The CARES Act did not suspend the requirement to meet a national objective, so you must ensure that every activity carried out with CDBG-CV funds will do so. Every CDBG-CV funded activity must meet the standards for one of the following three CDBG National Objectives.
- An activity that benefits low- and moderate-income (LMI) persons
- An activity designed to meet community development needs having a particular urgency. The activity must be designed to alleviate existing conditions which pose a serious and immediate threat to the health or welfare of the community which are of recent origin or which recently became urgent, and the recipient must demonstrate inability to finance the activity on its own and that other sources of funding are not available.
- An activity that aids in the prevention or elimination of slums or blight
The proposed activity must achieve one of these national objectives before you can proceed with a final decision to use CDBG-CV funds. You also need to ensure that your CDBG-CV grant meets the overall benefit requirement, meaning no less than 70 percent of the combined CDBG-CV expenditures from all three stages of funding must be used for activities that benefit LMI persons.
Since CDBG-CV funded activities must also prevent, prepare for, and respond to the COVID-19 pandemic, some activities may qualify under the Urgent Need objective, even though it is rarely used in the regular CDBG program. Before you undertake any Urgent Need national objective analysis, you should review the extensive discussion and guidance on recordkeeping methods to meet the Urgent Need national objective in the CDBG-CV Notice (see page 51465).
Though CDBG-CV funds may be used for activities that achieve any of the three national objectives, the elimination of slums and blight does not often apply. Under this national objective, CDBG-CV records must document the activity alleviates blighting conditions, and it may be difficult to relate activities that primarily meet this national objective to the prevention, preparation for, and response to coronavirus.