OFN, NCRC Letter to SBA to Support proposed reforms to the Community Advantage Pilot Program

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)

Accompany Capital

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

B:Side Capital

Bankers Small Business CDC of California

Bitwise Industries

BLDG Memphis

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.


Entrepreneur Works

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

Justine Peterson

La Fuerza CDC



Local Enterprise Assistance Fund (LEAF)

Michigan Oncology Quality Consortium

Micro Enterprise Services of Oregon (MESO)


Mountain BizWorks

Mustard Seed Development Center

National ACE

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

Northern Initiatives

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.

Pathway Lending

People Fund

People Trust Community Loan Fund

Philadelphia Association of Community Development Corporations

Prosperity Now

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

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