Date Published: March 2019
No. Doing so violates the 2 CFR Part 200 cash management requirements regarding drawing funds in advance of cash needs [2 CFR 200.305(b)(1)]. Any funds drawn in such a manner will be included by HUD in computing your timeliness ratio anyway. The grantee must return the funds to the LOC unless it can revise the draws to another activity that has immediate cash needs. In addition, the grantee may owe interest to the U.S. Treasury.