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CDFI Fund – New Reporting Requirements


Second Quarter 2015

 

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The CDFI Fund recently introduced two new reports as part of the Community Investment Impact System (CIIS). Overviews of these reports – the Sub-CDE Dissolution Report and the QEI Closeout Report – are provided below.

Sub-CDE Dissolution Report

Allocatees received a letter on or around March 16, 2015 notifying them that the long awaited Sub-CDE Dissolution Report is now available through the CIIS portal. Previously, they were instructed to notify the CDFI Fund of sub-CDE dissolutions via email. Allocatees are now required to use this report to notify the CDFI Fund of sub-CDEs that have dissolved or ceased activity after January 1, 2015.

Allocatees that have had sub-CDEs dissolve or cease activity prior to this date are also encouraged to report this activity. The report must include the following information:

  • The date that the sub-CDE was dissolved or the date that it exits the transaction and is no longer controlled by the Allocatee
  • The reason the sub-CDE was dissolved.


The report provides the following options for the reason for dissolution - Completion of NMTC Credit Period, No NMTC Activity, Loss of Control by Allocatee, or Other (which requires additional explanation).

QEI Closeout Report

Allocatees received a letter on or around April 3, 2015 notifying them that the QEI Closeout Report is available through the CIIS portal. This report requires Allocatees to report, at the end of the compliance period, the status of their investments and/or loans and the businesses that were the recipients of those investments and loans.

Allocatees are required to report on QEIs that have reached the end of the compliance period beginning with the 2014 reporting cycle. This report cannot be submitted until after the Allocatee submits its 2014 CIIS report. This report requires a greater amount of information than the Sub-CDE Dissolution Report although some of the fields will be pre-populated based on information provided in the CIIS report.

The report requires information about the use of any loan loss reserves, loan performance, sources of funding for loans that were refinanced, equity conversions, and the status of the business that received the investments and/or loans.

What Does CohnReznick Think?
CohnReznick expects that Allocatees will be pleased to have an official method of notifying the CDFI Fund of sub-CDE dissolutions and the status of QEIs that have completed their compliance period. Guidance for both reports is available on the CDFI Fund’s website. We are also available to answer any questions you may have on either of the reports.

We will keep you informed of any updates to the reports or guidance documents.

Contact

For more information, please contact Jennifer Kirkley, Senior Associate, at 410-783-7404.


This has been prepared for information purposes and general guidance only and does not constitute professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is made as to the accuracy or completeness of the information contained in this publication, and CohnReznick LLP, its members, employees and agents accept no liability, and disclaim all responsibility, for the consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it.
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