The U.S. Treasury’s Emergency Capital Investment Program (ECIP) provides funding to Community Development Financial Institutions (CDFIs) and Minority Depository Institutions (MDIs) to support financing activities in low-income and underserved communities.
As a leader in Treasury program compliance with a long history of working with CDFIs and other community development entities, CohnReznick has the experience and expertise necessary to help program participants navigate ECIP’s programmatic, compliance, and reporting requirements.
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
CohnReznick can assist ECIP funding recipients with the following consulting services:
Advisory and compliance 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
TECHNICAL SUPPORT
- 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
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
- Plus, we provide clients with the full option of outsourcing all their compliance and reporting needs.
Cindy Fang, CPA, Partner, Tax Credit Investment Services Leader
617.603.4524
Regan St.Pierre, Senior Manager, Project Finance & Consulting
617.603.4518
Jennifer Kirkley, Manager, Project Finance & Consulting
410.783.7404
Related Services
Cindy Fang
CPA, Partner, Tax Credit Investment Services Leader, Project Finance & Consulting
View full biography