Inclusiv Advocates for Change to the ACR Reporting Deadline
The CDFI Fund's change to a 90-day ACR deadline undercuts the efficiency and reliability of CDFI reporting
CDFI Fund services, including access to the CDFI Fund helpdesk and to the Funds Award Management Information Systems, better known as AMIS, are unavailable during the Federal government shutdown.
Fund Revises Reporting Requirements
Shortly before the shutdown, the CDFI Fund had announced revisions to the due dates for CDFIs to submit their required Annual Certification and Data Collection Reports or ACRs. Per the Fund, CDFIs are now required to submit their ACR within 90 days of the end of their organization's fiscal year. The announcement further noted that the Fund was in the process of revising the ACR submission form in AMIS and that the revised form would be available for use on January 31, 2019.
Inclusiv Advocates for Changes to New Requirements
No one knows when the government shutdown will end, but we wanted to make you aware that Inclusiv, the credit union industry's advocate to the Fund, is working on your behalf to restore a due date of 180 days following the close of your fiscal year. Our analysis shows that a 90-day deadline will increase costs to CDFI credit unions and will degrade the consistency and verifiability of the financial data in annual reports.
CDFI credit unions benefit from a standard and predictable reporting schedule that allows ample time for NCUA to release quarterly call report data.
In recent years, the variability of due dates as late as December and as early as March have created confusion in the field and conflicted with the 180-day deadline for activity reports for CDFI awardees.
As the CDFI Fund is considering new ACR data requirements for 2020, it would be beneficial for CDFIs to have a single, fixed date for all activity reporting to the CDFI Fund, including both annual recertification and grant reports.
A 90-day ACR deadline replaces an efficient, reliable and cost-free annual reporting with a costly and inconsistent requirement.
Currently, the financial data needed for the ACR is based on a standard crosswalk from account codes in NCUA year-end 5300 call reports. The data is most easily accessed when NCUA releases the bulk data in CSV files, which typically occurs sometime in early March. While the call report data originates with credit unions, the systems used to translate individual credit union account data into standard NCUA account codes vary widely -- larger credit unions use a myriad of automated reporting packages, while many smaller institutions rely on third-party vendors or compile the data manually. Without access to the bulk data released by NCUA, each credit union would have to add another step to their quarterly reporting process, to create a crosswalk from their individual account structure to the CDFI financial accounts. The 90-day deadline forces credit unions to change from a single, efficient reporting system to hundreds of individually customized approaches. The variety of reporting crosswalks and processes will increase the probability of error and decrease the CDFI Fund's ability to cross-check credit union data with NCUA call reports.
Inclusiv works to improve the efficiency and reliability of credit union reporting based on better use of regulatory data.
Inclusiv is the leading advocate for CDFI and community development credit unions serving low- and moderate-income communities. Inclusiv was instrumental in establishing the CDFI Fund in 1994 and we are a permanent member of the national CDFI Coalition. The CDFI Fund is a unique source of capital for community development credit unions. CDFI grants can fuel growth in credit union membership, deposits and loans.
If you have any questions about the CDFI Fund or about becoming a CDFI credit union, please contact Pablo DeFilippi, Inclusiv's SVP of Membership and Network Engagement at firstname.lastname@example.org.