# NEW MARKETS TAX CREDIT ALLOCATION APPLICATION

**Riverbend Community Capital CDE, LLC**

Application Round: not specified — CDE to state  
Requested Allocation: **$65,000,000**  
Prepared: 2026-08-23  
Readiness Grade: **A** (86.6/100 — this tool's own unsourced house heuristic, not a CDFI Fund evaluation)  

---

*This document was generated by nmtc-application-builder v1.5.5. Narrative placeholders marked \[NARRATIVE PLACEHOLDER\] require CDE review and customization.*

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## Executive Summary

Riverbend Community Capital CDE, LLC respectfully requests $65.0MM in New Markets Tax Credit allocation. Our 20-project pipeline spans 19 states with **87% of QEI committed to deep/severely distressed tracts**.

**Application Readiness Score: 86.6/100 (Grade A)**

*READINESS SCORE: An UNSOURCED HOUSE HEURISTIC of this tool (eligibility 25%, distress concentration 25%, geographic diversity 15%, impact metrics 20%, validation 10%, completeness 5%). The weights are this tool's own judgement; they are not calibrated against award data, the CDFI Fund publishes no such weighting, and the score does not predict an award outcome.*

*READINESS NARRATIVE WITHDRAWN (1.5.2). This tool no longer emits strengths, weaknesses or recommendations from the readiness composite, and none are offered in this release.*

*WHAT WAS WITHDRAWN. Earlier versions read this composite's sub-scores and told a CDE to act on them: to increase deep/severe distress concentration to a target share, to add operating-business projects to raise a jobs-per-$1MM-QEI figure, and (withdrawn separately in 1.5.1) to expand its footprint to >=5 states. They also asserted strengths and weaknesses -- that a share was 'above average', that a concentration was 'below competitive threshold'.*

*WHY. EVERY ONE OF THOSE TRIGGERS WAS A BAND THIS TOOL SET FOR ITSELF. The composite they weight is this tool's own unsourced house heuristic: the CDFI Fund publishes no readiness score, no such weighting and no grade, so none of the thresholds that fired those lines has a federal referent -- they are recorded HOUSE in this package's own constant registry. Restructuring a real pipeline is an expensive and sometimes irreversible act, and it was being instructed by arithmetic with nothing behind it. The measured case is on the record: following the withdrawn geographic advice moved a sample pipeline from Highly Qualified to Not Qualified under the Fund's own gate while this tool's grade did not change letter.*

*YOU WERE NEVERTHELESS DOCKED, AND HERE IS THE ARITHMETIC. A tool may decline to advise. It may not deduct silently.*

*ROWS THAT ARE HOUSE BOOKKEEPING END TO END -- the Fund scores no corresponding quantity:*

    Impact Metrics            38.2/100 at a 20% weight  ->  DOCKED 12.4 POINTS  [schema.IMPACT_BENCHMARKS (HOUSE)]
        FUND: The Fund scores whether outcomes are QUANTIFIED and THIRD-PARTY
              VALIDATED. It publishes no jobs-per-$1MM-QEI band, so no Fund
              quantity corresponds to the rate docking you here.
    Completeness              80.0/100 at a  5% weight  ->  DOCKED  1.0 POINTS  [this tool's own completeness curve]
        FUND: An internal check that this tool's own fields are populated. It
              has no Fund analogue and is not part of any application.

    TOTAL DEDUCTION 13.4 POINTS of the 100-point readiness headline.

*EVERY ROW ABOVE IS HOUSE BOOKKEEPING ON THIS RUN, AND ONLY ONE BLOCK RENDERS. A point recovered on any of them changes this tool's headline and nothing else -- the CDFI Fund scores no corresponding quantity for any row in the table. Nothing docked here on a quantity the Fund also scores, which is why the second block is absent rather than empty. THIS TABLE IS AN ACCOUNT OF WHAT THIS TOOL DID TO ITS OWN NUMBER, NOT A LIST OF THINGS TO FIX.*

*NONE OF THAT IS A FINDING ABOUT YOUR APPLICATION. The deduction is this tool's own bookkeeping against its own bands. In particular the CDFI Fund does not score geographic breadth at all, so nothing in the headline's geographic term has a federal referent; do not treat this pipeline's footprint as a finding either way, and do not expand it to recover those points.*

*WHERE THE SOURCED GUIDANCE IS. `intelligence.RecommendationEngine` is untouched. It never reads this composite -- it scores against the CY 2024-2025 NMTC Program Review Process and cites the section behind every item it emits. Reach it with `Application.recommendations()` in Python, or open the Win Alignment Scorer page in the Streamlit app.*

*IT IS NOT REACHED FROM HERE. Neither `nmtcapp analyze` nor the generated application documents run that engine, so neither now carries improvement guidance of any kind. That gap is stated rather than shipped quietly: reaching the sourced guidance is a separate call you have to make yourself.*

---

## Table of Contents

- [Section A: Business Strategy](#section-a)
- [Section B: Community Outcomes](#section-b)
- [Section C: Management Capacity](#section-c)
- [Section D: Capitalization Strategy](#section-d)
- [Section E: Prior Awards — Deployment History](#section-e)
- [Appendix A: Pipeline Detail](#appendix-a)
- [Appendix B: Distress Documentation](#appendix-b)
- [Appendix C: Geographic Targeting](#appendix-c)
- [Appendix D: Impact Projections](#appendix-d)
- [Appendix E: Track Record](#appendix-e)

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## Section A: Business Strategy

### Investment Thesis and Strategy

Riverbend Community Capital CDE, LLC will deploy $65.0 million in NMTC allocation across 20 projects in 19 states — targeting 87% of QEI in deep and severely distressed census tracts. The pipeline's largest sector concentration is healthcare.

[NARRATIVE PLACEHOLDER — Replace this text with your CDE's specific information. CDFI Fund reviewers score on specificity, evidence, and alignment with community need. Length is governed by the limit printed on the published application form for this question, which this tool does not encode — check the form, not this draft.]



### Target Markets — Geographic and Demographic

Primary geographic targets: AZ, CA, FL, GA, IL and others.

Riverbend Community Capital CDE, LLC's stated mission is: "Deploy New Markets Tax Credit capital into deep-distress communities across the Midwest and South, with a focus on healthcare, education, and small business operating businesses in persistent poverty…"

Per the persistent-poverty flags supplied in this CDE's own pipeline submission, the pipeline places 15% of QEI in tracts declared as persistent-poverty counties. 3% of QEI is in tracts recorded as High Migration Rural. This share is NOT solely the CDE's declaration: the high_migration_rural column of the pipeline submission is overwritten wherever nmtc-mapper returned a determination for the tract, so where the two disagree the figure above is the tool's, not the CDE's. Check it against your own submission before relying on it, and state which governs.



[NARRATIVE PLACEHOLDER — Replace this text with your CDE's specific information. CDFI Fund reviewers score on specificity, evidence, and alignment with community need. Length is governed by the limit printed on the published application form for this question, which this tool does not encode — check the form, not this draft.]



### Pipeline Overview

**Total Projects in Pipeline:** 20
**Total Pipeline QEI ($):** $122,500,000
**States Represented:** 19
**% QEI in Deep/Severe Distress:** 87%
**Dominant Sector:** Healthcare
**Total Jobs to Be Created:** 864
**Sector Diversity Score:** 91.8/100

### QEI Deployment Strategy and Timeline

Riverbend Community Capital CDE, LLC targets an NMTC allocation award. Application round: not specified — CDE to state.

[CDE TO COMPLETE: State your deployment timeline and the diligence status of each project — when you expect to close the first tranche, how the rest are sequenced, and how far each project has actually progressed through your underwriting. This tool holds neither: your pipeline submission records project economics and locations, not diligence milestones or target closing dates. Do not assert that a project has cleared underwriting review unless it has.]

QEI deployment strategy: 87% of QEI committed to deep/severe distress tracts. (This tool's own internal scoring band is ≥75%; it is not a CDFI Fund threshold.)



[NARRATIVE PLACEHOLDER — Replace this text with your CDE's specific information. CDFI Fund reviewers score on specificity, evidence, and alignment with community need. Length is governed by the limit printed on the published application form for this question, which this tool does not encode — check the form, not this draft.]



### Competitive Differentiation



[NARRATIVE PLACEHOLDER — Replace this text with your CDE's specific information. CDFI Fund reviewers score on specificity, evidence, and alignment with community need. Length is governed by the limit printed on the published application form for this question, which this tool does not encode — check the form, not this draft.]




---

## Section B: Community Outcomes

### Aggregate Community Impact Projections

The 20 projects in Riverbend Community Capital CDE, LLC's pipeline will produce the following direct community impacts upon project completion:

  • 864 permanent full-time-equivalent jobs created
  • 298 existing jobs retained
  • 234 affordable or mixed-income housing units developed
  • 198,500 sq ft of community facility / commercial space
  • 7.0 jobs per $1MM of QEI deployed



[NARRATIVE PLACEHOLDER — Replace this text with your CDE's specific information. CDFI Fund reviewers score on specificity, evidence, and alignment with community need. Length is governed by the limit printed on the published application form for this question, which this tool does not encode — check the form, not this draft.]



### Distress Level Commitments

**QEI in Deep Distress Tracts (a share of QEI, not of QLICIs — see the basis note below):** 53.5%
**QEI in Severely Distressed Tracts, Deep Distress included (a share of QEI, not of QLICIs — see the basis note below):** 86.7%
**— of which severely distressed but not also deep:** 33.2%
**QEI in LIC (Standard Eligible) Tracts:** 13.3%
**QEI in NMTC Native Areas (CDE-declared, not verified by this tool):** 10.0%
**QEI in High Migration Rural (HMR) Tracts:** 2.6%
**BASIS NOTE — the CDFI Fund's two distress commitments are measured on QLICIs, not on QEI:** Question 25 of the CY 2024-2025 NMTC Allocation Application (printed pp. 38-41) sets both commitments, and both are measured on QLICIs — specifically on QLICIs "in terms of aggregate dollar amounts", tested for each QLICI. Question 25(a) asks for at least 85% of QLICIs in areas characterized by at least ONE of items 1-5 (Severe Distress; NMTC Native Areas; U.S. Island Areas; Non-Metropolitan Counties; Targeted Populations) or by at least TWO of items 6-12 (25% poverty / 70% median family income / 1.25x unemployment; Brownfield Sites; ARC and/or DRA Areas; Colonias Areas; Federal Medically Underserved Areas; FEMA Disaster Areas; Low-Income and Low-Access to Supermarkets). "Multiple indicia of distress" is that two-of-seven test, applied per QLICI — not a loose notion of compounded distress and not a category of its own. Question 25(b)(i) is NOT a 20% bar. It is a selectable commitment level — 0, 5, 10, 15 or 20, and selecting 20 opens a field for any figure from 20% to 100% — over FOUR qualifying area types: Deep Distress, NMTC Native Areas, High Migration Rural Counties and U.S. Island Areas. A CDE that can honestly commit 10% selects 10 and has failed nothing; a CDE whose QLICIs sit in Native Areas, High Migration Rural Counties or Island Areas must count them, and no Deep Distress figure in this document does. The Application further states that "A QLICI that meets this commitment will also automatically meet the commitment made in Question 25(a)." Every distress share in this document is a share of QEI. nmtc-application-builder computes neither QLICI-denominated figure — it reads this pipeline's QLICI amounts only to print them in Appendix A and to check that each is no larger than its QEI — so no figure in this document answers either commitment, and none may be presented to the CDFI Fund as doing so. WHICH OF THE CDE'S QUALIFYING ROUTES ARE VISIBLE HERE: this package carries a per-project field for 6 of the 14 distinct area types Question 25 lists, and they do NOT share one provenance, so each is stated with its own. Severe Distress and Deep Distress: TOOL-VERIFIED — the distress level is read from the CDFI Fund eligibility table for the tract this package geocoded, and a CDE's own distress column is kept separately and labelled CDE-declared wherever it is shown. High Migration Rural Counties: CDE-DECLARED AND TOOL-VERIFIED — enrichment overwrites the CDE's declaration whenever nmtc-mapper returns a determination for the tract, so the declaration stands only where the tool reached none, and where enrichment did not run at all. NMTC Native Areas and U.S. territory: CDE-DECLARED AND TOOL-UNVERIFIED — nothing in this package checks either one, and a Native Area determination is a spatial intersection against the Fund's CIMS map rather than a tract-keyed lookup this package could perform (U.S. territory is the CDE's own word; the Application's U.S. Island Areas is a specific list of five). Non-Metropolitan Counties: TOOL-VERIFIED AND TRI-STATE — the OMB designation is read for the same geocoded tract, and a project the lookup could not resolve is recorded as undetermined rather than as metropolitan, so no project is counted in a county type it was never determined to be in. It carries NOTHING for Targeted Populations and nothing for any of items 6-12; it computes no multi-indicia measure at all. Holding those fields is not a partial answer to Question 25 and must not be read as one: the commitment is a share of QLICI DOLLARS, this package weights nothing by QLICI dollars, and a flag that enters no denominator contributes nothing to a share. Deep Distress is a strict subset of severe distress, so the severe-distress share already includes the deep-distress share. The CDE must compute both QLICI-denominated shares from its own QLICI amounts, against the Application's own area lists, before stating either commitment. (The CY 2026 NOAA is not yet published.)

### Community Need Documentation

[CDE TO COMPLETE: Document unmet capital need in the markets this pipeline serves. Supply the underlying evidence and cite each source by name, publisher and vintage — for example credit-access or lending data for your tracts, unemployment and poverty measures, business closures or disinvestment history, and community input gathered by your CDE. nmtc-application-builder does not compute, retrieve or verify community-need statistics of any kind, and supplies no figure for this subsection. No number may be entered here without a citation the CDE controls and can defend to the CDFI Fund.]



[NARRATIVE PLACEHOLDER — Replace this text with your CDE's specific information. CDFI Fund reviewers score on specificity, evidence, and alignment with community need. Length is governed by the limit printed on the published application form for this question, which this tool does not encode — check the form, not this draft.]



### Per-Project Impact Detail

(See Attachment: Impact Projections Table)

### Long-Term Community Impact Strategy



[NARRATIVE PLACEHOLDER — Replace this text with your CDE's specific information. CDFI Fund reviewers score on specificity, evidence, and alignment with community need. Length is governed by the limit printed on the published application form for this question, which this tool does not encode — check the form, not this draft.]




---

## Section C: Management Capacity

### CDE History and Certification

Riverbend Community Capital CDE, LLC was certified as a Community Development Entity by the CDFI Fund on 2018-06-20. Since certification, the organization has received 3 NMTC allocation awards totaling $155,000,000, of which 2 are recorded as fully deployed.

Per this CDE's own profile declaration, no prior NMTC reporting issues have been recorded.

[CDE TO COMPLETE: State the CDE's full compliance and performance history over its prior allocations — recapture or reduction events, defaults, cures, and material findings. The profile field above covers reporting issues only and is not by itself a representation about defaults or compliance violations.]



[NARRATIVE PLACEHOLDER — Replace this text with your CDE's specific information. CDFI Fund reviewers score on specificity, evidence, and alignment with community need. Length is governed by the limit printed on the published application form for this question, which this tool does not encode — check the form, not this draft.]



### Governance and Organizational Structure

**Board Members:** 9
**Community Representatives:** 4
**Independent Directors:** 3
**Board Meeting Frequency:** quarterly
**CDE Certification Date:** 2018-06-20
**Prior Allocations Received:** 3
**Total Prior Allocation ($):** $155,000,000
**Rounds Fully Deployed:** 2

### Track Record — Prior NMTC Deployments

(See Attachment: Track Record Table)

### Underwriting Process and Internal Controls

[CDE TO COMPLETE: Describe your CDE's underwriting process end to end — initial screening and how eligibility is established, impact assessment, financial underwriting and credit criteria, your investment committee's composition and approval threshold, and your compliance-monitoring practice over the seven-year period. This tool holds none of these: your CDE profile records a board headcount, which is not an approval rule, and nothing in it describes a control you actually operate.]



[NARRATIVE PLACEHOLDER — Replace this text with your CDE's specific information. CDFI Fund reviewers score on specificity, evidence, and alignment with community need. Length is governed by the limit printed on the published application form for this question, which this tool does not encode — check the form, not this draft.]



### Key Personnel and Qualifications



[NARRATIVE PLACEHOLDER — Replace this text with your CDE's specific information. CDFI Fund reviewers score on specificity, evidence, and alignment with community need. Length is governed by the limit printed on the published application form for this question, which this tool does not encode — check the form, not this draft.]




---

## Section D: Capitalization Strategy

### Deal Economics Summary

**Allocation Requested ($):** $65,000,000
**Total Pipeline QEI ($):** $122,500,000
**Total NMTCs Generated ($):** $47,775,000
**Estimated Investor Equity ($):** $39,653,250
**Assumed Credit Price ($/NMTC):** $0.83 (market assumption, not a CDFI Fund parameter)
**Total Leverage Loans ($):** $82,846,750
**CDE Fee Income ($):** $3,062,500
**Assumed CDE Fee Rate:** 2.5% of QEI (market assumption, not a CDFI Fund parameter)
**QEI Less CDE Fees ($):** $119,437,500 (not the QALICB's retained benefit — the $82.8MM leverage loan inside this figure is repaid or refinanced)
**Compliance Period:** 7 years (IRC §45D)

### Investor Strategy and Relationships

[CDE TO COMPLETE: Describe your actual investor relationships and their current status — named institutions where you have them, whether each is a term sheet, a letter of intent, a prior-round investor or a prospect, and who is expected to lead. This tool has no investor data for your CDE and cannot attest to any relationship, to investor motivation, or to how many investors will participate.]

Modelled on $122.5MM of pipeline QEI at an assumed credit price of $0.83/NMTC credit, the structure implies $39.7MM of investor equity. The credit price is a market assumption of this model, not a quoted or committed price.

Pipeline footprint: 19 states.



[NARRATIVE PLACEHOLDER — Replace this text with your CDE's specific information. CDFI Fund reviewers score on specificity, evidence, and alignment with community need. Length is governed by the limit printed on the published application form for this question, which this tool does not encode — check the form, not this draft.]



### Leverage Structure

Each transaction will utilize a standard leveraged NMTC structure:

  1. Leverage Lender provides senior debt (approx. $82.8MM total)
  2. Tax Credit Investor contributes equity ($39.7MM)
  3. Combined proceeds flow through the CDE as QLICI loans. 3 of 20 projects are declared below-market-rate in this CDE's own pipeline submission; the terms of the remainder are not recorded here.
  4. QEI less CDE fees: $119.4MM. This is not the QALICB's retained benefit — the $82.8MM leverage loan inside it is repaid or refinanced after the 7-year period.

Assumed CDE fee rate: 2.5% of QEI ($3.1MM) — a market assumption of this model, not a CDFI Fund parameter. Fees cover origination, compliance monitoring, and asset management over the 7-year compliance period.



[NARRATIVE PLACEHOLDER — Replace this text with your CDE's specific information. CDFI Fund reviewers score on specificity, evidence, and alignment with community need. Length is governed by the limit printed on the published application form for this question, which this tool does not encode — check the form, not this draft.]



### Investor Commitments

[CDE TO COMPLETE: This table is a blank form. nmtc-application-builder holds no investor data for your CDE and supplies no figure in it — not a name, a type, a CRA obligation, a commitment amount, a credit price or a status, and not the number of rows. Add one row per investor you can name and defend to the CDFI Fund, and delete any row you cannot.]

(See Attachment: Investor Commitments Table)

### Leverage Loan Sources



[NARRATIVE PLACEHOLDER — Replace this text with your CDE's specific information. CDFI Fund reviewers score on specificity, evidence, and alignment with community need. Length is governed by the limit printed on the published application form for this question, which this tool does not encode — check the form, not this draft.]




---

## Section E: Prior Awards — Deployment History

### Prior Allocation Summary

Riverbend Community Capital CDE, LLC has 3 prior NMTC allocation awards totaling $155,000,000, of which 2 are recorded in the CDE profile as fully deployed.

Per this CDE's own profile declaration, no prior NMTC reporting issues have been recorded.

[CDE TO COMPLETE: State the CDE's full compliance and performance history over its prior allocations — recapture or reduction events, defaults, cures, and material findings. The profile field above covers reporting issues only and is not by itself a representation about defaults or compliance violations.]

The deployment history table below provides details on each prior award, including states served and sectors financed.



### Award-by-Award Deployment History

- **Award 1 (FY2019):** $40,000,000 — Fully Deployed. States: IL, OH, TN. Sectors: healthcare, small_business.
- **Award 2 (FY2021):** $55,000,000 — Fully Deployed. States: IL, GA, LA. Sectors: education, affordable_housing.
- **Award 3 (FY2023):** $60,000,000 — Partially Deployed. States: OH, MI, MO, TN. Sectors: healthcare, community_facility.

### Compliance and Monitoring

(See Attachment: Track Record Table)

### Outcomes and Impact Achieved

Outcomes across all 3 prior awards:



[NARRATIVE PLACEHOLDER — Replace this text with your CDE's specific information. CDFI Fund reviewers score on specificity, evidence, and alignment with community need. Length is governed by the limit printed on the published application form for this question, which this tool does not encode — check the form, not this draft.]




---

## Appendix A: Pipeline Detail

| Project ID | QALICB Name | Project Name | Street Address | City | State | ZIP Code | Census Tract (11-digit) | NMTC Eligible (Y/N) | Distress Level | NMTC Native Area (CDE-declared, Y/N) | High Migration Rural (Y/N) | Opportunity Zone (Y/N) | Sector (as supplied) | Project Type | Total Project Cost ($) | QEI Request ($) | Total QLICI ($) | Leverage Loan ($) | Total NMTCs ($) | Estimated Investor Equity ($) | CDE Fee ($) | Construction Start | Operations Start | Closing Target Date | Jobs Created | Jobs Retained | Affordable Units Built | Square Feet |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| PRJ-001 | Southside HC QALICB LLC | Southside Community Health Center | 3400 S Michigan Ave | Chicago | IL |  | 17031838200 | Y | Deep Distress | N | N | N | Healthcare | Real Estate | $12,500,000 | $8,500,000 | $8,500,000 | $5,748,550 | $3,315,000 | $2,751,450 | $212,500 |  |  | 2025-09-30 | 52 | 18 | — | 24,000 |
| PRJ-002 | East Houston Academy QALICB LLC | East Houston Charter Academy | 5200 Lawndale St | Houston | TX |  | 48201223400 | Y | Deep Distress | N | N | Y | Education | Real Estate | $9,800,000 | $7,000,000 | $7,000,000 | $4,734,100 | $2,730,000 | $2,265,900 | $175,000 |  |  | 2025-12-15 | 38 | 22 | — | 0 |
| PRJ-003 | Bronx Food Hub QALICB LLC | Bronx Food Hub | 800 Hunts Point Ave | Bronx | NY |  | 36005035900 | Y | Severely Distressed | N | N | Y | Small Business | Real Estate | $7,200,000 | $5,000,000 | $5,000,000 | $3,381,500 | $1,950,000 | $1,618,500 | $125,000 |  |  | 2025-08-31 | 65 | 8 | — | 18,000 |
| PRJ-004 | Watts MFG QALICB LLC | Watts Manufacturing Center | 9500 S Grape St | Los Angeles | CA |  | 06037606200 | Y | Deep Distress | N | N | N | Small Business | Operating Business | $6,000,000 | $4,500,000 | $4,500,000 | $3,043,350 | $1,755,000 | $1,456,650 | $112,500 |  |  | 2025-11-30 | 80 | 25 | — | 0 |
| PRJ-005 | Cleveland Clinic QALICB LLC | Cleveland Neighborhood Clinic | 2100 Euclid Ave | Cleveland | OH |  | 39035103200 | Y | Deep Distress | N | N | N | Healthcare | Real Estate | $10,000,000 | $7,500,000 | $7,500,000 | $5,072,250 | $2,925,000 | $2,427,750 | $187,500 |  |  | 2026-01-31 | 42 | 30 | — | 20,000 |
| PRJ-006 | Atlanta AH QALICB LLC | Atlanta Affordable Homes Phase II | 640 McDaniel St SW | Atlanta | GA |  | 13121008700 | Y | Severely Distressed | N | N | Y | Affordable Housing | Real Estate | $14,000,000 | $9,000,000 | $9,000,000 | $6,086,700 | $3,510,000 | $2,913,300 | $225,000 |  |  | 2025-10-31 | 15 | 5 | 72 | 0 |
| PRJ-007 | Miami CRC QALICB LLC | Miami Community Resource Center | 3000 NW 27th Ave | Miami | FL |  | 12086000900 | Y | Low Income Community | N | N | N | Community Facility | Real Estate | $5,500,000 | $4,000,000 | $4,000,000 | $2,705,200 | $1,560,000 | $1,294,800 | $100,000 |  |  | 2025-09-15 | 28 | 10 | — | 12,000 |
| PRJ-008 | North Philly Wellness QALICB LLC | North Philadelphia Wellness Hub | 2500 N Broad St | Philadelphia | PA |  | 42101017900 | Y | Deep Distress | N | N | N | Healthcare | Mixed Use | $11,000,000 | $8,000,000 | $8,000,000 | $5,410,400 | $3,120,000 | $2,589,600 | $200,000 |  |  | 2026-03-31 | 55 | 20 | — | 22,000 |
| PRJ-009 | NOLA Culinary QALICB LLC | New Orleans Culinary Arts Center | 1800 Oretha Castle Haley Blvd | New Orleans | LA |  | 22071008500 | Y | Deep Distress | N | N | Y | Education | Real Estate | $8,200,000 | $6,000,000 | $6,000,000 | $4,057,800 | $2,340,000 | $1,942,200 | $150,000 |  |  | 2025-11-15 | 35 | 8 | — | 16,000 |
| PRJ-010 | Memphis SBI QALICB LLC | Memphis Small Business Incubator | 400 Monroe Ave | Memphis | TN |  | 47157002400 | Y | Deep Distress | N | N | N | Small Business | Operating Business | $4,800,000 | $3,500,000 | $3,500,000 | $2,367,050 | $1,365,000 | $1,132,950 | $87,500 |  |  | 2025-08-15 | 90 | 15 | — | 0 |
| PRJ-011 | MKE Affordable QALICB LLC | Milwaukee Affordable Apartments | 1900 W National Ave | Milwaukee | WI |  | 55079141700 | Y | Severely Distressed | N | N | N | Affordable Housing | Real Estate | $13,500,000 | $9,500,000 | $9,500,000 | $6,424,850 | $3,705,000 | $3,075,150 | $237,500 |  |  | 2026-02-28 | 12 | 4 | 64 | 0 |
| PRJ-012 | STL Solar QALICB LLC | St. Louis Community Solar Project | 3600 Market St | St. Louis | MO |  | 29510109500 | Y | Low Income Community | N | N | Y | Clean Energy | Operating Business | $5,000,000 | $3,800,000 | $3,800,000 | $2,569,940 | $1,482,000 | $1,230,060 | $95,000 |  |  | 2025-10-15 | 22 | 6 | — | 0 |
| PRJ-013 | Charlotte WTC QALICB LLC | Charlotte Workforce Training Center | 2810 Freedom Dr | Charlotte | NC |  | 37119004200 | Y | Severely Distressed | N | N | N | Education | Real Estate | $7,500,000 | $5,500,000 | $5,500,000 | $3,719,650 | $2,145,000 | $1,780,350 | $137,500 |  |  | 2025-12-31 | 30 | 12 | — | 14,000 |
| PRJ-014 | Phoenix Native HC QALICB LLC | Phoenix Native American Health Clinic | 4212 W Indian School Rd | Phoenix | AZ |  | 04013118400 | Y | Deep Distress | Y | N | N | Healthcare | Real Estate | $9,000,000 | $6,500,000 | $6,500,000 | $4,395,950 | $2,535,000 | $2,104,050 | $162,500 |  |  | 2026-01-15 | 48 | 25 | — | 18,500 |
| PRJ-015 | Detroit Auto Parts QALICB LLC | Detroit Auto Parts Manufacturer | 7800 E Jefferson Ave | Detroit | MI |  | 26163527900 | Y | Deep Distress | N | N | Y | Small Business | Operating Business | $6,500,000 | $5,000,000 | $5,000,000 | $3,381,500 | $1,950,000 | $1,618,500 | $125,000 |  |  | 2025-09-30 | 110 | 45 | — | 0 |
| PRJ-016 | Indy Community Hub QALICB LLC | Indianapolis Mixed-Use Community Hub | 1200 N Alabama St | Indianapolis | IN |  | 18097350200 | Y | Severely Distressed | N | N | N | Mixed Use | Mixed Use | $10,500,000 | $7,500,000 | $7,500,000 | $5,072,250 | $2,925,000 | $2,427,750 | $187,500 |  |  | 2026-03-15 | 35 | 10 | 24 | 20,000 |
| PRJ-017 | Rural MS Health QALICB LLC | Rural Mississippi Health Access Center | 510 Main St | Greenville | MS |  | 28065950100 | Y | Deep Distress | N | Y | N | Healthcare | Real Estate | $4,200,000 | $3,200,000 | $3,200,000 | $2,164,160 | $1,248,000 | $1,035,840 | $80,000 |  |  | 2025-11-30 | 20 | 15 | — | 8,000 |
| PRJ-018 | KC Senior Housing QALICB LLC | Kansas City Affordable Senior Housing | 3500 Troost Ave | Kansas City | MO |  | 29095017800 | Y | Low Income Community | N | N | N | Affordable Housing | Real Estate | $11,800,000 | $8,500,000 | $8,500,000 | $5,748,550 | $3,315,000 | $2,751,450 | $212,500 |  |  | 2026-02-15 | 10 | 3 | 56 | 0 |
| PRJ-019 | Baltimore Food QALICB LLC | Baltimore Community Food Market | 2700 Pennsylvania Ave | Baltimore | MD |  | 24510050200 | Y | Severely Distressed | N | N | N | Community Facility | Real Estate | $5,800,000 | $4,200,000 | $4,200,000 | $2,840,460 | $1,638,000 | $1,359,540 | $105,000 |  |  | 2025-10-31 | 45 | 8 | — | 11,000 |
| PRJ-020 | ABQ Arts QALICB LLC | Albuquerque Mixed-Use Arts District | 400 Central Ave NE | Albuquerque | NM |  | 35001000900 | Y | Deep Distress | Y | N | Y | Mixed Use | Mixed Use | $7,800,000 | $5,800,000 | $5,800,000 | $3,922,540 | $2,262,000 | $1,877,460 | $145,000 |  |  | 2025-12-15 | 32 | 9 | 18 | 15,000 |
| TOTALS |  | TOTAL (20 projects) |  |  |  |  |  |  |  |  |  |  |  |  | $170,600,000 | $122,500,000 | $122,500,000 | $82,846,750 | $47,775,000 | $39,653,250 | $3,062,500 |  |  |  | 864 | 298 | 234 | 198,500 |


---

## Appendix B: Distress Documentation

| Project ID | Project Name | City, State | Census Tract (GEOID) | NMTC Eligible | Distress Level | Severely Distressed Flag | NMTC Native Area (CDE-declared) | High Migration Rural (HMR) | Opportunity Zone | Poverty Rate (%) | Median Family Income | Unemployment Rate (%) | Data Source | ACS Vintage |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| PRJ-001 | Southside Community Health Center | Chicago, IL | 17031838200 | Yes | Deep Distress | Yes | No | No | No | See ACS | See ACS | See ACS | CDFI Fund NMTC Eligibility Table (2016–2020 ACS) | 2016–2020 ACS 5-Year Estimates |
| PRJ-002 | East Houston Charter Academy | Houston, TX | 48201223400 | Yes | Deep Distress | Yes | No | No | Yes | See ACS | See ACS | See ACS | CDFI Fund NMTC Eligibility Table (2016–2020 ACS) | 2016–2020 ACS 5-Year Estimates |
| PRJ-003 | Bronx Food Hub | Bronx, NY | 36005035900 | Yes | Severely Distressed | Yes | No | No | Yes | See ACS | See ACS | See ACS | CDFI Fund NMTC Eligibility Table (2016–2020 ACS) | 2016–2020 ACS 5-Year Estimates |
| PRJ-004 | Watts Manufacturing Center | Los Angeles, CA | 06037606200 | Yes | Deep Distress | Yes | No | No | No | See ACS | See ACS | See ACS | CDFI Fund NMTC Eligibility Table (2016–2020 ACS) | 2016–2020 ACS 5-Year Estimates |
| PRJ-005 | Cleveland Neighborhood Clinic | Cleveland, OH | 39035103200 | Yes | Deep Distress | Yes | No | No | No | See ACS | See ACS | See ACS | CDFI Fund NMTC Eligibility Table (2016–2020 ACS) | 2016–2020 ACS 5-Year Estimates |
| PRJ-006 | Atlanta Affordable Homes Phase II | Atlanta, GA | 13121008700 | Yes | Severely Distressed | Yes | No | No | Yes | See ACS | See ACS | See ACS | CDFI Fund NMTC Eligibility Table (2016–2020 ACS) | 2016–2020 ACS 5-Year Estimates |
| PRJ-007 | Miami Community Resource Center | Miami, FL | 12086000900 | Yes | Low Income Community | No | No | No | No | See ACS | See ACS | See ACS | CDFI Fund NMTC Eligibility Table (2016–2020 ACS) | 2016–2020 ACS 5-Year Estimates |
| PRJ-008 | North Philadelphia Wellness Hub | Philadelphia, PA | 42101017900 | Yes | Deep Distress | Yes | No | No | No | See ACS | See ACS | See ACS | CDFI Fund NMTC Eligibility Table (2016–2020 ACS) | 2016–2020 ACS 5-Year Estimates |
| PRJ-009 | New Orleans Culinary Arts Center | New Orleans, LA | 22071008500 | Yes | Deep Distress | Yes | No | No | Yes | See ACS | See ACS | See ACS | CDFI Fund NMTC Eligibility Table (2016–2020 ACS) | 2016–2020 ACS 5-Year Estimates |
| PRJ-010 | Memphis Small Business Incubator | Memphis, TN | 47157002400 | Yes | Deep Distress | Yes | No | No | No | See ACS | See ACS | See ACS | CDFI Fund NMTC Eligibility Table (2016–2020 ACS) | 2016–2020 ACS 5-Year Estimates |
| PRJ-011 | Milwaukee Affordable Apartments | Milwaukee, WI | 55079141700 | Yes | Severely Distressed | Yes | No | No | No | See ACS | See ACS | See ACS | CDFI Fund NMTC Eligibility Table (2016–2020 ACS) | 2016–2020 ACS 5-Year Estimates |
| PRJ-012 | St. Louis Community Solar Project | St. Louis, MO | 29510109500 | Yes | Low Income Community | No | No | No | Yes | See ACS | See ACS | See ACS | CDFI Fund NMTC Eligibility Table (2016–2020 ACS) | 2016–2020 ACS 5-Year Estimates |
| PRJ-013 | Charlotte Workforce Training Center | Charlotte, NC | 37119004200 | Yes | Severely Distressed | Yes | No | No | No | See ACS | See ACS | See ACS | CDFI Fund NMTC Eligibility Table (2016–2020 ACS) | 2016–2020 ACS 5-Year Estimates |
| PRJ-014 | Phoenix Native American Health Clinic | Phoenix, AZ | 04013118400 | Yes | Deep Distress | Yes | Yes | No | No | See ACS | See ACS | See ACS | CDFI Fund NMTC Eligibility Table (2016–2020 ACS) | 2016–2020 ACS 5-Year Estimates |
| PRJ-015 | Detroit Auto Parts Manufacturer | Detroit, MI | 26163527900 | Yes | Deep Distress | Yes | No | No | Yes | See ACS | See ACS | See ACS | CDFI Fund NMTC Eligibility Table (2016–2020 ACS) | 2016–2020 ACS 5-Year Estimates |
| PRJ-016 | Indianapolis Mixed-Use Community Hub | Indianapolis, IN | 18097350200 | Yes | Severely Distressed | Yes | No | No | No | See ACS | See ACS | See ACS | CDFI Fund NMTC Eligibility Table (2016–2020 ACS) | 2016–2020 ACS 5-Year Estimates |
| PRJ-017 | Rural Mississippi Health Access Center | Greenville, MS | 28065950100 | Yes | Deep Distress | Yes | No | Yes | No | See ACS | See ACS | See ACS | CDFI Fund NMTC Eligibility Table (2016–2020 ACS) | 2016–2020 ACS 5-Year Estimates |
| PRJ-018 | Kansas City Affordable Senior Housing | Kansas City, MO | 29095017800 | Yes | Low Income Community | No | No | No | No | See ACS | See ACS | See ACS | CDFI Fund NMTC Eligibility Table (2016–2020 ACS) | 2016–2020 ACS 5-Year Estimates |
| PRJ-019 | Baltimore Community Food Market | Baltimore, MD | 24510050200 | Yes | Severely Distressed | Yes | No | No | No | See ACS | See ACS | See ACS | CDFI Fund NMTC Eligibility Table (2016–2020 ACS) | 2016–2020 ACS 5-Year Estimates |
| PRJ-020 | Albuquerque Mixed-Use Arts District | Albuquerque, NM | 35001000900 | Yes | Deep Distress | Yes | Yes | No | Yes | See ACS | See ACS | See ACS | CDFI Fund NMTC Eligibility Table (2016–2020 ACS) | 2016–2020 ACS 5-Year Estimates |
| SUMMARY | 20 total projects |  |  | 20/20 |  | 17/20 (85%) | 2/20 |  |  |  |  |  |  |  |


---

## Appendix C: Geographic Targeting

| State | Project Count | QEI ($) | QEI (% of Total) | Deep/Severe Projects | Native Area Projects (CDE-declared) | HMR Projects | OZ Projects |
| --- | --- | --- | --- | --- | --- | --- | --- |
| AZ | 1 | $6,500,000 | 5.3% | 1 | 1 | 0 | 0 |
| CA | 1 | $4,500,000 | 3.7% | 1 | 0 | 0 | 0 |
| FL | 1 | $4,000,000 | 3.3% | 0 | 0 | 0 | 0 |
| GA | 1 | $9,000,000 | 7.3% | 1 | 0 | 0 | 1 |
| IL | 1 | $8,500,000 | 6.9% | 1 | 0 | 0 | 0 |
| IN | 1 | $7,500,000 | 6.1% | 1 | 0 | 0 | 0 |
| LA | 1 | $6,000,000 | 4.9% | 1 | 0 | 0 | 1 |
| MD | 1 | $4,200,000 | 3.4% | 1 | 0 | 0 | 0 |
| MI | 1 | $5,000,000 | 4.1% | 1 | 0 | 0 | 1 |
| MO | 2 | $12,300,000 | 10.0% | 0 | 0 | 0 | 1 |
| MS | 1 | $3,200,000 | 2.6% | 1 | 0 | 1 | 0 |
| NC | 1 | $5,500,000 | 4.5% | 1 | 0 | 0 | 0 |
| NM | 1 | $5,800,000 | 4.7% | 1 | 1 | 0 | 1 |
| NY | 1 | $5,000,000 | 4.1% | 1 | 0 | 0 | 1 |
| OH | 1 | $7,500,000 | 6.1% | 1 | 0 | 0 | 0 |
| PA | 1 | $8,000,000 | 6.5% | 1 | 0 | 0 | 0 |
| TN | 1 | $3,500,000 | 2.9% | 1 | 0 | 0 | 0 |
| TX | 1 | $7,000,000 | 5.7% | 1 | 0 | 0 | 1 |
| WI | 1 | $9,500,000 | 7.8% | 1 | 0 | 0 | 0 |
| TOTAL | 20 | $122,500,000 | 100.0% | 17 | 2 | 1 | 7 |


---

## Appendix D: Impact Projections

| Project ID | Project Name | State | Sector | Project Type | QEI ($) | Total Project Cost ($) | Jobs Created | Jobs Retained | Total Jobs | Cost per Job ($) | QEI per Job ($) | Affordable Units | Commercial Sq Ft | Distress Level | Native Area (CDE-declared) | HMR | OZ |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| PRJ-001 | Southside Community Health Center | IL | Healthcare | Real Estate | $8,500,000 | $12,500,000 | 52 | 18 | 70 | $240,385 | $163,462 | — | 24,000 | Deep Distress | No | No | No |
| PRJ-002 | East Houston Charter Academy | TX | Education | Real Estate | $7,000,000 | $9,800,000 | 38 | 22 | 60 | $257,895 | $184,211 | — | 0 | Deep Distress | No | No | Yes |
| PRJ-003 | Bronx Food Hub | NY | Small Business | Real Estate | $5,000,000 | $7,200,000 | 65 | 8 | 73 | $110,769 | $76,923 | — | 18,000 | Severely Distressed | No | No | Yes |
| PRJ-004 | Watts Manufacturing Center | CA | Small Business | Operating Business | $4,500,000 | $6,000,000 | 80 | 25 | 105 | $75,000 | $56,250 | — | 0 | Deep Distress | No | No | No |
| PRJ-005 | Cleveland Neighborhood Clinic | OH | Healthcare | Real Estate | $7,500,000 | $10,000,000 | 42 | 30 | 72 | $238,095 | $178,571 | — | 20,000 | Deep Distress | No | No | No |
| PRJ-006 | Atlanta Affordable Homes Phase II | GA | Affordable Housing | Real Estate | $9,000,000 | $14,000,000 | 15 | 5 | 20 | $933,333 | $600,000 | 72 | 0 | Severely Distressed | No | No | Yes |
| PRJ-007 | Miami Community Resource Center | FL | Community Facility | Real Estate | $4,000,000 | $5,500,000 | 28 | 10 | 38 | $196,429 | $142,857 | — | 12,000 | Low Income Community | No | No | No |
| PRJ-008 | North Philadelphia Wellness Hub | PA | Healthcare | Mixed Use | $8,000,000 | $11,000,000 | 55 | 20 | 75 | $200,000 | $145,455 | — | 22,000 | Deep Distress | No | No | No |
| PRJ-009 | New Orleans Culinary Arts Center | LA | Education | Real Estate | $6,000,000 | $8,200,000 | 35 | 8 | 43 | $234,286 | $171,429 | — | 16,000 | Deep Distress | No | No | Yes |
| PRJ-010 | Memphis Small Business Incubator | TN | Small Business | Operating Business | $3,500,000 | $4,800,000 | 90 | 15 | 105 | $53,333 | $38,889 | — | 0 | Deep Distress | No | No | No |
| PRJ-011 | Milwaukee Affordable Apartments | WI | Affordable Housing | Real Estate | $9,500,000 | $13,500,000 | 12 | 4 | 16 | $1,125,000 | $791,667 | 64 | 0 | Severely Distressed | No | No | No |
| PRJ-012 | St. Louis Community Solar Project | MO | Clean Energy | Operating Business | $3,800,000 | $5,000,000 | 22 | 6 | 28 | $227,273 | $172,727 | — | 0 | Low Income Community | No | No | Yes |
| PRJ-013 | Charlotte Workforce Training Center | NC | Education | Real Estate | $5,500,000 | $7,500,000 | 30 | 12 | 42 | $250,000 | $183,333 | — | 14,000 | Severely Distressed | No | No | No |
| PRJ-014 | Phoenix Native American Health Clinic | AZ | Healthcare | Real Estate | $6,500,000 | $9,000,000 | 48 | 25 | 73 | $187,500 | $135,417 | — | 18,500 | Deep Distress | Yes | No | No |
| PRJ-015 | Detroit Auto Parts Manufacturer | MI | Small Business | Operating Business | $5,000,000 | $6,500,000 | 110 | 45 | 155 | $59,091 | $45,455 | — | 0 | Deep Distress | No | No | Yes |
| PRJ-016 | Indianapolis Mixed-Use Community Hub | IN | Mixed Use | Mixed Use | $7,500,000 | $10,500,000 | 35 | 10 | 45 | $300,000 | $214,286 | 24 | 20,000 | Severely Distressed | No | No | No |
| PRJ-017 | Rural Mississippi Health Access Center | MS | Healthcare | Real Estate | $3,200,000 | $4,200,000 | 20 | 15 | 35 | $210,000 | $160,000 | — | 8,000 | Deep Distress | No | Yes | No |
| PRJ-018 | Kansas City Affordable Senior Housing | MO | Affordable Housing | Real Estate | $8,500,000 | $11,800,000 | 10 | 3 | 13 | $1,180,000 | $850,000 | 56 | 0 | Low Income Community | No | No | No |
| PRJ-019 | Baltimore Community Food Market | MD | Community Facility | Real Estate | $4,200,000 | $5,800,000 | 45 | 8 | 53 | $128,889 | $93,333 | — | 11,000 | Severely Distressed | No | No | No |
| PRJ-020 | Albuquerque Mixed-Use Arts District | NM | Mixed Use | Mixed Use | $5,800,000 | $7,800,000 | 32 | 9 | 41 | $243,750 | $181,250 | 18 | 15,000 | Deep Distress | Yes | No | Yes |
| TOTALS | 20 Projects |  |  |  | $122,500,000 | $170,600,000 | 864 | 298 | 1,162 | $197,454 | $141,782 | 234 | 198,500 |  |  |  |  |


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## Appendix E: CDE Track Record

| Award Year | Allocation ($) | Deployment Status | States Deployed | Sectors | Notes |
| --- | --- | --- | --- | --- | --- |
| 2019 | $40,000,000 | Fully Deployed | IL, OH, TN | healthcare, small_business |  |
| 2021 | $55,000,000 | Fully Deployed | IL, GA, LA | education, affordable_housing |  |
| 2023 | $60,000,000 | Partially Deployed | OH, MI, MO, TN | healthcare, community_facility |  |
| TOTALS | $155,000,000 | 2 rounds fully deployed | 7 states |  | $155,000,000 total prior allocation |


---

## Methodology Note

Generated by **nmtc-application-builder v1.5.5** on 2026-08-23.

- Eligibility data: CDFI Fund NMTC Eligibility Table, 2016–2020 ACS 5-Year Estimates
- DEAL ECONOMICS: computed using the nmtc-calc library, standard leveraged NMTC structure. Statutory credit rate 39% of QEI over 7 years (IRC §45D(a)(2): 5% of the QEI on each of the first three credit allowance dates and 6% on each of the remaining four). Assumed credit price $0.83/credit and CDE fee 2.5% of QEI are market assumptions of this model, not CDFI Fund parameters. The leverage loan is the residual of QEI less investor equity, so leverage plus equity equals QEI in every surface of this document.
- IMPACT SCREENING BANDS: THIS TOOL'S OWN BANDS (5 / 12 / 20 FTE per $1MM QEI). The CDFI Fund publishes no jobs-per-QEI benchmark in any denominator: it reports job counts and dollar counts separately and never divides them, and it publishes no distribution, so no band here is a percentile. These are not a federal figure and must not be cited as one.
- READINESS SCORE: An UNSOURCED HOUSE HEURISTIC of this tool (eligibility 25%, distress concentration 25%, geographic diversity 15%, impact metrics 20%, validation 10%, completeness 5%). The weights are this tool's own judgement; they are not calibrated against award data, the CDFI Fund publishes no such weighting, and the score does not predict an award outcome. WHICH ROUND THIS IS BASED ON. This tool encodes the CY 2024-2025 NMTC Allocation Application, which is the most recent PUBLISHED Application and is closed and awarded (it opened 19 Nov 2024, closed 29 Jan 2025, and was awarded 23 Dec 2025 with $10 billion in allocation authority). The CY 2026 Allocation Application and NOAA are NOT YET PUBLISHED: the CDFI Fund has announced that CY 2026 will make $5 billion available — half the prior round — and that it will publish the round's Application Materials when the round opens. USE THIS, AND THEN RE-CHECK IT. The CY 2024-2025 Application is a real federal instrument and is the right basis to prepare against today; nothing here is unreliable. But it is a PROXY for the CY 2026 instrument, not that instrument, so every round-specific figure in this document must be re-verified against the CY 2026 materials once the Fund releases them — specifically: the allocation authority and the number of awards available; the CDE certification deadline for eligibility; Question 25's QLICI-denominated commitment levels, its area-type lists and its ladder; Question 22's QLICI-denominated Non-Metropolitan minimum and maximum; Question 15's product-flexibility ladder; the scoring thresholds in the Review Process. SEPARATELY, AND SOONER: to be eligible to apply in CY 2026, an organization must either already be a certified CDE as of the NOAA's Federal Register publication date, or have submitted its CDE Certification Application through AMIS by 11:59 p.m. ET on August 31, 2026. That deadline is not a figure this tool computes and it does not move with anything in this document. AND IF YOU ARE A PRIOR ALLOCATEE, A THIRD OBLIGATION FALLS ON THE SAME DATE: any prior Allocatee that requires action by the CDFI Fund — certifying a Subsidiary entity as a CDE, or adding a Subsidiary CDE to an Allocation Agreement — in order to meet the Qualified Equity Investment (QEI) issuance thresholds published in the CY 2026 NOAA must submit a CDE Certification Application for its Subsidiary CDE(s) through AMIS by 11:59 p.m. ET on August 31, 2026. Full eligibility information, including the QEI issuance thresholds themselves, comes with the NOAA when it publishes. Verified against cdfifund.gov on 2026-08-20.
- Community need: NOT generated by this tool — documented by the CDE and cited to sources the CDE controls

All narrative sections marked \[NARRATIVE PLACEHOLDER\] require review and customization before submission.