ConPlan and CAPER & State CDBG

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Presentation transcript:

ConPlan and CAPER & State CDBG If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

ConPlan and CAPER & State CDBG If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

ConPlan and CAPER & State CDBG Project Hierarchy Expected Program Income If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

How are States using Projects? If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

How are States using Projects? 15 - MOD Categories 26 - Local Governments 7 - Single Annual Project 1 - Counties 1 - Fund-types 2016 Projects If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

MOD Categorical Projects If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

MOD Categorical Projects Goal: Improve Infrastructure If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

MOD Categorical Projects Goal: Improve Infrastructure MOD Category: Infrastructure If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

MOD Categorical Projects Goal: Improve Infrastructure MOD Category: Infrastructure Project: Water & Sewer If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

MOD Categorical Projects Goal: Improve Infrastructure MOD Category: Infrastructure Project: Water & Sewer Activities: Allen Town wells If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

MOD Categorical Projects Goal: Improve Infrastructure MOD Category: Infrastructure Project: Water & Sewer Activities: Allen Town wells Accomplishments If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

MOD Categorical Projects Goal: Improve Infrastructure MOD Category: Infrastructure Project: Water & Sewer Activities: Allen Town wells Accomplishments If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

Local Government-based Projects? Goal: Improve Infrastructure MOD Category: Infrastructure Project: Water & Sewer Activities: Allen Town wells Accomplishments If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

Local Government-based Projects? Goal: Improve Infrastructure MOD Category: Infrastructure Project: Allen Town Activities: Allen Town wells Accomplishments If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

Local Government-based Projects? Goal: Improve Infrastructure MOD Category: Infrastructure Project: Allen Town Activities: Allen Town wells Accomplishments If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

Local Government-based Projects? Goal: Improve Infrastructure MOD Category: Infrastructure Project: Bishop Town Activities: Bishop Town wells Accomplishments If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

Local Government-based Projects? Goal: Improve Infrastructure MOD Category: Infrastructure Project: Charles Town Activities: Charles Town wells Accomplishments If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

Local Government-based Projects? Goal: Improve Infrastructure MOD Category: Infrastructure Project: Dover Town Activities: Dover Town wells Accomplishments If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

Local Government-based Projects? Goal: Improve Infrastructure MOD Category: Infrastructure Project: Ellis Town Activities: Ellis Town wells Accomplishments If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

Local Government-based Projects? Goal: Improve Infrastructure MOD Category: Infrastructure Project: Ellis Town Activities: Ellis Housing Rehab Accomplishments If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

Local Government-based Projects? Goal: Improve Infrastructure MOD Category: Infrastructure Project: Ellis Town Activities: Ellis Housing Rehab Accomplishments If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

How are States using Projects? 15 - MOD Categories 26 - Local Governments 7 - Single Annual Project 1 - Counties 1 - Fund-types 2016 Projects If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

ConPlan and CAPER & State CDBG Project Hierarchy Expected Program Income If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

ConPlan and CAPER & State CDBG Project Hierarchy Expected Program Income If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

Federal resources. The consolidated plan must provide a concise summary of the federal resources expected to be made available. These resources include grant funds and program income. If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

LIST of Local Program Income Accounts (PI and RL) in ACTION PLAN If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

LIST of Local Program Income Accounts (PI and RL) in ACTION PLAN Name of the local entity, Contact information, Amounts $ EXPECTED, Eligible activity type(s), and National objective(s). 24 CFR 91.320(k)(1)(iv) If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

LIST of Local Program Income Accounts (PI and RL) in ACTION PLAN Name of the local entity, Contact information, Amounts $ EXPECTED, Eligible activity type(s), and National objective(s). 24 CFR 91.320(k)(1)(iv) If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

Local Government Reporting of any EXPECTED Amounts: Building this list: Local Government Reporting of any EXPECTED Amounts: If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

Local Government Reporting of any EXPECTED Amounts: Building this list: Local Government Reporting of any EXPECTED Amounts: Balances carrying over If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

Local Government Reporting of any EXPECTED Amounts: Building this list: Local Government Reporting of any EXPECTED Amounts: Balances carrying over Scheduled Loan Payments If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

Local Government Reporting of any EXPECTED Amounts: Building this list: Local Government Reporting of any EXPECTED Amounts: Balances carrying over Scheduled Loan Payments Properties Listed for Sale If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

ADD this list to the Action Plan: Attach the Table, Admin AD-26 If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

ADD this list to the Action Plan: Add a Method, MOD AP-30 Attach the Table, Admin AD-26 If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

AP-30 Methods of Distribution

ADD this list to Action Plan: Add a Method, MOD AP-30 Attach the Table, Admin AD-26 If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

ADD this list to Action Plan: Add a Method, MOD AP-30 Attach the Table, Admin AD-26 If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

Information on local program income accounts provides a full picture of the CDBG program across the State.

ConPlan and CAPER If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

ConPlan and CAPER If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

State CDBG Performance & Evaluation Report (PER) If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

PR28 Financial Summaries (annual grant-basis) PR28 Activity Summary (program year-basis) PR28 Financial Summaries (annual grant-basis) One PR28 for as many grants that are open at the time.

CPD Notice 16-10 Submission Procedure:

CPD Notice 16-10 Submission Procedure: States generate the report

CPD Notice 16-10 Submission Procedure: States generate the report Make Adjustments and attach Explanations

CPD Notice 16-10 Submission Procedure: States generate the report Make Adjustments and attach Explanations Include with CAPER for public comment and for submission

PR28 ACTIVITY SUMMARY

PR28 ACTIVITY SUMMARY Program year-based

PR28 ACTIVITY SUMMARY Program year-based Captures activities open at sometime during the program year, regardless of funding source.

PR28 ACTIVITY SUMMARY The PR28 Activity Summary will return a lot of detail about every activity that was open at sometime in the year, including draws, accomplishments, etc. This particular activity is in completed status, but that completion happened during the program year for this particular report, 2015. But the format of the report is more narrative in nature, and it doesn’t export to a spreadsheet in any way that resembles a spreadsheet, making this a difficult report to use for analysis.

PR28 FINANCIAL SUMMARY

How does it assign activities to a Grant Year?

The grant year field is highlighted The grant year field is highlighted. For the States, that is a manual entry field. For 2015 and subsequent grants it becomes fixed, the same as the grant account being drawn against in LOCCS. But for everything prior to 2015, the grant year field is a manual entry, and draws were set to LOCCS on a FIFO basis, meaning that even if the grantee entered 2013 here, the vouchers for this activity might say that they were applied to an earlier grant, like the 2011 grant. The PR28 uses this field to assign the funding and draws to a specific grant. So when you run the PR28 Financial Summary for the 2013 grant, the $3,825 of funding and draws will be included in that report. This grant year field is editable at any time. So if the wrong grant year was entered here, instead of making adjustments to two different PERs, the State could just come back here and change the year. If the State wants to know which activities have a certain grant year, without digging into IDIS and clicking on activity after activity, the can run a PR57. That is the only other report that uses this grant year field. Of course with 2015 and subsequent grants this is all a moot point. But in the meantime, for activities funded with pre-2015 grants, the PR57 is your best bet at reconciling a PR28.

So only the PR28 Financial Summary and the PR57 State Commitments report use that grant year field. And that is important to know, because all other reports are going to show you a “grant year” according to the LOCCs draw. Shelburne example: 2014 grant year for voucher, but 2013 grant year for funding… for 2015 and subsequent grants these will match.

Adjustments to the PR28 Financial Summary

So, What are these adjustments that the State has to do to submit the PR28 Financial Summary? When a grantee select the Reports Module, it doesn’t take them to MicroStrategy right away, first they have an option to make adjustments to certain reports.

A copy of this screen will be in the appendices of the new Notice, and is in the handout attached to the invite. The grantee may add and edit adjustments for any year. A few of the adjustments are a requirement, such line 60, which essentially indicates that this if the final PER and the grant is ready for closeout; and line 62, selecting the benefit period for the 70% public benefit test. States may choose a 1-, 2- or 3-year period. The most common adjustments for errors are related to associating money with the proper grant year. That is because the PR28 Financial Summary looks at activity funding and draws based the manual entry of the grant year. When there is an error, you would expect to see that amount being associated with a different grant, that means you would see two adjustment screens with a negative amount on one year and a positive amount on another year.

A copy of this screen will be in the appendices of the new Notice, and is in the handout attached to the invite. The grantee may add and edit adjustments for any year. A few of the adjustments are a requirement, such line 60, which essentially indicates that this if the final PER and the grant is ready for closeout; and line 62, selecting the benefit period for the 70% public benefit test. States may choose a 1-, 2- or 3-year period. The most common adjustments for errors are related to associating money with the proper grant year. That is because the PR28 Financial Summary looks at activity funding and draws based the manual entry of the grant year. When there is an error, you would expect to see that amount being associated with a different grant, that means you would see two adjustment screens with a negative amount on one year and a positive amount on another year.

A copy of this screen will be in the appendices of the new Notice, and is in the handout attached to the invite. The grantee may add and edit adjustments for any year. A few of the adjustments are a requirement, such line 60, which essentially indicates that this if the final PER and the grant is ready for closeout; and line 62, selecting the benefit period for the 70% public benefit test. States may choose a 1-, 2- or 3-year period. The most common adjustments for errors are related to associating money with the proper grant year. That is because the PR28 Financial Summary looks at activity funding and draws based the manual entry of the grant year. When there is an error, you would expect to see that amount being associated with a different grant, that means you would see two adjustment screens with a negative amount on one year and a positive amount on another year.

A copy of this screen will be in the appendices of the new Notice, and is in the handout attached to the invite. The grantee may add and edit adjustments for any year. A few of the adjustments are a requirement, such line 60, which essentially indicates that this if the final PER and the grant is ready for closeout; and line 62, selecting the benefit period for the 70% public benefit test. States may choose a 1-, 2- or 3-year period. The most common adjustments for errors are related to associating money with the proper grant year. That is because the PR28 Financial Summary looks at activity funding and draws based the manual entry of the grant year. When there is an error, you would expect to see that amount being associated with a different grant, that means you would see two adjustment screens with a negative amount on one year and a positive amount on another year.

PR28 FINANCIAL SUMMARY

Part I: Financial Status PR28 Financial Summary: Table of Contents Part I: Financial Status A. Sources of State CDBG Funds B. State CDBG Resources by Use C. Expenditures of State CDBG Resources D. Compliance with Public Service Cap E. Compliance with Planning and Administration Cap Part II: Compliance with Overall Low and Moderate Income Benefit

Part I: Financial Status PR28 Financial Summary: Table of Contents Part I: Financial Status A. Sources of State CDBG Funds B. State CDBG Resources by Use C. Expenditures of State CDBG Resources D. Compliance with Public Service Cap E. Compliance with Planning and Administration Cap Part II: Compliance with Overall Low and Moderate Income Benefit

Receipts of Program Income (PI, RL, SF) During* Initial Program Year Deposit of Annual Grant

Part I: Financial Status PR28 Financial Summary: Table of Contents Part I: Financial Status A. Sources of State CDBG Funds B. State CDBG Resources by Use C. Expenditures of State CDBG Resources D. Compliance with Public Service Cap E. Compliance with Planning and Administration Cap Part II: Compliance with Overall Low and Moderate Income Benefit

Part I: Financial Status PR28 Financial Summary: Table of Contents Part I: Financial Status A. Sources of State CDBG Funds B. State CDBG Resources by Use C. Expenditures of State CDBG Resources D. Compliance with Public Service Cap E. Compliance with Planning and Administration Cap Part II: Compliance with Overall Low and Moderate Income Benefit

Funding from Program Income (PI, RL, SF) During Initial Program Year Grant Funding & Funding from the LA account for the same grant

Line 11 – Timely Distribution Total obligated to recipients from just the grant. Consider the compliance relationship to 24 CFR 570.494 and HUD 40108 Line 9 is derived from activities’ grant funding in IDIS, which is not the standard for §570.494. Therefore, Line 10 allows the state to adjust for amounts “obligated and announced” but not yet funded in IDIS. Additionally, the 15 month deadline for §570.494 will typically not align with the end of the program year for this report, meaning that in limited circumstances amounts that were “obligated and announced” and reported on the HUD 40108 may have been subsequently de-obligated by the state, which would cause this amount to be less than the award amount. As appropriate, the state should discuss these factors in the explanation provided for Line 10;

Line 11 – Timely Distribution Total obligated to recipients from just the grant. Consider the compliance relationship to 24 CFR 570.494 and HUD 40108 Line 9 is derived from activities’ grant funding in IDIS, which is not the standard for §570.494. Therefore, Line 10 allows the state to adjust for amounts “obligated and announced” but not yet funded in IDIS. Additionally, the 15 month deadline for §570.494 will typically not align with the end of the program year for this report, meaning that in limited circumstances amounts that were “obligated and announced” and reported on the HUD 40108 may have been subsequently de-obligated by the state, which would cause this amount to be less than the award amount. As appropriate, the state should discuss these factors in the explanation provided for Line 10;

Line 9 is derived from activities’ grant funding in IDIS, which is not the standard for §570.494. Therefore, Line 10 allows the state to adjust for amounts “obligated and announced” but not yet funded in IDIS. Additionally, the 15 month deadline for §570.494 will typically not align with the end of the program year for this report, meaning that in limited circumstances amounts that were “obligated and announced” and reported on the HUD 40108 may have been subsequently de-obligated by the state, which would cause this amount to be less than the award amount. As appropriate, the state should discuss these factors in the explanation provided for Line 10;

Line 9 is derived from activities’ grant funding in IDIS, which is not the standard for §570.494. Therefore, Line 10 allows the state to adjust for amounts “obligated and announced” but not yet funded in IDIS. Additionally, the 15 month deadline for §570.494 will typically not align with the end of the program year for this report, meaning that in limited circumstances amounts that were “obligated and announced” and reported on the HUD 40108 may have been subsequently de-obligated by the state, which would cause this amount to be less than the award amount. As appropriate, the state should discuss these factors in the explanation provided for Line 10;

Line 9 is derived from activities’ grant funding in IDIS, which is not the standard for §570.494. Therefore, Line 10 allows the state to adjust for amounts “obligated and announced” but not yet funded in IDIS. Additionally, the 15 month deadline for §570.494 will typically not align with the end of the program year for this report, meaning that in limited circumstances amounts that were “obligated and announced” and reported on the HUD 40108 may have been subsequently de-obligated by the state, which would cause this amount to be less than the award amount. As appropriate, the state should discuss these factors in the explanation provided for Line 10;

Line 11 – Timely Distribution Total obligated to recipients from just the grant. Consider the compliance relationship to 24 CFR 570.494 and HUD 40108 Line 9 is derived from activities’ grant funding in IDIS, which is not the standard for §570.494. Therefore, Line 10 allows the state to adjust for amounts “obligated and announced” but not yet funded in IDIS. Additionally, the 15 month deadline for §570.494 will typically not align with the end of the program year for this report, meaning that in limited circumstances amounts that were “obligated and announced” and reported on the HUD 40108 may have been subsequently de-obligated by the state, which would cause this amount to be less than the award amount. As appropriate, the state should discuss these factors in the explanation provided for Line 10;

Line 18 – Admin Match This is the only place in IDIS to enter the amount of the administration cost match required by 24 CFR 570.489(a)(1). Line 9 is derived from activities’ grant funding in IDIS, which is not the standard for §570.494. Therefore, Line 10 allows the state to adjust for amounts “obligated and announced” but not yet funded in IDIS. Additionally, the 15 month deadline for §570.494 will typically not align with the end of the program year for this report, meaning that in limited circumstances amounts that were “obligated and announced” and reported on the HUD 40108 may have been subsequently de-obligated by the state, which would cause this amount to be less than the award amount. As appropriate, the state should discuss these factors in the explanation provided for Line 10;

Funding from Program Income (PI, RL, SF) During Initial Program Year Grant Funding & Funding from the LA account for the same grant

Part I: Financial Status PR28 Financial Summary: Table of Contents Part I: Financial Status A. Sources of State CDBG Funds B. State CDBG Resources by Use C. Expenditures of State CDBG Resources D. Compliance with Public Service Cap E. Compliance with Planning and Administration Cap Part II: Compliance with Overall Low and Moderate Income Benefit

Part I: Financial Status PR28 Financial Summary: Table of Contents Part I: Financial Status A. Sources of State CDBG Funds B. State CDBG Resources by Use C. Expenditures of State CDBG Resources D. Compliance with Public Service Cap E. Compliance with Planning and Administration Cap Part II: Compliance with Overall Low and Moderate Income Benefit

Draws from Program Income (PI, RL, SF) During* Initial Program Year Grant Draws & Draws from the LA account for the same grant

      State Admin and TA Cap *For 2014 and prior grants, pursuant to §570.489(a)(1)(v), states had the option of demonstrating compliance with this requirement in two ways, either cumulatively or year-by-year. Pursuant to the regulatory changes made by the Interim Rule, FR 5797-I-01, Changes to Accounting Requirements for the Community Development Block Grants (CDBG) Program, for 2015 and subsequent grants, compliance with §570.489(a)(1) may only be demonstrated on a year-by-year basis.

State Admin and TA Cap Public Service Cap       State Admin and TA Cap Public Service Cap *For 2014 and prior grants, pursuant to §570.489(a)(1)(v), states had the option of demonstrating compliance with this requirement in two ways, either cumulatively or year-by-year. Pursuant to the regulatory changes made by the Interim Rule, FR 5797-I-01, Changes to Accounting Requirements for the Community Development Block Grants (CDBG) Program, for 2015 and subsequent grants, compliance with §570.489(a)(1) may only be demonstrated on a year-by-year basis.

State Admin and TA Cap Public Service Cap Planning and Admin Cap       State Admin and TA Cap Public Service Cap Planning and Admin Cap Tier One: Combined Tier Two: Grant-Only *For 2014 and prior grants, pursuant to §570.489(a)(1)(v), states had the option of demonstrating compliance with this requirement in two ways, either cumulatively or year-by-year. Pursuant to the regulatory changes made by the Interim Rule, FR 5797-I-01, Changes to Accounting Requirements for the Community Development Block Grants (CDBG) Program, for 2015 and subsequent grants, compliance with §570.489(a)(1) may only be demonstrated on a year-by-year basis.

Draws from Program Income (PI, RL, SF) During* Initial Program Year Grant Draws & Draws from the LA account for the same grant

Part I: Financial Status PR28 Financial Summary: Table of Contents Part I: Financial Status A. Sources of State CDBG Funds B. State CDBG Resources by Use C. Expenditures of State CDBG Resources D. Compliance with Public Service Cap E. Compliance with Planning and Administration Cap Part II: Compliance with Overall Low and Moderate Income Benefit

Part I: Financial Status PR28 Financial Summary: Table of Contents Part I: Financial Status A. Sources of State CDBG Funds B. State CDBG Resources by Use C. Expenditures of State CDBG Resources D. Compliance with Public Service Cap E. Compliance with Planning and Administration Cap Part II: Compliance with Overall Low and Moderate Income Benefit

Draws from Program Income (PI, RL, SF) During* Initial Program Year Grant Draws Draws from the LA account for the same grant

Draws from Program Income (PI, RL, SF) During* Initial Program Year Grant Draws Draws from the LA account for the same grant

Draws from Program Income (PI, RL, SF) During* Initial Program Year Grant Draws Draws from the LA account for the same grant

Part I: Financial Status PR28 Financial Summary: Table of Contents Part I: Financial Status A. Sources of State CDBG Funds B. State CDBG Resources by Use C. Expenditures of State CDBG Resources D. Compliance with Public Service Cap E. Compliance with Planning and Administration Cap Part II: Compliance with Overall Low and Moderate Income Benefit

Part I: Financial Status PR28 Financial Summary: Table of Contents Part I: Financial Status A. Sources of State CDBG Funds B. State CDBG Resources by Use C. Expenditures of State CDBG Resources D. Compliance with Public Service Cap E. Compliance with Planning and Administration Cap Part II: Compliance with Overall Low and Moderate Income Benefit

Review

ConPlan and CAPER & State CDBG Project Hierarchy Expected Program Income If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.

PR28 Financial Summaries (annual grant-basis) PR28 Activity Summary (program year-basis) PR28 Financial Summaries (annual grant-basis) One PR28 for as many grants that are open at the time.

Robert.C.Peterson@hud.gov If you are allowing a local government to retain program income, either for continuing the same activity or for a revolving loan fund.