CPD Monitoring Handbook 6509.2 Rev-6 - OneCPD

HANDBOOK 6509.2 REV-6 

U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 

Office of Community Planning and Development 

Departmental Staff 

and Program Participants 

APRIL 2010 

COMMUNITY PLANNING 

AND DEVELOPMENT 

MONITORING HANDBOOK 

CHAPTER 8 – Economic Recovery Programs

________________________________________________________________________

CHAPTER 8 

TABLE OF CONTENTS 

ECONOMIC RECOVERY PROGRAMS 

8-1 APPLICABILITY……………………………………………………………...8-1 

8-2 REVIEW OBJECTIVES……………………………………………………….8-1 

8-3 MONITORING THE HOMELESSNESS PREVENTION AND RAPID 

RE-HOUSING PROGRAM (HPRP)… ………………………………………8-1 

8-4 MONITORING THE NEIGHBORHOOD STABILIZATION 

PROGRAM 1 (NSP-1)…………… …………..……………………………...8-3 

8-5 MONITORING THE NEIGHBORHOOD STABILIZATION 

PROGRAM 2 (NSP-2)………………………………………………………...8-5 

8-6 MONITORING THE COMMUNITY DEVELOPMENT BLOCK 

GRANT RECOVERY PROGRAM (CDBG-R)………………………………8-8 

EXHIBIT 8-1 

EXHIBIT 8-2 

EXHIBIT 8-3 

EXHIBIT 8-4 

EXHIBIT 8-5 

EXHIBIT 8-6 

EXHIBIT 8-7 

EXHIBIT 8-8 

EXHIBIT 8-9 

EXHIBIT 8-10 

EXHIBIT 8-11 

EXHIBIT 8-12 

EXHIBIT 8-13 

EXHIBIT 8-14 

EXHIBIT 8-15 

EXHIBIT 8-16 

EXHIBIT 8-17 

EXHIBIT 8-18 

Guide for Review of HPRP Program Progress 

Guide for Review of HPRP-Assisted Housing 

Guide for Review of HPRP Financial Assistance and Housing 

Relocation and Stabilization Services 

Guide for Review of HPRP Program Participants 

Guide for Review of HPRP Subgrantee Management 

Guide for Review of HPRP Overall Grant Management 

Guide for Review of HPRP Financial Management 

Guide for Review of HPRP Cost Allowability 

Guide for Review of HPRP Other Federal Requirements 

Guide for Review of NSP-1 Program Progress 

Guide for Review of NSP-1 National Objective of Benefit to Low-, 

Moderate-, and Middle-Income Persons 

Guide for Review of NSP-1 Cooperative Agreements 

Guide for Review of NSP-1 State Requirements 

Guide for Review of NSP-1 Continued Affordability 

Guide for Review of NSP-1 Eligible Use C: Establish Land Banks 

Guide for Review of NSP-1 Fair Housing and Equal Opportunity 

Requirements 


Guide for Review of CDBG-R Activities 

i 04/2010

6509.2 REV-6 

CHAPTER 8 

ECONOMIC RECOVERY PROGRAMS 

8-1 APPLICABILITY. The procedures outlined in this chapter are designed to provide 

guidance for monitoring funds provided under the Housing and Economic Recovery Act 

of 2008 (HERA) and the American Recovery and Reinvestment Act of 2009 (Recovery 

Act), specifically, for these programs: 

• the Homelessness Prevention and Rapid Re-Housing Program (HPRP), 

• the Neighborhood Stabilization Program 1 (NSP-1), 

• the Neighborhood Stabilization Program 2 (NSP-2), and 

• the Community Development Block Grant Recovery Program (CDBG-R). 

These funds have been appropriated for activities that will create jobs, restore economic 

growth and help those in greatest need, as a result of an unprecedented economic 

downturn. The expectation is that these funds will be spent with some degree of urgency. 

Therefore, monitoring and oversight by CPD Field Office staff is a critical function to 

protect this investment. 

8-2 REVIEW OBJECTIVES. HUD reviewers are to follow the risk analysis process as 

referenced in Chapter 2, Section 2-3, of this Handbook. Guidance specific to these 

programs is contained in the Notice, “Implementing Risk Analyses for Monitoring 

Community Planning and Development Grant Programs in FY 2010 and 2011,” dated 

August 4, 2009 (see: 

http://portal.hud.gov/portal/page/portal/HUD/program_offices/administration/hudclips/notices/cpd). 

While the guidance for the specific programs listed in Section 8-1 above is contained 

within this Chapter, each program has its own separate Exhibits to be used when 

conducting monitoring. It is important to note that the NSP-1, NSP-2, and CDBG-R 

Exhibits require the reviewer to use the existing CDBG Exhibits that are in Chapters 3 and 

4 of this Handbook. 

8-3 MONITORING THE HOMELESSNESS PREVENTION AND RAPID RE-HOUSING 

PROGRAM (HPRP). This part of Chapter 8 provides guidance for conducting 

comprehensive monitoring of the Homelessness Prevention and Rapid Re-Housing 

Program (HPRP). It contains nine Exhibits specific for monitoring the HPRP program, 

covering: HPRP Program Progress; HPRP-Assisted Housing; HPRP Financial Assistance 

and Housing Relocation and Stabilization Services; HPRP Program Participants; HPRP 

Subgrantee Management; HPRP Overall Grant Management; HPRP Financial 

Management; HPRP Cost Allowability; and HPRP Other Federal Requirements. 

8-1 04/2010


A. Program Overview. HUD awards funds for HPRP on a formula basis, for the purpose 

of providing financial assistance and/or housing relocation and stabilization services to 

either prevent individuals and families from becoming homeless or help those who are 

experiencing homelessness to be quickly re-housed and stabilized. HUD awarded 

HPRP funds through the approval of the Substantial Amendment to the Consolidated 

Plan 2008 Annual Action Plan submitted by eligible grantees. 

Eligible grantees are States, Metropolitan Cities, Urban Counties and Territories. 

Generally, grantees may only subgrant to non-profit organizations and local 

governments. However, a local government grantee that obtains a waiver from HUD 

may subgrant to a public housing agency. (Note: For purposes of this program, term 

“grantee” means the direct recipient of the HUD award. The term “subgrantee” means 

the organization that is responsible for carrying out the proposed project activities. The 

term “program participant” means the individuals and adults in families who received 

assistance during the operating year.) 

B. Preparing for Monitoring HPRP. The specific HPRP program areas or requirements to 

be monitored are determined as part of the risk assessment process (see additional 

guidance provided in Chapter 2 and Section 8-2 above). Before monitoring, the 

reviewer should be familiar with the HPRP requirements and the design and operation 

of the grantee’s project, particularly those areas that have been identified as high risk 

or are the focus of the monitoring. Information that will assist in successful HPRP 

monitoring includes: 

• the authorizing legislation, Title XII of Division A of the American Recovery 

and Reinvestment Act of 2009 (“Recovery Act”); 

• the “Notice of Allocations, Application Procedures, and Requirements for 

Homelessness Prevention and Rapid Re-Housing Program Grantees under the 

American Recovery and Reinvestment Act of 2009” (HPRP Notice); 

• the grant agreement(s) for the program(s) being monitored; 

• any HUD-approved waivers; 

• the most recent Annual Performance Report (APR); 

• the most recent HPRP Quarterly Performance Report; 

• Integrated Disbursement and Information System (IDIS) draw-down 

information; 

• the approved HPRP Substantial Amendment to the Consolidated Plan 2008 

Annual Action Plan; and 

• the Homeless Information Management System (HMIS) (examining usage of 

system for HPRP). 

04/2010 8-2


C. File Selection and Sampling. As described in Chapter 2, the risk analysis process will 

be used to determine which grantees and areas should be reviewed. The term “files” 

for compliance monitoring purposes, includes files from the grantee, the subgrantee, or 

a combination of both, as applicable. Once that process has been completed, where it 

is indicated that a file review is necessary to answer Exhibit questions, the HUD 

reviewer should consider the following factors when determining the specific files that 

will comprise the review sample: 

1. Where feasible, initial file selection should be made using a random selection 

method. 

2. The reviewer would consider adding more files to this selection in order to: 

i. Include a file or files from each staff person working in the respective 

program area being monitored. 

ii. Expand the sample, if possible, to include additional files with the same 

characteristics, if indicated by the severity or nature of any problems(s) noted 

during the review of the initial selection (for example, same problem category, 

same staff person, same activities or other characteristics). 

This expanded sampling aids in determining whether problems are isolated events 

or represent a systemic problem. Note, however, that Exhibit 8-4, “Guide for 

Review of HPRP Program Participants,” is mandatory for all HPRP projects. 

3. The reviewer may also add files to the selection from any HPRP program that the 

HUD reviewer has reason to believe may have compliance problems or that is 

substantially different in terms of size, complexity, or other factors from other 

projects the HPRP grantee has undertaken. 

8-4 

MONITORING THE NEIGHBORHOOD STABILIZATION PROGRAM 1 (NSP-1). 

This part of Chapter 8 provides guidance for conducting comprehensive monitoring of 

Neighborhood Stabilization Program 1 (NSP-1) projects. It contains seven Exhibits 

specific to monitoring this Program, covering: NSP-1 Program Progress; NSP-1 National 

Objective of Benefit to Low-, Moderate-, and Middle-Income Persons; NSP-1 

Cooperative Agreements; NSP-1 State Requirements; NSP-1 Continued Affordability; 

NSP-1 Eligible Use C: Establish Land Banks; and NSP-1 Fair Housing and Equal 

Opportunity Requirements. 

A. Program Overview. HUD awarded funds for NSP-1 on a formula basis, for the 

purpose of providing emergency assistance for redevelopment of abandoned and 

foreclosed homes and residential properties. HUD awarded NSP-1 funds through the 

approval of a Substantial Amendment to the 2008 Consolidated Annual Action Plan. 

The submission of the substantial amendment required grantees to design their 

program around a set of NSP-1 eligible uses that correlated with a number of eligible 

activities from the CDBG entitlement regulations. 

8-3 04/2010


Eligible grantees are entitlement communities, States, the State of Hawaii, and the 

insular areas. Grantees may subgrant to non-profit organizations and local 

governments. (Note: For purposes of these monitoring exhibits, term “Program 

Participant” means the direct recipient of the HUD award (Grantee) and the 

organization that is responsible for carrying out the proposed project activities.) 

B. Preparing for Monitoring NSP-1. The specific NSP-1 program areas or requirements 

to be monitored are determined as part of the risk assessment process (see additional 

guidance provided in Chapter 2 and Section 8-2 above). Before monitoring, the 

reviewer should be familiar with the NSP requirements and the design and operation 

of the grantee’s program, particularly those areas that have been identified as high risk 

or are the focus of the monitoring. Information that will assist in successful NSP-1 


• the authorizing legislation, Title III of Division B of the Housing and Economic 

Recovery Act of 2008 (HERA); 



• the authorizing legislation, Title I of Division A of the Helping Families Save 

Their Homes Act of 2009 (HFSTHA); 

• the “Notice of Allocations, Application Procedures, Regulatory Waivers 

Granted to and Alternative requirements for Emergency Assistance for 

redevelopment of Abandoned and Foreclosed Homes Grantees Under the 

Housing and Economic Recovery Act, 2008” (NSP Notice); 

• the “Notice of Allocations, Application Procedures, Regulatory Waivers 

Granted to and Alternative requirements for Emergency Assistance for 

redevelopment of Abandoned and Foreclosed Homes Grantees Under the 

Housing and Economic Recovery Act, 2008; Revisions to Neighborhood 

Stabilization Program (NSP) and Technical Corrections” (“Bridge Notice”); 

• the approved NSP-1 Substantial Amendment to the 2008 Consolidated Annual 

Action Plan; 

• the “Notice of Change in Definitions and Modification to Neighborhood 

Stabilization Program (NSP)” published at 75 Fed. Reg. 18228; 

• the State’s Public Law 111-22 minimum allocation substantial amendment (if 

applicable); 

• the grant agreement(s) for the project(s) being monitored; 


• the most recent Disaster Recovery Grant Reporting System (DRGR) Quarterly 

Performance Report (QPR); 

• the Integrated Disbursement and Information System (IDIS) draw-down 

information (if NSP-1 funds are being combined by other HUD funds); and 

04/2010 8-4


• other applicable chapters of this Handbook as the NSP-1 Exhibits contain only 

NSP-1 specific questions, whereas the grants are to be considered Community 

Development Block Grant (CDBG) funds. Therefore, Chapter 3, Community 

Development Block Grant (CDBG) Entitlement, Small Cities, Non Entitlement 

CDBG Grants in Hawaii, and Insular Area Programs; and Chapter 4, State 

Community Development Block Grant (CDBG) Program, are to be used in 

conjunction with the NSP-1 specific Exhibits for monitoring purposes. 




a combination of both as applicable. Once that process has been completed, where it is 

indicated that a file review is necessary to answer Exhibit questions, the HUD 




method. 





characteristics, if indicated by the severity or nature of any problems(s) noted 

during the review of the initial selection (for example, same problem 

category, same staff person, same activities or other characteristics). 

This expanded sampling aids in determining whether problems are isolated 

events or represent a systemic problem. 

3. The reviewer may also add files to the selection from any project that the HUD 

reviewer has reason to believe may have compliance problems or that is 


projects the NSP-1 grantee has undertaken. 

8-5 MONITORING THE NEIGHBORHOOD STABILIZATION PROGRAM 2 (NSP-2). 

This part of Chapter 8 provides guidance for conducting comprehensive monitoring of the 

Neighborhood Stabilization Program 2 (NSP-2) projects. 

A. Program Overview. HUD awarded funds for NSP-2 on a competitive basis, for the 

purpose of providing emergency assistance for redevelopment of abandoned and 

foreclosed homes and residential properties. HUD awarded NSP-2 funds through the 

competitive process, using a separate grant agreement. The submission of the NSP-2 

grant application required grantees to design their program around the requirements set 

forth in the NSP-2 Notice of Fund Availability (NOFA), using NSP eligible uses that 

correlated with a number of eligible activities from the CDBG entitlement regulations. 

8-5 04/2010


Eligible grantees are state governments, units of general local government, Indian 

tribes, public housing authorities, nonprofit entities (public and private), or consortium 

of nonprofits (public and private). Grantees may subgrant to non-profit organizations 

and local governments. (Note: For purposes of these monitoring Exhibits, term 

“Program Participant” means the direct recipient of the HUD award (Grantee) and the 

organization that is responsible for carrying out the proposed project activities.) 

B. Preparing for Monitoring NSP-2. The specific NSP-2 program areas or requirements 

to be monitored are determined as part of the risk assessment process (see additional 

guidance provided in Chapter 2 and Section 8-2 above). There is a single NSP-2 

Exhibit, 8-17, in this Chapter for monitoring program progress. Before monitoring, the 

reviewer should be familiar with the NSP-2 requirements and the design and operation 

of the grantee’s program, particularly those areas that have been identified as high risk 

or are the focus of the monitoring. Information that will assist in successful NSP-2 


• the authorizing legislation, Title III of Division B of the Housing and Economic 

Recovery Act of 2008 (HERA). 



• the “Notice of Definition Revision to Notice of Fund Availability (NOFA) for 

Fiscal Year 2009: Neighborhood Stabilization Program 2 (NSP-2) under the 

American Recovery and Reinvestment Act of 2009; Change in Definitions;” 

• the “Notice of HUD’s Fiscal Year (FY) 2009 Notice of Funding Availability 

(NOFA); Policy Requirements and General Section to HUD’s FY 2009 NOFAs 

for Discretionary Programs”; 

• the “Notice of Fund Availability (NOFA) for the Neighborhood Stabilization 

Program 2 under the American Recovery and Reinvestment Act, 2009” (NSP-2 

NOFA); 

• the three NSP-2 NOFA Correction Notices: 

o the “Notice of Fund Availability (NOFA) for Fiscal Year 2009 

Neighborhood Stabilization Program 2 under the American Recovery 

and Reinvestment Act of 2009; Correction” [Docket No. FR-5321-C-02, 

June 11, 2009]; 




November 9, 2009]; 




January 21, 2010]; 

04/2010 8-6


• the consortium agreement (if applicable) for the project(s) being monitored; 



• the most recent Disaster Recovery Grant Reporting System (DRGR) Quarterly 

Performance Report (QPR); 

• the Integrated Disbursement and Information System (IDIS) draw-down 

information (if NSP-2 funds are being combined by other HUD funds); and 

• other applicable chapters of this Handbook as the NSP-2 exhibit contains only 

NSP-2 specific questions, and the grants are to be considered Community 



CDBG Grants in Hawaii, and Insular Area Programs, Chapter 4, State 

Community Development Block Grant (CDBG) Program, and the NSP-1 

Exhibits in this Chapter outline the NSP-specific requirements that are 

applicable to both programs and are to be used in conjunction with the NSP-2 

specific Exhibit for monitoring purposes. 









method. 





characteristics, if indicated by the severity or nature of any problems(s) 

noted during the review of the initial selection (for example, same problem 



or represent a systemic problem. Note, however, that Exhibit 8-17, “Guide for 

Review of NSP-2 Program Progress,” is mandatory for all NSP-2 projects and 

must be used in conjunction with the NSP-1 Exhibits contained in Chapter 8 of 

this Handbook and all other aforementioned applicable CDBG Chapters and 

Exhibits as necessary to monitor the selected sample. 

8-7 04/2010





projects the NSP-2 grantee has undertaken. 

8-6 MONITORING THE COMMUNITY DEVELOPMENT BLOCK GRANT RECOVERY 

PROGRAM (CDBG-R). This part of Chapter 8 provides guidance for monitoring the 

Community Development Block Grant Recovery Program (CDBG-R). It contains a single 

Exhibit, 8-18, for review of CDBG-R activities. 

A. Program Overview. HUD awarded funds for CDBG-R on a formula basis, for the 

purpose of providing financial assistance for infrastructure improvements that meet the 

overall goals of the American Recovery and Reinvestment Act (“Recovery Act”) of 

2009, which are to stimulate the economy through measures that modernize the 

nation’s infrastructure, improve energy efficiency, and expand educational 

opportunities and access to health care. HUD awarded CDBG-R funds through the 

approval of a Substantial Amendment to the 2008 Consolidated Annual Action Plan. 

The submission of the substantial amendment required grantees to design their 

program based on the aforementioned purposes of the Recovery Act. Moreover, the 

Recovery Act requires that CDBG-R follow the requirements of the “Buy American” 

provision, that is, any project that includes the construction, maintenance, or repair of 

a public building or public work must use iron, steel, and manufactured goods that are 

produced in the United States, unless an official waiver has been given. 

Eligible grantees are entitlement communities, States, the State of Hawaii, and the 

insular areas. Entitlement grantees may subgrant to non-profit organizations and State 

grantees will subgrant to units of general local government. (Note: For purposes of 

these monitoring Exhibits, term “Program Participant” means the direct recipient of 

the HUD award (Grantee) and the organization that is responsible for carrying out the 

proposed project activities.) 

B. Preparing for Monitoring CDBG-R. The specific CDBG-R program areas or 

requirements to be monitored are determined as part of the risk assessment process 

(see additional guidance provided in Chapter 2 and Section 8-2 above). Before 

monitoring, the reviewer should be familiar with the CDBG-R requirements and the 

design and operation of the grantee’s program, particularly those areas that have been 

identified as high risk or are the focus of the monitoring. Information that will assist 

in successful CDBG-R monitoring includes: 



• the “Notice of Program Requirements for Community Development Block Grant 

Program Funding Under the American Recovery and Reinvestment Act of 2009 

(CDBG-R Notice); 

04/2010 8-8


• the “Requirements for Implementing Sections 1512, 1605, and 1606 of the 

American Recovery and Reinvestment Act of 2009 for Financial Assistance 

Awards” (“OMB Interim Guidance”); 

• the “ Buy American Exception Under the American Recovery and Reinvestment 

Act of 2009: Notice of National Exceptions of Section 1605 (Buy American 

Requirement) of the American Recovery and Reinvestment Act of 2009 

Applicable to Community Planning and Development Recovery Act Funds” 

(CPD “Buy American” Waiver Notice); 

• the “CPD Implementation Guidance for the Buy American Requirement of the 

American Recovery and Reinvestment Act of 2009 including the Exception 

Process” (NOTICE: CPD-09-05); 

• the approved CDBG-R Substantial Amendment to the 2008 Consolidated 

Annual Action Plan; 



• the most recent Consolidated Action Performance Evaluation report (CAPER) or 

Performance Evaluation report (PER); 

• Integrated Disbursement and Information System (IDIS) draw-down information; 

and 

• other applicable chapters of this Handbook as the CDBG-R Exhibit contains 

CDBG-R specific questions, and the grants are to be considered Community 



CDBG Grants in Hawaii, and Insular Area Programs, and Chapter 4, State 

Community Development Block Grant (CDBG) Program, are to be used in 

conjunction with the CDBG-R exhibit for monitoring purposes. 









method. 


8-9 04/2010





characteristics, if indicated by the severity or nature of any problems(s) 

noted during the review of the initial selection (for example, same problem 



or represent a systemic problem. 




projects the CDBG-R grantee has undertaken. 

04/2010 8-10

Exhibit 8-1 6509.2 REV-6 

Homelessness Prevention and Rapid Re-Housing Program (HPRP) 

Name of Grantee: 

Guide for Review of HPRP Program Progress 

Staff Consulted: 

Project Name/Number: 

Name(s) of 

Reviewer(s) 

Date 

NOTE: All questions that address requirements contain the citation for the source of the requirement 

(statute, regulation, or grant agreement). If the requirement is not met, HUD must make a 

finding of noncompliance. All other questions (questions that do not contain the citation for the 

requirement) do not address requirements, but are included to assist the reviewer in 

understanding the participant's program more fully and/or to identify issues that, if not properly 

addressed, could result in deficient performance. Negative conclusions to these questions may 

result in a "concern" being raised, but not a "finding." 

Instructions: This Exhibit is designed to review HPRP programs to determine if overall 

program deadlines are being met. 

1. 

Did the grantee sign and return the grant agreement to HUD within 15 days 

of the date that HUD signed the grant agreement? 

[HPRP Notice – Section IV. Requirements for Funding (F) Review and 

Approval of Applications (4) Grant Agreement] 

Describe Basis for Conclusion: 

Yes No N/A 

2. 

Did the grantee award or enter into legally binding grant agreements with all 

of its subgrantees by September 30, 2009? 

[HPRP Notice – Section V. Post-Award Process Requirements, (A) 

Deadlines for Using Grant Amounts (1) Grantee Obligation] 


Yes No N/A 

3. 

Do the IDIS drawdown records demonstrate that the grantee is drawing 

down HPRP funds at least quarterly? 

[HPRP Notice - Section V. Post-Award Process Requirements, (C) 

Timeliness Standards] 


Yes No N/A 

8-1 04/2010

6509.2 REV-6 Exhibit 8-1 

Homelessness Prevention and Rapid Re-Housing Program 

4. 

Did the grantee expend at least 60% of its HPRP funds within 2 years from 

the date that HUD signed the grant agreement? 

[HPRP Notice - Section V. Post-Award Process Requirements, (A) 

Deadlines for Using Grant Amounts, (2) Expenditure, and Division A, Title 

XII of the American Recovery and Reinvestment Act of 2009 (“Recovery 

Act”)] 


Yes No N/A 

5. 

Did the grantee expend all of its HPRP funds within the term of the grant? 

(Note: Drawdowns for eligible costs that were incurred during the grant 

period may be drawn down for up to 90 days after the expiration of the 

grant.) 

[HPRP Notice – Section V. Post-Award Process Requirements (A) 

Deadlines for Using Grant Amounts, (2) Expenditure, and Division A, Title 

XII of the Recovery Act] 


Yes No N/A 

6. 

Did the grantee submit all of its HPRP quarterly reports by the deadline in 

this review period? 

[HPRP Notice – Section VI. Reporting Requirements (C) Performance 

Reports, (2)(b), and Division A, Section 1512 of the Recovery Act] 


Yes No N/A 

04/2010 8-2




Guide for Review of HPRP-Assisted Housing 



Name(s) of 


Date 








Instructions: This Exhibit is designed to review the housing assistance provided, including 

meeting habitability standards. Follow guidance on program participant file sampling in Section 

8-3.C in the introductory text to this Chapter as well as Section 2-7.C in Chapter 2 of this 

Handbook. This same sample of files can also be used for Exhibit 8-3, “Guide for Review of 

HPRP Financial Assistance and Housing Relocation and Stabilization Services.” 

Questions: 

1. 

Do the records indicate that rental assistance paid for the unit(s) does not 

exceed actual rental cost and that the actual rental cost(s) is/are in 

compliance with HUD’s standard for rent reasonableness? 

[HPRP Notice – Section IV. Requirements for Funding (A) Eligible 

Activities (1) Financial Assistance (a) Rental Assistance (4)] 


Yes No N/A 

2. 

When HPRP funds were used to assist program participants with financial 

assistance in a unit into which they were moving, is there evidence that the 

units were inspected prior to occupancy and that the habitability standards 

were met? 

[HPRP Notice – Section VII. Other Federal Requirements (C) Habitability 

Standards and HPRP Notice – Appendix C] 


Yes No N/A 

8-1 04/2010


Homelessness Prevention and Rapid Re-housing Program 

3. 

Does the grantee have a written termination policy and provide a formal 

process that recognizes the rights of individuals receiving assistance to due 

process of law? 

[HPRP Notice – Section V. Post-Award Process Requirements (E) 

Termination of Housing Assistance] 


Yes No N/A 

4. 

If program participants have been terminated from receiving housing 

assistance, does a review of their files reveal that the minimum due process 

requirements for termination were followed? 

[HPRP Notice – Section V. Post-Award Process Requirements (E) 

Termination of Housing Assistance] 


Yes No N/A 

04/2010 8-2




Guide for Review of HPRP Financial Assistance and 

Housing Relocation and Stabilization Services 


Project: 

Name(s) of 


Program Year: 

Date 








Instructions: This Exhibit is designed to assess the grantee’s performance in providing the 

homelessness prevention assistance or rapid re-housing assistance activities related to Financial 

Assistance and Housing Relocation and Stabilization Services. In order to ensure a good mix of 

activities for review, select both completed and underway activities. The instructions for sample 

program participant file selection are included in Section 8-3.C in the introductory text to this 

Chapter. The same files randomly selected and used for this Exhibit can also be used to complete 

Exhibit 8-2, “Guide for Review of HPRP-Assisted Housing,” and Exhibit 8-4, “Guide for 

Review of Program Participants.” 

Questions: 

1. 

Do the program participants’ files indicate that HPRP assistance has been 

limited to a maximum of 18 months of rental assistance, 18 months of 

utilities assistance and 18 months of supportive services for each program 

participant reviewed? 

[HPRP Notice - Section IV. Requirements for Funding (A) Eligible 

Activities (1) Financial Assistance and (2) Housing Relocation and 

Stabilization Services] 


Yes No N/A 

2. 

If HPRP funds were used to pay rental and/or utility arrears, was that 

assistance limited to six months for each type? 


Activities (1)Financial Assistance (a) Rental Assistance (3)] 


Yes No N/A 

8-1 04/2010



3. 

If HPRP funds were used to pay rental/utility arrears, were the number of 

months of arrears assistance included within the 18-month limitation of 

assistance? 




Yes No N/A 

4. 

Do the program participant records indicate that participants who are 

receiving rental assistance are evaluated and certified for eligibility every 

three months? 


Activities (1) Financial Assistance (a) Rental Assistance (1), and (D) 

Eligible Program Participants] 


Yes No N/A 

5. 

Do the program participants’ files document the delivery of HPRP-eligible 

financial assistance and supportive services? 


Activities] 


Yes No N/A 

6. 

For program participants receiving motel or hotel vouchers, do their files 

document the lack of appropriate shelter beds available to house the 

individual or homeless family, that a subsequent residence was identified 

before placing the program participant into the motel or hotel, and that the 

voucher assistance did not exceed 30 days? (Note: If a domestic violence 

provider serves the program participant, it is not required that a subsequent 

residence be identified before placement of the household in a motel or 

hotel.) 


Activities (1) Financial Assistance (e) Motel and Hotel Vouchers] 


Yes No N/A 

04/2010 8-2



7. 

For participants receiving moving assistance, is there evidence that the 

moving costs were reasonable and, if storage fees were paid, that they were 

limited to no more than three months? 


Activities (1) Financial Assistance (d) Moving cost assistance] 


Yes No N/A 

8. 

For participants receiving legal assistance, is there evidence that the legal 

services were only used to help people stay in their homes and did not 

involve any mortgage-related issues? 


Activities (2) Housing Relocation and Stabilization Services (d) Legal 

Services] 


Yes No N/A 

9. 

Is there evidence in the participants’ files to indicate that the participants are 

not also receiving another federal, state or local housing subsidy for the 

same HPRP cost type and period of time? 




Yes No N/A 

10. 

Is there evidence that no HPRP funds are being used for operating costs or 

to assist persons residing in transitional housing? 


Activities (1) Financial Assistance (a) Rental Assistance (1), (5)] 


Yes No N/A 

11. 

Is there a process in place to ensure that payments for financial assistance 

were made only to third parties? 


Activities (1) Financial Assistance] 


Yes No N/A 

8-3 04/2010




Guide for Review of HPRP Program Participants 



Name(s) of 


Date 








Instructions: This review is mandatory for all HPRP programs. This Exhibit is designed to 

review the eligibility documentation that the grantee or subgrantees collected and evaluated to 

determine whether or not the program participants meet all of the eligibility criteria upon entry in 

the HPRP program. HUD reviewers should: 

• Request a listing of program participants (current and past), including their entry dates, 

from the selected programs. 

• Choose randomly from this list and then request the selected program participant files to 

complete your review. 

File selection should represent a cross-section of each homelessness prevention assistance and/or 

rapid re-housing assistance activity identified in the approved Consolidated Plan’s Annual 

Action Plan HPRP Substantial Amendment, the Integrated Disbursement and Information 

System (IDIS) completion screens, and the Homeless Management Information System (HMIS). 

Additional guidance regarding File Selection and Sampling can be found in Section 8-3.C in the 

introductory text to this Chapter. Files selected for this review may concurrently be used to 

answer questions in Exhibit 8-2, “Guide for Review of HPRP-Assisted Housing,” and Exhibit 8- 

3, “Guide for Review of HPRP Financial Assistance and Housing Relocation and Stabilization 

Services.” 

Questions: 

1. 

Does a review of the selected program participant files reveal adequate 

documentation that the individuals or families had at least one initial 

consultation with a case manager or other authorized representative who 

Yes No N/A 

determined the appropriate type of assistance to meet their needs prior to 

being accepted into the program? 

[HPRP Notice – Section IV. Requirements for Funding (D) Eligible 

Program Participants (2) Requirements for all Program Participants (1)] 


8-1 04/2010



2. 

Does a review of the program participant files reveal adequate 

documentation that all individuals or families served are at or below 50 

percent of the Area Median Income (AMI) upon entry into the program? 

[HPRP Notice – Section IV. Requirements for Funding (D). Eligible 



Yes No N/A 

3. 

Does a review of the program participant files reveal adequate 

documentation that the individuals or families were either homeless or at 

risk of losing their housing and were (1) without appropriate subsequent 

housing options and (2) without financial resources and support networks 

needed to obtain immediate housing or remain in its existing housing? 

[HPRP Notice – Section IV. Requirements for Funding (D) Eligible 



Yes No N/A 

04/2010 8-2



Guide for Review of HPRP Subgrantee Management 



Program Year: 

Name(s) of 


Date 


(statute, regulation, Consolidated Plan/IDIS, or grant agreement). If the requirement is not met, 

HUD must make a finding of noncompliance. All other questions (questions that do not contain 

the citation for the requirement) do not address requirements, but are included to assist the 

reviewer in understanding the participant's program more fully and/or to identify issues that, if 

not properly addressed, could result in deficient performance. Negative conclusions to these 

questions may result in a "concern" being raised, but not a "finding." 

Instructions: This Exhibit is designed to review the HPRP grantee’s management and oversight 

of its subgrantees. It is separated into two sections (Subgrantee Program Management and 

Subgrantee Financial Management). HUD reviewers should select a sample of subgrantees for a 

program year following the instructions for sampling in Section 8-3.C of the introductory text to 

this Chapter. The information in the file documentation, supplemented with grantee and 

subgrantee staff interviews, is to be used to answer the questions below. If the monitoring is onsite 

and time and resources permit, HUD reviewers should supplement this review with on-site 

subgrantee visits. 

Questions: 

A. SUBGRANTEE PROGRAM MANAGEMENT 

1. 

Did the grantee select subgrantees in accordance with 24 CFR part 85, and 

the grantee’s plan for distribution, administration, and oversight of funds 

identified in its Substantial Amendment to the Consolidated Plan 2008 

Action Plan for HPRP? 

[HPRP Notice – Section V. Post-Award Process Requirements (F) 

Responsibility for Grant Administration, Section VII. Other Federal 

Requirements (G) Uniform Administrative Requirements, and 24 CFR 

85.37] 


Yes No N/A 

8-1 04/2010



2. 

Has the grantee executed written agreements with subgrantees to carry out 

the activities proposed in the grantee’s approved Substantial Amendment to 

the Consolidated Plan 2008 Annual Action Plan for HPRP? 


Responsibility for Grant Administration, (I) Monitoring, Section VII. Other 

Federal Requirements (G) Uniform Administrative Requirements, and 24 

CFR 85.37] 


Yes No N/A 

3. 

Does a review of the subgrantee written agreements show that the 

agreements contain sufficient information regarding the subgrantees’ 

assigned HPRP activities to enable the grantee to conduct effective 

compliance monitoring reviews? 


Responsibility for Grant Administration (I) Monitoring, Section VII. Other 


CFR 85.40(a)] 


Yes No N/A 

4. 

Does the grantee have procedures in place to monitor the subgrantees’ 

submission of information required for the Quarterly and Annual 

Performance Reports? 


Responsibility for Grant Administration, (I) Monitoring, and Section VI. 

Reporting Requirements (C) Performance Reports] 


Yes No N/A 

5. 

Is there evidence that the grantee has procedures in place for ensuring that 

their subgrantees are compliant with the HPRP confidentiality requirements 

for participants? 

[HPRP Notice – Section V. Post-Award Process Requirements (D) 

Confidentiality, (F) Responsibility for Grant Administration] 


Yes No N/A 

04/2010 8-2



6. 

If the grantee conducts risk assessments of its subgrantees, is there evidence 

to show that the grantee performs compliance monitoring reviews in 

accordance with the risk assessment results? (If the grantee does not 

conduct a risk assessment, provide a brief narrative regarding its monitoring 

selection procedures.) 

[HPRP Notice – Section V. Post-Award Process Requirements (I) 

Monitoring, Section VII. Other Federal Requirements (G) Uniform 

Administrative Requirements, and 24 CFR 85.40(a)] 


Yes No N/A 

7. 

If monitoring discloses subgrantee deficiencies, does the grantee take 

appropriate and necessary follow-up actions to ensure that corrective actions 

are taken by its subgrantees? 

[HPRP Notice – Section V. Post-Award Process Requirements (I) 

Monitoring, Section VII. Other Federal Requirements (G) Uniform 

Administrative Requirements, and 24 CFR 85.40] 


Yes No N/A 

8. 

Does the grantee have a method for verifying the accuracy and 

confidentiality of the participants’ data in the Continuum of Care (CoC) 

HMIS system or other centralized intake system, and other documents 

maintained by the subgrantees? 

[HPRP Notice – Section V. Post-Award Process Requirements (D) 

Confidentiality (F) Responsibility for Grant Administration, (I) Monitoring, 

Section VII. Other Federal Requirements (G) Uniform Administrative 

Requirements, and 24 CFR 85.40(a)] 


Yes No N/A 

9. 

Does the grantee have a method for verifying that participant data is being 

submitted into the CoC HMIS system or other centralized intake system? 


Responsibility for Grant Administration, (I) Monitoring, Section VI. 

Reporting Requirements (B) HMIS and Section VII. Other Federal 

Requirements (G) Uniform Administrative Requirements, 24 CFR 85.40(a)] 


Yes No N/A 

8-3 04/2010



B. SUBGRANTEE FINANCIAL MANAGEMENT 

10. 

As a condition for reimbursement of HPRP expenses to subgrantees, does 

the grantee require, and receive, documentation from its subgrantees 

sufficient to ensure that payments are for eligible, actual and incurred 

expenditures? 


Responsibility for Grant Administration, Section VII. Other Federal 

Requirements (G) Uniform Administrative Requirements, 24 CFR 84.5, 

84.21, 85.20 and 24 CFR 85.37] 


Yes No N/A 

11. 

Does the grantee have procedures for determining subgrantee compliance 

with applicable program regulations regarding record retention and fiscal 

management requirements? 



Federal Requirements (G) Uniform Administrative Requirements, 24 CFR 

84.5, 84.21, 84.53, 85.20, 85.40(a), and 85.42] 


Yes No N/A 

12. 

Does the grantee have a tracking system or other method of documenting 

the need for, and actual submission of, subgrantee audits required under 

OMB Circular A-133? 




84.5, 84.26, 85.26, 85.40(a)] 


Yes No N/A 

04/2010 8-4



13. 

Does the grantee have a tracking system or other method of documenting 

subgrantee compliance regarding procurement and/or subcontracting 

requirements? (If the response is “NO,” this may warrant further review 

using Exhibit 9-10 of this Handbook as a guide.) 




84.5, 84.40-84.48, 85.36, 85.40(a)] 


Yes No N/A 

14. 

Does the grantee ensure that subgrantees maintain adequate records for 

property and assets acquired with grant funds? (If response is NO, this may 

warrant further review using Exhibit 9-11 of this Handbook as a guide.) 




84.5, 84.34(f), 85.32(d), 85.40(a) ] 


Yes No N/A 

15. 

Is there evidence that the grantee has safeguards for preventing loss, 

damage, or theft of subgrantee-held property? 




84.5, 84.34(f), 85.32(d), 85.40(a)] 


Yes No N/A 

8-5 04/2010



Guide for Review of HPRP Overall Grant Management 

Name of Program Participant: 


Name(s) of 


Date 


(statute, regulation, NOFA, or grant agreement). If the requirement is not met, HUD must make 

a finding of noncompliance. All other questions (questions that do not contain the citation for 

the requirement) do not address requirements, but are included to assist the reviewer in 




Instructions: This Exhibit is designed to evaluate the Homelessness Prevention and Rapid Re- 

Housing Program (HPRP) grantee’s management systems and HPRP administration. HUD 

reviewers should select a sample of files and records, as appropriate, following the sampling 

instructions in Section 8-3.C in the introductory text to this Chapter. A combination of the 

information in the file documentation and program participant staff interviews is to be used to 

answer the questions below. 

Questions: 

1. 

Does the grantee have a management plan or standard operating procedures 

(SOP) for ensuring that HPRP funds are used in accordance with all 

program requirements? 


Yes No N/A 

2. 

Are the duties for administrative personnel defined by job descriptions that 

reflect eligible HPRP administrative costs? 


Activities (4) Administrative Costs] 


Yes No N/A 

8-1 04/2010



3. 

Does a review of costs reveal that staff who are paid with HPRP funds are 

working on HPRP activities? 

[HPRP Notice – Section VII. Other Federal Requirements (G) Uniform 

Administrative Requirements, and 24 CFR 85.20, 85.22, and OMB Circular 

A-87, Attachment B(8)] 


Yes No N/A 

4. 

Are there procedures in place to ensure that the grantee is in compliance 

with the conflict of interest requirements of the HPRP Notice? 

[HPRP Notice – Section VII. Other Federal Requirements (A) Conflicts of 

Interest] 


Yes No N/A 

5. 

Does the file documentation reviewed indicate disbursements of HPRP 

funds only for carrying out activities eligible under the four categories 

(financial assistance, housing relocation and stabilization services, data 

collection and evaluation, and administrative costs)? 


Activities, Section VII. Other Federal Requirements (G) Uniform 

Administrative Requirements and 24 CFR 85.20] 


Yes No N/A 

6. 

Has the grantee shared a reasonable and appropriate amount of 

administrative funds with its subgrantees? 


Activities (4) Administrative Costs (d) Sharing of administrative funds] 


Yes No N/A 

04/2010 8-2



7. 

Does a review of expenditures indicate that no more than 5 percent of the 

total HPRP grant funds have been expended for eligible HPRP 

administrative costs? 


Activities (4) Administrative Costs (c) Limitations on administrative costs] 


Yes No N/A 

8. 

Are all pre-award costs limited to reasonable travel and accommodations for 

HUD-approved training and costs related to preparing the substantial 

amendment for submission to HUD? 


Activities (4) Administrative Costs (b) Pre-award administrative costs] 


Yes No N/A 

9. 

Are all funds used for the provision of financial assistance and services 

allocated to those activity types and not to the HPRP administrative budget 

line item? 




Yes No N/A 

10. 

If there have been changes made to the grantee’s HPRP budget, were the 

budget changes made in compliance with the Consolidated Plan Substantial 

Amendment process requirements? 


Responsibility for Grant Administration, 24 CFR 91.505] 


Yes No N/A 

8-3 04/2010



Guide for Review of HPRP Financial Management 



Name(s) of 


Date 








Instructions: This Exhibit is designed to assess an HPRP grantee’s financial management 

system as well as the eligibility of HPRP expenditures. While the bases for the requirements in 

this Exhibit are rooted in 24 CFR 84 and 24 CFR 85, not all of the requirements of, and 

allowable items under, these regulations apply to the HPRP program. Specifically, all 

expenditures for the HPRP program must be limited to those that require disbursement to third 

parties. The HUD reviewer should follow the sampling instructions in Section 8-3.C in the 

introductory text to this Chapter and randomly select a sample of the grantee’s financial 

transactions, assessing the supporting documentation to complete responses for the following 

questions. 

Questions: 

1. 

Does the grantee have written procedures covering the recording of 

transactions, an accounting manual and a chart of accounts? (If so, the 

reviewer may want to attach a copy to this Exhibit, if feasible.) 

[HPRP Notice - Section VII. Other Federal Requirements (G) Uniform 

Administrative Requirements, and 24 CFR Part 85.20] 


Yes No N/A 

2. 

Does the grantee have written procedures covering the authority for 

approving financial transactions? 




Yes No N/A 

8-1 04/2010


Homelessness Prevention and Rapid Re-Housing (HPRP) Program 

3. 

If the grantee has written procedures, does it provide guidelines for 

controlling expenditures, such as purchasing requirements and travel 

authorizations? 




Yes No N/A 

4. 

Does the grantee have written procedures regarding the maintenance of 

financial records? 

[HPRP Notice - Section VII. Other Federal Requirements, (G) Uniform 

Administrative Requirements, and 24 CFR Part 85.20, 85.42] 


Yes No N/A 

5. 

Are the grantee’s fiscal records and valuables secured in a limited-access 

area? 




Yes No N/A 

6. 

If the grantee has an interest-bearing account, is there evidence that, if the 

account earned interest on grant advances, all but $100 for eligible 

administrative costs were remitted to HUD at least quarterly? 


Administrative Requirements, and 24 CFR 85.21(h)(2)(i)] 


Yes No N/A 

04/2010 8-2



7. 

Does the grantee identify expenditures in its accounting records to eligible 

activities identified in the grantee’s Substantial Amendment for HPRP and 

the Integrated Disbursement and Information System (IDIS) activity 

information? 


Activities, (B) Ineligible and Prohibited Activities, Section VII. Other 


CFR Part 85.20] 


Yes No N/A 

8. 

Do the financial records indicate that the grantee has effective internal 

control over, and accountability of, all grant funds, property and other 

assets? 




Yes No N/A 

9. 

Does a review of the sample transactions indicate that grant expenditures 

were eligible costs? 


Activities, (B) Ineligible and Prohibited Activities] 


Yes No N/A 

10. 

Are the financial transactions drawn for this review supported by adequate 

source documentation, (e.g. invoices, contracts, purchase orders, remittance 

advice)? 




Yes No N/A 

8-3 04/2010



11. 

Are there internal controls, such as segregation of duties, that effectively 

reduce the opportunity for an individual to perpetrate or conceal errors or 

irregularities in financial transactions and in the course of normal duties? 


Yes No N/A 

12. 

a. Do charges to the HPRP program for salaries and wages based on 

supporting documentation appear allowable? 


Activities, Section VII. Other Federal Requirements (G) Uniform 

Administrative Requirements, 24 CFR 85.22, and OMB Circular A-87, 

Attachment B(8)(h)] 


Yes No N/A 

b. For employees working solely on the HPRP program, are charges for 

their salaries and wages supported by periodic certifications that the 

employees worked solely on that program for the period covered by the 

certification? 



Attachment B(8)(h)(3)] 


Yes No N/A 

c. Were the certifications prepared at least semi-annually and signed by the 

employee or a supervisory official having first-hand knowledge of the 

work performed by the employee? 



Attachment B(8)(h)(3)] 


Yes No N/A 

04/2010 8-4



13. 

Are payments for employee salaries supported by timesheets indicating 

actual times, not percentages, and in accordance with the applicable 

regulations? 



Attachment B(8)(h)] 


Yes No N/A 

14. 

If salaries are being paid from more than one source, do the fiscal records 

clearly define payments among the funding sources? 


Administrative Requirements, and 24 CFR 85.20] 


Yes No N/A 

15. 

Do the grantee financial records indicate that no cash payments were 

provided directly to the program participants? 


Activities (1) Financial Assistance and (B) Ineligible and Prohibited 

Activities] 


Yes No N/A 

16. 

Does a random selection of costs reflect that no disbursement of any grant 

funds were expended for ineligible HPRP activities? 


Activities and (B) Ineligible and Prohibited Activities] 


Yes No N/A 

8-5 04/2010



17. 

Does the IDIS withdrawal information match the information from the 

grantee’s draw-down voucher requests? 

[HPRP Notice - Section V. Post-Award Process Requirements (B) Method 

of Payment] 


Yes No N/A 

18. 

a. Are OMB Circular A-133 Single Audits required for any grantees or 

subgrantees? 


Administrative Requirements, 24 CFR 85.26] 


Yes No N/A 

b. If the answer to “a” above is “yes,” does the grantee have a system or 

methodology to ensure that such audits are conducted? 




Yes No N/A 

c. If A-133 audits are required for any subgrantees, does the grantee have 

documentation that the audits have been reviewed for compliance with 

OMB Circular A-133 and that appropriate follow-up actions have been 

taken, if necessary? 




Yes No N/A 

04/2010 8-6



19. 

a. Does the grantee have the appropriate written procedures and financial 

management systems in place? 


Administrative Requirements, 24 CFR 85.20, 85.21] 


Yes No N/A 

b. If the grantee requests funds in advance, does the grantee minimize the 

time elapsed between the transfer of funds and their disbursement by the 

grantee or subgrantee? 

[24 CFR 85.21] 


Yes No N/A 

c. If the grantee has elected to use a working capital advance, has it 

demonstrated that it cannot meet the criteria for advance payments 

described in 24 CFR 85.21, and has HUD determined that reimbursement 

is not feasible because the grantee lacks sufficient capital? 

[24 CFR 85.21] 


Yes No N/A 

d. Is the grantee meeting all other requirements of 24 CFR Part 85.20 and 

85.21? 


Administrative Requirements, 24 CFR 85.20; 24 CFR 85.21] 


Yes No N/A 

8-7 04/2010




Guide for Review of HPRP Cost Allowability 


Name(s) of 


Date 


(statute, notice, Consolidated Plan/IDIS/HMIS, or grant agreement). If the requirement is not 

met, HUD must make a finding of noncompliance. All other questions (questions that do not 

contain the citation for the requirement) do not address requirements, but are included to assist 

the reviewer in understanding the participant's program more fully and/or to identify issues that, 

if not properly addressed, could result in deficient performance. Negative conclusions to these 

questions may result in a "concern" being raised, but not a "finding." 

Instructions: This Exhibit is designed to review the grantee's allocation of cost to verify that its 

procedures fully comply with the requirements of OMB Circular A-87 and 24 CFR §85.22. 

Along with conducting staff interviews, HUD reviewers should select sample documentation 

following the instructions for sampling in Section 8-3.C in the introductory text to this Chapter to 

answer Exhibit questions. 

Questions: 

1. 

Does a sample of cost items reveal that salaries and related costs were 

allowable for the HPRP program? 



Attachment B(8), (13), (19), (32)] 


Yes No N/A 

2. 

Does a sample of cost items show that HPRP funds were not used for costs 

associated with ineligible or prohibited activities? 


Activities, (B) Ineligible and Prohibited Activities (2), (3)] 


Yes No N/A 

8-1 04/2010



3. 

Does a review of program expenditures indicate the absence of any 

unallowable costs as itemized in OMB Circular A-87, Attachment B, 

including entertainment, contributions and donations, fines and penalties, or 

general governmental expenditures including salary and expenses of the 

chief executive officer of the grantee? 



Attachment B] 


Yes No N/A 

4. 

Are costs charged to the HPRP program after subtraction of all applicable 

credits as a cost reduction or cash refund, as applicable? 



Attachment A(C)(1),4, (D)(1)] 


Yes No N/A 

5. 

Are costs charged to the HPRP program not allocable to or included as a 

cost of any other Federally financed program during the period under 

review? 



Attachment A(C)(1), (3)] 


Yes No N/A 

6. 

Have all HPRP administrative costs subject to the 5 percent limitation been 

properly classified? 




Yes No N/A 

04/2010 8-2



Guide for Review of HPRP Other Federal Requirements 



Name(s) of 

Date 



(statute, regulation, NOFA, or grant agreement). Note, however, that certain questions in this 

Exhibit reference reviews conducted using Exhibits elsewhere in this Handbook. If a 

requirement is not met, HUD must make a finding of noncompliance. Where responses to 

questions for this Exhibit are based on other Exhibit reviews, the conclusions should be noted 

here, as applicable. Other questions (questions that do not contain the citation for the 





Instructions: This Exhibit is designed to evaluate the HPRP grantee’s compliance with other 

applicable Federal requirements. It is divided into 4 sections: Drug-Free Workplace; Lobbying 

Restrictions; Compliance with Non-Discrimination, Section 504 of the Rehabilitation Act of 

1973, and Other Equal Opportunity Requirements; and Lead Hazard Abatement Requirements. 

Note, however, that the Davis-Bacon prevailing wage requirements do not apply to the HPRP 

program. In addition, activities associated with the Uniform Relocation Assistance and Real 

Property Acquisition Policies Act of 1970 (acquisition, rehabilitation, demolition, displacement 

or relocation) are ineligible HPRP activities. Pursuant to 24 CFR 50.19(b)(3), (11), and (12), all 

HPRP eligible activities are categorically excluded from assessment under the National 

Environmental Policy Act of 1969 (42 U.S.C. 4321) and are not subject to environmental review 

under the related laws and authorities. 

For certain requirements, a reference is made to other Exhibits or Chapters in this Handbook. If 

other Exhibits are used to monitor these areas, only the conclusion(s) should be noted here with a 

cross-reference to the supporting Exhibit. If the requirement does not pertain to the HPRP 

grantee, mark “N/A.” If the area is not covered during this monitoring, write under the applicable 

“Describe Basis for Conclusion” box: “Not covered due to ______ (provide reason).” If 

compliance monitoring for the areas below has been conducted in the past 12 months, under 

either the HPRP or other HUD programs, it is not necessary to review these areas again unless the 

last risk analysis results or subsequent information raise questions or concerns. 

Questions: 

A. DRUG-FREE WORKPLACE 

1. 

Does the HPRP grantee have a drug-free workplace statement per the 

requirements of 24 CFR 21.200? 

[HPRP Notice - Section VII. Other Federal Requirements (J) Drug-Free 

Workplace Requirements, 24 CFR 21.200] 


Yes No N/A 

8-1 04/2010



2. 

If the requirements of the Drug-Free Workplace actions were monitored, is 

the HPRP grantee in compliance? 

[HPRP Notice - Section VII. Other Federal Requirements (J) Drug-Free 

Workplace Requirements, 24 CFR part 21] 


Yes No N/A 

B. LOBBYING RESTRICTIONS 

3. 

a. Does the HPRP grantee conduct lobbying? 


Yes 

No 

b. If the answer to “a” above is “yes,” has the grantee correctly filed a 

certification and disclosure form? 

[HPRP Notice - Section VII. Other Federal Requirements (I) Lobbying 

and Disclosure Requirements, 24 CFR part 87] 


Yes No N/A 

C. COMPLIANCE WITH NON-DISCRIMINATION, SECTION 504 OF THE 

REHABILITATION ACT OF 1973, AND OTHER EQUAL OPPORTUNITY 

REQUIREMENTS 

4. 

If this area was reviewed, was the HPRP grantee determined to be in 

compliance with other applicable requirements? (Use pertinent Exhibits in 

Chapter 22 , such as Exhibit 22-5, and note conclusions below.) 

[HPRP Notice - Section VII. Other Federal Requirements (D) 

Nondiscrimination and Equal Opportunity Requirements] 


Yes No N/A 

04/2010 8-2



D. LEAD HAZARD ABATEMENT REQUIREMENTS 

5. 

For all HPRP-rental assisted units constructed before 1978 where a pregnant 

woman or a family with a child under the age of six years was identified, 

was a visual assessment for lead-based paint conducted? 

[HPRP Notice - Section VII. Other Federal Requirements (F) Lead-Based 

Paint Requirements, 24 CFR 35.1215(a)] 


Yes No N/A 

6. 

For all HPRP-rental assisted units constructed before 1978 where a pregnant 

woman or a family with a child under the age of six years was identified and 

where lead-based paint was identified, were the proper regulations followed 

for abatement? 

[HPRP Notice - Section VII. Other Federal Requirements (F) Lead-Based 

Paint Requirements, 24 CFR part 35, subparts A, B, M, and R] 


Yes No N/A 

8-3 04/2010


NSP-1 Program 


Name of 

Program Participant: 


Activity Name, Number and Brief Description: 

Name(s) of 

Reviewer(s): 

Date 

Limited Review 

In-depth Review 








Instructions: Use this Exhibit for a review of the program participant’s Neighborhood 

Stabilization Program 1 (NSP-1) program progress. One Exhibit is to be completed for each 

Program Participant. This Exhibit is divided into six sections: NSP-Specific Financial 

Management; Purchase and Resale of Properties; Initial Successor – Tenant’s Rights 

Documentation; Demolition and NSP-Eligible Uses; Program Income; and Summary. It is to be 

used in conjunction with the applicable exhibits that are contained in the following chapters of this 

Handbook: Chapter 3, Community Development Block Grant (CDBG) Entitlement, Small Cities, 

Nonentitlement CDBG Grants in Hawaii, and Insular Areas Programs; Chapter 4, State 

Community Development Block Grant (CDBG) Program; Chapter 21, Environmental Monitoring; 

Chapter 23, Labor Standards Administration; Chapter 24, Lead-Based Paint Compliance; Chapter 

25, Relocation and Real Property Acquisition; and other chapters with its accompanying exhibits 

that the reviewer believes are necessary in ensuring grantee compliance. It is important to note that 

the NSP falls under the same guidelines as the regular CDBG program, with some additional 

requirements, thresholds, and tests that are unique to its program design, as outlined in the “Notice 

of Allocations, Applications Procedures, Regulatory Waivers Granted to and Alternative 

Requirements for Emergency Assistance for Redevelopment of Abandoned and Foreclosed Homes 

Grantees Under the Housing and Economic Recovery Act, 2008” (73 Fed. Reg. 58330, October 6, 

2008), and the “Notice of Allocations, Application Procedures, Regulatory Waivers Granted to and 

Alternative Requirements for Emergency Assistance for Redevelopment of Abandoned and 

Foreclosed Homes Grantees Under the Housing and Economic Recovery Act, 2008; Revisions to 

Neighborhood Stabilization Program (NSP) and Technical Corrections” (74 Fed. Reg. 29223, June 

19, 2009). 

Questions: 

A. NSP- SPECIFIC FINANCIAL MANAGEMENT 

1. 

Does the program participant have any pre-award costs that have been 

reimbursed by NSP administration and planning funds? 

[73 Fed. Reg. 58335, II.C] 


Yes No N/A 

8-1 04/2010


NSP-1 Program 

2. 

Have the administrative costs occurred after 09/29/08 (Secretary signed, 

effective start date of NSP) and are these costs eligible? 

[73 Fed. Reg. 58335, II.C] 


Yes No N/A 

3. 

a. Does the program participant have any pre-award project specific costs 

that have been reimbursed by NSP funds? 

[73 Fed. Reg. 58335, II.C] 


Yes No N/A 

b. If the answer to “a” above is “yes,” have the activity-specific costs 

occurred after the NSP plan was received by HUD and an environmental 

release was received, or the responsible entity has determined that the 

cost is exempt from environmental review or is categorically excluded 

from NEPA review and not subject to review under related 

environmental authorities, and are these costs eligible? 

[73 Fed. Reg. 58335, II.C] 


Yes No N/A 

4. 

a. Has the program participant made any audits or on-site reviews of 

subrecipients? 

(NOTE: Applies to both State and Entitlement grantees.) 

[73 Fed. Reg. 58335, II.G.1] 


Yes No N/A 

b. If the answer to “a” above is “yes,” have there been any compliance 

issues that have arisen and are these compliance issues documented 

accordingly? 

[73 Fed. Reg. 58335, II.G.1] 


Yes No N/A 

04/2010 8-2


NSP-1 Program 

5. 

Has the program participant stayed within the 10 percent limitation, on the 

grant as a whole, for general administration, technical assistance, and 

planning activities (for the duration of the grant, which is 4 years from when 

HUD signed the grant agreement)? 

[73 Fed. Reg. 58335, II.H.4] 


Yes No N/A 

6. 

Has the program participant stayed within this same 10 percent limitation 

for all program income that was earned (for the duration of the grant, which 

is 4 years from when HUD signed the grant agreement)? 

[73 Fed. Reg. 58335, II.H.4] 


Yes No N/A 

7. 

Is the program participant on track with meeting the 18-month NSP funds 

use requirement? 

(NOTE: For the statutory 18-month use period, “accounting records and 

DRGR information must reflect outlays (expenditures) and unliquidated 

obligations for approved activities that, in the aggregate, are at least equal 

to the NSP allocation.” The DRGR system collects information on 

expenditures and obligations.) 

[73 Fed. Reg. 58340, II.M.1] 


Yes No N/A 

8. 

Is the program participant on track with meeting the 4-year original 

allocation expenditure deadline? 

[73 Fed. Reg. 58335, II.M.2] 


Yes No N/A 

8-3 04/2010


NSP-1 Program 

9. 

Is the program participant meeting the requirement that “not less than 25 

percent of any NSP grant shall be used for the purchase and redevelopment 

of abandoned or foreclosed homes or residential properties that will be used 

to house individuals or families whose incomes do not exceed 50 percent of 

area median income?” 

[73 Fed. Reg. 58336, II.E.2. as amended at 74 Fed. Reg. 29225] 


Yes No N/A 

10. 

If the program participant has received a reallocation of funds (excluding 

program income), is it on track with meeting the 25 percent requirement 

for those at or below 50 percent LMI housing set-aside, as described in 

question 9 above? 

[73 Fed. Reg. 58336, II.E.2. as amended at 74 Fed. Reg. 29225] 


Yes No N/A 

B. PURCHASE AND RESALE OF PROPERTIES 

11. 

Has the program participant purchased its properties with a minimum of a 

1 percent per property discount, from the current market appraised value? 

(NOTE: “The current market appraised value means the value of a 

foreclosed upon home or residential property that is established through an 

appraisal made in conformity with the appraisal requirements of the URA 

at 49 CFR 24.103 and completed within 60 days prior to an offer made for 

the property by a grantee, subrecipient, developer, or individual 

homebuyer; provided, however, if the anticipated value of the proposed 

acquisition is estimated at $25,000 or less, the current market appraised 

value of the property may be established by a valuation of the property that 

is based on a review of available data and is made by a person the grantee 

determines is qualified to make the valuation.”) 

[73 Fed. Reg. 58342, II.Q.1. and 3. as amended at 74 Fed. Reg. 29225] 


Yes No N/A 

04/2010 8-4


NSP-1 Program 

12. 

Has the program participant “provide[d] NSP funds to another party to 

finance an acquisition of tax foreclosed (or any other) properties from itself, 

other than to pay necessary and reasonable costs related to the appraisal and 

transfer of title”? 

[73 Fed. Reg. 58342, II.Q.2. as amended at 74 Fed. Reg. 29225] 


Yes No N/A 

13. 

Has the program participant paid “necessary and reasonable costs related 

to the appraisal and transfer of title” on any properties it owns, while being 

“conveyed to a subrecipient, homebuyer, developer, or other jurisdiction?” 

(NOTE: If these costs have been paid with NSP funds, “the property is 

NSP-assisted and subject to all program requirements, such as 

requirements for NSP-eligible use and benefit to income-qualified 

persons.”) 

[73 Fed. Reg. 58342, II.Q.2. as amended at 74 Fed. Reg. 29225] 


Yes No N/A 

14. 

Has the program participant ensured that homes or residential properties 

that have been sold to an individual as a primary residence is “in an 

amount equal to or less than the cost to acquire and redevelop or 

rehabilitate such home or property up to a decent, safe, and habitable 

condition”? (Sales and closing costs are eligible NSP redevelopment or 

rehabilitation costs.) 

(NOTE: “[T]he maximum sales price for a property is determined by 

aggregating all costs of acquisition, rehabilitation, and redevelopment 

(including related activity delivery costs, which generally may include, 

among other items, costs related to the sale of the property.”) 

[73 Fed. Reg. 58338-9, II.J.1. and 2. as amended at 74 Fed. Reg. 29228] 


Yes No N/A 

8-5 04/2010


NSP-1 Program 

C. INITIAL SUCCESSOR – TENANT’S RIGHTS DOCUMENTATION 

15. 

Has the program participant “document[ed] its efforts to ensure that the 

initial successor in interest in a foreclosed upon dwelling or residential real 

property (typically, the initial successor in interest in property acquired 

through foreclosure is the lender or trustee for holders of obligations 

secured by mortgage liens) has provided bona fide tenants with the notice 

and other protections outlined in the Recovery Act”? (NOTE: Bona fide 

tenants must be given a 90-day notice to vacate.) 

[73 Fed. Reg. 58339, K. as amended at 74 Fed. Reg. 29226, E] 


Yes No N/A 

16. 

a. Has the program participant been involved in the purchase of a 

property involving bona fide tenants? 

(NOTE: “Grantees are cautioned that NSP funds may not be used to 

finance the acquisition of property from the initial successor in interest 

that failed to comply with applicable requirements unless it assumes the 

obligations of such initial successor in interest with respect to bona fide 

tenants. Grantees who elect to assume such obligations are reminded 

that tenants displaced as a result of the NSP funded acquisition are 

entitled to the benefits outlined in 24 CFR 570.606, Section K, 

Acquisition and Relocation, on page 58339 of the October 6, 2008 

notice as amended by…” the June 19, 2009 notice.) 

Yes No N/A 



b. If the answer to “a” above is “yes,” has a 90-day notice to vacate 

been provided to bona fide tenants that were either under a lease 

that was signed before the notice, or without a lease, or a lease 

that is terminable at will under State law? 

(NOTE: Either of these two circumstances may apply – 1. “Under any 

bona fide lease entered into before the notice of foreclosure to occupy 

the premises until the end of the remaining terms of the lease, except 

Yes No N/A 

04/2010 8-6


NSP-1 Program 

that a successor in interest may terminate a lease effective on the date 

of sale of the unit to a purchaser who will occupy the unit as a primary 

residence, subject to the receipt of the 90-day notice;” 2. “[W]ithout a 

lease or with a lease that is terminable at will under the State law, 

subject to the receipt by the tenant of the 90-day notice… except that 

nothing … shall affect the requirements for termination of any Federalor 

State- subsidized tenancy or of any State or local law that provides 

longer time periods or other additional protections for tenants.”) 



c. If the answer to “a” above is “yes,” is the bona fide tenant “a 

recipient of assistance under section 8 of the United States 

Housing act of 1937 (42 U.S.C. 1437f) (the ”Section 8 

Program”) resid[ing] at the time of foreclosure?” 

(NOTE: “[T]he initial successor to the lease and to the housing 

assistance payments contract for the occupied unit.” See: 

74 Fed. Reg. 29226, E.2.b., for the details involving “Section 8 

Program” tenants.) 



Yes No N/A 

D. DEMOLITION AND NSP-ELIGIBLE USES 

17. 

a. Does the program participant have any activities covered under NSPeligible 

uses (D) or (E), where demolition is involved? 

[73 Fed. Reg. 58338, Table as amended at 74 Fed. Reg. 29228] 


Yes No N/A 

8-7 04/2010


NSP-1 Program 

b. If the answer to “a” above is “yes,” has the program participant 

determined an end use for all demolished properties, as appropriate for 

the national objective? 

[73 Fed. Reg. 58338, II.H.1-3. as amended at 74 Fed. Reg. 29228] 


Yes No N/A 

18. 

Has the program participant only carried out activities that are in 

conjunction with the NSP-eligible uses and correlated eligible activities 

from the CDBG entitlement regulations table that is found in the Jun 19, 

2009 notice? 

[73 Fed. Reg. 58338, II.H. as amended at 74 Fed. Reg. 29227-8] 


Yes No N/A 

19. 

Has the program participant applied for, received, and carried out any 

activities covered under an official waiver? 

[73 Fed. Reg. 58338, II.H. as amended at 74 Fed. Reg. 29227-8] 


Yes No N/A 

E. PROGRAM INCOME 

20. 

a. Is the program participant expecting to, or has received, any program 

income from any of its NSP-assisted activities? 

NOTE: “Revenue (i.e., gross income) received by a state, unit of general 

local government, or subrecipient (as defined at 24 CFR 570.500(c)) that 

is directly generated from the use of CDBG funds (which term includes 

NSP grant funds) constitutes CDBG program income. To ensure 

consistency of treatment of such program income, the definition of 

program income at 24 CFR 570.500(a) shall be applied to amounts 

received by states, units of general local government, and subrecipients.” 

[73 Fed. Reg. 58340, N. as amended at 74 Fed. Reg. 29224-5] 


Yes No N/A 

04/2010 8-8


NSP-1 Program 

b. If the answer to “a” above is “yes,” has “all program income…be[en] 

disbursed for eligible NSP activities before additional cash 

withdrawals…[were] made from the U.S. Treasury? 



Yes No N/A 

c. If the answer to “a” above is “yes,” has the program participant 

“incorporate[d] in subrecipient agreements such provision as are 

necessary to ensure compliance with the…[NSP program income] 

requirements?” 



Yes No N/A 

21. 

F. SUMMARY 

If the responses to any of the questions in this Exhibit indicate a need to go to another 

section of this Handbook for questions, or seek technical assistance or advice from another 

HUD staff person, please describe below. 


8-9 04/2010


NSP-1 Program 

Guide for Review of NSP-1 National Objective of 

Benefit to Low-, Moderate-, and Middle-Income Persons 




Name(s) of 


Date 










Instructions: Use this Exhibit for a review of compliance with the Neighborhood Stabilization 

Program (NSP) National Objective of Benefit to Low-, Moderate-, and Middle-Income Persons. 

One Exhibit is to be completed for each Program Participant. This Exhibit is to be used in 

conjunction with the following Exhibits which are located in Chapter 3 of this Handbook: 

• CDBG Entitlement Program 

o Exhibit 3-2: Guide for Review of National Objective of Low- and Moderate- 

Income Area Benefit 


Income Limited Clientele 


Income Housing 

• State CDBG Program 

o Exhibit 4-1: Guide for Review of Eligibility and National Objective 

It is important to note that the definition of “low- and moderate-income” under the regular 

CDBG program has been redefined and superseded by NSP to include those with incomes up to 

120% of area median income. As defined by the Notice of Allocations, Application Procedures, 

Regulatory Waivers Granted to, and Alternative Requirements for, Emergency Assistance for 

Redevelopment of Abandoned and Foreclosed Homes Grantees Under the Housing and 

Economic Recovery Act, 2008; Revisions to Neighborhood Stabilization Program (NSP) and 

Technical Corrections [74 Fed. Reg. 29227]. 

“To prevent confusion, HUD will refer to this new income group as “middle income,” and 

keep the regular CDBG definitions of “low income” and “moderate income” in use. Further, 

HUD will characterize aggregated households whose incomes do not exceed 120 percent of 

median income as “low-, moderate-, and middle-income households,” abbreviated as 

LMMH. For the purpose of NSP only, an activity may meet the HERA low-, and moderatenational 

objective if the assisted activity: 

8-1 04/2010


NSP-1 Program 

• Provides or improves permanent residential structures that will be occupied by a 

household whose income is at or below 120 percent of area median income 

(abbreviated LMMH). 

• Serves an area in which at least 51 percent of the residents have income at or below 

120 percent of area median income (LMMA); or 

• Serves a limited clientele whose incomes are at or below 120 percent of area 

median income (LMMC).” 

Therefore, the NSP definition of income encompasses low-, moderate-, and middle-income. 

Nevertheless, the requirement for meeting this National Objective is the same for NSP as it is 

for the regular CDBG program. After completing this Exhibit, complete the appropriate CDBG 

Exhibit in Chapters 3 or 4, keeping in mind the applicable income definition. 

Questions: 

1. 

Applying the NSP income requirements at 73 Fed. Reg. 58335, E. as amended at 74 Fed. 

Reg. 29227, complete the applicable Exhibit(s) referenced in the instructions above as a basis 

for answering this question: 

a. Is the program participant carrying out any activities that benefit Low-, 

Moderate-, and Middle-Income Households (LMMH)? 

Yes No N/A 

b. Is the program participant carrying out any activities that benefit Low-, 

Moderate-, and Middle-Income Area (LMMA)? 

c. Is the program participant carrying out any activities that benefit Low-, 

Moderate-, and Middle-Income Clientele (LMMC)? 


Yes No N/A 

Yes No N/A 

2. 

a. Did the original “NSP Action Plan substantial amendment include… an 

activity that addressed the HERA low- and moderate-income national 

objective requirement on the basis of job creation or retention”? 

[73 Fed. Reg. 58335, E. as amended at 74 Fed. Reg. 29227] 


Yes No N/A 

b. If the answer to “a” above is “yes,” were the funds obligated before 

publication of the June 19, 2009, Notice? 



Yes No N/A 

04/2010 8-2


NSP-1 Program 

c. If the answer to “b” above is “yes,” is there evidence that the activity is 

“designed to create or retain permanent jobs and at least 51 percent of 

the jobs will be held by or made available to persons whose incomes are 

at or below 120 percent median income”? 

(NOTE: The ability to carry out LMMJ-based activities was cancelled 

by the June 19, 2009, Notice. For program participants that had such 

activities in their initial NSP Substantial Amendment, it is important to 

note that the “activity may be completed provided” the funds were 

obligated prior to the publication of the June 19, 2009, Notice and the 

activity meets the requirement of low-, moderate-, middle-income jobs, 

as described in the original NSP notice dated 10/06/08.) 



Yes No N/A 

d. If the answer to “a” above is “no,” has the program participant 

“submit[ted] an amendment that includes one or more new activities 

(cannot be LMMJ-based) that comply with the NSP income eligibility 

requirements”? 



Yes No N/A 

3. 

After completion of this Exhibit, complete the appropriate CDBG National Objective Exhibit 

in either Chapter 3 or 4. If the responses to any of the questions in this Exhibit indicate a 

need to seek technical assistance or advice from another HUD staff person, please describe 

below. 


8-3 04/2010


NSP-1 Program 

Guide for Review of NSP-1 Cooperative Agreements 




Members of Cooperative Agreement: 

Lead Entity: 

Name(s) of 


Date 










Instructions: Use this Exhibit for a review for compliance with the Neighborhood Stabilization 

Program (NSP) Cooperative Agreements requirements. One Exhibit is to be completed for each 

program participant. It is important to note that under the regular CDBG program, cooperative 

agreements are allowed and will continue to be allowed under NSP-1. If a program participant 

has an existing cooperative agreement that governs FY 2008 CDBG funds, it will be considered 

to incorporate NSP funds, as amended appropriately. 

Questions: 

1. 

For the questions below, note that “[t]hese cooperation agreements will continue to apply to 

the use of NSP funds for the duration of the NSP grant, just as a cooperation agreements 

covering regular CDBG Entitlement program funds continue to apply to any use of the 

funds appropriated during the 3-year period covered by the agreements.” 

a. Is the cooperative agreement between “two or more contiguous 

entitlement communities (metropolitan cities or counties) that are in 

the same metropolitan area and that are eligible to receive an NSP 

Yes No N/A 

grant?” 

[73 Fed. Reg. 58332 and 58334, II.B.5.a] 

b. Is the cooperative agreement between an “entitlement community that 

is eligible to receive an NSP allocation… with its state?” 

[73 Fed. Reg. 58332 and 58334, II.B.5.b] 

Yes No N/A 

8-1 04/2010


NSP-1 Program 

c. Is there an existing cooperative agreement “between a local 

government and an urban county governing FY2008 CDBG funding 

(for purposes of either an urban county or a joint or a joint program)?” 

[73 Fed. Reg. 58332 and 58334, II.B.6] 


Yes No N/A 

2. 

Is there evidence that the lead entity is maintaining its responsibility for 

managing the NSP-1 grant (by ensuring compliance with grant 

requirements, overseeing the reporting, etc.)? 

[73 Fed. Reg. 58332 and 58334, II.B.5.a. and b] 


Yes No N/A 

3. 

a. Will the existing cooperative agreement expire prior to the expiration of 

the NSP-1 grant agreement (three years from the date signed)? 

[73 Fed. Reg. 58332 and 58334, II.B. and II.B.6] 


Yes No N/A 

b. If the answer to “a” above is “yes,” does the lead entity have a plan or 

policy in place that outlines the cooperative partners’ responsibilities 

until the expiration of the NSP-1 grant? 

[73 Fed. Reg. 58332 and 58334, II.B. and II.B.6] 


Yes No N/A 

4. 

a. Has the program participant applied for its “entire grant, and then 

enter[ed] into a subrecipient agreement with another jurisdiction or 

nonprofit entity to administer the grant?” 

(NOTE: “In this manner for example, all of the grantees operating in a 

single metropolitan area could designate the same land-bank entity (or 

the state housing finance agency) as a subrecipient for some or all of their 

NSP activities.”) 

[73 Fed. Reg. 58332, II.B] 


Yes No N/A 

04/2010 8-2


NSP-1 Program 

b. If the answer to “a” above is “yes,” is the program participant properly 

managing the subrecipient according to their agreement and the NSP-1 

requirements? 

[73 Fed. Reg. 58332, II.B] 


Yes No N/A 

5. 

If the responses to any of the questions in this Exhibit indicate a need to go to another section 

of this Handbook for questions, or seek technical assistance or advice from another HUD 

staff person, please describe below. 


8-3 04/2010


NSP-1 Program 

Guide for Review of NSP-1 State Requirements 




Amount of Funding Allocated: 

Name(s) 


Date 










Instructions: Use this Exhibit for a review for compliance of the Neighborhood Stabilization 

Program (NSP) State requirements. One Exhibit is to be completed for each Program 

Participant. It is coupled with Chapter 4 of the Monitoring Handbook, which is designed to look 

specifically at the State CDBG Program. However, it is important to note that, under the regular 

CDBG program, states may not directly use funds, but must distribute them to units of general 

local government. Under NSP, states are allowed to either use the “method of distribution” or 

act like entitlement grantees by carrying out projects themselves, or use a mixture of the two 

methods. 

Questions: 

1. 

Has the State been the recipient of the balance of another jurisdiction’s grant 

amount (pursuant to 73 Fed. Reg. 58332, II.B)? 

Yes No N/A 


2. 

Has the State entered into a cooperative agreement (pursuant to 73 Fed. 

Reg. 58332, II.B; 58334, II.B.5.b)? 

(NOTE: If the answer to this question is “yes,” Exhibit 8-12, Guide for 

Review of Cooperative Agreement, should also be completed.) 


Yes No N/A 

8-1 04/2010


NSP-1 Program 

3. 

Has the State received a reallocation of grant funds (pursuant to 73 Fed. 

Reg. 58333, II.E)? 


Yes No N/A 

4. 

a. Is the State making a grant within a regular CDBG Entitlement area? 

[73 Fed. Reg. 58336, II.F] 


Yes No N/A 

b. If the answer to “a” above is “yes,” is there evidence that the 

State included citizens of the local jurisdiction in its citizen participation 

process? 

[73 Fed. Reg. 58334, II.B.4] 


Yes No N/A 

c. If the answer to “a” above is “yes,” is there evidence that the 

State utilized “the area median income levels applicable to its regular 

CDBG program geography and not the “balance of state” levels? 

[73 Fed. Reg. 58336, II.E] 


Yes No N/A 

d. If the answer to “a” above is “yes,” is there evidence that the 

State “develop[ed] and ma[d]e public its definition of affordable rents 

for NSP-assisted rental projects” in the applicable regular CDBG 

program geography? 

[73 Fed. Reg. 58336, II.E.2.c] 


Yes No N/A 

04/2010 8-2


NSP-1 Program 

5. 

Is the State “distribut[ing] funds to or within any jurisdiction within the 

state that is among those with the greatest need, even if the jurisdiction is 

among those receiving a direct formula allocation of funds from HUD 

under the regular CDBG program or… [the NSP] notice?” 

(NOTE: “[T]he state is required to distribute funds without regard to a local 

government status under any other CDBG program and must use funds in 

entitlement jurisdictions if they are identified as areas of greatest need, 

regardless of whether the entitlement receive its own NSP allocation.”) 

[73 Fed. Reg. 58336, II.F] 


Yes No N/A 

6. 

a. Is the State a recipient of only the minimum allocation of 0.5 percent 

($19.6 million) of the amount specified in Section 2301 of the Housing 

and Economic Recovery Act (HERA) of 2008 (Sec. 2302 of HERA, 

Pub. L. 110-289, July 30, 2008; and 75 Fed. Reg. 18230, II.B)? 

[NOTE: Only “affects the following states: Alaska, Arkansas, Delaware, 

Hawaii, Idaho, Maine, Montana, North Dakota, Nebraska, New 

Hampshire, New Mexico, Oregon, Puerto Rico, Rhode Island, South 

Dakota, Utah, Vermont, West Virginia, and Wyoming.”] 


Yes No N/A 

b. If the answer to “a” above is “yes,” has the State completed and 

submitted to the HUD Field Office a substantial amendment that 

contains all of the information as outlined in Section (III)(3) of the April 

9, 2010, Federal Register notice , therefore demonstrating to HUD that 

It has fulfilled all of the requirements in Section 2301(c)(2) if 

HERA? 

(NOTE: In order for the State to implement Public Law 111-22, it must 

complete a substantial amendment to its NSP-1 plan. The Federal 

Register notice provides an outline of all necessary components that 

need to be included in the substantial amendment in order to 

demonstrate its fulfillment of the requirements in section 2301(c)(2) of 

HERA. The substantial amendment needs to be submitted to the HUD 

Field Office, though it does not need to be approved by HUD.) 

[Sec. 2301(c)(2) of HERA, Pub. L. 110-289, July 30, 2008; Section 105 

of the Helping Families Save Their Homes Act (HFSHA), Pub. L. 111- 

22, May 20, 2009; and 75 Fed Reg. 18230, III.3.] 


Yes No N/A 

8-3 04/2010


NSP-1 Program 

c. If the answer to “b” above is “yes,” is there evidence that the 

State is following the substantial amendment that was submitted to HUD 

that allows it to “re-program NSP funds to additional areas with 

homeowners at risk of foreclosure or in foreclosure without regards to 

the percentage of home foreclosures in such areas” (75 Fed. Reg. 18230, 

II.B.)? 

[Section 105 of the Helping Families Save Their Homes Act (HFSHA), 

Pub. L. 111-22, May 20, 2009; and 75 Fed Reg. 18230, III.3.] 


Yes No N/A 

7. 

Is the state using the “method of distribution” program model (pursuant to 

73 Fed. Reg. 58336, II.G)? 


Yes No N/A 

8. 

a. Is the state “carry[ing] out NSP activities directly for some or all of its 

assisted grant activities, just as CDBG entitlement communities do 

under 24 CFR 570.200(f), including, but not limited to, carrying out 

activities using its own employees, procuring contractors, private 

developers, and providing loans and grants through nonprofit 

subrecipients (including local governments and other public nonprofits 

such as regional or local planning or development authorities and public 

housing authorities)” (pursuant to 73 Fed. Reg. 58336-7, II.G)? 

(NOTE: “HUD is granting regulatory waivers of State CDBG 

regulations to conform the applicable management, real property change 

of use, and recordkeeping rules when a state chooses to carry out 

activities as if it were an entitlement community.”) 


Yes No N/A 

04/2010 8-4

. If the answer to “a” above is “yes,” is there evidence that the 

State is reviewing projects and “establishing remedies for 

noncompliance”? 


NSP-1 Program 

(NOTE: “24 CFR 570.492 is waived and the following alternative 

requirement applies: The state shall make reviews and audits, including 

on-site reviews of any subrecipients, designated public agencies, and 

units of general local government as may be necessary or appropriate to 

meet the requirements of 42 U.S.C. 5304(e)(2), as amended, as modified 

by th[e]… [NSP] notice.”) 

[73 Fed. Reg. 58337, II.G.1] 


Yes No N/A 

c. If the answer to “a” above is “yes,” is there evidence that the 

State has implemented the change of use of real property waiver in the 

projects it carries out directly? 

(NOTE: “For the purposes of this program, in 24 CFR 570.489(j), (j)(1), 

and the last sentence of (j)(2), “unit of general local government” shall 

read as “unit of general local government or state.”) 

[73 Fed. Reg. 58337, II.G.2] 


Yes No N/A 

d. If the answer to “a” above is “yes,” is there evidence that the 

State has adopted an appropriate recordkeeping method? 

(NOTE: Regarding 24 CFR 570.490(b): “The state shall establish and 

maintain such records as may be necessary to facilitate review and audit 

by HUD of the state’s administration of NSP funds under 24 CFR 

570.493. Consistent with applicable statues, regulations, waivers, and 

alternative requirements, and other federal requirements, the content of 

records maintained by the state shall be sufficient to: (1) Enable HUD to 

make the applicable determinations described at 24 CFR 570.493; (2) 

make compliance determinations for activities carried out directly by the 

state; and (3) show how activities funded are consistent with the 

descriptions of activities proposed for funding in the action plan. For 

fair housing and equal opportunity purposes, and as applicable, such 

records shall include data on the racial, ethnic, and gender 

characteristics of persons who are applicants for, participants in, or 

beneficiaries of the program.”) 

[73 Fed. Reg. 58337, II.G.3] 


Yes No N/A 

8-5 04/2010


NSP-1 Program 

e. If the answer to “a” above is “yes,” is there evidence that the 

State is in compliance with its certifications? 

(NOTE: “HUD is applying the regulations at 24 CFR 570.480(c) with 

respect to the basis for HUD determining whether the state has failed to 

carry out its certifications, so that such basis shall be that the state has 

failed to carry out its certifications in compliance with applicable 

program requirements.”) 

[73 Fed. Reg. 58337, II.G.4] 


Yes No N/A 

f. If the answer to “a” above is “yes,” is there evidence that the 

State, “[a]ccording to the environmental regulations at 24 CFR 58.4… 

submit[ted]… [its] certification and request for release of funds to HUD 

for Approval”? 

(NOTE: “Usually, a state… takes on HUD’s role receiving 

environmental certifications from the grant recipients and approving 

releases of funds.”) 

[73 Fed. Reg. 58337, II.G.5] 


Yes No N/A 

15. 





04/2010 8-6


NSP-1 Program 

Guide for Review of NSP-1 Continued Affordability 




Name(s) of 


Date 











Program (NSP) Continued Affordability requirements. It is divided into three sections: 

Homebuyer Programs; Rental Programs; and Summary. One Exhibit is to be completed for each 

Program Participant. It is important to note that under regular CDBG, “Continued Affordability” 

is not a recognized term. Under the requirements at 24 CFR 570.505, Use of Real Property, the 

subrecipient must maintain the identified use of the property from the time CDBG funds are first 

spent until at least five years after closeout of the grant from which the assistance to the property 

was provided. Nevertheless, the NSP Continued Affordability requirement resembles both the 

aforementioned CDBG use of real property regulation and the HOME Investment Partnership 

Program’s periods of affordability requirements at 24 CFR 92.252(a), (c), (e), and (f), and 

92.254. For the NSP program, continued affordability is defined as follows: 

“Grantees shall ensure, to the maximum extent practicable and for the longest feasible 

term, that the sale, rental, or redevelopment of abandoned and foreclosed-upon homes 

and residential properties under this section remain affordable to individuals or families 

whose incomes do not exceed 120 percent of area median income or, for units originally 

assisted with funds under the requirements of section 2301(f)(3)(A)(ii) [of HERA], 

remain affordable to individuals and families whose incomes do not exceed 50 percent 

of area median income.” [73 Fed. Reg. 58334, II.B.3] 

Questions: 

A. HOMEBUYER PROGRAMS 

1. 

Has the program participant implemented the same continued affordability 

mechanism(s) that it identified in its substantial amendment? 

[73 Fed. Reg. 58334, II.B.3] 


Yes No N/A 

8-1 04/2010


NSP-1 Program 

2. 

Is the mechanism being enforced appropriately, in that the program 

participant is demonstrating compliance with its own requirements? 

[73 Fed. Reg. 58334, II.B.3] 


Yes No N/A 

3. 

Does the mechanism remain effective throughout the continued affordability 

period? 


Yes No N/A 

4. 

Does the program participant have a monitoring plan or policy in place for 

the continued affordability mechanism(s) and has it been implemented? 

[73 Fed. Reg. 58334, II.B.3] 


Yes No N/A 

5. 

Has the program participant documented the individual property file with its 

continued affordability mechanism? 

[73 Fed. Reg. 58334, II.B.3] 


Yes No N/A 

B. RENTAL PROGRAMS 

6. 

Has the program participant implemented the same affordable rents 

definition that was included in its substantial amendment? 

[73 Fed. Reg. 58334, II.B.3] 


Yes No N/A 

04/2010 8-2


NSP-1 Program 

7. 

Has the program participant “ma[d]e public its definition of affordable rents 

for NSP-assisted rental projects”? 

[73 Fed. Reg. 58336, II.E.2.c] 


Yes No N/A 

8. 

Has the program participant established an enforcement mechanism to 

maintain the affordable rent on individual properties/units? 

[73 Fed. Reg. 58334, II.B.3] 


Yes No N/A 

9. 

Is the affordable rents mechanism being implemented and enforced 

appropriately, in that the program participant is demonstrating compliance 

with its own requirements? 

[73 Fed. Reg. 58334, II.B.3] 


Yes No N/A 

10. 

a. Does the program participant have a monitoring plan or policy in place 

for the implementation and enforcement of affordable rents? 

[73 Fed. Reg. 58334, II.B.3] 


Yes No N/A 

b. If the answer to “a” above is “yes,” is the program participant following 

its own monitoring plan or policy? 

[73 Fed. Reg. 58334, II.B.3] 


Yes No N/A 

8-3 04/2010


NSP-1 Program 

11. 

Has the program participant documented affordable rents on the individual 

property/occupant file? 

[73 Fed. Reg. 58334, II.B.3] 


Yes No N/A 

12. 

Overall, does the program participant have in place effective enforcement 

and monitoring mechanisms to guarantee continued affordability and/or 

affordable rents for the duration of the affordability period? 


Yes No N/A 

13. 

C. SUMMARY 





04/2010 8-4


NSP-1 Program 

Guide for Review of NSP-1 Eligible Use C: Establish Land Banks 




Name(s) of 


Date 











Program (NSP) “Eligible Use C: Establish Land Banks.” One Exhibit is to be completed for 

each Program Participant. This Exhibit is designed to look specifically at a project carried out by 

a land bank. It is important to note that, under the regular CDBG program, land banking is not 

an eligible activity. Nevertheless, the requirement for property acquisition compliance is the 

same for NSP as it is for regular CDBG. That is, the end use of the property must meet one of 

the national objectives of the program. For the NSP program, a land bank is defined as: 

“a governmental or nongovernmental nonprofit entity established, at least in part, to assemble, 

temporarily manage, and dispose of vacant land for the purpose of stabilizing neighborhoods and 

encouraging re-use or redevelopment of urban property. For the purposes of NSP, a land bank will 

operate in a specific, defined geographic area. It will purchase properties that have been foreclosed 

upon and maintain, assemble, facilitate redevelopment of, market, and dispose of the land-banked 

properties. If the land bank is a governmental entity, it may also maintain foreclosed property that 

it does not own, provided it charges the owner of the property the full cost of the service or places a 

lien on the property for the full cost of the service.” [74 Fed. Reg. 29224] 

Questions: 

1. 

Has the program participant carried out activities identified as Eligible Use 

C: “Establish and operate land banks for homes and residential properties 

that have been foreclosed upon,” as defined under the Neighborhood 

Stabilization Program? 

[73 Fed. Reg. 58335-6, II.E. and 58338, II.H. Table as amended at 74 Fed. 

Reg. 29228] 


Yes No N/A 

8-1 04/2010


NSP-1 Program 

2. 

Is the Land Bank operating within the defined LMMA service area 

(following the area benefit regulations described in 24 CFR 570.208(a)(1) 

and 570.483(b)(1)) that was submitted by the program participant with the 

substantial amendment? 

[73 Fed. Reg. 58335, II.E] 


Yes No N/A 

3. 

Is the Land Bank only carrying out acquisition activities? 

[73 Fed. Reg. 58336, 58338, II.E. and II.H] 


Yes No N/A 

4. 

a. Is the Land Bank carrying out activities beyond acquisition, with the 

“inten[tion]… [of] arrest[ing] neighborhood decline, such as 

maintenance, demolition, and facilitating redevelopment of the 

properties?” 

[73 Fed. Reg. 58336, II.E] 


Yes No N/A 

b. If the answer to “a” above is “yes,” is the Land Bank “provid[ing] 

sufficient benefit… [as defined by the program participant to the service 

area referenced in question 2] generally (as described in 24 CFR 

570.208(a)(1) and 570.483(b)(1)) to meet a national objective 

(LMMA)?” 

[73 Fed. Reg. 58336, II.E] 


Yes No N/A 

5. 

Are these activities being carried out, or have been carried out, “prior to 

final disposition of the banked property?” 

[73 Fed. Reg. 58336, II.E] 


Yes No N/A 

04/2010 8-2


NSP-1 Program 

6. 

Does the Land Bank maintain a separate file for each property, documenting 

the purchase and any other relevant items (such as the appraisal, 

environmental review, etc.)? 

[73 Fed. Reg. 58338, II.H] 


Yes No N/A 

7. 

Does the documentation show that the Land Bank used these funds to 

purchase homes that are vacant, and/or have been abandoned or foreclosed 

upon? 

[73 Fed. Reg. 58338, II.H] 


Yes No N/A 

8. 

a. Does the Land Bank have an established plan to either dispose of the 

properties or “obligat[e] the property for a specific, eligible 

redevelopment of… [the] property in accordance with NSP 

requirements,” within the 10-year time frame? 

[73 Fed. Reg. 58335, II.E.2.d] 


Yes No N/A 

b. If the answer to “a’” above is “yes,” is the Land Bank meeting (or has it 

met) this goal? 

[73 Fed. Reg. 58335, II.E.2.d] 


Yes No N/A 

9. 

Does the Land Bank have a written and established management system that 

they are implementing? 


Yes No N/A 

8-3 04/2010


NSP-1 Program 

10. 

a. Is it anticipated that the Land Bank will generate any program income? 


Yes No N/A 

b. If the answer to “a” above is “yes,” has the Land Bank set up a system 

for tracking the use and reuse of program income funds? 


Yes No N/A 

11. 





04/2010 8-4


NSP-1 Program 

Guide for Review of NSP-1 Fair Housing and Equal Opportunity Requirements 




Name(s) of 


Date 











Program (NSP) Fair Housing and Equal Opportunity (FHEO) requirements. This Exhibit is 

divided into five sections: Limited English Proficiency; Homebuyer Counseling; Homebuyer 

Mortgage; Affirmatively Furthering Fair Housing; and Summary. One Exhibit is to be used for 

each program participant. After completing this Exhibit, complete, from Chapter 22 of this 

Handbook, either Exhibit 22-1, Guide for Review of Civil Rights-Related Program Requirements 

for the Community Development Block Grant (CDBG) Entitlement Program, or Exhibit 22-2, 

Guide for Review of Civil Rights-Related Program Requirements for the State Community 

Development Block Grant (CDBG) Program. 

Questions: 

A. LIMITED ENGLISH PROFICIENCY (LEP) 

1. 

Does the program participant have any Limited English Proficiency (LEP) 

speaking populations within its area(s) of greatest needs? 


Yes No N/A 

2. 

Has the program participant evaluated its LEP Implementation Plan, to 

ensure that it includes any LEP populations that are within its area(s) of 

greatest needs? 

[73 Fed. Reg. 58333, II.B] 


Yes No N/A 

8-1 04/2010


NSP-1 Program 

3. 

Has the program participant ensured meaningful access to Neighborhood 

Stabilization Program (NSP) information, by providing it in the appropriate 

language for all English-speaking and LEP populations? 

[73 Fed. Reg. 58333, II.B] 


Yes No N/A 

4. 

If the program participant is a state, have all geographic areas been 

examined and meaningful access to information given for all LEP-speaking 

populations, even when it is in a regular CDBG entitlement jurisdiction? 

[73 Fed. Reg. 58333, II.B] 


Yes No N/A 

B. HOMEBUYER COUNSELING 

5. 

Does the program participant have a list of HUD-approved counseling 

agencies that it uses to deliver homebuyer counseling (pursuant to 73 Fed. 

Reg. 58334, II.B.3.b)? 


Yes No N/A 

6. 

Has the program participant applied for a waiver to the homebuyer 

counseling requirement? 

[73 Fed. Reg. 58334, II.B.3.b. as amended at 74 Fed. Reg. 29226-7] 


Yes No N/A 

7. 

Has the program participant ensured that each homebuyer has obtained at 

least “8 hours of homebuyer counseling from a HUD-approved housing 

counseling agency before obtaining a mortgage loan?” 



Yes No N/A 

04/2010 8-2


NSP-1 Program 

8. 

Has the program participant “document[ed] compliance in the records for 

each homebuyer?” 



Yes No N/A 

C. HOMEBUYER MORTGAGE 

9. 

Has the program participant “ensure[d] that the homebuyer[s] obtain[ed] a 

mortgage loan from a lender who agrees to comply with the bank 

regulators’ guidance for non-traditional mortgages?” 

(NOTE 1: “(S)ee Statement on Subprime Mortgage Lending issued by the 

Office of the Comptroller of the Currency, Board of Governors of the 

Federal Reserve System, Federal Deposit Insurance Corporation, 

Department of the Treasury, and National Credit Union Administration, 

available at http://www.fdic.gov/regulations/laws/rules/5000-5160.html”; 

NOTE 2: “Grantees are cautioned against providing or permitting 

homebuyers to obtain subprime mortgages for whom such mortgages are 

inappropriate, including homebuyers who qualify for traditional mortgage 

loans.”) 



Yes No N/A 

10. 

Has the program participant “document[ed] compliance in the records for 

each homebuyer?” 



Yes No N/A 

8-3 04/2010


NSP-1 Program 

D. AFFIRMATIVELY FURTHERING FAIR HOUSING 

11. 

In order to Affirmatively Further Fair Housing, “HUD… [has] encourage[d] 

each grantee to review its analysis to impediments to fair housing choice to 

determine whether an update is necessary because of current market 

conditions or other factors.” Has the program participant done so (pursuant 

to 73 Fed. Reg. 58342, II.S)? 


Yes No N/A 

12. 

E. SUMMARY 





04/2010 8-4


NSP-2 Program 





Name(s) of 


Date 










Instructions: Use this Exhibit for a review of compliance with program progress for the 

Neighborhood Stabilization Program 2 (NSP-2). This Exhibit is divided into six sections: NSP-2 

Specific Financial Management; “Buy American” Requirement; Returning of Units to the 

Market; NSP-2 Eligible Uses; Consortium; and Summary. One Exhibit is to be completed for 

each Program Participant. This Exhibit is to be used in conjunction with the applicable exhibits 

that are contained in the following chapters of this Handbook: Chapter 3, Community 

Development Block Grant (CDBG) Entitlement, Small Cities, Non Entitlement CDBG Grants in 

Hawaii, and Insular Area Programs; Chapter 4, State Community Development Block Grant 

(CDBG) Program; Chapter 21, Environmental Monitoring; Chapter 22, Fair Housing and Equal 

Opportunity (FHEO); Chapter 23, Labor Standards Administration; Chapter 24, Lead-Based 

Paint Compliance; and Chapter 25, Relocation and Real Property Acquisition, as well as the 

NSP-1 Exhibits 8-10 through 8-16 in this Chapter. It is important to note that the NSP-2 falls 

under the same guidelines as the NSP-1 and the regular CDBG program, with some additional 

requirements, thresholds, and tests that are unique to its program design, as outlined in: 

• the “Notice of Fund Availability (NOFA) for the Neighborhood Stabilization Program 2 

under the American Recovery and Reinvestment Act, 2009;” 

• the 3 NSP-2 NOFA Correction Notices: 

o the “Notice of Fund Availability (NOFA) for Fiscal Year 2009 Neighborhood 

Stabilization Program 2 under the American Recovery and Reinvestment Act of 

2009; Correction” [Docket No. FR-5321-C-02, June 11, 2009]; 



2009; Correction” [Docket No. FR-5321-C-03, November 9, 2009]; and 



2009; Correction” [Docket No. FR-5321-C-04, January 21, 2010]. 

8-1 04/2010


NSP-2 Program 

Questions: 

A. NSP-2 SPECIFIC FINANCIAL MANAGEMENT 

1. 

Is the program participant on track with meeting the expenditure of at least 

50 percent of allocated funds within the 2-years-of-receipt deadline? 

[NOFA; Appendix I: Program Requirements, Paragraph M.1, page 67] 


Yes No N/A 

2. 

Is the program participant on track with meeting the expenditure of at least 

100 percent of allocated funds within the 3-years-of-receipt deadline? 

[NOFA; Appendix I: Program Requirements, Paragraph M.1, page 67] 


Yes No N/A 

3. 

a. Has the program participant “not use[d] more than 10 percent of its grant 

for demolition activities under HERA, Section 2301(c)(3)(C) and (D)”? 

[NOFA; Appendix I: Program Requirements, Paragraph H.3.f, page 59] 


Yes No N/A 

b. If answer to “a” above is “no,” had the program participant requested a 

waiver as part of its NSP-2 application? 

[NOFA; Appendix I: Program Requirements, Paragraph H.3.f, page 59] 


Yes No N/A 

B. “BUY AMERICAN” REQUIREMENT 

4. 

a. Is the program participant complying with Recovery Act’s Buy 

American requirement? 

[NOFA, VI.K and 74 Fed. Reg. 18449] 


Yes No N/A 

b. Has the program participant requested an exception of the Recovery 

Act’s Buy American requirement? 

[NOFA, VI.K and 74 Fed. Reg. 18449] 


Yes No N/A 

04/2010 8-2


NSP-2 Program 

C. RETURNING OF UNITS TO THE MARKET 

5. 

Is the program participant on track to meet the requirement to return at least 

100 units to the market? 

[NOFA, II.B.2] 


Yes No N/A 

D. NSP-2 ELIGIBLE USES 

6. 

Under Eligible Use E, is the program participant only redeveloping 

demolished or vacant properties as housing? 

[NOFA, Appendix I: Program Requirements, H.3] 


Yes No N/A 

E. CONSORTIUM 

7. 

Is the lead applicant “assuming responsibility for the grant on behalf of the 

consortium in compliance with all program requirements,” and taking 

program management steps to ensure compliance, as well as overseeing the 

reporting, monitoring of the consortium members, etc.? 

[NOFA, II.A.5] 


Yes No N/A 

8. 

a. Is the lead applicant a non-profit? 

(NOTE: For nonprofits, 24 CFR 84 is applicable and HUD is required to 

perform the environmental release.) 


Yes No N/A 

8-3 04/2010


NSP-2 Program 

b. If the answer to “a” above is “yes,” is the operating capacity of the nonprofit 

such that assistance from a NSP-TA provider is recommended? 


Yes No N/A 

F. SUMMARY 

9. 





04/2010 8-4


CDBG-R Grant Program 

Guide for Review of CDBG-R Activities 




Amount of Funding Allocated: 

Name(s) of 


Date 










Instructions: Use this Exhibit for a review of compliance with the Community Development 

Block Grant Program Recovery (CDBG-R) requirements under the American Recovery and 

Reinvestment Act (Recovery Act) of 2009. One Exhibit is to be completed for each Program 

Participant. This Exhibit should be combined with Chapters 3 and 4 of this Handbook, which are 

designed to look specifically at the Entitlement and State and Small Cities CDBG Programs, 

respectively. Inasmuch as grantees shall expedite the expenditure of CDBG-R funds, these funds 

are subject to all other requirements of the CDBG program. Therefore, the CDBG monitoring 

Exhibits (including Exhibits 22-1 and 22-2 for fair housing and equal opportunity requirements), 

as appropriate, shall be used when reviewing CDBG-R funded activities. 

Questions: 

1. 

Has the program participant expended CDBG-R funds on any project 

expressly prohibited by the Recovery Act, i.e., any casino or other gambling 

establishment, aquarium, zoo, golf course, or swimming pool? 

[Section 1604 of title XVI of Division A of the Recovery Act, Pub. L. 111- 

5] 


Yes No N/A 

8-1 04/2010


CDBG-R Program 

2. 

a. Is the program participant complying with the Recovery Act’s “Buy 

American” requirement? 

[CDBG-R Notice, II.H.2.c and 74 Fed. Reg. 18449] 


Yes No N/A 

b. Has the program participant requested an exception to the Recovery 

Act’s “Buy American” requirement? 

[CDBG-R Notice, II.H.2.c and 74 Fed. Reg. 18449] 


Yes No N/A 

3. 





04/2010 8-2

CPD Monitoring Handbook 6509.2 Rev-6 - OneCPD

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