Top Five DOB and DRRA Implementation Issues to Address in Forthcoming Guidance Dec. 2018 training for Guidance expected to be published in 2019.

FAQ#: 94 published 3-4-2019

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?


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