FDIC-insured depository institutions seeking CRA credit opportunities may be eligible to apply for funding to further impact the distressed communities they serve. On March 31, 2023, the Department of Treasury’s Community Development Financial Institutions Fund (CDFI Fund) opened its fiscal year 2023 funding applications for its Bank Enterprise Award (BEA) Program. This year’s program includes up to $70 million in awards available to qualifying FDIC-insured depository institutions, which are to be invested in future “qualified activities.” Qualified activities are broken down into three categories:
- CDFI-Related Activities – Equity Investments, Grants, Equity-Like Loans, Loans, Deposits, and/or technical assistance provided to Certified CDFIs
- Distressed Community Financing Activities – Affordable Housing Loans, Affordable Housing Development Loans and Project Investments, Commercial Real Estate Loans and related Project Investments, Education Loans, Home Improvement Loans, Small Business Loans, or Small Dollar Loans to residents or businesses located in distressed communities
- Service Activities – checking accounts, savings accounts, check cashing, financial counseling, individual development accounts, or youth savings accounts provided to residents of distressed communities
Substantive changes to the FY 2023 BEA Program include an expansion of the applicable baseline and assessment periods, a new application format allowing applicants to electronically bulk upload transactions, and updated BEA Program eligibility data.
Depository institutions that have been federally insured since at least January 1, 2020, are eligible to apply. Award amounts align with an applicant’s increase in qualified activities from one annual period to another and are based on the qualified activity type, the CDFI Certification status of the applicant, and the asset size of the applicant. Importantly, an applicant may not receive a FY 2023 BEA Program Award if the applicant:
- Has been awarded assistance from the CDFI Fund or program within the 12 months prior to the federal award date of the FY 2023 BEA Program Award Agreement;
- Has received assistance under the CDFI Program based on the same activities during the same period for which it is seeking a FY 2023 BEA Program Award; or
- Has received assistance from another CDFI Fund program or federal program based on the same activities during the same period for which it is seeking a FY 2023 BEA Program Award.
Depending on the geography of the activities, BEA qualified activities may receive favorable consideration under the CRA.
FDIC-insured depository institutions interested in applying for the program will need to have key information and account access for several federal government websites, including SAM.gov, grants.gov, and AMIS. Part I of the application requires completion of the SF-424 Mandatory Form, which must be submitted though grants.gov by May 2, 2023. Part II consists of the FY 2023 BEA Program electronic application available through AMIS and must be submitted by June 1, 2023. Program awards are expected to be announced during Fall 2023. Bradley’s banking team will continue to monitor the CDFI Program website throughout the application period.
