On December 9, CDFI Fund Director Jodie Harris announced that CDFIs that made PPP loans outside their approved target market(s) during calendar year 2020 will not be required to make target market modifications for purposes of their CDFI recertification.
The letter states: "The CDFI Fund also understands that the emergency nature of loans provided under the PPP may have temporarily distorted the proportion, in dollar and/or number, of Financial Products some CDFIs provided to their identified Target Market(s). In consideration of this, and consistent with the mission of CDFIs, the CDFI Fund will allow all PPP loans originated in any Eligible Market—including those outside of a CDFI's approved Target Market(s)—during calendar year 2020 to be treated as Target Market activity for the purposes of recertification, without the need for a Target Market modification."
Read the full letter.
OFN is glad to see the CDFI Fund respond to industry appeals for modifications in the target market requirements for CDFI PPP lenders. We first reached out to the CDFI Fund in August and again in October. You can read OFN's letters to the Fund (and copies of all our communications with policy makers) on OFN's Public Policy Communications page.
 Eligible Market is defined as (i) a geographic area meeting the requirements set forth in 12 CFR 1805.201(b)(3)(ii), or (ii) individuals that are Low-Income, African American, Hispanic, Native American, Native Hawaiians residing in Hawaii, Alaska Natives residing in Alaska, or Other Pacific Islanders residing in American Samoa, Guam or the Northern Mariana Islands.