2011 CDBG Recipients’ Workshop CONFLICT OF INTEREST PROHIBITION

Page CDBG Recipients’ WorkshopSeptember Conflicts Prohibited No covered persons may obtain a financial interest or benefit from a CDBG-assisted activity, or have an interest in any contract, either for themselves or those with whom they have family or business ties, during their tenure or for one year thereafter. See page 12 CDBG Recipients’ Manual.

Page CDBG Recipients’ WorkshopSeptember Covered Persons Employees, Consultants, Elected or Appointed Officials, or Sub-recipients, and their families, of the State or Local Unit of Government receiving or administering CDBG.

Page CDBG Recipients’ WorkshopSeptember Requesting an Exception Granted by DCA on a case-by-case basis. Can be granted only if it will “serve the purposes of the CDBG program.” Request must be in writing to DCA. Submit ASAP.

Page CDBG Recipients’ WorkshopSeptember Conflict of Interest Prohibited We can grant an exception, not a waiver.

Page CDBG Recipients’ WorkshopSeptember Requesting an Exception Fully describe nature of conflict. Maps are helpful Describe the Public Disclosure. Copy of Posted Agenda or Advertisement See new material in 2011 Recipients’ Manual Certified Minutes of meeting Include opinion of local attorney addressing state and local law. How was “non-involvement” requirement met?

Page CDBG Recipients’ WorkshopSeptember DCA Decision Factors Is person involved LMI? Is the benefit the same as others receiving benefit? Have they withdrawn from responsibilities or decision making process? See other factors at 24 CFR (h)

Page CDBG Recipients’ WorkshopSeptember Procurement Conflicts of Interest Covers procurement of goods or services. Elected Officials or staff can not be a party to any contract. No exceptions. See Chapter 3 of Recipients’ Manual.

Page CDBG Recipients’ WorkshopSeptember For More Information: Recipients’ Manual ▪Chapter 1, Section 12, page 11 to 14. ▪Chapter 3, Section 4, page 60 ▪ Appendix II, Item V Regulation ▪24 CFR Part (h) ▪24 CFR Part 85.36