March 30, 2022
President Joseph R. Biden Jr.
The White House
1600 Pennsylvania Avenue, NW
Washington, DC 20500
Vice President Kamala Harris
The White House
1600 Pennsylvania Avenue, N.W.
Washington, DC 20500
Administrator Isabel Guzman
Small Business Administration
409 3rd Street, SW
Washington, D.C. 20416
Re: Support for Critical Reforms to the SBA’s Community Advantage Pilot Program
The Opportunity Finance Network (OFN) and the National Community Reinvestment Coalition (NCRC), along with the undersigned, are writing to express our strong support for the Small Business Administration’s (SBA) proposed reforms to the Community Advantage Pilot Program. The Biden-Harris Administration has made equitable entrepreneurship a cornerstone of its economic agenda. To achieve this, the SBA must deepen its partnership with lenders whose mission aligns with the Administration’s focus on closing the racial wealth gap and fostering a more inclusive economy.
The economic impacts of the pandemic were devastating for small businesses – especially businesses owned by women, people of color, and other business owners that have traditionally lacked access to capital. For many entrepreneurs, mission lenders were a lifeline that helped them access critical relief funding. Community Development Financial Institutions (CDFIs), Community Development Corporations (CDCs), and other mission lenders helped the SBA deliver more than $34 billion in Paycheck Protection Program loans – reaching more underserved borrowers than traditional lenders.
As our nation looks toward economic recovery, the SBA remains an important partner for diverse small businesses and the specialized lenders who serve them. Community Advantage is an underutilized tool that can help mission lenders provide more capital to underserved entrepreneurs. Over the past several months, the SBA has engaged in an unprecedented level of stakeholder outreach – consulting with current and potential Community Advantage lenders to determine ways to reform the program to increase its reach and impact. That collaboration produced a series of proposed regulatory changes that will unlock the program’s potential and help more small businesses access capital.
We are pleased to see SBA implementing critical program reforms including:
- Extending the Community Advantage Pilot Program before it sunsets on September 30, 2022
- Lifting the Community Advantage lender moratorium to allow more mission lenders to access SBA loan guarantees
- Allowing Community Advantage lenders to use the same credit criteria and collateral policies used to underwrite similarly sized non-SBA loans
- Removing the current restriction that prohibits individuals with criminal backgrounds from accessing the Community Advantage program, and
- Increasing the maximum loan size community advantage lenders can make to increase the impact for small businesses
We look forward to continuing to work with you to ensure entrepreneurs have access to the capital needed to start and grow their businesses.
Access to Capital for Entrepreneurs (ACE)
Affordable Homeownership Foundation Inc.
African American Alliance of CDFI CEOs
African American Chamber of Commerce of Montgomery County, Inc.
Albany Community Together (ACT)
AMPAC Business Capital
Appalachian Community Capital
Association for Enterprise Opportunity (AEO)
Association of Women’s Business Centers
Bankers Small Business CDC of California
Brooklyn Alliance Capital Lending Programs
Business Outreach Center Network
California Coastal Rural Development Corp.
Capital Impact Partners
Carolina Small Business Development Fund
CDC Small Business Finance
Center for Rural Affairs
Cherry Community Organization
Coastal Enterprises, Inc.
Common Capital, Inc.
Community Investment Collaborative
Cooperative Fund of the Northeast
DC Women’s Business Center
Delaware Community Reinvestment Action Council
Detroit Development Fund
Devotion USA, Inc.
Evergreen Business Capital
Fair Finance Watch
Family Housing Advisory Services
FORGE Community Loan Fund
Georgia Advancing Communities Together, Inc.
Harlem Entrepreneurial Fund
Hmong Wisconsin Chamber of Commerce
Homeownership Council of America
Housing Opportunities Made Equal of Greater Cincinnati
Impacto Fund Inc.
Jane Place Neighborhood Sustainability Initiative
La Fuerza CDC
Local Enterprise Assistance Fund (LEAF)
Michigan Oncology Quality Consortium
Micro Enterprise Services of Oregon (MESO)
Mustard Seed Development Center
National Association for Latino Community Asset Builders (NALCAB)
National Community Reinvestment Coalition
National LGBT Chamber of Commerce
National NeighborWorks Association
Neighborhood Community Development Fund
NeighborWorks Western Pennsylvania
New Town Loans, LLC
Opportunity Finance Network
Pacific Asian Consortium in Employment (PACE)
Pacific Coast Regional Small Business Development Corporation
Pacific Community Ventures
Partner Community Capital, Inc.
Pathstone Enterprise Center, Inc.
People Trust Community Loan Fund
Philadelphia Association of Community Development Corporations
Public Private Strategies Institute
Small Business Majority
Social Impact Strategies Group
South Dallas Fair Park Innercity Community Development Corporation
Southern Dallas Progress CDC
St. Petersburg Neighborhood Housing Services, Inc. dba Neighborhood Home Solutions
TMC Community Capital
TruFund Financial Services, Inc.
U.S. Black Chambers, Inc.
Universal Housing Solutions CDC
US Hispanic Chamber of Commerce
Utah Microloan Fund
Washington Area Community Investment Fund (WACIF)
Wisconsin Women’s Business Initiative Corporation (WWBIC)
Women’s Economic Ventures
Women’s Opportunity Resource Center