The CDFI Briefing
Policy and Legislative Updates for Credit Unions in 2026
September 2, 2026
Latest Update:
Congress Passes Continuing Resolution to Fund the Federal Government and CDFI Fund Through December 11
Congress has passed a Continuing Resolution (CR) that will keep the federal government funded through December 11, moving the next funding past the mid-term elections and removing the immediate threat of another government shutdown.
The House approved the Senate-passed measure September 1 by a 370-48 vote. It now goes to President Trump, whose administration has already said it supports the measure and would recommend that he sign it.
For the CDFI Fund, the CR generally continues FY 2026 funding levels and conditions during that period while Congress works toward final FY 2027 appropriations. The CDFI Fund received $324 million for FY 2026, so the CR essentially keeps the Fund operating at that funding rate through December 11. It does not, however, fully establish a final $324 million appropriation for FY 2027.
The legislation also temporarily blocks an OMB proposal that could have significantly changed how federal grants are awarded. That proposed rule would give senior political appointees a greater role in reviewing discretionary grants and require funding decisions to align with administration priorities. This is a detail that has met with significant pushback from many groups that do not want political appointees determining the “winners and losers” of Congressionally appropriated federal grant programs. Section 157 of the CR prevents OMB from issuing or finalizing that rule, or a substantially similar rule, through December 11.
That provision is notable given the scrutiny OMB has received over its role in federal grantmaking this year. The Senate passed the CR 90-6, and Senate Appropriations Committee Chair Susan Collins specifically cited concerns that the proposed OMB rule could politicize the grantmaking process. For CDFIs, it provides at least a temporary check on a proposed change that could have given political appointees significantly more influence over federal award decisions.
The CR also contains this provision:
SEC. 108. Appropriations made and funds made available by or authority granted pursuant to this Act may be used without regard to the time limitations for submission and approval of apportionments set forth in section 1513 of title 31, United States Code, but nothing in this Act may be construed to waive any other provision of law governing the apportionment of funds.
In plain English, section 108 says funding provided through the CR can still be apportioned and used even if those normal timing deadlines are no longer workable because of the timing of the CR. It does not eliminate the requirement for apportionment or the other laws governing how federal funds are made available.
CU Strategic Planning will be working with credit unions to keep pressure on the administration, particularly Treasury Secretary Bessent, from lawmakers and particularly appropriators to complete the funding of CDFI’s FY 2025 FA/TA grants before September 30, 2026, the end of this fiscal year for the federal government.
We will continue watching this closely and will be in touch directly with our 2025 Financial Assistance applicants who are still awaiting award decisions.
August 28, 2026:
America’s Credit Unions Urges New CDFI Fund Director to Address Funding and Certification Priorities
America’s Credit Unions’ August 26 letter to new CDFI Fund Director Chris Miller outlined several requested priorities for the Fund, including the release of already-appropriated funding and changes intended to address the decline in certified credit union CDFIs.
Written by James Akin, ACU’s Head of Regulatory Advocacy, it takes a thorough and straightforward approach. Akin is firm about the problems facing the CDFI Fund and credit unions, while also offering specific, tangible steps the new director could take to address them.
Among its priorities, ACU asks the CDFI Fund to:
Announce and obligate the remaining FY 2025 CDFI Fund awards before the funding expires September 30.
Work with the Office of Management and Budget to secure the timely apportionment and release of FY 2026 funding.
Support at least $324 million in funding for the CDFI Fund in FY 2027, matching the FY 2026 enacted level.
Address the decline in the number of certified credit union CDFIs.
The funding requests reinforce issues we’ve covered in previous CDFI Briefing updates, including delays in FY 2025 awards and the status of FY 2026 appropriations.
Akin also focuses on certification challenges facing credit unions. He points to Federal Reserve Bank of New York data showing that the number of certified CDFI credit unions fell from 519 in 2023 to 445 in 2025, while assets held by CDFI credit unions declined by approximately $18 billion.
This is an issue CU Strategic Planning has been discussing with America’s Credit Unions in recent months, sharing what we are seeing as credit unions work through the new certification and recertification requirements and where those requirements are creating unnecessary barriers.
Among the changes ACU proposes are greater flexibility in the recertification process and changes to Target Market methodology. Akin points out those changes would reduce the cost and burden of maintaining certification without limiting the Fund’s ability to verify that CDFIs are directing their lending to their designated Target Markets. Credit unions are a major part of the CDFI industry, accounting for approximately 62% of all CDFI assets as of the second quarter of 2025. That makes the decline in certified credit unions a significant issue for the CDFI field as a whole.
For Miller, who is taking over after more than a year of interim leadership, ACU has provided a practical agenda: move already-appropriated funding, maintain strong support for the Fund, and address certification requirements that are making it harder for some credit unions to remain certified.
August 25, 2026:
Treasury Names Chris Miller as New CDFI Fund Director
The U.S. Department of the Treasury announced August 25 that Chris Miller has been named Director of the CDFI Fund. Miller described himself in the announcement as a presidential appointee, although the position does not require Senate confirmation. He becomes the Fund’s first non-acting director in more than 13 months following the July 2025 resignation of Pravina Raghavan. Dietrich Douglas and, later, Alexandria Smith have served as Acting Director during the interim
Miller comes to the Fund with direct CDFI industry experience. Since 2016, he has been with Three Roots Capital, a certified CDFI loan fund based in Knoxville, Tennessee, most recently serving as Chief Financial Officer. He also previously managed a $150 million commercial loan portfolio focused on small and middle-market businesses.
In announcing his appointment, Miller said he looks forward to working with the CDFI Fund’s staff, the industry and other stakeholders to expand access to capital and create economic opportunity. Treasury did not provide details about his immediate priorities or what the leadership change could mean for the timing of pending Fund business. Even so, putting a director with hands-on CDFI experience in place after more than a year of interim leadership is a positive development for the Fund and the industry it serves.
August 14, 2026:
Lawsuit Seeks to Protect CDFI Fund Awards Ahead of September 30 Deadline
CAMEO Network and Inclusive Action for the City filed a federal lawsuit August 14 seeking to prevent FY 2025 CDFI Fund appropriations from expiring before they can be awarded. The lawsuit names the Treasury Department, CDFI Fund and Office of Management and Budget, along with Treasury Secretary Scott Bessent, Acting CDFI Fund Director Alexandria Smith and OMB Director Russell Vought.
The plaintiffs argue that Treasury and OMB have unlawfully delayed the use of $289 million in FY 2025 funding Congress appropriated for CDFI Fund programs, which expire September 30. The lawsuit asks the court to require the Administration to take the steps necessary to obligate FY 2025 awards before that date and also challenges OMB’s handling of FY 2026 CDFI Fund appropriations.
The lawsuit comes while FY 2025 CDFI Program awards remain pending. As we reported April 9, OMB apportioned the $289 million in FY 2025 program funding, making it available to Treasury. The funds have not yet been obligated, and because the appropriation expires September 30, the plaintiffs are asking the court to require Treasury to act before that deadline.
There have already been public indications that Treasury intends to distribute the funding before it expires. During a June 3 Senate Finance Committee hearing, Sen. Mark Warner pressed Treasury Secretary Scott Bessent on the outstanding CDFI funding. Bessent responded Treasury was “getting that funding out.” Politico later reported that Bessent had assured Congress the money would be distributed before its September 30 expiration.
That is consistent with the information we’ve been receiving that the remaining funds from the FY 2025 appropriation (Including the 2025 FA and remaining TA awards) are expected to be obligated before the end of September. As we noted in our June 29 briefing, The Fund’s NOFA for the FY 2026 SDL round (which is being funded with FY 2025 appropriations) states that it anticipates announcing SDL awards before September 30, although it reserves the right to change that date.
For credit unions waiting on FY 2025 CDFI Program awards or that recently applied for an SDL award, we don’t see the filing of this lawsuit itself as a signal that those awards will not be made. The lawsuit is intended to ensure the funds cannot simply expire if Treasury does not act before the September 30 deadline, while Treasury has separately indicated that it intends to get the funding out before then.
August 13, 2026
AMIS Update Abandons Some In-Progress CDFI Certification Applications, Sets August 19 Deadline for Others
The CDFI Fund notified organizations with in-progress CDFI Certification Applications on August 12 that it is updating the Certification Application in its Awards Management Information System (AMIS) and, as part of that change, is clearing out unsubmitted applications that were opened before August 11.
Applicants whose applications were less than 50% complete were notified that their applications had been moved to “Abandoned” status and that they will need to start a new application in AMIS if they still want to pursue certification. Those that the Fund identified as having completed more than 50% were given until 11:59 p.m. ET on August 19 to finish and submit their existing applications. Any of those applications not submitted by the deadline will also be moved to Abandoned status.
The short notice was unexpected. The CDFI Fund said the change is part of an update intended to improve the user experience in AMIS, but the August 12 notice gives applicants with substantial work already underway only one week to complete their applications. The Fund also cautioned applicants to make sure attached materials, including financial statements and Target Market activity, still meet any applicable date requirements.
Credit unions that are handling their own CDFI Certification applications should check their email and AMIS account immediately to determine whether their application has been abandoned or whether they received the August 19 submission deadline.
CU Strategic Planning CDFI Certification clients can rest assured we’re taking care of this issue and will either be submitting or re-starting their applications as appropriate.
August 10, 2026:
CDFI Fund Eases Target Market Rules for Rural Investment Areas
The CDFI Fund has eased the way lending activity is counted in certain rural Target Markets, potentially making CDFI Certification easier to achieve or maintain for some institutions serving non-metro communities.
First, a quick refresher on Customized Investment Areas.
A Customized Investment Area (CIA) is a Target Market geography created by combining contiguous qualified and non-qualified geographic areas, with more than 85% of the area’s population residing in geographic units that meet the CDFI Fund’s economic-distress criteria. Non-metro CIAs can be created using either contiguous census tracts or contiguous non-Metro counties or parishes.
That 85% requirement determines whether the geography itself qualifies as a CIA. The new policy doesn’t change it. What has changed is how much of a CDFI’s activity must occur specifically within the qualified portions of a non-metro CIA.
Effective August 6, 2026, a CDFI using a non-metro Customized Investment Area—whether made up of census tracts or non-metro counties or parishes—must direct at least 60% of its eligible activity within that geography to individually qualified census tracts. Once it reaches that threshold, eligible activity in the non-qualified portions of the same approved geography can also count toward the CDFI’s overall Target Market benchmark. Previously, that activity threshold was 75%, and it had been scheduled to increase to 85% in October 2027.
Put simply:
85% of the population must be in qualified areas to create the non-metro CIA.
60% of the CDFI’s eligible activity within that non-metro CIA must occur in qualified census tracts for activity throughout the entire CIA to count toward its Target Market benchmark.
This change applies specifically to non-metro CIAs. Other Customized Investment Areas remain subject to the 85% activity threshold.
For many credit unions, however, the practical impact of this change may be limited. In our experience, relatively few credit unions have service areas that lend themselves to an entirely non-metro CIA Target Market. Many institutions serving rural communities also serve metro areas, making other Target Market configurations more appropriate.
Still, the change could provide useful flexibility for credit unions whose Target Markets are predominantly rural. An institution serving a largely distressed rural geography may still make some loans in census tracts that don’t qualify individually. Under the new rule, those loans can count once the credit union meets the 60% activity threshold within the qualified tracts.
The new policy applies immediately. New certification applicants must use the revised threshold, while currently certified CDFIs with these Target Markets will be evaluated under it the next time they submit their Annual Certification and Data Collection Report.
August 4, 2026:
U.S. Appeals Court Blocks GGRF Clawback, Treasury Narrows Title VI Standard, and House Passes Main Street Capital Access Act
Appeals Court Blocks EPA from Clawing Back GGRF Funds
The full U.S. Court of Appeals for the District of Columbia Circuit ruled Tuesday that the Environmental Protection Agency cannot terminate and claw back roughly $20 billion in grants awarded through the Greenhouse Gas Reduction Fund. The court upheld an April 2025 preliminary injunction that prevents EPA from taking back funds already placed in grant recipients’ accounts.
Six judges concluded that EPA’s attempt to end the grants based solely on a policy disagreement likely violated the law that created and funded the program. The decision reverses a September ruling by a smaller panel of the same court that had sided with EPA.
The ruling is especially relevant to CDFIs and credit unions because the Greenhouse Gas Reduction Fund was designed to move clean-energy financing through community lenders. That includes the Clean Communities Investment Accelerator, under which Inclusiv received a $1.87 billion award to provide funding and technical assistance through credit unions.
While this stops the termination of the grants and clawback of funds, access to the awarded funds won’t resume immediately. The court is allowing time for EPA to seek review by the U.S. Supreme Court, and questions remain about how the grants will be administered following the 2025 repeal of the law that created the program. Still, the ruling is a significant step toward protecting funds that had already been awarded and disbursed.
Treasury Narrows Title VI Standard for CDFI Fund Applicants
The U.S. Department of the Treasury published a final rule August 3 narrowing how it enforces Title VI of the Civil Rights Act for recipients of federal financial assistance.
Under the revised rule, Treasury will focus on intentional discrimination. A policy or practice will no longer be considered a Title VI violation solely because it produces different outcomes based on race, color or national origin. Statistical disparities may still be considered as evidence, but they will not establish a violation on their own.
For CDFIs, the most direct connection is the Title VI Compliance Worksheet required annually for applicants to several CDFI Fund award programs. The worksheet is tied directly to Treasury’s Title VI regulations and currently asks about civil rights complaints, public notices, language assistance, subrecipient oversight and the composition of certain boards or advisory groups.
The CDFI Fund has not announced any changes to the worksheet or its instructions, and applicants should continue completing it as required. However, because the underlying regulatory standard has changed, Treasury and the CDFI Fund may revise how some questions are written or evaluated.
This is a foundational change rather than an immediate reporting change. It could shape future CDFI Fund guidance, compliance reviews and updates to the Title VI Compliance Worksheet. We’ll continue watching for additional direction.
House Passes Main Street Capital Access Act
The House passed the Main Street Capital Access Act, H.R. 6955, on July 21 by a vote of 270-155-1. The bill includes two provisions directly related to CDFIs.
The CDFI Fund Transparency Act would provide for annual congressional testimony on the Fund’s operations, its support for CDFIs and efforts to streamline certification and reporting requirements. The bill would also extend the CDFI Bond Guarantee Program through December 31, 2028, and lower its minimum guarantee from $100 million to $25 million, potentially making the program more accessible to smaller CDFIs. The House-passed legislation retains the program’s $1 billion annual limit on guarantees.
The bill was received by the Senate and referred to the Senate Banking Committee on July 22.
July 15, 2026:
CU Strategic Planning and DCUC Advocate for Revision of Five-Year CDFI Recertification Requirement
The five-year recertification requirement in the revised CDFI Certification Agreements has received little public attention or discussion, but is an area of concern that CDFI advocates would like to see addressed. This provision would require certified CDFIs to submit a full new certification application every five years, even when they remain in good standing and continue to meet annual reporting requirements.
To address this, CU Strategic Planning sent a letter July 13 to Acting CDFI Fund Director Alexandra Smith urging Treasury to reconsider the policy. The Defense Credit Union Council followed on July 14 with a letter to Treasury Secretary Scott Bessent asking that the requirement be suspended and withdrawn. Both letters make the same central point: the Fund already has extensive reporting and oversight tools to determine whether institutions continue to meet certification requirements.
CDFIs are already subject to annual certification reporting, transaction-level reporting, audits, compliance reviews and other ongoing oversight. The Fund also has the authority to investigate and terminate institutions that no longer meet certification requirements. Requiring every compliant CDFI to start the certification process again would repeat much of that work while adding significant costs and staff time.
The effect on processing times is also a concern, as DCUC’s letter pointed out. The Fund is still working through the current recertification cycle under its revised standards, with many credit unions waiting months for decisions. We have also seen some credit unions choose not to pursue recertification because the revised application process and regulatory burden had become too demanding, even though their commitment to serving underserved communities had not changed. Making full recertification a permanent five-year requirement could create recurring backlogs and continued uncertainty for certified institutions.
“The CDFI Fund already has ways to identify and address institutions that no longer meet certification requirements,” CU Strategic Planning President Stacy Augustine said. “Requiring every CDFI to complete a full recertification every five years would add another layer of administrative work without meaningfully strengthening oversight. The time and resources required for that process would be better spent on what Congress created CDFIs to do: expand responsible lending, invest in underserved communities and create lasting economic opportunity.
“We’ll continue advocating for CDFI credit unions so they can focus on the important work of serving the people and communities that need them most. We’ve seen many changes from the CDFI Fund in the past five years, and we know how much can change in the next five.”
We are asking the Fund to rely on annual reporting and targeted oversight, reserving full recertification for institutions with significant organizational changes, compliance concerns or other demonstrated reasons to reassess eligibility.
July 09, 2026:
CU Strategic Planning Submits Comments on Proposed Federal Grant Rules
CU Strategic Planning has submitted formal comments on a proposed OMB rule that would overhaul Title 2 of the Code of Federal Regulation, the government-wide framework governing how federal grants are administered. You can read the full comment letter here.
The proposal has drawn a large public response. As of this morning, 98,973 comments had been submitted, reflecting concern across many sectors that rely on federal grant dollars, not just CDFIs. Senate Appropriations Committee Chair Susan Collins asked OMB on July 6 to extend the comment period by at least 90 days.
Our letter, written by President Stacy Augustine, supports OMB's stated goals of accountability and responsible stewardship of taxpayer resources, but raises concerns about several provisions that would make federal grant administration less predictable for CDFI credit unions:
Fixed amount awards. The proposal would move toward a reimbursement-based accounting model, eliminating fixed amount awards unless specifically authorized by statute. That would add administrative burden, particularly for awards supporting loan loss reserves, without improving oversight.
Undefined standards for review and termination. Terms like "federal agency priorities" and "the national interest" would govern senior political review and termination authority without defining them or tying them to statutory authority. The letter asks OMB to define these terms clearly so that grant administration doesn't shift with each change in administration.
Converting guidance into binding regulation. The letter recommends OMB preserve the Uniform Guidance as guidance rather than binding regulation, preserving agency flexibility to administer programs suited to their own statutory purposes.
Implementation timeline. The proposal would apply to FY 2027 awards on a relatively short timeline. The letter asks for more time for agencies to update systems and communicate new requirements to recipients.
One provision drew support: retaining reasonable earnings on federal funds under Section 200.307, which the letter calls a sensible reduction in administrative burden.
Overall, the letter's core message is that grant administration works best when it stays predictable and closely tied to what Congress actually authorized, as that stability matters for CDFI credit unions trying to build multi-year lending and capital plans around these awards with confidence. That concern is echoed by the wide range of federal grant recipients who have weighed in during this comment period.
June 30, 2026:
CDFIs Remain in the Congressional Conversation
At today’s House Appropriations Financial Services and General Government Subcommittee oversight hearing with OMB Director Russell Vought, Rep. Ashley Hinson (R-Iowa) used part of her questioning to focus on Community Development Financial Institutions.
Hinson described CDFIs as specialized lenders that play a vital role in revitalizing and growing local economies, pointing to examples such as first-time homebuyer down payment assistance and payday alternative loan programs. She also noted Treasury Secretary Scott Bessent’s support for the role CDFIs play in underserved communities.
Vought acknowledged broad congressional support for the CDFI Fund and said OMB is working to implement the funding Congress has provided. He also reiterated the administration’s concerns about some uses of CDFI Fund dollars and said OMB is trying to ensure funds are spent appropriately. CU Strategic Planning submitted a letter to the subcommittee ahead of today's meeting.
For CDFIs and credit unions, the exchange was notable because Congress is still pressing OMB and Treasury on the timing of CDFI Fund dollars. Even amid continued scrutiny, the discussion was not about whether CDFIs matter. It was about how funds will move, how programs will be reviewed and how Congress can help ensure appropriated dollars are disbursed as intended.
We’re also watching the FY 2026 CDFI Program Financial Assistance and Technical Assistance funding closely. The fact that FY 2026 FA/TA appears on the apportionment list for disbursement in 2027 is a positive signal, though it should not be read as a NOFA, award announcement or firm timeline.
June 29, 2026:
FY 2026 Small Dollar Loan Program NOFA Announced
The CDFI Fund has announced it will open three FY 2026 funding rounds tomorrow, and of interest to credit unions is the Notice of Funding Availability for its the Small Dollar Loan Program. Also to be published tomorrow are notices related to the CDFI Bond Guarantee Program and the Bank Enterprise Award Program, but neither is relevant to CDFI credit unions.
The FY 2026 SDL Program makes an estimated $9 million available to help Certified CDFIs establish or expand affordable small dollar consumer loan programs. The program provides grants for Loan Loss Reserves, Technical Assistance, or a combination of both.
The application window is short, with applications due by July 30; this isn’t surprising given that the applications will have to be processed and awards announced before the government’s September 30 fiscal year-end in order to take advantage of remaining FY2025 funds.
For credit unions already working with CU Strategic Planning on SDL applications, we have core application materials ready and will move into finalization once the CDFI Fund releases the application instructions. We’re unable to take any more clients for 2026 SDL Program applications.
The timing of these NOFAs is notable. These are the first CDFI Fund funding opportunity notices since OMB released the remaining $289 million in FY 2025 funding that was appropriated for CDFI Fund grant programs in April.
The 2025 CDFI Program Financial Assistance awards and remaining Technical Assistance awards are still pending. We’re hopeful that today’s announcement means we’ll be seeing the 2025 FA/TA announcements soon, followed by the FY 2026 FA/TA NOFA. We will continue watching closely and will update credit unions as more information becomes available.
June 17, 2026
Updated CDFI Fund List Shows Drop in Certified CDFIs
The CDFI Fund has posted an updated list of Certified CDFIs for the first time since January, with 38 organizations added and 168 removed from the prior list. Credit unions saw the steepest decline; according to our review, 88 credit union CDFIs were removed and five were added.
This latest list, dated June 10, reflects only the applications the CDFI Fund has been able to review to date, with reviews still being conducted on a rolling basis. These include the revised applications from currently certified CDFIs that were required to reapply under the certification policy changes that took effect in December 2023.
The new list provides the first clearer look at the roster of certified CDFIs since January, but shouldn’t be read as the final result of the recertification process. Among our own recertifying credit unions, just over 10% have received notice from the CDFI Fund on their applications so far.
Based on what we’re seeing, many of the removals likely reflect institutions that either did not pursue recertification or could not complete the revised application process because their loan data did not support certification under the updated standards. As always, CDFIs must show that at least 60% of their loans, by both number and dollar amount, are directed to their approved Target Market.
The decline in the number of certified credit unions is larger than expected compared with other CDFI entity types. The updated standards may affect different types of CDFIs differently, depending in part on their lending portfolios. Nonprofit loan funds often have more concentrated lending activity to discrete populations or geographies, while credit unions often have more diversified portfolios, including home and small business lending. A credit union often meets the benchmark by number of loans but falls short by dollar amount if some of its larger loans are outside its approved Target Market. For example, the credit union may serve an area where low to moderate income members can’t easily afford the average home available on the market, driving the average income on these loans higher (in other words, only higher income members can afford to buy a home in the credit union’s market).
The CDFI Fund’s list will continue to change as application reviews are completed. For credit unions that were able to document the updated Target Market benchmarks and submit their revised applications, the June 10 list should not be read as an indication that their pending applications have been denied or are at risk.
June 10, 2026:
Recertification Approvals Begin to Arrive for CDFIs; Amendment Added to Existing Agreements
After roughly eight months of waiting, credit union CDFIs are beginning to receive answers on their recertification applications. Over the past week, a handful of CU Strategic Planning's recertification clients have received conditional notices of approval — a tangible sign that the CDFI Fund is working through its queue. These approvals are conditional at this point as the final Certification Agreements have not yet been made available for the CDFI’s signature; it’s unclear when those will be posted in AMIS accounts. The wait for those agreements is tied at least in part to a change in their contents.
One of the reasons behind the delay in processing certifications was Treasury’s decision to add a new provision to the certification agreement for CDFIs, as suggested in the Treasury April 9 press release.
The CDFI Fund announced in February that CDFIs that had been certified under the new application would be receiving amended agreements. The revised agreements contain a short addition: section 5.17(b), which brings CDFI Fund policy into alignment with the current administration’s policies concerning discrimination. All current CDFIs that have applied for recertification and grant recipients will presumably also receive agreements that contain this new section.
What do credit unions need to know about this addition?
Credit unions are required to comply with laws such as the Equal Credit Opportunity Act, the Home Mortgage Disclosure Act, and the Fair Housing Act. As a result, every CDFI credit union will already have controls in place that ensure fair lending, including policies against discrimination as part of an effective compliance management system.
Credit unions are also required to comply with laws against discrimination in employment such as Title VII of the Civil Rights Act. A credit union will also have policies in place ensuring that it does not discriminate on the basis of sex or race as part of its employment policies. There are narrow exceptions to discrimination in employment standards to address the effects of past discrimination or promote diversity through affirmative action programs. These programs would be inconsistent with the administration’s standards, even though they are permitted by law.
The bottom line
While the language of this new provision didn't appear in the certification application itself, it shouldn’t cause alarm for most. Unless your credit union has an employment-based affirmative action program in place, you should already have the fair lending and employment controls and policies in place that comply with new section 5.17(b) of the certification agreement.
May 28, 2026:
OMB Proposes Overhaul of Federal Grant Rules
A significant proposed rule published in the Federal Register May 29 is likely to make some noticeable changes for federal grant recipients, including CDFIs. The Office of Management and Budget has proposed a comprehensive revision to Title 2 of the Code of Federal Regulations, which governs how federal grants are administered government-wide. The proposed rule would cover 42 federal entities that include cabinet departments, independent agencies, and regulatory bodies — including both Treasury (hence the CDFI Fund) and the National Credit Union Administration. The proposal has a 45-day comment period.
The proposal has three stated objectives: tighten oversight and accountability, formalize OMB's authority over grant rules, and reduce administrative burden on recipients. The structural change behind the second goal is significant: the existing "Uniform Guidance," currently classified as guidance rather than regulation, would be formally redesignated as the "Uniform Grants Regulation." That shift would allow future OMB changes to take effect government-wide on OMB's own timeline, without requiring each participating federal entity to go through its own separate rulemaking.
The proposal's stated intent to reduce burden is a worthy one. However, the prerelease version of the proposed regulation is 412 pages and contains noticeably partisan language, particularly in the preamble that makes up roughly the first quarter of the document. And within the regulation are several provisions that appear to create new confusion or work against that goal in practice. CU Strategic Planning will be submitting comments on areas that affect CDFI credit unions.
This proposal also lands while the CDFI industry is still watching for the separate rulemaking Treasury Secretary Scott Bessent announced on April 9, which referenced the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 and promised additional reforms around anti-discrimination compliance for certified CDFIs. The OMB proposal covers some of the same ground, including provisions restricting the use of grant funds based on race, sex, or sexual identity. But the specific statutory language from Treasury's April 9 announcement doesn't appear here, leaving open the question of whether a separate Treasury rule is still on the way.
OMB's goal is for the new rules to apply to federal awards made in fiscal year 2027, which begins October 1, 2026. We will continue to track how this proposal develops and what it means specifically for CDFI Fund program structures as the comment period unfolds.
May 26, 2026:
2025 CDFI Fund Awards Remain Pending as Program Reviews Continue
Bloomberg Law reported today that the Consumer Financial Protection Bureau is investigating several CDFI loan funds. According to the report, the CFPB has sent “supervisory questionnaires” to at least four certified CDFI loan funds that had not previously been subject to CFPB supervision. At this point, it is not clear whether the CFPB activity is connected to Treasury’s late-April announcement that it had begun reviewing certified CDFIs for potential legal or program violations.
Program accountability is important to the long-term strength of the CDFI field. CDFI certification is intended to identify institutions that are serving eligible Target Markets and meeting program requirements. Institutions engaged in fraudulent, abusive or corrupt lending practices should not be able to obtain or maintain that certification. Effective oversight helps protect the communities the program is designed to serve, as well as the reputation of CDFIs that are meeting the rules and doing the work responsibly.
At the same time, the review is unfolding while key CDFI Fund decisions remain unresolved. The CFPB is currently led by acting chief Russell Vought, who also serves as director of the Office of Management and Budget. OMB has played a more visible role in the CDFI Fund’s appropriations story this year, including the April 2026 release of $289 million in remaining FY 2025 CDFI Fund appropriations after months of advocacy from CDFI industry groups and congressional supporters.
Even with those funds released, final FY 2025 CDFI Program Financial Assistance awards and remaining Technical Assistance awards have not yet been publicly announced. A partial list of 56 TA award recipients was announced in September 2025. The CDFI Fund’s Small Dollar Loan Program and Bank Enterprise Award Program are even more up in the air, with the most recent NOFAs for both programs occurring in FY 2024.
For CDFI credit unions, the key point is that accountability and timely funding both matter. “Protecting the integrity of CDFI certification and ensuring federal resources are used appropriately is critical,” explained CU Strategic Planning president Stacy Augustine. “So is making sure that the CDFIs committed to serving their communities responsibly have access to Congressionally allocated funds. If the CFPB’s housekeeping will help free up the funds for the good actors, let's get the broom out and get it taken care of.”
April 29, 2026:
Department of Treasury Review of CDFIs: What Credit Unions Should Know
Treasury recently announced that it is initiating a review of certified Community Development Financial Institutions (CDFIs) to assess compliance with program requirements and identify any potential legal or regulatory violations.
The review appears to relate to a CDFI loan fund, certified in 2019 under the Trump Administration, which Treasury Secretary Scott Bessent accused of fraudulent auto lending and retail practices; it’s now bankrupt with its leaders indicted for fraud. Advocates of the new certification standards had mentioned this fund, along with several others, as of concern at least as far back as 2022.
As regulated financial institutions, credit unions operate within established supervisory frameworks with ongoing oversight, reporting requirements, and governance standards that are designed to ensure accountability and responsible service to members.
Ensuring that bad actors are not able to obtain or maintain CDFI certification is important for the long-term strength and reputation of the program and the institutions holding the CDFI certification. Credit unions, as CDFIs, are responsible for meeting the rules of certification, including making 60% of the number and dollar to their CDFI Fund approved target markets of low income targeted populations (LITP) and loans made inside of CDFI Fund approved investment area (IA) census tracts. Credit union CDFIs meet those requirements while also meeting the lending needs of their entire communities.
As Bessent was quoted in the release, “CDFIs play a critical role in expanding access to capital in underserved communities,” and Treasury remains “committed to enforcing the law and protecting taxpayer resources while supporting the mission of responsible CDFIs.” The House FSGG Appropriations subcommittee recently approved $274 million for FY 2027, and the Senate Appropriations process is also underway. Full funding of the CDFI Fund is anticipated.
April 23, 2026:
FY 2027 CDFI Fund Funding Moves Ahead in House and Senate
The full House Appropriations Committee voted 34-28 yesterday to approve the Financial Services and General Government (FSGG) appropriations bill, including $276 million for the CDFI Fund for FY 2027. That outcome was expected after the subcommittee advanced the bill and keeps the House process moving along a path that looks very similar to last year’s cycle. The next step is House floor consideration as a stand-alone bill or as part of a larger appropriations package.
The House also again declined to follow the Administration’s funding approach. Rather than adopting the White House’s push for a much smaller rural-focused proposal, House appropriators kept the broader CDFI Fund number in place. That is another sign Congress is not simply accepting the Administration’s vision for the program.
The Senate is showing a similar pattern. Treasury Secretary Scott Bessent testified before the Senate FSGG Appropriations Subcommittee, where Senator Chris Coons pushed back on the Administration’s proposed cuts to the CDFI Fund. Coons described the fund as a proven, bipartisan tool for supporting affordable housing in both rural and urban communities and directly challenged the idea that this kind of funding reflects a partisan agenda.
Bessent responded by suggesting the proposal came from OMB and said he supports the new $100 million rural program. But the broader takeaway from the exchange was clear: just as the House is moving beyond the Administration’s request, the Senate also appears likely to do the same.
At this stage, FY 2027 funding is moving in a way that should feel familiar. The House has advanced its opening number, the process is moving normally, and both chambers appear prepared to take a more expansive approach than the Administration proposed.
April 17, 2026:
House Appropriations Subcommittee Passes Bill Funding CDFI Fund at $276M for FY 2027
The House Financial Services appropriations subcommittee voted today to advance its appropriations bill, including funding for the CDFI Fund at $276 million, the same level at which the House began the FY 2026 process.
That opening House number is not unusual. In recent years, the House has often started with a lower allocation than the Senate, with the final enacted appropriation ultimately landing higher after negotiations. In FY 2026, the final appropriation for the CDFI Fund was $324 million.
Today’s vote moves the bill to consideration by the full Appropriations Committee, which could take action on the legislation in the next few weeks. The bill will be assigned a number later today.
The subcommittee also did not adopt the Administration’s recommendation to reduce funding for the CDFI Fund.
Yesterday, OMB Director Russell Vought was hammered by Senators of both parties on his efforts to illegally hold up funding of many agencies on FY 2025 funds. Senator Mark Warner of Virginia, co-chair of the Community Development Caucus, specifically pressed Vought on CDFI Fund dollars that were finally released last week.
All of this action has meant CDFI Fund is returning to fully funded and more fully functioning as Congress asserts more control over the CDFI Fund appropriations.
April 15, 2026:
Senators Urge $324 Million for CDFI Fund in FY 2027
Sens. Mike Crapo (R-Idaho), Mark Warner (D-Virginia), and Steve Daines (R-Montana) are leading a bipartisan Senate push for strong FY 2027 support for the CDFI Fund, urging appropriators to provide no less than $324 million and to require the Fund to establish a clear schedule for publishing applications and making awards. In their April 15 letter, the senators argue that the CDFI Fund remains one of the federal government’s most effective community development tools, citing its ability to leverage private investment and support business growth, affordable housing, and essential community facilities in underserved areas. The letter included signatures from 43 senators in total. Of those, 35 are Democrats, 6 are Republicans, and 2 are independents that caucus with the Democrats.
The letter also mentions a familiar concern: FY 2025 awards still have not been announced. However, there is at least movement in that area. An OpenOMB posting shows an OMB-approved April 8, 2026 apportionment file for the Treasury’s Community Development Financial Institution Fund Program Account, which suggests the funding has at least cleared an important administrative step before the Fund announces the remaining FY2025 awards.
April 10, 2026:
Treasury Press Release Announces New CDFI Regulation Regarding Who May Benefit from CDFI Awards
A Treasury press release issued April 9 offers more context on the long-awaited movement of FY 2025 CDFI Fund dollars. The Office of Management and Budget (OMB) is in the process of releasing $289 million in FY 2025 funding for CDFI Fund grant programs.
Treasury’s announcement indicates that, alongside the release of those funds, it plans to issue rules concerning the treatment of certain CDFI Fund awards under the Personal Responsibility and Work Opportunity Reconciliation Act of 1996, or PRWORA. Treasury said the goal is to clarify that certain benefits funded through these awards are federal public benefits and therefore may not be provided to people who are not qualified under federal law, such as those without legal immigration status. The release quotes Secretary of the Treasury Scott Bessent as saying, “Under President Trump’s leadership, we are enforcing the law and preventing the abuse and misuse of CDFI Fund grants intended solely for American citizens and lawful residents.”
Credit union CDFIs working with CU Strategic Planning were not surprised by Treasury’s notice of rulemaking. We worked with our FY 2025 applicants to develop strategies that anticipated these administration initiatives, and once applicants that advanced in the process were given an opportunity to update their applications last fall (that deadline was later extended to April 10, 2026), we again reviewed and made adjustments to ensure that all applications matched the changing priorities and guidelines from the Fund. Three quarters of the grant applications we wrote for our clients advanced to this final round.
Credit unions, as highly regulated financial institutions and employers, have always abided by fair labor laws and regulations, so the new regulation from Treasury requiring certified CDFIs to comply with federal anti-discrimination laws and maintain policies and procedures add no new federal requirements. CU Strategic Planning expects these requirements will be included in CDFI certification/recertification agreements as well as grant award agreements.
In September 2025 the CDFI Fund committed to significantly restricting Other Targeted population as a qualified Target Market, as first showed in the amendment to the 2025 FA award. The OTP Target market has focused on race and ethnicity. The OTP Target Market is an agency interpretation and not statutory or regulatory, so these changes can occur without an official comment period.
The release reflected the two step dance between OMB and Treasury behind the delay in the release of the FY 2025 funds. The administration sought to ensure Treasury had regulations in place to enact its priorities that federal dollars not benefit immigrant communities without legal documentation to release those funds. CU Strategic Planning calls on the CDFI Fund to award FY 2025 applicants expeditiously and for them to proceed with the release of the NOFA to begin the delayed FY 2026 award cycle. Congress has already begun its process for FY 2027 CDFI funding and is expected to fully fund the CDFI Fund in spite of the administration’s 2027 budget request.
“Given the anticipated changes, it remains important for the CDFI credit union community to seek guidance as they navigate the evolving requirements and processes related to CDFI certification and funding opportunities. CU Strategic Planning’s experience and track record provide the best opportunity to obtain and retain CDFI certification and to win award dollars under the fully funded CDFI Fund programs,” concluded CU Strategic Planning President Stacy Augustine.
April 9, 2026:
Long Awaited FY 2025 Funds Expected for CDFIs Soon
CU Strategic Planning has confirmed that the government’s Office of Management and Budget (OMB) is in the process of releasing $289m of FY 2025 monies for CDFI Fund grant programs. The details are not completely clear as to exact timing of the release and how quickly this release will lead to the awarding of grant dollars to FY 2025 FA/TA applicants.
CDFI funds are appropriated for a two year period, which is fortunate since many other Congressionally approved funds expired last September at the end of the government's fiscal year. This gives the CDFI Fund until the end of September 2026 to distribute the FY25 appropriated funds.
We will update further as more information becomes available.
April 3, 2026
Notices of Award Noncompliance Sent to Recently Terminated CDFIs
The CDFI Fund has begun issuing notices of noncompliance to CDFIs that are still in the performance or reporting periods for CDFI Awards but lost certification after failing to submit recertification applications last year.
Institutions can cure the noncompliance by submitting a new certification application by May 1 or requesting additional time by April 10. Doing so places them in a cure period, suspending the noncompliance until at least August 1.
What This Means
Most affected institutions likely skipped recertification because they could not meet the updated standards. The cure period provides a narrow window to reapply using 2025 lending data instead of 2024 figures. For some, that shift alone may be enough to regain compliance.
Others will have a more difficult path—particularly those that remain below the required threshold of 60% of loans by number and 60% of loans by dollar volume to their Target Market, or that are not prepared to reapply quickly.
The notices do not clarify how much additional time may be granted. There is no indication that extensions would be long enough to incorporate 2026 lending data.
Risk of Sanctions
The notices cite standard assistance agreement language allowing the CDFI Fund to require repayment of award funds. In practice, that outcome appears unlikely. Based on our experience across hundreds of awards, we have seen occasional noncompliance notices but no instances of credit unions that we work with being required to return funds.
Historically, the CDFI Fund’s focus has been on ensuring funds are deployed to consumers and communities in need—not clawed back. Given how many institutions are struggling under the revised certification requirements, some flexibility is likely.
We are working directly with a number of credit unions that received notices and are advocating on their behalf. While repayment risk appears low based on past precedent, noncompliance should still be treated as a serious issue.
April 3, 2026:
Trump Releases 2027 Budget Request, Includes Proposed Cuts to CDFI Fund
President Trump has presented his 2027 budget request for the next fiscal year beginning in October, and, just as in past years of this and his previous administration, it includes significant cuts to the CDFI Fund. This year’s request also contains similar language to 2026’s request in its description of the CDFI Fund, claiming that Fund awards were “abused to advance a partisan agenda under prior administrations.” Despite that claim, the final passed FY2026 budget remained at the $324 million level seen for the last several years, a result of unwavering support in Congress.
The President’s budget request was prepared by White House Office of Management and Budget chief Russ Vought and shows huge increases to 2027 defense spending accompanied by huge cuts to domestic programs in the budget request. Also similar to last year is the "Cuts to Woke Programs” document accompanying the budget request. The section covering the CDFI Fund appears virtually identical to what was in last year’s version.
While this couldn’t be called good news, it’s not a surprise nor even a cause for concern. The President has attempted to zero out the CDFI Fund’s budget in every budget of both of his terms to this point. Both houses of Congress, on both sides of the aisle, have responded every year by continuing to fund what they and their constituents know is a valuable program that advances opportunity in communities across this country.
We at CU Strategic Planning have already started discussions with Congressional appropriators and the Senate Community Development Caucus, and will be fighting our way back to normal FY 2027 spending levels for CDFI in the months to come.
March 19, 2026:
CDFI Groups Urge Release of More Than $1B in Available Funding
A group of national CDFI and community lending associations is urging the White House to release more than $1 billion in already-approved funding to support affordable housing.
The request was outlined in a March 19 letter to National Economic Council (NEC) Director Kevin Hassett. The NEC is a White House agency that advises the president on economic policy and helps coordinate policy across federal agencies.
The letter follows several recent federal actions focused on housing supply, including updates to the Low-Income Housing Tax Credit through the One Big Beautiful Bill Act (OBBBA), Senate passage of the bipartisan 21st Century ROAD to Housing Act, and a new executive order aimed at reducing regulatory barriers to construction.
At the same time, the organizations point out that more than $1 billion in funding is already available but has not yet been put to work. This includes FY2025 and FY2026 funding for the CDFI Fund, Capital Magnet Fund dollars, and remaining Emergency Capital Investment Program (ECIP) funds.
They estimate that releasing these funds could support the construction or preservation of about 100,000 affordable homes. For CDFIs, including credit unions, this kind of funding is often what makes deals possible, especially in communities where traditional financing is limited.
More broadly, the letter highlights a familiar issue: new policies can help, but getting existing funds out the door is one of the fastest ways to increase housing supply. For credit unions engaged in CDFI work, movement on these funds would create more opportunities to support housing development in their communities.
March 10, 2026:
New Deadline Set for FY 2025 CDFI and NACA Program Application Updates
For the first time since September 2025, the CDFI Fund has posted information about the FY 2025 FA and TA Awards. The notice stated that the deadline for FY 2025 application updates is now April 10, 2026.
The Fund previously published amendments to the FY 2025 Notice of Funding Availability (NOFA) on September 25, explaining that the changes were intended to “promote consistency with recent court decisions regarding race-based preferences and reflect the current Administration’s priorities, as reflected in the President’s executive orders.” This was about six months after the original FY 2025 FA and TA application deadline.
Applicants that had reached Step 4 in the scoring and evaluation process were given the opportunity to update their applications by October 27. However, the process was cut short by the fall government shutdown, and applicants have not been able to submit updates since that time.
This update from the Fund is a positive sign that award operations are beginning to move forward again, as well as a hopeful sign that the NOFA for the FY 2026 FA and TA round will be coming soon. CU Strategic Planning has submitted requests to update our clients’ 2025 FA applications in AMIS, the Fund’s awards management system, and has updated files ready to submit.
February 27, 2026:
Bipartisan AFFORD Act Will Strengthen CDFI Fund
The bipartisan Advancing Financial Opportunities through Revitalizing and Developing CDFIs (AFFORD) Act was introduced this week by Senators Steve Daines (R-MT) and Mark Warner (D-VA), along with 28 additional Senate co-sponsors.
The legislation incorporates elements from several previously introduced bills, and of significant importance to CDFI credit unions is the CDFI Fund Transparency Act (S. 2704), which requires the Secretary of the Treasury to testify annually before the Senate Banking and House Financial Services Committees on CDFI Fund operations. This would create opportunities for more conversations on how the program is operating and to develop ways for it to accomplish even more with the funds it has be appropriated.
We at CU Strategic planning have long encouraged Congress to be aware of the regulatory burdens being created by the CDFI recertification process that create an environment where credit union lose or walk away from the CDFI certification.
As CDFIs are aware, the current requirement is to make 60% of the number of loans and 60% of the dollar amount of loans to their Target Market area. But as things stand, particularly in the current economy, it’s very possible for a CDFI credit union to lend more than 70% of the total number of loans to its target market of Low-Income Targeted Populations and Investment Areas and still not qualify as a CDFI because of the dollar-size of loans to a minority of members who are not in that Target Market.
This transparency requirement and the larger AFFORD act as a whole, is a sign of the important role CDFIs play in America's economy. That bipartisan action in these times must be seen for the way CDFIs bring rural, and urban, Republican and Democrats from across the political spectrum.
February 5, 2026:
CDFI Fund Questions Emerge During Treasury’s House Appearance
Treasury Secretary Scott Bessent appeared before the House Financial Services Committee this week to deliver the annual Financial Stability Oversight Council report, where he faced pointed questions from Rep. Joyce Beatty (D-Ohio) regarding the delayed release of FY 2025 CDFI Fund program awards. In a somewhat testy exchange, Secretary Bessent declined to give a yes-or-no answer on timing.
CU Strategic Planning President Stacy Augustine noted, “Because of Secretary Bessent’s on-the-record support for the CDFI Fund, I’m disappointed that he didn’t use this opportunity to gracefully extricate himself from a heated exchange by simply indicating that appropriated funds would be deployed as soon as they were actually received by Treasury from OMB.”
Many CDFI advocates understand the delay in FY 2025 CDFI Fund awards to stem from the Office of Management and Budget’s failure to apportion congressionally appropriated funds, which must occur before Treasury can move forward. We continue to view Secretary Bessent as a supporter of the CDFI Fund and remain hopeful that OMB will soon release the allocated funds.
February 4, 2026:
Second Shutdown Ends: CDFI Fund Secured for the Year
Yesterday saw the House’s passage and President’s signature of the funding bill that cements funding for 95% of the government through September. This includes the CDFI Fund’s $324 million budget for 2026.
Advocates for the CDFI Fund worked tirelessly throughout 2025 to ensure that the Congress’s historical bipartisan support for the Fund remained strong. As a result, the Fund’s 2026 budget is secure at a level similar to the previous several years. This paves the way for continued appropriations success in 2027.
CDFI credit union leaders were part of that advocacy, such as Southwest Louisiana Credit Union’s CEO Chad Miller. “Over the last several months, Southwest Louisiana CU has worked closely with CU Strategic Planning on sharing the story of small CDFIs like ours to our legislators and I strongly believe that this partnership played a key role in ensuring the future of the Fund.”
The credit union has branches in House Speaker Mike Johnson’s district, and Miller explained, “we were able to talk with several key regional offices of our members legislators, including Speaker Mike Johnson’s office, to share the direct impact that CDFI funds have on low-to-moderate income constituents and small businesses in rural Louisiana.”
Other CDFI credit union leaders expressed their reaction to the bill’s passage as well, with New Orleans Firemen’s FCU CEO Judy DeLucca stating, “We are very pleased that Congress has fully funded the CDFI Fund for 2026. This critical support allows us to continue doing the important work of serving people who deserve access to fair and affordable financial services, and it represents a meaningful win for small credit unions across the country. This is exactly the outcome we hoped for.”
While $334 million is a small portion of the roughly $1.2 trillion bill that is now secure, it means a great deal to the nearly 1,400 certified CDFIs nationwide, roughly a third of which are credit unions. The CDFI Fund is much like the institutions it certifies: relatively small in scale, but capable of delivering outsized impact. In 2024 alone, CDFIs collectively deployed over $24 billion dollars in financing to underserved communities, supporting small businesses, affordable housing, and consumer financial stability in places traditional capital often does not reach. The continued funding of the CDFI Fund ensures that this model can keep working where it’s needed most.
January 29, 2026:
Current Appropriations Standoff Presents No Threat to CDFI Funding
Discussions in the Senate this afternoon are focused on separating Homeland Security funding from the broader FY 2026 spending package in order to move the remaining appropriations bills forward.
The bill containing DHS funding is the sole point of contention, and if the Senate votes on the remaining five bills, they are expected to pass. This includes the Financial Services and General Government (FSGG) appropriations bill, which contains the CDFI Fund’s $324 million budget. If the Senate passes this smaller package as expected, it will need to return to the House for another vote, even though the House is not scheduled to return to session until Monday night.
The good news to keep in mind is that funding for the CDFI Fund is effectively settled at this point. The $324 million figure in the Senate bill keeps the agency on a normal funding track for FY 2026 and helps set up a stable funding outlook heading into FY 2027 and beyond.
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