The CDFI Briefing
- Mike Beall, CUDE, Chief Experience Officer
- 3 days ago
- 35 min read
Policy and Legislative Updates for Credit Unions
November 24, 2025
Latest Update:
Senate’s $324M CDFI Budget Proposal Boosts Funding by $50M Over House Plan
The Senate Appropriations Committee has released its draft of the FY 2026 Financial Services and General Government (FSGG) appropriations bill, proposing $324 million for the Community Development Financial Institutions (CDFI) Fund. The draft, which has not yet gone to markup, allocates at least $188 million for Financial Assistance and Technical Assistance awards, $28 million for Native American initiatives, and $9 million for the Small Dollar Loan Program.
This Senate draft builds on the already-released House proposal, which funded the CDFI Fund at $274 million. With the Senate recommending a level consistent with FY 2025 funding, the outlook is positive for the Fund, its programs, and its capacity — and for credit unions preparing FA/TA applications or pursuing CDFI Certification.
For credit unions, this means planning for the next funding cycle can continue confidently. We see no signs of unusual restrictions, structural changes, or disruptions to core CDFI Fund programs. The bill and accompanying report also recommend that Treasury “take into consideration the unique conditions, challenges, and scale of non-metropolitan and rural areas,” and emphasize increased targeted investment in persistent-poverty counties — aligning with existing CDFI program priorities and the Administration’s stated interest in expanding support for rural CDFIs.
The appropriations process is far from complete, as this Senate draft moves into markup and both chambers work toward reconciliation. But the direction is clear: FY 2026 is shaping up to be a healthy year for CDFIs. We’ll keep you informed as the bill advances.
November 13:
Shutdown’s End Brings Relief for CDFI Fund
Late Wednesday, President Trump signed legislation ending the longest federal government shutdown in U.S. history, shortly after the United States House of Representatives approved the funding measure.
The agreement funds the government through January 30, 2026, includes three full-year appropriations bills (for the Departments of Agriculture, Veterans Affairs, military construction, and Congress), reverses more than 4,000 federal layoffs that took effect in early October, and prohibits additional layoffs through the end of January.
Critically for the Community Development Financial Institution community, that layoff reversal restores the staffing at the CDFI Fund that was disrupted by recent reductions-in-force. With those positions reinstated, pending grant processing, certification workflows, and oversight activities at the CDFI Fund will be able to continue.
In short, the wheels are turning again at the Fund. With federal employees returning to their jobs and the staffing and funding stability restored, 2026 and beyond look more secure for CDFI-certified credit unions and applicants working toward certification.
November 10, 2025
Senate Advances Deal That Could Reopen Government and Restore CDFI Fund Staffing
Late last night, the U.S. Senate took a decisive step to end the government shutdown, voting 60–40 to advance an amended continuing resolution (CR) that funds the government through January 30, 2026. The bill restores stability at the CDFI Fund, reversing the recent reductions-in-force and barring further layoffs through the duration of the CR — a key move that allows staff to resume critical work on pending programs like Financial Assistance awards and processing of certification and recertification applications.
House Speaker Mike Johnson has now called Representatives back to Washington “as quickly as possible” to take up the Senate’s version, with the goal of completing action this week and reopening the government.
One of the main sticking points in negotiations had been the expiration of certain health care tax credits. Under a separate agreement with Republican leadership, the Senate will vote on Affordable Health Care credits by the second week of December. Another issue, the expiration of expanded SNAP benefits, is addressed in the Agriculture title of the agreement, which extends those benefits as part of the broader deal.
What this means for CDFIs: The end of the shutdown reverses the firing of CDFI Fund and Treasury staff, ensuring the Fund is once again fully staffed and funded at prior levels through January 30, 2026. This is encouraging news for a strong, stable CDFI Fund heading into FY 2026 and beyond — setting the stage for consistent, reliable CDFI funding over the next three years of the administration.
October 28, 2025
Democrats Add Support to Preserve CDFI Fund; Judge Indefinitely Blocks Layoffs
Following last week’s letter from Republican lawmakers defending the CDFI Fund, more than 120 Democratic Senators and Representatives have sent their own appeal to Treasury Secretary Scott Bessent and Office of Management and Budget Director Russell Vought.
Led by Representatives Maxine Waters (D-CA) and Bill Foster (D-IL), the October 27 letter expresses “deep concern at the attempt by the Trump Administration to unilaterally terminate all of the Treasury Department’s Community Development Financial Institutions Fund (CDFI Fund) staff as it pursues illegal ‘reductions in force’ during the government shutdown.” The lawmakers emphasized that “for more than 30 years, across Republican and Democratic Administrations, the CDFI Fund has been a bipartisan success” and warned that dismantling its operations “could mean a decades-long recovery for impacted communities.”
This means that in the span of less than a week, over 40% of all of Congress has signed statements of support of the CDFI Fund.
In addition, the temporary injunction halting the administration’s plan to lay off approximately 4,000 federal employees, including the entire CDFI Fund staff, has been extended indefinitely. The ruling found the proposed action likely exceeded executive authority.
Together, these congressional and judicial responses underscore the deep bipartisan commitment to the CDFI Fund’s mission, and affirm continued national support for the Fund’s role in expanding access to affordable capital and sustaining community growth across the country.
October 23:
More than 100 Republican Lawmakers Urge Administration to Reinstate CDFI Fund Staff
A bicameral letter was sent today to Treasury Secretary Scott Bessent and Office of Management and Budget Director Russell Vought, signed by more than one hundred Republican Senators and Representatives. Led by Senator Mike Crapo (R-ID) and Representative Young Kim (R-CA), the lawmakers requested the administration reverse its decision to terminate the staff of the Community Development Financial Institutions (CDFI) Fund.
In the letter, the signers emphasized that CDFIs play an important role in supporting economic development in rural and underserved communities, stating, “we strongly urge the Administration to continue carrying out the statutory obligations of the CDFI Fund that are essential to ensuring private investments reach our states and districts.”
The letter follows the administration’s October 10 Reduction in Force (RIF) notices permanently laying off the CDFI Fund’s staff, citing that the Fund and its programs “do not align with the President’s priorities.” The lawmakers’ action underscores that the CDFI Fund is far from a “Democrat program” as had been implied in the RIFs, and highlights that the Fund continues to have strong support within the majority party.
This renewed congressional backing reinforces the essential role CDFIs play in expanding access to affordable financial services for underserved Americans.
October 15:
Federal Court Temporarily Blocks Government Layoffs
Judge Susan Illston of the US district court’s northern district in California granted a temporary injunction of two weeks today against the reductions in force (RIFs) that were issued on October 10th, as well as blocking new layoffs for the time being. This is in response to a lawsuit filed by the American Federation of Government Employees, a union representing federal employees.
In her ruling, the judge said that she believed the administration had taken advantage of the lapse in government spending to “assume that all bets are off, that the laws don’t apply to them anymore, and that they can impose the structures that they like on the government situation that they don’t like, and I find, I believe, that the plaintiffs will demonstrate, ultimately, that what’s being done here is both illegal and is in excess of authority and is arbitrary and capricious.”
The hearing comes on the same day that Office of Management and Budget (OMB) Director Russell Vought said that more layoffs were coming, and that the RIFs could end up over 10,000 in number.
Criticism of Friday’s CDFI Fund staff layoffs has been bipartisan, with two senior Republican senators, Senate Community Development Finance Caucus co-chair Mike Crapo of Idaho and Senator Mike Rounds of South Dakota making public statements in support of the CDFI Fund on Tuesday.
October 10:
All CDFI Fund Staff Receive Layoff Notices Amid Ongoing Federal Government Shutdown
The entire staff of the U.S. Department of the Treasury’s Community Development Financial Institutions (CDFI) Fund received reduction-in-force (RIF) notices today. The terminations are to take effect December 13, 2025.
This appears to be part of the Trump administration’s effort to pressure Congress to reach a funding agreement. While previous shutdowns have included targeted furloughs, the scope of this action is highly unusual. One Hill source said that Treasury is expected to issue between 1,400 and 1,500 RIF notices agency-wide; CDFI staff numbered around 100 at the end of 2024.
The Office of Management and Budget has indicated that some staff may be re-hired once a budget resolution is passed, but no guarantees have been given. The blanket nature of the layoffs has raised concern among CDFI stakeholders about the continuity of critical programs.
“The termination date gives the administration time to reverse course—but right now, there’s no clarity on what staff, if any, will return, or when,” said CU Strategic Planning President Stacy Augustine. “The message being sent is political, but the consequences for community development are real.”
CDFIs across the country rely on the Fund for capital, but it’s Congress that relies on the Fund for oversight—ensuring that federally appropriated dollars are appropriately spent. In addition to the fact that Treasury Secretary Bessent has asserted all CDFI Fund programs are statutorily authorized, there remain hundreds of millions of dollars in awarded funds that are currently being overseen by Fund employees. Staff are required in order to meet federal reporting obligations.
More information is expected in the coming weeks as negotiations over the federal budget continue; we will continue to update as we learn more.
September 30:
Partial List of TA Award Recipients Announced
The CDFI Fund announced today that 56 organizations will be receiving Technical Assistance (TA) awards, from both the CDFI Program and NACA (Native American CDFI Assistance) Programs. While these awards are part of the FY2025 Program Awards, the $8.8 million awarded comes from previously appropriated funds that expire at the end of the day today.
The Fund included in the announcement that it expects to award additional TA Awards later this winter, using funds from the $324 million appropriated for FY2025-FY2026. These funds cannot be awarded by the Fund currently because they have not yet been released by the Office of Management & Budget. As a comparison, in 2022 the CDFI Fund awarded $25.2 million in 218 total TA awards for both the CDFI and NACA Programs.
September 30:
What a Government Shutdown Would Mean for CDFI Credit Unions
As agencies prepare for a possible government shutdown starting Wednesday, the CDFI Fund is among the groups informed by the Office of Management and Budget (OMB) to “consider Reduction in Force (RIF) notices” in addition to traditional furloughs. The message is aimed at employees in programs, projects, or activities funded by discretionary appropriations.
However, as has been asserted by Treasury Secretary Scott Bessent, The CDFI Fund and its programs are statutorily authorized and Congress appropriated FY25 funds for these programs, making them non-discretionary. In addition, the Fund’s amended notice for the FY2025 Financial Assistance Program was issued in consultation with the OMB.
While the shutdown may cause a postponement of the Oct. 27 deadline for application revisions based on that amended notice, there has been no word from the Fund about how this may affect the announcement of FY2025 awards.
September 25:
CDFI Fund Issues Amendment to Program Award Notice, Applicants Given Opportunity to Update Application
The CDFI Fund sent notice on Wednesday of an Amendment to the FY2025 CDFI Program Notice of Funds Availability (NOFA) for the Financial Assistance (FA) and Technical Assistance (TA) awards — more than eight months after the application was first released.
The Fund described the reasoning for the amendment as “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.”
Applicants for FA awards received emails from the CDFI Fund. Those that did not reach “Step 4” in the evaluation process were informed they would not be receiving a 2025 award. Those that are still in consideration for the award were told they had an opportunity to “reopen and update their Applications based on the amendments described in these notices.” It's unclear at this point if the amendment will have any effect on the evaluation of TA applications.
The amendment and the communications from the CDFI Fund state that while applicants have the opportunity to make updates to their applications in response to the amendment, it is not required.
The changes in the NOFA include the removal of climate-focused financing as an eligible activity for an award, and a change in the definition of Eligible Market, with the removal of non-Native ethnic and racial groups. Applicants will have until October 27 to submit updated applications, which will receive final review under the amended rules.
CU Strategic Planning is reviewing our credit unions’ FA applications and will be revising those that will be affected by these amendments.
September 19:
Recertifying CDFIs Able to Request Extension Ahead of September 30 Deadline
The Community Development Financial Institutions Fund (CDFI Fund) announced this week that CDFIs in “Window 2” with a recertification application deadline of September 30, 2025, are now able to file a request for extension if desired. CDFIs in Window 2 include all organizations with a fiscal year-end of December 31, February 28, or March 31.
The CDFI Fund stated that all extension requests must be submitted through its Awards Management Information System (AMIS) as a service request, and extension requests are due by 5:00 EDT on Tuesday, September 23.
The Fund had previously stated that “no additional grace period or extension will be provided to CDFIs that fail to submit their Application by the revised deadline.” In addition, the cut-off for application-related Service Requests and Help Desk questions for Window 2 applicants was September 12. For this reason, it’s expected that most Window 2 applications have already been submitted.
It’s still unknown how long these recertification applications will take to process. The total number of certified CDFIs has remained roughly the same since shortly before the first recertification application window closed on May 31, with 1376 total certified CDFIs as of September 11.
August 29:
OMB Creates Confusion on Congressional Appropriations (Including CDFI Fund), CUSP Requests Bessent Intervene
In a letter sent Friday, August 29, CU Strategic Planning asked Treasury Secretary Scott Bessent “to intervene with the Office of Management and Budget (OMB) to clarify that all programs at CDFI Fund have the full funding appropriated by law by Congress for FY 2025.” The letter is copied to Senators Mike Crapo (R-Idaho) and Mark Warner (D-Virginia) who lead the powerful Community Development Finance Caucus (CDFC) which includes 28 members of the United States Senate.
On July 29, 2025, Crapo and Warner, along with 24 other bipartisan senators, wrote to OMB Directors Russell Vogt “we urge you to swiftly obligate all discretionary funding provided by Congress to the CDFI Fund in a timely manner.” The letter specifically references the “the Full-Year Continuing Appropriations and Extensions Act of 2025 that appropriated $324 million for the CDFI Fund and prescribed those funds to support over 1,400 CDFIs in rural and urban communities.”
Bessent’ strongly worded statement from March 19, 2025, “This Administration recognizes the important role that the CDFI Fund and CDFIs play in expanding access to capital and providing technical assistance to communities across the United States. CDFIs are a key component of President Trump's commitment to supporting Main Street America in the pursuit of job growth, wealth creation, and prosperity,” came with bedrock clarification that the programs of the CDFI Fund are based in law.
March 20, 2025, was the deadline for CDFI’s to submit applications for the FY2025 FA/TA (Financial Assistance and Technical Assistance) for funding by the CDFI Fund. Those awards are generally announced in mid-September and are due soon. Annual CDFI Fund appropriations are able to be spent across the government’s fiscal year end, meaning that the 2025 funds will still be available into 2026.
OMB is under pressure to release funds across a plethora of government agencies that were properly appropriated by law by Congress which holds the “power of the purse” under clear Constitutional authority.
CU Strategic Planning urges “a clear and lasting solution to the appropriations challenge” especially in light of the House of Representatives sub-committee of Financial Services and General Governance (FSGG) earlier action in the summer to appropriate $274 million to CDFI Fund for FY 2026, and with the full House Appropriations Committee due to mark up the FSGG and other appropriations bills in the normal FY 2026 appropriations process as early as September 5, 2025. The letter further notes the work of the Defense Council of Credit Unions to secure support for CDFI Fund amendments to the FY 2026 National Defense Authorization Act (NDAA). There is clear and decisive Congressional support for these CDFI Fund appropriations.
August 19:
Recertification Deadline for CDFIs Approaches
The recertification deadline is approaching for most CDFIs. The CDFI Fund sent a reminder last week that organizations who fall under “Window 2,” which includes all CDFIs with a fiscal year-end of 12/31, are required to submit their applications by September 30.
The September 30 deadline will be familiar to all who are in the process of preparing their recertification applications. What may be a surprise, however, is that the Fund has stated that it is implementing a cut-off for application-related Service Requests and Help Desk questions. CDFIs must get all application-related questions in by Friday, September 12.
CU Strategic Planning is currently finishing the final stages of recertification applications for our credit unions. We will be submitting them in the next several weeks. Credit unions must close any outstanding items for recertification applications immediately.
It’s unknown how long the Fund will take to process these CDFI recertification applications. The first of three recertification windows closed May 31, 2025; as of August 12, there are 1375 total Certified CDFIs, down from 1440 in April.
July 22:
$276.6 Million for CDFIs Approved During Markup
The proposed $276.6 million for CDFIs in the FY 26 Financial Services and General Government (FSGG) Bill was approved during the July 21 subcommittee markup session.
July 21:
House Appropriations Bill includes $276.6 Million for CDFIs
The House Appropriations Committee released the draft Fiscal Year 2026 bill for the Financial Services and General Government Subcommittee on Sunday, July 20.
Included in this bill is an allocation of $276.6 million for the Community Development Financial Institutions (CDFI) Fund, which includes “not less than” $170 million for Assistance award programs (FA and TA). Also included is $3.42 million for NCUA’s Community Development Revolving Loan Fund, the sources for NCUA’s grant program for credit unions.
The bill will be considered in subcommittee today, July 21st, with markup session live-streamed at 5:30 EDT.
CU Strategic Planning, in a letter to FSGG Appropriations Subcommittee Chair Dave Joyce (R-OH) and Ranking Member Steny Hoyer (D-MD) urged the committee to provide:
Full funding for the CDFI Fund in FY 2026 of $330 million. The CDFI Fund is an important tool for the U.S Treasury to build economic success in every state, and
Fully fund each CDFI Program. Following the Treasury Secretary’s assessment that all are grounded in law as required by the President’s Executive Order that call for that review, CDFI credit unions look forward to working with Treasury on core programs such as the Financial Assistance, Technical Assistance, and Small Dollar Loan programs with full funding in FY 2026. These programs return as investments in all states in rural, suburban and urban areas.
The figure of $276 million is a significant figure for the CDFI fund for its programs. at this point. It’s down from last year’s $324 million and below the budget allocation advocated by CDFI industry groups, but in context it’s above the allocations for 2020 at $260m.
July 21:
Dietrich Douglas Named Acting Director of CDFI Fund
The Community Development Financial Institutions Fund announced July 21 that Dietrich Douglas has been named Acting Director, following Director Pravina Raghavan's resignation in late June.
Acting Director Douglas has served as the CDFI Fund's Legal Counsel since January 2023. Prior to joining the CDFI Fund, Director Douglas served as Branch Chief within the U.S. Department of Health and Human Services’ Medicare Operations Division and as Program Counsel with the Legal Services Corporation, performing grant oversight and program guidance to federally funded legal-aid organizations that serve low-income individuals.
July 9:
Raghavan Resigns as CDFI Fund Director
CU Strategic Planning has been informed by sources at the US Department of Treasury that CDFI Fund Director Pavina Raghavan resigned her position on June 25, effective June 27, 2025. Treasury has not publicly announced this information. We will continue to update with more details as they become available.
July 9:
Update on Greenhouse Gas Reduction Fund (GGRF)
A lawsuit, new recission legislation passes, and a power struggle.
The Trump Administration managed to eke out a slim win to pass its recission package (big, beautiful bill) with a 51-50 tie break vote in the Senate and a 218-214 vote in the House. The legislation rescinds obligated dollars totaling just $19 million in administrative expenses from 2025 related to the Greenhouse Gas Reduction Fund but not the $9 billion obligated by the previous Biden administration before the end of FY 2024.
The difference at this moment is the fact that the $9 billion awarded and obligated to hubs like Inclusiv and Climate Justice Fund are obligated. The Trump administration is working recission legislation to undo monies obligated to USAID, NPR and CPB but is not finding the process to be easy to get through Congress.
Associated Press reporting indicates “U.S. District Judge Tanya Chutkan has previously said that when the federal government was asked for evidence of fraud, the agency didn’t provide it and shifted its position. Chutkan decided the government can’t terminate the contracts and that the groups should have access to some of their frozen money. The EPA sought relief from the US Court of Appeals and received an administrative stay April 18th, 2025. Litigation would be expected to proceed on the merits at the trial court level in the future.
June 11:
Senate Appropriations Subcommittee Hearing on 2026 Budget Today
The Senate Appropriations Subcommittee on Financial Services & General Government (FSGG) is holding a hearing today to review the President’s FY 2026 budget request for the Department of the Treasury. Treasury Secretary Scott Bessent is testifying on key proposals, addressing administration concerns over deep cuts to the Community Development Financial Institutions (CDFI) Fund and the broader impact of the Treasury’s budget priorities. CU Strategic Planning has submitted a letter in support of maintaining full funding for the CDFI Fund, calling for $330 million to be allocated in the FY2026 budget.
May 29:
CU Strategic Planning's Letter to the CDFI Fund on Qualified Opportunity Zones
CU Strategic Planning President Stacy Augustine sent a letter today to CDFI Fund Director Pravina Rhagavan related to the new Qualified Opportunity Zone (QOZ) incentives included in the recently passed House tax bill. The letter concerns how QOZs may be best incorporated into future Financial Assistance (FA) Award applications, in order to allow applicants to better address mitigation of possible gentrification of QOZs as well as other impacts such as the creation of new jobs, increases in property value and reduction in crime.
May 13:
Congressional Republicans Reiterate Support for CDFI Fund Budget
As reported in Politico Pro, several Republicans in both the House and Senate have spoken out against President Trump’s proposed cuts to the CDFI Fund budget for awards, which they see as a valuable resource for small business lending. Sen. Mike Rounds (R-S.D.), Sen. Thom Tillis (R-N.C.), and Rep. Troy Downing (R-Mont.) all expressed to Politico that they supported maintaining funding for CDFIs.
Despite the president’s accusations of the CDFI Fund promoting a “woke” agenda, it has long received bipartisan support from Congress. CDFIs are found in 92% of all Congressional voting districts, with Republicans representing eight of the ten districts receiving the largest CDFI investments.
May 2:
Trump Releases 2026 Budget Request, Includes Proposed Cuts to CDFI Fund
President Trump unveiled his Fiscal 2026 budget proposal on May 2nd, with extensive cuts in nondefense discretionary spending. This “skinny budget” is largely symbolic, but important as it outlines the president’s priorities.
The CDFI Fund is mentioned in two areas of the budget document; the first recommends the appropriation of $100 million to create a new Rural Financial Award Program, which is described as being administered by the CDFI Fund and available to CDFIs working within rural areas. The second is a recommended decrease of $291 million (from $324 million in 2025) to what is labeled as “CDFI Fund Discretionary Awards.” The description describes the reduction as intended to essentially eliminate most CDFI Fund awards, with the remaining $33 million going to closing out prior awards, maintaining certification, and support for the New Markets Tax Credit administration and Bond Guarantee program.
Accompanying Trump’s budget is a document called "Cuts to Woke Programs” that calls out the CDFI Fund as being “abused to advance a partisan agenda,” despite the Fund receiving ongoing bipartisan support throughout its 30-year history.
This budget stands at odds with what Treasury Secretary Bessent has been communicating since the March 14 Executive Order first targeted the CDFI Fund. More importantly, it is also at odds with the support already shown by many members of Congress on both sides of the aisle as shown with a swiftly produced letter of support from the heads of the Senate Community Finance Caucus and signed by 23 Senators.. Congressional appropriators will now spend the next months creating and debating the appropriations bills that will become law, with a goal of adopting a budget for 2026 before the end of the federal government’s year end on September 30, 2025 (a goal they have not been very successful at achieving in recent years).
Congress is responsible for establishing a federal budget each year. As such, the President’s budget proposal is just that—a non-binding proposal. Nevertheless, CDFI and credit union trade associations are already doubling down on on-going efforts to educate key committee members on the value and critical role that CDFIs serve in providing capital to underserved communities to help ensure that the final budget developed and passed by Congress includes full funding for the CDFI Fund.
April 22:
Waters and Foster Head Letter to Bessent Urging Reversal of Executive Order Targeting CDFI Fund
Showing that the security of the Community Development Financial Institutions (CDFI) Fund remains a concern despite Treasury Secretary Bessent’s statements of support, House Financial Services Committee Ranking Member Maxine Waters, Financial Institutions Subcommittee Ranking Member Bill Foster and 86 other Democratic members of Congress urged Secretary Bessent in an April 21 letter to go farther to protect the CDFI Fund from the March 14 Executive Order aimed at cutting federal programs deemed "unnecessary."
Water’s letter directly addresses the possibility of a recission bill that would claw back funds already appropriated. Earlier this week President Trump indicated his interest in sending a budget recission bill to Congress cutting $10B in funds already approved. While this recission would be more likely to target organizations such as USAID, PBS and NPR, Water’s letter addresses the fact that the CDFI Fund was mentioned in one of the President’s Executive Orders alongside these organizations.
The lawmakers’ letter strongly rebukes any characterization of the CDFI Fund as dispensable, calling the move not only misguided but dangerous. It praises Secretary Bessent’s support of CDFIs, mentioning his statement that, “This Administration recognizes the important role that the CDFI Fund and CDFIs play in expanding access to capital and providing technical assistance to communities across the United States.”
Waters and her fellow Members of Congress urge Bessent to clarify the importance of the CDFI Fund lest it be included in the administration’s recission bill, saying:
“Your words, however, are in direct conflict with the plain language of the President’s Executive Order characterizing the CDFI Fund as “unnecessary.” Further, there remain unaddressed concerns that the Administration could use the Executive Order as the basis to seek deep funding cuts or staff reductions at the CDFI Fund… To the extent the President agrees with your recent statement and wants to support CDFIs, the appropriate thing to do would be to promptly update the Executive Order to exempt the CDFI Fund from its application, ensure that the staff has access to the internet to do their jobs, and work with Congress to strengthen and expand the work of the CDFI Fund. It would be a shame if this becomes the first Administration to forsake the long bipartisan tradition of collaborating with Congress to support our CDFIs and the communities they serve.”
April 16:
Trump Administration Must Unfreeze Pending GGRF Funding and Desist from Clawing Back Disbursed Awards
Federal judges overseeing two different lawsuits regarding the Greenhouse Gas Reduction Fund (GGRF) made rulings on April 15 that will keep funds going to award recipients while ongoing court cases proceed.
Mary McElroy, a US District Court judge in Rhode Island, issued a temporary injunction instructs the administration to release funds as the lawsuit filed by several nonprofit groups moves forward.
US District judge for the District of Columbia Tanya Chutkan indefinitely blocked the EPA from clawing back already disbursed GGRF funds or limiting access to undisbursed funds while that lawsuit, brought by Climate United, continues.
April 16:
Reported Takeover of grants.gov Website is Not Expected to Affect CDFI Award Applicants
The Washington Post reported on April 11 that employees at the Department of Government Efficiency (DOGE) have made changes to grants.gov, a federal website that posts around 5,000 notices of funding opportunities each year. The grants.gov website is administered by the Department of Health and Human Services (HHS) but is used by multiple federal agencies. According to the Post, officials at these agencies no longer have direct access to post notices of funding opportunities and instead have been told to email them to an HHS address.
In addition to posting notices of funding in the Federal Register and notifying CDFIs by email, the CDFI Fund posts notices of its funding opportunities on grants.gov, and while applications for all CDFI funding opportunities take place through the CDFI Fund’s Awards Management Information System (AMIS), applicants are required to submit a single form to grants.gov as part of the application process (CU Strategic Planning handles this on behalf of our credit unions). Applicant access to the website does not appear to have changed.
The CDFI Fund award applications themselves are processed through AMIS on the Fund’s own site. On March 28, Treasury made it clear that all programs administered by the CDFI Fund are statutorily required and will continue to operate. There is no reason to expect that any CDFI awards programs will be materially affected by the change in posting procedures on the grants.gov website.
April 3:
EPA Continues to Provide No Evidence of Fraud or Abuse in GGRF Program
Judge Tanya Chutkan of the United States District Court for the District of Columbia criticized Justice Department attorneys in an April 2 hearing as part of the case brought by Climate United to release frozen Greenhouse Gas Reduction Fund (GGRF) award funds, saying “here we are, weeks in, and you’re still unable to proffer me any evidence with regard to malfeasance.”
She noted that the E.P.A. has offered “different positions” to justify its actions without actually presenting evidence of waste, fraud or abuse. Chutkan has also questioned whether the EPA acted lawfully in freezing the money in Citibank accounts without a court order.
The EPA has been moving away from its claims of malfeasance on the part of GGRF recipients, arguing instead that it has an inherent “right to breach” contracts it enters into.
Inclusiv, one of five recipients of a Clean Communities Investment Accelerator (CCIA) award under the GGRF umbrella, filed a lawsuit on March 31 against the EPA and Citibank, seeking release of its awarded funds.
March 28:
Treasury’s Response to OMB Shows all CDFI Programs are Legally Required
Good news in the form of the report submitted by the Treasury Department to the Office of Management and Budget (OMB) in response to the March 14 Executive Order aimed at eliminating "non-statutory" elements of seven federal programs, including the CDFI Fund. The brief one-page report, made available today, verifies that all 11 CDFI Fund programs are legally required and continue to perform their statutory functions.
The Treasury response referenced the statutes authorizing each program while stating that it would continue to operate while seeking efficiency improvements.
As reported in previous updates of the CDFI Briefing, the EO was met with a swift bipartisan response from CDFI industry groups and members of Congress as well, with Senators Mark Warner (D-VA) and Mike Crapo (R-ID), co-chairs of the Senate Community Development Finance Caucus, authoring a letter in support of the Fund’s programs signed by 23 Senators.
March 26:
Treasury Recommendations in Response to Executive Order Not Yet Released, but Informal Indications of Support Continue
While there has been no official release of the Treasury’s response to the March 14 Executive Order, Politico has reported that Rep. Bill Huizenga of Michigan, the Republican Vice-Chair of the US House Committee on Financial Services, has stated he’s been in touch with the Trump Administration and has received assurance that “the language [of the executive order] allows support to the CDFIs to continue and there’s a lot of discretion.”
The Defense Credit Union Council (DCUC) is continuing to communicate with Treasury Secretary Bessent’s office, sending a follow up letter this week stressing the importance of transparency and timeline communication. Chief Advocacy Officer Jason Stverak requested any developments be shared with stakeholders, so that they can “understand the direction of policy and plan accordingly.”
March 21:
Treasury Affirms Support for the CDFI Fund in Response to Executive Order
Earlier today the Native CDFI Network received a communication from the White House Office of Intergovernmental Affairs within the Executive Office of the President. It affirmed the U.S. Department of Treasury’s continuing support of the CDFI Fund in the wake of last Friday’s Executive Order by President Trump. Beyond support, the message indicates that the CDFI Fund should expect to operate as normal and that we shouldn’t expect disruptions to any of its programs. The message reads as follows:
“The CDFI Fund programs and related activities are statutorily authorized. The CDFI Fund is operating as normal and does not anticipate any disruptions to the programs. Senior leadership at Treasury has consistently expressed support for CDFIs.”
More details will be forthcoming, but this is a crucial win for Community Development Financial Institutions. We will continue to update with information as it becomes available.
March 20:
23 Senators Sign Letter to Trump Administration in Show of Bipartisan Support for the CDFI Fund
Senators Mark Warner (D-VA) and Mike Crapo (R-ID), co-chairs of the Senate Community Development Finance Caucus, have reaffirmed bipartisan support for the CDFI Fund in a letter to the Trump administration. Signed by 23 senators, the letter highlights the Fund’s critical role in delivering capital to underserved communities and fueling economic growth.
The senators emphasized that CDFIs provide over $300 billion in financial services annually, financing small businesses, homeownership, and community development projects. The letter warns that reducing CDFI Fund support would jeopardize these efforts and undermine financial access for small businesses and homeowners. It also underscores the efficiency of the CDFI model, which aligns with the administration’s goal of maximizing taxpayer impact—generating an eightfold return on public investment. With CDFI industry assets having tripled and certified institutions growing by 40% since 2020, the senators urged the administration to maintain strong support for the fund to continue expanding economic opportunities nationwide.
March 20:
EPA Temporarily Blocked from Clawing Back Obligated Funds in Climate Grants
Climate United Fund and the two other National Clean Investment Fund (NCIF) awardees were granted a temporary restraining order March 17 by Judge Chutkan, preventing the EPA from reclaiming $20 billion in climate grants, including those awarded to Climate United Fund and other National Clean Investment Fund recipients. The ruling halts the EPA’s termination efforts due to a lack of legal justification, keeping funds in grantee accounts while further court proceedings unfold.
Inclusiv and other clean energy hubs awarded funds in both the NCIF and Clean Communities Investment Accelerator (CCIA) voiced strong support for Climate United’s efforts, recognizing this decision as a crucial step toward restoring grant funding. Importantly, Judge Chutkan’s order suggests a potential pathway to fully reinstating the funds, which would allow credit unions and other community lenders to continue financing energy-saving projects that create jobs and drive economic growth.
March 18:
CDFI Advocacy Alert Fact Sheet and Webinar Recording Available Now
CU Strategic Planning held a webinar on March 17, addressing President Trump’s executive order that threatened the CDFI Fund, along with six other organizations. The webinar had nearly 300 participants and included an overview of the current situation, insights into what could be considered statutory and non-statutory functions of the Fund, and advice on actions to take this week to show Congress and the Trump administration the importance of the CDFI Fund and the critical role that CDFIs serve in the American economy.
We have made available a fact sheet that provides outreach tips, key information and who to contact. The webinar recording and summary is also available for those who were unable to attend.
Immediate response is crucial, as the heads of the organizations affected by the EO have a deadline of the 21st to respond to the Office of Management and Budget. We urge all CDFI credit unions to contact their members of Congress to stress the statutory authority of the CDFI Fund and the impact it has on communities across the country.
March 18:
Treasury Secretary Bessent Gives Statement About Importance of CDFIs
Treasury Secretary Bessent provided a response to an inquiry from the Defense Credit Union Council about to the March 14 executive order:
“This Administration recognizes the important role that the CDFI Fund and CDFIs play in expanding access to capital and providing technical assistance to communities across the United States,” Bessent stated in his response to DCUC. “CDFIs are a key component of President Trump's commitment to supporting Main Street America in the pursuit of job growth, wealth creation, and prosperity. As required by President Trump's March 14, 2025, executive order, the Treasury Department will provide a response to the Director of the OMB on this matter and looks forward to future engagement with CDFIs and other stakeholders to strengthen the impact of these statutory programs and incentivize economic opportunities for all Americans."
March 16:
CDFI Funding Advocacy Alert: Executive Order Targets CDFI Fund
Congress and the Trump administration provided mixed signals for the CDFI Fund on at the end of the week of March 15th.
CU Strategic Planning and Callahan and Associates strongly objects to this directive to shut down the CDFI Fund following Congressional approval of continued full funding by Congress and the President to invest in the CDFI Fund and CU CDFIs.
Congress voted on a continuing resolution to fully fund the federal government and the CDFI Fund on Friday March 14, 2025, for FY 2025 which was signed by President Trump and announced Saturday morning March 15, 2025.
The White House also announced President Trump signed an Executive Order that directs the heads of 7 entities, including the CDFI Fund to submit a report within 7 days to the Office of Management and Budget to “reduce the performance of their statutory functions and associated personnel.”
This indicates that the CDFI Fund should wrap-up non statutory functions, however “non-statutory functions” is left undefined. The CDFI Fund was created by statute, the Riegle Community Development and Regulatory Improvement Act of 1994 which also established its programs. Whether this creation by statute qualifies as a “statutory function” is unknown, with the likely outcome of the agency largely dependent on a response from the agency’s director.
What can CDFI Credit Unions Can Do in Solidarity With CU Strategic Planning?
Immediately contact your member of the House of Representatives at their local district office and seek a meeting THIS WEEK to discuss Congressional votes to fully fund the CDFI versus the White House Executive order.
Be prepared to discuss your work as a CDFI, and how the funding has allowed you to help working families, home buyers and small businesses.
o Start with “I am very concerned with the President’s Executive order to wind down the CDFI Fund in spite of Congress voting for full funding in fiscal year 2025 this past week.”
Ask for an in-person meeting with your CU leadership this week.
Immediately call your member of the House of Representatives and both U.S. Senators to discuss this action that eliminates a key and well-functioning program that assists CU CDFIs capacity to help support low to moderate income members, and the entire credit union movement to meet the lending needs of families and small businesses.
Call and email the White House
202.456.1111 is the comment line. This administration only takes calls Tuesday through Thursday 11am – 3pm. The White House Switchboard is 202.456.1414 – they refer you to the limited comment line.
Email the President at comments@whitehouse.gov
Don’t expect an email acknowledgement – but fill that comment box!
Join us to stand up!
March 10:
House Continuing Resolution Includes Budget Allocation for CDFI Fund at 2024 Levels
On March 8, the House Appropriations Committee released its Continuing Resolution (CR) to fund the federal government through the remainder of Fiscal Year 2025. The proposed legislation maintains most programs at their FY 2024 funding levels, with some exceptions.
Importantly, the CDFI Fund remains untouched by any changes, securing an appropriation of $324 million for FY2025. This is the funding needed for the 2025 CDFI Program FA and TA awards that are due on March 21. This is very positive news for CDFIs.
We’ll be continuing to monitor all movement in the federal budget discussions, since as we've seen this is a year for surprises. The FY2026 appropriations negotiations remain an unknown at this point.
March 6:
Key Takeaways from CDFI Fund Director Pravina Raghavan at the GAC
At America’s Credit Union’s Governmental Affairs Conference, CDFI Fund Director Pravina Raghavan provided insights into the evolving CDFI certification and recertification process, emphasizing the need for strong narratives and supporting documentation. She also addressed pressing concerns, including the 60% lending threshold, the future of private-sector investment in CDFIs, and the Fund’s stance on clawbacks.
Raghavan encouraged credit union CDFIs to focus on the Low-Income Targeted Population, offered insights on advisory boards as a tool for accountability, and stressed that the Fund is not seeking to eliminate fees but wants to understand how CDFIs use them differently.
February 21:
CFPB's Credit Union Advisory Council to be Terminated
The president’s February 19 executive order entitled “Commencing the Reduction of the Federal Bureaucracy” covered the elimination and downsizing of multiple entities, programs, and advisory committees. Included in the list of advisory committees to be terminated are the Credit Union Advisory Council and Academic Research Council of the CFPB. There is no mention of other two CFPB advisory councils (the Consumer Advisory Board or the Community Bank Advisory Council) in the order, but it does call for the FDIC to terminate its Community Bank Advisory Council.
As stated in previous updates, it’s unclear if this will have direct impact on CDFI regulation or recertification. The CDFI Fund has not made any statement related to changes at the CFPB.
February 12:
CDFI 2024 FA Award Funds are Being Disbursed
Despite a federal judge on Monday finding that the Trump administration violated a court order lifting the broad freeze on federal spending and certain agencies continuing to withhold funds, CDFI 2024 FA award winners are beginning to see their first disbursements of award funds.
This follows the normal timeline of award distribution and is another positive sign that CDFI Fund operations are continuing as normal.
2024 FA award assistance agreements were signed and returned by recipients to the CDFI Fund by the first week in February. The Fund issues its first disbursements shortly after countersigning those agreements. CU Strategic Planning has seen final countersigned 2024 FA award agreements for three quarters of our clients at this point.
Jonathan Gould Nominated for Comptroller of the Currency, Jonathan McKernan to Lead CFPB
Less than a week after former NCUA chairman Rodney Hood was named Acting Comptroller of the Currency, the Trump administration has nominated Jonathan Gould to lead the financial regulator. Gould is former chief counsel for the Senate Banking Committee senior deputy comptroller and chief counsel of the OCC under Joseph Otting during the first Trump administration and has shown to be amenable to easing regulations for banks and cryptocurrency.
McKernan was one of two Republicans appointed to the mostly-Democratic FDIC board during the Biden administration. His nomination as head of the Consumer Finance Protection Bureau was announced the same day that President Trump reaffirmed his goal dismantle the CFPB.
The next step in the nomination process is for the Senate Banking Committee to hold a hearing on both nominations to lead the CFPB and OCC on a permanent basis.
While the OCC has no regulatory authority over credit unions, it was considered a positive sign when credit union veteran Hood was named as the acting head of the office. The CFPB has supervisory authority over credit unions above $10 billion in assets, and the OCC, CFPB, FDIC, and NCUA all participate in interagency guidance on consumer credit practices.
February 10:
CDFI Fund Grant Evaluator Contracts Under Review
The CDFI Coalition is reporting that the Department of the Treasury is evaluating several hundred contracts on the recommendation of the Department of Government Efficiency (DOGE) today, which include the cancellation of several hundred contracts. Among these are the evaluations of NMTC allocation applications, as well as CDFI and NACA applications.
The CDFI Fund uses outside, contracted grant scorers as part of its evaluation process for CDFI grant applications. If these contracts were to be canceled, it would create a personnel burden on the staff of the CDFI Fund, but would not necessarily prevent these applications from being scored.
The CDFI Coalition’s 2025 Advocacy Campaign includes congressional contact lists and sample emails for staffers in support of CDFI Fund appropriations.
February 10:
CFPB is Halting Operations
The new Director of the Office of Management and Budget Russel Vought directed the Consumer Financial Protection Bureau (CFPB) over the weekend to stop work on proposed rules, suspend the effective dates on any rules that were finalized but not yet effective, and stop investigative work and not begin any new investigations, and cease all supervision and examination activity. The offices of the CFPB headquarters in Washington, D.C. will also be closed this week. Consumer complaints may still be made on the CFPB website, although the home page of the site returns an error message.
The agency was created under the Obama administration to protect consumers following the 2008 financial crisis.
The impact this will have on CDFIs at this point is uncertain, but there is a possibility it may impact implementation of regulation of overdraft protection and other fees in the recertification process. The CDFI Fund has not yet made any statement about whether the changes to the CFPB will have any impact on its interpretation of the new CDFI certification guidelines.
February 7:
Rodney Hood, Champion of Credit Unions and CDFIs, Named Acting Comptroller of the Currency
Rodney Hood, former NCUA board member under two administrations and chairman of the NCUA during the Trump administration, has been named acting Comptroller of the Currency and is set to be sworn in on Monday. While Hood is not expected to be a candidate for the permanent position, history suggests that his tenure could be significant — Michael Hsu, who was initially appointed as an acting Comptroller under the Biden administration, served in the role for over three years.
A Champion for Credit Unions & CDFI Expansion
The Office of the Comptroller of the Currency supervises national banks and federal savings associations. The Comptroller also serves as a director of the FDIC and member of the Financial Stability Oversight Council and the Federal Financial Institutions Examination Council. Hood brings to the position a history with both credit unions and Community Development Financial Institutions (CDFIs).
As NCUA Chairman, Hood was a key advocate for credit unions seeking CDFI certification. In 2021, he launched the streamlined CDFI qualification process, a critical component of ACCESS, the agency’s financial inclusion initiative. His leadership made it easier for federally insured, low-income credit unions to secure CDFI certification, unlocking new funding opportunities and expanding their ability to serve underserved communities.
Hood’s lasting impact on financial empowerment efforts continues to benefit credit unions and the communities they serve.
What’s Next?
Though Hood’s appointment as acting Comptroller is technically temporary, his tenure could extend well beyond expectations. With no immediate successor named, Hood has the opportunity to influence key regulatory decisions and continue championing both credit unions and CDFIs within Treasury and at the OCC.
February 3:
District Court Issues Temporary Restraining Order to Block Federal Funding Pause
All US Treasury grantees and contractors received a notification this morning about the Temporary Restraining Order (TRO) issued by the U.S. District Court for Rhode Island in New York et al. v. Trump, blocking the federal government from pausing or delaying financial assistance programs.
The TRO was granted on Friday the 31st to make it abundantly clear that the initial Executive Order initiating the pause on federal funding is not effective against current or future grants and against all federal agencies, whether or not they were specifically named in the Executive Order.
What does that mean?
This means that federal agencies are to continue with all existing and future financial assistance programs that have been allocated. This will remain in place until a preliminary injunction hearing and further court ruling.
How the decision was made
In issuing the TRO, the Court considered the potential for harm on either side, and found, among other things that:
The Executive Branch lacks authority to unilaterally pause federal financial assistance without Congressional approval.
The funding pause likely violates the Administrative Procedure Act (APA) by overriding Congressional appropriations.
The action violates the Separation of Powers Doctrine by improperly asserting executive authority over funds appropriated by Congress.
January 29:
Let’s start with a brief recap:
The Trump administration initially issued a memo on Monday, January 27 to freeze or “pause” all federal grant programs with a deadline of 5pm Tuesday January 28. Just before the freeze was to go into effect a federal judge issued an order to delay implementation of the freeze, and finally on Wednesday, the administration reversed course, rescinding Monday’s memo and likely allowing federal grant programs to proceed.
Where do we stand now?
For FY 2024 Financial Assistance (FA) award winners, this means the CDFI Fund will continue moving forward with their normal processes. FA Assistance Agreements are being signed and disbursements should begin soon; Technical Assistance (TA) award Assistance Agreements have not yet been made available.
FY 2025 FA and TA applicants, the process continues as normal. Even before the pause was rescinded, the CDFI Fund has been operating in a matter that demonstrates confidence in the security of this next award round, with “business as usual” communications sent out this week. We are working on the end stages of our credit unions’ FY 2025 applications for a late March submission.
Current award recipients with funds still outstanding (FY 2022 FA/TA and ERP), there is no longer a need to rush any disbursement requests. We are, of course, always available to complete these requests for our clients at the time that’s best for the credit union.
What does this mean for the future?
The Trump administration has stated that the aborted pause order served its purpose to demonstrate federal agencies’ need to abide by the newly issued executive orders. It appears, however, that this is a recognition of the federal government’s need to meet its obligations in disbursing congressionally appropriated funding.
As to what will happen with future budgetary allocations, we’ll repeat what we’ve mentioned before – the CDFI Fund has been a part of the Treasury Department for 30 years. It has strong bipartisan support and was well-funded during the first Trump administration.
Further, newly seated Treasury Secretary Scott Bessent has already indicated his strong support for the CDFI Fund and the CDFI Fund’s programs during his confirmation, saying "I believe that the breadth of the US Financial Services industry is what… differentiates the US economy from the rest of the world and I think the addition of these CDFIs into underserved communities are very important."
In addition, our outside advocacy counsel on Capitol Hill has been meeting with key members of the House and Senate Appropriations and Banking Committees for intelligence on the fluid situation this week and has been receiving reassurance of support of the CDFI Fund and its programs.
Staying informed and moving forward
It’s safe to say that these are unprecedented times for agencies that rely on federal grants and loans for their services. We will continue to follow all legislative and regulatory news that relates to credit unions and CDFIs, in order to continue to help credit unions unlock opportunities that change the lives of their members and communities.
This week’s rapid unfolding of events demonstrates the need to transition our “All Things CDFI” column into an on-going report that can be updated whenever there’s news to share and helping keep you informed on issues impacting CDFI credit unions. We’d like to invite you all to subscribe below to receive email updates from us on these time-sensitive issues as they’re posted. And you’ll be hearing from us soon!
January 27:
Appropriations Process Underway: March 14 is Next Deadline for FY 2025 Budget
The “four corners” of Appropriations Senators Susan Collins (R-ME) and Patty Murray (D-WA) and House Members Kay Granger (R-TX) and Rosa DeLauro (D-CT) met last week on “top line” budget numbers for the 12 appropriations bills that need to be completed, passed by House and Senate and sent to President Trump for approval. Word is they have those top line numbers in mind and CU Strategic Planning will be working with all appropriators to keep CDFI Budget numbers as high as possible in the Financial Services General Governance (FSGG) budget which mostly makes up the budgets for the US Department of Treasury.
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