Summary of Public Comments and CDFI Fund Responses

1559-0016 NMTC Program Application Appendix A Supporting Statement 8.23.2024.pdf

New Markets Tax Credit (NMTC) Program Application

Summary of Public Comments and CDFI Fund Responses

OMB: 1559-0016

Document [pdf]

Download: pdf | pdf

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#
1

Date of
Comment
4/17/2024

Organization

4/23/2024

Evernorth
Rural Ventures

Beth
Boutin

Community
Outcomes

Application

LILA/Healthy
Foods

4/23/2024

Evernorth
Rural Ventures

Beth
Boutin

Community
Outcomes

Application

Medically
Underserved
Areas

4/23/2024

Evernorth
Rural Ventures

Beth
Boutin

Community
Outcomes

Application

Medically
Underserved
Areas

4/23/2024

Evernorth
Rural Ventures

Beth
Boutin

Community
Outcomes

Application

4/23/2024

Evernorth
Rural Ventures

Beth
Boutin

Community
Outcomes

Application

Commitment
to Areas of
Higher
Distress
Quality Jobs

St Mary's
Center for
Women and
Children
Evernorth
Rural Ventures

Author
Name
Alexis
Steel

Section

Category

Topic

Comment

NMTC Response

Community
Outcomes

Application

Concerns about changes to
Question 25(b).

Beth
Boutin

Community
Outcomes

Application

Commitment
to Areas of
Higher
Distress
Community
Accountabilit
y&
Involvement

The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund will
consider additional
guidance based on
this comment.

Delete new bullet asking
about use of data or
suggest alternate wording
because it disadvantages
rural CDEs or CDEs that
serve rural areas.
Revert back to the Healthy
Food Financing Initiative
(HFFI) definition.
Suggest adding Medically
Underserved Population to
Medically Underserved
Areas designated by
HRSA.
Support adding Healthcare
Professional Shortage
Areas (HPSAs).
Recommend clarifying
types of care projects will
increase availability for.
Suggest alternate changes
to Question 25(b).
Remove requirement to
discuss
temporary/construction
jobs for "Quality Jobs."

The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund is
maintaining the
current
requirements.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

Date of
Comment
4/23/2024

Section

Category

Topic

Comment

NMTC Response

Evernorth
Rural Ventures

Author
Name
Beth
Boutin

Community
Outcomes

Application

Community
Goods and
Services

Exempt MCOS projects
from providing third-party
metrics.

4/23/2024

Evernorth
Rural Ventures

Beth
Boutin

Community
Outcomes

Application

Community
Goods and
Services

4/23/2024

Evernorth
Rural Ventures

Beth
Boutin

Community
Outcomes

Application

4/23/2024

Evernorth
Rural Ventures

Beth
Boutin

Capitalizati
on Strategy

Application

Track Record
Alignment
with
Community or
Eco Dev
Strategies
Investor
Letters

Remove third-party
metrics requirement for
community goods and
services.
Restore previous Question
27(c) track record of
alignment with
Community or economic
development strategies.

The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund will
consider changes in
future application
rounds.

4/23/2024

Evernorth
Rural Ventures

Beth
Boutin

Capitalizati
on Strategy

Application

Investor
Letters

Confirm that document is
only required per Question
37(a).

4/23/2024

Evernorth
Rural Ventures

Beth
Boutin

Exhibits

Application

Business Type

Add "childcare" as
business type in Table A5.

4/23/2024

Evernorth
Rural Ventures

Beth
Boutin

Managemen
t Capacity

Application

Management
Experience

Revert changes in
character limits within the
Management Capacity
section.

Clarify when a prior
allocatee is required to
provide investor letters.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

Date of
Comment
4/23/2024

Author
Name
Beth
Boutin

Section

Category

Topic

Comment

NMTC Response

Glossary of
Terms

Application

Disadvantage
Business

The CDFI Fund
made revisions
based on public
comments.

NMTC
Working
Group Novogradac
NMTC
Working
Group Novogradac
NMTC
Working
Group Novogradac

Brad
Elphick

Business
Strategy

Application

Innovative
Investments

Support inclusion of
nonprofit businesses but
want to maintain "a
business that has
inadequate access to
investment capital."
Alternately suggest "a
business that has
inadequate access to
conventional investment
capital."
Clarify in FAQ that
Question 19 does not
impact scoring.

4/23/2024

Brad
Elphick

Business
Strategy

Application

Innovative
Investments

4/23/2024

Brad
Elphick

Business
Strategy

FAQ

Innovative
Investments

4/23/2024

NMTC
Working
Group Novogradac

Brad
Elphick

Business
Strategy

Application

Track Record
of
Investments

Evernorth
Rural Ventures

Increase character limit for
Question 19 narrative
when multiple innovative
activities are selected.
Add new FAQ to clarify
that advanced loan
purchases qualify as
investments in QALICBs.

Allow individual
experience to be included
in Question 21 and scored
in Phase 1.

The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund will
consider additional
guidance based on
this comment.
This comment is not
related to burden in
completing the
NMTC Program
Application. The
CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund is
maintaining the
current
requirements.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#
20

Date of
Comment
4/23/2024

4/23/2024

Organization
NMTC
Working
Group Novogradac
NMTC
Working
Group Novogradac
NMTC
Working
Group Novogradac
NMTC
Working
Group Novogradac
NMTC
Working
Group Novogradac
NMTC
Working
Group Novogradac
NMTC
Working
Group Novogradac
NMTC
Working
Group Novogradac

Author
Name
Brad
Elphick

Section

Category

Topic

Comment

NMTC Response

Community
Outcomes

Application

Persistent
Poverty
Counties

Add "Persistent Poverty
Census Tracts" to
Question 25(b).

Brad
Elphick

Community
Outcomes

Application

Brad
Elphick

Community
Outcomes

Application

Brad
Elphick

Capitalizati
on Strategy

Application

New
Community
Outcomes
Category
New
Community
Outcomes
Category
Track Record
of Raising
Capital

Add “Other” back as a
community outcome
category in Question
26(a).
Add “Microlending and
Nonprofit Support” as a
new community outcome
in Question 26(a).
Restore Question 35 as
one question.

Brad
Elphick

Previous
Awards

Application

Prior NMTC
Investments

Clarify instructions for
Question 44(a) through
FAQ# 133.

Brad
Elphick

Business
Strategy

Application

Financial
Products

Brad
Elphick

Business
Strategy

Application

Additional
Flexibility for
Debt

Remove requirement to
list percentage of financial
products when more than
one financial product is
offered.
Correct typo in Question
15(a).

The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund is
maintaining the
current
requirements.

Brad
Elphick

Business
Strategy

Application

Track Record
of
Investments

Revert change to Question
20(c) back to numerical.

The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund
made revisions
based on public
comments.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#
28

Date of
Comment
4/23/2024

4/23/2024

Organization
NMTC
Working
Group Novogradac
NMTC
Working
Group Novogradac
NMTC
Working
Group Novogradac
NMTC
Working
Group Novogradac
NMTC
Working
Group Novogradac
NMTC
Working
Group Novogradac

NMTC
Working
Group Novogradac

Author
Name
Brad
Elphick

Section

Category

Topic

Comment

NMTC Response

Business
Strategy

Application

Track Record
of
Investments

Brad
Elphick

Business
Strategy

Application

Track Record
of
Investments

Allow the Controlling
Entity to report discrete
NMTC activities as
opposed to all activities.
Revert change to Question
21(c) back to numerical.

Brad
Elphick

Community
Outcomes

Application

Federal/State/
Local Zones

Restore
"federal/state/local zones"
as an area of distress.

Brad
Elphick

Community
Outcomes

Application

Persistent
Poverty
Counties

Add "Persistent Poverty
Census Tracts" to
Question 25(b).

Brad
Elphick

Community
Outcomes

Application

LILA/Healthy
Foods

Revert back to the Healthy
Food Financing Initiative
(HFFI) definition.

Brad
Elphick

Community
Outcomes

Application

Medically
Underserved
Areas

Brad
Elphick

Community
Outcomes

Application

Commitment
to Areas of
Higher
Distress

Support adding Healthcare
Professional Shortage
Areas (HPSAs) but
request that the CDFI
Fund clarify qualified
projects. Suggest adding
Medically Underserved
Population to Medically
Underserved Areas
designated by HRSA.
Revert changes to
Question 25(b). Suggest
moving question to
Innovative Activity.

The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund
made revisions
based on public
comments.

The CDFI Fund
made revisions
based on public
comments.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#
35

Date of
Comment
4/23/2024

4/23/2024

Author
Name
Brad
Elphick

Section

Category

Topic

Comment

NMTC Response

Community
Outcomes

Application

Quality Jobs

Clarify the definition of
"Quality Jobs."

Brad
Elphick

Community
Outcomes

Application

Quality Jobs

Brad
Elphick

Community
Outcomes

Application

Accessible
Jobs

Brad
Elphick

Community
Outcomes

Application

Community
Goods and
Services

Brad
Elphick

Community
Outcomes

Application

Housing

Brad
Elphick

Community
Outcomes

Application

Brad
Elphick

Community
Outcomes

Application

Brad
Elphick

Community
Outcomes

Application

Community
Accountabilit
y&
Involvement
Community
Accountabilit
y&
Involvement
Community
Accountabilit
y&
Involvement

Remove requirement to
discuss
temporary/construction
jobs for "Quality Jobs."
Change the "limited
language proficiency"
reference to "limited
English language
proficiency" for
Accessible Jobs
Remove third-party
metrics requirement for
community goods and
services.
Update the language in
affordable housing to also
specify the percentage that
is considered low income.
Using data to qualify need
would disadvantage LICs
and Native communities

The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund
made revisions
based on public
comments.

Proposed alternate
wording to qualify "data"
used to demonstrate need.
Clarify if we are looking
for engagement directly
with LIPs/LIC residents or
with stakeholders.

The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider additional
guidance based on
this comment.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#
43

Date of
Comment
4/23/2024

4/23/2024

Author
Name
Brad
Elphick

Section

Category

Topic

Comment

NMTC Response

Community
Outcomes

Application

Revert changes to
Question 27(c) to discuss
track record.

Brad
Elphick

Managemen
t Capacity

Application

Community
Accountabilit
y&
Involvement
Key Personnel

Brad
Elphick

Managemen
t Capacity

Application

Organization
Capacity/Key
Personnel

Propose no or modest
decrease to character limit
in Question 31(b).

Brad
Elphick

Managemen
t Capacity

Application

Fee Structure

Brad
Elphick

Business
Strategy

Application

Maximize
Efficiency and
Financial
Impact

Brad
Elphick

Exhibits

Application

Brad
Elphick

Exhibits

Application

Total QEI
from
Unaffiliated
CDEs
Fee Structure

Clarify if Applicants
should include fees that
are conditional or
contingent.
Add new question in
Business Strategy to
discuss Applicant's
strategy to maximize
efficiency and financial
impact.
Change Row J to
“Estimated Total QEIs
from unaffiliated CDEs.”

The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider changes in
future application
rounds.

Brad
Elphick

Glossary of
Terms

Application

Enforcement
Action
Definition

Rephrase term
"subordinates."

Increase character limit to
"Description of the Fee”
field in Table D2.
Add "formal" to glossary
term.

The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund
made revisions
based on public
comments.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#
51

Date of
Comment
4/23/2024

4/23/2024

Organization

Author
Name
Brad
Elphick

Section

Category

Topic

Comment

NMTC Response

Glossary of
Terms

Application

Propose changes to
"Minority-owned or
Minority-controlled."

Brad
Elphick

General

Review
Process

Minority
Owned or
Controlled
Definition
Scoring
Process

NMTC
Working
Group Novogradac
NMTC
Working
Group Novogradac
NMTC
Working
Group Novogradac

Brad
Elphick

NOAA

CDE
Certification

Brad
Elphick

Glossary of
Terms

IT
Enhancement

Online
Application
Portal

Concerns/suggestions
regarding requiring CDEs
be certified by the NOAA
publication date.
Suggest IT enhancement
to display glossary term
within online Application.

Brad
Elphick

Post Award

Compliance

General
Consistency

The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund will
consider additional
guidance based on
this comment.
This comment is
related to Allocatee
reporting/complianc
e and will be
considered in the
future.

NMTC
Working
Group Novogradac

Brad
Elphick

Post Award

Debriefing

NMTC
Working
Group Novogradac
NMTC
Working
Group Novogradac

Various ideas for
increasing scoring
variability.

Update Compliance FAQ
to clarify that CDES will
not be evaluated
unfavorably if no more
than 15% of their
allocation is used to
finance investments
inconsistent w/ its
application strategy.
Give more robust
feedback in debriefing.

The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#
57

Date of
Comment
4/23/2024

Organization

4/23/2024

NMTC
Working
Group Novogradac

Brad
Elphick

NOAA

QEI Issuance
Requirements

4/23/2024

NMTC
Working
Group Novogradac

Brad
Elphick

Glossary of
Terms

Application

Disadvantage
Business

4/23/2024

Brad
Elphick

Managemen
t Capacity

Application

Fee Structure

4/23/2024

NMTC
Working
Group Novogradac
CAHEC
Community
Capital

Brian
Oxford

Community
Outcomes

Application

Question Note

4/23/2024

CAHEC
Community
Capital

Brian
Oxford

Business
Strategy

Application

Financial
Products

NMTC
Working
Group Novogradac
NMTC
Working
Group Novogradac

Author
Name
Brad
Elphick

Section

Category

Topic

Comment

NMTC Response

Glossary of
Terms

Application

Disadvantage
Business

Oppose <$100,000
revenue limitation.

Brad
Elphick

General

Application
Instructions,
FAQ

Integrate
Application
Material

Add Notice of Allocation
Availability (NOAA) to
online Application.
Incorporate FAQ guidance
into Application Notes.
Reduce QEI issuance
threshold requirement for
non-rural CDEs from 20%
to 0%.

The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund will
consider additional
guidance based on
this comment.

Clarify "primarily" in part
4 of definition revision;
clarification on whether
businesses need to be in
LICs before or after
investment; add non-profit
and socially disadvantaged
persons to part 2.
Make sure fee guidance is
consistent between
Question 43 and the
CDE's fee disclosure.
Clarify percentage of
commitments in Questions
25(a) and (b).
Support comparing
NMTC product with other
financial institutions or
investors.

The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund
made revisions
based on public
comments.

The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund
made revisions
based on public
comments.
Comment in support
of proposed or
existing text. No
action necessary.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

Date of
Comment
4/23/2024

Author
Name
Brian
Oxford

Section

Category

Topic

Comment

NMTC Response

Business
Strategy

Application

Additional
Flexibility for
Debt

Correct typo in Question
15(a).

CAHEC
Community
Capital

Brian
Oxford

Business
Strategy

Application

Question Note
Third
Paragraph

4/23/2024

CAHEC
Community
Capital

Brian
Oxford

Business
Strategy

Application

Question Note
First
Paragraph

4/23/2024

CAHEC
Community
Capital

Brian
Oxford

Community
Outcomes

Application

4/23/2024

CAHEC
Community
Capital

Brian
Oxford

Community
Outcomes

Application

4/23/2024

CAHEC
Community
Capital

Brian
Oxford

Community
Outcomes

Application

4/23/2024

CAHEC
Community
Capital

Brian
Oxford

Community
Outcomes

Application

Commitment
to Areas of
Higher
Distress
Commitment
to Areas of
Higher
Distress
Commitment
to Areas of
Higher
Distress
Community
Goods and
Services

Clarify level of specificity
required for business type
description in Question
17(c).
Clarify level of specificity
required for business type
description in Question
17(c).
Suggest moving question
to Innovative Activity.

4/23/2024

CAHEC
Community
Capital

Brian
Oxford

Community
Outcomes

Application

The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund will
consider additional
guidance based on
this comment.

4/23/2024

CAHEC
Community
Capital

Community or
Economic
Development
Strategies

Concerns with tracking
commitments to areas of
distress.
Concerns with revised
areas of distress.
Remove third-party
metrics requirement for
community goods and
services.
Revise wording or clarify
instructions for Question
27(d) to "discuss the
portion…."

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

Date of
Comment
4/23/2024

Author
Name
Brian
Oxford

Section

Category

Topic

Comment

NMTC Response

Capitalizati
on Strategy

Application

Part IV
instructions

Correct typo in Part IV
description.

CAHEC
Community
Capital

Brian
Oxford

Managemen
t Capacity

Application

Consistency
of Personnel
Names

4/23/2024

CAHEC
Community
Capital

Brian
Oxford

Exhibits

Application

Add "Project
Name" answer
field

Clarify if names in Table
C2 and Question 28(a)
should be identical to
Question 28(b).
Add a separate answer
field for project name.

4/23/2024

CAHEC
Community
Capital

Brian
Oxford

Combined
Rounds

NOAA

Combining
Rounds

Do not support combining
CY 2024 & CY 2025
rounds.

4/23/2024

CAHEC
Community
Capital

Brian
Oxford

Glossary of
Terms

Application

Disadvantage
Business

Revert definition of
"Disadvantage Business."

4/23/2024

CAHEC
Community
Capital

Brian
Oxford

General

Review
Process

Phase 1
reviewers

Revert back to three
reviewers for Phase 1
review.

The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund will
consider changes in
future application
rounds.
This comment is not
related to burden in
completing the
NMTC Program
Application. The
CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.

4/23/2024

CAHEC
Community
Capital

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

Date of
Comment
4/23/2024

Author
Name
Calvin
Holmes

Section

Category

Topic

Comment

NMTC Response

Allocation
Request

Application

Total QEI
Needs

Chicago
Community
Loan Fund

Calvin
Holmes

Allocation
Request

Application

Total QEI
Needs

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Business
Strategy

Application

Due Diligence

Comment in support
of proposed or
existing text. No
action necessary.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund is
maintaining the
current
requirements.

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Business
Strategy

Application

Due Diligence

Aligning allocation
request with total QEI is
more consistent and
realistic.
Describing detailed
investment strategy based
on community input
increase burden.
Due diligence
documentation requires
applicants to maintain
extensive records which
may exceed the assumed
preparation hours.
Provide checklist for due
diligence.

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Business
Strategy

Application

Due Diligence

Support changes to
Question 18.

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Community
Outcomes

Application

Describing the
involvement of LIC
representatives takes time.

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Business
Strategy

Application

Community
Accountabilit
y&
Involvement
Financial
Products

Chicago
Community
Loan Fund

Articulate distinction
between descriptions for
multiple financial
products. Provide
examples.

The CDFI Fund will
consider additional
guidance based on
this comment.
Comment in support
of proposed or
existing text. No
action necessary.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund will
consider additional
guidance based on
this comment.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

Date of
Comment
4/23/2024

Author
Name
Calvin
Holmes

Section

Category

Topic

Comment

NMTC Response

Business
Strategy

Application

Financial
Products

Support requiring distinct
narratives for financial
products.

Chicago
Community
Loan Fund

Calvin
Holmes

Business
Strategy

Application

Financial
Products

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Business
Strategy

Application

Financial
Products

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Business
Strategy

Application

Financial
Products

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Business
Strategy

Application

Financial
Products

Providing distinct
narratives for each
financial product and
detailed description of
product structuring
increases burden and cost
to prepare application.
Requirement to describe
circumstances dictating
rates and terms adds
burden.
Provide example or
template for Question
14(b). Simplify
requirements or provide
calculation tools.
Describing circumstances
of terms and rates increase
burden.

Comment in support
of proposed or
existing text. No
action necessary.
The CDFI Fund will
consider additional
guidance based on
this comment.

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Business
Strategy

Application

Invest in
Other CDEs

Revert changes to
instructions for Question
14(c).

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Business
Strategy

Application

Invest in
Other CDEs

Provide an example for
how benefits are passed on
when investing in other
CDEs.

Chicago
Community
Loan Fund

The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund will
consider additional
guidance based on
this comment.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

Date of
Comment
4/23/2024

Author
Name
Calvin
Holmes

Section

Category

Topic

Comment

NMTC Response

Business
Strategy

Application

Calvin
Holmes

Business
Strategy

Application

Explain criteria used to
assess the quality and
alignment of community
input with investment
strategies.
Support changes to
Question 17(c).

The CDFI Fund will
consider additional
guidance based on
this comment.

Chicago
Community
Loan Fund

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Community
Outcomes

Application

Detailing investment
strategies based on
community input could
further increase burden.

The CDFI Fund will
consider additional
guidance based on
this comment.

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Community
Outcomes

IT
Enhancement

Provide mapping tool or
database for qualified
distressed areas.

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Community
Outcomes

Application

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Community
Outcomes

Application

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Community
Outcomes

Application

Align
Investment
with
Community
Input
Align
Investment
with
Community
Input
Align
Investment
with
Community
Input
Commitment
to Areas of
Higher
Distress
Commitment
to Areas of
Higher
Distress
Commitment
to Areas of
Higher
Distress
Commitment
to Areas of
Higher
Distress

4/23/2024

Chicago
Community
Loan Fund

Comment in support
of proposed or
existing text. No
action necessary.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

Date of
Comment
4/23/2024

Author
Name
Calvin
Holmes

Section

Category

Topic

Comment

NMTC Response

Community
Outcomes

Application

Chicago
Community
Loan Fund

Calvin
Holmes

Community
Outcomes

IT
Enhancement

Commitment to invest in
specific distress areas
increase admin burden and
costs.
Request for questions to
be reformatted or add a
table.

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Community
Outcomes

Application

Commitment
to Areas of
Higher
Distress
Community
Accountabilit
y&
Involvement
Community
Accountabilit
y&
Involvement

The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund will
consider additional
guidance based on
this comment.

100

4/23/2024

101

102

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Managemen
t Capacity

Application

Organization
Capacity/Key
Personnel

103

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Managemen
t Capacity

Application

Organization
Capacity/Key
Personnel

104

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Managemen
t Capacity

Application

Organization
capacity/Key
Personnel

105

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Managemen
t Capacity

Application

Organization
capacity/Key
Personnel

Chicago
Community
Loan Fund

Consider updates to allow
more flexibility in how
accountability,
engagement and
involvement is
demonstrated.
Ensure consideration is
not limited to experienced
CDEs.
Incorporate dropdown
menus or autofill options
based on prior year
submissions to minimize
repetitive data entry.
Support collecting detailed
descriptions of org
structure, key personnel
and experience providing
QLICIs.
Information required adds
complexity requiring
additional resources. This
will increase operational
costs.

The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund will
consider additional
guidance based on
this comment.
Comment in support
of proposed or
existing text. No
action necessary.
The CDFI Fund will
continue its efforts
to reduce burden in
future application
rounds.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

106

Date of
Comment
4/23/2024

Author
Name
Calvin
Holmes

Section

Category

Topic

Comment

NMTC Response

Managemen
t Capacity

Application

Organization
Capacity/Key
Personnel

Provide clarification on
expectations for key
personnel.

Chicago
Community
Loan Fund

Calvin
Holmes

Managemen
t Capacity

Application

Organization
Capacity/Key
Personnel

Provide clarification on
expectations for key
personnel.

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Capitalizati
on Strategy

Application

Raising
Capital

109

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Capitalizati
on Strategy

Application

Capitalization

Consider incorporating
CDE overarching goals
and impact into
strategy/track record of
raising capital.
Add or integrate digital
templates for these
questions.

The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider changes in
future application
rounds.

107

4/23/2024

108

110

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Capitalizati
on Strategy

Application

Raising
Capital

111

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Capitalizati
on Strategy

Application

Raising
Capital

112

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Business
Strategy

Application

Innovation in
financial
product

Chicago
Community
Loan Fund

Documenting track record
of capital raising and
investment partnership is
challenging and could
increase cost.
Do not focus exclusively
on ability or track record
of raising capital. Add
consideration for
CDFI/CDEs and Minority
CDEs that demonstrate
growth potential and
community impact.
Provide space for CDEs to
discuss any innovative
features of their financial
products.

The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund will
continue its efforts
to reduce burden in
future application
rounds.
The CDFI Fund is
maintaining the
current
requirements.

The CDFI Fund will
consider changes in
future application
rounds.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

113

Date of
Comment
4/23/2024

Author
Name
Calvin
Holmes

Section

Category

Topic

Comment

NMTC Response

AMIS

IT
Enhancement

Online
Application
Portal

The CDFI Fund will
consider additional
guidance based on
this comment.

Chicago
Community
Loan Fund

Calvin
Holmes

Post Award

Debriefing

Suggest various format
updates, functionality
improvements to the
online application
interface for Applicants.
Give more robust
feedback in debriefing.

114

4/23/2024

115

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Estimated
Hours of
Burden

PRA

CDFI Fund
Burden
Estimate
(hours)

Review and potentially
increase burden estimate.

116

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Capitalizati
on Strategy

Application

Raising
Capital

Describing history and
strategies to raise capital
require additional
expertise/burden.

117

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Provide
Feedback

PRA

Review Draft
Application

Various ideas for
providing feedback,
financial rewards, or
advantages to certain
Applicants.

Chicago
Community
Loan Fund

The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.
The CDFI Fund will
continue its efforts
to reduce burden in
future application
rounds.
The CDFI Fund will
continue its efforts
to reduce burden in
future application
rounds.
This comment is not
related to burden in
completing the
NMTC Program
Application. The
CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

118

Date of
Comment
4/23/2024

Author
Name
Calvin
Holmes

Section

Category

Topic

Comment

NMTC Response

Customer
Service

Capacity
Building

Consistency
of Personnel
Names

The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.

Chicago
Community
Loan Fund

Calvin
Holmes

Provide
Feedback

PRA

Review Draft
Application

Conduct research to
review participation and
successes of Minority
CDEs and understand
barriers to entry and
success.
Allow early access to
application drafts and
provide feedback allowing
Applicants to revisit their
responses.

119

4/23/2024

120

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Estimated
Hours of
Burden

PRA

CDFI Fund
Burden
Estimate
(hours)

Current burden estimate
may underrepresent true
cost of burden.

121

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Community
Outcomes

Application

Align
Investment
with
Community
Input

Substantiating impacts for
LICs/LIPs increase
burden.

Chicago
Community
Loan Fund

This comment is not
related to burden in
completing the
NMTC Program
Application. The
CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund will
continue its efforts
to reduce burden in
future application
rounds.
The CDFI Fund will
consider additional
guidance based on
this comment.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

122

Date of
Comment
4/23/2024

Author
Name
Calvin
Holmes

Section

Category

Topic

Comment

NMTC Response

Provide
Feedback

PRA

Review Draft
Application

Allow early access to
application drafts and
provide feedback allowing
Applicants to revisit their
responses.

Chicago
Community
Loan Fund

Calvin
Holmes

Customer
Service

Capacity
Building

Provide
Technical
Assistance

Develop partnerships with
organizations to provide
capacity building
assistance for Minority
CDEs.

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Managemen
t Capacity

Application

Organization
Capacity/Key
Personnel

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Capitalizati
on Strategy

Application

Raising
Capital

Detailed information
requested may increase
burden for new Applicants
or those with recent
structural changes.
Request for additional
instructions and guidance
regarding data reported
and sharing preferred
format for Commitment
Letters and Letters of
Intent.

This comment is not
related to burden in
completing the
NMTC Program
Application. The
CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
This comment is not
related to burden in
completing the
NMTC Program
Application. The
CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund will
continue its efforts
to reduce burden in
future application
rounds.
The CDFI Fund will
consider additional
guidance based on
this comment.

123

4/23/2024

124

125

Chicago
Community
Loan Fund

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

126

Date of
Comment
4/23/2024

Author
Name
Calvin
Holmes

Section

Category

Topic

Comment

NMTC Response

Business
Strategy

Application

Sustainability
and Viability
of
Investments

The CDFI Fund will
consider changes in
future application
rounds.

Chicago
Community
Loan Fund

Calvin
Holmes

Business
Strategy

Application

Social &
economic
Impact

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

General

Regulations

Set-Aside

127

4/23/2024

128

129

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Customer
Service

Capacity
Building

Provide
Technical
Assistance

Provide technical
assistance to Minority
CDEs.

130

4/23/2024

Chicago
Community
Loan Fund

Calvin
Holmes

Community
Outcomes

Review
Process

Bonus Points

Give bonus points for
CDFIs.

Chicago
Community
Loan Fund

The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund
does not have
statutory authority
to implement this
recommendation.
This comment is not
related to burden in
completing the
NMTC Program
Application. The
CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund
does not have
statutory authority
to implement this
recommendation.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

131

Date of
Comment
4/23/2024

Author
Name
Calvin
Holmes

Section

Category

Topic

Comment

NMTC Response

General

Review
Process

Minority-led
CDEs

Revise review process to
evaluate experience and
performance of Minority
CDEs.

Chicago
Community
Loan Fund

Calvin
Holmes

Business
Strategy

Application

Total QEI
Needs

Request calculator tool to
align QEI needs with
business type.

4/23/2024

Urban Action
Community
Development

Carl
Struever

Community
Outcomes

Application

MBE/WBE
business

Consider adding
MBE/WBE participation.

134

4/23/2024

Urban Action
Community
Development

Carl
Struever

Community
Outcomes

Application

Restore question about
"catalytic impact."

135

4/23/2024

Urban Action
Community
Development

Carl
Struever

Managemen
t Capacity

Application

Catalytic
Impact in
Neighborhood
Transformatio
n
Fee Structure

The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund will
consider additional
guidance based on
this comment.

132

4/23/2024

133

136

4/23/2024

Urban Action
Community
Development

Carl
Struever

General

Application

NMTC
Pricing

Propose ways to increase
NMTC pricing.

Chicago
Community
Loan Fund

Support requirement to
disclose fees.

Comment in support
of proposed or
existing text. No
action necessary.
The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

137

Date of
Comment
4/23/2024

Author
Name
Carl
Struever

Section

Category

Topic

Comment

NMTC Response

Community
Outcomes

Application

Commitment
to Areas of
Higher
Distress

Distress criteria does not
consider collapse of
offices and commercial
properties in downtowns.

Urban Action
Community
Development

Carl
Struever

Community
Outcomes

Application

Do not support targeting
"deep distress"

4/23/2024

Urban Action
Community
Development

Carl
Struever

General

Application

Commitment
to Areas of
Higher
Distress
Reduce Cost

140

4/23/2024

Urban Action
Community
Development

Carl
Struever

General

Other

Expand
Eligible
Leverage
Loan Sources

Expand sources of
leverage loans.

141

4/23/2024

Urban Action
Community
Development

Carl
Struever

General

Other

Fee Structure

Expressed concern about
escrowing asset
management fees.

This comment is not
related to burden in
completing the
NMTC Program
Application. The
CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund
made revisions
based on public
comments.
This comment is not
related to burden in
completing the
NMTC Program
Application. The
CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.

138

4/23/2024

139

Urban Action
Community
Development

Suggested alternates to
escrowed funds.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

142

Date of
Comment
4/23/2024

Author
Name
Carl
Struever

Section

Category

Topic

Comment

NMTC Response

Regulation

Other

Financial
Products

Structure "put" as a loan at
the initial NMTC
investment.

Urban Action
Community
Development

Carl
Struever

General

Other

Reduce Cost

Made suggestions to
reduce transaction cost.

4/23/2024

Urban Action
Community
Development

Carl
Struever

General

Federal
Coordination

Streamline
NMTC with
Federal
programs

145

4/23/2024

Urban Action
Community
Development

Carl
Struever

General

Federal
Coordination

Reference
Justice40
White House
Initiative

Minimize requirements
from other federal and
public programs to
maximize impact of
NMTC.
Make references to
Justice40 (White House
Initiative).

146

4/23/2024

Urban Action
Community
Development

Carl
Struever

General

Application

Environmenta
l Impact

The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
This comment is not
related to burden in
completing the
NMTC Program
Application. The
CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund will
consider changes in
future application
rounds.

143

4/23/2024

144

Urban Action
Community
Development

Utilize language from
other federal programs to
generate environmental
impact.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

147

Date of
Comment
4/23/2024

Author
Name
Carl
Struever

Section

Category

Topic

Comment

NMTC Response

General

Other

Potential
Impact

The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.

Urban Action
Community
Development

Carl
Struever

General

Other

Fee Structure

Use NMTC as vehicles for
"defense dividend", local
and state using
federal/defense
investments to grow local
economy.
Cost of fees, bridge loans,
and escrowed accounts
devalues benefits of
NMTC.

148

4/23/2024

291

4/23/2024

The Rose
Urban Green
Fund

Charles
Perry

Community
Outcomes

Application

Federal/State/
Local Zones

Restore
"federal/state/local zones"
as an area of distress.

150

4/23/2024

The Rose
Urban Green
Fund

Charles
Perry

Community
Outcomes

Application

Revert changes to
Question 25(b).

151

4/23/2024

The Rose
Urban Green
Fund

Charles
Perry

Glossary of
Terms

Application

Commitment
to Areas of
Higher
Distress
Disadvantage
Business

152

4/23/2024

National New
Markets Fund

Deborah
La Franchi

Business
Strategy

Application

Market
Comparison

153

4/23/2024

National New
Markets Fund

Deborah
La Franchi

Business
Strategy

Application

Proposed
Pipeline

Urban Action
Community
Development

Revert definition of
"Disadvantage Business"
or add nonprofit
businesses servicing LIC
residents and LIPs.
Support comparing
NMTC product with other
financial institutions or
investors.
Clarify whether
deployment timeline is
required. Add project
readiness and financing
status to Question 17(c)
text or question note.

The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund
made revisions
based on public
comments.
Comment in support
of proposed or
existing text. No
action necessary.
The CDFI Fund is
maintaining the
current
requirements.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

154

Date of
Comment
4/23/2024

Section

Category

Topic

Comment

NMTC Response

National New
Markets Fund

Author
Name
Deborah
La Franchi

Business
Strategy

Application

Due Diligence

Increase character limit for
Question 18.

4/23/2024

National New
Markets Fund

Deborah
La Franchi

Business
Strategy

Application

Track Record
of
Investments

Allow Applicants to report
their track record, and not
their Controlling Entity's.

156

4/23/2024

National New
Markets Fund

Deborah
La Franchi

Community
Outcomes

Application

Add "Persistent Poverty
Counties" to Question
25b.

157

4/23/2024

National New
Markets Fund

Deborah
La Franchi

Community
Outcomes

Application

158

4/23/2024

National New
Markets Fund

Deborah
La Franchi

Community
Outcomes

Application

159

4/23/2024

National New
Markets Fund

Deborah
La Franchi

Exhibits

Application

Commitment
to Areas of
Higher
Distress
Commitment
to Areas of
Higher
Distress
Commitment
to Areas of
Higher
Distress
Track Record
of
Investments

160

4/23/2024

National New
Markets Fund

Deborah
La Franchi

Managemen
t Capacity

Application

Fee Structure

161

4/23/2024

National New
Markets Fund

Deborah
La Franchi

Glossary of
Terms

Application

Disadvantage
Business

The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund
made revisions
based on public
comments.
Comment in support
of proposed or
existing text. No
action necessary.
Comment in support
of proposed or
existing text. No
action necessary.
The CDFI Fund
made revisions
based on public
comments.

155

Revert changes to
Question 25(b).
Remove "higher" or
quantify "higher" in
Question 25(b).
Support allowing
applicants to report their
track record, and not their
Controlling Entity's.
Support requirement to
disclose fees.
Align definition of
"Disadvantage Business"
with SBA.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

162

Date of
Comment
4/18/2024

Author
Name
Dominik
Mjartan

Section

Category

Topic

Comment

NMTC Response

Post Award

Debriefing

Give detailed scoring in
debriefing.

Optus Bank

Dominik
Mjartan

Community
Outcomes

Review
Process

Bonus Points

Give bonus points for
CDFIs.

4/18/2024

Optus Bank

Dominik
Mjartan

Post Award

Debriefing

Give detailed comments in
debriefing.

165

4/17/2024

Smith NMTC
Associates

Donna
Aronoff
Smith

Community
Outcomes

Application

Community
Engagement

166

4/17/2024

Smith NMTC
Associates

Donna
Aronoff
Smith

Business
Strategy/Co
mmunity
Outcome

Application

Housing

Question on community
engagement implies
engagement with local
residents and/or local
economic development
agencies, which create
burden for CDEs serving a
national or large service
area.
Add high housing need as
severe distress criteria or
innovative activities.

The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.
The CDFI Fund
does not have
statutory authority
to implement this
recommendation.
The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.
The CDFI Fund will
consider additional
guidance based on
this comment.

163

4/18/2024

164

Optus Bank

The CDFI Fund will
consider changes in
future application
rounds.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

167

Date of
Comment
4/17/2024

Author
Name
Donna
Aronoff
Smith

Section

Category

Topic

Comment

NMTC Response

Community
Outcomes

Application

Revert changes to
Question 25(b).

Smith NMTC
Associates

Donna
Aronoff
Smith

Community
Outcomes

Application

Commitment
to Areas of
Higher
Distress
Housing

4/17/2024

Smith NMTC
Associates

Donna
Aronoff
Smith

Glossary of
Terms

Application

Disadvantage
Business

170

4/17/2024

Smith NMTC
Associates

Donna
Aronoff
Smith

NOAA

QEI Issuance
Requirements

Revert definition of
"Disadvantage Business"
or add nonprofit
businesses servicing LIC
residents and LIPs.
Reduce QEI issuance
threshold requirement for
non-rural CDEs from 20%
to 0%.

The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund
made revisions
based on public
comments.

168

4/17/2024

169

171

4/23/2024

Dwayne
Lee

Community
Outcomes

Application

Commitment
to Areas of
Higher
Distress

Revert changes to
Question 25(b).

172

4/23/2024

Dwayne
Lee

Glossary of
Terms

Application

Disadvantage
Business

Revert definition of
"Disadvantage Business."

The CDFI Fund
made revisions
based on public
comments.

173

4/23/2024

504
Corporation/A
dvance
CapAccess
(ACA)
504
Corporation/A
dvance
CapAccess
(ACA)
Homeownershi
p Alliance

Elizabeth
Coats

Business
Strategy/Co
mmunity
Outcome

Application

Housing

Add high housing need as
severe distress criteria or
innovative activities.

The CDFI Fund will
consider changes in
future application
rounds.

Smith NMTC
Associates

Increase character limit to
Question 26(a)(8).

The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund
made revisions
based on public
comments.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

174

Date of
Comment
4/23/2024

Section

Category

Topic

Comment

NMTC Response

Homeownershi
p Alliance

Author
Name
Elizabeth
Coats

Community
Outcomes

Application

Revert changes to
Question 25(b).

4/23/2024

Homeownershi
p Alliance

Elizabeth
Coats

Community
Outcomes

Application

Commitment
to Areas of
Higher
Distress
Housing

176

4/23/2024

Homeownershi
p Alliance

Elizabeth
Coats

General

Review
Process

External
Reviewers

Hire external reviewers
with housing experience.

177

4/23/2024

Homeownershi
p Alliance

Elizabeth
Coats

FAQ

Application
Instructions

Housing

Incorporate housing
examples in Phase 1
training & FAQ.

178

4/23/2024

Michigan
Community
Capital

Eric Hanna

Community
Outcomes

Application

Revert changes to
Question 27(c) to discuss
track record.

179

4/23/2024

Michigan
Community
Capital

Eric Hanna

Capitalizati
on Strategy

Application

Community
Accountabilit
y&
Involvement
Capitalization

180

4/23/2024

Michigan
Community
Capital

Eric Hanna

Community
Outcomes

Application

LILA/Healthy
Foods

Revert back to the Healthy
Food Financing Initiative
(HFFI) definition.

The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund will
consider changes in
future application
rounds.
This comment is not
related to burden in
completing the
NMTC Program
Application. The
CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund is
maintaining the
current
requirements.

175

Increase character limit to
Question 26(a)(8).

Restore Question 35 as
one question.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

181

Date of
Comment
4/23/2024

Author
Name
Eric Hanna

Section

Category

Topic

Comment

NMTC Response

Community
Outcomes

Application

Suggest alternate changes
to Question 25(b).

Michigan
Community
Capital

Eric Hanna

Community
Outcomes

Application

4/23/2024

Michigan
Community
Capital

Eric Hanna

Business
Strategy

Application

Commitment
to Areas of
Higher
Distress
Commitment
to Areas of
Higher
Distress
Maximize
Efficiency and
Financial
Impact

The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund will
consider changes in
future application
rounds.

182

4/23/2024

183

184

4/23/2024

Michigan
Community
Capital

Eric Hanna

Community
Outcomes

Review
Process

Bonus Points

185

4/18/2024

Dallas
Development
Fund

Heather
Lepeska

Community
Outcomes

Application

Revert changes to
Question 25(b).

186

4/23/2024

JarredMichael
Erickson

Community
Outcomes

Application

187

4/23/2024

Confederated
Tribes of the
Colville
Reservation
Confederated
Tribes of the
Colville
Reservation

Commitment
to Areas of
Higher
Distress
Federal
Native Areas

JarredMichael
Erickson

Community
Outcomes

Application

Community
Accountabilit
y&
Involvement

Adopt holistic definition
of data in Question 27(b).

Michigan
Community
Capital

Revert changes to
Question 25(b).
Add new question in
Business Strategy to
discuss Applicant's
strategy to maximize
efficiency and financial
impact.
Give bonus points to
CDFIs as Applicants or
Controlling Entities.

Support wording change
to "Federal Native Areas."

The CDFI Fund
does not have
statutory authority
to implement this
recommendation.
The CDFI Fund
made revisions
based on public
comments.
Comment in support
of proposed or
existing text. No
action necessary.
The CDFI Fund will
consider additional
guidance based on
this comment.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#
188

Date of
Comment
4/23/2024

Organization

189

4/23/2024

190

4/23/2024

Community
Development
Bankers
Association

Jeannine
Jacokes

Community
Outcomes

Application

Commitment
to Areas of
Higher
Distress

191

4/23/2024

Jeannine
Jacokes

Community
Outcomes

Application

Community
Goods and
Services

192

4/23/2024

Jeannine
Jacokes

Community
Outcomes

Application

193

4/23/2024

Community
Development
Bankers
Association
Community
Development
Bankers
Association
Community
Development
Bankers
Association

Jeannine
Jacokes

Community
Outcomes

Application

Community
Accountabilit
y&
Involvement
LIC
Involvement
in Past
Investments

Community
Development
Bankers
Association
Community
Development
Bankers
Association

Author
Name
Jeannine
Jacokes

Section

Category

Topic

Comment

NMTC Response

Business
Strategy

Application

Due Diligence

Jeannine
Jacokes

Business
Strategy

Application

Innovative
Investments

Provide some additional
flexibility for Applicants
when responding to this
question.
Support adding 'Investing
in Unrelated Minorityowned or Native
American-owned or
controlled CDEs."
Concerns that new distress
areas may not accurately
reflect need due to data
limitations and may result
in incentivizing different
outcomes than what's
desired.
Remove third-party
metrics requirement for
community goods and
services.
Using data to qualify need
would disadvantage LICs
and Native communities

The CDFI Fund is
maintaining the
current
requirements.
Comment in support
of proposed or
existing text. No
action necessary.

The CDFI Fund should be
more flexible in its
evaluation until the
impacts of the change in
Question 27(b) are fully
understood.

The CDFI Fund
made revisions
based on public
comments.

The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund is
maintaining the
current
requirements.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

194

Date of
Comment
4/23/2024

Author
Name
Jeannine
Jacokes

Section

Category

Topic

Comment

NMTC Response

Managemen
t Capacity

Application

Organization
Capacity/Key
Personnel

The CDFI Fund will
consider additional
guidance based on
this comment.

Community
Development
Bankers
Association

Jeannine
Jacokes

Capitalizati
on Strategy

Application

Management
Experience

Community
Development
Bankers
Association
Community
Development
Bankers
Association
Community
Development
Bankers
Association

Jeannine
Jacokes

Capitalizati
on Strategy

Application

Investor
Letters

Concerns that limiting
Table C2 to leadership
positions will
disadvantage smaller
CDFIs.
Maintain current space
limitations/character
lengths. Do not reduce
character limits or
combine question
responses.
Clarify when a prior
allocatee is required to
provide investor letters.

195

4/23/2024

196

4/23/2024

197

4/23/2024

Jeannine
Jacokes

Exhibits

Application

Business Type

Add "childcare" as
business type in Table A5.

198

4/23/2024

Jeannine
Jacokes

Capitalizati
on Strategy

Application

Management
Experience

4/23/2024

Community
Development
Bankers
Association

Jeannine
Jacokes

Community
Outcomes

Review
Process

Bonus Points

Allow Question 35
narrative to describe track
record raising capital to
offset character count lost
by consolidating Exhibit
E.
Give bonus points for
CDFIs.

199

200

4/23/2024

Community
Development
Bankers
Association

Jeannine
Jacokes

Glossary of
Terms

Application

Disadvantage
Business

Community
Development
Bankers
Association

Revisit updates to
definition.

The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund
does not have
statutory authority
to implement this
recommendation.
The CDFI Fund
made revisions
based on public
comments.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

201

Date of
Comment
4/23/2024

Author
Name
Jeannine
Jacokes

Section

Category

Topic

Comment

NMTC Response

Post Award

Debriefing

Give more robust
feedback in debriefing.

Community
Development
Bankers
Association
Community
Development
Bankers
Association
Native
American Bank

Jeannine
Jacokes

Glossary of
Terms

Application

Disadvantage
Business

Increase maximum
revenue level to $500k.

Jeannine
Jacokes

Glossary of
Terms

Application

Disadvantage
Business

Delay implementation of
definition change and
allow transition period.

Joel Smith

Community
Outcomes

Application

Targeted
Population

Include Indian
Reservation in definition
of "targeted population".

4/23/2024

Native
American Bank

Joel Smith

Community
Outcomes

Application

Federal
Native Areas

Support wording change
to "Federal Native Areas."

4/23/2024

Native
American Bank

Joel Smith

Community
Outcomes

Application

Community
Accountabilit
y&
Involvement

Adopt holistic definition
of data in Question 27(b).

The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund
made revisions
based on public
comments.
Targeted
Populations are
defined in IRS
Regulations, not by
the CDFI Fund
Application
materials.
Comment in support
of proposed or
existing text. No
action necessary.
The CDFI Fund will
consider additional
guidance based on
this comment.

202

4/23/2024

203

4/23/2024

204

4/23/2024

205

206

Community
Development
Bankers
Association

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

207

Date of
Comment
4/23/2024

Author
Name
Joel Smith

Section

Category

Topic

Comment

NMTC Response

General

Review
Process

Set-Aside

Create a set aside for
Native CDEs.

Advantage
Capital

Jonathan
Goldstein

Business
Strategy

Application

Due Diligence

Increase character limit for
Question 18.

4/23/2024

Advantage
Capital

Jonathan
Goldstein

Business
Strategy

Review
Process

Innovative
Investments

Assign scores to Question
19 as incentive for
innovative activities.

210

4/23/2024

Advantage
Capital

Jonathan
Goldstein

Business
Strategy

Application

Innovative
Investments

Add "non-use of affiliate
leverage" as a category of
innovative activity.

211

4/23/2024

Advantage
Capital

Jonathan
Goldstein

Business
Strategy

Application

Financial
Products

Increase character limit for
Question 14.

212

4/23/2024

Advantage
Capital

Jonathan
Goldstein

Business
Strategy,
Exhibits

Application

Track Record
vs Pipeline

213

4/23/2024

Advantage
Capital

Jonathan
Goldstein

Community
Outcomes

Application

Commitment
to Areas of
Higher
Distress

Focus on track record
instead pipeline,
alternatively evaluate
track record for past
awardees and pipeline
projects for new
allocatees.
Revert changes to
Question 25(b).

The CDFI Fund
does not have
statutory authority
to implement this
recommendation.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund is
maintaining the
current
requirements.

208

4/23/2024

209

Native
American Bank

The CDFI Fund
made revisions
based on public
comments.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

214

Date of
Comment
4/23/2024

Section

Category

Topic

Comment

NMTC Response

Advantage
Capital

Author
Name
Jonathan
Goldstein

Exhibits

Application

Operating
businesses

Add "business services" as
business type.

4/23/2024

Advantage
Capital

Jonathan
Goldstein

Glossary of
Terms

Application

Disadvantage
Business

Revert definition of
"Disadvantage Business."

216

4/22/2024

District Honor

Joseph
Crugnale

General

Application

Environmenta
l, Social and
Governance
indicators

Utilize Environmental,
Social, and Governance
indicators in investments.

217

4/23/2024

Southern
Bancorp Bank

Kenya
Davenport

Post Award

Debriefing

Give detailed comments in
debriefing.

218

4/23/2024

Southern
Bancorp Bank

Kenya
Davenport

Post Award

Debriefing

Give detailed scoring in
debriefing.

The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund
made revisions
based on public
comments.
This comment is not
related to burden in
completing the
NMTC Program
Application. The
CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.
The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.

215

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

219

Date of
Comment
4/23/2024

Author
Name
Kenya
Davenport

Section

Category

Topic

Comment

NMTC Response

Community
Outcomes

Review
Process

Bonus Points

Give bonus points for
CDFIs.

Illinois
Facilities Fund
- IFF

Kirby
Burkholder

Post Award

Debriefing

Give detailed comments in
debriefing.

4/23/2024

Illinois
Facilities Fund
- IFF

Kirby
Burkholder

Post Award

Debriefing

Give detailed scoring in
debriefing.

222

4/23/2024

Illinois
Facilities Fund
- IFF

Kirby
Burkholder

Community
Outcomes

Review
Process

Bonus Points

Give bonus points for
CDFIs.

223

4/23/2024

African
American
Alliance of
CDFI CEOs

Lenwood
Long

Business
Strategy

Application

Due Diligence

Due diligence
documentation requires
applicants to maintain
extensive records which
may exceed the assumed
preparation hours.

The CDFI Fund
does not have
statutory authority
to implement this
recommendation.
The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.
The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.
The CDFI Fund
does not have
statutory authority
to implement this
recommendation.
The CDFI Fund is
maintaining the
current
requirements.

220

4/23/2024

221

Southern
Bancorp Bank

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#
224

Date of
Comment
4/23/2024

225

4/23/2024

226

4/23/2024

227

4/23/2024

228

4/23/2024

229

4/23/2024

230

4/23/2024

Organization
African
American
Alliance of
CDFI CEOs
African
American
Alliance of
CDFI CEOs
African
American
Alliance of
CDFI CEOs
African
American
Alliance of
CDFI CEOs
African
American
Alliance of
CDFI CEOs
African
American
Alliance of
CDFI CEOs
African
American
Alliance of
CDFI CEOs

Author
Name
Lenwood
Long

Section

Category

Topic

Comment

NMTC Response

Business
Strategy

Application

Total QEI
Needs

Lenwood
Long

Business
Strategy

Application

Due Diligence

Describing detailed
investment strategy based
on community input
increase burden.
Support changes to
Question 18.

Lenwood
Long

Community
Outcomes

Application

Lenwood
Long

Managemen
t Capacity

Application

Community
Accountabilit
y&
Involvement
Organization
Capacity/Key
Personnel

Lenwood
Long

Business
Strategy

Application

Financial
Products

The CDFI Fund is
maintaining the
current
requirements.
Comment in support
of proposed or
existing text. No
action necessary.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund will
consider additional
guidance based on
this comment.

Lenwood
Long

Business
Strategy

Application

Financial
Products

Lenwood
Long

Business
Strategy

Application

Financial
Products

Describing the
involvement of LIC
representatives takes time.
Information required adds
complexity that requires
additional resources which
increases costs.
Articulate distinction
between descriptions for
multiple financial
products. Provide
examples.
Provide examples of
financial product
narratives or scoring
rubric.
Support revision in
Questions 14(a) & 14(b)

The CDFI Fund will
consider additional
guidance based on
this comment.
Comment in support
of proposed or
existing text. No
action necessary.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

231

Date of
Comment
4/23/2024

Author
Name
Lenwood
Long

Section

Category

Topic

Comment

NMTC Response

Business
Strategy

Application

Financial
Products

The CDFI Fund will
consider additional
guidance based on
this comment.

African
American
Alliance of
CDFI CEOs
African
American
Alliance of
CDFI CEOs

Lenwood
Long

Business
Strategy

Application

Financial
Products

Providing distinct
narratives for each
financial product and
detailed description of
product structuring
increases burden and cost
to prepare application.
Simplify requirements or
provide tool to calculate
blended interest rate.

232

4/23/2024

233

4/23/2024

Lenwood
Long

Business
Strategy

Application

Financial
Products

234

4/23/2024

African
American
Alliance of
CDFI CEOs
African
American
Alliance of
CDFI CEOs
African
American
Alliance of
CDFI CEOs
African
American
Alliance of
CDFI CEOs

Lenwood
Long

Business
Strategy

Application

Financial
Products

318

4/23/2024

Lenwood
Long

Business
Strategy

Application

Invest in
Other CDEs

Provide example or
template for Question
14(c).

236

4/23/2024

Lenwood
Long

Business
Strategy

Application

Invest in
Other CDEs

Provide example or
template for Question
14(c).

237

4/23/2024

Lenwood
Long

Business
Strategy

Application

Invest in
Other CDEs

Revert changes to
instructions for Question
14(c).

African
American
Alliance of
CDFI CEOs

Provide example or
template for Question
14(b). Simplify
requirements or provide
calculation tools.
Describing circumstances
of terms and rates increase
burden.

The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund is
maintaining the
current
requirements.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

238

Date of
Comment
4/23/2024

Author
Name
Lenwood
Long

Section

Category

Topic

Comment

NMTC Response

Community
Outcomes

Application

Lenwood
Long

Business
Strategy

Application

Explain criteria used to
assess the quality and
alignment of community
input with investment
strategies.
Provide tool to calculate
and align QEI needs with
allocation request.

The CDFI Fund will
consider additional
guidance based on
this comment.

African
American
Alliance of
CDFI CEOs
African
American
Alliance of
CDFI CEOs

Align
Investment
with
Community
Input
Total QEI
Needs

239

4/23/2024

240

4/23/2024

Lenwood
Long

Business
Strategy

Application

Support changes to
Question 17(c).

African
American
Alliance of
CDFI CEOs
African
American
Alliance of
CDFI CEOs
African
American
Alliance of
CDFI CEOs
African
American
Alliance of
CDFI CEOs
African
American
Alliance of
CDFI CEOs

Lenwood
Long

Community
Outcomes

IT
Enhancement

Lenwood
Long

Community
Outcomes

Application

Lenwood
Long

Community
Outcomes

Application

Lenwood
Long

Community
Outcomes

Application

Lenwood
Long

Community
Outcomes

Application

Align
Investment
with
Community
Input
Commitment
to Areas of
Higher
Distress
Commitment
to Areas of
Higher
Distress
Commitment
to Areas of
Higher
Distress
Commitment
to Areas of
Higher
Distress
Commitment
to Areas of
Higher
Distress

241

4/23/2024

242

4/23/2024

243

4/23/2024

244

4/23/2024

245

4/23/2024

African
American
Alliance of
CDFI CEOs

Provide mapping tool or
database for qualified
distressed areas.
Provide guideline, scoring
rubric and scoring metric
for Question 25(b).
Analyzing data on areas of
distress will increase
costs.
Commitment to invest in
specific distress areas
increase admin burden and
costs.
Commitment to invest in
specific distress areas
increase admin burden and
costs.

The CDFI Fund will
consider changes in
future application
rounds.
Comment in support
of proposed or
existing text. No
action necessary.
The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider additional
guidance based on
this comment.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#
246

Date of
Comment
4/23/2024

Organization

Author
Name
Lenwood
Long

Section

Category

Topic

Comment

NMTC Response

Community
Outcomes

Application

Request for questions to
be reformatted or add a
table.

Lenwood
Long

Community
Outcomes

Application

Community
Accountabilit
y&
Involvement
Community
Engagement

Lenwood
Long

Managemen
t Capacity

Application

Key Personnel

The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund is
maintaining the
current
requirements.

247

4/23/2024

248

4/23/2024

249

4/23/2024

250

4/23/2024

251

4/23/2024

African
American
Alliance of
CDFI CEOs

Lenwood
Long

Managemen
t Capacity

Application

Organization
capacity/Key
Personnel

Make sure to consider
wide range of CDEs, not
just those with
experienced management
structures.
Add dropdown menu or
autofill option to
incorporate prior year
submissions.
Support collecting detailed
descriptions of org
structure, key personnel
and experience providing
QLICIs.
Need to possibly hire
additional staff will
increase operational cost.

African
American
Alliance of
CDFI CEOs
African
American
Alliance of
CDFI CEOs

Lenwood
Long

Managemen
t Capacity

IT
Enhancement

management
experience

Lenwood
Long

Managemen
t Capacity

Application

management
experience

252

4/23/2024

African
American
Alliance of
CDFI CEOs

Lenwood
Long

Managemen
t Capacity

Application

Organization
Capacity/Key
Personnel

Provide clarification on
expectations for key
personnel.

African
American
Alliance of
CDFI CEOs
African
American
Alliance of
CDFI CEOs
African
American
Alliance of
CDFI CEOs

Make sure engagement is
flexible and reflects
unique communities.

The CDFI Fund will
consider additional
guidance based on
this comment.
Comment in support
of proposed or
existing text. No
action necessary.
The CDFI Fund will
continue its efforts
to reduce burden in
future application
rounds.
The CDFI Fund will
consider additional
guidance based on
this comment.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

253

Date of
Comment
4/23/2024

Author
Name
Lenwood
Long

Section

Category

Topic

Comment

NMTC Response

Capitalizati
on Strategy

Application

Capitalization

The CDFI Fund will
consider changes in
future application
rounds.

African
American
Alliance of
CDFI CEOs

Lenwood
Long

Capitalizati
on Strategy

Application

Raising
Capital

African
American
Alliance of
CDFI CEOs
African
American
Alliance of
CDFI CEOs

Lenwood
Long

Capitalizati
on Strategy

IT
Enhancement

Capitalization

Consider incorporating
CDE overarching goals
and impact into
strategy/track record of
raising capital.
Documenting track record
of capital raising and
investment partnership is
challenging and could
increase cost.
Add or integrate digital
templates for these
questions.

254

4/23/2024

255

4/23/2024

256

4/23/2024

Lenwood
Long

Capitalizati
on Strategy

Application

Capitalization

257

4/23/2024

African
American
Alliance of
CDFI CEOs

Lenwood
Long

Capitalizati
on Strategy

Application

Capitalization

258

4/23/2024

African
American
Alliance of
CDFI CEOs

Lenwood
Long

Business
Strategy

Application

Innovation in
Financial
Product

African
American
Alliance of
CDFI CEOs

Provide instructions and
formats for Questions 3537. Share preferred format
for Commitment Letters
and Letters of Intent.
Do not focus exclusively
on ability or track record
of raising capital. Add
consideration for
CDFI/Minority-CDEs that
demonstrate growth
potential and community
impact.
Provide space for CDEs to
discuss any innovative
features of their financial
products.

The CDFI Fund will
continue its efforts
to reduce burden in
future application
rounds.
The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund is
maintaining the
current
requirements.

The CDFI Fund will
consider changes in
future application
rounds.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

259

Date of
Comment
4/23/2024

Author
Name
Lenwood
Long

Section

Category

Topic

Comment

NMTC Response

Community
Outcomes

Application

Sustainability
and Viability
of
Investments

The CDFI Fund will
consider changes in
future application
rounds.

African
American
Alliance of
CDFI CEOs
African
American
Alliance of
CDFI CEOs

Lenwood
Long

Community
Outcomes

Application

Lenwood
Long

AMIS

IT
Enhancement

Anticipated
Social and
Economic
Impact
Online
Application
Portal

African
American
Alliance of
CDFI CEOs

Lenwood
Long

Provide
Feedback

PRA

Add a question that
encourages CDEs to
discuss their strategies for
ensuring the sustainability
and long-term viability of
their investments
(reinvestments, additional
capital, lasting benefits).
Add a question focused on
anticipated social and
economic impact of the
proposed investments.
Suggest various format
updates, functionality
improvements to the
online application
interface for Applicants.
Provide incentives for
CDEs to actively provide
feedback to draft
application.

260

4/23/2024

261

4/23/2024

262

4/23/2024

African
American
Alliance of
CDFI CEOs

Review Draft
Application

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

263

Date of
Comment
4/23/2024

Author
Name
Lenwood
Long

Section

Category

Topic

Comment

NMTC Response

Customer
Service

Capacity
Building

Provide
Technical
Assistance

Provide technical
assistance grants for
smaller CDEs.

African
American
Alliance of
CDFI CEOs

Lenwood
Long

Provide
Feedback

PRA

Review Draft
Application

Add a process for CDEs to
receive feedback on draft
applications.

4/23/2024

African
American
Alliance of
CDFI CEOs

Lenwood
Long

Capitalizati
on Strategy

Application

Raising
Capital

Describing history and
strategies to raise capital
require additional
expertise/burden.

4/23/2024

African
American
Alliance of
CDFI CEOs

Lenwood
Long

General

Application

Streamline
Application

Streamline application to
essential info will be more
cost efficient for smaller
or resource-constrained
CDEs.

264

4/23/2024

265

266

African
American
Alliance of
CDFI CEOs

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

267

Date of
Comment
4/23/2024

Author
Name
Lenwood
Long

Section

Category

Topic

Comment

NMTC Response

Estimated
Hours of
Burden

PRA

CDFI Fund
Burden
Estimate
(hours)

Current burden estimate
may underrepresent true
cost of burden.

African
American
Alliance of
CDFI CEOs

Lenwood
Long

Post Award

Debriefing

Give more robust
feedback in debriefing.

4/23/2024

African
American
Alliance of
CDFI CEOs

Lenwood
Long

Customer
Service

Capacity
Building

Provide
Technical
Assistance

Provide technical
assistance for revised
application sections.

270

4/23/2024

African
American
Alliance of
CDFI CEOs

Lenwood
Long

Customer
Service

Capacity
Building

Conduct
Research

271

4/23/2024

African
American
Alliance of
CDFI CEOs

Lenwood
Long

Customer
Service

Capacity
building

Develop
Partnerships

Conduct research to
review participation and
successes of Minority
CDEs and understand
barriers to entry and
success.
Develop partnerships with
organizations to provide
capacity building
assistance for Minority
CDEs.

The CDFI Fund will
continue its efforts
to reduce burden in
future application
rounds.
The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.
This comment is not
related to burden in
completing the
NMTC Program
Application. The
CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.

268

4/23/2024

269

African
American
Alliance of
CDFI CEOs

The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

272

Date of
Comment
4/23/2024

Author
Name
Lenwood
Long

Section

Category

Topic

Comment

NMTC Response

Managemen
t Capacity

Application

Organization
Capacity/Key
Personnel

African
American
Alliance of
CDFI CEOs
African
American
Alliance of
CDFI CEOs

Lenwood
Long

General

Application
Instructions

Cost to Apply

Lenwood
Long

Customer
Service

Capacity
Building

Provide
Technical
Assistance

Detailed information
requested may increase
burden for new Applicants
or those with recent
structural changes.
Provide guidance and
clarification so CDEs can
better estimate cost to
apply.
Provide technical
assistance to Minority
CDEs.

4/23/2024

African
American
Alliance of
CDFI CEOs

Lenwood
Long

Community
Outcomes

Review
Process

Bonus Points

Give bonus points for
CDFIs.

276

4/23/2024

African
American
Alliance of
CDFI CEOs

Lenwood
Long

General

Review
Process

Minority-led
CDEs

Revise review process to
evaluate experience and
performance of Minority
CDEs.

277

4/23/2024

Mid-City
Community
CDE

Lois Fried

Community
Outcomes

Application

Federal/State/
Local Zones

Restore
"federal/state/local zones"
as an area of distress.

The CDFI Fund will
continue its efforts
to reduce burden in
future application
rounds.
The CDFI Fund will
consider additional
guidance based on
this comment.
This comment is not
related to burden in
completing the
NMTC Program
Application. The
CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund
does not have
statutory authority
to implement this
recommendation.
The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund is
maintaining the
current
requirements.

273

4/23/2024

274

4/23/2024

275

African
American
Alliance of
CDFI CEOs

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

278

Date of
Comment
4/23/2024

Author
Name
Lois Fried

Section

Category

Topic

Comment

NMTC Response

Community
Outcomes

Application

Revert changes to
Question 25(b).

Mid-City
Community
CDE

Lois Fried

Glossary of
Terms

Application

Commitment
to Areas of
Higher
Distress
Disadvantage
Business

The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund
made revisions
based on public
comments.

279

4/23/2024

280

4/18/2024

Primary Care
Development
Corporation

Louise
Cohen

Community
Outcomes

Application

281

4/18/2024

Primary Care
Development
Corporation

Louise
Cohen

Community
Outcomes

Application

282

4/22/2024

Low Income
Investment
Fund

Makenzi
Sumners

Post Award

Debriefing

Mid-City
Community
CDE

Commitment
to Areas of
Higher
Distress
Medically
Underserved
Areas
Debriefing

Revert definition of
"Disadvantage Business"
or provide clarification to
include for-profit
businesses that create
benefits for LIC residents
or LIPs, or postpone
changes apply to
transactions closed after
1/1/25.
Concern about changes to
Question 25(b).
Support adding Healthcare
Professional Shortage
Areas (HPSAs).
Give detailed scoring in
debriefing.

The CDFI Fund
made revisions
based on public
comments.
Comment in support
of proposed or
existing text. No
action necessary.
The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

283

Date of
Comment
4/22/2024

Author
Name
Makenzi
Sumners

Section

Category

Topic

Comment

NMTC Response

Community
Outcomes

Review
Process

Bonus Points

Give bonus points for
CDFIs.

Low Income
Investment
Fund

Makenzi
Sumners

Post Award

Debriefing

Give detailed comments in
debriefing.

4/23/2024

Invest Detroit

Marcia
Ventura

Community
Outcomes

Application

Commitment
to Areas of
Higher
Distress

286

4/23/2024

Invest Detroit

Marcia
Ventura

General

Review
Process

Scoring
Process

Revert changes to
Question 25(b). Suggest
moving question to
Innovative Activity or
Phase 2.
Request changes to
increase scoring
variability.

284

4/22/2024

285

287

4/23/2024

Invest Detroit

Marcia
Ventura

Post Award

Debriefing

Low Income
Investment
Fund

Give more robust
feedback in debriefing.

The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

288

Date of
Comment
4/23/2024

Section

Category

Topic

Comment

NMTC Response

The Housing
Fund

Author
Name
Marshall
Crawford

Business
Strategy

Application

Total QEI
Needs

4/23/2024

The Housing
Fund

Marshall
Crawford

Business
Strategy

Application

Due Diligence

The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund is
maintaining the
current
requirements.

290

4/23/2024

The Housing
Fund

Marshall
Crawford

Business
Strategy

Application

Due Diligence

Describing detailed
investment strategy based
on community input
increase burden.
Due diligence
documentation requires
applicants to maintain
extensive records which
may exceed the assumed
preparation hours.
Support due diligence
requirement.

289

319

4/23/2024

The Housing
Fund

Marshall
Crawford

Business
Strategy

Application

Due Diligence

Provide checklist for due
diligence.

292

4/23/2024

The Housing
Fund

Marshall
Crawford

Community
Outcomes

Application

Describing the
involvement of LIC
representatives takes time.

293

4/23/2024

The Housing
Fund

Marshall
Crawford

Business
Strategy

Application

Community
Accountabilit
y&
Involvement
Financial
Products

294

4/23/2024

The Housing
Fund

Marshall
Crawford

Business
Strategy

Application

Financial
Products

Articulate distinction
between descriptions for
multiple financial
products. Provide
examples.
Support requiring distinct
narratives for financial
products.

Comment in support
of proposed or
existing text. No
action necessary.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund will
consider additional
guidance based on
this comment.
Comment in support
of proposed or
existing text. No
action necessary.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

295

Date of
Comment
4/23/2024

Section

Category

Topic

Comment

NMTC Response

The Housing
Fund

Author
Name
Marshall
Crawford

Business
Strategy

Application

Financial
Products

The CDFI Fund will
consider additional
guidance based on
this comment.

4/23/2024

The Housing
Fund

Marshall
Crawford

Business
Strategy

Application

Financial
Products

297

4/23/2024

The Housing
Fund

Marshall
Crawford

Business
Strategy

Application

Financial
Products

Providing distinct
narratives for each
financial product and
detailed description of
product structuring
increases burden and cost
to prepare application.
Provide example or
template for Question
14(b). Simplify
requirements or provide
calculation tools.
Describing circumstances
of terms and rates increase
burden.

296

298

4/23/2024

The Housing
Fund

Marshall
Crawford

Business
Strategy

Application

Invest in
Other CDEs

Revert changes to
instructions for Question
14(c).

299

4/23/2024

The Housing
Fund

Marshall
Crawford

Business
Strategy

Application

Invest in
Other CDEs

Provide example or
template for Question
14(c).

300

4/23/2024

The Housing
Fund

Marshall
Crawford

Community
Outcomes

Application

301

4/23/2024

The Housing
Fund

Marshall
Crawford

Business
Strategy

Application

Align
Investment
with
Community
Input
Total QEI
Needs

Explain criteria used to
assess the quality and
alignment of community
input with investment
strategies.
Provide tool to calculate
and align QEI needs with
allocation request.

The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider changes in
future application
rounds.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

302

Date of
Comment
4/23/2024

Section

Category

Topic

Comment

NMTC Response

The Housing
Fund

Author
Name
Marshall
Crawford

Business
Strategy

Application

Support changes to
Question 17(c).

Comment in support
of proposed or
existing text. No
action necessary.

4/23/2024

The Housing
Fund

Marshall
Crawford

Community
Outcomes

IT
Enhancement

Provide mapping tool or
database for qualified
distressed areas.

304

4/23/2024

The Housing
Fund

Marshall
Crawford

Community
Outcomes

Application

305

4/23/2024

The Housing
Fund

Marshall
Crawford

Community
Outcomes

Application

306

4/23/2024

The Housing
Fund

Marshall
Crawford

Community
Outcomes

Application

307

4/23/2024

The Housing
Fund

Marshall
Crawford

Community
Outcomes

Application

308

4/23/2024

The Housing
Fund

Marshall
Crawford

Community
Outcomes

Application

303

The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider additional
guidance based on
this comment.

Provide guideline, scoring
rubric and scoring metric
for Question 25(b).
Analyzing data on areas of
distress will increase
costs.
Commitment to invest in
specific distress areas
increase admin burden and
costs.
Make sure definition of
distress indicators are
clear.
Maintain flexibility to
acknowledge differences
in local governance,
organization type, and
approaches to engage
feedback.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

309

Date of
Comment
4/23/2024

Section

Category

Topic

Comment

NMTC Response

The Housing
Fund

Author
Name
Marshall
Crawford

Community
Outcomes

Application

Request for questions to
be reformatted or add a
table.

4/23/2024

The Housing
Fund

Marshall
Crawford

Managemen
t Capacity

Application

Community
Accountabilit
y&
Involvement
Organization
Capacity/Key
Personnel

311

4/23/2024

The Housing
Fund

Marshall
Crawford

Managemen
t Capacity

Application

management
experience

312

4/23/2024

The Housing
Fund

Marshall
Crawford

Managemen
t Capacity

Application

Organization
capacity/Key
Personnel

313

4/23/2024

The Housing
Fund

Marshall
Crawford

Managemen
t Capacity

Application

Organization
Capacity/Key
Personnel

Add dropdown menu or
autofill option to
incorporate prior year
submissions.
Information required adds
complexity that requires
additional resources which
increases costs.
Provide clarification on
expectations for key
personnel.

314

4/23/2024

The Housing
Fund

Marshall
Crawford

Capitalizati
on Strategy

Application

Capitalization

The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider changes in
future application
rounds.

310

315

4/23/2024

The Housing
Fund

Marshall
Crawford

Capitalizati
on Strategy

Application

Raising
Capital

316

4/23/2024

The Housing
Fund

Marshall
Crawford

Capitalizati
on Strategy

Application

Capitalization

Ensure consideration is
not limited to experienced
CDEs.

Ensure expectations for
leveraging non-equity
investments are grounded
in current and potential
capabilities.
Documenting track record
of capital raising and
investment partnership is
challenging and could
increase cost.
Add or integrate digital
templates for these
questions.

The CDFI Fund will
continue its efforts
to reduce burden in
future application
rounds.
The CDFI Fund will
consider changes in
future application
rounds.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

317

Date of
Comment
4/23/2024

Section

Category

Topic

Comment

NMTC Response

The Housing
Fund

Author
Name
Marshall
Crawford

Capitalizati
on Strategy

Application

Capitalization

The CDFI Fund will
consider additional
guidance based on
this comment.

4/23/2024

The Housing
Fund

Marshall
Crawford

Business
Strategy

Application

innovation in
financial
product

321

4/23/2024

The Housing
Fund

Marshall
Crawford

Community
Outcomes

Application

Sustainability
and Viability
of
Investments

322

4/23/2024

The Housing
Fund

Marshall
Crawford

AMIS

IT
Enhancement

Online
Application
Portal

149

4/23/2024

The Housing
Fund

Marshall
Crawford

Provide
Feedback

PRA

Review Draft
Application

Provide instructions and
formats for Questions 3537. Share preferred format
for Commitment Letters
and Letters of Intent.
Provide space for CDEs to
discuss any innovative
features of their financial
products.
Add a question that
encourages CDEs to
discuss their strategies for
ensuring the sustainability
and long-term viability of
their investments
(reinvestments, additional
capital, lasting benefits).
Suggest various format
updates, functionality
improvements to the
online application
interface for Applicants.
Provide incentives for
CDEs to actively provide
feedback to draft
application.

320

The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund will
consider changes in
future application
rounds.

The CDFI Fund will
consider additional
guidance based on
this comment.
This comment is not
related to burden in
completing the
NMTC Program
Application. The
CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

235

Date of
Comment
4/23/2024

Section

Category

Topic

Comment

NMTC Response

The Housing
Fund

Author
Name
Marshall
Crawford

Provide
Feedback

PRA

Review Draft
Application

Add a process for CDEs to
receive feedback on draft
applications.

4/23/2024

The Housing
Fund

Marshall
Crawford

Capitalizati
on Strategy

Application

Raising
Capital

Describing history and
strategies to raise capital
require additional
expertise/burden.

324

4/23/2024

The Housing
Fund

Marshall
Crawford

Customer
Service

Capacity
Building

Conduct
Research

325

4/23/2024

The Housing
Fund

Marshall
Crawford

Community
Outcomes

Application

Impact of
investments
on LIPs/LICs

326

4/23/2024

The Housing
Fund

Marshall
Crawford

Estimated
Hours of
Burden

PRA

CDFI Fund
Burden
Estimate
(hours)

Conduct research to
review participation and
successes of Minority
CDEs and understand
barriers to entry and
success.
Substantiating impact for
LICs/LIPs requires
additional analyst, which
might increase burden.
Current burden estimate
may underrepresent true
cost of burden.

This comment is not
related to burden in
completing the
NMTC Program
Application. The
CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund will
continue its efforts
to reduce burden in
future application
rounds.
The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.

323

The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund will
continue its efforts
to reduce burden in
future application
rounds.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

327

Date of
Comment
4/23/2024

Section

Category

Topic

Comment

NMTC Response

The Housing
Fund

Author
Name
Marshall
Crawford

Customer
Service

Capacity
Building

Provide
Technical
Assistance

Provide technical
assistance for revised
application sections.

4/23/2024

The Housing
Fund

Marshall
Crawford

Customer
Service

Capacity
building

Develop
Partnerships

329

4/23/2024

The Housing
Fund

Marshall
Crawford

Managemen
t Capacity

Application

Management
Experience

330

4/23/2024

The Housing
Fund

Marshall
Crawford

General

Application
Instructions

Cost to Apply

331

4/23/2024

The Housing
Fund

Marshall
Crawford

Business
Strategy

Application

Social &
economic
Impact

Develop partnerships with
organizations to provide
capacity building
assistance for Minority
CDEs.
Revisions could increase
burden and cost,
especially for new CDEs
or those with recent
changes.
Provide guidance and
clarification so CDEs can
better estimate cost to
apply.
Add a question focused on
anticipated social and
economic impact of the
proposed investments.

This comment is not
related to burden in
completing the
NMTC Program
Application. The
CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund will
continue its efforts
to reduce burden in
future application
rounds.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund is
maintaining the
current
requirements.

328

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

332

Date of
Comment
4/23/2024

Section

Category

Topic

Comment

NMTC Response

The Housing
Fund

Author
Name
Marshall
Crawford

Customer
Service

Capacity
building

Provide
Technical
Assistance

Provide technical
assistance to Minority
CDEs.

4/23/2024

The Housing
Fund

Marshall
Crawford

Community
Outcomes

Review
Process

Bonus Points

Give bonus points for
CDFIs.

334

4/23/2024

The Housing
Fund

Marshall
Crawford

General

Review
Process

Minority-led
CDEs

Revise review process to
evaluate experience and
performance of Minority
CDEs.

335

4/23/2024

The Housing
Fund

Marshall
Crawford

Post Award

Debriefing

Give detailed comments in
debriefing.

336

4/16/2024

Opportunity
Finance
Network

Mary Scott
Balys

Community
Outcomes

Review
Process

Bonus Points

Give bonus points for
CDFIs.

This comment is not
related to burden in
completing the
NMTC Program
Application. The
CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund
does not have
statutory authority
to implement this
recommendation.
The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.
The CDFI Fund
does not have
statutory authority
to implement this
recommendation.

333

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

337

Date of
Comment
4/16/2024

Author
Name
Mary Scott
Balys

Section

Category

Topic

Comment

NMTC Response

Glossary of
Terms

Application

Disadvantage
Business

Opportunity
Finance
Network

Mary Scott
Balys

Post Award

Debriefing

Have concerns about
$100K revenue limit.
Propose revisions to
glossary term.
Give detailed comments in
debriefing.

4/23/2024

Local
Initiatives
Support
Corporation

Matthew
Josephs

Business
Strategy

Application

Innovative
Investments

The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.
The CDFI Fund will
consider changes in
future application
rounds.

338

4/16/2024

339

340

4/23/2024

Local
Initiatives
Support
Corporation

Matthew
Josephs

Community
Outcomes

Application

Community
Outcomes

341

4/23/2024

Local
Initiatives
Support
Corporation

Matthew
Josephs

Community
Outcomes

Application

Commitment
to Areas of
Higher
Distress

Opportunity
Finance
Network

Recommend that the
determination of what
qualifies as an
underserved state be
reconsidered.
Request a comprehensive
list of metrics for each
community outcome and
the elimination of the
menu approach to
selecting community
outcomes.
Suggest moving question
to Innovative Activity.

The CDFI Fund will
consider additional
guidance based on
this comment.

The CDFI Fund is
maintaining the
current
requirements.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

342

Date of
Comment
4/23/2024

Author
Name
Matthew
Josephs

Section

Category

Topic

Comment

NMTC Response

Managemen
t Capacity

Application

Board/Key
Personnel/Staf
fing

The CDFI Fund is
maintaining the
current
requirements.

Local
Initiatives
Support
Corporation

Matthew
Josephs

Managemen
t Capacity

Application

Organization
Capacity/Key
Personnel

Local
Initiatives
Support
Corporation
Local
Initiatives
Support
Corporation
Local
Initiatives
Support
Corporation

Matthew
Josephs

Capitalizati
on Strategy

Application

Track Record
of Raising
Capital

Matthew
Josephs

Capitalizati
on Strategy

Application

Investor
Letters

Management capacity
narratives are time
consuming and should not
be necessary for prior
Allocatees. Consider only
requiring the Tables C1 &
C2.
Only require narratives for
past allocatees that have
experienced changes in its
key personnel or had
issues with prior
allocation.
Streamline questions for
Applicants that have a
track record of raising and
deploying capital.
Do away with requiring
investor letters or letters of
intent.

343

4/23/2024

344

4/23/2024

345

4/23/2024

346

4/23/2024

Matthew
Josephs

Managemen
t Capacity

Application

Fee Structure

Local
Initiatives
Support
Corporation

Concerned that the
question and table do not
capture all fees, which
might favor CDEs who are
banks.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

347

Date of
Comment
4/23/2024

Author
Name
Matthew
Josephs

Section

Category

Topic

Comment

NMTC Response

Managemen
t Capacity

Application

Fee Structure

The CDFI Fund will
consider changes in
future application
rounds.

Local
Initiatives
Support
Corporation
Local
Initiatives
Support
Corporation

Matthew
Josephs

NOAA

CDE
Certification

Matthew
Josephs

General

Review
Process

Scoring
Process

Consider (1) moving
Question 34 and Table D3
to Business Strategy so
that they are scored: (2)
factor into scoring whether
the Applicant is relying on
third-party entities to
support the bulk of their
NMTC deployment
activities; and (3) reduce
burden for prior allocatees
by reviewing fee data
already collected in the
TLR.
Concerns/suggestions
regarding requiring CDEs
be certified by the NOAA
publication date.
Various ideas for
increasing scoring
variability.

348

4/23/2024

349

4/23/2024

350

4/23/2024

Local
Initiatives
Support
Corporation

Matthew
Josephs

NOAA

QEI Issuance
Requirements

Local
Initiatives
Support
Corporation

Reduce QEI issuance
threshold requirement for
non-rural CDEs from 20%
to 0%.

The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

351

Date of
Comment
4/23/2024

Author
Name
Matthew
Josephs

Section

Category

Topic

Comment

NMTC Response

Post Award

Review
Process

Increased
Transparency

Clarify what causes
successful Applicants to
receive reductions in their
award amount.

Local
Initiatives
Support
Corporation

Matthew
Josephs

Post Award

Debriefing

Give more robust
feedback in debriefing.

4/23/2024

Local
Initiatives
Support
Corporation

Matthew
Josephs

Previous
Awards

Application

Information
on Previous
Awards

Part V should be scored.

354

4/23/2024

Community
Reinvestment
Fund

Matthew
Roth

Community
Outcomes

Application

Propose moving area of
deeper distress to Question
19.

355

4/23/2024

Community
Reinvestment
Fund

Matthew
Roth

Community
Outcomes

Application

Commitment
to Areas of
Higher
Distress
Quality Jobs

The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.
The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.
This comment is not
related to burden in
completing the
NMTC Program
Application. The
CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund will
consider additional
guidance based on
this comment.

352

4/23/2024

353

Local
Initiatives
Support
Corporation

Propose standardizing
definition of "Quality
Jobs."

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

356

Date of
Comment
4/23/2024

Author
Name
Matthew
Roth

Section

Category

Topic

Comment

NMTC Response

Post Award

Debriefing

Give detailed comments in
debriefing.

Community
Reinvestment
Fund

Matthew
Roth

General

Review
Process

Phase 1
Review
Instructions

Share instructions given to
Phase 1 reviewers.

4/23/2024

Community
Reinvestment
Fund

Matthew
Roth

Post Award

Debriefing

Give detailed scoring in
debriefing.

4/23/2024

Community
Reinvestment
Fund

Matthew
Roth

Community
Outcomes

Review
Process

Bonus Points

Give bonus points for
CDFIs.

The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.
This comment is not
related to burden in
completing the
NMTC Program
Application. The
CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.
The CDFI Fund
does not have
statutory authority
to implement this
recommendation.

357

4/23/2024

358

359

Community
Reinvestment
Fund

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

360

Date of
Comment
4/23/2024

Author
Name
Matthew
Roth

Section

Category

Topic

Comment

NMTC Response

Glossary of
Terms

Application

Disadvantage
Business

The CDFI Fund
made revisions
based on public
comments.

Peoples Bank

Michael
Tolleson

Post Award

Debriefing

Suggest alternate revision
for "Disadvantage
Business", and to postpone
implementation until CY
2026 round.
Give detailed scoring in
debriefing.

361

4/17/2024

362

4/17/2024

Peoples Bank

Michael
Tolleson

Community
Outcomes

Review
Process

Bonus Points

Give bonus points for
CDFIs.

363

4/17/2024

Peoples Bank

Michael
Tolleson

Post Award

Debriefing

Give detailed comments in
debriefing.

364

4/23/2024

River Gorge
Capital

Monica
Blanton

Community
Outcomes

Application

Federal/State/
Local Zones

Restore
"federal/state/local zones"
as an area of distress.

365

4/23/2024

River Gorge
Capital

Monica
Blanton

Community
Outcomes

Application

Commitment
to Areas of
Higher
Distress

Revert changes to
Question 25(b).

Community
Reinvestment
Fund

The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.
The CDFI Fund
does not have
statutory authority
to implement this
recommendation.
The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund
made revisions
based on public
comments.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

366

Date of
Comment
4/23/2024

Author
Name
Monica
Blanton

Section

Category

Topic

Comment

NMTC Response

Glossary of
Terms

Application

Disadvantage
Business

The CDFI Fund
made revisions
based on public
comments.

COPAL
(Communidade
s Organizando
el Poder y la
Accion Latina)
NMTC
Coalition Rapoza
Associates
NMTC
Coalition Rapoza
Associates

Moriah
O'Malley

Community
Outcomes

Application

Commitment
to Areas of
Higher
Distress

Revert definition of
"Disadvantage Business"
or add nonprofit
businesses servicing LIC
residents and LIPs.
Revert changes to
Question 25(b).

367

4/16/2024

368

4/23/2024

Paul
Anderson

Business
Strategy

Application

Additional
Flexibility for
Debt

Correct typo in Question
15(a).

Paul
Anderson

Business
Strategy

Application

Innovative
Investments

NMTC
Coalition Rapoza
Associates
NMTC
Coalition Rapoza
Associates

Paul
Anderson

Community
Outcomes

Application

Community
Goods and
Services

Support adding 'Investing
in Unrelated Minorityowned or Native
American-owned or
controlled CDEs."
Add "childcare" as
example in Question 26.

The CDFI Fund
made revisions
based on public
comments.
Comment in support
of proposed or
existing text. No
action necessary.

369

4/23/2024

370

4/23/2024

371

4/23/2024

Paul
Anderson

Community
Outcomes

Application

Community
Accountabilit
y&
Involvement

372

4/23/2024

NMTC
Coalition Rapoza
Associates

Paul
Anderson

Community
Outcomes

Application

LILA/Healthy
Foods

River Gorge
Capital

Delete new bullet asking
about use of data or
suggest alternate wording
because it disadvantages
rural CDEs or CDEs that
serve rural areas.
Support changes from
"Food Desert" to "Low
Income Low Access."

The CDFI Fund
made revisions
based on public
comments.

The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund will
consider additional
guidance based on
this comment.
Comment in support
of proposed or
existing text. No
action necessary.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#
373

Date of
Comment
4/23/2024

374

4/23/2024

375

4/23/2024

376

4/23/2024

377

4/23/2024

378

4/23/2024

379

4/23/2024

Organization
NMTC
Coalition Rapoza
Associates
NMTC
Coalition Rapoza
Associates
NMTC
Coalition Rapoza
Associates
NMTC
Coalition Rapoza
Associates
NMTC
Coalition Rapoza
Associates
NMTC
Coalition Rapoza
Associates
NMTC
Coalition Rapoza
Associates

Author
Name
Paul
Anderson

Section

Category

Topic

Comment

NMTC Response

Community
Outcomes

Application

Medically
Underserved
Areas

Support adding Healthcare
Professional Shortage
Areas (HPSAs).

Paul
Anderson

Community
Outcomes

Application

Persistent
Poverty
Counties

Add "Persistent Poverty
Census Tracts" to
Question 25(b).

Paul
Anderson

Community
Outcomes

Application

Paul
Anderson

Community
Outcomes

Application

Revert changes to
Question 25(b). Suggest
moving question to
Innovative Activity.
Revisit definition; very
narrow and limiting

Paul
Anderson

Community
Outcomes

Application

Paul
Anderson

Community
Outcomes

Application

Commitment
to Areas of
Higher
Distress
Commitment
to Areas of
Higher
Distress
Commitment
to Areas of
Higher
Distress
Community
Goods and
Services

Paul
Anderson

Exhibits

Application

Comment in support
of proposed or
existing text. No
action necessary.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund will
consider additional
guidance based on
this comment.

Business Type

Consider capping the
percentage of commitment
that will impact scoring.
Remove third-party
metrics requirement for
community goods and
services.
Add "childcare" as
business type in Table A5.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

380

Date of
Comment
4/23/2024

381

4/23/2024

382

4/23/2024

383

4/23/2024

NMTC
Coalition Rapoza
Associates
NMTC
Coalition Rapoza
Associates
NMTC
Coalition Rapoza
Associates

NMTC
Coalition Rapoza
Associates

Author
Name
Paul
Anderson

Section

Category

Topic

Comment

NMTC Response

Combined
Rounds

NOAA

Combining
Rounds

Support combining CY
2024 & CY 2025 rounds.

Paul
Anderson

Managemen
t Capacity

Application

Fee Structure

Support requirement to
disclose fees.

Paul
Anderson

Glossary of
Terms

Application

Disadvantage
Business

Revisit definition of
"Disadvantage Business."

Paul
Anderson

General

Review
Process

Phase 1
Review
Instructions

Share instructions given to
Phase 1 reviewers.

This comment is not
related to burden in
completing the
NMTC Program
Application. The
CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
Comment in support
of proposed or
existing text. No
action necessary.
The CDFI Fund
made revisions
based on public
comments.
This comment is not
related to burden in
completing the
NMTC Program
Application. The
CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

384

Date of
Comment
4/23/2024

Author
Name
Paul
Anderson

Section

Category

Topic

Comment

NMTC Response

Managemen
t Capacity

Application

Board/Key
Personnel/Staf
fing

The CDFI Fund will
continue its efforts
to reduce burden in
future application
rounds.

NMTC
Coalition Rapoza
Associates

Paul
Anderson

General

Review
Process

Scoring
Process

Support the reduction in
character particularly for
prior allocatees. Only
required narrative from
prior allocatees' when
they've experienced an
issue.
Various ideas for
increasing scoring
variability.

385

4/23/2024

386

4/23/2024

NMTC
Coalition Rapoza
Associates
NMTC
Coalition Rapoza
Associates

Paul
Anderson

Capitalizati
on Strategy

Application

Investor
Letters

Clarify when a prior
allocatee is required to
provide investor letters.

387

4/23/2024

Paul
Anderson

NOAA

QEI Issuance
Requirements

Reduce QEI issuance
threshold requirement for
non-rural CDEs from 20%
to 0%.

388

4/3/2024

Native CDFI
Network,
NAFOA
Native
American
Finance
Officers
Association

Pete
Upton;
Susan
Maston

Glossary of
Terms

FAQ

Targeted
Population

Confirm that American
Indians, Alaska Natives,
and Native Hawaiians are
included in "targeted
population" definition.

NMTC
Coalition Rapoza
Associates

The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
Targeted
Populations are
defined in IRS
Regulations, not by
the CDFI Fund
Application
materials.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#
389

Date of
Comment
4/3/2024

390

4/3/2024

391

4/3/2024

392

4/3/2024

Organization
Native CDFI
Network,
NAFOA
Native
American
Finance
Officers
Association
Native CDFI
Network,
NAFOA
Native
American
Finance
Officers
Association
Native CDFI
Network,
NAFOA
Native
American
Finance
Officers
Association
Native CDFI
Network,
NAFOA
Native
American
Finance
Officers
Association

Author
Name
Pete
Upton;
Susan
Maston

Section

Category

Topic

Comment

NMTC Response

Customer
Service

Capacity
Building

Develop
training for
federal and
private
investors

Work with Native CDEs
and national Native
Organizations to design a
training explaining
complications of
developing and financing
projects on tribal lands.

The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.

Pete
Upton;
Susan
Maston

Customer
Service

Capacity
Building

Compatibility
of Other
Federal
Funding

Work with other federal
agencies to streamline
guidelines and approval
process using NMTC with
other federal funding and
loan guarantee programs.

The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.

Pete
Upton;
Susan
Maston

Community
Outcomes

Application

General

Add qualitative outcomes
to quantitative community
outcomes.

The CDFI Fund is
maintaining the
current
requirements.

Pete
Upton;
Susan
Maston

Business
Strategy

Application

Track Record
of
Investments

Consider other ways of
evaluating track record
aside from dollars.

The CDFI Fund is
maintaining the
current
requirements.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

393

Date of
Comment
4/3/2024

Author
Name
Pete
Upton;
Susan
Maston

Section

Category

Topic

Comment

NMTC Response

Customer
Service

Capacity
Building

Provide
Technical
Assistance

Provide technical
assistance grants for
Native CDEs.

Native CDFI
Network,
NAFOA
Native
American
Finance
Officers
Association
Travois New
Markets

Pete
Upton;
Susan
Maston

General

Regulations

Set-Aside

Create a set aside for
Native CDEs or give
substantial priority points
to Native CDEs.

394

4/3/2024

395

3/15/2024

Phil Glynn

Community
Outcomes

Application

Federal
Native Areas

Support wording change
to "Federal Native Areas."

396

3/15/2024

Travois New
Markets

Phil Glynn

Community
Outcomes

Application

Adopt holistic definition
of data in Question 27(b).

4/19/2024

Travois New
Markets

Phil Glynn

Community
Outcomes

Application

Community
Accountabilit
y&
Involvement
Federal
Native Areas

397

Native CDFI
Network,
NAFOA
Native
American
Finance
Officers
Association

Support wording change
to "Federal Native Areas."

Comment in support
of proposed or
existing text. No
action necessary.
The CDFI Fund will
consider additional
guidance based on
this comment.
Comment in support
of proposed or
existing text. No
action necessary.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

398

Date of
Comment
4/19/2024

Author
Name
Phil Glynn

Section

Category

Topic

Comment

NMTC Response

Community
Outcomes

Application

Community
Accountabilit
y&
Involvement

The CDFI Fund will
consider additional
guidance based on
this comment.

River City
Capital

Ron
Brooks

Community
Outcomes

Application

Total QEI
Needs

4/23/2024

River City
Capital

Ron
Brooks

Business
Strategy

Application

Due Diligence

401

4/23/2024

River City
Capital

Ron
Brooks

Business
Strategy

Application

Due Diligence

Include tribal data in
CDFI Fund's definition of
"data." Make it clear that
such data are sufficient
response in FAQ.
Describing detailed
investment strategy based
on community input
increase burden.
Due diligence
documentation requires
applicants to maintain
extensive records which
may exceed the assumed
preparation hours.
Provide checklist for due
diligence.

399

4/23/2024

400

402

4/23/2024

River City
Capital

Ron
Brooks

Community
Outcomes

Application

LIC
representative
s

Describing the
involvement of LIC
representatives takes time.

403

4/23/2024

River City
Capital

Ron
Brooks

Community
Outcomes

Application

Community
Accountabilit
y&
Involvement

404

4/23/2024

River City
Capital

Ron
Brooks

Business
Strategy

Application

Financial
Products

Maintain flexibility to
acknowledge differences
in local governance,
organization type, and
approaches to engage
feedback.
Articulate distinction
between descriptions for
multiple financial
products. Provide
examples.

Travois New
Markets

The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider additional
guidance based on
this comment.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

405

Date of
Comment
4/23/2024

Section

Category

Topic

Comment

NMTC Response

River City
Capital

Author
Name
Ron
Brooks

Business
Strategy

Application

Financial
Products

Support revision in
Questions 14(a) & 14(b)

4/23/2024

River City
Capital

Ron
Brooks

Business
Strategy

Application

Financial
Products

407

4/23/2024

River City
Capital

Ron
Brooks

Business
Strategy

Application

Financial
Products

Provide example or
template for Question
14(b). Simplify
requirements or provide
calculation tools.
Describing circumstances
of terms and rates increase
burden.

Comment in support
of proposed or
existing text. No
action necessary.
The CDFI Fund will
consider additional
guidance based on
this comment.

406

408

4/23/2024

River City
Capital

Ron
Brooks

Business
Strategy

Application

Invest in
Other CDEs

Revert changes to
instructions for Question
14(c).

409

4/23/2024

River City
Capital

Ron
Brooks

Business
Strategy

Application

Invest in
Other CDEs

Provide example or
template for Question
14(c).

410

4/23/2024

River City
Capital

Ron
Brooks

Community
Outcomes

Application

411

4/23/2024

River City
Capital

Ron
Brooks

Business
Strategy

Application

Align
Investment
with
Community
Input
Total QEI
Needs

Explain criteria used to
assess the quality and
alignment of community
input with investment
strategies.
Provide tool to calculate
and align QEI needs with
allocation request.

The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider changes in
future application
rounds.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

412

Date of
Comment
4/23/2024

Section

Category

Topic

Comment

NMTC Response

River City
Capital

Author
Name
Ron
Brooks

Business
Strategy

Application

Support changes to
Question 17(c).

Comment in support
of proposed or
existing text. No
action necessary.

4/23/2024

River City
Capital

Ron
Brooks

Community
Outcomes

IT
Enhancement

Provide mapping tool or
database for qualified
distressed areas.

414

4/23/2024

River City
Capital

Ron
Brooks

Community
Outcomes

Application

415

4/23/2024

River City
Capital

Ron
Brooks

Community
Outcomes

Application

416

4/23/2024

River City
Capital

Ron
Brooks

Community
Outcomes

Application

417

4/23/2024

River City
Capital

Ron
Brooks

Community
Outcomes

Application

418

4/23/2024

River City
Capital

Ron
Brooks

Managemen
t Capacity

Application

413

419

4/23/2024

River City
Capital

Ron
Brooks

Managemen
t Capacity

Application

management
experience

Add dropdown menu or
autofill option to
incorporate prior year
submissions.

The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund will
consider additional
guidance based on
this comment.

Provide guideline, scoring
rubric and scoring metric
for Question 25(b).
Commitment to invest in
specific distress areas
increase admin burden and
costs.
Make sure definition of
distress indicators are
clear.
Request for questions to
be reformatted or add a
table.
Ensure consideration is
not limited to experienced
CDEs.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

420

Date of
Comment
4/23/2024

Section

Category

Topic

Comment

NMTC Response

River City
Capital

Author
Name
Ron
Brooks

Managemen
t Capacity

Application

Organization
Capacity/Key
Personnel

Provide clarification on
expectations for key
personnel.

4/23/2024

River City
Capital

Ron
Brooks

Capitalizati
on Strategy

Application

Raising
Capital

422

4/23/2024

River City
Capital

Ron
Brooks

Capitalizati
on Strategy

Application

Raising
Capital

423

4/23/2024

River City
Capital

Ron
Brooks

Capitalizati
on Strategy

Application

Capitalization

Consider incorporating
CDE overarching goals
and impact into
strategy/track record of
raising capital.
Documenting track record
of capital raising, and
investment partnership is
challenging and could
increase cost.
Add or integrate digital
templates for these
questions.

The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
consider changes in
future application
rounds.

421

424

4/23/2024

River City
Capital

Ron
Brooks

Capitalizati
on Strategy

Application

Capitalization

425

4/23/2024

River City
Capital

Ron
Brooks

Capitalizati
on Strategy

Application

Raising
Capital

Provide instructions and
formats for Questions 3537. Share preferred format
for Commitment Letters
and Letters of Intent.
Do not focus exclusively
on ability or track record
of raising capital. Add
consideration for
CDFI/CDEs and Minority
CDEs that demonstrate
growth potential and
community impact.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

426

Date of
Comment
4/23/2024

Section

Category

Topic

Comment

NMTC Response

River City
Capital

Author
Name
Ron
Brooks

Business
Strategy

Application

Innovation in
Financial
Product

4/23/2024

River City
Capital

Ron
Brooks

Community
Outcomes

Application

Sustainability
and Viability
of
Investments

The CDFI Fund will
consider changes in
future application
rounds.
The CDFI Fund will
consider changes in
future application
rounds.

428

4/23/2024

River City
Capital

Ron
Brooks

Community
Outcomes

Application

429

4/23/2024

River City
Capital

Ron
Brooks

AMIS

IT
Enhancement

Anticipated
Social and
Economic
Impact
Online
Application
Portal

430

4/23/2024

River City
Capital

Ron
Brooks

Provide
Feedback

PRA

Provide space for CDEs to
discuss any innovative
features of their financial
products.
Add a question that
encourages CDEs to
discuss their strategies for
ensuring the sustainability
and long-term viability of
their investments
(reinvestments, additional
capital, lasting benefits).
Add a question focused on
anticipated social and
economic impact of the
proposed investments.
Suggest various format
updates, functionality
improvements to the
online application
interface for Applicants.
Provide incentives for
CDEs to actively provide
feedback to draft
application.

427

Review Draft
Application

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

431

Date of
Comment
4/23/2024

Section

Category

Topic

Comment

NMTC Response

River City
Capital

Author
Name
Ron
Brooks

Customer
Service

Capacity
Building

Provide
Technical
Assistance

Provide technical
assistance grants for
smaller CDEs.

4/23/2024

River City
Capital

Ron
Brooks

Provide
Feedback

PRA

Review Draft
Application

Add a process for CDEs to
receive feedback on draft
applications.

433

4/23/2024

River City
Capital

Ron
Brooks

Capitalizati
on Strategy

Application

Raising
Capital

Describing history and
strategies to raise capital
require additional
expertise/burden.

434

4/23/2024

River City
Capital

Ron
Brooks

Customer
Service

Capacity
Building

Conduct
Research

Conduct research to
review participation and
successes of Minority
CDEs and understand
barriers to entry and
success.

432

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

435

Date of
Comment
4/23/2024

Section

Category

Topic

Comment

NMTC Response

River City
Capital

Author
Name
Ron
Brooks

Community
Outcomes

Application

Impact of
investments
on LIPs/LICs

4/23/2024

River City
Capital

Ron
Brooks

Managemen
t Capacity

Application

management
experience

Substantiating impact for
LICs/LIPs requires
additional analyst, which
might increase burden.
Provide clarification on
compliance measures
expected from Applicants.

437

4/23/2024

River City
Capital

Ron
Brooks

General

Application

Streamline
Application

438

4/23/2024

River City
Capital

Ron
Brooks

Customer
Service

Capacity
Building

Provide
Technical
Assistance

439

4/23/2024

River City
Capital

Ron
Brooks

Customer
Service

Capacity
Building

Develop
Partnerships

The CDFI Fund is
maintaining the
current
requirements.
This comment is
related to Allocatee
reporting/complianc
e and will be
considered in the
future.
The CDFI Fund will
continue its efforts
to reduce burden in
future application
rounds.
This comment is not
related to burden in
completing the
NMTC Program
Application. The
CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.

436

Streamline application to
essential info will be more
cost efficient for smaller
or resource-constrained
CDEs.
Provide technical
assistance for revised
application sections.

Develop partnerships with
organizations to provide
capacity building
assistance for Minority
CDEs.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

440

Date of
Comment
4/23/2024

Section

Category

Topic

Comment

NMTC Response

River City
Capital

Author
Name
Ron
Brooks

Managemen
t Capacity

Application

Management
Experience

4/23/2024

River City
Capital

Ron
Brooks

General

Application
Instructions

Cost to Apply

442

4/23/2024

River City
Capital

Ron
Brooks

Estimated
Hours of
Burden

PRA

CDFI Fund
Burden
Estimate
(hours)

Revisions could increase
burden and cost,
especially for new CDEs
or those with recent
changes.
Provide guidance and
clarification so CDEs can
better estimate cost to
apply.
Consider that changes will
increase burden especially
for smaller CDEs.

443

4/23/2024

River City
Capital

Ron
Brooks

General

Regulations

Set-Aside

Create a set aside for
Minority CDEs.

444

4/23/2024

River City
Capital

Ron
Brooks

Post Award

Debriefing

Give more robust
feedback in debriefing.

The CDFI Fund will
continue its efforts
to reduce burden in
future application
rounds.
The CDFI Fund will
consider additional
guidance based on
this comment.
The CDFI Fund will
continue its efforts
to reduce burden in
future application
rounds.
The CDFI Fund
does not have
statutory authority
to implement this
recommendation.
The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.

441

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

445

Date of
Comment
4/23/2024

Section

Category

Topic

Comment

NMTC Response

River City
Capital

Author
Name
Ron
Brooks

Post Award

Debriefing

Give more robust
feedback in debriefing.

4/23/2024

River City
Capital

Ron
Brooks

Community
Outcomes

Review
Process

Bonus Points

Give bonus points for
CDFIs.

447

4/23/2024

River City
Capital

Ron
Brooks

General

Review
Process

Minority-led
CDEs

Revise review process to
evaluate experience and
performance of Minority
CDEs.

448

4/23/2024

AltCap

Ruben
Alonso

Post Award

Debriefing

Give detailed scoring in
debriefing.

449

4/23/2024

AltCap

Ruben
Alonso

Community
Outcomes

Review
Process

Bonus Points

Give bonus points for
CDFIs.

The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.
The CDFI Fund
does not have
statutory authority
to implement this
recommendation.
The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.
The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.
The CDFI Fund
does not have
statutory authority
to implement this
recommendation.

446

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

450

Date of
Comment
4/23/2024

Author
Name
Ruben
Alonso

Section

Category

Topic

Comment

NMTC Response

Post Award

Debriefing

Give detailed comments in
debriefing.

PIDC
Community
Capital

Sam
Rhoads

Community
Outcomes

Application

Federal/State/
Local Zones

Restore
"federal/state/local zones"
as an area of distress.

4/23/2024

PIDC
Community
Capital

Sam
Rhoads

Community
Outcomes

Application

Revert changes to
Question 25(b).

453

4/23/2024

PIDC
Community
Capital

Sam
Rhoads

Glossary of
Terms

Application

Commitment
to Areas of
Higher
Distress
Disadvantage
Business

The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund
made revisions
based on public
comments.

451

4/23/2024

452

454

4/23/2024

Advanced
CapAccess

Stephanie
Koenen

Community
Outcomes

Application

455

4/23/2024

Advanced
CapAccess

Stephanie
Koenen

Glossary of
Terms

Application

456

4/23/2024

Black Hawk
Economic
Development

Stephen
Brustkern

Glossary of
Terms

Application

AltCap

Commitment
to Areas of
Higher
Distress
Disadvantage
Business
Disadvantage
Business

Revert definition of
"Disadvantage Business”
or postpone changing
definition to after
1/1/2025.
Revert changes to
Question 25(b).
Revert definition of
"Disadvantage Business."
Revert change to
"Disadvantage Business."

The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund
made revisions
based on public
comments.
The CDFI Fund
made revisions
based on public
comments.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#
457

Date of
Comment
4/23/2024

Organization

458

4/23/2024

459

4/22/2024

460

4/22/2024

AMCREF
Community
Capital

Susan
Seagren

Community
Outcomes

Application

Disadvantage
Business

Add "Persistent Poverty
Counties" in Question
25(a) or 25(b).

461

4/22/2024

AMCREF
Community
Capital

Susan
Seagren

Community
Outcomes

Application

Commitment
to Areas of
Higher
Distress

462

4/22/2024

AMCREF
Community
Capital

Susan
Seagren

NOAA

QEI Issuance
Requirements

Revert changes to
Question 25(b). Suggest
moving question to
Innovative Activity or
Phase 2.
Reduce QEI issuance
threshold requirement for
non-rural CDEs from 20%
to 0%.

Native
American
Finance
Officers
Association NAFOA
Native
American
Finance
Officers
Association NAFOA
AMCREF
Community
Capital

Author
Name
Susan
Masten

Section

Category

Topic

Comment

NMTC Response

Community
Outcomes

Other

Federal
Native Areas

Support wording change
to "Federal Native Areas."

Comment in support
of proposed or
existing text. No
action necessary.

Susan
Masten

Community
Outcomes

Other

Community
Accountabilit
y&
Involvement

Qualify "data" with
respect to Tribal data
sovereignty

The CDFI Fund will
consider additional
guidance based on
this comment.

Susan
Seagren

Community
Outcomes

Application

Federal/State/
Local Zones

Restore
"federal/state/local zones"
as an area of distress.

The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund is
maintaining the
current
requirements.
The CDFI Fund
made revisions
based on public
comments.

The CDFI Fund will
continue to evaluate
the issues raised in
making future
policy decisions.

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#

Organization

463

Date of
Comment
4/23/2024

Section

Category

Topic

Comment

NMTC Response

Beneficial
State Bank

Author
Name
Terra
Neilson

Post Award

Debriefing

Give detailed comments in
debriefing.

4/23/2024

Beneficial
State Bank

Terra
Neilson

Post Award

Debriefing

Give detailed scoring in
debriefing.

465

4/23/2024

Beneficial
State Bank

Terra
Neilson

Community
Outcomes

Review
Process

Bonus Points

Give bonus points for
CDFIs.

466

5/2/2024

Native
American Bank

Thomas
Ogaard

Post Award

Debriefing

Give detailed scoring in
debriefing.

467

5/2/2024

Native
American Bank

Thomas
Ogaard

Community
Outcomes

Review
Process

Bonus Points

Give bonus points for
CDFIs.

The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.
The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.
The CDFI Fund
does not have
statutory authority
to implement this
recommendation.
The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.
The CDFI Fund
does not have
statutory authority
to implement this
recommendation.

464

Appendix A. CY 2024-26 NMTC Program Application PRA - Summary of Public Comments and CDFI Fund Responses
#
468

Date of
Comment
5/2/2024

Organization
Native
American Bank

Author
Name
Thomas
Ogaard

Section

Category

Topic

Comment

NMTC Response

Post Award

Debriefing

Give detailed comments in
debriefing.

The CDFI Fund will
consider ways to
provide more
detailed information
in the debriefing
document for
unsuccessful
applicants.

File Type	application/pdf
File Title	CY 2024-2026 NMTC Application PRA Appendix A Supporting Statement
Author	Leung, Karen
File Modified	2024-08-23
File Created	2024-08-23