Community Development Block Grant: Compliance Requirements

Submit updated activity data to HUD's Integrated Disbursement and Information System (IDIS) within 90 days after the end of each program year, including financial summaries, activity accomplishments, and beneficiary demographics.

Deadline: Within 90 days after program year end

Source: 24 CFR 91.320; HUD IDIS Reporting Requirements

Maintain that at least 70% of CDBG funds are used for activities benefiting low- and moderate-income persons over a 1-, 2-, or 3-year period as selected by the grantee.

Deadline: Measured cumulatively over the elected certification period (1, 2, or 3 years); verified in annual performance reports

Source: 24 CFR 570.201(d)(1); 42 U.S.C. § 5301 et seq.

Public service expenditures cannot exceed 15% of the annual grant (plus 15% of prior-year program income for entitlement grantees), except where statutory exceptions apply.

Deadline: Calculated annually; verified in year-end IDIS reporting

Source: 24 CFR 570.201(d)(1)

Comply with cost principles in 2 CFR Part 200, Subpart E; ensure all costs are reasonable, necessary, allocable, and documented; avoid charging indirect costs without approved cost allocation plan or indirect rate agreement.

Deadline: Applicable to all drawdowns and expenditure reimbursement requests

Source: 2 CFR 200.403-200.411; 24 CFR 570.489(d)

Conduct procurement in compliance with 2 CFR Part 200, Subpart D (Uniform Guidance); require full and open competition, execute written procurement policies, maintain cost or price analysis documentation, and verify contractor non-debarment status before award.

Deadline: Prior to executing each contract; debarment checks must be performed before award

Source: 24 CFR 570.489(g)(h); 2 CFR 200.317-200.326

For housing rehabilitation projects involving more than 7 units, comply with Davis-Bacon Act wage and hour requirements, including payment of prevailing wages and submission of certified payroll records.

Deadline: Weekly certified payroll submissions during construction; enforcement continues for 3 years post-completion

Source: 40 U.S.C. § 3141 et seq.; 24 CFR 570.603

Complete environmental review in compliance with HUD regulations (24 CFR Part 58) before obligating or expending CDBG funds on any activity; document the environmental assessment level determination.

Deadline: Environmental review must be completed before activity obligation; FONSI or EIS must precede fund commitment

Source: 24 CFR 570 (implied through activity eligibility requirements); 42 U.S.C. § 4321 et seq.

Maintain complete files and supporting documentation for all CDBG activities, including activity eligibility determinations, cost substantiation, national objective documentation, and beneficiary income verification.

Deadline: Records must be retained for the greater of 3 years from grant closeout or period required by other applicable laws

Source: 24 CFR 570.490(a); 24 CFR 570.506

Document all subrecipient monitoring activities, including risk assessments, site visits, file reviews, and follow-up actions; maintain subrecipient agreements with required CDBG compliance terms.

Deadline: Monitoring frequency based on subrecipient risk profile; documentation must be contemporaneous with activity

Source: 24 CFR 570.490-570.493; 2 CFR 200.331-200.333

Verify and document income eligibility for beneficiaries at project intake; for activities serving low/moderate-income persons, maintain evidence that at least 51% of direct beneficiaries have incomes at or below 80% Area Median Income (AMI).

Deadline: Income certification must be completed at time of service delivery or project enrollment

Source: 24 CFR 570.201(d); 24 CFR 570.208