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A List Of Reasons Your NMTC Application May Have Failed

The Community Development Financial Institutions Fund (CDFI Fund) awarded $5 billion in tax credit allocations to 100 Community Development Entities (CDEs). The allocation awards were announced in September. The amounts allocated to almost 50% (48.1) of pool applicants ranged from $15 million to $65 million. However, this means that over half of the applicants for allocation awards were denied.

Savage & Associates can provide a thorough review of your NMTC application and provide the critical analysis that can help to improve your application  The following is a list of reasons why your application may have been denied.

The Applicant is not certified as a CDE

o be eligible to apply for NMTC Allocations from the CDFI Fund in the Allocation Round, an Applicant must: (a) be certified as a CDE at the time the CDFI Fund receives its NMTC Program Allocation Application; or (b) have submitted a CDE Certification Application in Awards Management Information System (AMIS) by the applicable deadlines. Savage & Associates can help your entity obtain certification as a CDE.

A poor past compliance record

The CDFI Fund considers whether you have complied with the terms and conditions of previous or existing assistance, award, or Allocation Agreements with the CDFI Fund. If your compliance record is poor, it may be a reason that your application for an NMTC allocation was denied.

Remember, if you are a prior award recipient or Allocatee under any other CDFI Fund program, it is highly recommended that you:

a) Submit all required reports by the deadlines specified in the assistance, award, or Allocation Agreements governing your prior awards or Allocations and to comply with all requirements included in the award documents n; and

b) Confirm that any affiliate that is a prior CDFI Fund awardee or Allocatee, has submitted all required reports to the CDFI Fund.

You failed to issue the required minimum amount of QEIs and close a minimum amount of QLICIs from prior allocation(s)

Applicants that have previously received an NMTC Allocation (or whose Affiliates have previously received an NMTC Allocation) are required to demonstrate that they have deployed the required minimum amount of QEIs and closed a minimum amount of QLICIs from their prior allocation(s) to be eligible for a new allocation award. The CDFI Fund will only consider as “issued” those QEIs that have been recorded and finalized. Those listed as “pending” will not be considered. At Savage & Associates, we pride ourselves on the work that we do after you receive your allocation to ensure that you meet all legal and administrative requirements associated with your project(s).

You failed to meet reporting deadlines

Any failure to meet the reporting deadlines outlined in any assistance, award, or Allocation Agreement(s) with the CDFI Fund during the period from October 29, 2019, to the Allocation Application deadline in the Notice of Allocation Authority (NOAA) have five points deducted from their application score. At Savage & Associates, we know that deadlines may be difficult to meet amidst the fast-paced everyday operations of CDE. Savage & Associates can provide the necessary guidance to ensure that you meet all deadlines set forth by any assistance award, or Allocation.

You failed to answer a question or explain a response on the application

The CDFI Fund has sole discretion to deem an Applicant’s Allocation Application ineligible if the CDFI Fund determines that the Applicant did any of the following related to the Allocation Application Assurances and Certifications:

a) Inaccurately responded to a question; or

b) Failed to submit any required written explanation; or

c) Failed to notify the CDFI Fund of any changes to the information submitted between the date of application and the date that the Applicant executed the Allocation Agreement if selected for an allocation award.

If an Applicant cannot certify to one or more questions, it must provide a written narrative explaining why the certification cannot be accomplished, the circumstances, and what the entity is doing to address the failure.

The Applicant submitted attachments that were not requested by the CDFI Fund.

The CDFI Fund only considers attachments that it has requested as part of the review process. The CDFI Fund will not accept any revisions, amendments, or attachments to an application once it is submitted. No materials only accessible through hyperlinks in submitted materials will be reviewed. All required documents must be submitted in AMIS.

Let’s Work Together to Develop our Communities

If you want to learn more about NMTCs, contact Savage & Associates at 215.880.9441 in Philadelphia, or 202.817.3941 in Washington D.C. to arrange a consultation. Dionne Savage can assist you to evaluate the benefits provided by the New Market Tax Credits, Low-Income Housing Tax Credits, C-PACE, Historic Tax Credits programs, and other vital economic development tools that benefit low-income communities throughout the United States. Visit our website at Savage & Associates 24 hours a day, seven days a week for more information.