CMF Program Application_Supporting Statement and Appendix A_FY 2025-FY 2027_Final Version

DEPARTMENT OF THE TREASURY
WASHINGTON, D.C. 20220

A. Justification

Supporting Statement
CDFI Fund Capital Magnet Fund (CMF) Application
OMB Control Number 1559-NEW

1. Circumstances necessitating collection of information
The Capital Magnet Fund (CMF) was established through the Housing and Economic
Recovery Act of 2008 (HERA), Pub. L. No. 110-289, section 1131, to carry out a
competitive grant program and is administered by the Community Development Financial
Institutions Fund (CDFI Fund). Through the CMF, the CDFI Fund provides financial
assistance grants for affordable housing and economic development to Certified Community
Development Financial Institutions (CDFIs) and to qualified Nonprofit Organizations having
the development or management of affordable housing as one of their principal purposes.
As required by the Paperwork Reduction Act (PRA) of 1995, 44 U.S.C. 3506(c)(2)(A), the
CDFI Fund solicited comments from the public and other Federal agencies concerning the
CMF program application (Application). In order to apply for funding through the CMF,
Applicants must submit an Application that will be evaluated in accordance with the
requirements stated in the applicable Notice of Funds Availability (NOFA). Recipients enter
into Assistance Agreements with the CDFI Fund that set forth certain terms and conditions of
the award.
In response to the request for public comment, the CDFI Fund received a total of 57
comments from six (6) organizations during the comment period. Modifications to the
Application reflect appropriate changes based upon the CDFI Fund’s review and adjudication
of the public comments. Most changes were made to provide additional clarity to intended
users. The Application information collected will be used to select Recipients based on a
merit-based selection process. The requested information is required by the CMF regulations
(12 C.F.R. part 1807) and respective NOFAs.
2. Method of collection and use of data
The CDFI Fund will collect Application data once per funding round by means of the
voluntary submission of an online Application. Applicants must complete and upload the
Application through a CDFI Fund-managed web-based application portal known as the
Awards Management Information System (AMIS). The CDFI Fund uses the data collected to
select eligible Applicants that are the most highly qualified to receive an award and to
determine the applicable award amounts.
3. Use of Information Technology
Only electronic submissions of the Application are accepted. The Application must be
submitted through AMIS.
Page 1 of 21

4. Efforts to identify duplication
The Application does not request information that is publicly available from other Federal
agencies, except for a limited amount of financial information from insured depository
institution or insured credit union applicants. This financial information is critical to the
evaluation of Applications, and a technical solution does not currently exist to import this
data in the correct format from other public sources. The CDFI Fund continually reviews the
status of reference datasets to identify opportunities to pre-fill additional data points.
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 Application form. Elements specified in HERA
and the CMF Interim Rule (12 C.F.R. part 1870, as amended) limit the extent to which the
burden can be reduced.
7. Circumstances requiring special information collection
There are no special circumstances requiring data collection to be inconsistent with
Guidelines in 5 C.F.R. 1320.5(d)(2).
8. Solicitation of comments on information collection
Comments on the Application were solicited in the Federal Register on September 24, 2024
(89 FR 77969). The CDFI Fund received 57 public comments in response to this request.
Comments on the Application were specifically requested on: (a) the need for the CDFI Fund
to collect the information; (b) the burden estimate; (c) ways to enhance the quality, utility and
clarity of the information; (d) ways to minimize the burden; (e) the cost of providing the
information; and (f) whether additional questions should be added.
Comments were solicited through Docket Number CDFI-2024-0003,
https://www.regulations.gov/docket/CDFI-2024-0003/comments.
Please see Appendix A for all of the specific comments and CMF staff responses.
Of the 57 comments, 28 were related specifically to the Application. The remaining 29
comments were primarily related to categories outside of the scope of the PRA: Application
review (2), compliance and reporting (9), the Interim Rule (2), and program administration
(16). All comments outside of the scope of the PRA approval will be considered by the CDFI
Fund, but are not relevant to this information collection.
9. Provision of payment to respondents
No payments or gifts will be made to respondents.

Page 2 of 21

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 Application process. No other assurances of
confidentiality have been provided.
11. Justification of sensitive questions.
No personally identifiable information (PII) is collected.
12. Estimate of the hour burden of information collection.
The estimated total number of burden hours for the fiscal year (FY) 2025-2027 CMF
Applications is 16,320 hours and the estimate of annualized cost to Applicants is a total of
$1,374,960. The hour burden estimate is based on the following: (i) the number of
Applications received during the FY 2024 funding round (136 Applications); (ii) the estimate
of annual burden hours per Applicant (120 hours); and (iii) the estimate of cost per hour to
respondents based on Bureau of Labor Statistics data for Employer Costs for Employee
Compensation for private workers by occupational and industry group, released September
2024 ($84.25 is the total hourly compensation including wages and benefits for management,
professional and financial private industry workers). 1
Instrument
Application

Affected
Public
Private
Sector

# of
Respondents

Total
Applications

Hours
per
Response

Total
Hours

Time
Value per
Hour

Monetized
Burden

136

136

120

16,320

$84.25

$1,374,960

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. No purchases of equipment or services
will need to be made by respondents for the sole purpose of completing the Application.

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 $84.25.
https://www.bls.gov/news.release/ecec.t04.htm

1

Page 3 of 21

14. Estimate of annualized cost to the Government
The cost to the government is the CDFI Fund staff and contractor time required to develop
the Application, review submitted Applications, collect follow-up information from
Applicants, and execute the Awards. The estimates of annualized cost to the Federal
government based on a methodology that estimated the time and loaded labor rate for the
CDFI Fund staff by general scale (GS) level and cost of contractor services. The estimated
total cost is $2,168,867.
Expense Category
IT Contract
External Review Contract
CDFI Fund Staff
Total

Cost
$715,715
$254,282
$1,198,870
$2,168,867

Specifically, the CDFI Fund estimated the hours by grade level for each step of the
Application life cycle including the Application material preparation, Application review,
Award announcement preparation, Assistance Agreement execution, and Award payment
processes. The staff wage rate was based on Step 5 of the respective GS level and then
multiplied by 1.63 to capture the value of non-wage compensation. The average fully loaded
cost per hour was based on a standard 2,000 full time equivalent (FTE) hours per year.
15. Any program changes or adjustments
Changes proposed to the FY 2025-2027 CMF Application reflect agency efforts and
suggestions from public comments to consolidate information requests, provide clarification
and consistency, and eliminate certain requests for information no longer needed. Many of
the proposed changes reflect updates needed to align the Application with the new CMF
Interim Rule (effective June 25, 2024).
In addition to those key changes, other changes proposed to the Application include the
following:
•

Replacing the previous Appendix 4 with a new table for “Secured Sources of
Leveraged Capital,” to reduce burden and focus data collection on the information
best suited to illustrate Applicants’ progress toward meeting leverage requirements.

•

In Appendix 7, using the “Compliance Evaluation Questions” currently used by other
CDFI Fund programs in the Application Analysis Tool – Compliance (AAT-C).

•

In Appendix 8, “Application Financial Data,” adding data fields in Table F for
affordable housing developers/managers, to allow for more comparable analysis with
Table E for Certified CDFIs.

It is anticipated that these changes will neither substantively increase nor decrease the total
burden hours per Application. The estimate of burden hours for FY 2025-2027 CMF
Applications of 16,320 hours is similar to, or less than, the previous total Application burden
hours for the FY 2021 CMF Application (16,440 hours).
Page 4 of 21

16. Plans for information tabulation and publication
Only aggregate information will be published. 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.
18. Explanation of exceptions to certification statement
There are no exceptions to the certification statement for this collection.
19. Collections of Information Employing Statistical Methods
There is no collection of information employing statistical methods.
Attachment: Appendix A

Page 5 of 21

APPENDIX A
#

Date of
Comment

Organization

1

11/25/2024

Community
Development
Bankers
Association
(CDBA)

2

11/25/2024

IFF

3

11/25/2024

4

11/25/2024

Community
Development
Bankers
Association
(CDBA)
Community
Development
Bankers
Association
(CDBA)

Author
Name/
Position
Brian Blake,
Chief Public
Policy Offer

Category

Section

Topic

Comment/
Recommendation

CMF Public Response

Application

Organization
and
Application
Information

Service Area

For Question 3.a, provide
more information on the
potential new option of a
“National Service Area.”

-The new Question Tip for 3.a
states: “Subject to the NOFA, a
national Service Area may
additionally be selected.”
-If a national Service Area is
included in a future NOFA, the
CDFI Fund will provide additional
guidance.

Kirby
Burkholder,
President
Core Business
Solutions

Application

Part 1:
Business
Strategy and
Leveraging
Strategy

Leverage and
Units

Commenter stated that they
"support focusing the CMF’s
leverage and unit level
requirements entirely at the
enterprise level... pushing
down these requirements to
the project level is not
reasonable."

Brian Blake,
Chief Public
Policy Offer

Application

Pipeline

For Questions 13.e and 13.f,
remove the new Question Tip,
or else increase the character
limit for those questions.

Brian Blake,
Chief Public
Policy Offer

Application

Part 1:
Business
Strategy and
Leveraging
Strategy
Part 2:
Community
Impact

-The current CMF practice
reflects the concern raised in this
comment. While certain CMF
requirements apply to the unit or
project level, the metrics of
leverage and unit counts in the
CMF Assistance Agreement are
assessed across the Recipient’s
CMF Portfolio for each Award.
- The CDFI Fund increased the
character limit for Questions 13.e
and 13.f, from 3,000 characters
to 5,000 characters.

Affordable
Housing Impacts
and Metrics

Reconsider the inclusion of
Questions 19.b.ii – 19.b.iv. If
kept, provide additional
guidance or increase the
character limit.

-The CDFI Fund revised the
Question Tips based on public
comments.
-The CDFI Fund reviewed the
questions and will not, at this
time, modify the character count
limit.

Page 6 of 21

#

Date of
Comment

Organization

5

11/25/2024

Community
Development
Bankers
Association
(CDBA)

6

11/25/2024

Poverty &
Race
Research
Action
Council

7

11/25/2024

8

11/25/2024

Author
Name/
Position
Brian Blake,
Chief Public
Policy Offer

Category

Section

Topic

Comment/
Recommendation

CMF Public Response

Application

Part 2:
Community
Impact

Economic
Development
Impacts and
Metrics

Reconsider the inclusion of
Questions 19.d.ii – 19.d.iv.

-The CDFI Fund revised the
Question Tips based on public
comments.
-The revisions to the subparts of
Question 19.d follows the CDFI
Fund’s goal for this PRA of
making the questions on
Economic Development Activities
parallel to Affordable Housing
Activities when possible.

Audrey Lynn
Martin,
Housing
Policy Counsel

Application

Part 2:
Community
Impact

Question 19

Commenter supports "the
additions of impact metrics
and narrative questions" to
Question 19.

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

Poverty &
Race
Research
Action
Council

Audrey Lynn
Martin,
Housing
Policy Counsel

Application

Part 2:
Community
Impact

Rental Housing
Income Targeting

Commenter supports the
addition of Question 21.c.

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

Community
Development
Bankers
Association
(CDBA)

Brian Blake,
Chief Public
Policy Offer

Application

Appendix 2:
Track Record
and
Projections

Table A1: Track
Record by
Housing/Economic
Development
Activity Type

Commenter states that in
"Appendix 2, Table A1," the
new table fields identifying
costs and units related to
“Projects Financed but not yet
Completed” will add burden.

-The CDFI Fund notes that
"Appendix 2, Table A1" collects
information on "Track Record by
Activity Type." Previously, costs
and units for "Completed
Projects" only were collected.
The addition of "Projects
Financed but not yet Completed"
is an additional data point to
provide. However, it allows
Applicants to show a fuller
picture regarding their track
record, rather than only
accounting for completed
projects.
Page 7 of 21

#

Date of
Comment

Organization

Author
Name/
Position
Brian Blake,
Chief Public
Policy Offer

Category

Comment/
Recommendation

Section

Topic

CMF Public Response

Application

Appendix 2:
Track Record
and
Projections

Table A1: Track
Record by
Housing/Economic
Development
Activity Type

Improve the layout of
“Appendix 2, Table A1,” by
splitting into multiple tables,
one for costs and one for units.

-The CDFI Fund will consider the
comment in making any table
design changes in the future.

9

11/25/2024

Community
Development
Bankers
Association
(CDBA)

10

11/25/2024

Community
Development
Bankers
Association
(CDBA)

Brian Blake,
Chief Public
Policy Offer

Application

Appendix 2:
Track Record
and
Projections

Tables B1 and B2:
Housing Units
Production by
Income Levels

Remove references to 50%
AMI.

-The CDFI Fund has taken this
comment into consideration and
will not, at this time, modify this
item in the Application including
adding or changing data fields,
questions, or tables as collection
of this data point is necessary to
administer the program.

11

11/25/2024

Community
Development
Bankers
Association
(CDBA)

Brian Blake,
Chief Public
Policy Offer

Application

Appendix 3:
Project
Pipeline and
Sources

Appendix 3b:
Sources

Instead of adding new,
separate fields for “State
Funding” and “Local Funding,”
combine these categories into
a single, new field for
“State/Local Funding.”

-The CDFI Fund revised the table
based on public comments.

12

11/25/2024

Capital
Magnet Fund
Coalition

Capital
Magnet Fund
Coalition

Application

Appendix 3:
Project
Pipeline and
Sources

Appendix 3b:
Sources

Commenter inquired about
the addition of collecting data
on state and local sources of
funding.

-The CDFI Fund notes that
Appendix 3b allows Applicants to
demonstrate the capital/leverage
they have secured related to
potential pipeline Projects and
how well the Applicant is
positioned to meet the CMF
leverage requirements. Adding
data entry for state/local funding
sources allows Applicants that
have secured such sources to
demonstrate this additional
leverage.
Page 8 of 21

#

Date of
Comment

Organization

13

11/25/2024

Capital
Magnet Fund
Coalition

14

11/25/2024

Poverty &
Race
Research
Action
Council

15

11/25/2024

16

17

Author
Name/
Position
Capital
Magnet Fund
Coalition

Category

Section

Topic

Comment/
Recommendation

CMF Public Response

Application

Appendix 4

Appendix 4:
Secured Sources
of Leveraged
Capital

Commenter asked about the
need to collect information on
secured sources of project
capital.

-The CDFI Fund uses this
information in its evaluation of
the feasibility of the Applicant’s
projections.

Audrey Lynn
Martin,
Housing
Policy Counsel

Application

Appendix 7:
Compliance
Evaluation
Questions

Compliance
Evaluation
Questions

Commenter supports the
compliance evaluation
questions (Appendix 7).

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

Community
Development
Bankers
Association
(CDBA)

Brian Blake,
Chief Public
Policy Offer

Application

Organization
and
Application
Information

Consultant
Contact
Information

Reconsider the addition of
Questions h.i – h.iii; or provide
additional information on
these fields.

- The CDFI Fund revised the
Question Tips based on public
comments.

11/25/2024

Capital
Magnet Fund
Coalition

Capital
Magnet Fund
Coalition

Application

Organization
and
Application
Information

Consultant
Contact
Information

Commenter requested
additional information on the
addition of Question 1h.

-The CDFI Fund revised the
Question Tips based on public
comments.

11/25/2024

Poverty &
Race
Research
Action
Council

Audrey Lynn
Martin,
Housing
Policy Counsel

Application

New
Question

Affordability
Period

Add questions to the
Application on the length of
affordability commitments and
report this data to the field.

-This comment would increase
burden, and the CDFI Fund does
not seek to evaluate this
information as part of the
Application process.
-The CDFI Fund has taken this
comment into consideration and
will not, at this time, add this
item to the Application.

Page 9 of 21

#

Date of
Comment

Organization

18

11/25/2024

Poverty &
Race
Research
Action
Council

19

11/25/2024

Poverty &
Race
Research
Action
Council

20

11/25/2024

21

11/25/2024

Author
Name/
Position
Audrey Lynn
Martin,
Housing
Policy Counsel

Category

Section

Topic

Application

New
Question

Permanent
Affordability

Audrey Lynn
Martin,
Housing
Policy Counsel

Application

New
Question

Tenant and
Community
Participation

Capital
Magnet Fund
Coalition

Capital
Magnet Fund
Coalition

Application

General

IFF

Kirby
Burkholder,
President
Core Business
Solutions

Application

General

Comment/
Recommendation

CMF Public Response

Add Application questions
regarding whether Projects are
creating permanently
affordable housing, through
mechanisms like “community
land trusts, cooperative
housing models, and other
non-market housing
structures.”
Add Application questions
regarding whether Projects are
seeking tenant and community
participation, through “tenant
advisory boards, funded
tenants’ associations,
community consultations, and
other governance structures
that allow residents to have a
meaningful voice in
development decisions.”

-This comment would increase
burden, and the CDFI Fund does
not seek to evaluate this
information as part of the
Application process.
-The CDFI Fund has taken this
comment into consideration and
will not, at this time, add this
item to the Application.
-This comment would increase
burden, and the CDFI Fund does
not seek to evaluate this
information as part of the
Application process.
-The CDFI Fund has taken this
comment into consideration and
will not, at this time, add this
item to the Application.

Burden

Eliminate or reduce
Application questions that are
unnecessary.

Burden

Commenter stated that the
Application process is fair and
reasonable for developers.

-This comment is being
addressed through the
Paperwork Reduction Act
process. Information being
collected is necessary to evaluate
Applications competitively.
-Given that the commenter does
not specify which questions are
being referenced, the CDFI Fund
is unable to make changes based
on the comment.
-Comment in support of
proposed or existing text. No
action necessary.

Page 10 of 21

#

Date of
Comment

Organization

22

11/25/2024

IFF

23

11/25/2024

IFF

24

11/25/2024

Community
Development
Bankers
Association
(CDBA)

Author
Name/
Position
Kirby
Burkholder,
President
Core Business
Solutions

Category

Section

Topic

Comment/
Recommendation

Application

General

Burden Hours

Commenter stated that an
estimated burden of 100 hours
is fair and reasonable for
developers.

Kirby
Burkholder,
President
Core Business
Solutions

Application

General

Burden Hours

Commenter stated that the
burden for financing entities is
significantly higher than 100
hours.

Brian Blake,
Chief Public
Policy Offer

Application

General

Burden Hours

Applicants report an average
of 298 hours to prepare a CMF
Application.

CMF Public Response
-The CDFI Fund reviewed
Applicant-reported data from the
past three rounds, which
supports an average estimated
burden of 120 hours across all
Applicant types.
-The CDFI Fund reviewed
Applicant-reported data from the
past three rounds, which
supports an average estimated
burden of 120 hours across all
Applicant types.
-The CDFI Fund reviewed
Applicant-reported data from the
past three rounds, which
supports an average estimated
burden of 120 hours across all
types of Applicants.
-The CDFI Fund notes that the
reported hours needed to
complete the CMF Application
varied widely. The maximum
reported value was 1,000 hours –
which equates to six months’
work of one Full Time Employee
(FTE). This suggests that some
Applicants may be including
other business processes, such as
preparing their audit or the hours
spent reporting on previous
Awards, in their totals for
preparing a new Application.

Page 11 of 21

#

Date of
Comment

Organization

25

11/25/2024

Community
Development
Bankers
Association
(CDBA)

26

11/25/2024

Community
Development
Bankers
Association
(CDBA)

27

11/25/2024

28

11/25/2024

Author
Name/
Position
Brian Blake,
Chief Public
Policy Offer

Category

Section

Topic

Comment/
Recommendation

Application

General

Data Entry

Use CMF data submitted in
prior years, such as
compliance reports, by having
it auto-populate in new CMF
Applications.

Brian Blake,
Chief Public
Policy Offer

Application

General

Data Entry

Use data submitted for other
CDFI Fund program
Applications submitted in the
same fiscal year, by having it
auto-populate in new CMF
Applications.

IFF

Kirby
Burkholder,
President
Core Business
Solutions

Application

General

Tables

Commenter stated that the
way the data was requested in
tables was often confusing.

Capital
Magnet Fund
Coalition

Capital
Magnet Fund
Coalition

Application

General

General

Commenter suggested that
dialogue outside of the PRA
process could have informed
the proposed Application
edits.

CMF Public Response
-The CDFI Fund notes this
recommendation is addressed
through the completion of
standard online forms in AMIS.
To reduce the reporting burden
and capture the impact of CMF,
the CMF Application includes the
outcomes and metrics of past
Awards. (See Question 27.d and
Appendix 6.)
-The CDFI Fund notes that all
organizational data is prepopulated from the AMIS
Organization Record. Information
on past Awards from other CDFI
Fund programs is also prepopulated.
-The CDFI Fund is exploring
opportunities to integrate data
across program Applications and
make improvements as
opportunities are identified.
-Given that the commenter does
not specify which tables are
being referenced, the CDFI Fund
is unable to make changes based
on the comment.
-The CDFI Fund notes that this
suggestion falls outside of the
established PRA process with
regards to how the CDFI Fund
collects feedback on proposed
Application changes.

Page 12 of 21

#

Date of
Comment

Organization

29

11/25/2024

Travois, Inc.

30

11/25/2024

Travois, Inc.

31

11/25/2024

32

11/25/2024

Author
Name/
Position
Erinn RoosBrown,
Project
Manager

Category

Section

Topic

Comment/
Recommendation

CMF Public Response

Application
Review

General

Size of Applicant

Commenter expressed their
opinion that CMF Application
scoring favors larger financial
or affordable housing
institutions, which puts smaller
Tribal Applicants at a
disadvantage.

-The CDFI Fund added
clarification to the Question Tips
based on public comments.

Erinn RoosBrown,
Project
Manager

Application
Review

General

General

Commenter expressed their
opinion that Tribally
Designated Housing Entities
(TDHE) can offer more flexible
financing than other CMF
recipients. Specifically, TDHE
can offer debt products that
do not need to be fully repaid.

-This comment is not related to
Application questions and
burden.

Poverty &
Race
Research
Action
Council

Audrey Lynn
Martin,
Housing
Policy Counsel

Compliance
and Reporting

New
Question

Impacts

-This comment is related to
reporting/compliance, not
Application questions and
burden.

Poverty &
Race
Research
Action
Council

Audrey Lynn
Martin,
Housing
Policy Counsel

Compliance
and Reporting

New
Question

Impacts

Add reporting outcome
metrics such as “tenant
demographics, rent levels,
maintenance practices, and
social supports provided to
residents.”
Commenter encourages
“meaningful reporting
requirements on affordability,
tenant outcomes, and
community benefits.”

-This comment is related to
reporting/compliance, not
Application questions and
burden.
-The CDFI Fund notes this
recommendation was addressed
through the recent Paperwork
Reduction Act process specific to
CMF compliance and reporting.

Page 13 of 21

#

Date of
Comment

Organization

33

11/25/2024

Community
Development
Bankers
Association
(CDBA)

34

11/15/2024

Grow South
Dakota

35

11/15/2024

Grow South
Dakota

Author
Name/
Position
Brian Blake,
Chief Public
Policy Offer

Category

Section

Topic

Comment/
Recommendation

Compliance
and Reporting

AMIS

Data Entry

The commenter states that
reporting via AMIS is
challenging, and that "one
CDFI Fund provided template
is incompatible with certain
reporting years and fails to pull
data correctly from source
material." It recommends that
the CDFI Fund review materials
and ensure that they are "fully
compatible with the reporting
software."

Lori J. Meon,
Chief
Operating
Officer

Compliance
and Reporting

AMIS

Data Entry

Alter annual reporting so that
Recipients can select specific
loans, from a list of all loans,
that did not have any changes
from the prior year.

Lori J. Meon,
Chief
Operating
Officer

Compliance
and Reporting

AMIS

Data Entry

Ensure that every input field
on Project records has help
text, including the autocalculation fields, to improve
clarity.

CMF Public Response
-This comment is related to
reporting/compliance, not
Application questions and
burden.
-The CDFI Fund updates and
publishes AMIS Manuals when
new reporting features are
implemented.
-The CDFI Fund encourages
Recipients to reach out, via an
AMIS Service Request, to provide
specifics on any materials they
find incompatible, to allow the
CDFI Fund to conduct
troubleshooting and find a
resolution.
- This comment is related to
reporting/compliance, not
Application questions and
burden.
-This comment is related to
reporting/compliance, not
Application questions and
burden.
-The CDFI Fund endeavors to
provide sufficient guidance on
how to complete reporting and
updates documents annually.
-The CDFI Fund encourages
Recipients to reach out, via an
AMIS Service Request, with
questions or recommendations
on what to input for any specific
data fields.

Page 14 of 21

#

Date of
Comment

Organization

36

11/15/2024

Grow South
Dakota

37

11/25/2024

Capital
Magnet Fund
Coalition

Author
Name/
Position
Lori J. Meon,
Chief
Operating
Officer

Capital
Magnet Fund
Coalition

Category

Section

Topic

Comment/
Recommendation

CMF Public Response

Compliance
and Reporting

AMIS

Data Entry

Create separate Project
records for Rental Affordable
Housing, Homeownership
Affordable Housing, and
Economic Development
Activities.

-This comment is related to
reporting/compliance, not
Application questions and
burden.
-The CDFI Fund notes that
separate types of Project records
for the different eligible activities
already exist in AMIS.

Compliance
and Reporting

AMIS

Testing

Ensure that changes to AMIS
are appropriately tested
before reporting from
Recipients is required,
including upload functionality.

-This comment is related to
reporting/compliance, not
Application questions and
burden.
-The CDFI Fund engages in
thorough end-to-end testing
prior to launching changes in
AMIS, but occasionally problems
may arise, given the wide variety
of Recipient types and Project
approaches.
-The CDFI Fund is committed to
promptly troubleshooting AMIS
problems as they arise and
encourages Recipients to submit
specific issues via an AMIS
Service Request.

Page 15 of 21

#

Date of
Comment

Organization

38

11/25/2024

Capital
Magnet Fund
Coalition

39

11/25/2024

IFF

40

11/25/2024

Capital
Magnet Fund
Coalition

Author
Name/
Position
Capital
Magnet Fund
Coalition

Category

Section

Topic

Comment/
Recommendation

Compliance
and Reporting

AMIS

Testing

Create a technical working
group that includes interested
CMF Recipients to beta test
AMIS improvements to
reporting.

Kirby
Burkholder,
President
Core Business
Solutions

Compliance
and Reporting

General

Reporting for
Multiple Years

Apply the same reporting
requirements to all Awards.

Capital
Magnet Fund
Coalition

Interim Rule

Compliance
and
Reporting

Presumptively
Compliant

Commenter supports "efforts
to institute a ‘Presumptively
Complaint’ metric for
assessing qualification of
projects that already qualify
and utilize funding and/or tax
credits through other federal
affordable housing programs.”

CMF Public Response
-This comment is related to
reporting/compliance, not
Application questions and
burden.
-The CDFI Fund notes that this
comment was provided during
the recent PRA process for the
CMF Compliance data collection.
The CDFI Fund responded as
follows: "The CDFI Fund
appreciates the recommendation
to create a technical working
group, however, we are not able
to accommodate this request at
this time."
-This comment is related to
reporting/compliance, not
Application questions and
burden.
-This request cannot be
accommodated since the specific
performance metrics have
changed over time in the
Assistance Agreements. The data
collected is necessary to evaluate
Recipient performance specific to
each Award year.
-This comment is related to
reporting/compliance, not
Application questions and
burden.
-Comment in support of
proposed or existing text. No
action necessary.

Page 16 of 21

#

Date of
Comment

Organization

Author
Name/
Position
Kirby
Burkholder,
President
Core Business
Solutions

Category

Section

Topic

Interim Rule

Rental
Affordable
Housing

Tenant Income
Certification

Comment/
Recommendation

41

11/25/2024

IFF

Commenter indicated its
support of the Revised Interim
Rule that will no longer require
the annual tenant income
recertification for projects
where 100 percent of units are
subject to CMF affordability
restrictions.
Communicate with applicants,
grant writers, industry
coalitions, and governmental
entities to ensure successful
program administration.

42

11/25/2024

Capital
Magnet Fund
Coalition

Capital
Magnet Fund
Coalition

Program
Administration

General

Communication

43

11/25/2024

Capital
Magnet Fund
Coalition

Capital
Magnet Fund
Coalition

Program
Administration

General

Data Publication

Make more Application,
performance, and transaction
level report data publicly
available.

44

11/25/2024

Travois, Inc.

Erinn RoosBrown,
Project
Manager

Program
Administration

General

Infrastructure

Commenter emphasized the
lack of subsidy to pay for
infrastructure costs, especially
in rural areas of Tribal
reservations, and noted how
this impacts the overall cost of
affordable housing.

CMF Public Response
-This comment is related to
reporting/compliance, not
Application questions and
burden.
-Comment in support of
proposed or existing text. No
action necessary.
-The CDFI Fund notes this
recommendation is being
addressed through the
Paperwork Reduction Act
process, as well as its annual
provision of reference materials
and live webinars regarding the
Application.
-This comment is related to
reporting/compliance, not
Application questions and
burden.
-Note that the CMF program
does not use the Transaction
Level Report (TLR) system that
some other CDFI Fund programs
use.
-This comment is related to
policy issues, not Application
questions and burden.
-The CDFI Fund appreciates the
need for infrastructure in the
development of affordable
housing and plans to review its
policies and provide additional
guidance as to appropriate and
reasonable use of CMF Award for
project-related infrastructure
costs.
Page 17 of 21

#

Date of
Comment

Organization

45

11/25/2024

IFF

46

11/25/2024

Poverty &
Race
Research
Action
Council

Author
Name/
Position
Kirby
Burkholder,
President
Core Business
Solutions

Audrey Lynn
Martin,
Housing
Policy Counsel

Category

Section

Topic

Comment/
Recommendation

Program
Administration

General

Partnerships and
Capital Stacks

Commenter requested that
CMF provide guidance on how
CMF funding is used as part of
a larger capital stack and how
awardees can participate with
other lenders on projects,
within the limits of program
regulations.

Program
Administration

General

Policy Priorities

Commenter expressed their
opinion that, “the CDFI Fund
should be cautious and
intentional when choosing
projects in historically
disinvested communities to
ensure that the project does
not perpetuate segregation,
gentrification, or the
concentration of poverty.”

CMF Public Response
-The CDFI Fund's publicly
available guidance posted on its
website includes information on
how Recipients should report on
Projects with multiple funding
sources. The CDFI Fund also
provides direct support to Award
Recipients to facilitate their CMF
reporting and compliance needs,
which can and does include
information on leverage and
partnerships.
-The CDFI Fund encourages
Recipients to reach out, via an
AMIS Service Request, with any
specific questions on
partnerships.
-This comment is policy related
and not related to burden of the
CMF Application. The CDFI Fund
notes that the CMF Program
does not select specific projects,
but rather provides funding to
organizations who have latitude
in project selection.

Page 18 of 21

#

Date of
Comment

Organization

47

11/25/2024

Poverty &
Race
Research
Action
Council

48

11/25/2024

Travois, Inc.

49

11/25/2024

50

11/15/2024

Author
Name/
Position
Audrey Lynn
Martin,
Housing
Policy Counsel

Category

Section

Topic

Comment/
Recommendation

CMF Public Response

Program
Administration

General

Policy Priorities

Commenter expressed their
opinion that CMF-funded
project locations should be
consistent with the
Affirmatively Furthering Fair
Housing portion of the Fair
Housing Act.

-This comment is policy related
and not related to burden of the
CMF Application. The CDFI Fund
notes that the CMF Program
does not select specific projects,
but rather provides funding to
organizations who have latitude
in project selection. The CDFI
Fund follows the Fair Housing Act
as applicable.

Erinn RoosBrown,
Project
Manager

Program
Administration

NOFA

Definition of Areas
of Economic
Distress (AED)

Recognize all Tribal
Reservations as qualifying
Areas of Economic Distress,
rather than strictly utilizing
Census tract data.

Poverty &
Race
Research
Action
Council

Audrey Lynn
Martin,
Housing
Policy Counsel

Program
Administration

NOFA

Eligibility

-Prioritize non-profit housing
organizations and non-profit
CDFIs over for-profit CDFIs.

-This comment is related to
policies in the NOFA, not
Application questions and
burden.
-The CDFI Fund will continue to
evaluate the issues raised in the
comment in making future policy
decisions.
-This comment is not Application
questions and burden.
-The CDFI Fund does not have a
statutory basis for prioritizing
non-profit housing organization
and CDFIs over for-profit CDFIs.

Grow South
Dakota

Lori J. Meon,
Chief
Operating
Officer

Program
Administration

NOFA

Length of
Affordability
Period

Change the Affordability
Period for Homeownership
Affordable Housing from 10
years to 5 years.

-This comment is related to
policy considerations, not
Application questions and
burden.
-The CDFI Fund will continue to
evaluate the issues raised in the
comment in making future policy
decisions.

Page 19 of 21

#

Date of
Comment

Organization

51

11/25/2024

Poverty &
Race
Research
Action
Council

52

11/15/2024

Grow South
Dakota

53

11/25/2024

54

11/25/2024

Author
Name/
Position
Audrey Lynn
Martin,
Housing
Policy Counsel

Category

Section

Topic

Comment/
Recommendation

CMF Public Response

Program
Administration

NOFA

Length of
Affordability
Period

Implement a 30-year
affordability period or longer.

-This comment is related to
policy considerations, not
Application questions and
burden.
-The CDFI Fund will continue to
evaluate the issues raised in the
comment in making future policy
decisions.

Lori J. Meon,
Chief
Operating
Officer

Program
Administration

NOFA

Percentage of
Award for Direct
Admin. Expenses

Allow a higher percentage of
the Award amount for
administration to support
annual compliance and
reporting requirements
through AMIS.

Poverty &
Race
Research
Action
Council

Audrey Lynn
Martin,
Housing
Policy Counsel

Program
Administration

NOFA

Policy Priorities

-Prioritize projects serving
households at or below 30%
AMI.

Poverty &
Race
Research
Action
Council

Audrey Lynn
Martin,
Housing
Policy Counsel

Program
Administration

NOFA

Policy Priorities

-Target projects with
permanently affordable
housing.

-This comment is related to
policies in the NOFA, not
Application questions and
burden.
-Currently, Direct Administrative
Expenses are capped at 5% of the
total Award amount.
-The CDFI Fund will continue to
evaluate the issues raised in the
comment in making future policy
decisions.
-This comment is related to
policies in the NOFA, not
Application questions and
burden.
-The CDFI Fund will continue to
evaluate the issues raised in the
comment in making future policy
decisions.
-This comment is related to
policies in the NOFA, not
Application questions and
burden.
-The CDFI Fund will continue to
evaluate the issues raised in the
comment in making future policy
decisions.
Page 20 of 21

#

Date of
Comment

Organization

55

11/15/2024

Grow South
Dakota

56

11/25/2024

Capital
Magnet Fund
Coalition

57

11/25/2024

Travois, Inc.

Author
Name/
Position
Lori J. Meon,
Chief
Operating
Officer

Category

Section

Topic

Comment/
Recommendation

Program
Administration

NOFA

Rural Applicants

Create a separate Application
pool for Applicants operating
predominately in Rural Areas.

Capital
Magnet Fund
Coalition

Program
Administration

NOFA

Set-aside for
Smaller Applicants

Create a separate application
category for smaller
applicants, reserving at least
10 percent of the year's funds.
Reduce reporting burden for
smaller Applicants as well.

Erinn RoosBrown,
Project
Manager

Program
Administration

NOFA

Tribal Set-Aside

Set aside a portion of CMF
funding specifically for Tribal
affordable housing entities.

CMF Public Response
-This comment is related to
policies in the NOFA, not
Application questions and
burden.
-As established through the
Housing and Economic Recovery
Act of 2008 (HERA), Public Law
110–289, section 1131, HERA
does not include the authority to
create programmatic set-asides
for CMF.
-This comment is related to
policies in the NOFA, not
Application questions and
burden.
-HERA does not include the
authority to create programmatic
set-asides for CMF.
-This comment is related to
policies in the NOFA, not
Application questions and
burden.
-HERA does not include the
authority to create programmatic
set-asides for CMF.

Page 21 of 21