Audit Report - Oig 23 033 Coronavirus Disease 2019 Pandemic Relief Programs Audit Of The Communi
Summary
Audit Report OIG-23-033 of the Office of Inspector General, Department of the Treasury, dated September 13, 2023, titled Audit of the Community Development Financial Institutions Fund's Implementation of the CDFI Equitable Recovery Program. It is addressed to Marcia Sigal, Acting Director of the Community Development Financial Institutions Fund. The report states that the objective was to assess the CDFI Fund's CDFI ERP implementation, including pre-award and award activities, and that the scope covered December 2020 through December 2022. Its Results in Brief states that the CDFI Fund took appropriate steps to establish the CDFI ERP, that the Consolidated Appropriations Act, 2021 did not specify a due date to make funds available or expend them, and that the report makes no recommendations.
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Audit Report
OIG-23-033
CORONAVIRUS DISEASE 2019 PANDEMIC RELIEF
PROGRAMS
Audit of the Community Development
Financial Institutions Fund's Implementation
of the CDFI Equitable Recovery Program
September 13, 2023
Office of Inspector General
Department of the Treasury
This Page Intentionally Left Blank
Contents
Audit Report
Results in Brief ...................................................................................................2
Background ........................................................................................................4
Audit Results ......................................................................................................7
CDFI Fund’s Implementation of CDFI ERP Complied With Federal
Requirements .............................................................................7
Appendices
Appendix 1: Objective, Scope, and Methodology .................................................. 20
Appendix 2: Management Response .................................................................... 27
Appendix 3: Major Contributors to This Report ..................................................... 28
Appendix 4: Report Distribution .......................................................................... 29
Abbreviations
AMIS Awards Management Information System
CAA, 2021 Consolidated Appropriations Act, 2021
CDFI Community Development Financial Institutions
CDFI ERP CDFI Equitable Recovery Program
CDFI FA CDFI Financial Assistance Program
CDFI Fund Community Development Financial Institutions Fund
CDFI RRP CDFI Rapid Response Program
COVID-19 Coronavirus Disease 2019
FY Fiscal Year
GAO U.S. Government Accountability Office
Green Book GAO’s Standards for Internal Control in the Federal Government
MLI Minority Lending Institution
NOFA Notice of Funding Availability
OCME Office of Compliance Monitoring and Enforcement
OIG Treasury Office of Inspector General
OMB Office of Management and Budget
PG&Ms Performance Goals and Measures
SAM System for Award Management
Treasury Department of the Treasury
Uniform Guidance Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards, 2 CFR Part 200
i
This Page Intentionally Left Blank
September 13, 2023
Marcia Sigal
Acting Director of the Community Development Financial
Institutions Fund
This report presents the results of our audit of the Community
Development Financial Institutions (CDFI) Fund's implementation of
the CDFI Equitable Recovery Program (CDFI ERP). Title V, Subtitle
B in Division N of the Consolidated Appropriations Act, 2021 1
(CAA, 2021) authorized the CDFI Fund to provide emergency
support to CDFIs and communities responding to the economic
impact of the Coronavirus Disease 2019 (COVID-19) pandemic.
Furthermore, the Department of the Treasury's (Treasury) Office of
Inspector General (OIG) is required to submit a report no less than
twice a year to Congress 2 and Treasury on the oversight provided
for the programs established under Subtitle B, including any
recommendations for improvement. In accordance with this
mandate, we conducted this audit.
The objective of this audit was to assess the CDFI Fund’s CDFI
ERP implementation, to include pre-award and award activities,
including making funds available. 3 The scope of our audit included,
but was not limited to, reviewing (1) CDFI ERP application
requirements; (2) grant opportunity announcements; (3) policies
and procedures; (4) award terms and conditions; and (5) other
documentation governing the CDFI Fund’s administration of CDFI
ERP grants. We also reviewed the CDFI Fund’s plans for
establishing CDFI ERP post-award monitoring procedures. Our audit
1
P.L. 116-260, Consolidated Appropriations Act, 2021 (December 27, 2020).
2
The committees of Congress named under Subtitle B include the Committee on Financial
Services of the House of Representatives and the Committee on Banking, Housing, and Urban
Affairs of the Senate.
3
As it relates to our audit objectives, funds available is defined as the announcement of a funding
opportunity advertising the CDFI ERP to the public.
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 1
scope included the CDFI Fund’s activities related to the design and
implementation of the CDFI ERP from December 2020 through
December 2022.
To accomplish our audit objective, we reviewed the CDFI ERP
Notice of Funds Availability 4 (NOFA) and application materials;
documented and reviewed CDFI ERP policies and procedures, major
decisions, award terms and conditions, and other supporting
documentation related to the CDFI Fund’s implementation of the
CDFI ERP; performed walkthroughs of the CDFI Fund’s Awards
Management Information System 5 (AMIS); and interviewed CDFI
Fund officials and personnel responsible for implementing the CDFI
ERP. Because the CDFI ERP was still under development, we
performed an assessment of the design of processes and internal
controls over CDFI ERP pre-award activities and award activities.
We conducted our fieldwork from August 2022 to
December 2022. Appendix 1 contains a detailed description of our
audit objective, scope, and methodology.
Results in Brief
The CDFI Fund took appropriate steps to establish the CDFI ERP to
include making funds available to recipients, as well as establishing
policies, procedures, and program guidance. While the CDFI Fund
established the CDFI ERP in accordance with applicable laws and
regulations, the CAA, 2021 did not specify a due date to make
funds available or expend them.
During our assessment, we found that CDFI Fund management
allocated existing staff, hired new personnel, and contracted
external reviewers in standing up the CDFI ERP. In designing a
framework to comply with the CAA, 2021, management consulted
with officials from Treasury, the Office of Management and Budget
4
The NOFA is a Federal agency’s formal announcement of the availability of Federal funding for a
financial assistance program.
5
AMIS is an enterprise-wide business system that supports all CDFI Fund programs through each
phase of the programs’ life cycles, including processes related to certification, program awards and
allocations, pre-award requirements, compliance reporting, and data analysis. Additionally, applicants
use AMIS to create, complete, and submit applications.
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 2
(OMB), and staff members from the Senate Committee on Banking,
Housing, and Urban Affairs and the House Financial Services
Committee. Additionally, the CDFI Fund leveraged the existing
program structures from the CDFI Rapid Response Program 6 (CDFI
RRP) and CDFI Financial Assistance 7 (CDFI FA) Program, and used
existing tools to evaluate CDFI ERP candidates’ financial and
compliance risk.
The CDFI Fund established internal controls over the CDFI ERP in
accordance with the U.S. Government Accountability Office’s
(GAO) Standards for Internal Control in the Federal Government 8
(Green Book) to include (1) a process for CDFIs to apply for CDFI
ERP awards conforming to the CAA, 2021; and (2) a CDFI ERP
application evaluation process (including award determinations) to
meet the legislative requirements.
We determined that the CDFI Fund provided sufficient guidance to
potential CDFI ERP applicants and developed CDFI ERP-specific
application submission and review processes’ policies, procedures,
and internal guidance for program personnel.
As of February 2023, the CDFI Fund continued to build out its
CDFI ERP-specific post-award policies and procedures, and other
program guidance and documentation.
We make no recommendations in this report. As part of our
reporting process, we provided CDFI Fund management an
opportunity to comment on a draft of this report. In a written
response, the CDFI Fund management acknowledged there was no
recommendation and stated that they appreciated the work of
6
The CAA, 2021 provided $1.25 billion to the CDFI Fund to award CDFIs with grants to deliver
immediate assistance in communities impacted by the COVID-19 pandemic through the CDFI RRP.
The CDFI RRP was designed to quickly and broadly deploy capital to certified CDFIs through a
streamlined application and valuation methodology. On June 15, 2021, Treasury announced that it
had awarded $1.25 billion in COVID-19 relief funds to 863 CDFIs.
7
The CDFI FA Program offers awards of up to $2 million to allow CDFIs to sustain and expand their
products and services as outlined in their funding applications. CDFIs must match this award with
funds from a non-Federal source. CDFI FA awards can be used for lending capital, loan loss reserves,
capital reserves, operations, and development services.
8
The GAO Green Book sets the standards for an effective internal control system for Federal agencies
and provides the overall framework for designing, implementing, and operating an effective internal
control system.
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 3
Treasury OIG staff, and the opportunity to review and provide a
response to the report. The CDFI Fund’s management response, in
its entirety, is included in appendix 2 of this report.
Background
The CDFI Fund
The CDFI Fund was established by the Riegle Community
Development Regulatory Improvement Act of 1994, 9 as a
bipartisan initiative created for the purpose of promoting economic
revitalization and community development through investment in
and assistance to CDFIs. Since its creation, the CDFI Fund has
awarded more than $5.5 billion to CDFIs, community development
organizations, and financial institutions through: the Bank
Enterprise Award Program; the Capital Magnet Fund; the CDFI RRP;
the Community Development Financial Institutions Program,
including the Healthy Food Financing Initiative; the Economic
Mobility Corps; the Native American CDFI Assistance Program; and
the Small Dollar Loan Program. In addition, the CDFI Fund has
allocated $66 billion in tax credit allocation authority to Community
Development Entities through the New Markets Tax Credit
Program, and closed guaranteed bonds for more than $2.1 billion
through the CDFI Bond Guarantee Program.
The CDFI Fund is led by a Director 10 who is supported by a Senior
Advisor, the Chief Financial Officer, the Office of Legal Counsel,
and the Office of Legislative and External Affairs. There are two
Deputy Directors who oversee program and operations: (1) the
Deputy Director of Policy and Programs who oversees the efforts
of all the CDFI Fund’s award programs in support of the CDFI
Fund’s strategic visions; and (2) the Deputy Director of Finance
and Operations who is responsible for developing policies,
operating procedures, internal controls, and short- and long-term
strategic plans for the CDFI Fund.
9
P.L. 103-325, The Riegle Community Development and Regulatory Improvement Act of 1994
(September 23, 1994).
10
As of May 8, 2023, the Deputy Director of Policy and Programs is the Acting Director of the CDFI
Fund. The Senior Advisor to the Deputy Director of Policy and Programs is currently the Acting
Deputy Director of Policy and Programs.
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 4
CDFI Certification
CDFI certification is the CDFI Fund’s recognition of specialized
financial institutions serving low-income communities. Through
certification, CDFIs are qualified to apply for CDFI FA Program
awards, as well as training provided by the CDFI Fund through the
Capacity Building Initiative. 11
To apply for a CDFI ERP award, organizations must have been
certified by the CDFI Fund as of the date of the CDFI ERP NOFA
publication in the Federal Register. 12
To become a certified CDFI, an organization must:
(1) be a legal entity;
(2) have a primary mission of promoting community
development;
(3) be a financing entity;
(4) provide development services along with financing activities;
(5) serve one or more target market(s); 13
(6) maintain accountability to its defined target market(s); and
(7) be a non-government entity and not under the control of any
government entity.
Once a CDFI has been certified, it must submit an Annual
Certification and Data Collection Report to allow the CDFI Fund to
assess whether the organization remains in compliance with their
11
The CDFI Fund created the Capacity Building Initiative to help CDFIs improve their ability to deliver
financial products and services to economically underserved communities. CDFIs can access free
training workshops, webinars, market research, customized technical assistance, and informational
resources to help them develop, diversify, and grow.
12
The CDFI ERP NOFA was published in the Federal Register on June 24, 2022.
13
A target market refers to one or more investment area(s) and/or targeted population(s). Targeted
populations may include low-income targeted populations (defined based on income) or other
targeted populations (an identifiable group of individuals in the organization's service area for which
there exists a strong basis in evidence that the group lacks access to loans, equity investments,
and/or financial services).
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 5
certification requirements and to monitor any changes in the
organization’s financial and/or other data. 14
CAA, 2021
Title V, Subtitle B, Community Development Investment, within
Division N of the CAA, 2021, appropriated $3 billion to the CDFI
Fund, of which, up to $1.75 billion shall be made available until
expended to provide grants to CDFIs to respond to the economic
impact of the COVID-19 pandemic. 15
The CDFI Fund shall use the funds to expand lending, grant
making, or investment activity in low- or moderate-income minority
communities that have significant unmet capital or financial service
needs using criteria such as certification status, financial and
compliance performance, portfolio and balance sheet strength, a
diversity of CDFI business model types, status as a minority
lending institution 16 (MLI), and program capacity, as well as
experience making loans and investments in those areas and
populations identified.
Additionally, up to $1.2 billion shall be for providing financial
assistance, technical assistance, awards, and training and outreach
programs to recipients that are MLIs.
14
In May 2020, the CDFI Fund announced that they would be requesting public comment on a revised
CDFI certification application and two certification reports: the Annual Certification and Data
Collection Report and a new certification Transaction Level Report. The CDFI Fund paused the
acceptance of new CDFI certification applications and requests for target market modifications for a
period of six months beginning on October 1, 2022 in order to complete preparations needed to
deploy the new CDFI certification application and reporting tools. CDFIs applying for the CDFI ERP
were required to be certified.
15
The $1.75 billion was allocated for the CDFI ERP. The remaining $1.25 billion was allocated for the
CDFI RRP, which is not within the scope of this audit.
16
The CAA, 2021 defines an MLI as a CDFI: (A) with respect to which a majority of both the number
and dollar volume of arm’s-length, on-balance sheet financial products of the CDFI are directed at
minorities or majority minority census tracts or equivalents; and (B) that— (i) is a minority depository
institution, as defined in section 308(b) of the Financial Institutions Reform, Recovery, and
Enforcement Act of 1989 (12 U.S.C. 1463 note), or otherwise considered to be a minority
depository institution by the appropriate Federal banking agency, as defined in section 3 of the
Federal Deposit Insurance Act (12 U.S.C. 1813), or by the National Credit Union Administration, as
applicable; or (ii) meets standards for accountability to minority populations as determined by the
Administrator.
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 6
Audit Results
CDFI Fund’s Implementation of CDFI ERP Complied With
Federal Requirements
CDFI Fund management took appropriate steps to establish the
CDFI ERP in compliance with the GAO Green Book, the CAA,
2021, and OMB’s Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards, 2 Code of
Federal Regulations 200 (Uniform Guidance).
Specifically, CDFI Fund management staffed the program in
accordance with GAO Green Book Principles by allocating existing
staff, hiring new personnel, and contracting external reviewers.
The CDFI Fund also made funds available to recipients and
designed the program in compliance with the CAA, 2021 and the
Uniform Guidance. Furthermore, the CDFI Fund followed the GAO
Green Book when establishing program-specific policies,
procedures, and program guidance relating to the application
submission and review processes.
The CDFI Fund Staffed and Established the CDFI ERP
As part of the CAA, 2021, the CDFI Fund was permitted to use
funds appropriated to the emergency support programs for
administrative expenses, such as staffing costs and contracts. As
of the end of fiscal year (FY) 2022, the CDFI Fund expended
approximately $2.74 million in administrative expenses related to
the implementation of the CDFI ERP. The CDFI Fund allocated
$8.37 million in remaining funds to be used to administer the
program. 17
The CDFI Fund established the CDFI ERP consistent with GAO
Green Book Principle 3, which states that “management should
establish an organizational structure, assign responsibility, and
delegate authority to achieve the entity’s objectives.” The CDFI
Fund created an organizational chart, determined staffing needs for
17
In the September 26, 2021 FY 2022 SF-132 apportionment request to OMB, the CDFI Fund
estimated it would need to retain $11.04 million to cover administrative expenses for the CDFI ERP
prior to the finalization of the program’s design. As a result of the finalization of the CDFI ERP
design, the CDFI Fund has revised its initial budgetary needs to approximately $11.11 million.
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 7
the program to accomplish the objectives, and assigned authority
and responsibility to key staff members. In addition, the CDFI ERP
Program team is supported by other CDFI Fund business units.
Specifically, these business units include (1) the Information
Technology unit; (2) the Office of Compliance Monitoring and
Evaluation (OCME); (3) the Office of Certification Policy and
Evaluation; (4) the Financial Strategies and Research Unit; (5) the
Office of Legal Counsel; (6) the Office of Legislative and External
Affairs; and (7) the Office of the Deputy Director for Policy and
Programs. An example of this support is the application review and
award determination processes. The application review and award
determination processes include staff from OCME and the Program
Office, along with external reviewers. 18 OCME staff members are
also responsible for ensuring that award recipients are in
compliance with their Assistance Agreements. 19
The CDFI Fund designed the CDFI ERP framework in compliance
with Uniform Guidance §200.202, which states that the Federal
awarding agency must design a program with clear goals and
objectives that facilitate the delivery of results consistent with the
Federal authorizing legislation and create an Assistance Listing
before announcing the NOFA. Specifically, CDFI Fund and Treasury
management consulted with officials from the Treasury Office of
General Counsel and other government organizations 20 regarding
the NOFA, the program application, and other program
documentation. Additionally, the CDFI Fund leveraged the existing
program structures from the CDFI RRP and the CDFI FA Program,
18
As of June 13, 2022, the CDFI Fund hired an external contractor to support completion of the CDFI
ERP application evaluation process and related activities. The original contract period of performance
was set to end on January 16, 2023, but a modification to the contract extended the period of
performance through February 17, 2023.
19
Once selected to receive an award, each applicant must enter into a CDFI ERP Assistance
Agreement with the CDFI Fund in order to receive payment. The Assistance Agreement will set
forth the award’s terms and conditions, including but not limited to the: (i) award amount; (ii) award
type; (iii) the approved uses of award; (iv) eligible use of funds; (v) performance goals and measures
(PG&Ms); and (vi) reporting requirements. Assistance Agreements will have a five-year period of
performance.
20
The CDFI Fund met with officials from OMB, along with staff members from the Senate Committee
on Banking, Housing, and Urban Affairs and the House Financial Services Committee.
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 8
along with existing tools, such as the Application Assessment
Tool. 21
The CDFI Fund published the CDFI ERP Assistance Listing and
NOFA, and announced the funding opportunity, in compliance with
the Uniform Guidance. Per Uniform Guidance §200.203, the
Federal awarding agency must create the Assistance Listing based
on the authorizing legislation.
In accordance with Uniform Guidance §200.202 and §200.203,
the CDFI Fund posted the CDFI ERP Assistance Listing in the
System for Award Management 22 (SAM.gov) on June 3, 2022,
prior to the publication of the NOFA.
Furthermore, per Uniform Guidance §200.204, the Federal
awarding agency must announce specific funding opportunities by
providing key information in a public notice. The CDFI Fund
published the NOFA in the Federal Register on June 24, 2022. The
NOFA provides public information about the program, including
eligibility requirements, critical deadlines, and reporting
requirements. Finally, the CDFI Fund announced the CDFI ERP
funding opportunity on Grants.gov. 23
The NOFA was subsequently amended on July 19, 2022, to
change the application deadline from August 23, 2022, to
September 22, 2022, 24 and to issue a technical correction related
to the eligibility requirements for the program.
21
The CDFI Fund uses the Application Assessment Tool within AMIS to produce applicants’ total
compliance composite scores based on responses to the compliance questions, as well as
information in an applicant’s reporting history, reporting capacity, and performance risk with respect
to the CDFI Fund’s PG&Ms.
22
SAM.gov is an official website of the U.S. Government. Users can use the site to: register to do
business with the U.S. Government; update, renew, or check the status of an entity’s registration;
search for entity registration and exclusion records; search for assistance listings, wage
determinations, contract opportunities, and contract data reports; view and submit BioPreferred and
Service Contract Reports; and access publicly available award data via data extracts and system
accounts.
23
Grants.gov is a system that provides a centralized location for grant seekers to find and apply for
federal funding opportunities. The Grants.gov system houses information for over 1,000 grant
programs and vets grant applicants for federal grant-making agencies.
24
On September 21, 2022, due to Hurricane Fiona, the CDFI Fund extended the application deadline
for organizations headquartered in Puerto Rico from September 22, 2022, to October 6, 2022.
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 9
CDFI ERP Requirements
The CDFI Fund created the requirements to apply for the program
to provide funding to CDFIs with a demonstrated experience and
interest in CDFI ERP-Eligible Geographies. Additionally, the CDFI
Fund limited eligibility for the CDFI ERP to only certified CDFIs, as
required by the CAA, 2021.
The CDFI ERP general requirements provided in the NOFA include
the following:
(1) organizations must be certified by the CDFI Fund as of the
date of the CDFI ERP NOFA publication in the Federal
Register;
(2) organizations must have at least 30 percent of their average
annual financial products closed 25 and grants made (dollar
volume and number of transactions) in CDFI ERP-Eligible
Geographies over their five most recent historic fiscal years;
and
(3) organizations must have audited financial statements for
their two most recent historic fiscal years.
CDFI ERP-Eligible Geographies are those areas that meet at least
one of the following two criteria: (i) they are census tracts that
have the following three characteristics: (1) severe impact from
COVID-19 pandemic; (2) Low-or Moderate-Income Census
Tract(s); 26 and (3) are CDFI Investment areas; or (ii) they are Native
Areas. The CDFI Fund created the CDFI ERP-Eligible Geography
term for the CDFI ERP and used a combination of data elements to
fulfill the requirements of the CAA, 2021.
Furthermore, applicants must have at least 30 percent of their
average annual financial products closed and grants made (both in
25
Financial products closed means loans, equity investments, and similar financing activities (as
determined by the CDFI Fund) including the purchase of loans originated by certified CDFIs and the
provision of loan guarantees. In the case of CDFI intermediaries, financial products may also include
loans to CDFIs and/or emerging CDFIs and deposits in insured credit union CDFIs, emerging insured
credit union CDFIs, and/or state-insured credit union CDFIs.
26
Low- or Moderate-Income Census Tracts have a median income at or below 120% of the Area
Median Income.
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 10
dollar volume and in number of transactions) in CDFI ERP-Eligible
Geographies over their five most recent fiscal years.
The CDFI Fund prioritized CDFI ERP applicants with a track record
in one or more of the following areas:
(1) making loans, grants, or investments in low- or moderate-
income minority communities that are also CDFI ERP-Eligible
Geographies;
(2) making loans, grants, or investments to minorities that have
significant unmet capital or financial services needs;
(3) making loans, grants, or investments in Persistent Poverty
Counties, 27 Native Areas, and/or U.S. Territories; and
(4) making loans, grants, or investments to small businesses
with less than $1 million in annual gross revenue or to small
farms, with an emphasis on small businesses with less than
$100,000 in annual gross revenue.
Additionally, the CDFI Fund prioritized CDFI ERP applicants who
had taken one or more of the following actions since the onset of
the COVID-19 pandemic:
(1) increasing lending in CDFI ERP-Eligible Geographies;
(2) creating new financial products and grants to support CDFI
ERP-Eligible Geographies; and
(3) expanding into previously underserved CDFI ERP-Eligible
Geographies.
To submit a CDFI ERP application, the applicant must register in
Grants.gov, SAM.gov, and AMIS. Additionally, the applicant must
27
A Persistent Poverty County means any county, including county equivalent areas in Puerto Rico,
that has had 20 percent or more of its population living in poverty over the past 30 years, as
measured by the 1990 and 2000 decennial census and the 2011-2015 5-year data series available
from the American Community Survey of the Bureau of the Census, or any other territory or
possession of the United States that has had 20 percent or more of its population living in poverty
over the past 30 years, as measured by the 1990, 2000, and 2010 Island Areas Decennial
Censuses, or equivalent data, of the Bureau of the Census.
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 11
obtain an Employer Identification Number, 28 a Unique Entity
Identifier, 29 and ensure consistency of information between
SAM.gov and AMIS.
Furthermore, applicants must undergo a two-step process that
requires the submission of application documents by two separate
deadlines in two different locations:
(1) the OMB Standard Form-424 “Application for Federal
Assistance” in Grants.gov; and
(2) all other required application documents in AMIS. 30
CDFI ERP Eligible Activities
The CDFI Fund determined the minimum award size for a CDFI ERP
Award to be $500,000 with a maximum award size being
$15 million, or three times the applicant’s average on-balance
sheet financial products closed in its five most recent historic fiscal
years, whichever is less.
The period of performance for each CDFI ERP award begins with
the date the CDFI Fund announces the recipients of the program
and includes five full consecutive fiscal years after the date of the
award announcement. The CDFI Fund will provide CDFI ERP
awards in the form of grants to support eligible activities which
28
An Employer Identification Number is also known as a Federal Tax Identification Number, and is
used to identify a business entity.
29
A Unique Entity Identifier is a unique number assigned to all entities (public and private companies,
individuals, institutions, or organizations) who register to do business with the Federal government.
30
Applicants must have submitted an OMB Standard Form-424 via Grants.gov by August 18, 2022,
and the CDFI ERP Application Package through AMIS by September 22, 2022.
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 12
may be expended as (1) financial products and services 31
and (2) operational support. 32
For any award size, no more than 25 percent of the award amount
may be used for financial services and development services
combined. The CDFI Fund limited the uses of CDFI ERP awards on
financial services and development services to encourage CDFIs to
expand lending through financial instruments. These financial
instruments are intended to support communities experiencing
financial capital needs and encourage investments during a
financial crisis. Additionally, the recipient may use up to the greater
of $166,667 or 15 percent of the award amount, up to a maximum
of $400,000, for eligible activities in the operational support
categories combined.
CDFI ERP recipients must meet certain performance goals and
measures (PG&Ms) as a condition of their award, including, but not
limited to:
(1) all CDFI ERP recipients must expend 60 percent of the award
amount by the end of year three of the period of
performance, 80 percent of the award amount by the end of
year four, and 100 percent of the award amount by the
period of performance end date;
(2) recipients must deploy 90 percent of funds for program
activities in the CDFI ERP-Eligible Geographies; and
31
Financial products and services may serve commercial real estate, small businesses,
microenterprise, community facilities, and affordable housing, and also includes consumer financial
products, consumer financial services, commercial financial products, commercial financial services,
intermediary lending to non-profits and CDFIs, and other lines of business as deemed appropriate by
the CDFI Fund in the following six eligible financial products and services categories: (i) financial
products (e.g. loans and equity investments); (ii) financial services (e.g. providing checking and
savings accounts); (iii) development services (e.g. activities that promote community development):
(iv) grants (e.g. funds transferred without a repayment requirement to a person, business, or other
organization); (v) loan loss reserves (e.g. award funds set aside in the form of cash reserves to
cover losses on loans); and (vi) capital reserves (e.g. award funds set aside as reserves to support a
CDFI’s ability to leverage other capital for a specific purpose, such as providing financing).
32
A portion of a CDFI ERP award may also be used for the following seven eligible operational support
categories: (vii) compensation – personal services; (viii) compensation – fringe benefits; (ix)
professional service costs; (x) travel costs; (xi) training and education costs; (xii) equipment; and
(xiii) supplies.
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 13
(3) any award funds deployed outside of CDFI ERP-Eligible
Geographies must serve low- or moderate-income persons or
businesses disproportionately impacted by the COVID-19
pandemic that are included in CDFI Eligible Markets.
Additional PG&Ms for each recipient will be determined based on
the recipients proposed commitments relative to the CDFI ERP
policy priorities in the CDFI ERP application. Final PG&Ms may
differ and will be set forth in the CDFI ERP Assistance Agreement.
The CDFI Fund Sought Public Comment for the Definition
of an MLI
Pursuant to Section 523 of Division N of the CAA, 2021, an MLI is
a CDFI that (i) directs a majority of its financial products to minority
populations or communities; and (ii) either (a) is a minority
depository institution or (b) demonstrates accountability to minority
populations. While the CAA, 2021 allows up to $1.2 billion in
awards for MLIs, the CDFI Fund opted not to set aside funds for
MLIs.
On July 28, 2022, the CDFI Fund published a notice in the Federal
Register to solicit public comment 33 on the designation criteria for a
MLI. Through the public comment process, the CDFI Fund sought
feedback from the public on certain aspects of the MLI designation
criteria and the process the CDFI Fund should use to designate a
CDFI as a MLI. The CDFI Fund plans to consider the feedback
received through the public comment period prior to establishing a
final definition or designation.
Upon implementation of the final MLI designation criteria, the CDFI
Fund plans to utilize the designation for limited purposes, including
data collection and reporting.
On February 16, 2023, the CDFI Fund reported that a total of
25 comments were submitted in response to the request. The CDFI
Fund is in the process of reviewing these comments to formulate
33
The request for comment was published in the Federal Register on July 28, 2022, with a closing
date of November 25, 2022.
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 14
MLI designation criteria. The CDFI Fund anticipates releasing final
MLI criteria later in 2023.
CDFI Fund Communication with CDFI ERP Applicants
On June 24, 2022, the CDFI Fund published the NOFA in the
Federal Register inviting applicants to apply for grants under the
CDFI ERP. The CDFI Fund provided an extensive list of guides, two
sets of frequently asked questions, and three application webinars
to assist applicants in applying for grants under this program.
On July 15, 2022, the CDFI Fund published an amended NOFA in
the Federal Register to change the application package deadline in
AMIS from August 23, 2022, to September 22, 2022, as well as
make a technical correction related to the eligibility requirements.
The CDFI Fund extended the application deadline to allow
prospective applicants time to review their portfolios to ensure that
they could meet the new requirements of the program regarding
eligibility criteria.
In order to develop CDFI ERP-specific documents, the CDFI Fund
started with existing documents, program guidance, and processes
from the CDFI RRP and CDFI FA. Specifically, the CDFI Fund used
required information, definitions, and data points consistent with
the CDFI RRP and CDFI FA to meet the legislative requirements for
CDFI ERP.
The CDFI Fund Developed the CDFI ERP Application
Review Process
The CDFI Fund established control activities for the CDFI ERP
application review process consistent with GAO Green Book
Principle 10, which states that “management should design control
activities to achieve objectives and respond to risks.”
Specifically, the CDFI Fund created a four-step application review
process, which includes:
(1) determining applicants’ eligibility for the CDFI ERP award
based on the requirements in the NOFA;
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 15
(2) evaluating each applicant’s financial health and compliance
risk;
(3) reviewing and scoring applications; and
(4) award sizing and final determinations.
The CDFI Fund also designed policies and procedures for the
application review process consistent with GAO Green Book
Principle 12, stating, “management should implement control
activities through policies.” Leveraging policies and procedures
from existing CDFI Fund programs, the CDFI Fund created
procedures, such as the CDFI ERP Standard Operating Procedures,
to standardize the application review process, and to allocate
review responsibilities across CDFI Fund staff and units.
Additionally, the CDFI Fund created detailed Job Aids for specific
aspects of the CDFI ERP application review process, including the
eligibility review and the financial analysis and compliance risk
evaluation.
CDFI ERP Applicants Requested Over Four Times the
Available Award Funding
On February 1, 2023, the CDFI Fund released application data for
the CDFI ERP. In total, 696 CDFIs headquartered in 46 states, the
District of Columbia, Guam, and Puerto Rico requested a total of
$7.69 billion in awards, which is over four times the amount of
available funding ($1.75 billion).
More than half of all certified CDFIs submitted an application for a
CDFI ERP award, which included applications submitted by:
• 326 CDFI loan funds, which represents 46.8% of all CDFI
ERP applicants and 57% of all certified CDFI loan funds;
• 222 CDFI credit unions, which represents 31.9% of all CDFI
ERP applicants and 47% of all certified CDFI credit unions;
• 141 CDFI banks/bank holding companies, which represents
20.3% of all CDFI ERP applicants and 44% of all certified
CDFI bank/bank holding companies; and
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 16
• 7 CDFI venture capital funds, which represents 1% of all
CDFI ERP applicants and 47% of all certified CDFI venture
capital funds.
During the application process, CDFI ERP applicants were required
to select from one of five policy priorities where they would
commit to deploy their CDFI ERP Awards. CDFI ERP applicants
committed to devote their prospective awards in the following
areas:
• 37.8% of applicants committed to serve Low- or Moderate-
Income Majority Minority Census Tracts that are also CDFI
ERP-Eligible Geographies;
• 29.5% of applicants committed to serve minority individuals
or minority-owned or controlled businesses;
• 20.5% of applicants committed to serve Persistent Poverty
Counties, Native Areas and/or U.S. Territories;
• 7.3% of applicants committed to serve small businesses and
farms; and
• 4.9% of applicants committed to increase the dollar volume
of financial products closed and grants made by their
organizations in CDFI ERP-Eligible Geographies.
The CDFI Fund Designed Information Systems for the
CDFI ERP
The CDFI Fund established control activities in AMIS to submit and
evaluate CDFI ERP applications. Per GAO Green Book Principle 11,
“management should design the entity’s information system and
related control activities to achieve objectives and respond to
risks.” For example, management created validity checks within
AMIS to prevent errors in submitting and reviewing applications,
which the Program Office demonstrated during a walkthrough of
the application submission and review processes in AMIS. 34
34
At the time of the walkthrough, the CDFI ERP applications were still under review. As such, the
Program Office demonstrated the application submission and review processes using test data.
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 17
Furthermore, the CDFI Fund designed policies and procedures for
the application review process in AMIS consistent with GAO Green
Book Principle 12 that states “management should implement
control activities through policies.” The CDFI Fund established
AMIS policies and procedures for the program’s application review
process, including the “CDFI ERP Internal Review AMIS Navigation
Guide” and the “FY 2022 CDFI ERP External Review AMIS
Navigation Guide.” Specifically, these documents provided Federal
and external reviewers with instructions for completing their
respective steps in the application review process in AMIS.
The CDFI Fund also published AMIS guidance for the program’s
application submission process, such as the “FY 2022 AMIS
Training Manual for CDFI Equitable Recovery Program,” on the
CDFI Fund website. Per GAO Green Book Principle 15,
“management should externally communicate the necessary quality
information to achieve the entity’s objectives.” This publicly
available guidance provided applicants with the steps to complete
their CDFI ERP applications in AMIS according to the program’s
objectives.
Next Steps
Post-Award Monitoring Procedures for CDFI ERP
The FY 2022 CDFI ERP application period closed on
October 6, 2022. 35 As of the end of our fieldwork, CDFI Fund
management was developing CDFI ERP post-award monitoring
procedures. The CDFI Fund is leveraging existing data collection
tools and post-award compliance monitoring procedures to meet
the specific requirements of CDFI ERP. In addition, CDFI Fund
management intends to incorporate the CDFI ERP into its standard
operating procedures.
******
35
On April 10, 2023, Treasury announced that it had awarded over $1.73 billion in grants to 604
CDFIs for the CDFI ERP.
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 18
We appreciate the courtesies and cooperation provided to our staff
during the audit. If you wish to discuss the report, you may
contact me at (202) 577-6609 or James Fuller, Audit Manager, at
(202) 961-1080. Major contributors to this report are listed in
appendix 3. A distribution list for this report is provided as
appendix 4.
/s/
Cecilia Howland
Audit Director, State and Local Fiscal Recovery, RESTORE, and
CDFI Programs
Appendices
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 19
Appendix 1: Objective, Scope, and Methodology
The objective of this audit was to assess the Community
Development Financial Institutions (CDFI) Fund’s Equitable
Recovery Program (CDFI ERP) implementation, to include pre-award
and award activities, including making funds available.
The scope of our audit included, but was not limited to, reviewing
(1) CDFI ERP application requirements; (2) grant opportunity
announcements; (3) policies and procedures; (4) award terms and
conditions; and (5) other documentation governing the CDFI Fund’s
administration of CDFI ERP grants. Our audit scope included the
CDFI Fund’s activities related to the design and implementation of
the CDFI ERP from December 2020 through December 2022. We
also reviewed the CDFI Fund’s plans for establishing CDFI ERP
post-award monitoring procedures.
To accomplish this audit objective, we performed the following
procedures during audit fieldwork, which was conducted remotely
due to the Coronavirus Disease 2019 (COVID-19) pandemic,
between August 2022 and December 2022.
• Reviewed applicable Federal laws, regulations, and guidance,
including:
o P.L. 116-260, Title V, Subtitle B in Division N of
Consolidated Appropriations Act, 2021,
December 27, 2020;
o P.L. 103-325, Riegle Community Development and
Regulatory Improvement Act of 1994,
September 23, 1994;
o 12 Code of Federal Regulations Part 1805, “Community
Development Financial Institutions Program,”
August 31, 2015;
o Office of Management and Budget (OMB), Uniform
Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards, 2 Code of Federal
Regulations 200, Updated August 13, 2020 (effective
November 12, 2020);
o U.S. Government Accountability Office’s (GAO),
Standards for Internal Control in the Federal Government
(Green Book), September 2014; and
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 20
Appendix 1: Objective, Scope, and Methodology
o OMB Circular A-123, “Management’s Responsibility for
Enterprise Risk Management and Internal Control,”
July 15, 2016.
• Reviewed GAO’s Green Book to identify the components and
principles of internal control that were significant in the context
of the audit objective. Specifically, we evaluated the Control
Environment, Risk Assessment, Control Activities, Information
and Communication, and Monitoring internal control
components; and assessed policies, procedures, and guidance
against the following principles:
o Principle 3: Management should establish an
organizational structure, assign responsibility, and
delegate authority to achieve the objectives;
o Principle 7: Management should identify, analyze, and
respond to risks related to achieving the defined
objectives;
o Principle 9: Management should identify, analyze, and
respond to significant changes that could impact the
internal control system;
o Principle 10: Management should design control activities
to achieve objectives and respond to risks;
o Principle 11: Management should design the entity’s
information system and related control activities to
achieve objectives and respond to risks;
o Principle 12: Management should implement control
activities through policies;
o Principle 13: Management should use quality information
to achieve the entity’s objectives;
o Principle 14: Management should internally communicate
the necessary quality information to achieve the entity’s
objectives;
o Principle 15: Management should externally communicate
the necessary quality information to achieve the entity’s
objectives;
o Principle 16: Management should establish and operate
monitoring activities to monitor the internal control
system and evaluate the results; and
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 21
Appendix 1: Objective, Scope, and Methodology
o Principle 17: Management should remediate identified
internal control deficiencies on a timely basis.
• Reviewed CDFI Fund documentation related to the planning and
design of the CDFI ERP, including:
o CDFI ERP Notice of Funding Availability (NOFA),
June 24, 2022;
o CDFI ERP pre-award documentation, such as the
Assistance Listing (21.033) and Grants.gov
announcement;
o “Draft Minority Lending Program Design Matrix,”
(undated), provided on October 26, 2022;
o CDFI ERP staff lists, provided June 10, 2022 and
October 4, 2022;
o “CDFI ERP Spend Plan (for OMB)”, May 12, 2022;
o Memorandum for Fiscal Year (FY) 2022 Equitable
Recovery Program Notice of Funds Availability Approval,
June 9, 2022;
o “CDFI Minority Lending Program Overview Presentation,”
March 29, 2022;
o “Minority Lending Program Research Overview,”
August 16, 2021;
o Certified CDFI List as of June 24, 2022;
o “Memorandum of Understanding Between the Community
Development Financial Institutions Fund and the National
Credit Union Administration,” January 21, 2016;
o CDFI ERP Reviewer Contract effective June 13, 2022
(and modifications effective July 8, 2022,
September 2, 2022, and October 27, 2022);
o “COVID Impact Program: Geographic Eligibility,”
November 9, 2021; and
o OMB, “SF-132 Apportionment Schedule,”
September 27, 2021.
• Reviewed CDFI Fund documentation related to program
announcements, application educational materials and
presentations, and application assistance documents, including:
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 22
Appendix 1: Objective, Scope, and Methodology
o “CDFI Equitable Recovery Program Pre-Application
Overview,” May 2022;
o “CDFI Equitable Recovery Program 2022 Application
Frequently Asked Questions,” June 2022 and
September 9, 2022;
o “CDFI Equitable Recovery Program 2022 Application
Instructions,” June 2022;
o “CDFI ERP Eligible Geographies List,” June 2022;
o “CDFI ERP Application Financial Data Inputs,” June 2022;
o “CDFI ERP Data Inputs Workbook,” June 2022;
o “FY 2022 Awards Management Information System
(AMIS) Training Manual for CDFI Equitable Recovery
Program,” July 6, 2022;
o “CDFI Equitable Recovery Program Application
Overview,” June 30, 2022; and
o “Bulk Address Geocoding AMIS Training Manual,”
June 2022.
• Reviewed the CDFI Fund’s policies, procedures, and guidance
materials related to CDFI ERP application evaluation and award
determination processes, including:
o “FY 2022 CDFI Equitable Recovery Program Standard
Operating Procedures Step A Thru E,” October 4, 2022;
o “FY 2022 CDFI Equitable Recovery Program Step 1:
Eligibility Review Job Aid,” Version 1.1
October 18, 2022;
o “FY 2022 CDFI Equitable Recovery Program Step 2:
Financial Analysis and Compliance Risk Evaluation Job
Aid,” October 14, 2022;
o “CDFI ERP Regulator Data Job Aid,” (undated), provided
on November 4, 2022;
o “Compliance Monitoring and Evaluation Unit Standard
Operating Procedures,” (undated), provided on
November 4, 2022;
o “CDFI ERP Internal Review Guidance: Federal Reviewer,
Reviewing Official and Selecting Official,”
October 25, 2022;
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 23
Appendix 1: Objective, Scope, and Methodology
o “CDFI ERP Internal Review AMIS Navigation Guide:
Federal Reviewer, Reviewing Official and Selecting
Official,” October 25, 2022;
o “FY 2022 CDFI ERP External Review AMIS Navigation
Guide,” October 1, 2022;
o “FY 2022 CDFI Equitable Recovery Program External
Review Guide,” (undated), provided on
November 4, 2022;”
o “CDFI Equitable Recovery Program External Reviewer
Orientation Kickoff Webinar,” October 19, 2022;
o “FY 2022 CDFI Equitable Recovery Program External
Reviewer Training,” October 2022;
o “FY 2022 CDFI Equitable Recovery Program Internal
Review Training,” October 2022; and
o “Conflict of Interest Policy for CDFI Fund Application
Reviewers,” (undated), provided on November 4, 2022.
• Reviewed selected CDFI Fund’s guidance related to the CDFI
Program and CDFI Rapid Response Program (CDFI RRP):
o “CDFI Certification Fact Sheet,” January 14, 2016;
o “Community Development Financial Institutions Program
Fact Sheet,” February 28, 2020;
o “FY 2022 CDFI Program & NACA Program Application
Overview Presentation,” February 23, 2022;
o “FY 2022 CDFI NACA Frequently Asked Questions,”
March 2022;
o “CDFI RRP Assistance Agreement Template,”
June 16, 2021;
o CDFI Program NOFA, February 11, 2022; and
o CDFI RRP NOFA, February 26, 2021.
• Reviewed Department of the Treasury (Treasury) Office of
Inspector General (OIG) reports and GAO reports, including, but
not limited to:
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 24
Appendix 1: Objective, Scope, and Methodology
o Treasury OIG, Audit of the Community Development
Financial Institutions Fund’s Implementation of the CDFI
Rapid Response Program, OIG-22-023
(December 21, 2021);
o Treasury OIG, Audit of ASI Federal Credit Union’s CDFI
Program Awards, OIG-19-038 (July 11, 2019);
o Treasury OIG, Improvements Are Needed in the CDFI
Fund’s Administration of Technical Assistance Awards,
OIG-20-037 (June 12, 2020);
o Treasury OIG, Audit of Treasury’s Implementation of the
Emergency Capital Investment Program, OIG-22-028
(March 8, 2022);
o Treasury OIG, Audit of the Community Development
Financial Institutions Fund’s Financial Statements for
Fiscal Years 2021 and 2020, OIG-22-020
(December 15, 2021); and
o GAO, COVID-19: Significant Improvements Are Needed
for Overseeing Relief Funds and Leading Responses to
Public Health Emergencies, GAO-22-105291
(January 27, 2022).
• Interviewed the following CDFI Fund and Department of the
Treasury personnel:
o CDFI Fund Deputy Director of Policy & Programs;
o CDFI Fund Senior Policy Advisor;
o CDFI Fund Attorney Advisor;
o Treasury Assistant General Counsel; and
o Treasury Deputy Assistant General Counsel.
• Conducted walkthroughs of the CDFI Fund’s processes to gain
an understanding of the CDFI ERP application process, and
planned activities for making award determinations in AMIS.
Since no awards were made during our audit, we were only able
to assess the design of processes and internal controls
established over CDFI ERP pre-award and award activities.
We conducted this performance audit in accordance with generally
accepted government auditing standards. Those standards require
that we plan and perform the audit to obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings and
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 25
Appendix 1: Objective, Scope, and Methodology
conclusions based on our audit objectives. We believe that the
evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 26
Appendix 2: Management Response
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 27
Appendix 3: Major Contributors to This Report
James Fuller, Audit Manager
Lawrence Delva-Gonzalez, Auditor-in-Charge
Kristin Prestel, Auditor
Clint Hoellrigl, Auditor
Kajuana Britt, Referencer
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 28
Appendix 4: Report Distribution
Department of the Treasury
Secretary
Deputy Secretary
Under Secretary for Domestic Finance
Assistant Secretary for Domestic Finance
Assistant Secretary for Financial Institutions
Deputy Assistance Secretary for Community and Economic
Development
Acting Chief Recovery Officer
Office of Strategic Planning and Performance Management
Office of the Deputy Chief Financial Officer, Risk and Control
Group
Community Development Financial Institutions Fund
Acting Director
Acting Deputy Director of Policy and Program
Deputy Director of Finance and Operations
Legal Counsel
Office of Management and Budget
OIG Budget Examiner
U.S. Senate
Chairman and Ranking Member
Committee on Banking, Housing, and Urban Affairs
U.S. House of Representatives
Chairman and Ranking Member
Committee on Financial Services
Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program (OIG-23-033) 29
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