1 CDBG Recordkeeping Requirements For Local Officials

2 Recordkeeping Requirements UGLG Records 24 CFR –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

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

4 Recordkeeping Local government must keep all records because the state, HUD, general public, or the press, may want or need to access them for a variety of valid reasons Keep files in a secure location in the UGLG, not in the grant administrator’s car

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

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

7 Recordkeeping Acquisition and Relocation Files Acquisition and Disposition Register Documentation of AFFH activities Income surveys Monitoring Letters Beneficiary information

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 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 (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

Record Retention Hold records until notified by State Or, For Other Specified Periods –24 CFR , Other Applicable Laws –24 CFR , Displacement, Relocation, etc

11 Access to Records UGLG must provide access to records (24 CFR (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