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Reminder: Annual Compliance, Certification and Reporting Obligations

Lydia Wedlock

Are you the Authorized Representative of either a Certified Community Development Financial Institution (CDFI) or an organization that has received a Community Development Financial Institutions Fund (CDFI Fund) Award and/or Allocation? If so, to maintain your organization’s CDFI Certification status all Certified CDFIs still must submit an Annual Certification and Data Collection Report (ACR). Additionally, to ensure compliance with your Award, Assistance and/or Allocation Agreement(s), you must complete and submit the annual report(s) specified in these agreement(s).  

The due dates to submit annual compliance report(s) vary by fiscal year end date and type of award, as well as by the specific terms within each organization's individual Award, Assistance and/or Allocation Agreement(s). The due date for Certified CDFIs to submit the ACR also varies by fiscal year end date. This reminder is specifically for organizations with Award, Assistance and/or Allocation Agreements, as well as ACRs, which have an upcoming report(s) due by June 30, 2024.

The CDFI Fund will resume accepting Certification Applications in the Awards Management Information System (AMIS) on September 16, 2024, only for currently CDFIs who notified the CDFI Fund in February 2024 of their intent to submit an early Certification Application. All other currently Certified CDFIs will gain access to the Certification Application in AMIS based on the updated general reapplication submission schedule.

How to Check Your Report Date

CDFI Fund Recipients and/or Allocatees: The due date(s) for your organization’s required report(s) can be found in the Award, Assistance or Allocation Agreement(s) and on the Reporting Schedule in AMIS.All Certified CDFIs: The due date(s) for your organization’s ACR can be found in the ACR Reporting Schedule in AMIS.

Submission of the CDFI/NACA/RRP Transaction Level Report and CDFI Certification Application

The CDFI Fund is reminding all financial assistance award recipients with a TLR reporting requirement that the full-length TLR submitted as a requirement of their assistance agreement is the same TLR that will be used to assess Target Market activity under the revised CDFI Certification Application. Therefore, the full-length TLR’s “Designated Target Market Type” data field should be completed using any Target Market types for which the award recipient is currently approved to use as well as any that will be in the revised CDFI Certification Application.

With publication of the updated general reapplication submission schedule, the CDFI Award Recipients’ TLR submission requirements will now coincide with CDFI Certification Application submission deadlines in calendar year 2025, reducing the likelihood that Award Recipients will need to amend existing TLR submissions in order to complete their CDFI Certification Application.

If an award recipient certified and submitted their full-length TLR using a different understanding for how to tag transactions for the “Designated Target Market Type” data field and this same TLR is the TLR being used to measure Target Market activity for their unsubmitted CDFI Certification Application, then they should submit an AMIS Service Request asking for their TLR submission to be reopened so they can correct the values entered for the Designated Target Market Type” data field.

Currently Certified CDFIs should submit only one TLR to the CDFI Fund. The CDFI Fund will use that TLR for Certification and compliance (if applicable) purposes for the relevant fiscal year. No CDFI should submit both a certified abbreviated TLR and a certified full-length TLR to the CDFI Fund for the same fiscal year’s activities.

Annual Certification and Data Collection Report Deadline Reminder

Unless directed otherwise by the CDFI Fund, all Certified CDFIs are required to submit ACRs on an annual basis. Currently Certified CDFIs are still required to submit an ACR in accordance with the prior CDFI Certification standards and the ACR reporting schedule as listed in their AMIS profile to maintain their Certification status. Certified CDFIs must submit their ACRs, in AMIS, within 90 days after their organization’s fiscal year end date using the current version of the ACR. 

For the 2024 reporting cycle, all Certified CDFIs, regardless of their date of Certification, will be required to submit an ACR. Currently Certified CDFIs will NOT lose their Certification or be placed into a cure period as long as they submit accurate analysis or responses to the 2024 ACR. However, an organization may have its Certification terminated if they fail to submit their 2024 ACR by the required deadline.

The AMIS ACR Reporting Schedule displays the due date for the ACR based on the organization’s fiscal year end. The ACR Reporting Schedule section is located at the bottom of the Certification Related page in AMIS. Additional information on the AMIS Reporting Schedule can be found in the AMIS Training Manual – Annual Certification and Data Collection Report available on the CDFI Fund’s website. Be sure to check that your organization’s fiscal year end is correct on your AMIS Organizational Detail Page.

Advise the CDFI Fund of Material Events

As specified in the terms of your organization’s Award, Assistance and/or Allocation Agreement(s), please remember that your organization is required to advise the CDFI Fund of an occurrence of a Material Event, which should be submitted via a Service Request initiated in your organization’s AMIS account. Please refer to the link titled “Material Events” under the “For More Information” section below to access updated guidance documents for submitting the Certification of Material Events Form. 

CDFI Fund Recipients with active awards/allocations are required to submit a Material Events form (including all supporting documentation) within 30 days or as specified in their Award, Assistance and/or Allocation Agreements, of the occurrence of a Material Event.

The CDFI Fund is reminding all Certified CDFIs, Certified CDEs, as well as program Recipients and/or Allocatees to review their recent organizational history to determine if a Material Events form should be submitted. Certified CDFIs that do not have an Award, Assistance and/or Allocation Agreement should report changes in their organization’s fiscal year end through the AMIS Service Request portal.

Submission of Audit Confirmation Requests

The CDFI Fund will respond to all audit requests by email, only. As such, requests must include an email address and instructions of where the CDFI Fund should deliver the requested information. Questions regarding the process for submitting audit confirmation requests can also be submitted via email at FMAuditConfirmations@cdfi.treas.gov.

Updates for CDFI Program Healthy Food Financing Initiative-Financial Assistance Award Recipients

All CDFI Program Healthy Food Financing Initiative-Financial Assistance (HFFI-FA) Recipients are now required to enter aggregate HFFI data in their Performance Progress Report (PPR), just as they enter aggregate data for the other deployment performance goals. Keep in mind, HFFI-FA Recipients must continue to enter individual HFFI data in the CDFI Transaction Level Report (TLR).

For More Information

The CDFI Fund has developed training materials to help users better navigate AMIS. All AMIS training manuals and information can be found on the AMIS Training Materials page at https://amis.cdfifund.gov/Training. Information and instructions on submitting annual compliance and certification reports, as well as Material Events forms can be found on the CDFI Fund’s website at the following links:

If you have questions about the annual compliance and certification reports, or Material Events please submit a Service Request via your organization’s AMIS account. For more information about the CDFI Fund and its programs, please visit www.cdfifund.gov.

Organizations are encouraged to review the revised Certification Application, ACR and TLR information on the CDFI Fund’s website to understand the scope of changes and new process requirements, for future reference.