Community Development Financial Institutions (CDFI) Fund

Transcription

1 Community Development Financial Institutions (CDFI) Fund Community Investment Impact System (CIIS): NMTC/CDE NMTC Coalition June 7,

2 CIIS CDE Reporting: Presentation Agenda CIIS 9.0 Changes Census Data Update and CIMS Problem with Current Reporting for Multiple-CDE Investments in Same Project CDFI Fund s Objectives Background on Data Collection Diagnosis of Problems Proposed Solutions/Requirements for CIIS 9.1 2

3 Changes in CIIS 9.0 for CDE ILR/TLR Reporting TLR CDE questions added on fees, compensation and profits charged to Investors, Borrowers/Investees, and other Entities: Front-end, on-going and back-end fees, compensation and profits; (i.e. origination fees, brokerage fees, legal fees, closing costs, guarantee fees, etc). Expressed in basis points. Total QEI Proceeds Retained by the CDE 3

4 9.0 Change: Business Description to Primary and Other with details required for all QALICBs Old (CIIS 8.1) New (CIIS 9.0) FOODRETAIL (Restaurants, hotels, food services, or other retail space) RETAIL (Includes restaurants) HOTEL FOOD (Includes groceries, bakeries, food wholesalers, farmers markets. Please note if this is a healthy food type project use the Business Description Other fields below to provide additional detail on the project.) OFFICE INDUSTRIAL HOUSING HEALTH COMMUNITY ARTS OTHER (No equivalent) OFFICE INDUSTRIAL HOUSING HEALTH COMMUNITY ARTS OTHER MIXEDUSE (Includes combinations of office/retail, housing, and community spaces. For mixed-use projects with a food component, this component should be described in Business Description-Other. ) 4

5 CIMS Update: Census Data 2010 and American Community Survey (ACS) 5-Year Estimates The CDFI Fund has a three-step plan to update its Census-based program eligibility criteria by next year, relying on: The 5-Year ACS estimates which replace the decennial long form and provide key socioeconomic data for program eligibility (poverty, income, etc.). New Census tracts to be released in December 2011 (increasing from 66,000 to 74,000 tracts). First, two contractors are currently analyzing the first 5-year ACS for (released Dec. 2010) to assess how program eligibility has changed for current tracts and to review program criteria. Note, the first ACS 5-year estimates are NOT benchmarked to new 2010 head count. Second, analyze the next ACS for (expected Dec. 2011) which will be benchmarked to the 2010 head count and the new Census tracts. Third, the CDFI Fund will issue an RFP for new software platform for deploying a new Community Investment Mapping System (CIMS) incorporating the ACS data ( ) and new Census tract boundaries. 5

6 CIMS Policy Issues 1.Refresh once every five-years? 2.Grandfathering rules for investment area definitions of eligible tracts/projects? 3.Review distress criteria for programs and options? 4.Non-metro definitions, program targets and options? 6

7 Problem with Current Reporting for Multiple-CDE Investments in Same Project Background of the issue: Multiple Community Development Entities (CDEs) are investing in a single NMTC Project but are often reporting separately with inconsistent data in reporting fields: Different Total Project Cost; Adjustment over time; Different project phases; Addresses Issues and non-geocoded addresses; Project Numbers and IDs are inconsistent and vary over time; Different Outcomes. As a result, The CDFI Fund has found that it cannot readily and reliably link and track the relationships between these CDE s investments and the project s outcomes. 7

8 CDFI Fund s objectives in addressing projects with Multiple CDE investments Provide consistent operational definitions and tools for reporting on a unique NMTC Project when there is multiple CDE investments. Clarify business rules to define roles and responsibilities and eliminate ambiguities in reporting, including potential over/under counts. Conduct outreach to comment on proposed solutions. 8

9 Background on Data Collection and Issue The NMTC program collects data annually from CDEs through the Transaction Level Report in the Community Investment Impact System (CIIS). The CDFI Fund had previously tried to correct this problem with a disbursement address but that approach proved unworkable. The previous attempt at a solution was not vetted by discussions with users. Outreach to help assure a successful solution. 9

10 Diagnosis of Inconsistent Multi-CDE Reporting Different Project Phases vs. Project Succession at same Address. Differing Business Descriptions. Slight Address Discrepancies Across CDEs Project phasing or project succession may account for some of the variation. Inconsistent Total Project Costs: Total project costs often differ slightly and may change over time. Project phasing may contribute to variation in total costs. Current Project Numbers and Project IDs have been changed by software vendors making it difficult to link organizations and projects over time. 10

11 Example of a Multi-CDE Project in CIIS One Address, Four CDEs, Four Descriptions, Four Project Costs Year Allocatee Business Description Address QLICI Amount Total Project Cost 2008 Washington CDE Mixed Use Hotel - Commercial 567 N Main $ 1,138,470 $ 82,297, Washington CDE Mixed Use Hotel - Commercial 567 N Main $18,389,450 $ 82,297, Washington CDE Mixed Use Hotel - Commercial 567 N Main $ 9,700,877 $ 82,297, Washington CDE Mixed Use Hotel - Commercial 567 N Main $ 7,140,000 $ 123,767, Washington CDE Mixed Use Hotel - Commercial 567 N Main $ 4,935,617 $ 123,767, Washington CDE Mixed Use Hotel - Commercial 567 N Main $ 4,800,000 $ 123,767, Lincoln CDE Owner of Real Estate 567 North Main $ 1,659,473 $ 102,517, Lincoln CDE Owner of Real Estate 567 North Main $ 3,145,775 $ 102,517, Lincoln CDE Owner of Real Estate 567 North Main $ 194,752 $ 102,517, Jefferson CDE Hotel 567 North Main Street $ 1,659,473 $ 102,517, Jefferson CDE Hotel 567 North Main Street $ 3,145,775 $ 102,517, Jefferson CDE Hotel 567 North Main Street $ 194,752 $ 102,517, Roosevelt CDE Mixed Use Real Estate 567 North Main Street $10,898,987 $ 123,767,268 11

12 Proposed Solution for CIIS 9.1 TLR Reporting Create a Multi-CDE Project Number in the TLR that will be used for the life of the project by each CDE involved in the project. CIIS will provide tools for managing Multi-CDE project reporting based on one of two options: 1. Lead-CDE model to report all project outcomes and total project costs; 2. Coordinated approach with each CDE reporting its own activities but agreeing to total project costs and outcomes. CIIS will create a single group project number that starts with MC (8 digits). Login into CIIS and select from drop down menu to setup Projects with multiple CDE investments. From a drop down box the user selects the name of the other Organizations that are involved within the Project. 12

13 Proposed Solutions for Multi-CDE Reporting Roles and responsibilities for resolving reporting inconsistencies among CDEs: CIIS contractor through cleansing process; Lead CDE or Coordinating Group to manage Multi-CDE projects; CDFI Fund through compliance and FS&R; Managing Entry/Exit of CDEs. 13

14 CIIS Mock Up of Report 14

15 Key Reporting Requirements for Solution Same Multi-CDE Project Number must be used by all CDEs involved in a Multiple CDE Project. Each CDE s Initial CIIS reports should identify all CDEs expected to be involved in project. Since Total Project Costs can (and sometimes do) change year by year, CDEs must use a consistent method for reporting Total Project Costs. Define business rules for reporting outcomes by each CDE participating in the Multiple CDE Project. Made at time of QLICI. Align CDEs reports in advance of annual reporting. 15

16 Wrap Up Feedback? Other Issues? 16

17 Contact Information Greg Bischak, Ph.D. Program Manager, Financial Strategies & Research Community Development Financial Institutions 601 Thirteenth Street, NW, Suite 200 South Washington DC, Phone: