94. Top Five DOB and DRRA Implementation Issues to Address in Forthcoming Guidance Dec. 2018 training for Guidance expected to be published in 2019. 3-4-2019 94 Disaster Recovery Reform Act of 2018 (PL 115-254, Division D) ("DRRA") Input Requested: Top Five DOB and DRRA Implementation Issues to Address in Forthcoming Guidance: How should grantees treat undrawn loan amounts? How should grantees treat SBA loan funds that are drawn down but not used, and could be returned to SBA? How should grantees document "that all Federal assistance is used toward a loss suffered as a result of the major disaster or emergency", which is a requirement of the provision that a loan is not a DOB? Must grantees complete a new DOB check for beneficiaries that previously took SBA loans before providing additional assistance? Can CDBG-DR be used to make a loan to cover an existing DOB?