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Neal Rackleff, Assistant Secretary Community Planning and Development

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2 Neal Rackleff, Assistant Secretary Community Planning and Development
COSCDA Fall 2017 Update Neal Rackleff, Assistant Secretary Community Planning and Development

3 Staff Changes Pamela Patenaude, Deputy Secretary – confirmed September 14, Neal Rackleff, Assistant Secretary for Community Planning and Development – started August 16, 2017. Ralph Gaines is on board as the Principal Deputy Assistant Secretary for Community Planning and Development. Stanley Gimont, Deputy Assistant Secretary for Grant Programs – September 11, 2017.

4 BUDGET/FUNDING: FY 2017 $3B for FY 2017: State CDBG - $897,900 M.
1209 Entitlement grantees for FY 2017 (net decrease of 3 from FY 2016). Section $300 M in guarantee authority: Program now has a loan guarantee financing fee. CDBG-DR - $163 M supplemental funding. HUD used the ACS data plus 07/01/15 Census population estimates to determine 2017 CDBG awards. Disasters in 2017: $7.4 B President Trump Signed the Consolidated Appropriations 2017 bill into law on May 5, 2017: The 2017 appropriation contains $3 billion for CDBG with $897,900 million for the State CDBG program. As a note, there are 1,209 Entitlements for 2017. The Section 108 loan guarantee has $300 million in authority and the one-time financing fee is at 2.59% of the principal amount (Published in the Federal Register on 10/04/16). And the $163 million supplemental funding was for Louisiana, West Virginia, Texas, Florida, and North and South Carolinas. As a note, HUD used the American Community Survey Data plus the July 1, 2015 Census population estimates to determine the 2017 awards. On September 8, 2017, Congress appropriated $7.4 billion to HUD for disasters in 2017.

5 Focus Service orientation
Focus on families, individuals and communities we serve HUD should be a resource to solve problems and move our work forward Transparency—democratization of data Intelligent decision making Efficient use of funding within our stewardship Getting the job done!

6 Office of Assistant Secretary
What has been your experience with Small Infrastructure Programs in your States? My Texas experience

7 Jobs & Economic Impact Per Project (Texas Case Study)
Typical Texas Small Infrastructure Texas CDBG Award $275,000 Local Match Funds $41,250 Total Investment $316,250 Jobs & Economic Impact Per Project (Texas Case Study) $316,250 Direct Impact Indirect Impact 3.5 Jobs 5.5 Jobs

8 City of Bay City, Texas 2015 TxCDBG $350,000 grant + $52,500 local funds
In less than two years the City of Bay City designed, environmentally cleared, and constructed a project to replace deteriorated sewer lines that were causing frequent disruptions in sewer service. The City installed approximately 5,300 linear feet of 8" sewer line, manholes, service reconnections, and all associated appurtenances. 356 residents were served by this project, including 190 who have low and moderate incomes. Bay City’s population is approximately 18,000 and the city’s largest employer is a petrochemical plant.

9 Kerr County, Texas 2014 TxCDBG $500,000 grant + $25,000 local funds
Sewer Lift Station Improvements Kerr County, Texas 2014 TxCDBG $500,000 grant + $25,000 local funds BEFORE Residents in the Kerrville South colonia did not have public sewer service and relied upon failing septic systems, resulting in a threat to public health. The County installed force main, manholes, expanded lift station capacity and installed a generator at the Quail Valley lift station to supply first-time service and mitigation to housing in the Kerrville South colonia. The project benefited 113 residents, including 104 who have low-to-moderate incomes. The population of Kerr County is approximately 50,000. Jobs in the area are predominantly in manufacturing and agriculture (livestock). AFTER

10 City of Domino, Texas 2014 Economic Development $625,000 grant + $625,000 equity and working capital
BEFORE This project provided sewer improvements to the City in support of Love’s Travel Stops & Country Stores. The City installed 6,600 linear feet of sewer line, manholes, and constructed a 25,000 gallon per day wastewater treatment plant. Love’s created 25 permanent new jobs of which 13 are held by low and moderate income persons. AFTER

11 NSP Closeout NSP team at headquarters is working collaboratively with field offices and TA providers to close out NSP grants - 66 grants closed Technical assistance includes assessments, DRGR help, and project-specific TA States closed out = 4 states/6 grants NSP1 – Arizona; NSP2 – Ohio; NSP3 – Arizona, Hawaii, Michigan, & Ohio Program income transfers to CDBG via one of two methods: Local government returns funds to State and State then asks field office approval to transfer from NSP to CDBG Local government has an open CDBG grant and State gives permission to transfer to CDBG (with prior field office approval) State of Hawaii has transferred $225,421 of NSP program income to Kauai County Headquarters NSP Team expanded on Frequently Asked Questions to clarify for states the process to transfer NSP program income to an open CDBG grant or back to a state CDBG program To date the state of Hawaii has been able to transfer $225,421 of NSP3 program income to the county of Kauai’s CDBG program For all 3 rounds of NSP funding 6 state grants are closed: NSP1 – Arizona NSP2 – Ohio NSP3 – Arizona, Hawaii, Michigan, and Ohio

12 State AFH Tool The State Assessment of Fair Housing – still in development. HUD held multiple engagements with COSCDA and its members. Further development of the data made available: Data Mapping Tool updated with the state boundaries. States can start to examine what is being developed by HUD’s Office of Policy Development and Research. Refining of the data sets for the balance of state. The State Assessment of Fair Housing Tool is still in development, as previously held engagements with COSCDA and HUD’s internal discussions, have led to the need for data development. The Data Mapping Tool has been updated recently for the state boundaries. States can use the tool to see what data sets have been made available for the balance of state. HUD’s Office of Policy Development and Research is continually working to refine the data sets as they are made available in order to provide a better understanding of the level of assessment the data will provide.

13 TECHNICAL ASSISTANCE RESOURCES
“Explore CDBG” & call for good news stories to populate database: products/ “Using CDBG for Public Facilities and Improvements” and “How to use CDBG for Public Service Activities” was recently posted, and a module on Timeliness is being developed. CDBG Disaster Recovery Program webpage: Ask for technical assistance if you need help! We have a continual need for good projects for our database to showcase CDBG. If you have a projects that you would like to showcase, please go to the “Explore CDBG” page on the HUD EXCHANGE and tell us about it. This is a good resource for other grantees to see what you have accomplished and provides them with a network to provide amongst you all on activities that have worked well. Brand New Explore CDBG products that have been posted recently: “Using CDBG for Public Facilitates and Improvements.” “How to use CDBG for Public Service Activities.” We are developing a product on Timeliness that should be posted soon. Our CDBG Disaster Recovery Program page contains a lot of information and we encourage you to take a look. Recently we uploaded a new DR Fact sheet. Last, we are finding some grantees needing specialized assistance and in some cases we have grantees that need help, but may not know exactly what is needed. If you need assistance, please let us know. One of the aspects of our technical assistance is the ability to assess the needs of a grantee. From this we can help identify what targeted TA we are able to provide to help you, even if you don’t know what you need.

14 UPDATED CPD MONITORING HANDBOOK
Revisions to CPD Monitoring Handbook were issued on February 27, 2017. For the CDBG Program, revisions were made to: Chapter 3 – CDBG Entitlement Exhibits. Chapter 4 – State Monitoring Exhibits (All New Exhibits). Chapter 5 - Section 108 Loan Guarantees, Economic Development Initiative (EDI), and Brownfields Economic Development Initiative (BEDI). Chapter 6 – Disaster Recovery CDBG Supplemental Grants. Chapter 19 – Citizen Participation. Chapter 20 – Consolidated Plan (Removed). Chapter 34 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (New Chapter). Earlier this year, CPD undertook a complete overhaul of the CPD Grantee Monitoring Handbook, primarily to include 2 CFR Part 200, though it was an opportunity to the program offices to make other changes. Listed on this slide are the changes that have the most impact on the CDBG program. The State CDBG exhibits in Chapter 4 have been rewritten to conform with the applicable statutory and regulatory requirements in order to make it easier for the field offices and out grantees to use in measuring compliance. We encourage our grantees to use the exhibits in doing a self-assessment on your programs. Chapter 34 is a new chapter that covers the Uniform Administrative Requirements in 2 CFR Part Parts of these exhibits would be used to monitor State CDBG, both the aspects of 2 CFR Part 200 that apply in the State CDBG regulations and those that a grantee may adopt if they choose to do so. Some of the other changes include the incorporation of Section 108 into IDIS, the AFFH citizen participation requirements, and the removal of the Consolidated Plan chapter as it is redundant of other monitoring efforts.

15 RECENT NOTICES AFFECTING THE CDBG PROGRAM
CPD Notice 17-06, Using CPD Funds for Disaster Response and Recovery CPD Notice 17-04, Reporting Requirements in the Integrated Disbursement and Information System (IDIS) for Section 108 Loan Guarantee Recipients CPD Notice 17-06: Using CPD Funds for Disaster Response and Recovery: Issued June 1, 2017 – this notice encourages grantees to carry-out pre-disaster planning and provides guidance to grantees on hose to use CDP formula grant funds to carry-out disaster response and recovery activities. CPD Notice 17-04: Reporting Requirements in the Integrated Disbursement and Information System for Section 108 Loan Guarantee Recipients: Issued May 26, 2017 – This notice provides an overview for how grantees can ensure compliance with the reporting requirements for financial transactions and accomplishments for eligible activities carried out with Section 108 funds.

16 RULEMAKING/FEDERAL REGISTER NOTICES
The Final Rule on New Certification Requirements for Housing Counseling was published on December 14, On May 31, 2017, a Federal Register Notice was published announcing the availability of the housing counseling certification exam. The three-year clock to become certified is now ticking. The final rule on the housing counceling certification requirements was published on December 14, 2016 The rule states that there six major topic areaa covered in the definition of housing counseling: Financial management; property maintenance; responsibilities of homeownership and tenancy; fair housing laws and requirements; housing affordability; and avoidance of, and responses to, rental and mortgage delinquency and avoidance of eviction and mortgage default. It can be called housing education, credit counseling, managing financial obligations as a homeowner, or something else, but if it does not cover the six major topic areas and if the person is not working for an agency that has been approved by HUD to participate in its Housing Counseling program, the service provided cannot be called housing counseling. What does this mean for CDBG? Housing counseling provided as a public service or as part of a homeownership assistance program must meet these requirements or it cannot be called housing counseling. Last, on May 31, 2017, the availability of the housing counseling certification examine was published in the Federal Register on May 31, 2017, so the three-year clock to become certified has begun.

17 RULEMAKING/FEDERAL REGISTER NOTICES (Cont.)
Final Rule issued December 20, 2016, Narrowing the Digital Divide Through Installation of Broadband Infrastructure in HUD-Funded New Construction and Substantial Rehabilitation of Multifamily Rental Housing. Final Rule issued December 16, 2016, Modernizing HUD's Consolidated Planning Process To Narrow the Digital Divide and Increase Resilience to Natural Hazards. Why? Installation of broadband infrastructure at the time of new construction or substantial rehabilitation is generally easier and less costly than when such installation is undertaken as a stand-alone effort. The Final Rule requires that the Consolidated Plan describe broadband access in housing occupied by low- and moderate-income households. If low income residents in the communities do not have such access, States and jurisdictions must consider providing broadband access to these residents in their decisions on how to invest HUD funds. The second concept added to the Consolidated Plan process requires jurisdictions to consider incorporating resilience to natural hazard risks, taking care to anticipate how risks will increase due to climate change, into development of the plan in order to begin addressing impacts of climate change on low- and moderate-income residents.

18 POLICY GUIDANCE IDIS Release – March 27, 2017: Update to correct the allowed Accomplishment Types/Matrix Code/National Objective combinations. Timely Distribution – No longer publishing annually HUD Form is being updated. 60-Day Federal Register Notice (June 16, 2017). 30-Day publication pending. New Timely Distribution Notice once form is approved. Area Benefit Data – Draft version under review, “Place-Level Margin of Error Data Set” is posted on the HUD EXCHANGE: The IDIS release on March 27, 2017 updated the system to reflect the appropriate Accomplishment Types/Matrix Code/National Objective combinations for activities. Instead of seeing the whole list to select from, you should be able to see only what is allowed under the specific matrix code you select for your activity. The State CDBG IDIS manual, Appendix C has been updated as well. There have been a few errors with the release, so if you do not see the option you want to select, please submit an AAQ to have the activity corrected manually by our programmers. CPD previously published an annual notice on Timely Distribution for states. This annual notice included a list of all states and whether they complied with the 15-month distribution requirement. We will no longer be publishing this CPD notice annually. The list will still be compiled and given to the Office of the Inspector General. HUD Form that is within the current notice is being updated to better reflect the compliance calculation of this requirement and it has already undergone the 60-day publication as required by the Paperwork Reduction Act, with the 30-day publication pending. Once this form has been approved, we will publish a new CPD notice with this form and subsequent CPD notices will only be published when there is another policy change. Many grantees have requested that HUD publish area-benefit data that includes the margin of error so they may make an assessment on using this data or performing a survey. While still in draft form, and under review, posted on the HUD EXCHANGE is the Place-Level Margin of Error Data Set. It is only for Census Places, and only for Places with 20% or more margin of error. As a reminder, the HUD provided LMI% is still the LMI% to be used. 189

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