Date Published: March 2019
Yes. If a CDBG grantee also has a Section 108 loan guarantee, the overall low- and moderate-income benefit requirement is required to be met. The CDBG grantee must include the Section 108 loan guarantee expenditure in its overall benefit test. The language at Section 104(b)(3)(A) and 24 CFR 91.225(b)(4)(ii) references a guarantee or a grant under Section 108, if applicable.