1. The Treasury Department and the SBA should set aside 5% of the Paycheck Protection Program appropriation for underserved small businesses and nonprofits to be deployed by CDFIs lenders that have a track record of effectively serving these populations. A set aside deployed through CDFIs is the only way to ensure, in the rush to access funding, that underserved small businesses and nonprofits will not be left out of this program.
2. The SBA should provide “Delegated Authority” to additional lenders that have a track record of opening access to capital for underserved small businesses and nonprofits. This can be best accomplished by automatically providing “Delegated Authority” to any CDFI that applies by virtue of the fact that they have already obtained a relevant certification from the Treasury Department.
3. The SBA or the Treasury Department should directly provide liquidity to eligible lenders that have a track record of opening access to capital for underserved small businesses and nonprofits, specifically for the purpose of deploying the PPP product. SBA should begin by providing these authorized providers of the PPP product with sufficient cash up front to cover 15 days of anticipated deployment to be held in a segregated account. SBA should then provide cash based on documentation of actual deployment taking into account when a provider is rapidly scaling their operation. This will eliminate the need for time consuming and expensive secondary market transactions and allow the SBA time to process payments without creating a cash payment Community Development, Civil Rights and Small Business Organizations Call on Congress to Ensure Underserved Small Businesses and Non-profits Benefit from the CARES Act bottleneck. Providers of the PPP product would return any repayments they recover from borrowers to SBA on a quarterly basis.

4. The SBA should change the regulation to allow businesses to include in their applications amounts to pay 1099 contractors that primarily rely on that business for their income, as determined by the business owner and documented through an attestation.
5. The SBA should set a minimum fee of $2,500 per PPP loan to eliminate the current disincentive in the lender fee structure for processing small loans below $50,000, which are more likely to be made to underserved microbusinesses, who may in fact cost more to serve because they are likely to require more assistance from the lender.

On behalf of the communities and organizations we serve,

National Organizations

Opportunity Finance Network
NALCAB – National Association for Latino Community Asset Builders
American Business Immigration Coalition
UnidosUS
National Urban League
National CAPACD
National Alliance of Community Economic Development Associations (NACEDA)
Inclusiv
Prosperity Now
Self-Help Federal Credit Union

Regional, State and Local Organizations

Mission Economic Development Agency (MEDA) (Calif.)
Chicanos Por La Causa & Préstamos CDFI (Ariz., Nev., N,M,, Texas)
Latino Economic Development Center (District of Columbia, Md., Va.)
Mi Casa, Inc. (District of Columbia)
Community Reinvestment Alliance of South Florida (Fla.)
Azteca Economic Development and Preservation Corporation (Texas)
California Association for Microenterprise Opportunity – CAMEO (Calif.)
New Economic for Women and New Capital (Calif.)
Opportunity Fund (Calif.)
CDC Small Business Finance (Calif.)
Bankers Small Business CDC of California (Calif.)
FINANTA (Pa.)
Hispanic Economic Development Center (Mo.)
Hispanic Interest Coalition of Alabama (Ala.)
Latino Community Credit Union (N.C.)
The Resurrection Project (Ill.)
Tierra del Sol Housing Corporation (N.M.)
Community Resources & Housing Development Corporation and Colorado Housing Enterprises (Colo.)
Rural Community Development Resources (Wash.)