If CDBG funds only pay for pre-development costs on a project that will ultimately lead to jobs for low- and moderate-income people, does the use of the CDBG funds in the project trigger Davis-Bacon requirements? CDBG funds will not be used to pay for any other part of the project which may include acquisition, construction, or rehabilitation.
Date Published: May 2015
There are a number of project costs that may be paid with CDBG funds without triggering the Davis-Bacon requirements. These include:
The use of CDBG for predevelopment costs such as those described in your question will not alone trigger Davis-Bacon prevailing wage requirements. However, if any construction work of $2,000 or more is paid for with CDBG funds, then all of the construction costs are covered. It is the use of funds, not the timing, that matters.