HUD CDBG Disaster Recovery: Compliance Requirements

Grantee must report all performance and financial data in the Disaster Recovery Grant Reporting (DRGR) system throughout the grant lifecycle and maintain records of performance in DRGR.

Deadline: Data entry and updates required continuously; HUD conducts performance reviews within two years of Allocation Announcement Notice effective date

Source: Universal Notice Section III.G; Federal Register 90 FR 1756

Grantee must submit housing, infrastructure, and economic revitalization policies and procedures: housing policies within one year and infrastructure/economic revitalization policies within 18 months of Allocation Announcement Notice applicability date, subject to HUD monitoring within two years.

Deadline: Housing policies due within 12 months; infrastructure/economic policies due within 18 months of AAN effective date

Source: Universal Notice Section III.B; HUD Checklist on Programmatic Policies Review

Grantee must ensure grant administration expenditures do not exceed 5 percent of total grant award plus 5 percent of program income. All administrative costs must qualify as eligible administration expenses.

Deadline: Must be monitored throughout grant life cycle; enforcement at closeout

Source: HUD CDBG-DR FAQ; 24 CFR 570 (financial management standards)

Grantee must use at least 80 percent of award to benefit HUD-identified Most Impacted and Distressed (MID) areas. Local governments with entire jurisdiction in MID areas must use 100 percent of award for MID-area benefit.

Deadline: Must be identified in Action Plan submitted within 90 days of Allocation Announcement Notice applicability date

Source: Universal Notice Section I.A; 24 CFR 570.208 (national objectives)

Grantee must prevent duplication of benefits by ensuring no person, household, or business receives disaster assistance from multiple sources for the same recovery purpose in excess of total unmet need.

Deadline: Must be monitored for each activity and beneficiary throughout grant life cycle using best available data from FEMA, SBA, and insurers

Source: Universal Notice Appendix C; Robert T. Stafford Act Section 312; 2 CFR 200.404

Grantee must apply Necessary and Reasonable cost principles under 2 CFR 200 subpart E, ensuring all costs are reasonable in nature and amount, do not exceed what a prudent person would incur, and comply with Federal requirements.

Deadline: Standard applies to all expenditures throughout grant term; reviewed during financial monitoring and at closeout

Source: 2 CFR 200.404; 2 CFR 200.403

Grantee must maintain proficient procurement processes and policies in place prior to award that comply with 2 CFR Part 200 and applicable state/local law where state/local standards exceed Federal minimums.

Deadline: Must be submitted and certified in Financial Management and Grant Compliance Certification within 60 days of AAN effective date or with Action Plan submission, whichever is earlier

Source: Universal Notice Section II.A.1.b; 2 CFR 200 Part 319-326

Grantee must comply with all environmental requirements, Davis Bacon Act prevailing wage requirements, Civil Rights requirements, Lead Safe Housing Rule, and Uniform Relocation Assistance and Real Property Acquisition Policies Act (URA) for all CDBG-DR funded activities.

Deadline: Environmental review must occur before activity authorization; wage certifications required on all construction; URA compliance before displacement

Source: Universal Notice Section III.A; 24 CFR 570 subpart E; 2 CFR 200 Appendix II

Grantee must maintain all records pertinent to the grant for three years after grant closeout, including supporting documentation. Records must be readily accessible and organized by compliance area.

Deadline: Retention period begins at grant closeout and extends three years; must be available for HUD audit at any time

Source: 24 CFR 570.490(d); 2 CFR 200.334

Grantee must maintain a comprehensive accessible website documenting all disaster recovery activities assisted with CDBG-DR funds, including decisions made and funds expended, with citizen access to past use records.

Deadline: Website must be established and maintained continuously; citizen access required at all times; updated as activities progress

Source: Universal Notice Section II.A.1.c; 24 CFR 570.508