CDFI Fund Extends Effective Date for CDFI Certification Small Business Loan Disclosure Policy

CDFI Fund Extends Effective Date for CDFI Certification Small Business Loan Disclosure Policy

The U.S. Department of the Treasury's Community Development Financial Institutions Fund (CDFI Fund) has extended the effective date for when CDFI Certification Applicants and currently Certified Community Development Financial Institutions (CDFIs) must begin implementing small business loan product disclosures to borrowers.

In December 2023, the CDFI Fund released the final revised CDFI Certification Application. As part of the new policy changes with the revised CDFI Certification Application, the CDFI Fund implemented the following small business disclosure policy:

"Beginning January 1, 2026, new Applicants that offer small business loan products that do not disclose, in writing, the periodic payment due, the total amount to be repaid over the life of the loan, the total finance charges over the life of the loan, or the APR of the loan will be ineligible for CDFI Certification. Certified CDFIs that offer small business loan products will be required to attest in their ACR to making such disclosures no later than October 1, 2026, in order to maintain their certification."

Effective with today's announcement, the dates have been changed to as follows:

"Beginning October 1, 2028, any organization seeking CDFI Certification that offers small business loan products that do not disclose to the borrower, in writing, the periodic payment due, the total amount to be repaid over the life of the loan, the total finance charges over the life of the loan, or the APR of the loan will be ineligible for CDFI Certification. Beginning on October 1, 2028, currently Certified CDFIs that offer small business loan products will be required to attest in their ACR submission to making such disclosures in order to maintain their CDFI Certification."

This policy pertains to question PM17 (PM17.1 through PM17.4) in the revised CDFI Certification Application and questions RFP17.1 through RFP17.4 in revised Annual Certification and Data Collection Report that asks the following:

"For each of the Applicant's small business loan products, does the Applicant disclose in writing:

The periodic payment due?

The total amount to be repaid over the life of the loan?

The total finance charges over the life of the loan?

The annual percentage rate of the loan?"

The CDFI Fund is still in the process of updating all relevant guidance materials to reflect this effective date change. All updated CDFI Certification Application guidance materials will be posted to the CDFI Fund's website at https://www.cdfifund.gov/cdficert under 'Step 2: Application Process'.

Questions

Questions about the CDFI Certification Application should be directed to the Office of Certification Policy and Evaluation (OCPE) via AMIS Service Request (preferred), or by email at [email protected].