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V.B.1. Subsidized Loans For this notice, subsidized loans (including forgivable loans) are loans other than private loans. Both SBA and FEMA provide subsidized loans for disaster recovery. Subsidized loans may also be available from other sources. Subsidized loans are assistance that must be included in the DOB analysis, unless an exception applies.
As a general rule, CDBG–DR grant funds are available only to pay for new activities. However, most Federal Register notices governing CDBG–DR grants permit payment of costs dating back to the date of the disaster that led to the CDBG–DR grant award. These Federal Register notices require grantees to adhere to reimbursement requirements previously established by HUD when reimbursing applicants' costs.(Resource #5) Reimbursement is not permitted if payment of the cost with CDBG–DR funds will cause a DOB because an exception does not apply or violate the requirement that CDBG–DR funds shall not be used for activities reimbursable by, or for which funds are made available by, FEMA or the Army Corps of Engineers.
- Resource #5: The most recent CPD notice made applicable by Federal Register notices governing CDBG–DR grants is CPD Notice 2015–07, "Guidance for Charging Pre-Application Costs of Homeowners, Businesses, and Other Qualifying Entities to CDBG Disaster Recovery Grants" HUD may update this notice and amend reimbursement requirements in Federal Register notices from time to time. This notice applies to reimbursement of applicants other than the grantee and subrecipient. The requirements on reimbursement of costs of the grantee or subrecipient are described in the Federal Register notices governing the grants.