Function 1: Identify Procedures for Recording Financial Transactions

AmpliFund Maintenance

• Identify staff responsible for authorizing and disbursing funds and ensuring that funds are not improperly issued.

Financial Information to Collect and Report

• Assessment of the entity’s audited financial statements;
• Financial systems, or written procedures manual for financial management;
• Budget and budget changes;
• Invoices for reimbursement;
• Project closeout documentation;
• Match share amount; and
• Eligible costs.

Function 2: Capture Allowable Activities

Eligible Costs

HUD differentiates between project costs and activity delivery costs. In the context of the Match Program, PCs are the direct costs of undertaking a project that can be tied to a final cost objective and eligible activities. ADCs are the costs incurred directly related to delivery of a specific Match project; these costs are not required to be tied to a specific address but must be tied to the delivery of eligible project costs.

Project Costs

• Environmental Reviews (if completed by developer for review and approval by the Responsible Entity);
• Acquisition costs;
• Construction hard costs;
• Demolition and site clearance;
• Architecture, engineering, and permits, when paid by the beneficiary;
• Developer fees, contractor overhead, and profit; and
• Loans to businesses to assist with repairs.

Activity Delivery Costs

• Environmental Reviews (if completed by Grantee or Subrecipient);
• Development of program policies and procedures necessary to implement the program;
• Duplication of Benefits review and analysis;
• Completing work writeups;
• Conducting underwriting or applicant selection;
• Leased office space for single program operation;
• Equipment and supplies necessary for carrying out eligible activity; and
• Applicant intake/eligibility screening for a specific program that does not result in eligible project or beneficiary.

Function 3: Ensure Compliance

Financial Reporting

Financial reporting prepared by the Subrecipient must be accurate, timely, and current and represent complete disclosure of the financial activity and status of CDBG-DR grants. A Subrecipient must have the capacity to provide the following:

• Amount budgeted;
• Reimbursements received to date;
• Program income and other miscellaneous receipts in the current period and year to-date; and
• Actual expenditures/disbursements in the current period and cumulatively to-date, for both program income and regular CDBG-DR grant funds.

Financial Recordkeeping

Financial records must be retained for at least three years beyond the later of (1) HUD’s closeout of DED’s CDBG-DR grant or (2) DED’s closeout of the Subrecipient’s grant from DED.

Function 1: Identify Procedures for Recording Financial Transactions

AmpliFund Maintenance

• Identify staff responsible for authorizing and disbursing funds and ensuring that funds are not improperly issued.

Financial Information to Collect and Report

Periodic Draws

The obligation of DED to approve any draw request of Program funds is subject to the satisfaction of the following conditions at the time of making such request and such other conditions as outlined in the CDBG-DR Agreement.

• Draws will not be processed if the Owner is in default under the CDBG-DR loan or any other loan the Owner has received for the Project;
• The Project shall not have been materially damaged by fire or other casualty since the date of the award;
• DED shall have received evidence satisfactory to DED that all work and improvements requiring inspection by any governmental authority having jurisdiction have been inspected and approved by such authorities and by any other persons or entities having the right to inspect and approve construction; and
• Owner shall have submitted, at least 30 calendar days prior to the date a disbursement is desired, a completed disbursement request form including AIA G-702 (Contractor’s Application for Payment) and G-703 (Continuation) forms and such other appropriate source documentation as may be required by DED and/or HUD including, without limitation, the following:
  • Current Contractor Tracking Form and lien waivers, which are to be dated no less than 10 business days prior to the date of the submission of the requested disbursement;
  • Evidence satisfactory to DED that the Project and the contemplated use thereof are permitted by and comply with all applicable uses or other restrictions and requirements in prior conveyances, zoning ordinances, or regulations that have been duly approved by the municipal or other governmental authorities having jurisdiction; that the required building permits and other permits have been obtained as required; and that no environmental impact statement is required or that such environmental impact statement has been properly filed and approved;
  • Appropriate certifications of compliance in all respects with labor standards and prevailing wage requirements applicable under Federal law;
  • Such other supporting evidence as may be requested by DED or its agents to substantiate all payments (proof of payment) which are to be made from the relevant disbursement and/or to substantiate all payments then made with respect to the Project, including but not limited to, canceled checks, invoices, and receipts;
  • DED shall have determined that all CDBG-DR requirements pertaining to the disbursement of funds have been met;
  • DED shall have received a current inspection report from a DED inspector (which may include a contracted third-party inspector) that verifies satisfactory completion of work to CDBG-DR standards;
  • DED shall have received a current/updated title endorsement, if required; and
  • No determination shall have been made by DED that the undisbursed amount of the loan is less than the amount necessary to pay all costs and expenses of any kind that reasonably may be anticipated in connection with the completion of the Project.

Final Draw

DED requires the following prior to the final disbursement of funds, the request for which shall not be submitted before completion of the Project, including all landscape requirements and offsite utilities and streets and correction of defects in workmanship and/or materials.

• A certificate of occupancy, if applicable; a certificate of substantial completion from the Project’s architect; the builder’s warranty from the general contractor; and a final approved construction report from DED’s inspector for the Project and other requirements as outlined in the SRA;
• Evidence satisfactory to DED that the Project has been completed lien free and substantially in accordance with the plans and specifications;
• Review and final settlement of the cost certification performed by an independent CPA;
• Such other supporting evidence as may be requested by DED or its agent to substantiate all payments which are to be made from the final disbursement and/or to substantiate all payments then made with respect to the Project;
• Lease-up of all CDBG-DR assisted units, submission of tenant data necessary for DED to complete the Project in HUD’s DRGR system, and DED’s approval of income determinations for assisted tenants; and
• A determination by DED that all CDBG-DR requirements pertaining to the initial development of the Project have been met, including but not limited to, the monitoring of Davis-Bacon compliance, as applicable.

Function 2: Capture Allowable Activities

Eligible Activities: LIHTC

DED will entertain proposals for new construction and acquisition/rehabilitation, including adaptive reuse and historic preservation projects, of multifamily rental developments. This may include awards financing the residential component of mixed-use projects, but mixed-use projects may trigger additional requirements.

The maximum award is $2,000,0000. Consistent with the Action Plan, awards are subject to the following additional restrictions:

• Not to exceed $150,000 per housing unit constructed; and
• The $150,000 award cap for each household includes all hard and soft construction costs.

Eligible Costs: LIHTC

Program funds awarded will only reimburse eligible costs incurred to develop the approved project. No program funds will be advanced to reimburse a project cost unless the Request for Disbursement Form with backup AIA certification, invoices, and receipts are submitted and approved. No funds will be disbursed until all environmental conditions are satisfied and all funding commitments/agreements are signed. To simplify administration and Subrecipient and Successful Applicant compliance, DED is limiting the use of CDBG-DR funding to reimburse specifically for:

• Acquisition of property (including vacant land or existing housing to be rehabilitated);
• Hard costs of construction (or rehabilitation);
• Architectural and engineering costs associated with the design of the Project; and
• Legal and accounting costs associated with the acquisition, financing, and construction of the Project (not including organizational or syndication related legal fees).

Function 3: Ensure Compliance

Drawing Funds

The CDBG-DR award is intended as construction and/or permanent financing. Proceeds of the CDBG-DR loan will only be released for reimbursement of eligible project costs, with supporting documentation for actual costs incurred.

Period of Affordability

For projects under the CDBG-DR/LIHTC gap financing program, then, DED will enforce an Affordability Period of either 15 or 20 years from December 31 of the year in which the project is placed in service (i.e., date of Occupancy). For rehabilitation projects, this will align to the LIHTC compliance period, and for new construction projects, this will run for five (5) years beyond the end of the LIHTC compliance period.

Affirmative Marketing, Tenant Selection, and Leasing

Leases between the tenant and owner shall be for one (1) year, unless by mutual agreement between the tenant and the owner. Owners are required to provide 30-days’ written notice prior to terminating or refusing to renew the lease. Owners are prohibited from including unfair provisions in their leases and the following terms from 24 CFR § 92.253(b) are prohibited from CDBG-DR project leases:

• Agreement to be sued;
• Treatment of personal property;
• Excusing owner from responsibility;
• Waiver of notice;
• Waiver of legal proceedings;
• Waiver of a jury trial;
• Waiver of right to appeal court decision;
• Tenant chargeable with cost of legal actions regardless of outcome; and
• Mandatory participation in supportive services.

In general, the DED anticipates providing a standard form lease addendum for use by owners of CDBG-DR assisted housing that will provide required tenant protections and eliminate any prohibited provisions from leases otherwise used by owners.

Financial Recordkeeping

Financial records must be retained for at least three years beyond the later of (1) HUD’s closeout of DED’s CDBG-DR grant or (2) DED’s closeout of the Subrecipient’s grant from DED.

Function 1: Identify Procedures for Recording Financial Transactions

AmpliFund Maintenance

• Identify staff responsible for authorizing and disbursing funds and ensuring that funds are not improperly issued.

Financial Information to Collect and Report

• Household income;
• Rent limits;
• Project-based rental assistance;
• Three (3) most recent audited annual financial statements (if unavailable, then the three (3) most recent tax returns);
• Operating budget and expenses;
• Identity of interest relationships;
• Other public funding;
• Proposals; and
• Deposits.

Function 2: Capture Allowable Activities

Eligible Activities

If eligible, CDBG-DR funds under this sub-program may be used to fund:

• Construction of rental housing;
• Rehabilitation of rental housing; and
• Land acquisition for eligible construction/rehabilitation activities.

Award Limits

The maximum award is $2,000,0000. Consistent with the Action Plan, awards are subject to the following additional restrictions:

• Not to exceed $150,000 per housing unit constructed; and
• The $150,000 award cap for each household includes all hard and soft construction costs.

Function 3: Ensure Compliance

Underwriting and Subsidy Layering

Project Underwriting

All CDBG-DR applications must include the three (3) most recent audited annual financial statements (if unavailable, then the three (3) most recent tax returns) of the developer(s), ownership entity, guarantors, and Project, if applicable, and will be subject to DED’s evaluation of fiscal soundness. 

Generally, project underwriting will also include the following: 

• A vacancy factor of at least 7% will be used for projects where all units are supported by a project-based rental assistance contract with a term equal to or in excess of the Affordability Period (e.g., project-based Section 8), and at least 8% for all other projects, unless the market study indicates another, more conservative, vacancy factor is needed;
• DED staff will use a maximum 2% inflation factor for all sources of income;
• All operating expenses will be underwritten with an inflation factor of at least 3%;
• All projects must maintain a DCR of at least 1.25 for the Affordability Period or loan term, whichever is longer. Properties with excessive DCRs may have rent increases reduced or denied. An Expense Coverage Ratio will be analyzed for projects with no required debt payments. DED will generally expect underwritten cash flow to equal not less than 8% of the sum of operating expenses, replacement reserve deposits, and hard debt service (as applicable);
• Proposals must include justification of operating costs that includes a comparison to similar projects in the local market (e.g., taking into consideration size, age, configuration, senior/family, and other factors). Developers with REO portfolios that include comparable projects should submit operating cost data for most recent trailing 12-month period;
• Unless otherwise approved by DED, the operating budget of new construction project must include a minimum deposit of $400 per unit per year for family projects or $300 per unit per year for senior projects to the Replacement Reserve. The Replacement Reserve must be funded and maintained for the full Affordability Period or loan term (whichever is longer) and reflected in the operating expenses for the full projection of expenses, as applicable. Replacement Reserve deposits must be inflated at 3% annually. In the case of rehabilitation, the capital needs assessment obtained from a qualified third-party professional acceptable to DED will be used to establish the minimum annual Replacement Reserve deposits, which shall be inflated at 3% annually;
• Projects must include a capitalized operating reserve equal to eight (8) months of underwritten operating expenses, amortizing debt service (if any), and required reserve deposits. If drawn, the operating reserve must be replenished prior to distributions of surplus cash flow. The operating reserve is intended to protect against unplanned operating deficits. If the DED’s underwriting projections anticipate deficits within the applicable Affordability Period, an operating deficit reserve must be capitalized as well;
• To substantiate any historic, or other (i.e., non-LIHTC) tax credit equity pricing, Successful Applicants must submit documentation indicating that a syndicator or investor has reviewed the proposal and indicated preliminary pricing along with their interest in the Project. Prior to closing, DED will review the amended/restated partnership/operating agreement, including detailed pricing and equity pay-in provisions; and
• Successful Applicants must provide the amounts and terms for all project funding sources. Amortizing permanent financing that will be senior to any CDBG-DR loan may not mature prior to the expiration of the CDBG-DR Affordability Period.

Performance Requirements

DED requires submission of a project proforma in the common format (i.e., Microsoft Excel) provided in the DED Application. However, DED may require additional project finance detail prior to closing, including development period and lease-up/stabilization cash flow projections.

If not otherwise itemized, Successful Applicants must be able to separate the hard costs of any stand‐alone accessory buildings, including leasing offices, community buildings, laundry facilities, free‐standing garages or carports, or maintenance buildings.

Cost Limitations

Consistent with DED’s obligations under 2 CFR Part 200, all project costs must be reasonable and necessary whether directly paid with CDBG-DR funding or another source. As part of its underwriting review, DED will review all project costs, including hard and soft costs, to evaluate their reasonableness and may, at its option, require Successful Applicants to obtain additional quotes, bids, or third-party reviews of individual or total costs. Applications may be determined ineligible if costs are determined to be unreasonable. 

Identify of Interest 

Successful Applicants must disclose any identity of interest relationship purchases or contracts with related companies during either the development or ongoing operation of the project. DED must approve identity of interest relationships and has sole discretion over this matter. Considerations will include the capacity and track record of the related party and whether pricing is equivalent to that which could be expected from an arms-length relationship.

Other Public Funding 

Successful Applicants must disclose all other commitments for funding with the initial CDBG-DR application to DED at the time of application and/or upon receiving any additional commitments of funding following application to DED.

Function 1: Identify Procedures for Recording Financial Transactions

AmpliFund Maintenance

• Identify staff responsible for authorizing and disbursing funds and ensuring that funds are not improperly issued.

Financial Information to Collect and Report

• Acquisition costs;
• Architectural fees;
• Contingencies;
• Contractor fees;
• Developer fees;
• Realtor commissions;
• Sales proceeds;
• Other funding sources; and
• Draws.

Function 2: Capture Allowable Activities

Eligible Costs

On a direct basis, CDBG-DR funding under HPP may be used to reimburse an Applicant for any of the following costs:

• Acquisition of property upon which new housing will be developed or existing housing will be rehabilitated, including reasonable and necessary closing costs associated with the purchase;
• Site Preparation, Clearance, and Site Improvements necessary for the production of housing, which may include selective demolition, grading, excavation, removal of vegetation and the like;
• Hard Costs related to the construction or rehabilitation of housing, including labor and materials;
• Soft Costs determined by DED to be necessary and reasonable, which may include but not be limited to:
  • Architectural, engineering, and design services;
  • Third-party studies or reports (such as lead-based paint testing and assessment, radon testing, energy efficiency modeling and verification testing, appraisals required by DED, and the like);
  • Financing costs including origination fees and closing costs associated with interim construction financing (interest on such loans will not be allowed, see further discussion of the developer fee below);
  • Legal costs directly related to the purchase, construction or rehabilitation, and subsequent sale of specific properties; and
  • Impact, permit, plan review, zoning, or other similar fees payable to state or local authorities.
• Developer fees of up to lesser of (1) 15% of the subtotal of acquisition, hard, and soft costs but excluding the developer fee itself and the disposition/sales costs noted below; or (2) $20,000. This item is not applicable to local government Subrecipients.
  • DED will not allow for carrying costs (including interest on construction loans, interim utilities, insurance, lawn care or snow removal, or other similar ongoing cost of ownership) to be included as a development cost. Rather, developers will be expected to pay such costs from the proceeds of the developer fee. This simplifies accounting and recordkeeping requirements for both the developer and DED and reduces the administrative burdens of monitoring. Most importantly, it aligns a developer’s economic interest with DED’s interests in cost effective use of limited CDBG-DR funding and promoting timely production and sale of CDBG-DR funded units. The effect of this approach then is that developers who are most cost effective in managing carrying costs and keeping projects on schedule (thus reducing the developer’s period of ownership) will receive larger “net” developer Fees compared to other developers who manage such costs less efficiently or are unable to keep their projects on schedule.
• Activity Delivery Costs, including staff and overhead costs of a local government Subrecipient directly attributable to carrying out the housing development activity, including but not limited to identifying and negotiating the purchase of property, evaluation and development of work specifications for construction, procurement and oversight of contractors and service providers, and other similar functions. DED will limit Activity Delivery Costs to no more than 20% of a Subrecipient’s total CDBG-DR award, not to exceed an average of $20,000 per anticipated unit. Activity delivery costs do not include general reporting to DED on the progress of a Subrecipient’s overall award or other award level administrative items. Subrecipients will not receive any allotment in their award from DED for planning and administrative costs. This item is not applicable to non-profit developers.
• Disposition and Sales Costs, including realty commissions and seller closing costs determined to be reasonable and customary in the market (not to include any “seller concessions” or other seller-paid contributions to the down payment or closing costs otherwise regularly paid by a buyer of residential real estate). In practice, notwithstanding their general eligibility, DED expects that most disposition and sales costs will be paid at the closing table from the proceeds of sale.

Function 3: Ensure Compliance

Acquisition Costs

Acquisition costs must be supported by an independent third-party appraisal prepared by a State-licensed appraiser. The purchase price must be at or below the as-is market value of the property. In the event an Applicant (or a related party) has previously purchased land prior to applying to DED, the project budget may only reflect the lesser of the actual purchase price or the current market value. Standard closing costs from the acquisition may be included. In the case of properties acquired for less than $25,000, DED may use local tax assessments to determine cost reasonableness in lieu of an appraisal. 

Applicants who purchased property prior to applying to DED, or following environmental releases under NEPA but prior to closing, may not charge or include financing costs associated with interim financing, whether from third-party or related lenders.

Architectural Fees

Architectural fees cannot exceed the following:

• Design services: 6% of total construction costs; and
• Supervision/Administration: 2% of total construction costs. 

Contingencies 

Applicants should include a contingency (inclusive of hard and soft costs) within the minimum and maximum amounts noted below. The contingency will be measured as a percentage of hard costs.

• New construction projects should include a contingency of least 5% and no more than 10% of hard costs; and
• Acquisition/rehabilitation projects should include a contingency of at least 10% and no more than 15% of hard costs.

DED may consider higher contingencies based on identified risk factors such as the known need for environmental remediation or rehabilitation of a historic structure requiring compliance with SHPO/THPO standards.

Contractor Fees

When a general contractor has not been competitively procured and is paid on any sort of “cost plus” basis, contractor fees (whether defined as profit, overhead, general conditions, or in some other manner) are limited as a percentage of net construction costs as further identified below. Net construction costs exclude the contractor fees, any budgeted contingency, and (even if otherwise included in the construction contract) permits and builder’s risk insurance.

• Construction contracts for fewer than 10 units: 18% of net construction costs; or
• Construction contracts for 10 or more units: 15% of net construction costs.

In the case of a non-profit developer that is acting as its own general contractor, a “construction management fee” not to exceed 10% of third-party hard costs (i.e., excluding itemized labor costs for any in-house construction staff) may be included.

Developer Fees

DED allows the inclusion of developer fees as follows:

• Developer fee: Up to 15% of total development costs less (1) the developer fee itself; and (2) disposition and sales costs (e.g., realtor commissions or other seller closing costs); and
• Maximum Limit: Regardless of percentage calculation, the maximum developer fee shall be $20,000 per unit.

Realtor Commissions

Realtor commissions, paid from the proceeds of sale, cannot exceed 6% of the sales price.

Other Funding Sources

Prior to entering into the HPP Development Loan, all other funding sources necessary for a project must be identified, committed in writing, and consistent with the both DED’s underwriting requirements and the affordability restrictions of the CDBG-DR program. In general, Applicants must make all reasonable efforts to maximize the availability of other funding sources, including construction lending and/or Applicant equity, within commercially available and reasonable terms.

Additionally, restrictions or limitations imposed by other funding sources cannot conflict with any applicable CDBG-DR requirements and cannot, in the discretion of DED, create undue risk to DED.

To limit the risk of taking on too much construction debt, DED generally expects an Applicant to obtain interim construction sources (loans or equity) equal to no more than 80% of the projected buyer’s funds (i.e., an affordable first mortgage minus buyer closing costs). 

Draws

The obligation of DED to approve any draw request of HPP funds is subject to the satisfaction of the following conditions at the time of making such request and such other conditions as outlined in the CDBG-DR Agreement between DED and the Applicant. 

Sales and Marketing 

As part of the application process, Applicants must submit a Sales and Marketing Plan in a form acceptable to DED, identifying among other items the profile of typical buyers, relationships with HUD-approved homeownership counseling agencies or other sources of buyer referrals, and plans for marketing the homes.

Function 1: Identify Procedures for Recording Financial Transactions

AmpliFund Maintenance

• Identify staff responsible for authorizing and disbursing funds and ensuring that funds are not improperly issued.

Financial Information to Collect and Report

• Project costs; and
• Planning costs.

Function 2: Capture Allowable Activities

Eligible Costs       

HUD differentiates between project costs and planning costs. Project costs are the direct costs of undertaking a project that can be tied to a final cost objective and eligible activities. Planning costs are the costs for creating a plan, including data gathering, studies, analysis, and preparation of plans.

Project Costs

• Environmental Reviews;
• Acquisition costs;
• Construction hard costs;
• Demolition and site clearance;
• Architecture, engineering, and permits, when paid by the beneficiary;
• Developer fees, contractor overhead, and profit; and
• Loans to businesses to assist with repairs.

Planning Costs

• Comprehensive plans;
• Functional plans for housing, land use, or economic development;
• Mitigation or disaster resiliency plans;
• Community development plans; and 
• Action Plans and Action Plan amendments.

Function 3: Ensure Compliance

Tie to the Disaster

Areas considered under the Risk Awareness Planning Program must have been impacted by Winter Storm Ulmer (DR-4420) to receive assistance. For the purposes of the Risk Awareness Planning Program, only counties that received a disaster declaration will be considered in the data collection and analysis process. Research will further focus on the flooding impacts directly resulting from Winter Storm Ulmer and/or have resulted in repetitive losses to communities. Outreach efforts will similarly be directed to declared counties, with particular focus to those areas that are within the HUD-defined MID area, which includes Dodge, Douglas, and Sarpy counties.

Financial Recordkeeping

Financial records must be retained for at least three years beyond the later of HUD’s closeout of DED’s CDBG-DR grant

Function 1: Identify Procedures for Recording Financial Transactions

AmpliFund Maintenance

Identify staff responsible for authorizing and disbursing funds and ensuring that funds are not improperly issued. 

Application Submission

Applicants must create an application and submit it to DED through its grants management system (GMS), AmpliFund. The GMS user interface will guide Applicants through the process, which requires: 

• Program eligibility documentation that shows the Applicant is eligible for funding;
• Compliance documentation; and
• Funding information.

Financial Information to Collect and Report

Financial reporting prepared by the Subrecipient must be accurate, timely, and current and represent complete disclosure of the financial activity and status of CDBG-DR grants. A Subrecipient must have the capacity to provide the following:

• Amount budgeted;
• Reimbursements received to date;
• Program income and other miscellaneous receipts in the current period and year to-date; and
• Actual expenditures/disbursements in the current period and cumulatively to-date, for both program income and regular CDBG-DR grant funds.

Function 2: Capture Allowable Activities

Eligible Activities

The HRP Program will support eligible Applicants in developing a housing plan (the Plan), that (1) focuses on reducing flood vulnerability in the community. and (2) must have one or more of the following areas of focus:

• Housing recovery, which supports communities in gathering data about existing housing stock and damages and implementing programs that help communities recover by using available funds.
• Housing resilience, which allows communities to determine their existing risks and vulnerabilities and develop actions that increase resilience against future disasters. Communities can use funding from the HRP Program to further assess their long-term recovery needs.
• Affordable housing, which helps communities develop programs that preserve existing affordable housing and encourage the development of new affordable housing.

Eligible Costs

HUD differentiates between project costs and planning costs. Project Costs are the direct costs of undertaking a project that can be tied to a final cost objective and eligible activities. Planning Costs are the costs for creating a plan, including data gathering, studies, analysis, and preparation of plans.

Project Costs

• Environmental reviews;
• Acquisition costs;
• Construction hard costs;
• Demolition and site clearance;
• Architecture, engineering, and permits, when paid by the beneficiary;
• Developer fees, contractor overhead, and profit; and
• Loans to businesses to assist with repairs.

Planning Costs

• Comprehensive plans;
• Functional plans for housing, land use, or economic development;
• Mitigation or disaster resiliency plans;
• Community development plans; and
• Action Plans and Action Plan amendments.

Function 3: Ensure Compliance

Tie to the Disaster

All entities applying to the HRP Program must have been impacted by Winter Storm Ulmer (DR-4420) to receive assistance. For the purposes of the HRP Program, only , and Economic Development Districts in the HUD-defined MID are eligible for funding. Eligible communities will be asked to document that they demonstrate a tie-back to the disaster in the form of a narrative description in a NOFO, with supplemental information provided, if available, such as:

• Damage or insurance estimates for losses to the housing stock; or
• Post-disaster analyses or assessments documenting the relationship between the loss and the disaster.

While the HRP Program does not invest directly in housing rehabilitation or construction, the total amount of damage will be considered in the applicant selection process. Narratives will be maintained in the DED system of record, as described in Chapter 17: Recordkeeping & Data Management of the CDBG-DR Manual.

Financial Recordkeeping

Financial records must be retained for at least three years beyond the later of (1) HUD’s closeout of DED’s CDBG-DR grant or (2) DED’s closeout of the Subrecipient’s grant from DED.