1

CDBG Recordkeeping Requirements

For Local Officials

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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

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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

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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

5

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

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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

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Recordkeeping

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

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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

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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

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

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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