CDBG Recordkeeping Requirements For Grant Administrators

1. 1  CDBG Recordkeeping Requirements For Grant Administrators In this module we will be discussing the recordkeeping requirements of the CDBG program. The 2 most important things to take away from this section are: The UGLG owns the records = not the Grant Administrator Funding for the current and all future projects could be in jeopardy if recordkeeping requirements are not met. In this module we will be discussing the recordkeeping requirements of the CDBG program. The 2 most important things to take away from this section are: The UGLG owns the records = not the Grant Administrator Funding for the current and all future projects could be in jeopardy if recordkeeping requirements are not met.

2. 2 Recordkeeping Requirements UGLG Records 24 CFR 570.490 States will Establish Recordkeeping Requirements for UGLGs State records include information from UGLG reports and records Both State and UGLG Records Must Include Racial, Ethnic, and Gender Data on Applicants, Participants, Beneficiaries The State establishes recordkeeping requirements for the UGLG�s based on federal and state requirements. Confidentiality must be maintained for the applicants and beneficiaries as much as possible. Applicants and Beneficiaries can be numbered and their names/social security numbers protected if UGLG is required to release info to public. Data provided to state on applicants and beneficiaries is entered into a confidential database. Access to Records will be discussed later. The State establishes recordkeeping requirements for the UGLG�s based on federal and state requirements. Confidentiality must be maintained for the applicants and beneficiaries as much as possible. Applicants and Beneficiaries can be numbered and their names/social security numbers protected if UGLG is required to release info to public. Data provided to state on applicants and beneficiaries is entered into a confidential database. Access to Records will be discussed later.

3. 3 Recordkeeping Absolutely critical to establish good record keeping system Records are the only method of verifying compliance with the program requirements All records must be retained for the period of time designated by the state from the application through the certification of closeout FROM THE APPLICATION THROUGH THE CLOSE OUT OF THE PROJECT, INCLUDING CERTIFICATION OF CLOSEOUT FROM THE STATE - ALL RECORDS MUST BE RETAINED FOR THE DESIGNATED PERIOD OF TIME Keep files under control of UGLG during project, and secure, this includes both the electronic and paper version of files. It is a good idea to think about back-ups of data and records in case of natural or other disasters. UGLG should always have access to the project records and the UGLG is responsible for maintaining the records. Why? Because all Project records during the project process must be accessible to State for monitoring, and the state could come for a monitoring visit and your contract grant administrator might not be available. Even though the project is completed and not in use by the town, all paperwork must be completed and filed. In many ways the paper can be equally as important as the construction!FROM THE APPLICATION THROUGH THE CLOSE OUT OF THE PROJECT, INCLUDING CERTIFICATION OF CLOSEOUT FROM THE STATE - ALL RECORDS MUST BE RETAINED FOR THE DESIGNATED PERIOD OF TIME Keep files under control of UGLG during project, and secure, this includes both the electronic and paper version of files. It is a good idea to think about back-ups of data and records in case of natural or other disasters. UGLG should always have access to the project records and the UGLG is responsible for maintaining the records. Why? Because all Project records during the project process must be accessible to State for monitoring, and the state could come for a monitoring visit and your contract grant administrator might not be available. Even though the project is completed and not in use by the town, all paperwork must be completed and filed. In many ways the paper can be equally as important as the construction!

4. 4 Recordkeeping You must keep them because the state, HUD, general public, or the press, may want or need to access them for a variety of valid reasons Files must always be kept by the UGLG, in a secure location! Records must be retained after close out, for the time period designated by the State. UGLG must keep the originals after close out, not contract grant administrator. Records must be retained after close out, for the time period designated by the State. UGLG must keep the originals after close out, not contract grant administrator.

5. 5 Recordkeeping Application Award letter Grant agreement Citizen Participation Plan All financial records Program Income Environmental Review Record (Especially Release of Funds Letter) Procurement Documents Labor Standards Documents We have discussed all the CDBG program compliance areas throughout the day, this is a list representing the type of files that must be maintained. The HUD Guide to Eligible Activities and National Objectives also has guidance that you have/will be provided. Some important records to note: Citizen participation � must have original copy of the affidavit of publication and the tear sheets. Send copy of the hearing minutes. Must be able to verify that there were 2 notices published. ERR - especially release of funds Financial Records Draw downs and supporting documents Budget information and revisions Must document use of program income generated and/or expended after grant closeout. Labor � must get the wage decision from the state but the town can document the debarred contractors and consultant list We have discussed all the CDBG program compliance areas throughout the day, this is a list representing the type of files that must be maintained. The HUD Guide to Eligible Activities and National Objectives also has guidance that you have/will be provided. Some important records to note: Citizen participation � must have original copy of the affidavit of publication and the tear sheets. Send copy of the hearing minutes. Must be able to verify that there were 2 notices published. ERR - especially release of funds Financial Records Draw downs and supporting documents Budget information and revisions Must document use of program income generated and/or expended after grant closeout. Labor � must get the wage decision from the state but the town can document the debarred contractors and consultant list

6. 6 Recordkeeping Section 3 Reports WBE/MBE Reports Proof that projects are eligible and meet a national objective Sub-recipient agreements Affordability agreements (housing) Economic development agreements to provide jobs (specifics) Job retention and creation tracking form Records of contractors efforts made to hire Section 3 individuals and MBE/WBE firms reported to State Sub-recipient Agreements are very important because they will be required to report long after construction is complete Same for Job Creation AgreementsRecords of contractors efforts made to hire Section 3 individuals and MBE/WBE firms reported to State Sub-recipient Agreements are very important because they will be required to report long after construction is complete Same for Job Creation Agreements

7. 7 Recordkeeping Acquisition and Relocation Files Acquisition and Disposition Register Documentation of AFFH activities Income surveys Monitoring Letters Beneficiary information Monitoring Letters � proof that your project has been monitored and any findings have been resolvedMonitoring Letters � proof that your project has been monitored and any findings have been resolved

8. 8 Recordkeeping Close out documents (as specified by state) Monitoring findings resolved and final budget completed based on actual expenditures Certificate of completion (from State) Final audit report Others Records related to any open audits, reviews, or investigations should be retained

9. 9 Record Retention Length of time for record retention at local level is related to when HUD closes out the Federal grant with the State 24 CFR 570.490(d): Records of the UGLG shall be retained for three years after the State grant is closed by HUD Change of use of a project by the UGLG requires longer period of record retention HUD requires the State to retain records for three years after HUD �closes out� each annual grant to the State, this requirement is extended by regulation to the UGLGs. However, HUD may not close out its grant with the State for many years after an individual UGLG grant/project is finished. Therefore, the State will notify UGLGs with respect to how long records must be kept and when they can be disposed of in a secure manner. Change of use in a project requires that many records, such as beneficiary data, etc. begin again, necessitating a longer period of retention. In addition to the CDBG program regulations, other program regulations also govern record retention, such as the anti-displacement regulations or in relation to other applicable laws. HUD requires the State to retain records for three years after HUD �closes out� each annual grant to the State, this requirement is extended by regulation to the UGLGs. However, HUD may not close out its grant with the State for many years after an individual UGLG grant/project is finished. Therefore, the State will notify UGLGs with respect to how long records must be kept and when they can be disposed of in a secure manner. Change of use in a project requires that many records, such as beneficiary data, etc. begin again, necessitating a longer period of retention. In addition to the CDBG program regulations, other program regulations also govern record retention, such as the anti-displacement regulations or in relation to other applicable laws.

10. Record Retention Hold records until notified by State that they can be disposed of Or, For Other Specified Periods 24 CFR 570.487, Other Applicable Laws 24 CFR 570.488, Displacement, Relocation, etc

11. 11 Access to Records UGLG must provide access to records (24 CFR 570.490(c)) HUD, IG, and GAO have access rights to all records State and UGLG will provide citizens with reasonable information about past use of CDBG funds 24 CFR 570.490 says that the UGLG must provide access to the records of projects assisted with CDBG. The financial records of businesses and payroll verifications can also be kept confidential to a certain extent by keeping the identity of the workers separated (number them) and by releasing only the details of the transactions between the business and the UGLG that are pertinent (moved from slide #2) This does not mean that you must share ALL records. For example, payroll records submitted by a contractor are NOT required to be released. When you are in doubt � contact State and/or UGLG attorney.24 CFR 570.490 says that the UGLG must provide access to the records of projects assisted with CDBG. The financial records of businesses and payroll verifications can also be kept confidential to a certain extent by keeping the identity of the workers separated (number them) and by releasing only the details of the transactions between the business and the UGLG that are pertinent (moved from slide #2) This does not mean that you must share ALL records. For example, payroll records submitted by a contractor are NOT required to be released. When you are in doubt � contact State and/or UGLG attorney.