Disability Advocates Offer Help as Treasury Implements ABLE Act

I am writing in regard to the U.S. Department of the Treasury Notice 2015-18, providing advance notification of proposed regulations under Section 529A of the Internal Revenue Code, as established in the Achieving a Better Life Experience Act of 2014 (ABLE Act). On behalf of the Disability Opportunity Fund (DOF) and Disability CDFI Coalition (DCC), I strongly believe that implementation of the ABLE Act savings accounts not only marks an important milestone for the disability community, but it represents a key opportunity for CDFIs to work with the Treasury Department and traditional banking partners to expand access to this new resource.

The Disability Opportunity Fund is a national Community Development Financial Institution (CDFI) located in Albertson, New York that is exclusively focused on serving unmet financing needs of individuals with disabilities and their families. As a father of a child with cerebral palsy, I launched DOF in 2007 with the goal of partnering with people with disabilities to expand their access to capital. Informed by my career at Merrill Lynch and as a former Assistant United States Attorney, I designed DOF as a business-inclusive model to provide housing opportunities for and to advance the needs of people with disabilities and their families.

Building on the success of DOF, I spearheaded the launch of the Disability CDFI Coalition (DCC) in February 2015. The DCC is a membership organization committed to harnessing the power of CDFIs to empower people with disabilities and their families. The coalition serves as a bridge between the CDFI industry and the disability community to ensure that CDFIs can effectively address the needs of individuals with disabilities and their families. DCC also offers technical assistance and support to CDFIs developing financing products and services to address the needs of people with disabilities. Since its launch just a few weeks ago, some 50 individuals and organizations from the CDFI industry and disability community have joined the coalition.

In the coming months, the Treasury Department will develop regulations and rules to bring the concept of ABLE Act savings accounts into reality. As it undergoes this process, it is critical that the Department seek the input of not only disability advocates, but CDFIs that have a strong track record of meeting the needs of underserved individuals and markets -- including individuals with disabilities and their families.

Moreover, many CDFIs already support asset development for people with disabilities through the operation of Individual Development Account programs. Under the program, CDFIs recruit participants, provide financial education classes, and provide additional training based on the participant's asset choice -- homeownership education and counseling, small business training, or guidance on choosing and enrolling in post-secondary education or job training. The experience of CDFIs in supporting asset development among traditionally underserved individuals and communities will be invaluable to the Department as it moves forward under the ABLE Act.

I look forward to working with you to help ensure that ABLE Act savings accounts serve as a significant tool for individuals with disabilities and their families.