CDFI Connect Community Discussions

Subscribe to CDFI Connect Community Discussions feed CDFI Connect Community Discussions
View RSS Feed from Opportunity Finance Network
Updated: 27 min 9 sec ago

RE: Are CDFIs required to have Know Your Customer and Anti-Money Laundering policies?

Thu, 2019-02-07 09:29
From : Communities>>Open Forum
Thanks so much to you all for the feedback, it has been a tremendous help in determining our needs. ------------------------------ Shane Simmons People, Inc. Financial Services Abingdon VA (276) 623-9000 ------------------------------

RE: Collection, Repossession and Default Rate

Wed, 2019-02-06 17:25
From : Communities>>Open Forum
Hello Bee,  As a small business lender in New York City these are our procedures and practices:  1.) Attached is an excerpt of our monitoring and collection procedures within our general lending policy.  2.) We do not require collateral for loans less than $10K so we do not encounter many asset recovery scenarios, however, we do require a personal guarantor and signed confession of judgement for all loans as well as a general UCC filing on business assets for loans above $10K. Our collection process [More]

Files Attached Document
RE: Collection, Repossession and Default Rate

RE: Are CDFIs required to have Know Your Customer and Anti-Money Laundering policies?

Wed, 2019-02-06 15:43
From : Communities>>Open Forum
My read of Fincen is CDFIs do fall under BSA, AML and OFAC (KYC regulaltions) compliance, and the larger banks are requiring compliance from us (incoudes staff and Board training,.a board-approve dpolicy and a board-designated Officer(s)). Doing an internal risk assessment defines the areas where you need active compliance, though much of it doesn't apply. F'or example, we do not accept cash (except for tickets to events, but there's a $ limit), cash checks, provide third-party wires, take deposits [More]

RE: Car liens

Wed, 2019-02-06 14:46
From : Communities>>Open Forum
Thank you everyone for the input.  Just want to clarify that we are primarily looking into this procedures for our small business loans (up to $75K) for two scenarios: (1) To purchase a vehicle for car service/taxi purposes and (2) Refinancing car loans with high interest rates.  Heather -- When you say an extra procedure to perfect collateral, is this for either of these scenarios?  Or is the vehicle used as general collateral for your general purpose loans? ------------------------------ Jessica [More]

Accion is Hiring!

Wed, 2019-02-06 12:24
From : Communities>>Open Forum
Join me! Accion currently has three positions open on our Advancement Team: Manager of Philanthropy (MOP) (Albuquerque-based), Senior Grant Writer and Grant Writer (location open, with preference for one of our 5 states AZ, CO, NV, NM, TX). The titles are pretty self-explanatory, but in brief, the Manager of Philanthropy will build and maintain the pipeline for our grants, investments, and donations, manage calendar for submissions and reporting, oversee team with responsibilities for both individual [More]

RE: CDFI Fund FA Awards: Revenue Recognition

Wed, 2019-02-06 12:21
From : Communities>>Open Forum
OFN's Performance Counts report on presentation of grants addresses this issue as well, and generally recommends that CDFI Fund FA awards be treated as unrestricted (not even temp restricted).  "Grants that are for a CDFI's financing in general (which include loan capital, loan operations, loan loss reserves, etc.)-with no other restrictions-should be classified as unrestricted. Because a CDFI's main business activity is financing, GAAP provides enough flexibility to allow these grants to be treated [More]

RE: Are CDFIs required to have Know Your Customer and Anti-Money Laundering policies?

Wed, 2019-02-06 11:10
From : Communities>>Open Forum
Exactly - for regulated financial institutions. ------------------------------ Jason Friedman Principal Friedman Associates 319-341-3556 jasonj@friedmanassociates.net www.friedmanassociates.net ------------------------------

RE: Are CDFIs required to have Know Your Customer and Anti-Money Laundering policies?

Wed, 2019-02-06 11:06
From : Communities>>Open Forum
Go Robin! Exception Number 1.​​ ------------------------------ Jason Friedman Principal Friedman Associates 319-341-3556 jasonj@friedmanassociates.net www.friedmanassociates.net ------------------------------

RE: Are CDFIs required to have Know Your Customer and Anti-Money Laundering policies?

Wed, 2019-02-06 11:04
From : Communities>>Open Forum
This is a great discussion, which highlights the different environment that regulated and non-regulated CDFIs operate in.  Non-regulated CDFIs are not required to have these policies as part of an industry standard PPM; neither do their core public funders at all levels of government. However, some govt contracts make you sign statements saying that you don't lend to terrorist groups, for example. Cool. We understand that regulated institutions have really strict anti money laundering policies.  [More]

RE: Are CDFIs required to have Know Your Customer and Anti-Money Laundering policies?

Wed, 2019-02-06 10:34
From : Communities>>Open Forum
Our State Financial Institutions Division says we do. They regulate and license us as a mortgage lender. I am not aware of any exemption for CDFIs. ------------------------------ Mark Vanderlinden Chief Lending Officer Homewise Santa Fe NM ------------------------------

RE: Are CDFIs required to have Know Your Customer and Anti-Money Laundering policies?

Wed, 2019-02-06 10:31
From : Communities>>Open Forum
The CDFI Fund doesn't require it but as a single family loan fund we are regulated by our State which requires us to have this policy along with several others. ------------------------------ Robin Coffey Chief Credit Officer Neighborhood Lending Services, Inc. Chicago IL 773-329-4134 ------------------------------

Collection, Repossession and Default Rate

Wed, 2019-02-06 10:19
From : Communities>>Open Forum
Microlenders and CDFI's please share what works for your organization and what you can suggest. 1. What is your policy for collection? 2. How do you handle asset recovery? Do you hire outside third party or handle it in-house? 3. The balance between access to capital and risk management is often translated into the default rate. What works for you and what was your 2018 year end default rate? Anything anyone can share will be greatly appreciated! ------------------------------ Bee Vang Neighborhood [More]

RE: Are CDFIs required to have Know Your Customer and Anti-Money Laundering policies?

Wed, 2019-02-06 10:10
From : Communities>>Open Forum
I would just add that if the Treasury Department or Department of Justice have a reason to investigate a CDFI customer and find that the CDFI did not have KYC/AML policies and procedures in place, the lack of a direct requirement to have them will not serve as protection. See Mr. Arena's post for further confirmation. ------------------------------ William Sutherland President TransPecos Development Corporation San Antonio TX 2102284444 ------------------------------

RE: Are CDFIs required to have Know Your Customer and Anti-Money Laundering policies?

Wed, 2019-02-06 09:34
From : Communities>>Open Forum
Shane, Jason, The KYC (customer due diligence) requirements of 31 U.S.C. § 5318(j) and (l) apply to "Financial Institutions" and the applicable definition is reproduced below. Review this carefully in light of your CDFI's licensing regime and board-approved activities, and discuss with your legal advisor any ambiguities. Todd financial institution (2)"financial institution" means- (A)an insured bank (as defined in section 3(h) of the Federal Deposit Insurance Act (12 U.S.C. 1813(h))); (B)a commercial [More]

RE: Are CDFIs required to have Know Your Customer and Anti-Money Laundering policies?

Wed, 2019-02-06 09:04
From : Communities>>Open Forum
Jason, Thanks so much for your reply and the information, I really appreciate it greatly. ------------------------------ Shane Simmons People, Inc. Financial Services Abingdon VA (276) 623-9000 ------------------------------

Accion is Hiring!

Tue, 2019-02-05 15:52
From : Communities>>Open Forum
Join me! Accion currently has three positions open on our Advancement Team: Manager of Philanthropy (MOP) (Albuquerque-based), Senior Grant Writer and Grant Writer (location open, with preference for one of our 5 states AZ, CO, NV, NM, TX). The titles are pretty self-explanatory, but in brief, the Manager of Philanthropy will build and maintain the pipeline for our grants, investments, and donations, manage calendar for submissions and reporting, oversee team with responsibilities for both individual [More]

RE: CDFI Fund FA Awards: Revenue Recognition

Tue, 2019-02-05 14:46
From : Communities>>Open Forum
We apply the treatment how Daniel from MN explained.  Recognized as a receivable & deferred revenue upon award.  Recognized as revenue when deployed as it is a restricted contribution.  I am going to a breakfast seminar tomorrow about the rev rec pronouncement and will ask their opinion. ------------------------------ Cyndi Barber, CPA Director of Finance & Administration Network for Oregon Affordable Housing cyndib@noah-housing.org 503 501 5542 office 503 730 7486 cell ------------------------- [More]

RE: Are CDFIs required to have Know Your Customer and Anti-Money Laundering policies?

Tue, 2019-02-05 13:57
From : Communities>>Open Forum
Hi - not required by the CDFI Fund or other public funders as a requirement for certification or compliance with award agreements.  Also, Loan Review Committee and Board would be an appropriate check and balance, as they approve loan policies and procedures.  Good luck! ------------------------------ Jason Friedman Principal Friedman Associates 319-341-3556 jasonj@friedmanassociates.net www.friedmanassociates.net ------------------------------

RE: CDFI Fund FA Awards: Revenue Recognition

Tue, 2019-02-05 13:18
From : Communities>>Open Forum
I know there is debate around this issue but here is how we have recognized CDFI FA revenue that has been reviewed and approved by our auditors. The grant is recognized at the time of award notice as a grant receivable.   The General Award Terms and Conditions state that the disbursement of funds should be recognized as an advance until the recipient expends the funds for the activities authorized under the assistance agreement.  As such,  we recognize revenue as the grant funds are expended for [More]

Vice President of Community Development Lending

Tue, 2019-02-05 12:56
From : Communities>>Open Forum
As a high performing CDFI with a growing pipeline and expansion into CD lending, Ohio Capital is seeking to fill a new position with an energetic and knowledgeable Vice President of Community Development Lending.  The VP will be responsible for originating and evaluating risks associated with community development and affordable housing real estate while creatively developing solutions to complex financing, underwriting and closing issues.  This person will manage, coordinate and execute the lending [More]

Files Attached Document
Vice President of Community Development Lending

Pages