CDFI Fund Policy Change for Credit Union Certification
At Inclusiv’s 2013 Annual Conference in Baltimore, CDFI Fund Director Donna Gambrell announced a major policy change that had long been a central point for Inclusiv advocacy. One of the seven tests for CDFI certification is accountability to specific target markets. Unlike other types of CDFIs, credit unions are cooperatives, directly governed by and accountable to their members. As of 2013, the CDFI Fund will recognize that credit unions that predominantly serve a CDFI Target Market are automatically accountable to that market.
NCUA Final Rule on Short-Term Small Amount (STS) Loans: On behalf of our members, Inclusiv advocated for clear guidelines to help credit unions offer responsible alternatives to short-term payday and emergency loans from high-cost and predatory lenders. While far from perfect, the NCUA guidelines represent a major step forward in helping credit unions to offer a better deal to consumers.
Housing Counseling Funding Restored: As part of tense budget negotiations In 2011, Congress eliminated funding for the HUD Comprehensive Housing Counseling program, which each year provides vital pre-purchase, post-purchase and foreclosure intervention counseling services to millions of families across the country. As a HUD-approved National Housing Counseling Intermediary, Inclusiv joined with our partners to advocate successfully for a restoration of this important program in 2012.
NCUA Doubles the Number of Low-Income Credit Unions: Inclusiv had long advocated with NCUA to conduct a more regular and systematic analysis of credit union eligibility for Low-Income Designation (LID). In 2012, NCUA’s Office of Small Credit Union Initiatives carried out that analysis for all federally chartered credit unions. The analysis identified one thousand credit unions eligible for the designation, doubling the number of LID credit unions to more than 2,000.
NCUA Accepts Statistical Surveys for Low-Income Determinations: NCUA typically determines low-income eligibility by analyzing the residential addresses of all credit union members. If a member lives in an area that has been classified by the US Census Bureau as low-income, then that member is assumed to be low-income. This approach is an efficient and effective way to identify the vast majority of credit unions that are eligible for Low-Income Designation (LID), but it leaves out credit unions that forcus on the poorest communities in higher income areas. In response to Inclusiv advocacy, in 2011 NCUA published a revised rule on Low-Income Designation that allowed credit unions to use actual member income data drawn from a statistically valid random sample to demonstrate LID eligibility.
NCUA Supervisory Letter on Examination of CDCUs: In 2004 Inclusiv launched a series of round-table discussions with NCUA and CDCUs to discuss distinctive operating characteristics of CDCUs and NCUA guidelines and training for field examiners. These discussions led first to a 2005 NCUA White Paper (discussed below) and the stronger 2010 “Supervisory Letter on Examination of Low-Income and Community Development Credit Unions.”
NCUA Removes Regulatory Barriers for CDCI Program: Immediately after the release of the CDCI program details February 2010, Inclusiv identified a number of regulatory barriers that would prevent credit unions from applying for secondary capital under the program. In response to detailed analysis and recommendations provided by Inclusiv, NCUA officially removed the regulatory barriers within 30 days, which enabled 48 credit unions to obtain $69.9 million in secondary capital by October 1, 2010.
Treasury Announces Community Development Capital Initiative (CDCI): From the time Congress announced a massive program to support banks through the financial crisis in 2008, Inclusiv advocated for a measure of help for credit unions that remained active lenders in communities hardest hit by the recession. In February 2012 the Treasury Department announced the Community Development Capital Initiative (CDCI) that offered long-term, low interest secondary capital loans to credit unions that were both low-income designated by NCUA and certified Community Development Financial Institutions (CDFIs) by the Treasury Department CDFI Fund. By October 1, 2010, CDCI had disbursed $69.9 million in secondary capital to eligible credit unions.
CDFI Bond Guarantee Program signed into law
New York State CDFI Fund signed into law
White Paper on Examination of Community Development Credit Unions issued by NCUA
Credit unions accepted by Small Business Administration as SBA 7(a) lenders
Secondary Capital for Credit Unions recognized by Congress as regulatory net worth (H.R. 1151)
Low Income Credit Unions exempted from portfolio cap on Member Business Lending (H.R. 1151)
Empire State Development Corporation’s CDFI Financial Assistance Program launched
Secondary Capital for Credit Unions invented and deployed by Inclusiv
New York State CDFI Coalition established
Community Development Financial Institutions (CDFI) Fund established by 1994 Riegle Community Development and Regulatory Improvement Act
CDFI Coalition (formerly Public Purpose Lenders Group) formed
New York State Corporation for Community Banking introduced in NYS Assembly (A-8145)
NCUA Community Development Revolving Loan Fund created