CDBG Entitlement FAQ

What kind of written agreements are required between a CDBG urban county and participating UGLGs? If no agreement is required by state/local law, does this mean that no written agreement should exist between the urban county and its UGLGs?

Date Published: March 2019

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There must be a written cooperation agreement between the urban county and its participating units of general local government (UGLGs) unless the urban county can undertake essential community development and housing assistance activities in incorporated areas. Urban counties must have cooperation agreements with UGLGs unless state/local law gives the urban county essential powers countywide, even in incorporated UGLGs. Since participating UGLGs are to be treated as subrecipients in accordance with 24 CFR 570.501(b), minimally, there must be an agreement between the urban county and its UGLGs that meets all the requirements at 24 CFR 570.503 [Agreements with subrecipients].

Cooperation agreements are not the same as subrecipient agreements. Cooperation agreements require UGLGs' cooperation to use their powers to carry out essential community development and housing assistance activities in accordance with the urban county's CDBG program. The agreements are in effect for three years unless they contain an automatic renewal clause. Cooperation agreements do not identify the activities to be carried out by the UGLGs. Subrecipient agreements contain a scope of work that the participating local government or subrecipient (a public or private nonprofit) is required to perform; have a budget; and usually have a beginning and ending date. The subrecipient agreement is not automatically renewing; the grantee and subrecipient may enter into a new subrecipient agreement. Cooperation agreements are only created between urban counties and participating UGLGs. Urban counties are encouraged to have both types of agreements with UGLGs, particularly when they or the UGLGs are carrying out CDBG assisted activities in an UGLG.

Tags: CDBG Entitlement Program Urban County