The US Treasury CDFI Fund recently provided $1.25 billion in grants through its Rapid Response Program in response to the economic impact of COVID-19. CU Strategic Planning’s clients received nearly 10% of the congressional appropriation. But that’s not the end of the support for Certified Community Development Financial Institutions! Another $1.75 billion in grants will become available from the CDFI Fund’s Emergency Support and Minority Lending Program this summer. That’s $1.75 billion to help CDFI-certified credit unions to unlock greater potential in their communities and demonstrate their relevance through increasing service to minority populations and communities historically underserved and underbanked. “These are the people and the communities who’ve been hardest hit by the COVID-19 pandemic, through lost jobs or reduced hours,” CU Strategic Planning Co-Owner Mike Beall observed. “Credit unions’ historic work, and specifically CDFIs serving minority populations, distressed communities and underestimated people have earned the respect and funding to put America on a path to recovery. It was so gratifying to see Vice President Kamala Harris, Treasury Secretary Janet Yellen, Representative Maxine Waters and Senator Mark Warner announce the RRP grants right in front of the White House!” Another upcoming piece of the CARES Act funding is the Emergency Support and Minority Lending Program, for which $1.75 billion will be granted to expand lending, grant making, or investment activity in LMI minority communities and to minorities who have significant unmet capital or financial services needs. Funding from this program will provide a combination of grant capital and technical assistance that target communities affected by the pandemic. Eligible participants include depository and non-depository CDFIs, including a $1.2 billion set-aside for a new category of CDFIs, “minority lending institutions.” Treasury expects to open this program by early summer 2021. “Leveraging these grants can help CDFIs reserve the capital they need to have even more of an impact on minority communities that have been neglected by traditional financial services companies,” CU Strategic Planning Co-Owner Jamie Strayer added. “Credit unions couldn’t be more relevant than they are right now and using these grant funds as a resource is critical to maximizing financial inclusion.” Ronaldo Hardy, CU Strategic Planning’s Chief Diversity & Inclusion Officer, shared his hope that credit unions leverage the funding to create more inclusive lending practices starting at the policy level, crafted with an increasingly diverse executive teams and boards. He is leading a DEI Certification program for many of the participating CDFI credit unions.

June 23, 2020 The Honorable Mike Quigley, Chairman The Honorable Steve Womack, Chairman House Committee on Appropriations House Committee on Appropriations Subcommittee on FSGG Subcommittee on FSGG 2000 Rayburn House Office Building 2000 Rayburn House Office Building Gentlemen: CU Strategic Planning is the small business consultancy that credit union’s turn to advise them and has written more than $250 million dollars in CDFI award-winning grants for credit unions, more than anyone else in the CDFI industry. We recommend the Congress needs to fund the CDFI Fund to a level of at least $330 million for FY 2022 to help CDFI credit unions continue to lend during these times economic rebuilding following the pandemic. We also request $4 million be appropriated for the National Credit Union Administration’s Community Development Revolving Loan Fund. We anticipate the economic fallout of unemployment, evictions, and struggle to continue into 2022 for working families and that these funds will help credit unions lending for small dollar consumer loans, new and used auto loans, small business loans beyond what are backed by the SBA, loans for first month’s and last month’s rent as well as first time homebuyers and new home loans. CU Strategic Planning has written more than $250 million dollars in winning grants for CDFI credit unions to implement all over the nation, and has the ability to help CDFI credit unions get immediate help for low to moderate working families in the form of small consumer loans, auto loans, home mortgages and micro and small business loans. The Community Development Revolving Loan Fund (CDRLF), administered by the National Credit Union Administration, has been a reliable and well-managed program providing direct benefits for credit unions, especially those that serve consumers in disadvantaged communities, since 1979. Credit unions use the funding available, whether in the form of grants or loans, to provide direct assistance to credit unions, and we strongly encourage Congress to support this investment in America’s consumers. CU Strategic Planning stands ready to help hundreds of credit unions restore consumer confidence, create and recreate lost jobs and get the economy moving again with two small yet vital programs. I encourage you to contact me directly if you have any questions or suggestions at 202.802.0036 or mike@creditunionstrategicplanning.com. Respectfully, Michael V. Beall, Esq. Chief Strategic and Advocacy Officer CU Strategic Planning

Fully 10% of $1.25 Billion from Rapid Response Program & 29% of CU Awards Credit Union Strategic Planning, the credit union movement’s largest organization for helping credit unions obtain Community Development Financial Institutions Fund grants, facilitated 65 successful CDFI RRP grant applications for credit unions, totaling $115.2 million. The awards announced today for CU Strategic Planning clients nearly match the entirety of the company’s previous 12 years of achievement in helping credit unions serve low- to moderate-income families. The firm has now directly won nearly $250 million in grants for credit unions from the Treasury Department’s CDFI Fund! Vice President Kamala Harris made a historic statement on the importance of community development financial institutions announcing today’s release of funds to community development financial institutions through the CDFI Fund’s Rapid Response Program. Harris’s role in the announcement indicates the increased importance of CDFI in the administrations community development and assistance for working families. “CU Strategic Planning is proud to be a key facilitator for CDFI credit unions to be a significant part of the solution to provide rapid relief funding to families and distressed communities,” said CU Strategic Planning CEO Stacy Augustine. “The rightful attention CDFIs are receiving – particularly the announcement coming from the Vice President today from the White House – has been spectacular and well deserved.” The Coronavirus Response and Relief Supplemental Appropriations Act provided $1.25 billion to the CDFI Fund for CDFIs delivering immediate assistance in response to the financial and economic effects of the COVID-19 pandemic. The CDFI RRP was designed to quickly deploy capital to certified CDFIs through a streamlined application and review process, allowing them to get help and funds into the hands of those who need it most – particularly those in economically distressed areas and underserved communities. “Based on our credit union clients’ challenging, yet rewarding, efforts to serve hard-working Americans in underserved and underbanked communities, we’re not surprised at their success in obtaining grant funding through this special, emergency program,” Augustine commented. “Credit unions are the solution to eviction prevention, business sustainability and rebuilding and economic recovery for distressed families and communities.”

Up to 20 new hires this year! For more than a decade, credit unions have discovered the full suite of services CU Strategic Planning has to offer community development credit unions, and now the company is growing by leaps and bounds. As a result, CU Strategic Planning is proud to announce the following promotions: Carrie Ostrem, AVP, Certification Services Kathleen Falotico, AVP, Operations Sydney Moreau, Certification Specialist Additionally, Rick Thomas, who has worked with CU Strategic Planning as a contractor, was hired to the position of vice president of Community Development & Transformation. Alongside grant fulfillment, he will be actively engaged in our other client-based projects, such as strategic planning. CU Strategic Planning will also be adding new team members. CU Strategic Planning Chief Diversity & Inclusion Officer Ronaldo Hardy is recruiting for two new community development managers. The company is also hiring two additional admin positions, one of which will be filling an entirely new position. “The new supplemental appropriations bill passed by Congress added fuel to our growth plans,” CU Strategic Planning CEO Stacy Augustine said. “We and our community development credit unions will be busier than ever. As the country moves forward, we plan to continue provide the best service we can for our credit union partners.”

The coronavirus pandemic caused temporary furloughs, many of which have turned permanent, obliterating mom-and-pop shops and other service professions. Though unemployment is improving in the near term, long-term unemployment is worsening. According to CNBC, around one-third of the unemployed have been out of work for at least six months, creating a dangerous financial situation for vulnerable households. To help CDFI-certified credit unions increase their results serving the unbanked and underbanked, CU Strategic Planning is pleased to announce a new partnership with financial technology and marketing provider Kasasa. The overall goal of this partnership is to move families from just surviving to building back generational wealth and is guided by CU Strategic Planning's mission to unlock opportunities for credit unions to change lives and their communities. Lack of access to affordable financial services leaves the most financially distressed consumers vulnerable to be taken advantage of by wealth-stripping predatory lenders, check cashers, and the like. As the pandemic continues to impact consumers across the nation, credit unions and Community Development Financial Institutions (CDFIs) remain dedicated to empowering and protecting working class, moderate to low-income people, vulnerable populations, and disadvantaged communities. "Kasasa's products are not just best-in-class for credit unions," Shirley Senn, CU Strategic Planning's Chief Social Impact Engineer, says, “but they are the best we've seen to bank the unbanked for all 98 of the award-winning CDFI certified credit unions we advise." "This partnership is driven by more than just Kasasa products," Ronaldo Hardy, CU Strategic Planning's Chief Diversity and Inclusion Officer, explains. "Kasasa uses data analytics to target potential members with a nationally recognized brand to drive financial inclusion in a way that credit unions can't accomplish on their own. “Minorities comprise the greatest share of the underbanked. Like all consumers, the underbanked place greater trust in national brands. Let's move those consumers away from national cash checkers and payday lenders, like MoneyTree, and into credit unions that want to help them succeed." The partnership is guided by CU Strategic Planning's mission to unlock opportunities for credit unions to change lives and their communities with the goal to move families from just surviving to building back generational wealth. CDFIs prevent deceptive service providers from siphoning household income critically needed to pay for groceries, utilities, and housing. The CU Strategic Planning team is most excited by the Kasasa Loan®, the only loan on the market with Take-Backs™ that allow consumers to pay down loan principal faster, reducing interest payments with the option to borrow back their funds in case of emergency. "So many families could benefit by reducing interest payments to retain household income, but it is too risky to take away from emergency savings. This is the best of both worlds," according to Senn. CU Strategic Planning takes a multi-year approach to community development and is an investment that allows CDFI-certified credit unions to make real differences in the lives of their members and communities. This partnership will enhance credit unions’ ability to offer the augmented services and products that existing and potential members value. “We are thrilled to partner with CU Strategic Planning as they continue to drive profound change for credit unions and the communities they serve,” Jill Feiler, EVP of Client Success at Kasasa, says. “Credit unions work on a local level and have the benefit of knowing their communities better than the megabanks do, making them the best financial institution to reach underbanked consumers in the area. By offering innovative products with a national brand, credit unions are able to expand their reach and grow while creating value for their members and providing a people-first banking experience.”

The recently enacted Coronavirus Response and Relief Supplemental Appropriations Act of 2021 (H.R. 133) contained $12 billion for CDFIs and MDIs through three additional Treasury programs. The intent of the appropriation is to help communities struggling with the economic impacts of the COVID-19 pandemic. This overview describes the ECIP Program. PURPOSE The ECIP provides direct and indirect investments in the form of subordinated debt as secondary capital to eligible CDFI certified or Minority Depository (MDI) credit unions to, among other things, support their efforts to provide loans, grants and forbearance for small businesses, minority-owned businesses, and consumers, especially in low income and underserved communities, including Persistent Poverty Counties, that may be disproportionately impacted by the economic effects of the COVID-19 pandemic. FUNDS AVAILABLE The maximum amount available to any individual institution through ECIP is $250,000,000. The maximum amount by asset size is: Not more than 7.5 percent of total assets for an institution with total assets of more than $2,000,000,000; Not more than 15 percent of total assets for an institution with total assets of not less than $500,000,000 and not more than $2,000,000,000; and Not more than 22.5 percent of total assets for an institution with total assets of less than $500,000,000. INTEREST RATE The rate on the investment will not exceed 2% for 10 years. No payments will be due during the first 24 months after investment. If lending to underserved communities increases 200-400% of the amount of the capital investment, the rate is reduced to 1.25%. If lending to underserved communities increases by more than 400% of the amount of the capital investment, the rate is reduced to 0.5%. ELIGIBILITY A credit union must be either CDFI certified or designated as a Minority Depository Institution (MDI), and federally insured to apply for funding. A credit union must be Low Income Designated to count secondary capital toward its net worth. INELIGIBILITY A credit union is ineligible to participate in the ECIP if it is: Considered to be in a Troubled Condition by the NCUA, which means that the credit union has been assigned a 4 or 5 composite CAMEL rating; or Is subject to an NCUA formal enforcement action that addresses unsafe or unsound lending practices. Formal enforcement actions are defined as LUAs, Administrative Orders or Consent Orders relating to unsafe lending. Applicants that are uncertain regarding their eligibility status due to a formal enforcement action may contact the ECIP Program for further clarification. TIMELINE/URGENCY Applications will be reviewed and evaluated by the Treasury Department on an ongoing basis, in the order in which they are received. CU Strategic Planning has established an application cap and is focused on serving existing clients with current data on-file to ensure expedited submission of applications. Funding pools are set by asset tiers. Treasury will carve out at least $4,000,000,000 of the appropriation for successful applicants who have total assets under $2,000,000,000, and will carve out at least $2,000,000,000 for successful applicants with total assets of less than $500,000,000. APPLICATION The application format is similar to a CDFI Financial Assistance (FA) Award Application. The content mirrors the FA application with community development specific needs, challenges, strategies, goals, quantitative and qualitative impacts, products, assumptions and financial projections. COMPLIANCE REQUIREMENTS There will be reporting requirements. They are unknown at this time. Per the application, “Reporting requirements will be outlined in the final agreement and may be added to or modified at any time at the discretion of the Secretary.” Requirements may be waived by the Secretary of the Treasury in his or her sole discretion to the extent permitted by law. CU Strategic Planning will provide compliance reporting services. The cost of these services is not yet determined because the scope of work is unknown until the compliance requirements are released. FAQ Q: Will the NCUA review and approve the Emergency Capital Lending Plan in addition to the U.S. Treasury? A: Yes. Q: Do I need to apply without knowing the compliance requirements in order to be eligible to receive the funding? A: Yes, the process is to apply. The reporting requirements will not be released until your credit union is approved and receives its Assistance Agreement. Q: If the compliance requirements outlined in the Assistance Agreement are unfavorable to our credit union may we decline the funds? A: Yes. Q: Is it possible that the compliance requirements overlap with CDFI grant reporting requirements? A: Yes. As part of CU Strategic Planning’s grant reporting and ECIP reporting, we will advise clients on success strategies to ensure compliance. Q: Is CU Strategic Planning approaching the development of the ECIP application using the same process as the CDFI FA Application? A: Yes. Beyond the application writing, CU Strategic Planning is providing consulting services to develop the strategies and goals collaboratively with credit union executive teams. CU Strategic Planning will leverage community and economic development research, market conditions, needs and challenges in line with a credit union’s existing strategic priorities, products and community development activities to inform the development of sustainable activities, successful strategies, operational goals and realistic financial projections. CU Strategic Planning is the only provider of CDFI consulting services to credit unions that developed and submitted secondary capital plans to the U.S. Treasury through the CDCI Program in 2010. It is leveraging that experience to ensure that credit unions can access the historic $9,000,000,000 available in the Emergency Capital Investment Program. CU Strategic Planning exists to unlock opportunities for credit unions to change lives and their communities. Its ECIP services are comprehensive and will include compliance support based on terms outlined in the Assistance Agreement between the U.S. Treasury and each credit union. Contracts for that service are separate from the application to receive funds.

The work we do with credit unions allows them to make real differences in the lives of their members and communities. This could be through CDFI certification or grant funding, assisting with business plans, product design, partnership creation or any of our other many services. And as part of this work, we get to hear the wonderful member impact stories that illustrate what credit unions are doing to unlock opportunities in the communities they serve. We will be highlighting some of these stories here. Ascension Credit Union’s Staff Trained as HEROs Save Two Members $30,000 When $86 million Ascension Credit Union in Gonzales, LA received a NCUA grant to certify its entire staff as Community Development Certified Financial Counselors through CU Strategic Planning’s HERO program, management’s intention wasn’t that they all provide in-depth counseling. The goal was to train all staff to recognize members specific financial challenges and intervene, including cross-department transfers to solve problems. What it wasn’t expecting is shortly after the training staff would save two members $30,000. In detailing the impact of HERO training, Ascension shared a story where a MSR recognized that a member had a high interest rate on his second mortgage at another financial institution. After working with the member, Ascension was able to approve a loan to pay off the second mortgage. The member not only saved over $12,000 in interest over the life of the loan but was also able to lower their payments and shave off five-years from the original loan term. Ascension cut a second member’s interest rate by over half, saving the family over $18,000 without extending the loan term. “These are just a few of many situations that allowed us to rescue members from high interest rates and longer terms,” shared Lux. “Our stories grow each day. The impact that we have made in our community is overwhelming.” Ascension Credit Union hopes to help underserved members by giving them lifelong tools necessary to obtain and maintain financial freedom, become savers for short-term and long-term needs. Ascension credited the HERO program with helping staff learn how its members can achieve savings through loans, allowing them to be able to manage their money for years to come. Lux credited the use of HERO tools as giving members the help they need to budget their monthly income and manage their expenses to start saving for college funds, emergency savings for unforeseen crisis, and ultimately for their own retirement. “They can finally see progress in debt reduction and see their savings grow at the same time.” To learn more about HERO, visit herocounseling.org.

The CDFI Fund proposes changes to CDFI certification. CU Strategic Planning responds on behalf of credit unions. The CDFI Fund's proposal could have severe consequences reducing the number of CDFI certified credit unions. Tanya McInnis, Program Manager Office of Certification, Compliance Monitoring & Evaluation Community Development Financial Institutions Fund U.S. Department of the Treasury 1500 Pennsylvania Ave. NW Washington, DC 20220 Via Email: ccme@cdfi.treas.gov Subject: Request for Public Comment: Community Development Financial Institutions Program—Certification Application, OMB Number: 1559-0028 CU Strategic Planning is a consultancy working with both CDFI certified and emerging CDFI credit unions across the country. On behalf of our clients we appreciate the opportunity to provide comments in response to the CDFI Fund’s request for public comment on its certification application process. Key Definitions The CDFI Fund recognizes a finite list of products and services as Financial Services for the purposes of certification. Other Financial Services that could be included are: shared branching services, individual retirement accounts, prize-linked savings accounts, individual development accounts, on-line bill pay/account access and virtual tellers. For example, although IRAs are often inaccessible to low income consumers, a number of credit unions have lowered the barriers to entry to encourage savings and give consumers access to higher-paying savings vehicles. Shared branching services gives the member of a credit union the ability to perform deposits, withdrawals and check cashing at other credit unions within the same cooperative network, dramatically reducing the need for expensive check cashing services and reducing costs to the consumer. Virtual tellers—whether deployed on-site at partner locations or available through Video Teller Machines, give low income consumers access to accounts in areas where a branch isn’t feasible. Finally, the CDFI Fund may also wish to consider recognizing allowance for Target Market account losses as an eligible Financial Service (losses associated with Financial Services accounts deployed to the Target Market). Applicant Basic Information Question BI21.1 of the certification application asks if a credit union’s bylaws demonstrate that the credit union’s governing board is democratically elected by the credit union’s members. Because all credit unions in the United States are not for profit, democratically controlled financial cooperatives, this question is unnecessary. Democratic control is a necessary tenant, and one of the defining principles of credit union operation. By removing this question and its subsidiary questions, the CDFI Fund reduces unnecessary paperwork for both the applicant and the CDFI Fund. Under this same category, it’s very helpful that the CDFI Fund appears to be moving away from automatically requiring credit union applicants to include copies of their articles of incorporation. Most credit unions in the U.S. were chartered more than 50 years ago, with many chartered in the early 1930’s. While most have copies of their original articles of incorporation, these articles are sometimes less than legible, have often been amended over the years, and are often located off-site in long-term storage—making them somewhat inaccessible. With the knowledge that all credit unions are democratically controlled, and by checking to ensure that the credit union applicant has a charter number assigned by the National Credit Union Administration, the CDFI Fund will save the time and paperwork necessary in collecting and submitting credit union bylaws and articles of incorporation. Question BI-FP10 of the certification application requires the applicant to create a separate AMIS entry for each type of Financial Product offered, which includes information on the terms and conditions of the product, repayment terms, etc. Depository applicants are apt to offer many types of Financial Products, therefore, to reduce paperwork, we’d suggest that the CDFI Fund limit the number of entries to a reasonable number since there is considerable burden involved in entering all of the terms for each type of Financial Product offered. Legal Entity To qualify as a Certified CDFI, each applicant must validly exist under state or federal law. There’s some ambiguity between this section and the applicant Basic Information section concerning what information must be submitted to validate legal existence. For example, the guidance requires a credit union to include a copy of its charter, however just what this constitutes is uncertain. Is it the credit union’s bylaws? Its articles of incorporation? By checking to ensure that the credit union applicant has a charter number assigned by the National Credit Union Administration, the CDFI Fund will save the time and paperwork necessary in collecting and submitting credit union bylaws and articles of incorporation. Question LE02 of the certification application requires the applicant to include its official EIN letter from the IRS. Is this information necessary if the CDFI Fund can confirm that a credit union is active and operating with the NCUA? Is the EIN used for another purpose? Again, because credit unions have most commonly been in operation for more than 50 years— long before the federal EIN system was created by the IRS in 1974, original EIN documentation can be difficult to locate. All credit unions have an EIN since having an EIN is a prerequisite to paying employment taxes. Perhaps requesting the EIN itself, if needed, would be sufficient and reduce paperwork—at least for regulated applicants. Question LE12 of the certification application asks if the applicant is a State-Insured Credit Union. It’s worth noting that those credit unions that are not federally insured, may protect consumers against loss in a variety of ways. They could be state-insured, privately guaranteed or even potentially be uninsured. Although this last category of credit unions is dwindling, there are more privately guaranteed credit unions than those that are state-insured. In other words, perhaps this question should ask if the applicant is a non-federally insured credit union, with additional follow-up questions that allow the CDFI Fund to understand the applicant’s protection of consumer funds. Question LE16 of the certification applicant asks if there have been any amendments to the applicant’s legal entity documentation. Again, because most credit unions were chartered more than 50 years ago, it can be arduous to track down all amendments over the course of time. We’d encourage the CDFI Fund to request only those amendments that are necessary to ensure that the applicant meets the need to prove that they are a legal entity. Perhaps the CDFI Fund is looking to understand the history of the applicant as a legal entity since inception. However this could be described in a short narrative, creating less burden combined with ensuring that the credit union has as an active charter number with the NCUA. Primary Mission Documentation of Primary Mission: A certified CDFI must have a primary mission of promoting community development and directing its activities toward improving the social or economic conditions of underserved people or communities. To date, the CDFI Fund has based part of its determination of community development mission by looking at an applicant credit union’s mission statement. One of the most important comments we’d like to leave with the CDFI Fund is that a mission statement often does not equate to mission at a credit union. By way of background, because credit unions are governed by democratically elected representatives from the credit union’s membership that are almost entirely contributing their time as volunteers, credit union mission statements sometimes lack the polish and specificity of larger corporation, instead emphasizing service to the credit union’s members and financial stability. Credit union mission statements are often developed by this group of volunteers as part of a planning session. As a result, in our experience, their missions can be somewhat generic. We applaud the CDFI Fund’s willingness to look at other documentation that evidences strategies that demonstrate a community development mission and we encourage the CDFI Fund to expand its willingness to show evidence of other community development-related strategies that focus activities toward improving the social or economic conditions of underserved people or communities. Further, we’d encourage the CDFI Fund to consider creating the assumption that any applicant that can show the deployment of over 60% of its total loan volume to an eligible market (or perhaps a slightly higher benchmark) already has a primary mission of promoting community development in an effort to reduce paperwork and burden. Applicants that fail to meet this standard could then be required to demonstrate a primary mission with additional documentation. Further, it seems very reasonable to require a CDFI to have a primary mission devoted to promoting community development for at least 12 months, so long as evidence of the primary mission can be documented in ways other than looking to the applicant’s mission statement alone. Because credit union applicants often have a decided community development mission focused on directing their activities to addressing the economic conditions of underserved people or communities, but also often have mission statements that don’t reflect this underlying organizational mission, some have, in the past, illustrated their mission by adopting a community development mission statement. The recent adoption of a community development mission statement does not belie the fact that the credit union applicant always had a community development mission, therefore the applicant should be given the opportunity to illustrate their underlying mission in other, flexible ways. Affiliate Primary Mission: The CDFI Fund’s proposal appears to require any affiliate in the family of applicant entities to meet the primary mission test (see p. 29 and 30 of Certification Application Overview). However, an affiliate not seeking certification as a CDFI should not be required to meet the primary mission test—only the certification applicant. This may simply be a section of the proposal that’s somewhat confusing and where additional clarification would be helpful. For example, the CDFI Fund may only intend to require affiliate information if the affiliate is actively involved in providing a Financial Product or Financial Service to the applicant’s Target Market. Responsible Financing Practices: Although not a statutory requirement for certification, the CDFI Fund is proposing that applicants meet requirements for responsible financing practices. It’s understandable that the CDFI Fund wants to protect the CDFI brand as one that represents organizations certified to help, and not harm consumers. A cautionary consideration: does the CDFI Fund want to be the arbiter of what is a responsible financing practice (particularly when responsible finance is not a prerequisite of the underlying statute)? This determination could be a source of litigation or legislative scrutiny for applicants denied certification on these grounds. This is particularly true since a rate considered high for a borrower with a moderate to high credit score, could represent a godsend for a borrower with a poor credit history. For example, if a CDFI credit union offered a $500 payday loan alternative to be paid back within six months (extending the term to ensure that loan payments are kept affordable for a low income borrower), even at the highest rate allowed to a federally chartered credit union at 36% (which seems very high when compared to rates available to A paper borrowers), this adds up to a consumer loan cost of $90. At a comparable payday lender, the borrower would probably be unable to pay off the loan within one pay cycle and the loan would be rolled over, on average, four times. Over six months, the cost of the loan to the borrower could be as high as $2,895 in some states. In other words, “responsible financing” could be a very difficult benchmark for the CDFI Fund to define, as it’s often subjective and contextual. Use of Military Annual Percentage Rate: The CDFI Fund proposes that all certification applicants recalculate all rates in the form of a Military Annual Percentage Rate. This requirement would represent a tremendous application burden to applicants, and the need for considerable expertise to fully ensure compliance with the requirement. Credit union lending systems aren’t set up for MAPR reporting, but are structured around meeting the disclosure requirements of the federal Truth in Lending Act. We’d strongly encourage the CDFI Fund to rely on the calculation requirements of the Truth in Lending Act since the Act was established to create a uniform disclosure of costs that allows consumers to effectively shop for rates and understand the true cost of credit. Question PM19 of the certification application asks applicants whether they have disclosed periodic payments due, total amounts to be repaid over the life of the loan, total finance charges over the life of the loan, etc. Each of these disclosures appears to mirror the disclosures required under the Truth in Lending Act and Regulation Z. If all lenders applying for CDFI certification are already bound by the disclosure requirements of Reg. Z, this question seems unnecessary. If there are lenders applying for CDFI certification not bound by the disclosure requirements of Reg. Z, perhaps this question should be solely directed to those applicants. Question PM26 of the certification application asks applicants whether they offer at least one Financial Services depository account with “total functionality” with associated low fees. We would appreciate greater clarity around the use of the term “total functionality”. Since each Financial Services account can be structured differently, we’d need to know which functions should be included in order to answer the question accurately. Primary Mission – Affiliates (see p. 42): Here again, we would appreciate greater clarity over when information concerning an affiliate should be included in an applicant’s CDFI application. We do not believe it is the CDFI Fund’s intent to require this information on affiliates, if the affiliate is not applying with the applicant or supplying one or more of the characteristics needed to qualify the applicant as a CDFI (for example, providing Financial Products). The most common example at a credit union would be a wholly owned credit union service organization or CUSO that offers insurance services. These services are kept separate from those offered by the credit union because they are not core credit union services and can’t be offered under the credit union’s not for profit charter. A credit union applying to become a CDFI would not typically rely on any CUSO activities to meet the requirements to become a CDFI and a credit union CUSO would probably not meet the primary mission test since the affiliate was specifically chartered separately from the credit union to offer a service outside the scope of the credit union’s mission and unlikely to be focused on community development. Financing Entity Question FE-AS12 of the certification application asks applicants if any of the applicant’s staff are dedicated to activities other than the direct provision of Financial Products and/or Financial Services and provides a pick list of other non-financing activities to choose from. We’re unclear on why the CDFI Fund is seeking the answer to this question, since the applicant is already required to list the total number of FTEs dedicated to Financial Products and Financial Services, however, if the answer to this question is important, it’s worth noting that there should be many other pick list categories to choose from such as: management, marketing, financial management, compliance, security, data analytics, etc. Capital Available to Support Financial Products (FE-AC01 through FE-AC03): These questions in the proposed certification application concern the cash needed to fund Financial Products. We’re unclear on whether this question is directed to non-depository applicants or all applicants. If directed to regulated, depository institution, this information could be reliably verified through public call report data to reduce regulatory burden (specifically the following line items on a credit union call report: ACCT_730A (representing cash on hand) and ACCT_730B (representing cash on deposit)). Because every CDFI, once certified, is required to submit an Annual Certification Report that tracks lending to the CDFI’s Target Market, perhaps this question could be eliminated since, the proof of lending will figuratively be in the pudding! Financing Entity Projections (FE-PO1 & FE-PO2): These questions in the proposed certification application ask the applicant to project the total number of transactions expected to be closed in the next three months along with the dollar amount of financing transactions projected. These questions are highly relevant to a grant application that requires the grantee to meet established performance benchmarks, but we are unclear on how the questions relate to the statutory tenants for certification as a CDFI. Year-to-year performance should be illustrated by year-over-year annual certification reporting data without requiring applicants to include loan projections as part of their certification application. Target Market Calculation of Financial Products to Target Market: The CDFI Fund’s request for comments institutionalizes recent practice, requiring certification applicants to direct at least 60% of both the number and dollar volume of Financial Products to one or more eligible Target Market types. We recognize that the CDFI Fund is responsible for establishing an enforceable standard used to determine when a certification applicant can reasonably be said to have a primary mission of community development under 12 USC 4702(5) and 12 CFR 1805.201(b)(1). (Although it might be more reasonable to recognize any entity providing over half of its products and services (51%) to an eligible Target Market type.) Nonetheless, requiring an applicant to meet a supermajority-type, 60% standard in both the number and dollar volume of Financial Products to an eligible Target Market creates a standard that does not serve the interests of public policy—carefully balancing the need to ensure that applicants have a community development mission with the overarching policy of encouraging applicants to embrace a community development focus. Further, reliance on a standard that requires 60% of loan dollar volume can skew true Target Market deployment for applicants competing with predatory small dollar marketplace lenders. For example, an applicant making 50 small, payday alternative loans in the amount of $200 to an eligible Target Market, and just one housing loan for $250,000 to a non-eligible Target Market would not meet the CDFI Fund’s calculation standards because even though 98% of loans were deployed to an eligible Target Market, less than 4% of the dollar amount of loans were deployed to an eligible Target Market. As a result, we’d encourage the CDFI Fund to adopt greater flexibility with its primary mission standards that better balance evidence of primary mission with public policy that encourages applicants to meet the standards associated with CDFI certification. Use of Financial Services to Calculate Primary Mission to Target Market: The CDFI Fund’s request for comments proposes to allow depository institutions to incorporate the delivery of Financial Services into the applicant’s calculation of service to a Target Market. This proposed change recognizes the crucial importance of lifeline account services to low income consumers. We appreciate the CDFI Fund’s recognition of Financial Services and its creative proposal for calculating these services to a Target Market (since many Financial Services are provided without the knowledge of the user’s income—income that would only be obtained through loan underwriting). An unfortunate hurdle to using Financial Services accounts to calculate service to low to moderate income consumers comes from the fact that low income consumers are more likely to have just one account at an applicant credit union, whereas a higher income consumer might have multiple accounts (e.g., savings account, checking account, money market account, IRA). This is likely to skew the calculation of Financial Services provided. For the purpose of calculating the provision of Financial Services to an eligible Target Market, perhaps the CDFI Fund should disregard duplicate Financial Services provided to a single consumer. We further encourage the CDFI Fund to allow applicants to rely more heavily on the provision of Financial Services to a Target Market to demonstrate its primary mission to an eligible Target Market, including wholesale reliance on Financial Services to meet the standards established by the CDFI Fund (in other words, allowing the applicant to show 60% of Financial Services to an eligible Target Market instead of requiring both 60% of Financial Services to an eligible Target Market AND an additional 50% of the number of Financial Products to an eligible Target Market AND 50% of the dollar volume of Financial Products to an eligible Target Market). Allowed Target Market Types: Investment Area: The CDFI Fund’s Certification Application PowerPoint presentation indicates that geographic boundaries and mapping requirements are being eliminated for most Target Markets (page 26). This change would seem to streamline future reporting, however we would appreciate additional clarification on how an applicant will use pre-qualified Investment Areas to meet the CDFI Fund’s benchmarks for certification. Target Market Verification Process: The CDFI Fund’s request for comments appears to disallow loan sampling used to determine whether the applicant meets the benchmarks established by the CDFI Fund. For the reasons illustrated in the example above (50 payday alternative loans + one mortgage loan), loan sampling represents an important tool for illustrating true service to an eligible Target Market. If the CDFI Fund’s analysis is based on 12-months of history in deploying Financial Products (and possibly Financial Services) to an eligible Target Market, depending on the volume of the applicant’s lending, one commercial loan can dramatically impact and skew the results of the calculations used to determine whether the applicant is meeting its benchmarks. For other, large applicants, requiring 12-months of loan data represents its own challenge. Large credit unions can easily produce over 100,000 loans during a 12-month period. For grant reporting purposes AMIS has been unable to accept file uploads over 1,000 records. During grant reporting, this requires high-volume lenders originating 100,000 loans during a year to break their files into an estimated 100 separate uploads (issues that “time out” the upload appear to depend on file size, so it’s difficult to estimate the exact number of loan files AMIS can routinely support before erroring out, however we’ve found that reducing the number of loan records to 1,000 or less generally circumvents the upload error). On several larger credit unions we’ve worked with, we’ve needed to enlist CDFI Fund staff support to be able to submit this many records. If the CDFI Fund is proposing that all certification and annual certification reports include a full 12-months of lending data, we have concerns over whether the systems used to collect the data can support it. Development Services Tracking of Development Services: The CDFI Fund’s request for comments requires certification applicants to track the delivery of, and participation in Development Services along with the amount of time staff spend on the administration and delivery of Development Services. While we recognize that many CDFI applicants routinely track this information for (non-CDFI) grant reporting and to attract funders, other applicants do not. It’s important that the CDFI Fund continue to allow applicants to estimate this information consistent with past practice. Requiring actual tracking would be a burdensome new requirement, diverting applicant attention away from actively providing the products and services that represent the fulfillment of its community development mission. Information Not Considered Development Services: The request for comments indicates that the CDFI Fund will not consider information presented in newsletters, flyers, or online to be Development Services. Here, we feel it’s important to distinguish between general information presented on an applicant’s website and information specifically designed to provide information that helps consumers or small business owners better their ability to borrow, budget and plan for their financial future. Some of our clients have developed extraordinarily helpful informational materials geared to a consumer’s stage in life and including tools that can be used to develop budgets, develop small business marketing plans and determine the amount of house they can afford. These resources should be considered Development Services, whereas general web pages that promote products should not. Further, the proposal indicates that the CDFI Fund will not consider presentations at one-off events or regular events held by other entities as a Development Service. While a presentation at a singular event probably lacks the continuity needed to help prepare and qualify consumers for Financial Products, we believe that regular events held at partner locations are, and should qualify as Development Services. By conducting events at partner locations, CDFIs have in-roads into underserved communities that most need the Development Services expertise often provided by the CDFI. Accountability Demonstration of Accountability: When using an advisory board to demonstrate accountability, the CDFI Fund’s proposal requires at least one governing board member to have a seat on the advisory board. It’s understandable that there should be a link between the advisory board representing an eligible Target Market and the CDFI’s governing board, however, perhaps the CDFI Fund could allow for other ways of creating this link. For example, one of our clients serves a native population, and the ultimate advisory board might be comprised of an existing organization of consumers elected from within the native population. As elected representatives, these consumers would have a thorough understanding of the native population’s economic issues and needs, however, aligning the election of this separate governance organization with a credit union’s democratically elected board would be difficult. Could there be other ways of establishing accountability by requiring attendance at the credit union’s board meetings, reports to the independent native governance organization, etc.? Question AC28 of the certification application asks applicants applying for certification using an Other Targeted Population to identify the means of accountability used to demonstrate this accountability to the OTP. Under the “select all that apply” pick list, we are unclear on the application of the pick list references to persons with disabilities. Are the responses indicating that unless the applicant’s OTP is made up of disabled persons accountability cannot be shown by being employed by, or by serving on the governing or advisory board of an organization that primarily provides services to an OTP? If so, why would it not be acceptable to show accountability to any OTP through one of these methods? Finally, the acceptable forms of accountability to an OTP in Question AC28 is inconsistent with the means of demonstrating accountability to a native community in Question NACR10 which allows accountability to be demonstrated by employees of organizations primarily providing services to residents of the native community or governing/advisory board members primarily providing services to residents of the native community. Question AC-CU01 of the certification application asks credit union applicants if the credit union’s board of directors are elected by the credit union’s members. Along the same lines of those comments provided relating to Question BI21.1, all credit union boards of directors are democratically elected by members of the credit union from among members of the credit union, making this question unnecessary. Question AC-CU03 and Question AC-CU04 of the certification application require credit union applicants to parse all of its members, identifying which, if any, Target Markets each falls into. These questions represent a burdensome and nearly impossible requirement. To understand which eligible Target Market every member of a credit union might fall into, a credit union would need to have access to member income (to qualify the member under a LITP Target Market), or race/ethnicity/disability information (to qualify the member under an OTP Target Market). Credit unions don’t know a member’s income absent a loan application, and don’t know a member’s racial/ethnic information absent a home loan application (which may be requested, but not required from the home loan applicant under the Home Mortgage Disclosure Act. Many credit unions have upwards of 200,000 members, with some credit unions serving over a million consumers. Classifying each of these members into eligible Target Markets without using a statistically valid sample, would make CDFI certification insurmountable for large credit unions. ▪▪▪ Broad public policy should encourage organizations with a community development mission to apply for CDFI certification, which represents a laudable and recognizable credential. We respect the CDFI Fund’s mission of protecting the “CDFI brand” by ensuring that all certified applicants meet reasonable benchmarks, however in several areas where we have provided comments, we believe that the broader public policy could be achieved by giving the CDFI Fund the flexibility needed to identify those organizations with a calling focused on community development, rather than bright line definitions that could exclude organizations with a mission and heart for community development. The CDFI Fund’s proposed certification changes are clearly the product of much time and intensive effort. Thank you for the opportunity to provide our input on this important proposal. As always, if you have any questions concerning these comments, please do not hesitate to reach out. Respectfully yours, Stacy S. Augustine President/CEO

Twenty-five CU Strategic Planning credit unions received nearly $16.7 million dollars in grants to improve their communities from the US Treasury’s Community Development Financial Institutions Fund. It is a labor of love that paid off for the credit union executive teams and CU Strategic Planning's staff. CU Strategic Planning clients represented nearly half of all credit unions receiving the CDFI FA grants and half of all dollars. The big news is how much more CU Strategic Planning clients received than peers. Credit unions working with CU Strategic Planning received an average CDFI Award of $666,420, which is 10.4% more than other credit unions granted Financial Assistance (FA) Awards. According to Mike Beall, CU Strategic Planning's Chief Strategic and Advocacy Officer, "This is significant because it exemplifies the ROI of working with the most sophisticated credit union consulting team in designing the comprehensive business plans which are submitted as award applications. The consulting more than pays for itself." CU Strategic Planning also wrote two of the three largest credit union awards at $900,000 each. Only one loan fund was awarded a grant of $900,000 in the FA awards. “Congratulations to all of the CDFI Grant winners this year,” CU Strategic Planning Founder Jamie Strayer said. “We are particularly proud of our clients, who put in the time, effort and empathy to co-create and execute these award-winning business plans. We love working with all of our credit union clients to help them unlock the potential in their communities.” With the addition of the 2020 CDFI awards, CU Strategic Planning has written 150 award-winning CDFI applications for 97 credit unions. Those credit unions received over $135 million in grants to unlock opportunities to change lives and their communities. "This year's awards show a phenomenal trend for the credit unions CU Strategic Planning has worked with for many years and many first-time credit unions," said Stacy Augustine, CU Strategic Planning's CEO. Pelican State Credit Union won its fifth award, Industrial Credit Union of Whatcom County and Houston Metropolitan FCU each won their fourth awards, and Suncoast, Southwest Louisiana, Peninsula, Innovations and Buckeye State credit unions all won their third awards. "The CDFI Fund recognizes credit unions doing in-depth community development work with our sophisticated plans and guidance." In total, the 2020 CDFI Financial Assistance grants awarded $35.1 million to 55 credit unions. The HFFI Awards and TA awards were also announced. Treasury’s CDFI Fund pairs federal dollars with innovative investments of private sector capital to support mission-driven financial institutions to increase lending and financial services to low income people, minority populations and economically disadvantaged communities. CDFI Financial Assistance awards can be up to $1 million, and they are used to boost usage of products and services, provide new services, expand operations or service new targeted populations. CU Strategic Planning's 2020 CDFI Award-Winning Clients Aneca Federal Credit Union Buckeye State Credit Union Commodore Perry Federal Credit Union Community South Credit Union Empower Federal Credit Union Financial Partners Credit Union First Family Federal Credit Union Guardians Credit Union Hawaii Central Federal Credit Union Heritage Financial Federal Credit Union Houston Metropolitan Federal Credit Union Innovations Federal Credit Union Industrial Credit Union of Whatcom County Lake Trust Credit Union Michigan First Credit Union Pelican State Credit Union Peninsula Community Federal Credit Union REV Federal Credit Union Skypoint Federal Credit Union Sisseton- Wahpeton Federal Credit Union Southwest Louisiana Credit Union Suncoast Credit Union Tallahassee-Leon Federal Credit Union Telhio Credit Union The New Orleans Firemen's Federal Credit Union

HERO is a Community Development-Certified Financial Counseling Program The $9.3 billion Self-Help family of credit unions has contracted with CU Strategic Planning for its HERO Community Development Certified Financial Counseling program. HERO provides training, testing and certification to allow credit union staff to better serve consumers, safely increase lending beyond A and B borrowers to serve more and boost profitability, and cultivate effective partnerships with cooperatives and community organizations to achieve broader community revitalization. “Every staff member at Self-Help will learn steps to take to help members and identify members who are in trouble,” CU Strategic Planning Founder Jamie Strayer explained, “which can include transferring them to the counseling department or skilled loan officers for refinancing predatory loans, transferring them to collections for workout solutions to avoid foreclosures and repossessions.” “Investing in people is part of our mission, and an investment in staff strengthens our ability to make a difference in the broader community,” Melitta Wright, Self-Help director of operations training, said. “The HERO program empowers our staff to identify opportunities to help our members overcome financial barriers and stress and to know when to offer specific asset- and credit-building products.” Self-Help has more than 62 branches nationwide to assist members. “As we champion a strong organizational culture that fosters learning and development, we feel the HERO Certified Financial Counseling training program is an ideal fit,” Wright added. “We’re so humbled that Self-Help has invited CU Strategic Planning into its credit union to help them improve members’ financial stability,” Strayer said. “We truly believe in the power of credit unions to lift up communities that have been historically underserved. Our team is looking forward to working with the team to expand the credit union’s reach to more hard-working consumers who need a hand up and unlocking opportunities for Self-Help.”

Senator Mitch McConnell Senator Richard Shelby 317 Russell Senate Office Building 304 Russell Senate Office Building Washington, DC 20510 Washington, DC 20510 Senator John Kennedy Senator Charles E Schumer 416 Russell Senate Office Building 322 Hart Senate Office Building Washington DC 20510 Washington, DC 20510 Senator Patrick Leahy Senator Christopher Coons 437 Russell Senate Office Building 218 Russell Senate Office Building Washington, DC 20510 Washington DC 20510 Letter in Support of $1 billion appropriation for the CDFI Fund and $5 million for NCUA’s CDRLF Dear Senators: We strongly encourage leadership to include an appropriation of $1 billion for the Department of Treasury’s CDFI Fund in the Coronavirus stimulus bill. This funding will be leveraged by CDFI-certified financial institutions, including credit unions, to provide billions more in targeted lending to low-to- moderate income consumers and very small businesses, and for continued mortgage lending to carry on with the healing of the main street economy. Additionally, we ask Senate leaders to include $5 million for the National Credit Union Administration’s (NCUA) Community Development Revolving Loan Fund (CDRLF). These important appropriations are supported by the U.S. Chamber of Commerce Statement of the Record for the Senate Committee on Small Business made today. Credit unions stand prepared with “shovel-ready” lending programs for housing and very small businesses, and with consumer loan programs that are the lifeblood of our fragile yet improving economy. The CDFI Fund’s initiatives, alongside the other programs identified for this stimulus package, will work hand in hand with CDFI credit union lending to keep working families working, off of unemployment benefits, and in their own homes and cars as the economy continues to improve. We look forward to working with you on the appropriations of these vital programs and will be working closely with the CDFI Fund and NCUA to get these funds into the hands of credit unions for the main street loan programs that are so in need at this important moment. CU Strategic Planning is a women and minority-owned small business that credit unions turn to for strategic business plans to successfully lend to low-to-moderate income families and small businesses. CU Strategic Planning has developed more award-winning CDFI grants for credit unions than any other provider. Our small business of 15 employees has written successful business plans providing funding of more than $120 million for CDFI and low-income and minority designated credit unions to implement in communities across the country, resulting in more than $10 billion in loans to stimulate economies across our great nation. I encourage you to contact me directly with questions or further examples of use of funds from these two important programs at 202.802.0036 or mike@creditunionstrategicplanning.com. Michael V. Beall, Esq Chief Strategic and Advocacy Officer, CU Strategic Planning CU Strategic Planning | 535 Dock Street, Suite 208 | Tacoma, Washington, 98402 253.200.0418 (o) 253.200.5824 (f) | www.creditunionstrategicplanning.com

Credit unions were caught off guard in 2009, during the housing crisis, when the CDFI Fund provided a supplementary grant round and provided secondary capital. CU Strategic Planning is hosting an educational town hall Wednesday, March 25 from 2-3 PM ET to ensure your credit union is prepared should the opportunity arise in response to the COVID-19 pandemic. In response to the housing crash in 2009, the CDFI Fund provided a supplementary grant round and provided secondary capital. CU Strategic Planning, in addition to CUNA, NAFCU, Opportunity Finance Network and CDFI Connect, is advocating for an increase in current funding, a supplemental funding round and raising the NCUA's Community Development Revolving Loan Fund level. Register here to learn how other credit unions are preparing to handle members who are suddenly laid off with empathy while dealing with related risks, build loan loss reserves and access secondary capital. Leading the town hall will be: Ronaldo Hardy, Former CEO of Southwest Louisiana CU and current Chief Diversity and Inclusion Officer/Owner for CU Strategic Planning Sharon Hall, former CEO of Express Credit Union and current CFO/Owner for CU Strategic Planning Mike Beall, Chief Strategic & Advocacy Officer/Owner for CU Strategic Planning During the town hall, attendees will learn: How mainstream credit unions can get access to CDFI funds How CDFI-certified credit unions can prepare How CDFI grant funds can be used for loan loss reserves How to use secondary capital in this unprecedented time