Shih v. Community Development Financial Institutions Fund

CourtDistrict Court, District of Columbia
DecidedAugust 4, 2025
DocketCivil Action No. 2024-1378
StatusPublished

This text of Shih v. Community Development Financial Institutions Fund (Shih v. Community Development Financial Institutions Fund) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Shih v. Community Development Financial Institutions Fund, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

PIM SHIH,

Plaintiff,

v. Civil Action No. 24 - 1378 (LLA) COMMUNITY DEVELOPMENT FINANCIAL INSTITUTIONS FUND, et al.,

Defendants.

MEMORANDUM OPINION

Plaintiff Pim Shih, proceeding pro se, brings this suit against the Community Development

Financial Institutions Fund (“CDFI Fund”) and the U.S. Department of the Treasury. ECF No. 1.

Mr. Shih claims that two private organizations that disburse monies from the CDFI Fund treated him

unfairly and that the CDFI Fund ignored his complaints about them. Id. ¶¶ 22, 38; ECF No. 11,

at 2.1 Defendants now move to dismiss the complaint. ECF No. 10. For the reasons explained

below, the court will grant Defendants’ motion and dismiss the complaint.

I. STATUTORY AND REGULATORY BACKGROUND

The CDFI Fund was established as part of the Treasury Department by the Riegle

Community Development and Regulatory Improvement Act of 1994, 12 U.S.C. § 4701 et seq.

The purpose of the Fund is to “promote economic revitalization and community development

through investment in and assistance to community development financial institutions.” 12 U.S.C.

1 The citations for ECF Documents 11 and 13 refer to the PDF page numbers, as the documents themselves do not contain internal page numbers. § 4701(b). The government does not make direct loans to individuals from the CDFI Fund;

instead, the Fund provides financing to local Community Development Financial Institutions

(“CDFIs”), which in turn “provide loans, investments, financial services and technical assistance

to underserved populations and communities.” Community Development Financial Institutions

Fund, About Us;2 see Arab v. Blinken, 600 F. Supp. 3d 59, 63 n.1 (D.D.C. 2022) (“The Court may

take judicial notice of information posted on official public websites of government agencies.”).

Notably, “[a] CDFI shall not be an agency or instrumentality of the United States, or any State or

political subdivision thereof.” 12 C.F.R. § 18005.201(b)(6).

The Treasury Department has issued regulations to ensure nondiscrimination in the

provision of federal financial assistance through its programs, including the CDFI Fund. 31 C.F.R.

§§ 22.1, 22.4; see Community Development Financial Institutions Fund, Non-Discrimination

Statement and Civil Rights Information.3 An individual who believes that he has been

discriminated against in connection with the CDFI Fund program may file a complaint with the

Treasury Department’s Office of Civil Rights and Equal Employment Opportunity. 31 C.F.R.

§ 22.7; see U.S. Department of the Treasury, Office of Civil Rights and Equal Employment

Opportunity.4 The final determination of such a complaint is subject to judicial review. 31 C.F.R.

§ 22.11.

2 Available at https://perma.cc/7PE8-GZUC. 3 Available at https://perma.cc/CBX5-4S2R. 4 Available at https://perma.cc/S9FM-FACT.

2 II. FACTUAL BACKGROUND

The following factual allegations drawn from Mr. Shih’s complaint, ECF No. 1, are

accepted as true for the purpose of evaluating the motion before the court, Jerome Stevens Pharms.,

Inc. v. Food & Drug Admin., 402 F.3d 1249, 1250 (D.C. Cir. 2005).

Mr. Shih is a “minority business owner” who identifies as an “Asian-American and [a]

Christian.” ECF No. 1 ¶ 4. Mr. Shih applied to two CDFIs—the Greater Newark Enterprise

Corporation (“GNEC”) and the Union County Economic Development Corporation

(“UCEDC”)—seeking funds for his business. Id. ¶¶ 6, 9, 11-14. “[D]espite [his] robust FICO

score” and “business serving the Newark, NJ area,” id. ¶ 11, both organizations declined to loan

Mr. Shih monies from the CDFI Fund, id. ¶¶ 11-14.

In August 2023, Mr. Shih sent an email to the CDFI Fund “expressing dissatisfaction with

the difficulties encountered in obtaining financial assistance” from GNEC and UCEDC. Id. ¶ 7.

Specifically, he wrote that his “experience this year and last year is [that] it is harder to approach

CDFI than regular loaners” and that “[t]he people with CDFI money to give don’t seem to care

about the community and making their country better. They seem to want to make companies

jump through hoops and seem judgemental [sic] and not helpful at all, or even discriminatory.”

ECF No. 15-1 (Mr. Shih’s initial letter to the CDFI Fund); see Banneker Ventures, LLC v. Graham,

798 F.3d 1119, 1133 (D.C. Cir. 2015) (“A district court may consider a document that a complaint

specifically references without converting the motion into one for summary judgment.”). Mr. Shih

alleges that the CDFI Fund responded the following day by “acknowledging [his] concerns and

requesting additional documentation of specific encounters with CDFI-approved organizations.”

ECF No. 1 ¶ 8. He maintains that he “provided details regarding interactions with GNEC and

UCEDC,” id. ¶ 9, and that the CDFI Fund “assured [him] that a representative would contact [him]

3 within two business days,” id. ¶ 10. “Despite CDFI’s initial acknowledgement and assurance of a

prompt response,” Mr. Shih did not “receive[] any communication for three months.” Id. ¶ 15. In

September 2023, Mr. Shih “emphasized [his] protected status as an Asian American and believer

[in] Jesus Christ The Lord,” and he alleges that the CDFI Fund’s “lack of response may be linked

to discrimination based on these factors.” Id. ¶ 16.

III. PROCEDURAL HISTORY

In May 2024, Mr. Shih brought this case against the CDFI Fund and the Treasury

Department seeking declaratory, compensatory, and injunctive relief. ECF No. 1, at 16. In

Count I, Mr. Shih contends that the CDFI Fund’s administration of its program violates Title VI

of the Civil Rights Act of 1964, 42 U.S.C. § 2000d et seq., and 42 U.S.C. § 1983. ECF No. 1

¶¶ 22-27. In Count II, he alleges that the CDFI Fund negligently breached its duty of “ensuring

fair and non-discriminatory practices” when processing his loan application(s). Id. ¶¶ 28-29. In

Count III, Mr. Shih asserts that the CDFI Fund violated Title VI by discriminating against him.

Id. ¶¶ 30-36. And in Count IV, he claims that the CDFI Fund’s “prolonged silence and inaction

following [his] expression of concerns surrounding the discriminatory application process”

constitutes retaliation in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e

et seq. ECF No. 1 ¶¶ 37-43.

In January 2025, Defendants filed a motion to dismiss for lack of subject-matter jurisdiction

under Federal Rule of Civil Procedure 12(b)(1) and for failure to state a claim under Rule 12(b)(6).

ECF No. 10, at 1. Mr. Shih quickly filed an opposition. ECF No. 11. Because Mr. Shih filed his

opposition before the court had an opportunity to advise him of his obligations under Fox v.

Strickland, 837 F.2d 507, 509 (D.C. Cir. 1988), the court issued a Fox/Neal order and allowed him

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Shih v. Community Development Financial Institutions Fund, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shih-v-community-development-financial-institutions-fund-dcd-2025.