CDBG Entitlement FAQ

How does HUD measure compliance with the overall low- and moderate-income benefit requirement?

For example, is it tested based upon:

  1. Expenditure of CDBG funds that occurs during the program year(s) listed in the certification?
  2. Expenditure of CDBG funds out of the individual grant years listed in the certification?

Date Published: March 2019

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HUD measures compliance with this requirement by reviewing the expenditure CDBG funds that occurs during the one-, two-, or three-year certification period, as appropriate. It is not based on the expenditure of CDBG funds out of the individual year grant(s) listed in the certification. This is because some CDBG funds for a grant year may not be spent until the following or subsequent years. For example, a grantee planned to spend $500,000 from its 2014 CDBG grant for a senior center. However, the project was delayed for various reasons, and the senior center was not completed until fall 2016. The 2014 CDBG funds spent in 2016 for this activity will be considered when conducting a compliance review during the grantee's certification period containing program year 2016. The fiscal years referenced in the certification are, therefore, the fiscal years that correspond to the grantee's program years. If a grantee selects a three-year certification period of FY 2015-2017 and it has a July 1 program year start date, compliance will be based on the grantee's expenditures between July 1, 2015 and June 30, 2018.

Tags: CDBG Entitlement Program Overall Benefit