CDBG Entitlement FAQ

What records must grantees keep in their files to show that the CDBG-assisted code enforcement meets all CDBG program requirements?

Date Published: April 2019

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At a minimum, grantees' files must contain:

  • The definition of deteriorated/deteriorating used by grantees.  If the state/local law definition of deteriorated/deteriorating is used, a copy of the definition with the citation should be included.

  • A description of the conditions of the areas in which CDBG funds are used for code enforcement, demonstrating that these areas meet the state local law definition of deteriorated/deteriorating or meet the criteria at 24 CFR 570.208(b)(1) or 24 CFR 570.483(c)(1) to define deteriorated/deteriorating.

  • Salary records (salaries, benefits, timesheets) of code enforcement inspectors being paid with CDBG funds and a description of all areas they are responsible for inspecting.  The timesheets should be supported by documentation showing that the inspections were performed on buildings located in designated deteriorated areas.

  • Documentation such as inspection logs that show the amount of time inspectors performed inspections within the designated deteriorated areas.

  • Salary records (salaries, benefits, timesheets) for employees that process and issue citations and collect and process fines.

  • Invoices for the purchase of necessary equipment (e.g., tablets, coveralls, vehicle lease payments, etc.) and use logs.

  • Costs for legal proceedings such as salaries of hearing officers and attorneys (salaries and timesheets).

  • If the low/moderate income area benefit national objective criterion is used, the boundaries of the areas in which CDBG funds are used for code enforcement and the low/moderate income summary data or local survey data that demonstrate compliance with this national objective.

  • If the slum/blight area national objective criterion is used, the grantee's delineation of the areas inspected as slum/blighted under state or local law; when the determination was made; a determination that a minimum of 25 percent of the buildings in the delineated area have either physical deterioration, property abandonment, chronic high occupancy turnover rates, and/or significant declines in property values or abnormally low property values relative to other areas in the community; and documentation of known or suspected environmental contamination.

  • If the slum/blight urban renewal national objective criterion is used, the Urban Renewal Plan in effect at the time of closeout of Federal financial assistance under the Housing Act of 1949 or financial settlement under Section 112 of the HCDA, documentation that the urban renewal plan is incomplete, and a description of how the code enforcement inspections and enforcement were needed to complete the plan for the area.

  • If the urgent need national objective is used, for entitlement grantees, a certification that the buildings inspected posed a serious and immediate threat to the health and welfare of the community, the disastrous occurrence was of recent origin (18 months before the grantee's certification, and that no other funding resources were available to assist the activity [24 CFR 570.208(c)].  For the State CDBG program, the unit of general local government makes the certification, and the State determines, that the criterion above was met. See 24 CFR 570.483(d).

  • Identification of other activities to be carried out (whether CDBG-assisted or not) that will arrest the decline of the areas and their funding sources.

  • Compliance with the procurement standards at 2 CFR 200.318-200.326 when equipment and services are procured.

Tags: CDBG Entitlement Program Code Enforcement