CDBG Entitlement FAQ

Where can I get resources to help the incorporated areas, the county commissioners, and other elected officials, especially, understand the CDBG urban county qualification and requalification process?

Date Published: March 2019

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HUD has produced a technical assistance product on the urban county qualification and requalification process. Access the product on the HUD Exchange Explore CDBG page by clicking on the link titled, "The Urban County CDBG Qualification Process--Requirements, Procedures and Deadlines."

The following table compares requirements for Joint Agreements and Cooperative Agreements.


A joint agreement is an agreement between an Urban County (UC) and a metropolitan city (entitlement). The UC receives both its own and the entitlement's CDBG grants and administers the entitlement's CDBG program in addition to its own CDBG program. The entitlement is treated as any other Unit of General Local Government (UGLG) that participates in the urban county's CDBG program (subject to the same requirements as subrecipients). A UC may be joined by more than one entitlement, but an entitlement located in more than one UC may be a joint recipient with only one UC at a time.
If an entitlement that was part of a UC becomes an entitlement grantee, it may elect to have a joint agreement with the UC. An existing entitlement may also elect to enter into a joint agreement instead of receiving and administering its own CDBG grant. However, it may only do so during the year that the UC is requalifying. The entitlement is legally obligated to remain in a joint agreement status for the duration of the three-year UC qualification period.

A cooperation agreement is an agreement made between a UC and a Unit of General Local Government, or UGLG (non-entitlement). The UC must enter into a cooperation agreement with any UGLG where the UC does not have power to carry out essential community renewal and lower-income housing assistance activities. UCs usually have essential powers in their unincorporated areas unless state or local law says otherwise.

Responsibilities of the Entitlement and UC


  • Provides input regarding activities to be funded with CDBG
  • Other responsibilities may be spelled out in the joint agreement, as agreed to by the entitlement and the UC
  • The UC is required to expend the entitlement's CDBG grant in and for the benefit of that entitlement


  • Administers CDBG program
  • Develops Consolidated Plan and Action Plan
  • Conducts the Assessment of Fair Housing
  • Conducts Citizen Participation
  • Submits CAPER
  • Administers IDIS
  • Program Income and Timeliness computed by UC

Responsibilities of the UGLG and UC


  • Work with the UC to determine what activities need to be carried out
  • UGLGs may carry out eligible activities


  • The UC maintains all responsibilities for CDBG grant administration such as submission of the Consolidated Plan/Action Plan and CAPER, A-133 audit, Assessment of Fair Housing, environmental review, design of the UGLGs CDBG program, and management/oversight of subrecipients
  • The UC may select UGLGs for CDBG awards but is not required to award CDBG funds to every participating UGLG. CDBG awards should be made only to the UGLGs that plan on carrying out an eligible activity
  • Management and oversight of the UGLG in carrying out CDBG-assisted activities


  • HUD computes a separate allocation amount each year for the entitlement and the UC, using their respective demographies.
  • HUD combines the two amounts and executes one grant agreement for the combined amount with the UC.
  • Joint agreements may be automatically renewing.
  • All program requirements such as the 20 percent planning and general administration cap, the 15 percent public service cap, and the 70 percent overall benefit requirement are based on the combined grant amount and apply to the UC's grant as a whole. The caps do not apply separately to the entitlement's and the UC's CDBG grants.
  • Low/moderate income summary data and the upper quartile exception criteria will be based on the UC's grant as a whole. These do not apply separately to the entitlement's and the UC's CDBG grants.

Regulatory and Operational Impacts of Cooperation Agreement

  • HUD computes one allocation amount for the UC as a whole, including the demographics of all participating UGLGs plus the unincorporated areas of the county.
  • HUD executes one grant agreement with the UC.
  • HUD has no contractual relationship with the UGLG - the UC does.
  • A UC may choose to use automatically-renewing cooperation agreements; in this situation, any participating UGLG is automatically included as a participant for the next three-year UC qualification period unless the UGLG notifies the UC in writing that it wishes to opt out of the UC when it is requalifying.
  • All program requirements such as the 20 percent planning and general administration cap, the 15 percent public service cap, the 70 percent overall benefit requirement, low/moderate income summary data, and the upper quartile exception criteria, etc. apply to the UC's grant as a whole, not to each individual sub-award to an UGLG.

HOME Program Implications

If the entitlement qualifies to receive a separate allocation of HOME funds, it has three options:

  1. it may form a HOME consortium with the UC, in which case it will be included as part of the UC when the HOME funds for the county are calculated;
  2. it may elect to continue to receive its separate HOME allocation but have the UC administer it; or
  3. the entitlement may administer its HOME program on its own.

HOME Program Implications

When included UGLGs become part of a UC for the CDBG Program, they are part of the UC for the HOME Program and may receive a formula allocation under the HOME Program only as part of the UC. Thus, even if the UC does not receive a HOME formula allocation, the participating UGLG cannot form a HOME consortium with other local governments. However, this does not preclude the UC or a UGLG within an urban county from applying to the State for HOME funds, if the State allows.

Tags: CDBG Entitlement Program Urban County

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