CUNA Regulatory Comment Call
August 15, 2003
Treasury Proposal to Measure CDFI Performance
(NOT A MAJOR RULE)
- The Department of Treasury's Community Development Financial Institutions (CDFI) Fund is requesting public comment on the indicators it will use to measure a CDFI's performance in community development impact, financial strength, portfolio quality, and management.
- The CDFI Fund's mission is to expand the capacity of financial institutions, including credit unions, to provide credit, capital, and financial services to underserved populations and communities in the United States.
- Each CDFI will be scored in the following four components, which will then be aggregated in a single PLUM rating:
- Performance effectiveness, such as community development impact;
- Leverage, liquidity and solvency;
- Underwriting; and
- The Fund plans to use the PLUM rating to monitor the Fund's portfolio of CDFI awardees, recognize and communicate best practices for community development finance, underwrite CDFIs, and target the Fund's technical resources to CDFIs that need to improve their performance. The PLUM rating system will assess a CDFI's performance relative to that of its peers
- The rule provides information on how to send comments directly to the Department of Treasury, which are due by October 10, 2003. You may also submit comments to CUNA. Please feel free to fax your responses to CUNA at 202-638-7052; e-mail them to Associate General Counsel Mary Dunn at email@example.com and to Assistant General Counsel Jeff Bloch at firstname.lastname@example.org; or mail them to Mary and Jeff in c/o CUNAs Regulatory Advocacy Department, 601 Pennsylvania Avenue, NW, South Building, Suite 600, Washington, DC 20004-2601. Click here for a copy of the rule, if you are viewing this from the CUNA website, or contact Jeff if you would like a copy sent to you.
Eric Richard General Counsel (202) 508-6742 email@example.com |
Mary Mitchell Dunn SVP & Associate General Counsel (202) 508-6736 firstname.lastname@example.org
Jeffrey Bloch Assistant General Counsel (202) 508-6732 email@example.com
Catherine Orr Senior Regulatory Counsel (202) 508-6743 firstname.lastname@example.org