1. What should the access to capital and credit report accomplish?

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1 February 28, 2013 Amber Kuchar Associate Program Manager CDFI Fund U.S. Department of the Treasury 1500 Pennsylvania Avenue, NW Washington, DC Dear Ms. Kuchar: The Native CDFI Network is a coalition formed in 2009 to unify Native CDFIs serving American Indian, Alaska Native, and Native Hawaiian communities. Its purpose is to create opportunities to share our stories, identify our collective priorities, and strengthen our industry. NCN s mission is to be a national voice and advocate that strengthens and promotes Native CDFIs creating access to capital and resources for Native people. We are pleased to respond to the CDFI Fund s Request for Comments published in the Federal Register Notice on November 30, What should the access to capital and credit report accomplish? Make a case for the continuation of the Native American CDFI Assistance (NACA) program within the CDFI Fund. Provide investors, funders, policy makers, and other stakeholders with a broad overview of lending and investing challenges and opportunities in Native communities. Document the growth and increased capital needs of the Native CDFI industry since the 2001 Native American Lending Study. Establish a core baseline of data that is updated on a regular basis. Stress the continued need for financial education throughout Native communities, including in schools, workplaces, and other community outreach efforts. Provide data to document Native CDFIs higher than average need for operating capital to sustain enhanced development services to support lending activity to a historically underserved market. 1

2 2. What should be the scope and focus of the report? All Native communities where American Indian, Alaska Native, and Native Hawaiian people live, including communities on or near reservations, Hawaiian trust land, and Urban Indian communities. Capital and credit needs of Native consumers, homebuyers, and businesses. Solutions and successes created by Native CDFIs that serve as models to their peers. Best practices of the community development lending and asset building industries that may be applicable to the Native CDFI industry. Challenges still faced by Native CDFIs and their borrowers, e.g. legal environment, physical infrastructure, workforce analysis, entrepreneurial capacity, ability to collateralize mortgages, lack of private sector providers, etc. Ongoing need for personal finance skills and access to financial institutions in Native communities. Credit needs of the healthy food and agriculture sectors. 3. What are the top three desired outcomes of the report? Evidence of the meaningful impact that Native CDFIs have had since the Native American Lending Study was published in 2001 with providing access to capital, credit, and financial management skills in their communities. Documentation of the ongoing need for lending capital and core operating funds for Native CDFIs for both private and public sectors. Enhancement of the CDFI Fund s NACA program including additional Financial Assistance (FA) funding, Technical Assistance (TA) funding, and capacity building initiatives. 2

3 4. Who are the key users of the report? Native CDFIs Economic development agencies including tribal economic development and business support offices Housing agencies, including Tribally Designated Housing Entities Investment analysts Federal and state agencies Lenders Academic researchers 5. Are there emerging trends, innovative concepts, and promising solutions that could significantly improve capital access and availability and quality of credit in Native Communities that the report should focus on or address? Native CDFIs are emerging as an effective investment vehicle for socially responsible investors to invest in Native communities. Tribal leaders are becoming increasingly more interested in growing private sector economies through tribal citizen-owned businesses rather than focusing exclusively on tribal enterprises. This could potentially lead to more tribal support of Native CDFIs. With the economic and population growth in Native communities, opportunities are expanding for entrepreneurs to meet increased demand for new market sectors such as amenities, entertainment, and social activities. 3

4 Native CDFIs incur high operating costs which they are not able to recoup due to lack of scale. One strategy worth exploring may be shared platforms which might help to defray costs such as loan software, annual audits, marketing, etc. The impact of the Consumer Finance Protection Bureau (CFPB) on the lack of credit and financial services in Native communities is unclear. The proposed study may provide critical data to inform CFPB s future activity. Given the historic lack of financial management skills and access to financial services in Native communities, Native CDFIs have increased need for operating capital to sustain enhanced development services to support their lending products. The Department of Health and Human Services recognized this situation and created the Native Asset Building Initiative which combined sources of lending capital and operating capital into one initiative. This effort serves as a best practice which could be replicated by other federal and private funders. Given that 42 percent of the Native population is under 25 years old, there is a strong need to improve the financial capability and access to credit of young people in Native communities. The impact of technology on access to financial products and services in Native communities is unclear. The study could explore the potential for technology to increase access to capital and credit. 6. How did you or your organization use the Native American Lending Study? Native CDFIs refer to the study in discussions with state, county, and regional economic development and housing agencies to educate them on the unique challenges faced by Native communities. The study provides an introduction to potential partners new to Native communities who are interested in supporting the work of Native CDFIs. 4

5 Native CDFIs cite the study in funding proposals to document the need for capital and credit, lack of existing financial services, low income levels, barriers, and equity gaps. 7. What were the most significant outcomes for you or your organization from the Native American Lending Study? The lending study provides emerging and certified Native CDFIs with broad demographic and socio-economic information to use as baseline data in the analysis of individual Native communities. The study helps Native CDFIs to gain the support of their own tribal leaders as well as other stakeholders, by providing credible information to use to develop strategies and seek funding to support the goals and objectives outlined in those strategies. The study provides regional characteristics of the barriers and challenges faces by Native communities across the country. There was a clear identification of the unique challenges of access to mainstream financial services in Native communities. 8. What were the best elements of how the Native American Lending Study was conducted? Gathering input through such as expansive series of regional in-person workshops. Publishing the proceedings from each of the regional workshops so that they could be used as a reference on the regional level. Compiling a comprehensive summary of barriers and proposed solutions. Collecting and analyzing data through surveys of tribal leaders and financial service providers. Engagement of private sector representatives. 5

6 Thank you once again for this opportunity to provide our comments. NCN would be pleased to assist with organizing additional focus groups to facilitate additional input into the research process. Sincerely, Tanya Fiddler Chairperson 6

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