Record Retention

How long must I retain grant records? (§ 578.103(c))

All records pertaining to CoC Program funds must be retained for at least five years unless CoC Program funds were used for the acquisition, new construction, or rehabilitation of a project site.

Program participants’ qualifications, eligibility documentation, and other program participant records must be retained for five years after expenditure of all funds from grant under which program participants were served (§ 578.103(c)(1)). Records for acquisition, new construction, and rehabilitation must be retained for 15 years following the date the project is first occupied, or used, by program participants (§ 578.103(c)(2)).

The five-year record retention request requirement for a project is tied to an individual grant. The recipient must maintain its records for five years per grant, even if the project keeps operating. For example, if an agency was awarded a grant for a project without hard costs to operate from September 1, 2017 through August 30, 2018, you would save records for that grant until at least August 30, 2023. If that project was renewed from September 1, 2018 through August 30, 2023, records from that grant would need to be saved until at least August 30, 2024.

Looking for definitions of the common CoC and ESG Program terms referenced throughout the Virtual Binders?

Virtual Binders Glossary

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There are also recordkeeping requirements related to establishing and operating the CoC (§ 578.103(a)(1)). Each collaborative applicant must keep the CoC's documentation related to establishing and operating a CoC, including monitoring reports of recipients and subrecipients and evidence that the CoC has prepared the application for funds as set forth in Section 578.9, including the designation of the eligible applicant to be the collaborative applicant.