POST-AWARD COMPLIANCE CHECKLIST

Federal Home Loan Bank Affordable Housing Program: Compliance Requirements

What you must do after you win this award — administered by Federal Home Loan Bank (Cincinnati / Indianapolis) · Federal Program.

9
Total requirements
3
Clawback-risk items
9
Deadline-bound

⚠ Common Disallowed-Cost Pitfalls

  • Financial & Cost Eligibility: Failure to notify or repay triggers full recapture of AHP subsidy plus interest; property may be subject to foreclosure by the bank
  • Financial & Cost Eligibility: Failure to disburse within one year results in automatic loss of award; funds returned to the bank
  • Ongoing Eligibility: Violation of affordability requirements during retention period triggers mandatory repayment of grant; property may be recaptured by bank
  • Reporting: Late or missing reports may delay or suspend disbursements; repeated non-compliance may trigger full grant recapture and breach of subsidy agreement
  • Recordkeeping: Failure to provide requested records is grounds for non-compliance determination and potential subsidy recapture
  • Reporting: Failure to submit Initial Monitoring documentation may result in suspension of final disbursement and determination of non-compliance
  • Reporting: Failure to submit LTM documentation or discovery of non-compliance during monitoring may trigger grant recapture and breach proceedings
  • Environmental: Material violations of fair housing, accessibility, or environmental laws trigger non-compliance determination and potential full subsidy recapture
  • Other Obligations: Failure to report LIHTC non-compliance is itself a breach of the AHP agreement and may trigger recapture of AHP subsidy

Reporting

  • HighSemi Annual

    Submit Periodic Progress Reports (PPR) to the sponsoring FHLBank on a bi-annual schedule from the award date until project completion and final disbursement.

    Deadline: Due bi-annually until project completion; typically within 30-45 days of reporting period end based on AHP Implementation Plans

    Source: FHLBCIN AHP Compliance Information; standard across all FHLB districts per 12 CFR 1291

  • HighOne Time

    Submit Initial Monitoring documentation to the bank at time of disbursement for owner-occupied projects, or nine months after final disbursement for rental projects, certifying project completion and continued compliance with program requirements.

    Deadline: Initial Monitoring due at disbursement for ownership projects; within 9 months after final disbursement for rental projects

    Source: FHLBCIN AHP Compliance Information §5.3

  • HighAnnual

    For rental projects, submit Long-Term Monitoring documentation annually throughout the 15-year retention period, confirming continued affordability compliance, income eligibility of residents, and adherence to all AHP commitments.

    Deadline: Annual Long-Term Monitoring submissions due each year on or before anniversary date of project completion; typically by January 31 or as specified by bank

    Source: FHLBCIN AHP Compliance Information §5.3; 12 CFR 1291.67

Financial & Cost Eligibility

  • Clawback riskEvent Driven

    For owner-occupied units receiving AHP subsidy, ensure the property is subject to a deed restriction requiring the bank be notified of any sale, transfer, or refinancing during the five-year retention period. Upon sale or refinancing, repay the AHP subsidy amount to the bank unless a statutory exception applies.

    Deadline: Notice required prior to or at time of sale, transfer, assignment, or refinancing; repayment due within 30 days of the triggering event

    Source: 12 CFR 1291.1(a)(2)(i)-(ii)

  • Clawback riskOne Time

    Disburse the awarded AHP subsidy within one year of the award announcement. If funds are not disbursed within this timeframe, the award may be withdrawn and funds reallocated.

    Deadline: Subsidy must be fully disbursed within 12 months of award announcement date

    Source: FHLBank Chicago AHP Program guidelines §4.13; standard FHLB requirement

Environmental

  • HighOngoing

    Ensure the project complies with all applicable federal and state fair housing laws, accessibility regulations (ADA, Section 504), and environmental statutes throughout the project term.

    Deadline: Compliance required from award announcement through end of retention period; violations must be reported within 10 days of discovery

    Source: FHLBank Chicago AHP Program guidelines §4.1; 12 CFR 1291.1(a)(1)

Recordkeeping

  • HighOngoing

    Maintain and provide all documentation requested by the bank to verify project compliance with commitments made in the approved AHP application, including evidence of continued financial and operational feasibility.

    Deadline: Documentation must be provided upon request throughout the retention period; no later than 30 days of request unless extended by bank

    Source: FHLBCIN AHP Compliance Information; FHLBank Chicago AHP Program guidelines §4.9

Ongoing Eligibility

  • Clawback riskOngoing

    For rental projects, maintain affordability restrictions throughout the 15-year retention period following project completion. Units must remain affordable and occupied by eligible very-low-, low-, or moderate-income households as specified in the subsidy agreement.

    Deadline: Affordability must be maintained continuously from date of project completion through end of 15-year retention period

    Source: 12 CFR 1291; FHLBank Chicago Retention/Recapture Agreement §2-3; FHLBCIN AHP Compliance Information

Other Obligations

  • HighEvent Driven

    If the project also received Low-Income Housing Tax Credits (LIHTC), provide prompt written notice to the bank if the project experiences material and unresolved non-compliance with LIHTC income targeting or rent requirements.

    Deadline: Notice must be provided immediately upon discovery of non-compliance; no later than 10 business days

    Source: FHLBank Chicago Retention/Recapture Agreement §5.3

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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 Federal Home Loan Bank (Cincinnati / Indianapolis).