FY 2026-2028 SDLP Application PRA Renewal - Supporting Statement

DEPARTMENT OF THE TREASURY
WASHINGTON, D.C. 20220

Supporting Statement
Small Dollar Loan Program (SDL Program) Application
1559-0051
A. Justification
1. Circumstances necessitating collection of information
The Department of the Treasury, through the Community Development Financial Institutions Fund
(CDFI Fund) administers the Small Dollar Loan Program (SDL Program). To be eligible for an SDL
Program Award, an Applicant must be a Certified CDFI.
The CDFI Fund collects data from prospective SDL Program Applicants once per funding round by
means of an online SDL Program Application. The CDFI Fund administers SDL Program funding
rounds every two years, subject to appropriations. As required by the Paperwork Reduction Act (PRA),
the CDFI Fund invited the public and other Federal agencies to comment on the proposed and/or
continuing information collection for the Fiscal Year (FY) 2026 through 2028 funding rounds. In
response to this request, the CDFI Fund received 13 comments. There were no changes to the SDL
Program Application based on the CDFI Fund’s review and adjudication of the comments.
The information collected will be used to select recipients, based on a merit-based selection process.
The requested information is required by the SDL Program Authorization (12 CFR § 1.4719) and
respective Notice of Funding Availability (NOFA).
2. Method of collection and use of data
The CDFI Fund will collect data once per funding round by means of the voluntary submission of an
online Application. Applicants must complete and upload all Application materials through the Awards
Management Information System (AMIS), a CDFI Fund-managed web-based application portal. The
CDFI Fund uses the data collected to determine award recipients and applicable award amounts. The
award selection process and award amount criteria are described in the respective NOFA.
3. Use of Information Technology
Only electronic applications are accepted. All Application materials must be submitted via the AMIS
platform.
4. Efforts to identify duplication
The SDL Program Application makes every effort to avoid requesting duplicate data by pulling data
from existing organizational profiles such as addresses, Employer Identification Numbers (EIN), and
CDFI certification information whenever possible.
5. Impact on small entities
This collection of information is not expected to have a significant impact on small entities.

6. Consequences of less frequent collection and obstacles to burden reduction
The CDFI Fund cannot meet its statutory requirement to make funding decisions based on data received
from Applicants without the SDL Program Application form. The SDL Program is authorized by Title
XII – Improving Access to Mainstream Financial Institutions Act of the Dodd-Frank Wall Street
Reform and Consumer Protection Act of 2010 (Pub. L. 111-203), which amended the Riegle
Community Development Banking and Financial Institutions Act of 1994 (Pub. L. 103-325) to include
the SDL Program (12 U.S.C. § 4719).
7. Circumstances requiring special information collection
There are no special circumstances. The collection of information is conducted in a manner consistent
with the regulations in 5 CFR 1320.6.
8. Solicitation of comments on information collection
Comments on the SDL Program Application were solicited in the Federal Register on December 6,
2024 (Vol. 89, No. 235). In response to this request, the CDFI Fund received 13 comments from 3
commenters. One comment was on data collection, while the other comments were related to SDL
Program’s Prohibited Practices, Loan Loss Reserve’s 20% award cap, maximum award thresholds,
track record and projections, and period of performance. Two comments were not related to the PRA
request.
9. Provision of payment to respondents
No payments or gifts will be made to respondents.
10. Assurance of confidentiality
The CDFI Fund is subject to all applicable federal laws and regulations with respect to confidentiality
of information supplied in the SDL Program Application process. No other assurances of
confidentiality have been provided.
11. Justification of sensitive questions.
No personally identifiable information is collected.
12. Estimate of the hour burden of information collection.
The estimated total number of burden hours for the SDL Program Application in the FY 2026 funding
round is 7,820. This is equivalent to $578,915 monetized burden hours per funding round, equivalent to
$289,457 annualized burden hours (the SDL Program is generally administered every two years). This
estimate is based on receiving 92 applications in the FY 2026 funding round, which is approximately
5% higher than the number of Applications received in FY 2024, the most recent round. This projected
increase is based on anticipated outreach activities and modest growth of Certified CDFIs eligible to
apply.
The CDFI Fund has made efforts to further minimize the collection burden following the 2022 SDL
Program Application PRA review of the Application by updating the SDL Program Application for the
FY 2026 – 2028 funding rounds, clarifying guidance and instructions, improving the Application
submission process, and by implementing technical updates. The CDFI Fund anticipates that these
changes will reduce the average hours per response from 89 hours in the FY 2024 funding round to 85
hours in FY 2026.
The estimated cost per hour to respondents is based on the Bureau of Labor Statistics data for Employer
Costs for Employee Compensation for private workers and for government workers by occupational
and industry group (released September 2024), the total compensation including wages and benefits for

management, professional and financial private industry and government workers at a total hourly
compensation of $74.031.

Affected
Public

#
Respondents

# Responses
Per
Respondent

Private
Sector

92

1

Total
Responses per
Funding
Round*

Average
Hours Per
Response

Total
Hours

92

85

7,820

Time
Value (per
hour)

$74.03

Monetized
Burden
Hours per
Funding
Round**
$578,915

* SDL Program funding rounds are administered every two years.
** Annual monetized burden hours $289,457(half the monetized burden of a funding round).

13. Estimate of total annual cost burden to respondents
It is not expected that this information collection will have a cost burden to respondents other than the
hour burden described in item number 12. The CDFI Fund notes that no purchase of equipment or
services is required to complete the Application.
14. Estimate of annualized cost to the Government
There is no direct Federal contractor service associated with the SDL Program Application. The cost to
the federal government can be estimated using the number of staff hours required to develop the
Application, review submitted applications and report the results. The estimated annualized cost to the
federal government is $54,540 ($109,080 per funding round, administered every two years). This
estimate is based on the projected federal employee labor costs of $72.72. The federal employee labor
costs reflect loaded rates by GS level and based on an estimated 1,500 labor hours.
15. Any program changes or adjustments
The SDL Program proposed relatively minor changes to the FY 2026 - 2028 SDL Program Application
relative to the approved FY 2022 SDL Program Application PRA.
Proposed revisions to the FY 2026 - 2028 SDL Program Application include: 1) elimination of certain
requests to the SDL Program Application that are no longer needed, minimizing the collection burden;
and 2) clarification of the methodology to be used in the all-inclusive Annual Percentage Rate (APR) to
align with the updated CDFI Certification Application requirements. Applicants will use the Military
Annual Percentage Rate (MAPR) methodology, ensuring consistency in how the APR is calculated and
reported in the Application and for Certification purposes. The CDFI Fund anticipates that these
changes will reduce the average hours per response from 89 hours in the FY 2024 funding round to 85
hours in FY 2026 - 2028.
16. Plans for information tabulation and publication
Confidential or proprietary information collected through the Application will not be published.
17. Reasons for not displaying expiration date of OMB approval
The CDFI Fund will display the expiration date of the OMB approval on the Application form.
18. Explanation of exceptions to certification statement
There are no exceptions to the certification statement.

The hourly rate is based on the Bureau of Labor Statistics “Table 4. Employer Costs for Employee Compensation for private workers
by occupational and industry group” (released September 2024), the total compensation including wages and benefits for management,
professional and financial private industry workers is $74.03. Link to the Bureau of Labor Statistics wage data report:
https://www.bls.gov/news.release/ecec.t04.htm
1

Appendix A. Comment and Response Summary
FY 2026-2028 SDLP Application PRA Renewal - Supporting Statement
60-Day Federal Register Notice Comment Adjudication
#

Date of
Comment

Organization

Author’s
Name

Topic

SDL Program Policy Issues and
Application Burden PRA Questions

1

12/30/2024

N/A Individual

Tiffany
Graven

Data
Collection

1. Should any data fields, questions,
or tables, be added, removed, or
clarified to ensure collection of
relevant information?

2

12/30/2024

N/A Individual

Tiffany
Graven

20% LLR
Award Cap

3

12/30/2024

N/A Individual

Tiffany
Graven

Max LLR
Award Size

4

12/30/2024

N/A Individual

Tiffany
Graven

Demonstrated
Need for LLR
Award

2. The Application states that LLR
Awards cannot exceed 20% of the
Applicant’s three-year projected total
of small dollar loans closed. Is the
20% cap appropriate for the purpose
of supporting a wide variety of small
dollar loan program designs? If not,
provide a rationale and state what
alternative cap would be more
appropriate.
3. Is the maximum LLR Award size of
$350,000 appropriate for the purpose
of supporting a wide variety of small
dollar loan program designs? If not,
what maximum award size would be
more appropriate and why?
4. The Application requests
information on how the Applicant will
use an LLR Award to establish a small
dollar loan program or expand an
existing one. Is the requested
information adequate to demonstrate
a need for an LLR Award? Why or why
not? What, if any, additional

Related
to SDL
Program
Policy
Issue?
No

Related to
SDL
Program
Application
Burden?
Yes

Author’s Comment / Recommendation

Yes

No

Consider a sliding scale cap or an alternative
metric (e.g., percentage of operating
expenses) to provide flexibility for diverse
program designs.

Yes

No

Consider a tiered approach with different
maximum award sizes based on factors like
applicant size, program scope, and target
population.

Yes

No

Request information on existing financial
resources, staffing, technology, previous
attempts to address the need, and challenges
encountered.

Add data fields for borrower demographics,
loan product features, borrower outcomes,
and financial counseling participation. Clarify
definitions, data entry instructions, and
provide examples for complex questions.

CDFI Fund SDL Program Response

All data fields noted in the comment are
already captured in the SDL Program
Application. The SDL Program
Application and the AMIS Technical
Guide provide clear instructions for data
entry and definitions, and the CDFI Fund
plans to develop an SDLP Glossary with
key terms and definitions for future
funding rounds.
This comment is not related to
Application burden and related to
programmatic structure. It will be
considered by the CDFI Fund in
developing the program’s Notice of
Funds Availability (NOFA).

This comment is not related to
Application burden and related to
programmatic structure. It will be
considered by the CDFI Fund in
developing the program’s Notice of
Funds Availability (NOFA).
All data elements noted in the comment
are already captured in the SDL
Program Application. No changes to the
proposed form are required.

#

Date of
Comment

Organization

Author’s
Name

Topic

5

12/30/2024

N/A Individual

Tiffany
Graven

Max TA
Award Size

6

12/30/2024

N/A Individual

Tiffany
Graven

Track Record
& Projections

7

12/30/2024

N/A Individual

Tiffany
Graven

Period of
Performance

8

12/30/2024

N/A Individual

Tiffany
Graven

Other
Information
Not Currently
Requested

SDL Program Policy Issues and
Application Burden PRA Questions

information should be collected to
assess the need and use of an LLR
Award request?
5. Is the maximum award size for
Technical Assistance Awards of
$150,000 appropriate to support
eligible Technical Assistance
activities? If not, what maximum
award size would be appropriate and
why?
6. Is the data collected in the track
record and projections tables
adequate and appropriate to assess
an Applicant’s experience in small
dollar lending and projections? Why
or why not?
7. The period of performance for
SDLP awards is three years. Is three
years sufficient to expend the award
to launch or expand a small dollar
loan program? If it’s not sufficient,
what period would be more
appropriate and why?
8. Is there other information not
requested (such as additional detail
on other unsecured consumer loans
below $10,000) in the Application
that would demonstrate an
Applicant’s experience in small dollar
lending and projected small dollar
lending activities? If yes, what is that
information?

Related
to SDL
Program
Policy
Issue?

Related to
SDL
Program
Application
Burden?

Author’s Comment / Recommendation

CDFI Fund SDL Program Response

Yes

No

Consider a tiered approach based on the
scope and complexity of the proposed
activities.

This comment is not related to
Application burden and related to
programmatic structure. It will be
considered by the CDFI Fund in
developing the program’s Notice of
Funds Availability (NOFA).

No

Yes

Include questions about managing risk,
addressing borrower defaults, and providing
financial counseling services.

All data elements noted in the comment
are already captured in the SDL
Program Application. No changes to the
proposed form are required.

Yes

No

Consider a flexible performance period with
the option for extensions.

This comment is not related to
Application burden and related to
programmatic structure. It will be
considered by the CDFI Fund in
developing the program’s Notice of
Funds Availability (NOFA).

No

Yes

Request data on other unsecured consumer
lending products and experience with serving
borrowers with poor credit histories.

All data elements noted in the comment
are already captured in the SDL
Program Application. No changes to the
proposed form are required.

#

Date of
Comment

Organization

Author’s
Name

Topic

SDL Program Policy Issues and
Application Burden PRA Questions

9

12/30/2024

N/A Individual

Tiffany
Graven

Assess
Program
Impact

10

2/4/2025

American
Financial
Services
Association

Celia
Winslow

Prohibited
Practices

9. The Application includes questions
about the intended impact of an
Applicant’s small dollar lending
strategy. (1) How should the CDFI
Fund assess the impact of SDL
Program Awards on communities
served by Applicants? (2) The CDFI
Fund has identified a set of impact
options for Applicants to choose in
the Application. Are the current
impact choices sufficient? Why or
why not? Are there impacts that
should be added or modified and if
yes, what are they?
10. The SDL Program Application
states that the Awards will not be
made to Applicants that engage in the
Prohibited Practices listed in Table 1.
Are the Prohibited Practices
appropriate to prevent predatory or
abusive lending practices that lowincome borrowers often face? Why
are why not? Are there any
Prohibited Practices that should be
added, eliminated, or clarified? What
are they?

Related
to SDL
Program
Policy
Issue?
Yes

Related to
SDL
Program
Application
Burden?
No

Yes

No

Author’s Comment / Recommendation

CDFI Fund SDL Program Response

Use a mix of quantitative and qualitative data
to assess borrower outcomes, communitylevel changes, and applicant performance.
Expand impact options to include specific
outcomes like credit score improvement,
reduced reliance on high-cost credit, and
increased access to mainstream financial
products.

All data elements noted in the comment
are already captured in the SDL
Program Application. No changes to the
proposed form are required.

We appreciate the CDFI and Treasury’s
mission to ensure that SDLP applicants
engage in fair lending practices. The criteria
for measuring whether an applicant is
engaging in responsible lending practices
should not be whether the applicant lends
above a 36% MAPR, but: whether it offers
transparent, fully amortized loans that are
repaid in substantially equal payments. The
removal of the prohibition against purported
high-rate loans would help continue to foster
diversity of types, activities and geography;
support the growth and reach of CDFIs;
protect the CDFI brand; minimize burden on
CDFIs; and promote efficiency. We encourage
the Treasury Department and CDFI Fund to
amend its application.

This comment is not related to
Application burden and related to
programmatic structure. It will be
considered by the CDFI Fund in
developing the program’s Notice of
Funds Availability (NOFA).

#

Date of
Comment

Organization

Author’s
Name

Topic

SDL Program Policy Issues and
Application Burden PRA Questions

11

12/30/2024

N/A Individual

Tiffany
Graven

Prohibited
Practices

12

12/7/2024

N/A Individual

Bryan
Richardso
n

Misc.

10. The SDL Program Application
states that the Awards will not be
made to Applicants that engage in the
Prohibited Practices listed in Table 1.
Are the Prohibited Practices
appropriate to prevent predatory or
abusive lending practices that lowincome borrowers often face? Why
are why not? Are there any
Prohibited Practices that should be
added, eliminated, or clarified? What
are they?
N/A

13

12/30/2024

N/A Individual

Tiffany
Graven

Misc.

N/A

Related
to SDL
Program
Policy
Issue?
Yes

Related to
SDL
Program
Application
Burden?
No

No

No

Author’s Comment / Recommendation

CDFI Fund SDL Program Response

Carefully review the list of Prohibited
Practices. Consider adding or clarifying
prohibitions on excessive fees, deceptive
marketing, coercion, harassment, and
discriminatory lending practices.

This comment is not related to
Application burden and related to
programmatic structure. It will be
considered by the CDFI Fund in
developing the program’s Notice of
Funds Availability (NOFA).

No

Am I eligible

No

Side note: links for laws, rights and
protections of applicants. Advocacy and
support when CDFIs deny applicant request
for loans as low income, minorities. I
personally applied for a CDFI loan for startup
affordable childcare. The reasons were
inconsistent and did not represent my
character. I was dismissed and could not find
any information or anyone to help me
navigate on what was required of CDFI when
denied. Credit background check was not
done. It is important that consumers know
the regulations and should be easily available
for reference. How would one navigate a
denial that was incorrect?

The comment is NOT related to
Application burden. The CDFI Fund does
not provide loans directly to individual
consumers.
The comment is NOT related to the
proposed Application burden.