CDBG Entitlement FAQ

What certifications are required upon submission of the Consolidated Plan (Con Plan) or annual action plan?

Date Published: March 2019

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The consolidated plan certifications required by a jurisdiction can be found at §91.225 (local governments), §91.325 (States) and §91.425 (HOME Consortia). The specific certifications required are determined by whether a jurisdiction is a member of a HOME consortia, a state entity or a local government. The following chart highlights the general certifications required by each type of jurisdiction.

General Certification Local Jurisdiction State HOME Consortium
Affirmatively Furthering Fair Housing X X X
Anti-Displacement and Relocation Plan X X X
Anti-Lobbying X X X
Authority of consortium     X
Authority of jurisdiction X    
Authority of state   X  
Consistency with Plan X X X
Acquisition and Relocation X X X
Section 3 X X X

Program-specific certifications are also required. The following chart highlights the required program-specific information that should be contained in each certification by funding source.

CDBG Certification ESG Certification HOME Certification HOPWA Certification
  • Citizen participation
  • Consultation with local governments
  • Community development plan
  • Use of funds
  • Compliance with anti-discrimination
  • Excessive force
  • Compliance with laws
  • Rehab/conversion - 10-yr/3-yr min period of use
  • Not less than 3 years
  • Limits for shelter for street outreach
  • Renovation will result in safe and sanitary buildings
  • Recipients will assist in obtaining permanent housing and supportive services
  • Match requirements
  • Confidentiality
  • Involvement of homeless individuals and families
  • Consistency with con plan
  • Discharge policy
  • TBRA is consistent with plan
  • Use for eligible activities
  • PJ will evaluate HOME assisted projects for appropriate financial assistance
  • Certification of consistency from the authorized public officials for each other locality in the EMSA where housing assistance is provided
  • Activities funded under the program will meet urgent needs not being met by public and private sources
  • Any building or structure assisted under that program shall be operated for the purpose specified in the plan
  • For 10-year period involving new construction, substantial rehabilitation, or acquisition
  • Three-years in the case of assistance involving non-substantial rehab or repair of the building or structure

Tags: CDBG Entitlement Program Consolidated Plan