ICBA sent comments to the Office of Management and Budget on its proposed revisions to the Guidance for Federal Financial Assistance. ICBA said it supports the proposed rule's stated objectives of improving transparency and accountability in the use of federal financial assistance dollars, but is concerned that several of the proposed changes to the government-wide CFR framework, as they would apply to the CDFI Fund's grant and award programs, risk contravening the intent of Congress in establishing the CDFI Fund and could inhibit the ability of community bank CDFIs to deliver economic impact in the communities they serve.