Our solutions are tailored to each client’s strategic business drivers, technologies, corporate structure, and culture.
MOVE TO MAXIMIZE PARTICIPATION
ECIP funding – over $8.28 billion invested so far – is intended to enable CDFIs and MDIs to provide loans, grants, and forbearance for small and minority-owned businesses and consumers, especially in low-income and underserved communities disproportionately impacted by COVID-19’s economic effects. Rather than a direct grant, the funding enables Treasury to purchase senior preferred stock, if feasible for the institution, or subordinate debt if not. The funding lowers the CDFI/MDI participants’ cost of capital because it carries a maximum dividend/interest rate of 2% that may be reduced to as low as 0.5% depending on the level of qualified and deep-impact lending.With interest rates rising, which can dampen demand for qualified and deep impact lending, recipients will want to be in the best position to access their ECIP funding. To do this, they will need to:
Prepare their Initial Supplemental Report (ISR) to establish baseline qualified and deep impact lending activity; this must be completed no later than 10 business days before closing on their ECIP investment
Develop program policies and procedures to identify and track their pipeline of qualified lending prospects
Conduct compliance tests to confirm ongoing activity is eligible through the 10-year reporting period
Advisory, compliance, and technical services
CohnReznick can assist ECIP funding recipients with the following consulting services:
Provide affordable housing industry benchmarking data to help assess qualified and deep impact lending activities in local markets
Provide third-party organizational reviews of potential affordable housing syndicators and developers with whom participants may collaborate to achieve increases in qualified and deep impact lending activity
Develop due diligence and documentation procedures to qualify loan activities’ eligibility under the qualified or deep impact lending criteria
Develop internal reporting and asset management procedures to track and monitor qualified and deep impact lending activity
Create ongoing ECIP program compliance procedures to determine whether lending activity satisfies qualified/deep impact lending criteria, including internal compliance reviews or any special or additional requirements
Provide technical assistance and training on tools to geocode eligible addresses
Review eligibility to determine if loans are qualified or deep impact lending
Review participant’s reports prior to submission to the U.S. Treasury: ISR – Qualified Lending Baseline, Ongoing reporting – Quarterly Supplemental Report
Conduct annual quality control reviews of loan activities under this program
Test loan compliance and testing policies and procedures
why cohnreznick?
CohnReznick has a dedicated consulting practice group made up of subject matter experts in the community development finance industry. With a long history of providing compliance, reporting, and/or asset management services to clients who work with federal grant and tax credit programs, including CDFIs, we understand the importance of compliance. Our team is intimately familiar with other government programs, such as the Low-Income Housing Tax Credit (LIHTC), HUD programs, New Markets Tax Credits (NMTC), Paycheck Protection Program (PPP) loans, and CDFI Fund Financial Assistance and Technical Assistance Awards, to name a few.Treasury awards are highly regulated programs with extensive programmatic, compliance, and reporting requirements. Our consulting practice group has extensive experience assisting clients in:
Establishing compliance policies and procedures
Designing and implementing compliance programs/checklists
Training staff in compliance
Evaluating compliance programs
Issuing compliance reports
Providing clients with the full option of outsourcing all their compliance and reporting needs
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