e-snaps FAQ
Q

Our CoC submitted a Code of Conduct which was listed on HUD's website; however, when we checked the website recently our Code of Conduct was no longer listed. Is this an error, and do we need do submit a new Code of Conduct?

Date Published: July 2017

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If your organization's Code of Conduct is no longer listed on HUD's website, you must attach an updated Code of Conduct to your Project Applicant Profile. Due to the implementation of 2 CFR part 200, many Codes of Conduct that were listed on HUD's website were removed as the Codes were not in compliance with (2 CFR 200.318(c)(1)).

Codes of Conduct must:

  1. Be written as a letter on company letterhead that provides the name and title of the responsible official, mailing address, business telephone number and email address;
  2. Prohibit real and apparent conflicts of interest that may arise among officers, employees or agents, or any member of his or her immediate family, his or her partner or an organization that employs any of the indicated parties;
  3. If applicable, the standards must also cover organizational conflicts of interest;
  4. Prohibit the solicitation and acceptance by employees, of gifts or gratuities in excess of minimum value; and
  5. Provide for administrative and disciplinary actions to be applied for violations of such standards.

The Office of Grants Management within HUD has reached out to organizations to obtain Codes of Conduct to ensure all HUD-funded projects are in compliance with 2 CFR part 200. If your organization is not appearing on HUD's website indicating the Code of Conduct is on file and in compliance, HUD strongly recommends that you attach your organization's Code of Conduct that meet all 5 of the criteria above to your Project Applicant Profile. Doing this now will prevent the need to resolve a condition for your CoC Program project if conditionally awarded.


Tags: e-snaps NOFAs/Notices - FY 2017 NOFA

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FAQ ID:

3260