Banking & Credit

CFA submits comments to CDFI Fund on Small Dollar Loan (SDL) Program Application

CFA joined Center for Responsible Lending (CRL), National Consumer Law Center (NCLC), and Americans for Financial Reform Education Fund in submitting comments on the CDFI Fund (Fund) Small Dollar Loan (SDL) Program Application. The comments focus on aspects of the application aimed to ensure that the program is promoting affordable and responsible small dollar loan products. The Fund’s Notice of Funds Availability (NOFA) released in April 2021 clearly evidences the Fund’s thoughtful efforts to help ensure the SDL Program supports only affordable and responsible products, primarily through the Fund’s determination that certain practices will be prohibited for SDL Programs (“prohibited practices“). In addition, the Fund provides that certain practices will be prioritized in the consideration of award determinations (“prioritized practices”). The groups wrote that they generally support this approach, have some suggestions for strengthening it, and urge that, at a minimum, these safeguards not be weakened.