CDBG Entitlement FAQ

Does the use of CDBG funds to pay fees to a general contractor/builder managing a project trigger Davis-Bacon requirements?

Date Published: May 2015

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There are a number of project costs that may be paid with CDBG funds without triggering the Davis-Bacon requirements. These include:

  • Acquisition costs,
  • Financing costs, and
  • Soft costs such as the cost of legal, architectural and engineering, and construction management services.

You can find HUD’s description of the applicability of Davis-Bacon to CDBG projects provided on the Factors of Labor Standards Applicability page. If the fees to a general contractor/builder managing a project you cite are fees for services (e.g., communicating with building officials, consulting with the project architect, reviewing the construction schedule, conducting site inspections, etc.) payment of CDBG funds for these activities, alone, will not trigger the Davis-Bacon requirements.

Tags: CDBG Entitlement Program Davis-Bacon

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