CDBG Recordkeeping Requirements For Local Officials 1 Recordkeeping

CDBG Recordkeeping Requirements For Local Officials 1

Recordkeeping Requirements • UGLG Records 24 CFR 570. 490 – States will Establish Recordkeeping Requirements for UGLGs • State records include information from UGLG reports and records • Both State and UGLG Records – Must Include Racial, Ethnic, and Gender Data on Applicants, Participants, Beneficiaries 2

Recordkeeping • Absolutely critical to establish good record keeping system • Records are the only method of verifying compliance with the program requirements • All records must be retained for the period of time designated by the state from the application through the certification of closeout 3

Recordkeeping • Local government must keep all records because the state, HUD, general public, or the press, may want or need to access them for a variety of valid reasons • Keep files in a secure location in the UGLG, not in the grant administrator’s car 4

Recordkeeping • • Application Award letter Grant agreement Citizen Participation Plan All financial records Program Income Environmental Review Record – (Especially Release of Funds Letter) • Procurement Documents • Labor Standards Documents 5

Recordkeeping • Section 3 Reports • WBE/MBE Reports • Proof that projects are eligible and meet a national objective • Sub-recipient agreements • Affordability agreements (housing) • Economic development agreements to provide jobs (specifics) • Job retention and creation tracking form 6

Recordkeeping • • • Acquisition and Relocation Files Acquisition and Disposition Register Documentation of AFFH activities Income surveys Monitoring Letters Beneficiary information 7

Recordkeeping • Close out documents (as specified by state) – Monitoring findings resolved and final budget completed based on actual expenditures – Certificate of completion (from State) – Final audit report – Others • Records related to any open audits, reviews, or investigations should be retained 8

Record Retention • Length of time for record retention at local level is related to when HUD closes out the Federal grant with the State • 24 CFR 570. 490(d): Records of the UGLG shall be retained for three years after the State grant is closed by HUD • Change of use of a project by the UGLG requires longer period of record retention 9

Record Retention • Hold records until notified by State • Or, For Other Specified Periods – 24 CFR 570. 487, Other Applicable Laws – 24 CFR 570. 488, Displacement, Relocation, etc

Access to Records • UGLG must provide access to records (24 CFR 570. 490(c)) • HUD, IG, and GAO have access rights to all records • State and UGLG will provide citizens with reasonable information about past use of CDBG funds 11