CDBG Recordkeeping Requirements

1

• CDBG Recordkeeping Requirements
• For Local Officials

2
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

3
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

4
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 administrators 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

6
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

7
Recordkeeping

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

8
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

9
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

10
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

11
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