CUNA Regulatory Comment Call

June 12, 2008

Burden of CDFI Program Certification Application

EXECUTIVE SUMMARY

Please feel free to fax your responses to CUNA at 202-638-7052; e-mail them to Senior Vice President and Deputy General Counsel Mary Dunn at mdunn@cuna.coop; or mail them to Mary in c/o CUNA's Regulatory Advocacy Department, 601 Pennsylvania Avenue, NW, South Building, Suite 600, Washington, DC 20004-2601. You may also contact us at 800-356-9655, ext. 6732, if you have questions or would like a copy of the proposed rule. You may also access a copy of the proposed rule here.

BRIEF DESCRIPTION OF THE CURRENT APPLICATION

The objective of the CDFI Program is to promote economic stimulation and community development through investment in certified CDFIs. “Through the CDFI Program, the CDFI Fund makes financial investments in and provides technical assistance grants to CDFIs and organizations seeking CDFI certification that have comprehensive business plans for creating demonstrable community development impact through the deployment of capital within their respective target markets for community development finance purposes.” An entity must complete an application with the CDFI Fund in order to be certified as a CDFI.

The CDFI Fund is simply soliciting comments on the application for certification/re-certification for institutions, at this time no changes to the application form or process are being proposed. The estimated average burden associated with this collection of information is 37.5 hours per applicant. Comments are requested regarding this burden estimate and suggestions for reducing the burden. Click here to view the current CDFI Certification Application.

QUESTIONS TO CONSIDER REGARDING THE PROPOSED CHANGES

  1. Is the collection of information necessary for the proper performance of the functions of the CDFI Fund? Will the information have practical utility?
















  2. The CDFI Fund estimates the annual burden per respondent to be 37.5 hours. Is this an accurate estimate?
















  3. How can the quality, utility, and clarity of the information collected be enhanced?
















  4. How can the burden of the collection of information on respondents be minimized? Would somehow incorporating the use of technology into the process help?
















  5. Please provide estimates of capital or start-up costs and costs of operation, maintenance, and purchase of services to provide information.
















  6. Any other comments regarding the burden of the application?
















Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
Mary Mitchell Dunn • SVP & Deputy General Counsel • (202) 508-6736 • mdunn@cuna.com
Jeffrey Bloch • Assistant General Counsel • (202) 508-6732 • jbloch@cuna.com
Lilly Thomas • Assistant General Counsel • (202) 508-6733 • lthomas@cuna.com
Luke Martone • Senior Regulatory Counsel • (202) 508-6743 • lmartone@cuna.com