Today, the CDFI Fund opened the Calendar Year (CY) 2024-2025 Notice of Allocation Availability. CDEs will have until January 29, 2025 to apply for a record $10 billion in allocation.
KEY DATES
- Application Registration Deadline: Dec. 5, 2024
- Application Webinar: Dec. 17, 2024, 2pm-3pm ET. Zoom, Webinar ID: 1619431849.
- Submission Deadline in AMIS: Jan. 29, 2025
- QEI Issuance and QLICI Requirements Deadline: April 17, 2025
- Report QEIs and certify QLICIs in AMIS by: April 24, 2025
The decision to combine the 2024 and 2025 rounds puts the CDFI Fund back on schedule to award allocation in the year in which it was authorized.
APPLICATION CHANGES
QEI Threshold for Non-Rural CDEs
- The 2024/2025 NOAA reduced the first year QEI threshold for CY23 allocatees from 20 percent to 10 percent. The threshold for Rural CDEs is still zero percent for the first year.
OTHER NOTABLE REVISIONS (compared to CY23):
In their announcement, the CDFI Fund noted several changes in the application (compared to the CY23 application).
- Question 25(b) has been updated to include two new sub-questions for applicants to indicate (1) the extent their NMTC investments will serve areas of deep distress, U.S. territories, high migration rural counties, and NMTC Native Areas; and (2) its track record of serving such areas. An Applicant that commits to a higher percentage commitment to Question 25(b) below will generally score more favorably.
- Question 27 has been revised to include additional sub-questions related to the Applicant’s community accountability and involvement.
- Updates to various definitions in the NMTC Program Application Glossary, including the definition of Disadvantaged Businesses.
- Additional revisions were made to clarify instructions and streamline the information collected.
NEW FAQs
The CDFI Fund made several notable additions to the Application FAQ.
On our first read through the FAQ, here are the most notable changes:
- Award Cap? The CDFI Fund advises that while there is no cap on award requests, the they do not envision awarding more than $120 million (#FAQ 23)
- Q17 (Pipeline): Revisions to information requested in Q17. CDEs must provide a percentage of their pipeline investments going to different business types. The CDFI Fund also includes instructions urging CDEs to avoid “duplicating information provided in Table A5.” There are other significant updates to the instructions for Q17. Please read the FAQ.
- Infrastructure: Affirmation that NMTC financing can go to broadband and infrastructure-related activities (FAQ #55)
- Mixed-use: A revised definition of mixed-use (FAQ #54).
- Due Diligence: Updated instructions on how Q18 will be scored (FAQ #57).
- Underserved States: Arizona, California, Colorado, Connecticut, Florida, Kansas, North Carolina, Texas, Virginia, and West Virginia.
- NMTC Native Areas: Can be identified in CIMS4.
- Updates on 85% QLICI Commitments in Q25A: The new areas introduced in Q25b (Deep Distress, etc) automatically count as part of any commitments made in 25a.
- Commercial Goods and Services: A lengthy revision of the definition of commercial goods and services to LIC residents was added in FAQ #92.
- Benefit to LIPs/Residents of a LIC: New examples were provided to outline how the CDFI Fund would like CDEs to describe community outcomes (FAQ #93 and FAQ #99).
- Transaction Costs vs Applicant fees: New descriptions of how transaction costs differ from applicant fees and operating expenses (FAQ #115).
- Question 34(c)/Table D3: A warning added that states that “Any ambiguity between the responses to Question 34(c), Table D2, and Table D3 could negatively impact the CDFI Fund’s evaluation of the Allocation Application.”
- Consultant Fees: Clarification on inclusion of consultant fees and QALICB fees (FAQ #117) along with a warning that the CDFI Fund will be comparing proposed fee structures for consistency with the updated NMTC TLR guidance’s data fields on fees (FAQ #118).
- Investor letters: Clarification on when Investor Letters are needed (FAQ #127).
- Read the FAQ
