CDBG-DR Order of Assistance. When the Grantee takes CDBG-DR grants to pay for FEMA or Army Corps projects.
V.C. Order of Assistance
CDBG–DR appropriations acts generally include a statutory order of assistance for Federal agencies. Although the language may vary among appropriations, the statutory order of assistance typically provides that CDBG–DR funds may not be used for activities reimbursable by or for which funds are made available by FEMA or the Army Corps. This means that grantees must verify whether FEMA or Army Corps funds are available for an activity (i.e. the application period is open) or the costs are reimbursable by FEMA or Army Corps (i.e., the grantee will receive FEMA or Army Corps assistance to reimburse the costs of the activity) before awarding CDBG–DR assistance for costs of carrying out the same activity. If FEMA or Army Corps are accepting applications for the activity, the applicant must seek assistance from those sources before receiving CDBG–DR assistance. If the applicant's costs for the activity will be reimbursed by FEMA or the Army Corps, the grantee cannot provide the CDBG–DR assistance for those costs. In the event that FEMA or Army Corps assistance is awarded after the CDBG–DR to pay the same costs, it is the CDBG–DR grantee's responsibility to recapture CDBG–DR assistance that duplicates assistance from FEMA or the Army Corps.
Under the Stafford Act, a federal agency that provides duplicative assistance must collect that assistance. For CDBG–DR grants, the CDBG–DR grantee must collect duplicative assistance it provides.
FEMA regulations at 44 CFR 206.191 set forth a delivery sequence that establishes which source of assistance is duplicative for certain programs. CDBG–DR assistance is not listed in FEMA's sequence, but as a practical matter, CDBG–DR assistance duplicates other sources received before the CDBG–DR for the same purpose and portion of need. Any amount received from other sources before the CDBG–DR assistance that is determined to be duplicative must be collected by the grantee. The mandatory agreement to repay (discussed in VII. below) can be used to prevent duplication by assistance that is available, but not yet received. If the duplicative assistance is received after CDBG–DR, the grantee must collect the DOB or contact HUD if it has questions about whether another Federal agency is responsible for collecting the duplication.
Research Resources:
Terms:
- Grantee = State Managing HUD CDBG-DR funds
- Aggregate amount = Total Dollar Amount
- Subsidized loans = SBA loans
FAQ Research based learning
"Providing resource supported answers."
FEMA Disaster Assistance for Individuals and Households Program which is provided for temporary repairs of your home so you are not dependent on other housing assistance and is not a Duplication of Benefits (DOB) to other assistance and HUD CDBG-DR Grants
State of Louisiana Restore LA Program managed by the OCD-DRU says it will not pay interest on SBA loans.
HUD to clarify the sequence of delivery of disaster assistance to individuals.
Multiple disasters occur in the same location, and the applicant has not recovered from the first disaster.
CDBG-DR Order of Assistance. When the Grantee takes CDBG-DR grants to pay for FEMA or Army Corps projects.
Subsidized Loans for HUD Guidance June 2019 notice. What the notice includes.
SBA Disaster Recovery Loan Applicant Information: Cancelled SBA Loan, Cancelled subsidized loan.
SBA Disaster Recovery Loan Applicant Information: Declined or cancelled subsidized loans
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HUD CDBG-DR Grant Denied?
Did your state inform you that you qualify for federal assistance only to later deny you assistance based on state created policy or procedure? Is your home listed as being in one of the most impacted areas? Do you have proof your state accepted you into the federally funded HUD CDBG-DR grant program? Contact us about your experience.
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