Multifamily Housing Program Financial Management Toolkit

6e. Grantee and Sub-recipient Organizations’ Policies and Procedures

For both small purchases and more substantial procurements, grantees and sub-recipients must have written policies and procedures that describe how their organizations will procure goods and services, what information they will require when receiving a price or rate quote, and who will have approval authority.
Additionally, grantees and sub-recipients of HUD funds must have regular in-house trainings and a written code of standards for employees who award and administer contracts. An employee, officer or agent of a HUD grantee or sub-recipient organization should not participate in awarding a contract if any of the following people have an interest – financial or otherwise – in a firm that might be selected:

  • The employee, officer, or agent
  • Any member of their immediate family or a partner
  • An organization that employs, or is about to employ, any of the above

The board of directors and program staff should identify potential conflicts of interest. The board should review these situations, using the organization’s own procedures for addressing conflicts of interest. The independent auditors of a grantee or sub-recipient organization’s finances will typically also review the organization’s policies and activities for potential conflicts of interest and include recommendations for strengthening these policies if need be.