Establishing A Record Keeping / Data Collection System
The State has established uniform record keeping requirements for local governments receiving funds under the State CDBG program (24 CFR Part 570). See Exhibit I-A for details. We suggest the grantee establish separate files for each of the major compliance areas. These files will be required in all instances for Items A through E below. Some projects, e.g. construction, will also be required to establish and maintain separate files for Items F thought H, as applicable. See Exhibit I-K: Project Files Checklist.
- Contract
- Project Start-up
- Financial Management and Reporting
- Environmental
- Civil Rights
- Labor Standards (if applicable)
- Acquisition and Replacement (if applicable)
- Relocation (if applicable)
The lists of required records for each compliance areas are contained in the exhibits for each of those respective sections of this Guidebook.
Housing Projects Only
At project closeout, you will be required to provide information about each applicant, whether or not they were approved to receive benefits. A file must be kept on all program applicants, whether they are eligible or ineligible. The information that needs to be tracked on each applicant includes:
Race: # of persons in household who are White, Black, Hispanic, Asian/Pacific Islander, or Indian (American Indian/Alaskan Native)
FHH: Female Head of Household
Disabled: # of persons in household who are disabled, or in the case of economic development, is the applicant disabled
For ineligible clients, a single file containing the above required information will be sufficient. Individual client files must be maintained for eligible applicants and will be accounted for in the Project Completion Report. (See Exhibit XI-B).
The checklists that state staff will use for monitoring compliance with national objectives, eligibility, and start-up/certification requirements are contained in Section X: DOLA CDBG Monitoring Checklist.