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1/16/2024

Update on Treasury’s Approach to Equitable Community Finance | U.S. Department of the Treasury

Update on Treasury’s Approach to Equitable Community
Finance
January 16, 2024

Graham Steele, Assistant Secretary for Financial Institutions
Over the past few years, the field of community finance has been transformed both by the
historic scale of federal investments and policies focused on supporting equitable economic
growth. During the Biden-Harris Administration, the Treasury Department has focused on
unlocking the economic potential of financially underserved communities across the country.
Secretary Yellen has outlined an economic strategy called “modern supply-side economics,”
which calls for, among other actions, boosting economic productivity by addressing inequality
and making investments in people, places, and infrastructure that have been constrained by a
lack of resources and opportunity. Treasuryʼs community finance programs have played an
important role in this overarching strategy, and we are seeing results in financially
underserved communities across the country, from increases in lending in the most
economically disadvantaged areas to new clean-energy investments in low-income
communities. In December 2022, I provided an overview of Treasuryʼs approach to community
finance policy. I am now pleased to provide an update on how Treasuryʼs community finance
related e orts are supporting underserved communities throughout the country.
***
Since early 2021, Treasury has implemented programs that have made available a historic
amount of funding to mission-driven organizations to open access to capital for financially
underserved borrowers and economically distressed geographies.
Through the Emergency Capital Investment Program (ECIP), Treasury made more than $8.5
billion in investments in 175 community financial institutions to support lending to small
businesses and consumers, especially in low-income, minority and financially underserved
communities that struggled during the COVID-19 crisis.
The CDFI Fund has delivered $3 billion in funding to address the economic impacts of the
COVID pandemic through the Rapid Response Program and the Equitable Recovery Program.
In addition, since early 2021, the CDFI Fund has:
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Made nearly $1.4 billion in grants through its flagship Financial Assistance program, the
Bank Enterprise Awards, the a ordable housing-focused Capital Magnet Fund, and the
Small Dollar Loan Program;
Provided more than $755 million in guarantee authority under the CDFI Bond Guarantee
Program; and
Made $15 billion in tax credit allocations under the New Markets Tax Credit (NMTC)
Program.
The State Small Business Credit Initiative (SSBCI), run by Treasuryʼs O ice of Capital Access,
has approved capital program plans from 54 states and territories for more than $8.2 billion in
funding and nearly $251 million in funding for Tribal government capital programs. SSBCI has
also made available approximately $400 million for technical assistance to support small
businesses and underserved minority entrepreneurs. CDFIs are playing a prominent role in the
implementation of many capital and technical assistance SSBCI programs.
The Inflation Reduction Act (IRA), the CHIPS and Science Act, and the Bipartisan Infrastructure
Law complement these e orts, presenting new opportunities to scale community finance. For
example, the IRA authorized the U.S. Environmental Protection Agency (EPA) to implement the
Greenhouse Gas Reduction Fund (GGRF), a $27 billion investment to “finance clean energy
projects that reduce pollution and energy costs, increase energy security, and create goodpaying jobs, especially in low-income and disadvantaged communities and places that have
historically shouldered the burden of harmful pollution.” In July of 2022, EPA launched $20
billion in grant competitions under the GGRF. Also, in October, Treasury and the Department of
Energy opened applications for the IRAʼs Low-Income Communities Bonus Credit, which
provides a 10- or 20-percentage point boost to the investment tax credit for qualified solar or
wind facilities in low-income communities.
***
Treasuryʼs approach to community finance policy has been cra ed to advance broad-based
equitable growth, a key goal of Treasuryʼs Strategic Plan

, and has been deeply informed by

Treasuryʼs O ice of Racial Equity and the O ice of Tribal and Native A airs. The following six
key principles have served as a foundation for this approach to equitable community finance:
Establish responsible financing standards – In December 2023, Treasuryʼs CDFI Fund published
a significant update to the CDFI certification application and process. The CDFI Fundʼs
previous certification application did not do enough to distinguish a CDFI with a community
development mission from other lenders without such a mission. The past three years have
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seen a historic level of investment in CDFIs, and without clear definitions and guardrails, there
is a risk that resources intended to support community development could be misused or
used less impactfully than intended. The revised CDFI certification application now identifies
responsible financing standards for CDFIs, including a specific list of products and services
that are inconsistent with CDFI certification. The application also provides greater clarity
about how an applicant for CDFI certification will be determined to be accountable to its
target market, the area where it is required to focus its financing activity.
Di erentiate “deep impact” lending to the most underserved communities – In its
implementation of ECIP, Treasury defined and prioritized lending to the most underserved
communities, or “deep impact” lending. The idea of deep impact lending reflects an
understanding that there can be financial disincentives for lending to the most underserved
borrowers. Deep impact lending

includes financing for borrowers that are financially

underserved or located in an economically distressed community and for which a community
lender may need to spend more time and resources to prepare the borrower, or that may
result in less revenue for the community lender because the borrower may need a smaller loan
with concessionary terms. In this way, Treasury has focused public community finance
resources on prioritizing borrowers and areas that experience the greatest challenges in
accessing capital. Treasury has published data about the deep impact lending of ECIP
participants. The CDFI Fund has applied a similar approach in its programs, including in the
CDFI Equitable Recovery Program

.

Collect more disaggregated demographic data – Because we know that peopleʼs
experiences in the financial services marketplace are shaped by their race, gender, and other
demographic characteristics, by collecting disaggregated demographic data we can better
understand how community lenders are impacting diverse segments of a financially
underserved community. For example, jurisdictions participating in SSBCI will report
demographic information collected from small businesses that receive capital through the
program, including data on race, ethnicity, sexual orientation, and gender identity. Further, in
the new CDFI certification application, the CDFI Fund will collect data on the race and
ethnicity of board members and executive leadership of CDFIs, which will help the CDFI Fund
to better understand how the leadership of CDFIs reflects the communities that they serve.
Encourage equitable community engagement – By encouraging equitable community
engagement, we are helping recipients of Treasury funding align their own policies and
strategies with the needs and context of the beneficiaries they seek to serve. Examples of
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encouraging equitable community engagement can be found in the requirement that ECIP
applicants submit a plan for community engagement and in the requirements of the
competition for NMTC

.

Support capacity building – Treasury recognizes that opening access to capital for the most
financially underserved borrowers o en requires significant investments in building the
capacity of those borrowers and of their lenders. For example, the CDFI Fund established the
NMTC Native Initiativeto broaden the on-ramp to the NMTC program. The goal of the NMTC
Native Initiative is to increase NMTC investments in Federal Indian Reservations, O Reservation Trust Lands, Hawaiian Homelands, and Alaska Native Village Statistical Areas,
collectively referred to as NMTC Native Areas. Similarly, the SSBCI Technical Assistance Grant
Program is making available funding to provide legal, accounting, and financial advisory
services to very small businesses and underserved businesses applying for SSBCI capital
programs and other government small business programs.
Coordinate with interagency partners and the private sector – Treasury is not doing this
work alone. Our approach to community finance is aligned with interagency policy e orts
including the White Houseʼs e orts on Urban Equitable Development, Rural Prosperity and
Housing Supply. In July 2022, Treasury and other federal agencies established the Interagency
Community Investment Committee

(ICIC) to facilitate the flow of resources into

underserved communities across the country by better aligning federal community
investment programs and attracting aligned private-sector investments. Treasury chaired the
ICIC in its first year, and in June 2023, the ICIC released an action plan

to define and guide

the collaborative e orts of the participating federal agencies. Treasury has also engaged with
the private sector, including the Economic Opportunity Coalition (EOC), an e ort among some

of the nationʼs largest companies and foundations that have committed to aligning major
investments in underserved communities with investments made by the Biden-Harris
Administration.
***
Investing in financially underserved communities is essential to our shared economic growth
and prosperity. Treasuryʼs intentional approach to promoting equitable investment has
opened access to capital to applicants that have struggled in the past to secure federal
community finance resources. For example, through ECIP, Treasury has invested
approximately $1.4 billion in Black-designated minority depository institutions (MDIs). In April
2023, $226 million in Equitable Recovery Program grant awards were made to 69
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coopertivas in Puerto Rico. In September 2023, the CDFI Fund announced its latest,
highly competitive round of NMTC allocations, which included $100 million allocated to
Native Community Development Entities.
We are beginning to see quantifiable results from these e orts. In October 2023, Treasury
announced that the first round of ECIP reporting

showed that in approximately the last six

months of 2022, one-third of total originations by ECIP participants were “deep impact” loans,
made to the hardest-to-serve borrowers, totaling approximately $8.5 billion. In December
2023, Treasury, the IRS, and the Department of Energy announced that in the initial application
period for solar and wind facilities through the IRAʼs Low-Income Communities Bonus Credit
Program, the program received more than 46,000 applications for new energy facilities
located in low-income communities, on Indian land, as part of a ordable housing, or directly
benefitting low-income households, representing more than 8 gigawatts of generation
capacity. Also, a recent Treasury analysis showed that, since the passage of the IRA, clean
investments have been landing in more economically disadvantaged counties, including areas
with a history of fossil fuel production.
Treasuryʼs approach to community finance policy is not only shaping the delivery of tens of
billions of dollars in federal funding. It is also influencing the private-sector investments that
are leveraging those federal dollars. There are opportunities for private and philanthropic
investors to “crowd in” and consider this policy framework and to learn from the data these
programs produce. For example, at Treasuryʼs 2023 Freedmanʼs Bank Forum, the EOC
announced a $3 billion commitment by its members to make deposits in CDFIs and MDIs, a er
having previously achieved the $1 billion commitment that they announced at the 2022
Freedmanʼs Bank Forum.
Treasury is committed to seeking further data and lessons about the impacts of its
community finance programs, and Treasuryʼs Economic Recovery Learning Agenda
provides detail on our approach.
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