My agency administers a Community Development Block Grant (CDBG)-funded activity that we have called housing counseling, but it is not as comprehensive/individualized as is defined in 24 CFR 5.100. Must we change our program to comply with the new housing counseling certification rule, as of August 1, 2020, the final compliance date for certification? Must we discontinue our program if it doesn’t comply? Or can we continue the program as currently designed?
Date Published: June 2017
A CDBG or CDBG Disaster Recovery (CDBG-DR) grantee still has the flexibility to design activities to meet its locally identified needs. The Final Rule does not mandate that anything previously characterized as “housing counseling” must now either meet the new requirements or stop receiving CDBG funds. (However, there is one exception: if a recipient is funding housing counseling under 24 CFR 570.201(k), Housing Services, in support of a HOME- funded homeownership program to which the Final Rule applies, then the CDBG- or CDBG-DR- funded activity will also be subject to the new Part 5 requirements.)
Apart from this exception for a recipient funding housing counseling under 24 CFR 570.201(k), Housing Services, in support of a HOME-funded homeownership program, a grantee may decide that it wishes to continue funding its activity as currently designed. Henceforth, however, an activity that does not meet the definition of 24 CFR 5.100 should not be called “housing counseling.” Grantees will need to come up with another term to characterize this type of activity, such as “housing information and referral services” or “homeownership education program” or “general budget/financial counseling”. HUD plans to make changes to the Integrated Disbursement and Information System (IDIS) system (used by grantees to report on formula CDBG funding) and the DRGR system (used by grantees to report on CDBG-DR funding) to reflect the changes triggered by the final housing counseling certification rule. These system changes will allow grantees (and HUD) to distinguish between those housing counseling activities that are subject to the Part 5 requirements and other types of housing information and education services that do not meet the 24 CFR 5.100 definition of housing counseling.