COSCDA Fall 2016 Update Jessie Handforth Kome, Acting Director, OBGA HUD Office of Block Grant Assistance Entitlement Communities Division

BUDGET/FUNDING: FY 2016 $3B for FY 2016 2009-2013 ACS data plus 7/1/14 Census population estimates to determine 2016 CDBG awards. 1212 Entitlement grantees for FY 2016 (net increase of 7 from FY 2015). $300M CDBG-DR appropriation $300 M in Section 108 authority. Program now has a loan guarantee financing fee.

BUDGET/FUNDING: FY 2017 FY 2017 budget released 2/19/16 Status: Proposed CDBG allocation is $2.8 billion. Proposed Section 108 guarantee authority is $300 million. Status: Full Senate & House Subcommittee passed HUD appropriation bills for FY17, but expect a CR.

UNIFORM ADMINISTRATIVE REQUIREMENTS Part 200 Uniform Administrative Requirements effective 12/26/14. Interim Final Rule on Changes to Accounting Requirements for the Community Development Block Grants (CDBG) published in November 2015; final rule not published. IDIS reporting changes released July 2016. Resources: Conforming rule changes made to CPD program rules published 12/07/15, effective 1/6/16 HUD Notice SD-2015-01 (02/26/15) discusses implementation & CPD Notice 16-04 (4/13/16). Monitoring exhibits currently being updated Elimination of FIFO drawdown: Grantees were required to use grant based accounting for CDBG funds beginning with their FY 2015 CDBG grants. Major issues to be dealt with were program income, and for CDBG Entitlement grantees, the 20% planning & admin cap. New second test: limits expenditures of (appropriated) grant funds (excluding PI) over the life of that origin year to 20%. New LA fund to track reimbursement of funds to local program accounts as a result of disallowed/ineligible costs that can’t go back into LoC. The 8 year limitation on use of grant funds will start to matter. If you don’t have 2015 origin year funds disbursed out of LoC by Sept 2022, you will lose them. IDIS manuals, resources all updated to incorporate grant based accounting. Uniform Administrative Requirements Part 200 requirements have been in effect for over a year now – except grantees can elect to defer implementation of procurement requirements for 2 fiscal years. HUD issued Department wide implementation guidance 2/26/15. Notice 16-04 = specific to CPD programs. The new notice supplements the previous Notice, does not supersede it. Specifically deals with the applicability of part 200 to subrecipients & other lower level entities; transitioning from part 85 “common rule” to part 200 given the lag time in issuing conforming rule changes.

AFFIRMATIVELY FURTHERING FAIR HOUSING Final Rule published 7/16/15 Assessment of Fair Housing Tool for Local Governments published in December 2015. Various due dates for AFH. State tool not yet finalized – second round of public comments 3/14/16 memo to all grantees on Incorporating 24 CFR Part 5 AFFH into the Consolidated Program Year and Citizen Participation Plan The Assessment Tool is a series of questions designed to help local governments identify racially and ethnically concentrated areas of poverty, patterns of integration and segregation, disparities in access to opportunity, and disproportionate housing needs. Due on rolling basis based on Consolidated Plan cycle. The AFH is due 270 days prior to the program year for which a new consolidated plan is due. This will start with program years beginning: For entitlements receiving over $500,000 in CDBG funds in FY2015: January 1, 2017; For all other grantees: January 1, 2018 Grantees/Consortia/PHAs doing a joint or regional AFH need to consider aligning PYSDs and ConPlan cycles where practical. 20 grantees will be first to submit new AFH. Anyone in the audience who will be one of the first to submit an AFH later this year? States do not have to submit an AFH until they are required to have a new 5-Year ConPlan on or after January 1, 2018. Until required to submit a new 5-Year ConPlan, a jurisdiction must continue to follow the existing Analysis of Impediments (AI) to fair housing choice process, certifying that the jurisdiction has conducted an analysis of impediments and is taking appropriate actions to overcome the effects of any impediments. On the next slide we have a link to some of the TA resources available…

TECHNICAL ASSISTANCE RESOURCES “Explore CDBG” & call for good news stories to populate database https://www.hudexchange.info/community-development/cdbg-ta-products/ AFFH TA- sign up for mailing list, mapping updates, other materials & TA products https://www.hudexchnage.info.programs/affh/ eCon Planning Suite – General Information, resources, desk guides and tutorials & resources: https://www.hudexchange.info/programs/consolidated-plan/ Brand New Explore CDBG products: CDBG 101: Overview of Eligibility & National Objectives The formula & appropriations process Program Income- states and ecs Urban County qualification process CDBG Life Cycle: 2 parts: Planning process; implementation process Using CDBG for Disaster Response/Recovery These each offer separate paths within each video/multimedia presentation for entitlement or for state program Also: project profiles page, for you to share your excellent local success story projects with the world. + Multimedia Scrapbook which tells the story of people whose lives have been affected. These are on top of the 4 introductory videos HUD released in the fall of 2014. We encourage you to share these with public officials, citizen groups, advisory groups, neighborhood associations, etc. Suggest you put a “useful link” to them – th idea is to help educate, and to answer those many basic questions we all get about how the program works or how someone can access funding.

TECHNICAL ASSISTANCE RESOURCES 2016 Section 108 webinar- includes fee based component https://www.hudexchange.info/training-events/courses/targeted-community- reinvestment-hud-s-section-108-loan-guarantee-program-as-a-financing-tool-2016-update- webinar/ Grant Based Accounting Webinar & Materials www.hudexchange.info/manage-a-program/grant-based-accounting Ask for technical assistance if you need help! https://www.hudexchange.info/get-assistance/ ` 2016 Section 108 webinar (fee based program overview) https://www.hudexchange.info/training-events/courses/targeted-community- reinvestment-hud-s-section-108-loan-guarantee-program-as-a-financing-tool-2016- update-webinar/ https://www.hudexchange.info/programs/affh/ Sign up for AFFH Mailing List Mapping Updates Latest Publications, Proposed/Final Tools, Resource Materials Overview of the Assessment of Fair Housing webinars/webcasts TA can be on call, specific, comprehensive- just ask! Loop in field offices Call Diane if TA request was submitted & you haven’t heard anything.

POLICY GUIDANCE New State PER CPD Notice published 05/06/16 2016 § 8 Income Limits were published March 28, 2016. Grantees must use HOME income limits, published May 9: Federal Register Notice on NSP Closeout/Program Income - issued 06/24/16 CPD Notices in development: Mandatory underwriting for economic development to for-profit businesses Updated NRSA Notice Submission of FY 17 Action Plans 189

REGULATION DEVELOPMENTS Final Rules in Development: Broadband Initiative - Proposed Rules published in Federal Register May 18: Substantial Rehabilitation & New Construction of Housing Incorporating broadband* & resilience needs into Consolidated Plans Final Housing Counseling rule Section 3 – Proposed Rule published 03/27/2015. First updates to Section 3 requirements since 1994. *FAQs on using CDBG funds for broadband may be accessed at https://www.hudexchange.info/resource/4891/cdbg-broadband-infrastructure-faqs/ Broadband: President’s Broadband Opportunities Initiative – follows on NYIA broadband opportunities council working group, HUD ConnectHome initiative for assisted housing. 2 proposed rules: New Housing construction & substantial rehabilitation of housing Consolidated Plan – also includes resilience Housing Counseling Section 3 Final rules are in development for likely publication later this fall. (No, we cannot discuss contents of final rules or comments on proposed rules while they’re in development) Housing Counseling Rule: Will cover all HOME-funded housing counseling and some CDBG-funded housing counseling (when tailored to each unique client’s needs). More general housing information/referrals not affected 189

TRANSITIONING FROM THIS ADMINISTRATION TO THE NEXT CDBG emphasis on cleaning up old business. HUD emphasis on seeing various rules/initiatives through to completion Office of Inspector General is conducting six major audits of CDBG, Disaster Recovery, § 108, NSP, HOME homeownership. New law establishes more formal transition process from one administration to the next Senior management staff departures Who in the audience still has an open NSP grant? Seeing initiatives through – list of rules on previous slide, Section 3, etc. : Continuing closeout of NSP grants, remaining CDBG-R grants, 2011 OIG-IDIS audit findings; §108 reporting in IDIS. . Audit already issued on acquisition and disposition of property with CDBG funds – concerns about grantees’ lack of documentation on eventual use/reuse Stan as Acting DASGP; General Counsel is retiring; Mike Roanhouse (familiar face) retiring from ESG program. Also recognize Rufus W as new CPD Director in Atlanta.

Questions and Answers Jessie.Handforth.Kome@hud.gov Refer to Directors that can help- Pamela/James, Tennille on DR, Paul (expect questions about size of state CDBG division)