AFSA Comments on CDFI Rules Unfairly Targeting Lenders
This week, AFSA sent comments regarding the Community Development Financial Institutions (CDFI) Fund. The CDFI provides funding to certain eligible financial institutions. The funding process requires funding recipients to report “material events,” including events that cause the recipient to lose funding eligibility.
For our comment letter, we noted that the CDFI has included in its eligibility criteria a 36% Military APR cap on loans along with a list of loan characteristics. Our letter urges CDFI to stop imposing these limits, as these limits are improper for a federal agency to impose and limit the availability of credit in places where state laws allow such loans to exist.
August 28th, 2025
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