will not be scored as
favorably. To the extent the Applicant indicates a
range of offerings within an item listed above
(e.g., interest rates from 100 basis points (bps) to
500 bps below market), it should describe what
circumstances would dictate the best rates, terms,
and features.
The sheer number of financial products selected
by the Applicant in Question 14(a) has no effect
the scoring of the Allocation Application.

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

Question Notes

Field Type

(b) For each financial product
selected in Question 14(a),
provide the expected
percentage of Allocation for
each product and provide a
narrative that addresses the
following elements:

FP 1 ______%

The Applicant should base the expected
percentage of Allocation for each financial
product, on the Applicant’s intended strategy and
planned use. For Applicants that plan to offer
more than one financial product, the expected
percentages of Allocation should add up to 100%.
Expected percentages of Allocation will not be
subject to reporting or be considered in measuring
compliance with the Allocation Agreement.

Numerical Percentage

• Indicate whether the
product is debt, equity, or
some combination of the
two. If debt, describe if it
will have any equity
equivalent features (e.g.,
convertible debt, debt with
warrants, etc.) and which
of the following flexible or
non-traditional features the
Applicant intends to
include as part of the
financial product:
• Below market interest
rates (or rate of return in
the case of Equity
Investments)
• Lower than standard
origination fees

FP 2 ______%
FP 3 ______%

For each product, the Applicant should clearly
discuss how the product is structured as well as
benefits this structure provides to
borrowers/investees. A financial product
structured with multiple financial notes (e.g., an A
and B note, or an A, B, and C note, etc.) must be
described as one financial product. In this case,
the rates and terms of the financial notes should
be discussed on a blended basis. For additional
guidance on calculating blended interest rates,
see the Application FAQ. The individual financial
notes should not be listed as separate products
unless they will also be offered on a stand-alone
basis. Applicants will not be scored as favorably if
they do not follow these instructions.
The Applicant may discuss other flexible or nontraditional features of its financial products in
Question 14(b). Only the non-traditional and
flexible features listed below are subject to

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text
• Longer than standard
period of interest-only loan
payments
• Higher than standard loanto-value ratio

Response
FP 1 Narrative
FP 2 Narrative

Question Notes
reporting and only these features will be
considered in measuring compliance with the
Allocation Agreement.

FP 3 Narrative

• Longer than standard
amortization period

Field Type
Text box
Maximum
Response
Length: 5,000
characters

• More flexible borrower
credit standards
• Non-traditional forms of
collateral
• Lower than standard debt
service coverage ratio
• Subordination
Include a brief description of the
rates, terms, and features that
will be offered with its NMTC
financial product and explain
how these rates and terms
compare with what is typically
offered by other financial
institutions or investors in the
Applicant’s service area.
Provide an example of how the
product will be used (alone or in
conjunction with non-NMTC
capital) to finance a projected
NMTC investment identified in
Question 17.
(c) For an Applicant that
indicated under Question
13(b) that it intends to
finance other CDEs,
describe the strategy by

Text Entry

If a QLICI has not been identified and no project
specific data is available, provide an example of
the how the Applicant expects the QLICI in a
recipient CDE to be used to finance investments.
Applicant must also describe its efforts to ensure

Text box
Maximum
Response
34

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

which the Applicant will
ensure that those CDEs will
pass along the NMTC
benefits to their QALICB
borrowers in the form of
more favorable rates or
terms. Provide an example
of how the QLICI in a
recipient CDE will be used
(alone or in conjunction with
non-NMTC capital) to
finance an investment
identified in Table A5 and
how it will result in more
favorable rates and terms.
15. Additional
Flexibility
for Debt

Choose one of the following
options. Check only one.
The Applicant will commit that
100% of its QLICIs will:

□ (a): be provided in the form
of equity; equity-equivalent
financing; debt with interest
rates at least 50% below
market; or debt that
otherwise satisfies at least 5
indicia of flexible or nontraditional rates and terms,
as listed in Question 14.
□ (b) be provided in the form
of equity; equity-equivalent
financing; debt with interest
rates at least 33% below
market; or debt that
otherwise satisfies at least 4
indicia of flexible or nontraditional rates and terms,
as listed in Question 14.

Question Notes

Field Type

that the NMTC benefits will be passed on to
QALICB borrowers and details on the benefits of
any loans or investments provided to other CDEs
and how its strategy will result in more favorable
rates and terms.

Length: 3,000
characters

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

Check box

Please refer to the Application FAQ document for
guidance on how to calculate below market
interest rates.

□ (c) be provided in the form
of equity; equity-equivalent
financing; debt with interest
rates at least 25% below
35

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

Question Notes

Field Type

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

Check box

market; or debt that
otherwise satisfies at least 3
indicia of flexible or nontraditional rates and terms,
as listed in Question 14.
□ (d) be provided in the form
of equity; equity-equivalent
financing; debt with interest
rates at least 15% below
market; or debt that
otherwise satisfies at least 2
indicia of flexible or nontraditional rates and terms,
as listed in Question 14.
□ (e) None of the above.

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

(a) Will the Applicant require the
CDE from which it purchases
loans to reinvest all or a
portion of the proceeds from
the loan sales in QLICIs?
If yes, identify the
percentage and briefly
describe the Applicant’s
mechanisms for enforcing
this requirement:

□ Yes
□ No
_____% of loan purchases
that the Applicant will require
the CDE to reinvest in QLICIs
Text Entry

Numerical Percentage
Text box
Maximum
Response
Length: 2,000
characters

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

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

Text Entry

Question Notes

Field Type
Text box
Maximum
Response
Length: 2,000
characters

NMTC Allocation Application Template for Public Comment – July 2024

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

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

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

17. Projected
NMTC
Investments

(a) Complete Tables A1-A4, as
applicable, according to the
types of QLICI activities in
which the Applicant intends
to engage

Table

(b) Complete Table A5 for
each QALICB or NMTC
activity to be financed using
the Applicant’s requested
NMTC Allocation in
Question 1.

Table

•

The total number of
businesses or CDEs
already identified,
including the total
dollar amount of
NMTC financing (i.e.,
QEI and QLICI
amount) to be
provided.
Describe the factors
that inform the
Applicant’s investment
strategy, including
borrower/investee
selection criteria, the
capital needs of its
borrowers/investees,
range of dollar
amounts of proposed
NMTC investments,
etc.

Response

Text Entry

Question Notes

Field Type

The tables that appear depend on the Applicant’s
responses to Question 13(b)(i-iv)

Table A1A4

Table A5

Total QEI needs should be equivalent to the
Applicant’s allocation request in Question 1; be sure to
indicate what portion of the Applicant’s pipeline falls
into different business types (e.g., education, retail,
manufacturing/industrial, etc.) and activity types (e.g.
loans to QALICBs, investments in CDEs, loan
purchases from CDEs, etc.).

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If loans are being made to other CDEs, describe
criteria used to select a CDE for an investment/ loan,
types of investments the Applicant are looking to
achieve, and types of pipeline projects for secondary
CDEs.
The CDFI Fund expects that obtaining community input
will be an important factor that informs the Applicant’s
investment strategy. However, the Applicant should not
provide information about how it obtained community
input in Q.17(c). The information should be provided in
the Community Accountability and Involvement subsection (Q.27a-d).

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

Question Notes

Field Type

18. QALICB Due
Diligence

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

Text Entry

Please describe any documents that will be required
from borrowers/investees and the types of analyses
performed as part of the Applicant’s due diligence, prior
to making a QLICI, in determining QALICBs’ ability to
remain financially viable and operational, including but
not limited to:

Text box

•
•
•
•

financial considerations of the borrower or investee
(i.e., QALICB Affiliate);
the likelihood of project completion related to the
asset(s) financed with NMTC;
management team’s ability to effectively undertake
and manage the QALICB; and
analysis of market demand for the QALICB’s
products or services.

Maximum
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Length:
3,500
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The Applicant should also explain how the analyses
performed are documented.
19. Innovative
Investments

1. Does the Applicant intend to
pursue any of the following
innovative investments?

□ Yes

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

(a) ____% of loan purchases
that the Applicant will require
the CDE to reinvest in QLICIs

□ No

(b) _____% Investing in
Unrelated Minority-owned or
Native American-owned or
controlled CDEs that do not
have NMTC Allocations;
(c) _____% Investing in states
identified by the CDFI Fund as
having received fewer dollars
of QLICIs historically
(d) _____% Providing QLICIs

Question 19 will not be evaluated and scored in Phase
I of Allocation Application reviews. Therefore, this
question will not be used to determine whether an
Applicant scored highly enough to receive
consideration for an NMTC Allocation. The response to
this question will be considered in Phase II of the
Allocation Application reviews and may affect the size
of the Applicant’s NMTC Allocation (along with other
evaluation criteria as discussed in the NOAA). For
more information on the Allocation Application review
process, please see the NMTC Program Application
Presentation Slides on the NMTC page of the CDFI
Fund’s website and the NOAA. If selecting the
innovative QLICIs option, note that no particular activity
is preferred over another. Applicants are required to
provide the percentage of total QLICIs to be used for
each innovative investment type. If the Applicant
receives an NMTC Allocation, it may be required to
meet the percentage identified in Question 19 and such

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Numerical Percentage

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response
where the total QLICIs received
by the QALICB are $4 million or
less
(e) _____% Making QLICIs
with an original term less than or
equal to 60 months
(f) _____% Providing QLICIs for
non-Real Estate Activities, such
as working capital, inventory or
equipment purchase

Question Notes

Field Type

requirement may be a term of its Allocation Agreement.
The CDFI Fund will only consider the activities listed in
Question 19 as innovative investments.
If the Applicant proposes to pursue innovative QLICIs
by investing in states that have historically received
fewer dollars of QLICIs, the Applicant should refer to
the Application FAQ to find the list of 10 states (plus
Puerto Rico) that have received the least amount of
QLICI investments through FY 2022, based on AMIS
Compliance and Performance Reporting System
(ACPR) reporting data.

(2g) _____% Investing in
Federal Indian Reservations,
Off-Reservation Trust Lands,
Hawaiian Home Lands, and
Alaska Native Village Statistical
Areas
3. If the Applicant entered a
percentage above, discuss
the Applicant’s strategy to
deploy QLICIs for the
innovative investment
type(s) selected above. The
Applicant should reference
sample transactions from
Question 17(c) and Table
A5, as well as its track
record of similar activities in
the past.

Text Entry

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NMTC Allocation Application Template for Public Comment – July 2024

C. Prior Performance
NOTE: An Applicant that can demonstrate (either on its own or through its Controlling Entity) a strong, successful track record of providing products,
services, or FCOS similar to those that it intends to provide with QEI proceeds will score well under this sub-section. Only the organizational track record of
the Applicant or the Controlling Entity may be referenced. The track record of the Controlling Entity must include the financing activities (loans and Equity
Investments) of all Subsidiaries of the Controlling Entity, including the Applicant if the Applicant is a Subsidiary of the Controlling Entity. The track record of
the Applicant must include the financing activities of all Subsidiaries of the Applicant. The track records of staff, Principals, board members and other
management individuals are not relevant for this sub-section. There will be an opportunity to discuss individual qualifications in the Management Capacity
section of this Application.
NOTE: The NMTC Program authorizing statute requires the CDFI Fund to give priority to any Applicant that has a track record of successfully providing capital
or technical assistance to Disadvantaged Businesses or Disadvantaged Communities. An Applicant may receive up to five “priority points” for demonstrating
such a track record. Responses to Question 20 and Question 21 as well as Exhibit B, are used to determine the amount of “priority points.” Only the
organizational track record of the Applicant or the Controlling Entity may be referenced. Do not refer to the track record of individuals (e.g., staff, Principals,
consultants) associated with the Applicant or its Controlling Entity.
NOTE: The Applicant may reference, in the Tables in Exhibit B and in the narratives in Question 20(b) and Question 21(b) (if applicable), loans or Equity
Investments that the Applicant (or its Controlling Entity) has itself financed and for which it has capital at risk (direct financing/investment). Only loans or Equity
Investments may be included in the Tables in Exhibit B and in the narratives in Question 20(b) and Question 21(b). Grants provided by the Applicant or
Controlling Entity may not be included. Please note that capital provided to non-profit businesses that are not in the form of a loan will be considered grants
and should not be referenced in Question 20, Question 21 or included in Exhibit B. For additional details on completing Exhibit B, please refer to the NMTC
Application FAQ document.
NOTE: An Applicant that demonstrates a longer track record of providing similar direct financing/investments or FCOS to entities that are not Affiliates (either
on its own or through its Controlling Entity) will generally score higher in this section than an Applicant that demonstrates a shorter track record of direct
financing/investments or FCOS. An Applicant (either on its own or through its Controlling Entity) will score lower in this section if its track record is comprised
primarily or exclusively providing indirect financing/investments, and/or a track record of primarily or exclusively financing Affiliates.

NMTC Allocation Application Template for Public Comment – July 2024

NOTE: If an Applicant intends to utilize its NMTC Allocation to engage in the provision of FCOS as a discrete line of business (as indicated in Question 13), it
must include the following in its narrative response to Question 20(b): (1) the number of businesses/entrepreneurs to which the Applicant has provided
counseling or other services in the last five years; and (2) the percentage of those businesses/entrepreneurs that were located in Low-Income Communities.
This information will be used to evaluate the Applicant’s eligibility to receive “priority points” for demonstrating a track record of successfully providing capital
or technical assistance to Disadvantaged Businesses or Disadvantaged Communities.
Please note that if an Applicant intends to use its NMTC Allocation to engage in the provision of FCOS as its sole line of business, and not in the purchase or
origination of loans or Equity Investments, it does not need to complete Tables B1-B4.

Question Number

Question Text

20. Track
Record
(Table B1B3)

(a) Does the Applicant, or its
Controlling Entity, have a track
record in any of the following
activities listed below? Your
selection should correspond to
the activities selected in Question
13 and described in Question 17.
Check all that apply. A narrative is
required (Question 20(b)) if at
least one activity is selected.

Response

Question Notes

Field Type

Tables B1-B3 will stay hidden in AMIS unless you select a
‘Yes’ response for the related sub-question for Question 20
(ex. track record of directly providing or otherwise facilitating
loans or Equity investments to Real Estate and Operating
Businesses (excluding Restricted NMTC Business
Activities), loans or Equity investments to CDEs, etc.).

Directly providing or otherwise
facilitating loans or Equity
investments to Real Estate and
Operating Businesses (excluding
Restricted NMTC Business
Activities).

□ Yes

Directly providing loans or Equity
investments to other CDEs

□ Yes

Purchasing loans from other CDEs

□ Yes

If 'Yes' is selected, complete Question 20(b) and Table B1

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If ‘Yes’ is selected, complete Question 20(b) and Table B2

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If ‘Yes’ is selected, complete Question 20(b) and Table B3

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□ No

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text
(b) Provide a narrative discussion of
the organization’s track record
relevant to each type of activity
selected (including FCOS) in
Question 13, referencing data
included in Tables B1-B3, as
appropriate. Applicants that
intend to use the NMTC
Allocation to make loans to or
investments in QALICBs should
describe the similarity between
their track record and the types of
businesses to which they plan to
provide QLICIs.

Response
Text Entry

Question Notes

Field Type

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

Text box

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

Maximum
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10,000
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Focus the discussion specifically on the Applicant’s or its
Controlling Entity’s experience targeting Disadvantaged
Businesses or Disadvantaged Communities.
(c) Provide the overall number of
years that the Applicant or its
Controlling Entity has provided
capital or technical assistance to
Disadvantaged Businesses or
Disadvantaged Communities
21. Track
Record
(Table B4)

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

Numerical

□ Yes
□ No

Numerical

See the Application FAQ for additional guidance on the
types of “Financing/Investment Activities that would not
qualify as QLICI Activities.”

Check box

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

Question Notes

Field Type

consumer loans, and residential
mortgages) but are similar to the
proposed NMTC activities?
(b) Referencing Table B4 as
appropriate, describe the
Applicant’s, or Controlling
Entity’s, track record over the
past five years of successfully
providing the loans or Equity
Investments and financial
counseling included in Table B4
and how these activities are
similar to the proposed NMTC
activities:

Text Entry

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

Numerical

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Numerical

NMTC Allocation Application Template for Public Comment – July 2024

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

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

22. NonMetropolitan
Counties

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

□ Yes

Question Notes

Field Type
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□ No

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

Numerical

(c) What is the minimum percentage
of QLICIs that the Applicant is
willing to commit to deploy in
Non-Metropolitan Counties?

______%

(d) What is the maximum percentage
of QLICIs that the Applicant is
willing to commit to deploy in
Non-Metropolitan Counties?

______%

This value must be equal to or greater than the value for
Question 22(c)

Numerical Percentage

(e) If the response to Question 22(c)
above is greater than 0%,
referencing Exhibit B, briefly
describe the Applicant’s (or its
Controlling Entity’s) five-year
direct financing track record in
Non-Metropolitan Counties in
Tables B1-B3 and Table B4.
Specifically, describe the types of
projects and the dollar amounts
that the Applicant (or its
Controlling Entity) provided
directly to projects located in

Narrative

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

Text box

Value cannot be greater than 6.

Numerical age

Numerical Percentage

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NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

Question Notes

Field Type

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

Text box

Non-Metropolitan Counties. See
the Application FAQ.
(f) If the response to Question 22(c)
above is greater than 0%, and
only to the extent not discussed
elsewhere in the Application,
discuss the Applicant’s strategy
for deploying QLICIs in NonMetropolitan Counties.

Narrative

Reference sample transactions in the Applicant’s nonmetropolitan pipeline included in Table A5.
Discuss the key challenges the Applicant anticipates it will
have providing QLICIs in Non-Metropolitan Counties and
how the Applicant proposes to overcome those challenges.

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NMTC Allocation Application Template for Public Comment – July 2024

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

Question Number

Question Text

23. Investments
in Unrelated
Entities

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

24. Notable
Relationships

In items (a) – (e), Describe any
potential situations in which the
Applicant, its Affiliates (including the
Controlling Entity) or its personnel
(including governing or advisory
board members, consultants, etc.)
involved in identifying NMTC
investments or making investment
decisions on behalf of the Applicant
will also receive financial benefits
from the QALICBs, Affiliates of
QALICBs, QEI investors, and/or
other participants in the
transactions resulting in the
Applicant’s QLICIs.

Response

Question Notes

 Yes

Field Type
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 No

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

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text
(a) Will the Applicant, its Affiliates or
its personnel own more than a
1% interest in the QALICB?

Response
 Yes

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

 Yes

 Yes
 No

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 No
Text Entry

Field Type
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 No
Text Entry

(b) Will the Applicant, its Affiliates or
its personnel be lessees at
property developed with the
QLICI?

Question Notes

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NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text
business transaction financed
with the QLICIs?

Response

Question Notes

Text Entry

Field Type
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(d) Will the Applicant, its Affiliates or
its personnel (including
governing or advisory board
members, consultants, etc.)
provide professional services
(project development, real estate
agent, property manager,
general contractor, etc.) or
capital outside of the QLICI for
the QALICB, including Affiliates
of the QALICB and/or other
participants in the transactions
resulting in the Applicant’s
QLICIs?

 Yes

(e) Are there other financial benefits
that the Applicant, its Affiliates or
its personnel may receive, but
are not included in items (a)-(d)
above?

 Yes

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 No
Text Entry

If “Yes” was selected, described the fees for such
professional services. Are the services and/or products
required to be provided by the Applicant as a condition of
receiving the QLICI? Explain how rates and fees for
products and/or services to QALICBs compare with what is
typically offered by the Applicant (or its Controlling Entity)
and by other providers in the Applicant’s service area.
Provide a specific example and quantify how such
relationships will create cost savings for QALICBs and/or
benefits to unaffiliated end-users, such as tenant
businesses, or residents of Low-Income Communities.

Maximum
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 No
Text Entry

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NMTC Allocation Application Template for Public Comment – July 2024

PART II: COMMUNITY OUTCOMES
Information in Part II is scored during the Phase I stage of the Application review. Total Maximum Points for Part II: 25 points. Information provided in
this section will also be evaluated during the Phase II stage of the Application review. For more information on the NMTC Allocation Application review
process, please consult the NOAA.
NOTE: The CDFI Fund will review the extent to which the Applicant’s strategy will have positive community outcomes. An Applicant will generally score well
under this section to the extent that:
(a) it is working in particularly economically distressed or otherwise underserved communities;
(b) it shows that its projected financing activities will generate demonstrable community outcomes; and
(c) it demonstrates meaningful engagement with community stakeholders when vetting potential NMTC investments.
NOTE: The CDFI Fund does not expect that each and every investment will be in an area identified in Question 25.

A. Targeting the Use of QLICIs
Question Number

Question Text

Response

25. Areas to be
Served by
the
Applicant

(a) Will the Applicant commit to
providing at least 85% of its QLICIs
(in terms of aggregate dollar
amounts) in areas that are either: (1)
characterized by at least one of
items 1-5 on the list below for each
QLICI; or (2) characterized by at
least two of items 6-12 on the list
below for each QLICI?

☐ Yes
☐ No

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

Field Type
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Applicants that check “Yes” are required to answer Question
25(b).

Identify all of the areas to be served
by the Applicant (check all that
apply):

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

Question Notes

Field Type

1. SEVERE DISTRESS

 Yes

Census tracts with poverty rates greater than 30%; OR
Census tracts with, if located within a Non-Metropolitan
County, have a median family income that does not exceed
60% of statewide median family income, or, if located within
a Metropolitan Area, have a median family income that does
not exceed 60% of the greater of the statewide median
family income or the Metropolitan Area median family
income; OR Census tracts with unemployment rates at least
1.5 times the national average

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

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Island Areas of the United States as determined by the
United States Census Bureau including Puerto Rico, U.S.
Virgin Islands, Guam, the Commonwealth of the Northern
Mariana Islands, and American Samoa.

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Qualifying census tracts that are located in counties not
contained within a Metropolitan Statistical Area (MSA), as
defined in OMB Bulletin No. 20–01 (Update of Statistical
Area Definitions and Guidance on Their Uses) and applied
to the 2020 census tracts.

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

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Census tracts with one of the following: (i) poverty rates
greater than 25%; or (ii) if located within a Non-Metropolitan
Counties, median family income that does not exceed 70%
of statewide median family income, or, if located within a
Metropolitan Area, median family income that does not

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 No

2. FEDERAL NATIVE AREAS

 Yes
 No

3. U.S. TERRITORIES

 Yes
 No

4. NON-METROPOLITAN
COUNTIES

 Yes

5. TARGETED POPULATIONS

 Yes

 No

6. 25% POVERTY/70% MEDIAN
FAMILY INCOME/1.25
UNEMPLOYMENT RATE

 Yes
 No

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

Question Notes

Field Type

exceed 70% of the greater of the statewide median family
income or the Metropolitan Area median family income; or
(iii) unemployment rates at least 1.25 times the national
average.
7. BROWNFIELD SITES

 Yes

As defined under 42 U.S.C. 9601 (39).

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Areas designated as distressed by the Appalachian
Regional Commission (ARC) or Delta Regional Authority
(DRA).

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As designated by the U.S. Department of Housing and
Urban Development (HUD).

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Medically Underserved Areas (MUA) or geographic Health
Professional Shortage Area (HPSA), as designated by
Health Resources & Service Administration (HRSA), to the
extent QLICI activities will support mental health, primary
and dental health related services.

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

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Census tracts designated as Low-Income and Low-Access
(LILA) to supermarkets, supercenters, or large grocery
stores in the Food Access Research Atlas (FARA) by the
U.S. Department of Agriculture Economic Research Service
(USDA-ERS), to the extent QLICI activities will increase
access to healthy food.

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A QLICI that meets this commitment will also automatically
meet the commitment made in Question 25(a).

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 No
8. ARC AND/OR DRA AREAS

 Yes
 No

9. COLONIAS AREAS

 Yes
 No

10. FEDERAL MEDICALLY
UNDERSERVED AREAS

 Yes

11. FEMA DISASTER AREAS

 Yes

 No

12. LOW-INCOME and LOWACCESS TO SUPERMARKETS

 Yes

(b)(i) If the Applicant selected “Yes”
to Question 25(a), select the
percentage of its QLICIs (in terms

 0%

 No

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text
of aggregate dollar amounts) the
Applicant will commit to providing
in areas characterized by at least
one of four items in the list below
for each QLICI?

Response

Question Notes

 5%

An Applicant that commits to a higher percentage
commitment to Question 25(b) below will generally score
more favorably and may be considered for additional
allocation. Applicants will not be held to the individual
commitments to any of the areas listed below and will have
the flexibility to invest in any of the areas as long as the
overall commitment percentage is met.

 10%
 15%
 20% or more

Field Type

If the Applicant is selected to receive an NMTC Allocation, it
will be required to meet the commitment percentage
selected as a term of its Allocation Agreement.

(b)(ii) For Applicants that selected
'20% or more', input the
maximum commitment
percentage.

___% of QLICIs

1. DEEP DISTRESS

 Yes
 No

2. FEDERAL NATIVE AREAS

 Yes
 No

3. HIGH MIGRATION RURAL
COUNTIES

 Yes

This field should only be completed by Applicants that select
"20% or more" as their response to Question 25(b)(i).
Applicants may enter any percentage amount starting from
20% and up to 100%. This Question will not factor into an
Applicant’s score. However, Applicants that commit to an
amount that is 20% or greater maybe considered for
additional allocation. If the Applicant is selected to receive
an NMTC Allocation, it will be required to meet the
commitment percentage as a condition of its Allocation
Agreement.

Numerical Percentage

Census tracts with poverty rates greater than 40%; OR
Census tracts, if located within a Non-Metropolitan Counties,
with a median family income that does not exceed 40% of
statewide median family income, or, if located within a
Metropolitan Area, have a median family income that does
not exceed 40% of the greater of the statewide median
family income or the Metropolitan Area median family
income; OR Census tracts with unemployment rates at least
2.5 times the national average

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

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Section 223 of the American Jobs Creation Act of 2004 (P.L.
108-357, 118 Stat. 1418) amended the definition of LICs to

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NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

4. U.S. TERRITORIES

Response

Question Notes

 No

include census tracts in High Migration Rural Counties with
a median family income at or below 85% of the applicable
area median family income. A High Migration Rural County
is any county which, during the 20-year period ending with
the year in which the most recent census was conducted,
has a net out-migration of inhabitants from the county of at
least 10% of the population of the county at the beginning of
such period.

 Yes

Island Areas of the United States, as determined by the
United States Census Bureau including Puerto Rico, U.S.
Virgin Islands, Guam, the Commonwealth of the Northern
Mariana Islands, and American Samoa.

 No

Field Type

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(c) Discuss the Applicant's track
record of loans and Equity
investments in the areas selected
in Q.25(b).

Text Entry

Applicants that commit to investing a percentage of their
Allocation in any of the areas listed in Q.25(b) above should
discuss their track record of loans and Equity investments in
the areas where the Applicant selected “Yes” in Q.25(b).

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NMTC Allocation Application Template for Public Comment – July 2024

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

Question Number

Question Text

26. Community
Development
Outcomes

(a) Select the outcome(s) the
Applicant expects to achieve as a
result of the projected QEIs
described the Business Strategy
section.

Response

Question Notes

Field Type

Select all that apply and for each outcome selected, please:
• Quantify the Applicant’s projected community outcomes;
• Considering the Applicant’s planned NMTC
financing/investments described in Question 17, explain how
the Applicant quantified the potential outcomes that would
result from receiving an NMTC Allocation;
• Describe and quantify (to the extent possible) the
Applicant’s track record of achieving each selected outcome
through past financings/investments. Discuss how the track
record of achieving outcomes compares with projected
outcomes.

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

Question Notes

Field Type

1. JOB CREATION / RETENTION

☐ Yes

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

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

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

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box

☐ No

2. QUALITY JOBS

☐ Yes
☐ No

3. ACCESSIBLE JOBS

☐ Yes
☐ No

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NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

Question Notes

Field Type

4. COMMERCIAL GOODS OR
SERVICES TO LOW-INCOME
COMMUNITIES

☐ Yes

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

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

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

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

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box

5. COMMUNITY GOODS OR
SERVICES TO LOW-INCOME
COMMUNITIES

6. FINANCING MINORITY
BUSINESSES

7. FINANCING NATIVE
AMERICAN BUSINESSES

☐ No

☐ Yes
☐ No

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NMTC Allocation Application Template for Public Comment – July 2024

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Question Text

Response

Question Notes

Field Type
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8. HOUSING UNITS

☐ Yes
☐ No

9. ENVIRONMENTALLY
SUSTAINABLE OUTCOMES

(b) Describe the Applicant’s track
record of establishing and
monitoring community outcomes.
Describe how the Applicant will
track and document the community
outcomes QALICBs are expected to
achieve as a result of the
Applicant’s QLICIs.

☐ Yes
☐ No

Text Entry

Quantify (e.g. number of total units, number of affordable
units) and describe the extent to which the Applicant will
provide housing opportunities for Low-Income Persons; the
extent to which housing will be offered in areas of high
affordable housing need, including communities with high
concentrations of vacancies or foreclosures or communities
where housing costs are high; and/or the extent to which the
housing development adheres to principles of “smart
growth,” including transit-oriented development. Housing
units must meet the affordable housing requirements in the
Allocation Agreement and NMTC Compliance FAQ.

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

Check box /
Text box

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

Text box

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NMTC Allocation Application Template for Public Comment – July 2024

NOTE: All CDEs are required to maintain accountability to Low-Income Communities. An Applicant will be evaluated more favorably to the extent:
•
•

It articulates meaningful involvement in Low-Income Communities and with a variety of Low-Income Community stakeholders, and
It clearly explains how benefits to Low-Income Persons and/or LIC residents are prioritized and considered in its investment decisions.

Question Number
27. Community
Accountability
and
Involvement

Question Text

Response

(a) Complete Table C1. List the number and
percentage of Low-Income Community
representatives on the Applicant’s Advisory
and/or Governing Board. Discuss the role these
individuals play in formulating the Applicant’s
pipeline of investments, setting investments
priorities, and approving the Applicant’s
investment decisions.

Table

(b) Describe the Applicant’s (or Controlling Entity’s)
process for ensuring that Low-Income Persons
and/or LIC residents will benefit from its
proposed investments. When answering this
question, make sure to specifically discuss:

Text Entry

•

How specific needs or challenges of the
Applicant’s service area will be addressed
with NMTC, including a brief summary of the
service area. Provide quantitative and/or
qualitative data used by the Applicant to
determine the needs of the communities in
which the Applicant intents to invest; and

•

How the Applicant will prioritize its
investments to benefit Low-Income Persons
and/or LIC residents.

(c) Explain how the Applicant’s investment
decisions, including the types of business
selected, are informed by its project-specific
community engagement with Low-Income

Question Notes

Field Type
Table C1
Text box
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Maximum
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Text Entry

Examples of project-specific community
engagement related to past investment
decisions include:

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NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

Persons, and/or residents of Low-Income
Communities. Please note that simply consulting
with the Advisory Board is not an example of
community engagement. Provide 1-2 examples
of past investment decisions.

Question Notes

Field Type

• Consulting with a local government economic
development agency, or local neighborhood
organization and/or business association
regarding projects; and

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characters

• Receiving community feedback on projects at
local public hearings, charrettes, or through
community surveys.
(d) Discuss the portion of the Applicant’s planned
NMTC financings/investments described in
Question 17 that align with or contribute to goals
identified by a broader community or economic
development strategy (e.g., neighborhood
revitalization plan, county or state economic
development plans, local strategies to remediate
environmental contamination or reduce
greenhouse gases, strategies to build
intergenerational wealth, etc.). Please describe
how one or more of the Applicant’s planned
QLICIs will contribute to the goals of such
strategies or initiatives.

Text Entry

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NMTC Allocation Application Template for Public Comment – July 2024

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

Question Text

28. Organizational
Chart and Key
Personnel

(a) Submit organizational
chart(s) that depict the
following:
• The Applicant’s
relationship to its
Controlling Entity, as
well as any Affiliate,
Subsidiary entities, or
any entities with an
ownership interest in the
Applicant (if applicable);
and

Response
Upload attachment

Question Notes

Field Type

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

Attachment

• The Applicant’s staff
structure (i.e., the
names and titles of key
personnel that will have
a direct role in managing
the NMTC Allocation),
including names of the
Applicant’s Advisory
Board and Governing
Board members, key
board committees, and
consultants; and
• The names of
Controlling Entity
Governing Board
members, and names of
staff members shared
with Affiliates, including
Controlling Entity
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NMTC Allocation Application Template for Public Comment – July 2024

Question Number

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

Response
Table

Question Notes

Field Type

Be sure to identify the Applicant’s (and Controlling Entity’s)
personnel and any and all consultants that will have a
direct role in assisting the Applicant in managing an NMTC
line of business, including consultants who assisted in
preparing the Allocation Application.

Table C2

The Applicant should limit its personnel to individuals that
will have a direct role managing the requested allocation.
The Applicant should not include the names of staff that will
support or assist in managing the requested allocation.
Also, please note that Table C2 is limited to 15 individuals
and that individuals listed in Table C2 should also be
reflected in the organizational chart(s) in Q. 28(a).

• Providing QLICIs–
identifying and
underwriting
transactions; structuring
NMTC loans and Equity
Investments; and/or
providing FCOS;
• Raising Capital from
Investors – including
raising tax credit equity
and leveraged debt if
the Applicant will use
the leveraged
investment model;
• Asset and Risk
Management; and
NMTC Program
Compliance.
(c) If the Applicant has
received an Allocation in
CY 2021, 2022, or 2023,
has there been any
notable changes to the
Applicant’s key personnel?

☐ Yes
☐ No
☐ Not Applicable

The most recent funding rounds are CY 2021, 2022, and
2023.

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Applicants should only report any notable changes to key
personnel that were included in Table C2 of the previously
awarded Allocation Application.
Applicants must also submit a Material Event Form if
required to do so by its Allocation Agreement(s) or Award
Agreement(s) with the CDFI Fund.
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NMTC Allocation Application Template for Public Comment – July 2024

Question Number

29. Providing
QLICI’s

Question Text

Response

(d) If ‘Yes’ to (c), provide a
brief description of the
change(s) making sure to
address: (1) the
circumstances; and (2) the
qualifications of the new
individual(s) that filled the
role.

Text Entry

(a) Referencing information
from Table C2 as
necessary, describe the
current roles and
responsibilities of the
Applicant’s (and
Controlling Entity’s) key
personnel (including staff,
Governing or Advisory
board members, and
consultants) in:
• Identifying borrowers or
investees and
evaluating their ability to
remain financially viable
and operational for the
term of the QLICI;

Question Notes

Field Type
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(Maximum
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Text Entry

The CDFI Fund expects the Applicant’s personnel to have
relevant experience in the types of activities the Applicant
intends to pursue with its NMTC Allocation – particularly in
situations where the Applicant (or its Controlling Entity)
lacks prior organizational performance in providing loans or
Equity Investments and related functions (e.g. monitoring
loan repayments or dividend payments, managing
disbursement of construction draws, etc.).

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An Applicant will be evaluated more favorably under this
sub-section if it can also demonstrate that its personnel
have experience identifying borrowers or investees in LICs:
evaluating business to determine long-term sustainability;
and structuring QLICIs or providing FCOS that meet the
needs of LIC borrowers/investees.

• Structuring its current
loans and/or equity and
providing Financial
Counseling and Other
Services (if applicable).
• Please indicate the
percentage of work
currently performed by
consultants, internal
staff, and board
members on the
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NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

Question Notes

Field Type

activities referenced in
this question.
(b) Describe how the
Applicant will manage the
addition of NMTC
financing activities into its
current portfolio of
activities, specifically:

Text Entry

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• If the roles and
responsibilities
described in Question
29(a) will change, be
sure to describe such
changes;
• Indicate the percentage
of work to be performed
by consultants, internal
staff, and/or board
members; and
• Whether additional staff
(or consultants) will
need to be hired.
30. Asset and
Risk
Management
Experience

(a) Describe the current roles
and responsibilities of the
Applicant’s (and
Controlling Entity’s) key
personnel, consultants
and board members in
managing the assets to be
financed with an NMTC
Allocation and associated
risks. The Applicant
should reference
personnel’s prior
experience from Table C2

Text Entry

Each Applicant must demonstrate that it has the capacity
and relevant experience to manage the types of assets it
intends to invest in with the requested NMTC Allocation, as
well as monitor the QALICB’s use of NMTC proceeds (e.g.,
construction, equipment purchase, etc.) and control
associated risks (e.g., loan repayments, cash distributions
to the investment fund, leverage lenders, etc.)

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An Applicant will be evaluated favorably under this subsection if it has experienced personnel and appropriate
procedures and systems in place to successfully manage a
loan and/or investment portfolio, including informational

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

as necessary. Be sure to
indicate the percentage of
work completed or
expected to be completed
by consultants, internal
staff, and board members.

Field Type

and performance aspects of administering such assets or
pools of similar assets.

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

Text Entry

• Explain how the
organization will ensure
that QLICI proceeds are
used to finance the
assets for which they
are intended and
identifies borrowers at
greater risk (e.g., risk
rating system for a loan

Question Notes

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NMTC Allocation Application Template for Public Comment – July 2024

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Field Type

portfolio, QALICB
reporting, etc.) and how
the Applicant responds
when assets are at
greater risk.
• Indicate if the Applicant
(or Controlling Entity)
has written asset
management and
collection policies and
whether it has ever
deviated from those
policies in the past five
years and, if so, why.
• Address the Applicant's
strategy for minimizing
defaults and managing
delinquencies to
mitigate against writedowns or write-offs
going forward.
(d) For the Applicant (or
Controlling Entity),
complete Table D1
(Investment Portfolio) and
discuss the Applicant’s (or
Controlling Entity’s)
delinquency rate(s) as of
the Allocation Application
release date for each
major asset class as well
as its default rate (writeoffs) over the past three
years for each major asset
class. Also:

Table
Text Entry

Table D1
Delinquency rate means the percentage of loan payments
and mandatory dividend payments, on a dollar basis, that
were 90 days past due (i.e., the combined dollar amount of
principal, interest and mandatory dividend payments, 90
days or more past due divided by the total dollar amount of
loans and Equity Investments outstanding).

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• Describe the trends in
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NMTC Allocation Application Template for Public Comment – July 2024

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Question Text

Response

Question Notes

Field Type

offs, and defaults as
shown in Table D1.
• Explain the reasons for
any negative results
such as an increase or
unusual spikes in
delinquencies or writeoffs that have occurred.
• Describe the measures
the Applicant (or its
Controlling Entity) has
taken to address
delinquencies, including
loan restructurings, and
write-offs.
• If the Applicant, or its
Controlling Entity, is a
regulated financial
institution, please
compare delinquency
and default rates with
the appropriate peer
group.
(e) Discuss any delinquent,
defaulted, or impaired
loans or Equity
Investments from prior
NMTC investments in the
last ten years, specifically:

Text Entry

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• Provide the total value
of each investment, the
allocation year, as well
as the total number of
days delinquent and the

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

Question Notes

Field Type

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

Text box

amount charged off, if
applicable.
• Discuss the Applicant’s
strategies for managing
these troubled
investments, including
any work-out strategies
(e.g. restructuring,
forbearance
agreements, etc.), as
well as any
administrative changes
implemented to
minimize future
delinquencies and writeoffs.
31. Program
Compliance
Experience

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

Text Entry

(Maximum
Response
Length:
3,000
Characters)

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

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

Response
Text Entry

Question Notes

Field Type
Text box
(Maximum
Response
Length:
7,000
Characters)

• At least 85% of the
proceeds of the QEIs
are invested in QLICIs in
accordance with the
NMTC Program Income
Tax Regulations. If the
Applicant is providing
loans or investments to
another CDE, how will it
ensure that the
secondary CDE fulfills
its investment
requirements?
• The businesses that the
Applicant invests in are
QALICBs, in accordance
with the NMTC Program
Income Tax
Regulations. If
purchasing a portfolio of
loans, how will the
Applicant ensure that it
purchases loans that are
QLICIs?
71

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

Question Notes

Field Type

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

(a) If the Applicant, its
Controlling Entity, or any
of its Affiliates is an
insured financial
institution that receives
Community Reinvestment
Act (CRA) ratings from
regulators, has the
organization received
CRA ratings within the
past five years?
(b) Is the Applicant,
Controlling Entity, or any
Affiliate a federallyregulated thrift, bank,
bank holding company, or
credit union (Y/N)?” If “Y”
is selected, please
complete the following
chart Question 32c,
below:
(c) Regulated Entity
Information:

☐ Yes

Dropdown
Menu

☐ No

☐ Not Applicable

☐ Yes

Dropdown
Menu

☐ No

☐ Not Applicable

Report all federally regulated entities that are affiliated with
the Applicant. Use ‘Add Row’ to list as many as applicable.
72

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text
Record No.

Response

Question Notes

Field Type

Text Entry

Enter a number to identify the Entry - Example 1,2,3,4 etc.

Numerical
(Maximum
Response
Length: 5
Characters)

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

Organization Name

☐ Applicant

☐ Controlling Entity

Dropdown
Menu

☐ Affiliate

Text Entry

Text box
(Maximum
Response
Length: 100
Characters)

☐ Yes

Dropdown
Menu

State

Select State or US Territory

Dropdown
Menu

City

Text Entry

Text box

Is this entity a Holding
Company?

☐ No

(Maximum
Response
Length: 50
Characters)
Federal Regulator

☐ FDIC

☐ FRB

Dropdown
Menu

☐ NCUA
73

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

Question Notes

Field Type

☐ OCC
FDIC /NCUA
Charter/FRB Certification
or OTS Docket #

33. Financial
Health

Answer the following
questions regarding the
Applicant’s (or the Controlling
Entity’s) financial health.
Indicate if the responses are
(check one):

Text Entry

Text box
(Maximum
Response
Length: 50
Characters)

☐ For the Applicant (if it
has incurred operating
expenses).

Dropdown
Menu

☐ For the Controlling Entity
(if the Applicant has not
yet incurred operating
expenses).
☐ Not applicable (neither
the Applicant nor the
Controlling Entity has
incurred operating
expenses).

(a) Have the financial
statements for the last
complete fiscal year been
independently audited or
is an audit underway?

☐ Yes

☐ No

Dropdown
Menu

☐ N/A

Please provide fiscal year
end date for the last
completed independent
audit (mm/dd/yyyy).

Text Entry

If no audit has been
completed or is underway
for the last complete

Text Entry

Text box
(Maximum
Response
Length: 10
Characters)
Text box
(Maximum
Response
74

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

fiscal year, please explain
why and what steps the
Applicant, or its
Controlling Entity, is
taking to obtain audited
financials in the future:
(b) If “Yes”, have any of the
Applicant’s, and its
Controlling Entity’s,
completed audits within
the past three years (or, if
shorter, for the period
from inception) indicated
any of the following:

Question Notes

Field Type
Length:
2,000
Characters)

☐ Yes

☐ No

Dropdown
Menu

1. An opinion other than
unqualified?
2. A going-concern
paragraph?
3. Repeated findings of
reportable
conditions?
4. Material weaknesses
in internal controls?
If “Yes” to any of the
above, indicate the fiscal
years of the occurrences
and describe the
circumstances and
corrective action(s) being
taken:

Text Entry

Text box
(Maximum
Response
Length:
2,000
Characters)

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text
(c) Have the Applicant’s, and
its Controlling Entity’s
financial statements
shown positive net
income (or if a non-profit,
positive change in net
assets) for each of the
last three years, or if in
business for less than
three years, for the period
of time it has operated?
If “No”, please explain the
circumstances, indicate
the fiscal year in which
this occurred, and
describe the corrective
action being taken:
(d) Is the Applicant (and
Controlling Entity) aware
of any non-compliance
issues cited since the
issuance of its most
recent audited financial
statements or
Management’s Annual
Report on Internal
Controls Over Financial
Reporting?
If “Yes”, please explain
the circumstances and
describe the corrective
action being taken:

Response
☐ Yes

☐ No

Question Notes

Field Type
Dropdown
Menu

☐ N/a

Text Entry

Text box
(Maximum
Response
Length:
2,000
Characters)

☐ Yes

Check box

☐ No

Text Entry

Text box
(Maximum
Response
Length:
2,000
Characters)
76

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

34. Fee Structure

Question Text

Response

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

Text Entry

(a) Complete Table D2:
Based on the projections
in Exhibit A, for each
Financial Product
identified in Question 14,
provide an itemized list of
the individual fees that
represent the Fee
Structure the Applicant
anticipates will typically
apply to the proposed
NMTC investments and
result in compensation to
the Applicant (or
Controlling Entity),
Affiliates, Subsidiary
CDEs, or unaffiliated third
parties.

Table

(b) Description of Table D2:
In the narrative below, for
each Financial Product
identified in Question 14,
explain how the Applicant
determined that the Fee
Structure and Average
Fee Percentage are
appropriate for the

Text Entry

Question Notes

Field Type
Text box
(Maximum
Response
Length:
1,000
Characters)

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

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

Table D2

Text box
(Maximum
Response
Length:
4,000
Characters)

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

investment strategy
described in this
Allocation Application

Question Notes

Field Type

from the QEI proceeds, paid from QLICI proceeds, or
retained from the tax credit equity at the end of the
NMTC compliance period.
• Applicants that plan to charge exit fees must quantify
the amount and describe the circumstances that
determine when such fees will be charged, as well as
the frequency these events will occur.
Applicants that plan to retain all or a portion of the tax
credit equity at the end of the NMTC compliance period
must quantify the amount, as well as describe the
circumstances and frequency.

(c) Complete Table D3
based on the projected
activities reflected in
Exhibit A and fees
described in Question
34(b) and Table D2.

Table

The narrative response in Question 34(c) should clearly
describe the assumptions and calculations used to derive
each income and expense line from Table D3 in a way that
CDFI Fund staff will be able to easily understand, quantify,
and evaluate. The Applicant should indicate whether it is
using cash or accrual methods of accounting. Table D3
should be completed using the Applicant’s fiscal year
indicated in Question 2(h) (see the Application FAQ).

Table D3

Text Entry

If the Applicant has engaged (or intends to engage) any
third parties (e.g., consulting firms) that will receive any
NMTC related income from the Applicant, QEI proceeds,
QALICBs, or investors, the Applicant must disclose,
describe and include this compensation as an offsetting
income and expense of the Applicant in Table D3. It must
also be clearly described in the response to Question
34(c).

Text box
(Maximum
Response
Length:
5,000
Characters)

Based on the projections
in Table D3:
• Describe the Applicant’s
projected sources of
income and expense(s)
associated with
administering the
Applicant’s NMTC line of
business and how the
Applicant will be able to
sustain this line of
business, consistent
with its overall business
strategy, including its
timeline for making
investments.
• QLICI interest and
dividend payments

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

Question Notes

Field Type

should be described as
income. If all or a portion
of the QLICI interest or
dividend payments will
be passed through the
investment fund to
investors or leverage
lenders, then describe
those payments as an
off-setting expense.
• If the Applicant will use
existing resources (e.g.,
accumulated cash
balances), third parties
as a source of operating
income (e.g., grants or
loans), or in-kind
contributions (e.g. use of
personnel, back office
systems), describe the
Applicant’s progress in
securing firm
commitments;
• Explain how the
Applicant would address
any operating deficit.
(e.g., income or loan
from Affiliates or
alternate sources,
reduce scope of
activities, use reserves,
etc.).

NMTC Allocation Application Template for Public Comment – July 2024

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

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

Question Number
35. Track
Record of
Raising
Capital

Question Text
(a) Describe the track record of
the Applicant (or its Controlling
Entity) raising capital from
third-party sources, particularly
equity capital at market or
near-market rates between
January 1, 2019, and the
release date for the NMTC
Allocation Application. Be sure
to quantify the five-year total
and subtotals, distinguishing
between raising capital from
profit-motivated investors; from
government or philanthropic
sources of capital; or using tax
credits as an incentive.

Response
Text Entry

Question Notes

Field Type

The Applicant should only discuss its track (or its
Controlling Entity) in Question 35.

Text box
(Maximum
Response
Length:
5,000
Characters)

The Applicant may also refer to the qualifications and fiveyear capital-raising track record of the Applicant’s (or its
Controlling Entity’s) key personnel in Table C2, or
individuals (e.g., board members, Principals, consultants)
listed in Table C1 for organizations other than the
Applicant (or its Controlling Entity) in Question 35.
Reference information provided in Table C2 as
appropriate.
The release date for the NMTC Allocation Application is
specified in the Application FAQ document.

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

36. Investment
Partnerships

(a) Does the Applicant intend to
secure investments from
partnership entities that will
leverage non-Equity
Investments (e.g., debt, grant
dollars) from outside of the
partnership to increase the tax
credit yield for members of the
partnership?

☐ Yes

(b) If Yes, provide the percentage
of equity versus non-Equity
investments for all such
investor partnerships based on
the Applicant’s requested
NMTC Allocation.
37. Investment
Strategy

(a) Has the Applicant or its
Affiliates, either directly or
through Subsidiary CDE(s),
received QEIs from investors in
amounts equal to or greater
than the Allocation request in
Question 1 between January 1,
2019, and the release date for
the NMTC Allocation
Application (specified in the
NMTC Application FAQ
document)?

☐ No

Question Notes

Applicants planning to use the leverage model to raise
QEIs for all or a portion of their allocation should select
“Yes”

___% Equity
Investments

Field Type
Dropdown
Menu

NumericalPercentage

___% Non-Equity
Investments
☐ Yes, Questions
37(b) and 37(c) will
not apply
☐ No, complete
Question 37(b) and
37(c)

Applicants (or Affiliates) that select “No” to Question 37(a)
and have received QEIs in amounts less than the
Allocation request in Question 1, between January 1,
2019, and the release date for the NMTC Allocation
Application, are required to complete Question 37(b) and
37(c).

Dropdown
Menu

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

Question Notes

Field Type

(b) If “No” to Question 37(a)
above, complete Table E1 and
provide investor Commitment
letters; Letters of
Interest/Intent.

Upload attachment

All Applicants that answered “No” to Question 37(a), are
required to submit documentation demonstrating proof of
investor interest (e.g., Commitment letters; Letters of
Interest/Intent). Investor letters should identify whether the
investor will make a direct investment in the CDE or into a
partnership.

Attachment

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text
(c) If the Applicant responded “No”
to Question 37(a), Discuss the
extent to which the Applicant
may raise capital from equity
and/or debt investors not listed
in Table E1.

Response
Text Entry

Question Notes

Field Type

If the Applicant plans to source non-Equity Investments
from sources that are specific to particular QALICBs, the
Applicant should discuss this strategy in the response to
Question 37(c) to the extent that it may invest in QALICBs
that have not yet been identified at the time of the
Allocation Application.

Text box
(Maximum
Response
Length:
5,000
Characters)

• Applicants that intend to
raise QEIs using the
leverage structure must also
describe potential sources of
leveraged debt related to
their planned NMTC
investments (described in
Question 17), including the
percentage of leverage debt
that is anticipated to be
sourced from the QALICB or
Affiliates of the QALICB.
• If Table B1 includes nonNMTC direct
loans/investments deployed
by the Applicant or
Controlling Entity, quantify
and describe the three
largest sources of capital
used for such
loans/investments and the
types of businesses
financed.
38. Investors
Identifying
Transactions

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

☐ Yes

☐ No

Dropdown
Menu

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

(b) Will the Applicant receive any
QEIs from Affiliates?

☐ Yes

Question Notes

Field Type
Dropdown
Menu

☐ No

Text Entry

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

Text box
(Maximum
Response
Length:
2,000
Characters)

Text Entry

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

Text box
(Maximum
Response
Length:

• The name of each such
equity investor or non-equity
provider;
• The role of each equity
investor or non-equity
provider with respect to
locating, underwriting, and
structuring each investment;
• Whether each equity investor
or non-equity provider offers
similar products or services
already; and
• If applicable, the extent to
which the Applicant will offer
products with more favorable
rates or terms than those
currently offered by the
equity investor or non-equity
provider, and/or will target its
activities to areas of greater
economic distress than those
currently targeted by the
equity investor or non-equity
provider.
39. Distribution
of Benefits

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

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text
i.

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

ii.

the Applicant (or its
Subsidiaries/Affiliates),
through economic returns
(including fees).

iii.

the QALICB
investees/borrowers,
through lower costs of
capital;

iv.

if applicable, the
unaffiliated end-users
through lower costs (e.g.,
lower tenant lease rates).

Response

Question Notes

Field Type
5,000
Characters)

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

Text Entry

Text box
(Maximum
Response
Length:
3,000
Characters)

(c) If the Applicant generates a
profit from its overall NMTC
activities, discuss how this
profit will be used (e.g., dollar
amount or percentage of profit
that will be distributed to
investors or shareholders,

Text Entry

Text box
(Maximum
Response
Length:
2,000
Characters)
85

NMTC Allocation Application Template for Public Comment – July 2024

Question Number

Question Text

Response

Question Notes

Field Type

support additional NMTC or
non-NMTC Low-Income
Community investments,
support other activities of the
Applicant or Affiliates, etc.).
(d) If at least one proposed
investment will involve two or
more unaffiliated CDEs, please
describe the total number of
planned co-investments with
other CDEs. Please describe
the factors that lead to coinvesting with other CDEs and
benefits to the QALICB and/or
unaffiliated end-users.

Text Entry

Text box
(Maximum
Response
Length:
2,000
Characters)

NMTC Allocation Application Template for Public Comment – July 2024

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

Question Number

Question Text

Response

40. Percent of
QEIs
Invested as
QLICIs

Will more than 85% of the QEI
proceeds be invested/re-invested
in QLICIs?

☐ Yes

If yes, what percentage?

___% of the
QEI proceeds

An Applicant that indicates in Question 40 “yes” and provides a
percentage greater than 85% will be required to meet the
percentage identified above, and such requirement will be a term
of its Allocation Agreement.

NumericalPercentage

41. Minimum
Request
Amounts

Is there an absolute minimum
amount below which the
Applicant would be unwilling to
accept an NMTC Allocation?

☐ Yes

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

Dropdown Menu

If yes, please provide the amount.

$_____

Describe how this amount was
determined. Be sure to address
why the Applicant could not
administer a smaller award.

Question Notes

Field Type
Dropdown Menu

☐ No

Text Entry

Numerical-Dollar
Amount
Text box
(Maximum
Response Length:
1,000 Characters)
87

NMTC Allocation Application Template for Public Comment – July 2024

PART V: INFORMATION REGARDING PREVIOUS AWARDS
Information in Part V is not scored during the Phase I stage of the Application review. Information provided in this section will be evaluated during the
Phase II stage of the Application review. For more information on the NMTC Allocation Application review process, please consult the NOAA.
NOTE: Receipt of a prior award or allocation through any of the CDFI Fund's programs will not affect the likelihood of an Applicant receiving an NMTC
Allocation in this round. The CDFI Fund will examine the compliance status of Applicants (or their Affiliates) that have previously received CDFI Fund awards
or allocations.
NOTE: The CDFI Fund will review transaction-level data submitted by Applicants that are prior year Allocatees through AMIS and may seek additional
information from Applicants to determine whether activities and the QLICIs made were consistent with the transactions and activities proposed in the relevant
prior-year Allocation Application(s).

Question Number

Question Text

42. CDFI Fund
Award
Status

Has the Applicant and/or any of its
Affiliates previously received a
financial award (not including an
NMTC Allocation) from the CDFI
Fund?

Response

Question Notes

Field Type

If Yes, please ensure that the award(s) is listed in the
table. If an Affiliate of the Applicant has received a
financial award and it is not listed in the table, please
return to the Applicant’s Organization Profile in AMIS
and ensure that the Affiliate is listed in
the Affiliate section. Please see the CY 2024 NMTC
Program AMIS Navigation Guide (Section 6.0) on how
to associate Affiliates with your AMIS Organization
Profile.
The following three fields are prepopulated in AMIS.
There are separate entries for every financial award
received from the CDFI Fund.

Name of Award Recipient

Name of Award
Recipient Displays

This field is prepopulated from the AMIS Profile and
locked.

Prepopulated

NMTC Allocation Application Template for Public Comment – July 2024

Award Control Number

Award Control
Number Displays

This field is prepopulated from the AMIS Profile and
locked.

Prepopulated

Total Award Amount

Award Amount
Displays

This field is prepopulated from the AMIS Profile and
locked.

Prepopulated

Is the Award information complete?

☐ Yes

You must select Yes to the question for this subsection to be marked as complete.

Dropdown Menu

☐ No
43. NMTC
Allocation
Status

Has the Applicant and/or any of its
Affiliates received an NMTC
Allocation from the CDFI Fund in a
prior allocation round?

If Yes, please ensure that the allocation(s) is listed in
the table. If an Affiliate of the Applicant has received an
NMTC Allocation and it is not listed in the table, please
return to the Applicant’s Organization Profile in AMIS
and ensure that the Affiliate is listed in the
Affiliate section. Please see the CY 2024 NMTC
Program AMIS Navigation Guide (Section 6.0) on how
to associate Affiliates with your AMIS Organization
Profile. You must select Yes to the question below for
this sub-section to be marked as complete.
Please note that Applicants and/or any Affiliates that
have shared Control of a CDE (or Subsidiary of a CDE)
that is a prior round Allocatee should answer “Yes” to
Question 45 and provide requested responses.
Applicants providing responses to Question 45 need
only make one entry per Allocatee, per award for which
the Applicant has provided QEIs regardless of the
number of individual QEIs made to that Allocatee under
a single award. For example, if an Applicant has made
10 QEIs in Allocatee X under its second round
allocation, then the Applicant would provide the
aggregate amount of those 10 QEIs in its response to
Question 45.
89

NMTC Allocation Application Template for Public Comment – July 2024

The following three fields are prepopulated in AMIS.
There are separate entries for every NMTC Allocation
received from the CDFI Fund.
Name of Allocatee

Name of Allocatee
Displays

This field is prepopulated from the AMIS Profile and
locked.

Prepopulated

Award Control Number

Award Control
Number Displays

This field is prepopulated from the AMIS Profile and
locked.

Prepopulated

Total Allocation Amount

Total Allocation
Amounts Displays

This field is prepopulated from the AMIS Profile and
locked.

Prepopulated

Is the Award information complete?

☐ Yes

You must select Yes to the question for this subsection to be marked as complete.

Dropdown menu

☐ No
44. Prior NMTC
Investments

Have you received previous
allocations?*
If the Applicant answered Yes to
Question 43, briefly explain the
current status of its previous
allocation award(s). Be sure to
address the following:
(a) If the Applicant has made
QLICIs, describe the types of
transactions that have been
financed to date. The Applicant
must discuss the projects that
received the largest QLICIs in
each of the Applicant’s three
most recent Allocations, as of
the Allocation Application
release date. If a single project
received the QLICIs from more

☐ Yes

Dropdown menu

☐ No

Text Entry

For each project identified, describe how NMTC
proceeds were used, including:
• How the CDE ensured that the NMTCs allocated
did not exceed the amount necessary to assure
project feasibility.

Text Box
Maximum
Response
Length: 10,000
characters

• Efforts to secure alternative sources of capital in
the marketplace in order to complete the project.
• Any community outcomes or benefits that were
generated as a result of the transaction.
• The source(s) and amount(s) of leveraged debt
from all sources (including the percentage of
leverage sources derived from the QALICB,
Affiliates of the QALICB and/or Project Sponsor), if
any.
90

NMTC Allocation Application Template for Public Comment – July 2024

than one of the past three
awards, see the FAQ Document
(Information Regarding
Previous Awards Section) for
more details. If the Applicant
has received less than three
Allocations, it should discuss
the three projects that received
the largest investments in the
last five years. See Application
FAQ for additional guidance.

• The Fee Percentage and Fee Structure for each
project. The Applicant should provide the total Fee
Percentage and Fee Structure by listing the
individual fees applicable to each project using the
categories listed in Table D2 which are: (1) Type –
Upfront, Ongoing, Backend; (2) Source (Payer) –
Investor or Investor Affiliate, QALICB or QALICB
Affiliate fees or interest, Other; and (3) Recipient –
Applicant or Applicant Affiliate, Investor or Investor
Affiliate, Unaffiliated Third Party.

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

Text Entry

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

Text Entry

(d) To the extent the Applicant’s
past transactions have been
structured to allow QALICBs to
acquire a portion of QLICIs
through a put/call option at the
end of the seven-year credit

Text Entry

Text box
Maximum
Response
Length: 3,000
characters

Text box
Maximum
Response
Length: 2,000
characters
91

NMTC Allocation Application Template for Public Comment – July 2024

period, please quantify the
value of the investment
acquired by the QALICBs at the
end of the seven-year credit
period both as a dollar amount
and as a percentage of total
QLICIs.

45. Investment
or Control of
Previous
Allocatees

(e) Discuss whether the activities
undertaken with the NMTC
dollars were consistent with the
Notable Relationships
presented in the relevant
Allocation Application. If the
activities were not consistent
with the relevant Allocation
Application, describe the
inconsistencies

Text Entry

Has the Applicant and/or any of its
Affiliates assumed Control (not
resulting from unwinding of a
transaction) of one or more CDEs
(or Subsidiary CDEs) that received
an NMTC Allocation in a prior
round?

☐ Yes

Record Number

Text box
Maximum
Response
Length: 2,000
characters

☐ No

If ‘Yes’, list the allocation(s) and total QEIs invested per
allocation in the table above. Only include
those CDEs (or Subsidiary CDEs) where
the Allocatee and/or any of
its Affiliates assumed Control not resulting from the
unwinding of a transaction. The Applicant may use
additional space as necessary.

Check box

Report every CDE that the Applicant has assumed
Control of. Use ‘Add Row’ to list as many as applicable.
Text Entry

Text box
Maximum
Response
Length: 5
characters

Name of Allocatee

Text Entry

Text box
Maximum
Response
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NMTC Allocation Application Template for Public Comment – July 2024

Length: 50
characters

Award Control Number

Text Entry

Text box
Maximum
Response
Length: 11
characters

Total QEI Amount Invested

Text Entry

Numeric
Maximum
Response
Length: 14
characters

NMTC Allocation Application Template for Public Comment – July 2024

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

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

NMTC Allocation Application Template for Public Comment – July 2024

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

Total # transactions to be financed

Total $ amount of financing

2025

2026

2027

2028

2029

Total

$ Amount of financing (debt)

$ Amount of financing (equity)

Total # of reinvestment transactions

Total $ amount of reinvested financing

$ Amount of reinvested financing (debt)

$ Amount of reinvested financing (equity)

NMTC Allocation Application Template for Public Comment – July 2024

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

Total # transactions to be financed

Total $ amount of financing

2025

2026

2027

2028

2029

Total

$ Amount of financing (debt)

$ Amount of financing (equity)

Total # of reinvestment transactions

Total $ amount of reinvested financing

$ Amount of reinvested financing (debt)

$ Amount of reinvested financing (equity)

NMTC Allocation Application Template for Public Comment – July 2024

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

Total # selling CDEs

Total # of loan portfolios purchased

Total # of loans purchased

Total $ amount of loan purchases

Total # of loans purchased via reinvested financing

Total $ amount of loans purchased via reinvested
financing

2025

2026

2027

2028

2029

Total

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

2025

2026

2027

2028

2029

Total

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

Total estimated hours spent counseling or providing
other services per year

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

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

NMTC Allocation Application Template for Public Comment – July 2024

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

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

Rows n through p, Applicants must select each option that applies to the transaction.

NMTC Allocation Application Template for Public Comment – July 2024

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

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

(b) Address

City [Text]
State [Picklist]

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

(11-digit number)

(d) Located in a Non-Metropolitan
County?

[Yes/No]

(e) Projected QLICI Closing Date

[Drop Down: 2025, 2026, 2027, 2028, 2029, 2030]

(f) Total Project Costs

(g) Total Applicant QEI

(h) Total Applicant QLICIs

(i) Total Non-QLICI Sources

(j) Total QEIs from unaffiliated CDEs

(Single-Tract or Multi-Tract)

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

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

NMTC Allocation Application Template for Public Comment – July 2024

TABLE A5: PROPOSED TRANSACTIONS
(m) Small Dollar and/or Revolving
Loan Fund

[Yes/No]

(n) Business Type

[Check all that apply]

-Hospitality/Tourism

-Cultural

-Manufacturing/Industrial

-Education/Training

-Mixed-Use Real Estate

-Healthcare

-Office Space

-Multi-Service Community Organization/Social Services

-Consumer Retail/Services

-For-Sale Housing

-Business Services
-Utilities/Energy Generation
-Infrastructure
-Other _________________

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

[Check all that apply]

-Leasehold Improvements/Buildouts

-Acquisition

-Equipment Purchase and Installation

-Construction

-Inventory Purchase

-Rehabilitation

-Other _____________________

-Working Capital
(p) Targeted Community Outcomes

[Check all the apply]

- Community Goods or Services to Low-Income Communities

- Job Related

- Financing Minority Businesses

- Commercial Goods or Services to Low-Income Communities

- Financing Native Businesses
- Housing Units
- Environmentally Sustainable Outcomes

100

NMTC Allocation Application Template for Public Comment – July 2024

EXHIBIT B: TRACK RECORD OF ACTIVITIES
Instructions for Exhibit B: Applicants must complete the Tables B1-B3 in Exhibit B for the Applicant’s (or Controlling Entity’s) track record of loans and/or
Equity Investments to Real Estate and Operating Businesses (excluding Restricted NMTC Business Activities), loans or Equity investments to CDEs, or
purchasing loans from CDEs. Applicants must complete Table B4 for any loans/investments that do not directly correspond to the activities in Question 13
(e.g. Restricted NMTC Business Activities, loans and/or investments in NMTC investment funds or non-CDE financial institutions, personal or consumer
loans, and residential mortgages). If the Applicant’s or the Controlling Entity’s track record includes the provision of grants to entities, including real estate,
Operating Businesses, and/or CDEs, do not include these activities in Tables B1-B4 or discuss in the narratives for Questions 20 or 21.
When completing a given table, for each annual column, Applicants should report on the totality of historical loans and Equity Investments for the period
2019-2024 YTD. Please be aware of the allowable financing activities for each table in Exhibit B. All types of business lending, except for Restricted NMTC
Business Activities, should be listed in Tables B1-B3, regardless of the size of the investment or geographic location of the investment. Similarly, the
Applicant’s track record of Financial Counseling and Other Services (FCOS) provided to businesses should be described in the narrative response to
Question 20. Per the 2024 Allocation Application glossary, FCOS is advice provided by a CDE relating to the organization or operation of a trade or
business. See 26 CFR 1.45D-1(d) (7) for more guidance. In the columns “Total to DBCs (2019-2024),” Applicants should report the amount of their overall
loans or Equity Investment that are directed to Disadvantaged Businesses or Disadvantaged Communities.
An Applicant must provide information for the years referenced in the tables or for as many years as the Applicant (or Controlling Entity) has been in
operation, if it has been in operation for fewer than five years. An Applicant, at its discretion, may choose to rely upon the track record of its Controlling
Entity. In order to list the track record of the Controlling Entity in Exhibit B, the Applicant must designate a Controlling Entity in Question 3. If
the Applicant chooses to complete the tables in Exhibit B with information from the Controlling Entity, it must also use the Controlling Entity for
populating Table D1.

101

NMTC Allocation Application Template for Public Comment – July 2024

NOTE for Exhibit B, Tables 1-4:
1) Where indicated in Table B1, enter the dollar amount of debt financing provided by the Applicant (or Controlling Entity) in row 2a. In row 2b, enter the
dollar amount of equity financing provided by the Applicant (or Controlling Entity). Enter all financing from other sources (excluding grant dollars) in row
3. Row 2 will automatically calculate based on your entries in rows 2a and 2b. The Applicant may discuss in Question 20 any role the Applicant (or
Controlling Entity) played in leveraging or facilitating financing for which it did not provide direct financing.
2) Grants provided by the Applicant (or Controlling Entity) must be excluded from Tables B1 – B4. Equity investments into non-profit organizations are
considered grants (per the definition of Equity Investment in the application glossary).
3) Do not include tax credit equity raised as QEIs from investors in Table B1 or Table B2. Row 2(b) in Table B1 should only include equity financing
provided to Real Estate and Operating Businesses (excluding NMTC Restricted Business Activities). Row 4 in Table B2 should only include equity
financing provided to other CDEs.
4) For the purpose of completing Tables B1-B4, the Applicant must choose to either use its own track record or that of its Controlling Entity. If the
Applicant chooses to use its own track record it must include, in the aggregate, the financing track record of all Subsidiaries of the Applicant and may
not include any of the Controlling Entity’s activities. However, if the information in Tables B1-B4 reflects the activities of the Controlling Entity, the
information must include, in the aggregate, the financing track record of all Subsidiaries of the Controlling Entity, including the Applicant if the Applicant
is a Subsidiary of the Controlling Entity. The Applicant must discuss track records of both the Applicant and Controlling Entity in the narrative to
Questions 20 or 21 (as applicable). The narrative should clearly distinguish between the track records of each entity.
5) The Applicant must distinguish between direct financing provided by the Applicant or its Controlling Entity, as entered in Table B1, row 2 and Table B4,
row 1 and indirect financing (financing provided by third-party sources), entered in Table B1, row 3 and Table B4, row 2. Applicants should not enter
the same data in more than one row.
6) Tables B1-B4 should be mutually exclusive. Applicants should not enter the same data in more than one Table in Exhibit B.
7) In the Column titled “2024 Year to Date (YTD),” the Applicant can only enter information on activities closed by the Applicant or Controlling Entity on or
before the release date of the Allocation Application (specified in the NMTC FAQ Document). The Applicant may not enter information on activities
planned or projected to close after the Allocation Application release date, including issued QEIs that have not resulted in QLICIs closed by the release
date of the Allocation Application. For additional details on completing Exhibit B, please refer to the NMTC Application FAQ document.
8) For Disadvantaged Businesses or Communities, please see the definitions in the Glossary for the new definition starting in CY 2024.

102

NMTC Allocation Application Template for Public Comment – July 2024

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

____Applicant

_____Controlling Entity

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

Calendar Year(s)
2019

2020

2021

Total # businesses financed

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

(a) $ Amount of debt financing provided
by Applicant

(b) $ Amount of equity financing
provided by Applicant

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

3
4

2022

2024
YTD

2023

Disadvantaged Businesses or Communities, see Glossary for full definitions.
Non-Metropolitan Counties, see Glossary for a full definition.
103

Totals
(20192024)

Totals to
DBCs 3
(20192024)

Totals to
NonMetro
Counties
4

(20192024)

NMTC Allocation Application Template for Public Comment – July 2024

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

Calendar Year(s)

2019

2020

2021

2022

2023

Totals
(20192024)

2024 YTD

Totals to
DBCs
(20192024)

Totals to
NonMetro
Counties
(20192024)

Total # CDEs financed

Total $ amount of financing

$ Amount of financing (debt)

$ Amount of financing (equity)

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NMTC Allocation Application Template for Public Comment – July 2024

TABLE B3: TRACK RECORD OF LOAN PURCHASES FROM OTHER CDES

Calendar Year(s)

1
2

2019

2020

2021

2022

2023

2024 YTD

Totals to
Non-Metro
Counties

Totals
(2019-2024)

Totals to
DBCs
(2019-2024)

(2019-2024)

Total # of loans
purchased
Total $ amount of
loans purchased

105

NMTC Allocation Application Template for Public Comment – July 2024

Table B4: TRACK RECORD OF LOANS/EQUITY INVESTMENTS THAT DO NOT DIRECTLY CORRESPOND TO THE SELECTIONS IN
QUESTION 13 (e.g. RESTRICTED NMTC ACTVITIES, LOANS OR INVESTMENTS IN NMTC INVESTMENT FUNDS, NON-CDE FINANCIAL
INSTITUTIONS OR INVESTMENT FUNDS, PERSONAL OR CONSUMER LOANS, AND RESIDENTAL MORTGAGES)
Totals to
Non-Metro
Counties

Calendar Year(s)
1

2019

2020

2021

2022

2023

2024 YTD

Totals to
Totals
DBCs
(2019-2024) (2019-2024) (2019-2024)

Total $ amount of direct
financing provided by the
Applicant

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

106

NMTC Allocation Application Template for Public Comment – July 2024

EXHIBIT C: STAFF AND BOARD QUALIFICATIONS
Instructions for Tables C1 and C2: The Applicant should complete Table C1 and Table C2 in their entirety. Please note that Table C2 allows the Applicant
to identify key personnel that have experience in multiple management areas. Applicant should discuss key personnel’s experience specific to Low-Income
Communities, where relevant. Table C2 is limited to 15 individuals. For each narrative response in Questions 29-31 and their corresponding sub-sections,
reference and discuss the combined management experience of all individuals listed in Table C2 as it relates to the Applicant’s management capacity in
that given area. An Applicant must also identify any consultant(s) contracted to write either portions or the entirety of its Allocation Application.

107

NMTC Allocation Application Template for Public Comment – July 2024

TABLE C1: LOW-INCOME COMMUNITY ACCOUNTABILITY
Board
Member
Name

Firm

Title at
Firm

Advisory or
Governing
Board
Member?

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

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

__ Advisory

__ Resident

__ Governing

__ Small business owner

__ Both

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

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

Yrs. on
Board

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

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NMTC Allocation Application Template for Public Comment – July 2024

TABLE C2: MANAGEMENT CAPACITY
Name

Firm

Title at
Firm

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

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

Position with Applicant
(Select all that apply)
__ Governing board (GB) chair

__ Capital-raising

__ GB member on loan/investment
committee

__ Capital deployment

__ Other GB member

__ Sourcing or loan underwriting

__ Advisory board member

__ Asset management

__ Executive Director or equivalent

__ Loan servicing

__ Chief Financial Officer or equivalent

__ NMTC Program compliance

__ Dir. of Lending/investing or
equivalent

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

__ Other key management

__ Legal services

__ Loan/investment Officer or
equivalent

__ Other (specify): _____________

__ Compliance Officer
__ Other finance staff
__ Contracted consultant
__ Other (specify):______________

109

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

NMTC Allocation Application Template for Public Comment – July 2024

EXHIBIT D: ASSET MANAGEMENT / INCOME & OPERATING EXPENSES
Instructions for Table D1: Table D1 should closely reflect the direct financing indicated in Exhibit B. For each of the fiscal years, indicate the total number
and dollar amount of loans and Equity Investments that are referenced in Question 20, Question 21 and Exhibit B as part of your track record and is
outstanding to both real estate and Operating Businesses. For each fiscal year end, report in rows 4 and 9 the percentage of loans and mandatory dividend
payments, on a dollar basis, that were 90 days past due (e.g., the combined dollar amount of principal, mandatory dividend, and interest payments 90 days
or more past due / the total dollar amount of loans and Equity Investments outstanding at fiscal year-end). In rows 5 and 10, enter the total dollar amount of
capital from loans and Equity Investments written off during the fiscal year (e.g., total dollar value of loans and/or Equity Investments written off less capital
recovered).
If the Applicant (or Controlling Entity) has not made loans to either real estate or Operating Businesses, check the corresponding “N/A” box. If the Applicant
(or Controlling Entity) has no delinquencies at the end of a particular fiscal year, indicate “0” in lines 4 and 9, as appropriate. If the Applicant (or Controlling
Entity) has had no write offs of loans and/or equity during a particular fiscal year, indicate “0” in lines 5 and 10, as appropriate.
Even if the Applicant has experienced zero delinquencies and write-offs in the past three years, it still needs to complete Table D1. In this case, the
Applicant should simply list the number and dollar amount of loans & Equity Investments outstanding at each fiscal year end and enter “0” for the
delinquency rates and write-offs. Applicants should not select “N/A” for Table D1 in this scenario.
If the Applicant chooses to complete any table in Exhibit A with information from the Controlling Entity, it must do so for all tables where
Controlling Entity is an option, including Table D1. If the Applicant completes Table D1 for the Applicant, the information must include, in the aggregate,
the financing track record of all Subsidiaries of the Applicant and may not include any of the Controlling Entity’s activities. However, if the Applicant
completes Table D1 for the Controlling Entity, the information must include, in the aggregate, the financing track record of all Subsidiaries of the Controlling
Entity, including the Applicant if the Applicant is a Subsidiary of the Controlling Entity.
Applicants should select their most recently completed Fiscal Year in Column 3. The options are ‘2023’ or ‘2024’. Columns 1 and 2 will auto-populate based
on this selection.

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NMTC Allocation Application Template for Public Comment – July 2024

The information in Table D1 reflects the activities of (check one): ____Applicant _____Controlling Entity
TABLE D1: INVESTMENT PORTFOLIO

Fiscal Year(s)
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.

Year 1 (Autopopulated)

Year 2 (Autopopulated)

Select 2023 or
2024

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

$
____%
$

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

$
____%
$

111

NMTC Allocation Application Template for Public Comment – July 2024

Instructions for Table D2: Based on the proposed transactions listed in Question 17 and Table A5, provide an itemized list of the individual fees that represent
the Fee Structure the Applicant anticipates will typically apply to investments closed with the requested NMTC Allocation and result in compensation to the
Applicant (or Controlling Entity), an Affiliate or an unaffiliated third party. Applicants should report the Fee Structure for every financial product listed in Question
14(a) that the Applicant intends to offer with capital raised from an NMTC Allocation. Applicants must disclose any and all fees, regardless of the expected
source and recipient, when in the NMTC investment lifecycle the fee is expected to be charged, and where in relation to the QEI it is expected to be charged.
Applicants must not include transaction costs such as legal opinions, financial modeling/projections, audit, tax preparation, and accounting expenses that are
not part of the Applicant’s fee structure. Applicants should assume that they will receive the full amount of the requested NMTC Allocation and fund each of the
proposed transactions listed in Question 17 and Table A5.
1. Select 'Type' based on the time in the NMTC investment lifecycle the fee is expected to be charged:
a. Select ‘Upfront Fee’ for any fee that is expected to be charged before or at the time the QLICI is closed. This category includes but is not limited
to, fees such as origination, placement, sub-allocation or syndication fees. Applicants should note this includes any fee that will be charged before
the QEI is made. An ‘Upfront Fee’ is a one-time charge and not recurring.
b. Select ‘Ongoing Fee’ for any fee that is expected to be charged after the QLICI is closed and during the seven-year compliance period. This
category includes but is not limited to, fees such as asset management fees, interest income that will be received, etc. An ‘Ongoing Fee’ is a not a
one-time charge and is recurring--which means that it is expected to be charged more than once during the seven-year compliance period.
c.

Select ‘Backend Fee’ for any fee that is expected to be charged at the end of or after the seven-year compliance period. This category includes
but is not limited to, fees such as backend, exit, or success fees. Applicants that plan to retain all or a portion of the tax credit equity at the end of
the seven year compliance period should report this as ‘Backend Fee’. A ‘Backend Fee’ is a one-time charge and not recurring.

2. Select the ‘Source (Payer)’ to indicate the entity responsible for paying the fee. The options include:
a. Investor or Investor Affiliate – Compensation and profits charged to investors.
b. QALICB or QALICB Affiliate fees – Compensation and profits charged to borrowers through fees.
c.

QALICB or QALICB Affiliate interest – Compensation and profits charged to borrowers through interest, Ordinary interest or dividend payments
passed through to investors or leverage lenders should not be included.

d. Other – Compensation and profits charged to any other party to the transaction.
3. Select the ‘Recipient (Payee)’ to indicate the entity that will receive the fee. The options include:
a. Applicant or Applicant Affiliate – Compensation and profits received by the Applicant CDE and/or Affiliates including the Controlling Entity and
Subsidiary CDEs.
b. Investor or Investor Affiliate – Compensation and profits received by the Investor or Investor Affiliate.

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NMTC Allocation Application Template for Public Comment – July 2024

Unaffiliated Third Party – Compensation and profits received by entities Unrelated to the Applicant. Applicants should include any costs incurred
for activities related to managing requested NMTC Allocation (e.g., preparing or assisting in the preparation of the Applicant’s Allocation Application,
identifying and underwriting transactions, managing a portfolio of QLICIs, and Allocation Agreement compliance). Applicants should not select this
option to report transaction costs such as legal financial modeling/projections, audit, tax preparation, and accounting expenses associated with
closing an NMTC transaction.

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

TABLE D2 – FEE STRUCTURE
Financial
Product 1

Type

Source (Payer)

Recipient (Payee)

Amount in
Percent

Description of the fee (Required).

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

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

Average Fee Percentage

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

0.00%

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

0.00%

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NMTC Allocation Application Template for Public Comment – July 2024

TABLE D2 – FEE STRUCTURE
Financial
Product 2

Type

Source (Payer)

Recipient (Payee)

Amount in
Percent

Description of the fee (Required).

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

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

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

Average Fee Percentage

0.00%

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

0.00%

TABLE D2 – FEE STRUCTURE
Financial
Product 3

Type

Source (Payer)

Recipient (Payee)

Amount in
Percent

Description of the fee (Required).

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

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

Average Fee Percentage

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

0.00%

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

0.00%

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NMTC Allocation Application Template for Public Comment – July 2024

Instructions for Table D3: All Applicants must complete Table D3. Applicants should ensure that data entered into Table D3 takes into consideration the
projected loans and investments listed in Exhibit A: Projected Activities. Applicants should assume that NMTC Allocation awards will be made in the fall of
2025. Applicants must provide an explanation of Table D3 in response to Question 34(c). The information in Table D3 must reflect the projected income
and operating expense of the Applicant.
1. When entering income data by source, the Applicant must include any and all fees and other sources of compensation that the Applicant and/or its
Affiliates will charge:
a. Investors (including investment partnership funds, if using the leverage structure). Be sure to include any income generated prior to the QEI
being made, any QEI proceeds retained by the Applicant, Controlling Entity or its Subsidiary CDEs;
b. QALICBs (i.e. borrowers/investees) fees and other sources of compensation paid directly to the CDE, including interest income;
c.

Affiliates, including the Controlling Entity or Subsidiary CDEs; and

d. Other sources of revenue, including grants, contributions, consulting, other line(s) of business, etc.
2. When entering expenses:
a. Fixed Expenses are expenses incurred by Applicant that are unlikely to vary regardless of the amount of the NMTC Allocation award or size
and number of QLICIs considered or made. For example, staff, facilities, Board/Insurance, CDE audit, etc.
b. Variable Expenses are all other expenses incurred by the Applicant, including compliance, accounting, tax returns, sub-CDE audits, loan
servicing, etc.
3. Data should be stated in dollars by fiscal year, starting with the fiscal year 2025.

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NMTC Allocation Application Template for Public Comment – July 2024

TABLE D3: INCOME AND OPERATING EXPENSES
Fiscal Year

2025

1. Income by source:

2026

2027

2028

2029

2030

2031

After 2031

(a) Investor(s)
(b) QALICBs or Affiliates
(c) CDE’s Affiliates
(d) Other Sources
Total Income

Total Expenses

Profit/(Loss)

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

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NMTC Allocation Application Template for Public Comment – July 2024

EXHIBIT E: INVESTOR STRATEGY
NOTE for Exhibit E:
1) Complete Table E1, if the Applicant (or Affiliates) received QEIs from investors in amounts less than the Allocation requested in Question 1 between
January 1, 2019, and the release date for the NMTC Allocation Application. Applicants completing Table E1 are required to submit, along with their
Applications, documentation demonstrating proof of investor interest (e.g., proof of QEI issuance; Commitment letters; Letters of Interest/Intent). For
examples of acceptable documentation for the required information, refer to the CDFI Fund’s NMTC Allocation Application FAQ Document. Be sure to
refer to the AMIS Navigation Guide for information regarding the submission of these documents.

Instructions for Table E1: Applicants should only list the names of actual or prospective investors that have provided Equity Investments (in accordance
with applicable IRS rulings regarding the issuance of QEIs prior to notification of an allocation), Commitments or Letters of Interest/Intent in connection with
a potential NMTC Allocation. To the extent an Applicant has or intends to secure investments from partnership entities that will leverage non-Equity
Investments (e.g., debt, grant dollars), such investments should be separately reported under “Type of Investment.” If an Applicant plans to engage an
investment banker (or other third party) to raise equity capital on the Applicant’s behalf, DO NOT INCLUDE such third-party organizations in this
table.

TABLE E1: IDENTIFICATION OF INVESTMENTS AND INVESTOR COMMITMENTS

Name of
Investor
1
2
3
4
5

Type of
Investment1

Using
Leverage
Structure?

Affiliate of
the
Applicant?

Previous
Investor?2

Total Funding
Provided from 20192024 (if previous
investor)

Dollar
Amount
Sought

Status of
Request3

Yes/No
Yes/No
Yes/No
$
$
Yes/No
Yes/No
Yes/No
$
$
Yes/No
Yes/No
Yes/No
$
$
Yes/No
Yes/No
Yes/No
$
$
TOTAL
N/A
N/A
N/A
N/A
$
$
N/A
1 Debt, equity, both debt and equity, or grant.
2 A previous investor is any investor that has invested in the Applicant, its Controlling Entity, or any Subsidiary entities since 2019.
3 Funds have been received; investor provided Commitment; investor issued Letter of Interest/Intent.

117

Estimated or
Actual Date for
Receipt of
Funds

N/A

NMTC Allocation Application Template for Public Comment – July 2024

GLOSSARY OF TERMS
Affiliate

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

Alaska Native Village
Statistical Areas

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

Allocatee

An Applicant that receives an NMTC Allocation.

Allocation Agreement

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

Allocation Application

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

Applicant

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

Application Contact Person

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

Assistance Agreement

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

Authorized Representative

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

CDE Certification Application

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

Commitment

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

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NMTC Allocation Application Template for Public Comment – July 2024

Community Development
Entity (CDE)

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

Community Development
Financial Institution (CDFI)

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

AMIS Compliance and
Performance Reporting
System (ACPR)

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

Control

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

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NMTC Allocation Application Template for Public Comment – July 2024

Controlling Entity

For CDEs that received Allocations under the CY 2013 Round
through the CY 2020 Round:
An entity that at the time of Application and throughout the term of
the Allocation Agreement (if the CDE is selected to receive an
Allocation), Controls an Applicant, and has a controlling influence
over the day-to-day management and operations (including
investment decisions) of the Applicant and of any Subsidiary entities
to which the Applicant may transfer its allocation of tax credit
authority.
For CDEs that did not receive Allocations under the CY 2013
through the CY2020 Round:
A Controlling Entity is an entity that, at the time of Application and
throughout the term of the Allocation Agreement (if the CDE is
selected to receive an Allocation), Controls the CDE as follows:
a. For-profit CDEs:
(i) ownership, Control, or power to vote more than 50% of
the outstanding shares of any class of voting securities of
the CDE and
(ii) Control in any manner over the election of a majority of
the directors, trustees, or general partners (or individuals
exercising similar functions) of the CDE, including Control
over the appointment and removal of the CDE’s
Executive management team (e.g. CEO, COO, CFO);
and
(iii) Approval authority over the management policies and
investment decisions of the CDE.
b. Not-for-profit CDEs:
(i) Control in any manner over the election of a majority of
the directors, trustees, or general partners (or individuals
exercising similar functions) of the CDE, including Control
over the appointment and removal of the CDE’s
Executive management team (e.g. CEO, COO, CFO);
and
(ii) Approval authority over the management policies and
investment decisions of the CDE.

Controlling Entity
Representative

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

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NMTC Allocation Application Template for Public Comment – July 2024

Disadvantaged Business or
Disadvantaged Community

A Disadvantaged Business meets one of the following.
1. A business that is located in:
a. a Persistent Poverty County;
b. a NMTC Native Area; or
c. a U.S. Territory
2. A business that is Low-Income Person-owned or -controlled
3. A for-profit business with $1,000,000 or less annual
revenues in the last fiscal year prior to the date the loan or
investment was closed
4. A non-profit business that predominately serves LowIncome Community residents or Low-Income Persons

II. A Disadvantaged Community has the same meaning as a LowIncome Community.

Enforcement Action

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

Equity Equivalent Loan

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

Equity Investment

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

Federal Indian Reservation

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

Financial Counseling and
Other Services (FCOS)

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

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Full Time Equivalent (FTE)

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

Hawaiian Home Lands

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

Letter of Interest/Intent

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

Low-Income Community
(LIC)

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

Low-Income Low-Access
(LILA) to supermarkets

A census tract designated as Low-Income and Low-Access to
supermarkets based on the census tract’s poverty rate or median
family income (according to the American Community Survey) and a
substantial number or share of residents has low access to a
supermarket, supercenter, or large grocery store.
Formerly known as “Food Deserts,” census tracts qualify if they
meet low-income and low-access thresholds established by the U.S.
Department of Agriculture (USDA) and can be found using the Food
Access Research Atlas at http://www.ers.usda.gov/dataproducts/food-access-research-atlas.aspx

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NMTC Allocation Application Template for Public Comment – July 2024

Low-Income Person

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

Low-Income Person-owned
or
Low-Income Personcontrolled

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

Metropolitan Areas

Counties contained within a Metropolitan Statistical Area, as such
term is defined in OMB Bulletin No. 20–01 (Revised Delineations of
Metropolitan Statistical Areas, Micropolitan Statistical Areas, and
Combined Statistical Areas, and Guidance on Uses of the
Delineations of These Areas) and applied to the 2020 census tracts.

Minority-owned or Minoritycontrolled

A Minority-owned or Minority-controlled entity is a:
a. Minority-owned for-profit entity: A for-profit entity that is not a
MDI and that has at least 51% of its equity ownership (or the
equivalent in limited liability companies) interest being
owned by individuals who identify themselves as American
Indian or Alaskan Native, Asian, Black or African American,
Hispanic or Latino, or Native Hawaiian or Other Pacific
Islander;
b. Minority-controlled not-for-profit entity: A not-for-profit entity
with at least 51% of its Board of Directors (i.e. Governing
Board) comprised of individuals who identify themselves as
American Indian or Alaskan Native, Asian, Black or African
American, Hispanic or Latino, or Native Hawaiian or Other
Pacific Islander; or
c. Minority Depository Institution (MDIs): An entity that is
designated by the FDIC as a Minority Depository Institution.
The CDFI Fund will rely on the categories established by the 1997
Office of Management and Budget (OMB) standards to define
American Indian or Alaskan Native, Asian, Black or African
American, Hispanic or Latino, and Native Hawaiian or Other Pacific
Islander.

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Native American

For the purpose of the NMTC Program this term shall include,
members of Tribal entities recognized by the U.S. Department of the
Interior, Bureau of Indian Affairs (BIA); and individuals having origins
in any of the original peoples of Hawaii.

Native American-owned or
Native American-controlled

For-profit entity: A for-profit entity, including an MDI, that has at least
51% of its equity ownership (or the equivalent in limited liability
companies) interest being owned by individuals who are Native
American.
Not-for-profit entity: A not-for-profit entity with at least 51% of its
Board of Directors (i.e. Governing Board) comprised of individuals
who are Native American.

New Markets Venture Capital
Company (NMVCC)

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

Non-Metropolitan Counties

Counties not contained within a Metropolitan Statistical Area, as
such term is defined in OMB Bulletin No. 20–01 (Revised
Delineations of Metropolitan Statistical Areas, Micropolitan Statistical
Areas, and Combined Statistical Areas, and Guidance on Uses of
the Delineations of These Areas) and applied to the 2020 census
tracts.
For guidance on Non-Metropolitan County designations, please see:
New Markets Tax Credit 2016-2020 American Community Survey
Census Transition FAQs

Notice of Allocation
Availability (NOAA)

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

NMTC Allocation

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

NMTC Program Income Tax
Regulations

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

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Off-reservation Trust Lands

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

Operating Business

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

Principal

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

Project Sponsor

An entity that owns or Controls the QALICB.

Public Contact Person

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

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Qualified Active Low-Income
Community Business
(QALICB)

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

Qualified Equity Investment
(QEI)

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

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NMTC Allocation Application Template for Public Comment – July 2024

Qualified Low-Income
Community Investments
(QLICI)

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

Real Estate Activities

Restricted NMTC Business
Activities

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

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NMTC Allocation Application Template for Public Comment – July 2024

Rural CDE

A Rural CDE is one that has a track record of at least three years of
direct financing experience, has dedicated at least 50% of its direct
financing dollars to Non-Metropolitan Counties over the past five
years, and has committed that at least 50% of its NMTC financing
dollars with this Allocation will be deployed in such areas. NonMetropolitan Counties are counties not contained within a
Metropolitan Statistical Area, as such term is defined in OMB
Bulletin No. 20–01 (Revised Delineations of Metropolitan Statistical
Areas, Micropolitan Statistical Areas, and Combined Statistical
Areas, and Guidance on Uses of the Delineations of These Areas)
and applied using 2020 census tracts.

Small Business Investment
Company (SBIC)

An entity defined in 15 USC 662(3).

Specialized Small Business
Investment Company
(SSBIC)

An entity defined in IRC §1044(c)(3).

Subsidiary

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

Targeted Population

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

Unrelated

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

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NMTC Allocation Application Template for Public Comment – July 2024

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

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

Authorized Representative Signature:
Authorized Representative Title:
Date:

_____________________
_____________________
_____________________

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NMTC Allocation Application Template for Public Comment – July 2024

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

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NMTC Allocation Application Template for Public Comment – July 2024

Controlling Entity’s Certification
2024 NMTC Allocation Application
Applicant Name:
Control Number:
By signing this Allocation Application:
•

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

•

I hereby acknowledge that all information contained in this Application and any attachments or
supplements thereto will be subject to disclosure pursuant to the Freedom of Information Act (FOIA) 5
USC 552, et seq.
I hereby certify that the Controlling Entity is indeed the Controlling Entity of the Applicant and
supports this Allocation Application.

•

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

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File Type	application/pdf
File Title	CY 2024 - 2026 NMTC Allocation Application Template
Author	Leung, Karen
File Modified	2024-08-23
File Created	2024-08-23