Post updated September 13, 2023
Is Change Lending a CDFI?
The Change Company CDFI, LLC and its subsidiary Change Lending, LLC (“Change Lending”) both remain community development financial institutions (CDFI) certified by the United States Department of the Treasury’s CDFI Fund (the “CDFI Fund”). Attached here, are recent communications from the CDFI Fund that document the active CDFI certification status at each entity. Additionally, the spreadsheet with the list of active CDFIs published on the CDFI Fund’s website can be found here and for convenience available for download here.
Do Loans Purchased from Change Lending Retain Their Exemption From the CFPB’s ATR Rule?
All loans originated by Change Lending since it was certified as a CDFI in April 2018 retain their exemption from the CFPB’s ATR Rule even if they are subsequently purchased by a non-CDFI. Change Lending has made public this attached letter to Change Lending from the law firm of Garris Horn, LLP. Garris Horn’s letter confirms “loans made by a lender properly certified as a CDFI at the time of consummation remain exempt from the ATR Rule as CDFI loans for the life of the loan.” The letter continues that these rights “are not altered, nor amended, if a lender later loses its CDFI status…”
Additionally, Change Lending and the CDFI Fund have entered into this attached agreement which clarifies that existing Change Lending cannot retroactively lose its certification causing any existing loan to lose their exemption form the CFPB’s ATR Rule.
Does Change Lending Make Representations Regarding the Race, Ethnicity or Income of its Borrowers in Connection with its Securitizations?
Change Lending does not make representations regarding the race, ethnicity or income of its borrowers in the private placement memoranda or other documents describing its securitizations of mortgage loans.