The Partners for Rural Transformation (PRT) appreciates the CDFI Fund’s stated goal to “increase transparency and reduce burden” through a revised CDFI Certification Application that in part will feature “a list of pre-approved Target Market assessment methodologies [TMAMs] that Applicants and Certified CDFIs may use and rely upon to demonstrate that they are serving their identified Target Market(s).”1 Below, PRT provides some introductory context to the importance of Native CDFIs, followed by our answers to certain questions of particular concern to our Native CDFI and other Native CDFIs that have been posed by the CDFI Fund.
Native CDFI’s play a vital role in including Native Communities into the nation’s economic mainstream. Native CDFIs have proven themselves vital engines for fueling the growth of healthy, vibrant Native economies and communities. Despite the extraordinary economic progress certified and emerging Native CDFIs are cultivating across Indian Country, significant unmet needs for capital, credit, training, technical assistance, and financial capability building across Native communities persists.
- Native people are the only ethnic/cultural group that the CDFI Fund would require to show verifiable proof of their affiliation with one of the three OTPs listed above. All other groups (namely Hispanics, African Americans, and People with Disabilities) do not have to meet this mandate.
- It is critical that the CDFI Fund recognize federally designated service counties/service areas that encompass a significant portion of the service population (or, in this instance, “Target Market”) of many Native CDFIs across the country.
- Loans made to a non-Native person or entity that is serving a Native CDFI’s Target Market should count as a qualified loan product for said Target Market if it can be clearly demonstrated that the end beneficiary is Native people or Native communities