MCUL Submits Comments on CDFI Comment Request: Annual Certification and Data Collection Report Form
Today, MCUL filed comments in response to the CDFI Fund’s Request for Public Comment on revisions made to the Annual Certification and Data Collection Report (ACR) and Abbreviated Transaction Level Report (TLR). This submission marks the third comment letter we’ve submitted in recent months. In December, we commented on the Fund’s proposed Certification Application and on the Fund’s newly proposed Target Market Assessment Methodologies. Following those comments, earlier this week the Fund announced that it would be extending its timeline for implementing the new Certification Application to allow for additional time to review and consider the comments made.
Our comments on the ACR and TLR revision include the following 4 points:
- Ensure member PII is protected when requesting loan-level data reporting from CDFI credit unions
- Highlights an issue raised in our previous comments that are carried over into this issue, related to formalizing Developmental Services programs and pegging them to specific product offerings. We ask for that requirement to be eliminated for credit unions, given our mission-oriented focus.
- Request that the Fund utilize publicly available call report data to pre-populate data points
- The proposed instructions includes a new policy that establishes an entirely new cure standard. We request that this new policy be ran through the rulemaking process and subjected to proper public comment
