POST-AWARD COMPLIANCE CHECKLIST

Capital Magnet Fund: Compliance Requirements

What you must do after you win this award — administered by CDFI Fund US Treasury · Federal Program.

10
Total requirements
4
Clawback-risk items
10
Deadline-bound

⚠ Common Disallowed-Cost Pitfalls

  • Recordkeeping: Failure to retain records or allow access will result in inability to support reported expenditures; costs cannot be claimed without documentation
  • Reporting: Failure to submit required annual reports can trigger non-compliance determinations and potential recapture of funds
  • Financial & Cost Eligibility: Significant deficiencies in audit reports must be explained and corrected; non-remediation can trigger fund recapture
  • Financial & Cost Eligibility: Failure to meet leverage requirements results in disallowed costs and potential clawback of unlevered amounts
  • Other Obligations: Expenditures for lobbying activities are ineligible and will be disallowed
  • Ongoing Eligibility: Costs incurred for unapproved uses are ineligible and will be disallowed; may trigger clawback
  • Financial & Cost Eligibility: Loss of affordability or failure to verify income compliance results in project noncompliance and potential loss of project completion status
  • Procurement & Vendor Rules: Non-competitive or improperly documented procurements result in disallowed costs
  • Reporting: Failure to achieve Project Completion or misreporting status affects leverage calculations and project performance evaluation; may trigger non-compliance
  • Financial & Cost Eligibility: Misuse or misreporting of Program Income results in disallowed costs and repayment obligation

Reporting

  • Clawback riskAnnual

    Recipients must submit annual reports to the CDFI Fund as specified in the Assistance Agreement, including project-level and portfolio-level compliance data via the AMIS system.

    Deadline: Due dates vary by award; CDFI Fund sends reminders 365, 180, 90, 60, 30 and 15 days prior to deadline

    Source: 12 CFR § 1807.901; CMF Compliance FAQs (June 2025); AMIS User Guide CMF Compliance and Reporting

  • HighEvent Driven

    Recipients must track and report Project Completion status (including title transfer and final CMF disbursement for real estate; specific requirements for non-real estate activities per 12 CFR § 1807.503) and Placed in Service dates for all projects.

    Deadline: Project Completion and Placed in Service status reported within annual project report following achievement

    Source: 12 CFR § 1807.503; CMF Compliance FAQs section 4 (Project Completion, Placed into Service)

Financial & Cost Eligibility

  • Clawback riskAnnual

    Recipients must provide periodic financial reporting, including audited financial statements and must comply with audit requirements. Single Audit reports (A-133) must be submitted if applicable based on Federal funds expended.

    Deadline: Financial statements and single audit reports due annually in accordance with 2 CFR 200.501

    Source: 12 USC 4569(b)(ii)(I); 2 CFR 200 (Uniform Guidance); CMF Compliance FAQs (June 2025)

  • Clawback riskAnnual

    Recipients must achieve the private leverage multiplier specified in Schedule 1 of their Assistance Agreement by the Investment Period End Date. The total Eligible Project Costs funded by Private Leveraged Capital must equal or exceed the CMF Award amount times the private leverage multiplier.

    Deadline: Leverage achievement measured at end of each reporting period and at Investment Period End Date

    Source: CMF Compliance FAQs (June 2025); 12 CFR § 1807.500

  • HighAnnual

    Recipients must ensure housing projects maintain affordability for the entire Affordability Period (at least 10 years or longer as specified in the NOFA). Tenant income must be verified and re-examined annually; occupancy data must be reported.

    Deadline: Tenant income recertification and occupancy data reporting due with annual project reports

    Source: 12 CFR § 1807.104 (Affordability Period definition); CMF Compliance FAQs sections 17.1-17.3

  • MediumAnnual

    Recipients must track Program Income (gross income from CMF-financed projects) separately and report it annually. Program Income must be used for eligible uses or returned to the CDFI Fund as specified in the Assistance Agreement.

    Deadline: Program Income reported in annual financial and project reports

    Source: 12 CFR § 1807.104 (Program Income definition); CMF Compliance FAQs

Procurement & Vendor Rules

  • HighEvent Driven

    Recipients must comply with the Uniform Administrative Requirements and Cost Principles (2 CFR 200) in all procurements, including competitive bidding requirements for purchases of goods, services, and construction.

    Deadline: Procurement standards apply to all acquisitions over applicable thresholds at time of procurement

    Source: 12 CFR § 1807.201 (Uniform Administrative Requirements apply); 2 CFR 200.317-326

Recordkeeping

  • Clawback riskOngoing

    Recipients must retain all applicable record retention requirements set forth in the Uniform Administrative Requirements, the Assistance Agreement, and the applicable NOFA. The U.S. Treasury, Comptroller General, and authorized representatives have full access to all books, documents, records, and financial statements relating to use of Federal funds.

    Deadline: Documentation must be retained for the duration of the grant and through any audit period

    Source: 12 CFR § 1807.901(d); 12 USC 4569(b)(ii)(I)

Ongoing Eligibility

  • HighEvent Driven

    Recipients must obtain prior written CDFI Fund approval before engaging in any Eligible Use or eligible activity not specifically approved in Schedule 1 of the Assistance Agreement. Amendments to Assistance Agreements are granted only in limited circumstances.

    Deadline: Amendment requests must be submitted before engaging in the new activity; approval must be received in writing

    Source: CMF Compliance FAQs (June 2025), Q 2.3-2.4; CMF Program Amendments Guide

Other Obligations

  • HighOngoing

    Recipients may not use CMF Award funds to pay any person to influence or attempt to influence any agency, elected official, or state/local government official regarding contracts, grants, loans, or cooperative agreements (lobbying restriction).

    Deadline: Restriction applies to all fund expenditures throughout the grant period

    Source: 12 USC 4569(b)(2)

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This checklist is compiled from official program sources and general grant-management rules for informational purposes. Final compliance obligations are governed by your specific grant agreement and the administering agency — always verify with CDFI Fund US Treasury.