2019-11-15 HCHA Approved Minutes

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Special HCHA meeting November 15, 2019 expenditure to see how you're doing and make sure that your in...your performance is...complies with all the rules, HUD rules and federal rules. Your, the grantees responsibility is to design and implement the recovery program according to how you have determined the needs to be and the best solution to be. You'll have to establish internal controls to make sure that your actually, the work your doing is in compliance with your requirements and if you have...if you pass money through to somebody else, you need to play the role that H U D does, watching over you, you need to watch over those sub...sub-recipients. And, that internal control process is a big part of getting ready to spend CDB(G)-DR funds. It can take a long time to get those procedures...policy, procedures, systems, in place because this is generally a whole lot more money, it's a whole lot more CDBG money then you normally get annually, a lot more. The speed that your spending money is going to be greatly increased. Generally our grants...the target is to have it spent in six years, not the activity is going to be complete but the disaster funds need to be spent in six years, that's the target. But when you apply to some grantees with large...large grants to spend all that in six years would be 12 million dollars a day so that's the kind of volume you need to think about. The adjustment from an annual program to a disaster program you're going to be spending a whole lot more money a whole lot faster then you have previously and the financial controls you have to be in place need to be much stronger to make sure that there's proper oversight of that. The capacity to manage the grant but also the capacity to manage the flow of funds is critical, essentially to keep the grantee out of trouble, really. You want to make sure your spending it right. If its determined that you didn't spend it right, it needs to be repaid from non-federal source so its best to do...get your system set up and take the time to get those set up right in the first place so that keeps you out of trouble down the road. And just like we provide technical assistance to...to the grantee, the grantees provide technical assistance to their sub-grantees, sub-recipients. Cause essentially you're responsible for all the money. If your sub-recipient is spending it, if they spent it wrong, you might have to tell them to re-pay it from non- federal funds but then we, when HUD looks at it, we need to make sure that they re-paid you or you re-pay us...you pay the treasury, not HUD...out of non- federal funds if there's any funds that weren't properly...eligibly spent. So the other things that the grantees responsibility is to review any project applications, make sure that activities are eligible. Ensure that there compliant with all...there special HUD requirements for your annual CDBG program, the section three, it's an employment...low income...employment target, all the fair- housing rules need to apply to all the DR funds as well, as well as the environmental rules. Page 4 of 31