Shared information from the state of Louisiana Office of Community Development - Disaster Recovery Unit and the Department of Administration regarding the processing of US Treasury disbursements of HUD funds used to repay SBA loans.
To understand the graphs and states language you must understand what phase you are in.
The state identified 3 phases in APA 12 that was not completely approved by HUD. The state since Oct. 10, 2019 has refused to publish an updated APA 12 that would show only approved items. Until the state opens it's management meetings to the public and allows transparency in government our reports will be 30 to 90 days delayed by state bureaucracy.
Current HUD Approved Phases
- Phase I (Declined Canceled all income groups)
- Phase II (Declined in part all income groups)
- Phase III Below 120% AMI
The processing is to be by income but you will find that phases that are not income dependent are not processed in the order of income but in order of project completion date.
Additionally you should know which laws provided you access the HUD CDBG-DR funds. Phases 1 and 2 are supported by Public Law 115-123 signed into law Feb. 9, 2018 by President Trump. Phase III follows Public Law 115-254 signed into law Oct. 5, 2018 and often referred to as the DRRA which is confusing at times. This law covers the "Stafford Act Amendment" under section 1210. This is making a SBA loan not a publication of benefits and eligible for repayment under HUD Guidance June 20, 2019.
Repayments apply only to qualified structural repairs. You should review REIMB_ECR and ECR's to find out what is qualified for repayment under your phase III (3) processing.
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