POST-AWARD COMPLIANCE CHECKLIST

HUD HOME Investment Partnerships: Compliance Requirements

What you must do after you win this award — administered by US Department of Housing and Urban Development · Federal Program.

10
Total requirements
5
Clawback-risk items
10
Deadline-bound

⚠ Common Disallowed-Cost Pitfalls

  • Financial & Cost Eligibility: Failure to meet 25% match requirement can result in disallowed costs for the unmatched portion and reduction or clawback of HOME funds.
  • Recordkeeping: Inadequate recordkeeping prevents verification of compliance; may result in disallowed costs for unsubstantiated expenditures and audit findings.
  • Ongoing Eligibility: Assistance to households exceeding AMI limits results in disallowed costs for that beneficiary's entire benefit amount and may trigger recapture.
  • Financial & Cost Eligibility: Sale or rent of HOME-assisted property outside affordability period without required repayment results in complete recapture of HOME funds plus interest.
  • Other Obligations: Missing or inadequate written agreements result in disallowed costs for all associated expenditures and may trigger repayment obligations.
  • Reporting: Failure to timely report may result in suspension of future disbursements, audit findings, and reduced funding allocations.
  • Financial & Cost Eligibility: Properties failing physical standards or showing insufficient financial viability may result in affordability covenant enforcement, recapture of funds, and project disallowance.
  • Financial & Cost Eligibility: Advance or excessive drawdowns may be disallowed and required to be returned to HUD; interest may accrue.
  • Reporting: Missing or inaccurate rent reports prevent verification of affordability compliance; properties with excess rents may trigger recapture and cost disallowance.
  • Procurement & Vendor Rules: Failure to document affirmative marketing steps may result in findings, corrective action requirements, and potential cost disallowance if pattern is established.

Reporting

  • HighAnnual

    Report all HOME activity data to HUD via the Integrated Disbursement and Information System (IDIS), including project details, beneficiary information, and accomplishments within 90 days of each program year end.

    Deadline: End-of-year reporting due within 90 days after close of each program year

    Source: 19-18: 'Within 90 days after the end of their program year...HOME funds...must ensure that all activity information in IDIS is up-to-date'; 24 CFR §92.502

  • HighAnnual

    Annually provide rental property owners' reports on rents charged and occupancy of HOME-assisted units to document compliance with HOME affordability and rent restrictions (§92.252).

    Deadline: Annual rent and occupancy reports from owners due to PJ; deadline specified in owner agreement

    Source: 17-4,17-15: 'The written agreement must require the owner of rental housing to annually provide the participating jurisdiction with information on rents...and occupancy of HOME-assisted units to demonstrate compliance with §92.252'

Financial & Cost Eligibility

  • Clawback riskOngoing

    Provide 25% nonfederal match for every dollar of HOME funds used. The match may be satisfied through nonfederal cash, materials, labor, land, or other resources approved by HUD.

    Deadline: Match must be provided concurrent with use of HOME funds; verified at end of program year

    Source: 24 CFR Part 92; 5 HUD.gov (match requirement statement)

  • Clawback riskOngoing

    Enforce affordability periods for HOME-assisted housing (15 years for rental, 10 years for homeownership). Maintain deed restrictions, covenants, or agreements requiring repayment if affordability period is broken.

    Deadline: Affordability covenants effective for entire affordability period; enforced through deed restrictions or written agreements

    Source: 17-19,17-20: 'The agreement must require housing assisted with HOME funds to meet the affordability requirements...and must require repayment of the funds if the housing does not meet the affordability requirements for the specified period'

  • HighAnnual

    For rental housing with 10 or more units, conduct annual financial viability examination and physical inspections (NSPIRE-compliant by Oct 1, 2025) to verify ongoing compliance with affordability and property standards.

    Deadline: Inspections must be conducted annually throughout affordability period; NSPIRE compliance required by October 1, 2025

    Source: 4-9: 'PJs must also examine the financial viability of HOME-assisted rental projects with ten or more units at least annually during the affordability period'

  • HighEvent Driven

    Request disbursement of HOME funds only when needed for immediate payment of eligible costs; do not request funds in advance. Disburse program income before requesting additional HOME funds.

    Deadline: Fund drawdowns must align with eligible cost payments; program income expended first

    Source: 17-9,17-10,17-11: 'The agreement must specify that the State recipient may not request disbursement of HOME funds...until the funds are needed for payment of eligible costs...Program income must be disbursed before the State recipient requests funds'

Procurement & Vendor Rules

  • MediumOngoing

    Take affirmative steps to ensure small and minority-owned businesses, women-owned businesses, and labor surplus area firms are used in procurement when possible, in accordance with 2 CFR 200.321.

    Deadline: Affirmative steps must be documented in procurement files for each procurement action during the award period

    Source: 16-4,16-18: 'Under 2 CFR 200.321, recipients, their sub-recipients and contractors must take all necessary affirmative steps to assure small and minority businesses, women's business enterprises, and labor surplus area firms are used when possible'

Recordkeeping

  • Clawback riskOngoing

    Maintain records sufficient to document compliance with HOME program requirements, including activity descriptions, budgets, eligibility determinations, policies, procedures, and subrecipient agreements for all HOME-assisted projects.

    Deadline: Records must be maintained throughout the project period and affordability period (10-15 years depending on activity type)

    Source: 24 CFR §92.504(a)(2)(vi); 24 CFR §92.508

Ongoing Eligibility

  • Clawback riskOngoing

    Ensure beneficiary households do not exceed 80% of Area Median Income (AMI) limits. Income verification documentation must be maintained for all assisted households.

    Deadline: Income limits verified at project inception and annually for ongoing assistance (TBRA, rental property re-screening)

    Source: 8-16,8-17,8-18: Income limits requirement; 24 CFR §92.203 (income targeting)

Other Obligations

  • Clawback riskOne Time

    Maintain written agreements with all subrecipients, contractors, owners, and housing recipients that specify their obligations for compliance with HOME program requirements, including recordkeeping, reporting, affordability maintenance, and VAWA/nondiscrimination compliance.

    Deadline: Written agreement must be executed before any HOME funds are disbursed to the entity

    Source: 4-5,4-6: 'Before disbursing any HOME funds to an entity...a PJ must enter into a written agreement...all must ensure compliance with HOME program requirements'

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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 US Department of Housing and Urban Development.