Is it acceptable for an Intermediary to combine the grant awards that were intended for two different sub-grantees, and reallocate the lump sum to a new sub-grantee?
Date Published: January 2018
Yes, the Intermediary must revise their plan and allocations according to the guidelines within their HUD Housing Counseling Grant Agreement for Intermediaries. According to HUD’s 2017 Housing Counseling Agreement (HCA) for Intermediaries, Article IV. C.1, a grantee shall have wide discretion to implement use of its grant through its sub-grantees, if applicable, and is responsible for managing the daily operations of its program. Also, Article V. B.2 states that a HUD grantee may make changes to the composition of sub-grantees and branches and/ or corresponding sub-grant amounts after the execution of the grant award document. Grantee must send HUD a written request to amend the list of branches or sub-grantees, or both, identified in HCS through the sub-allocation tool. Upon HUD’s approval of such request, the sub-allocation tool in the Housing Counseling System (HCS) must be amended by the Intermediary, State Housing Finance Agency (SHFA), or Multi-State Organization (MSO) and the Agreement shall be deemed amended accordingly. HUD may decrease the award amount available to the grantee if changes to the composition of sub-grantees and branches would result in a lower Maximum Award Amount than was awarded using the funding methodology stated in the Housing Counseling NOFA. HUD may also require a grantee to execute an amendment to this Agreement when a change in the composition of sub-grantees or branches providing counseling services changes a grantee’s classification as a National or Regional Intermediary or MSO and reduces the applicable Housing Counseling NOFA award limits under which grantee’s grant application was evaluated.
Grantees must maintain copies of all sub-grant agreements and a written record explaining how it sub-granted funds to its sub-grantees. Grantee shall also maintain a written record of funds allocated to its branches. These sub-grant agreements and records shall be available to HUD and the grantee’s sub-grantees.
Please note that grantees should always refer to the NOFA and grant agreement applicable to the year in which they received funding. These documents can be found on the HUD Exchange NOFA page.