Staying Ready: How Credit Unions Can Maintain CDFI Certification Through Uncertainty

Deadlines don’t pause. Even with Washington in flux, your members still need you, and the choices you make this quarter may shape your CDFI Certification story next year.

Let's step back: CDFI Certification requires maintaining Target Market lending levels above 60% every year. This drives the best practice of continuously monitoring TM lending for compliance with this requirement.

When we looked across clients’ lending patterns, we saw something simple but powerful: mid-year Target Market trends reliably foreshadow year-end results. In other words, if you were on track in June, you would probably finish strong — or, if you were behind, momentum rarely fixed itself without intention.

What this moment asks of leaders

The shutdown is frustrating. Uncertainty tempts us to wait. But CDFI leadership requires staying focused on what we know rather than waiting for uncertainty to be resolved. This is especially true when the mission is having an impact on underserved communities.

Two truths to keep front of mind

• Your annual recertification (ACR) will reflect your 2025 lending. When you file in 2026, that’s the story you’ll be telling — so the lending you book now matters.
• For those not yet Certified, your ability to apply in 2026 will require favorable TM lending in 2025.

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What to do this week

Take a fresh look at your year-to-date Target Market lending. Please reach out if you're not sure how to upload your lending data to our dashboard for an analysis. Be in the know: Are you trending where you want to land?

• If you’re on track: Keep doing what’s working and protect the mix from year-end distractions.
• If you’re behind: Be intentional about Target Market lending in a way that actually moves the needle — targeted outreach, a partner referral push, or a CDFI-qualified participation. These take planning; starting now gives them time to land before the end of the year.

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Don’t wait for the shutdown to end

Headlines and disruptions ebb and flow. We do know with certainty that the requirements for the program are in place and will be the basis of CDFI determination. When you submit your ACR in 2026, it will be based on your 2025 activity, regardless of the headlines. The lending you choose to do — this quarter — keeps you ready for whatever comes next.

If your data suggests you may fall short — or if you haven’t taken a close look yet — let’s talk. We’ll meet you where you are, pressure-test your path to the finish line, and focus on the few steps that matter most right now.