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CDBG Recordkeeping Requirements For Grant Administrators. Recordkeeping Requirements. UGLG Records 24 CFR 570.490 States will Establish Recordkeeping Requirements for UGLGs State records include information from UGLG reports and records Both State and UGLG Records
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CDBG Recordkeeping Requirements For Grant Administrators
Recordkeeping Requirements • UGLG Records 24 CFR 570.490 • States will Establish Recordkeeping Requirements for UGLGs • State records include information from UGLG reports and records • Both State and UGLG Records • Must Include Racial, Ethnic, and Gender Data on Applicants, Participants, Beneficiaries
Recordkeeping • Absolutely critical to establish good record keeping system • Records are the only method of verifying compliance with the program requirements • All records must be retained for the period of time designated by the state from the application through the certification of closeout
Recordkeeping • You must keep them because the state, HUD, general public, or the press, may want or need to access them for a variety of valid reasons • Files must always be kept by the UGLG, in a secure location!
Recordkeeping • Application • Award letter • Grant agreement • Citizen Participation Plan • All financial records • Program Income • Environmental Review Record • (Especially Release of Funds Letter) • Procurement Documents • Labor Standards Documents
Recordkeeping • Section 3 Reports • WBE/MBE Reports • Proof that projects are eligible and meet a national objective • Sub-recipient agreements • Affordability agreements (housing) • Economic development agreements to provide jobs (specifics) • Job retention and creation tracking form
Recordkeeping • Acquisition and Relocation Files • Acquisition and Disposition Register • Documentation of AFFH activities • Income surveys • Monitoring Letters • Beneficiary information
Recordkeeping • Close out documents (as specified by state) • Monitoring findings resolved and final budget completed based on actual expenditures • Certificate of completion (from State) • Final audit report • Others • Records related to any open audits, reviews, or investigations should be retained
Record Retention • Length of time for record retention at local level is related to when HUD closes out the Federal grant with the State • 24 CFR 570.490(d): Records of the UGLG shall be retained for three years after the State grant is closed by HUD • Change of use of a project by the UGLG requires longer period of record retention
Record Retention • Hold records until notified by State that they can be disposed of • Or, For Other Specified Periods • 24 CFR 570.487, Other Applicable Laws • 24 CFR 570.488, Displacement, Relocation, etc
Access to Records • UGLG must provide access to records (24 CFR 570.490(c)) • HUD, IG, and GAO have access rights to all records • State and UGLG will provide citizens with reasonable information about past use of CDBG funds