Date Published: October 2012
24 CFR 570.611 of the CDBG regulations govern conflicts of interest. In general, conflicts arise when a representative of the grantee has a financial interest in a contract awarded by the agency. If the broker is independently representing a beneficiary of the program, it is unlikely that there is a conflict but the relationship should be disclosed to the local NSP grantee and any fee paid to the broker on the transaction must meet federal standards of cost reasonableness (OMB Circular A-122). If the broker is working on behalf of the NSP grantee, the NSP grantee may be required to follow specific federal procurement guidelines in entering into a contract with the real estate broker. If these procurement guidelines were followed and the potential conflict of interest for the property is disclosed to the organization responsible for selling the NSP property, the broker may represent beneficiary.
NOTE: When Dealing with Conflict of Interest questions, it is recommended that you contact your local field office to ensure compliance with all applicable regulations. Specific facts vary greatly such that general advice has limited applicability.