HOPE Submits Public Comment on Opportunities and Challenges in Federal Community Investment Programs

February 7th, 2023

December 15, 2022

Throughout HOPE’s 25-year history, federal programs have been critical to the fulfillment of the organization’s mission. Federal programs represent one of HOPE’s most effective tools available to leverage private dollars through member deposits, corporate investments, and philanthropic support. Organized around the questions posed in a Request for Information (RFI) called for by the Interagency Community Investment Committee (ICIC), HOPE has provided insights on the challenges and opportunities associated with HOPE’s experience in using federal programs to strengthen communities and improve the lives in the Deep South.

The ICIC is a collaboration of the Department of the Treasury (Treasury), Small Business Administration (SBA), Department of Commerce (Commerce), Department of Transportation (DOT), Department of Housing and Urban Development (HUD), and the Department of Agriculture (USDA), that focuses on federal programs that facilitate the flow of capital and the provision of financial resources into historically underserved communities, including communities of color, rural communities, and Tribal nations. They requested public comments on how they “can promote economic conditions and systems that reduce racial disparities and produce stronger economic outcomes for all communities.”

HOPE’s comment outlined key opportunities and challenges from the Emergency Capital Investment Program, the New Markets Tax Credits program, the Rapid Response Grant program, the Paycheck Protection Program, and several other federal programs. The comment also underscores the importance of Minority Depository Institutions (MDIs) and Community Development Financial Institutions (CDFIs) with long track records of reaching underserved communities and communities of color to ensure federal funds reach communities in need. CDFIs and MDIs, long on the front lines of meeting the financial needs of underserved communities, continue to serve as important drivers of economic mobility in rural economies and among people of color.

HOPE also called for increased accountability for each program’s impact on racial equity. Accountability should begin with data reporting and transparency by federal agencies and their grantees, including information on who is ultimately benefiting from the programs, specifically by race, ethnicity, and gender. Financial and technical support should be provided for grantees with limited resources to collect and report such data.

The design, structure, reporting, and accountability measures must be in place for all federal programs to ensure capital works to end wealth and capital access gaps rather than widening them. This RFI represents an important first step in strengthening our system of federal investment to advance community development outcomes.

HOPE’s full comment is available here.