what is code enforcement?
Use of CDBG Funds for Code Enforcement Activities Webinar April 1, 2015 Hosted by The International Association of Plumbing and Mechanical Officials HOUSEKEEPING Who is IAPMO? Introduc3ons Founded in 1926, the Interna:onal Associa:on of Plumbing and Mechanical Officials (The IAPMO Group) is a nonprofit trade associa:on comprised of U.S. and interna:onal plumbing, mechanical and solar professionals. For the last 90 years, IAPMO has focused on the technical aspects of these industries addressing core areas such as codes/standards development, training/professional development, and third party tes:ng and cer:fica:on. Presenters • Steve Johnson, Director of the En:tlement Communi:es Division in HUD's Office of Community Planning and Development • Gloria Coates, Community Planning and Development Specialist in the Office of Block Grant Assistance, En:tlement Communi:es Division USE OF CDBG FUNDS FOR CODE ENFORCEMENT ACTIVITIES WHAT WILL BE COVERED TODAY • Overview of the CDBG program – statutory/regulatory authority, objec:ves, how funds are awarded, eligible ac:vi:es, and na:onal objec:ve compliance. • How CDBG funds may be used for code enforcement ac:vi:es: – – – – – – – – – what is code enforcement purpose of code enforcement eligible code enforcement costs ineligible code enforcement costs na:onal objec:ve compliance fair housing and civil rights considera:ons how revenue from code inspec:ons and enforcement of codes is treated 2012 statutory provision on code enforcement Recordkeeping requirements Slide 5 OVERVIEW OF THE CDBG PROGRAM • The CDBG program is authorized by Title I of the Housing and Community Development Act of 1974, as amended and codified at 24 CFR Part 570. • The objec:ve is the development of viable urban communi:es, provision of decent housing and a suitable living environment, and expanding economic opportuni:es, principally for low and moderate income persons. OVERVIEW OF THE CDBG PROGRAM • $3 billion appropriated for 2015. Seventy percent is appropriated to en:tlement communi:es. Thirty percent is appropriated to States (non-‐ en:tlements). • Annual en:tlement grants are provided on a formula basis to states, metropolitan ci:es, and urban coun:es to implement a wide variety of community-‐based ac:vi:es directed toward neighborhood revitaliza:on, economic development, and public facili:es and services. Slide 6 OVERVIEW OF THE CDBG PROGRAM • The CDBG program is authorized by Title I of the Housing and Community Development Act of 1974, as amended and codified at 24 CFR Part 570. • The objec:ve is the development of viable urban communi:es, provision of decent housing and a suitable living environment, and expanding economic opportuni:es, principally for low and moderate income persons. • $3 billion appropriated for 2015. Seventy percent is appropriated to en:tlement communi:es. Thirty percent is appropriated to States (non-‐ en:tlements). • Annual grants are provided on a formula basis to states, metropolitan ci:es, and urban coun:es to implement a wide variety of community-‐based ac:vi:es directed toward neighborhood revitaliza:on, economic development, and public facili:es and services. Slide 7 OVERVIEW OF THE CDBG PROGRAM (CONT.) • CDBG ac:vi:es are ini:ated and developed at the local level based upon a community’s percep:on of its local needs, priori:es, and benefits to the community. Ci:zens are part of the process. HUD is not part of the decision-‐making process. • Each grantee receiving CDBG funds is free to determine what ac:vi:es it will fund as long as they meet all CDBG program requirements, are eligible, and meet one of three na:onal objec:ves: – benefits persons of low and moderate income (70% requirement) – aids in the preven:on or elimina:on of slums or blight – meets other community development needs of a par:cular urgency that the grantee is unable to finance on its own Slide 8 OVERVIEW OF THE CDBG PROGRAM (CONT.) • Annual Ac:on Plans must be submiied to the local HUD field office at least 45 days prior to start of program year for HUD approval. • Ninety days aker the end of the program year, grantees are required to submit their Consolidated Annual Performance and Evalua:on Reports (CAPER or performance report) to HUD. • HUD measures the annual performance repor:ng against Ac:on Plan goals and ac:vi:es iden:fied in the Ac:on Plan. • HUD conducts on-‐site monitoring of CDBG grantees to ensure compliance with all CDBG program requirements. Slide 9 OVERVIEW OF THE CDBG PROGRAM (CONT.) • Grantees must develop a ci:zen par:cipa:on plan that iden:fies their policies and procedures for ci:zen par:cipa:on in the development of the Consolidated Plan, Ac:on Plan, amendments to those plans, and performance reports. • CDBG grantees develop a Consolidated Plan every 3-‐5 years that iden:fies their housing and homeless needs, needs of specific groups of persons (such as elderly, renters, large families, and public housing families), and a strategic plan for carrying out ac:vi:es to meet iden:fied needs. • With ci:zen par:cipa:on, grantees iden:fy ac:vi:es that will be carried out in their annual Ac:on Plans. Slide 10 OVERVIEW OF THE CDBG PROGRAM (CONT.) • Eligible ac:vi:es include but are not limited to: – – – – – – – – – – – – Acquisi:on of real property for a public purpose Public facili:es and improvements Clearance and remedia:on Public services Rehabilita:on (housing, public facili:es, commercial w/ limits) Special economic development Code enforcement Homeownership assistance Reloca:on Historic preserva:on Microenterprise assistance Planning and administra:on Slide 11 OVERVIEW OF THE CDBG PROGRAM (CONT.) • CDBG Statute – Housing and Community Development Act of 1974, as amended • CDBG En:tlement Program Regula:ons – 24 CFR Part 570 (Par:al List) – – – – – – – – – 570.1 – Purpose and Primary Objec:ve 570.3 – Defini:ons 570.200 – General Policies 570.201 – Basic Eligible Ac:vi:es 570.202 – Eligible Rehabilita:on and Preserva:on Ac:vi:es 570.203 – Special Economic Development 570.206 – Program Administra:on Costs 570.207 – Ineligible Ac:vi:es 570.208 – Criteria for Na:onal Objec:ves • 570.480 – 497 – State CDBG Program Regula:ons Slide 12 OVERVIEW OF THE CDBG PROGRAM (CONT.) • In the State CDBG Program, States oversee the grants that they award to non-‐en:tled units of general local government. • States distribute funds to units of general local government (non-‐ en:tlements) based on state method of distribu:on. • States may distribute the funds on a compe::ve basis. • States oversee but do not choose the ac:vi:es carried out by units of general local government. Slide 13 WHAT IS CODE ENFORCEMENT? • As defined at 24 CFR 570.202(c) for En:tlement grantees: Costs incurred for inspec:on for code viola:ons and enforcement of codes (e.g., salaries and related expenses of code enforcement inspectors and legal proceedings, but not including the cost of correc:ng the viola:ons) in deteriora:ng or deteriorated areas when such enforcement together with public or private improvements, rehabilita:on, or services to be provided may be expected to arrest the decline of the area. HOW CDBG FUNDS MAY BE USED FOR CODE ENFORCEMENT • As defined at Sec:on 105(a)(3) for States: the use of CDBG funds for code enforcement in deteriorated or deteriora:ng areas in which such enforcement, together with the public or private improvements or services to be provided, may be expected to arrest the decline of the area. Slide 14 WHAT IS CODE ENFORCEMENT? • As defined at 24 CFR 570.202(c) for En:tlement grantees: Costs incurred for inspec:on for code viola:ons and enforcement of codes (e.g., salaries and related expenses of code enforcement inspectors and legal proceedings, but not including the cost of correc:ng the viola:ons) in deteriora:ng or deteriorated areas when such enforcement together with public or private improvements, rehabilita:on, or services to be provided may be expected to arrest the decline of the area. • As defined at Sec:on 105(a)(3) for States: the use of CDBG funds for code enforcement in deteriorated or deteriora:ng areas in which such enforcement, together with the public or private improvements or services to be provided, may be expected to arrest the decline of the area. Slide 15 WHAT IS CODE ENFORCEMENT? (CONT.) • Code enforcement is defined by some jurisdic:ons as the preven:on, detec:on, inves:ga:on, and enforcement of viola:ons of statutes and ordinances regula:ng public health, safety and welfare. • Jurisdic:ons may also include the maintenance and preserva:on of the value and appearance of residen:al, commercial, and industrial buildings within its boundaries in its defini:ons of code enforcement. • Some jurisdic:ons focus on buildings and structures while other focus on neighborhood cleanliness, public adver:sement displays, lawn care, environmental concerns, and the condi:on of motor vehicles on its streets. Slide 16 WHAT IS CODE ENFORCEMENT? (CONT.) • For CDBG program purposes, code enforcement is defined as a process whereby local governments gain compliance with ordinances and regula:ons regarding health and housing codes, land use and zoning ordinances, sign standards, and uniform building and fire codes. • The CDBG program expects the focus of code enforcement to be on health and safety issues in buildings and structures. • Supplemental efforts to address code viola:ons related to vacant lots, signs, and motor vehicles are allowed in conjunc:on with efforts involving buildings and should only be a minor part of the grantee’s code enforcement program. Slide 17 WHAT IS CODE ENFORCEMENT? (CONT.) • The lack of :me distribu:on records and documenta:on to demonstrate use of CDBG funds for code enforcement in eligible areas has been a significant problem for some grantees. Not having complete and accurate documenta:on has resulted in monitoring findings and disallowed costs. • To avoid this, grantees must ensure that their records and documenta:on show ac:vity eligibility, na:onal objec:ve compliance, allowability of costs, and cost reasonableness; grantees must also ensure that their :me distribu:on records are accurate. Slide 18 PURPOSE OF CODE ENFORCEMENT • to protect the public health, safety and welfare. • to encourage homeowners and tenants to maintain the appearance and value of their housing units. • to protect the health and safety of persons u:lizing buildings such as public facili:es. • to reduce crime in a neighborhood. Slide 19 ELIGIBLE CODE ENFORCEMENT COSTS • Salaries of code enforcement officers working in CDBG-‐eligible areas. • Procurement of code enforcement inspec:on specialists or companies or hiring another unit of government to perform code inspec:ons. • Lease of vehicle to conduct inspec:ons and/or use allowances for vehicles purchased with other funding sources. • Uniforms and coveralls if they are a job requirement. • Hand-‐held computers and tablets to record informa:on in propor:on to the :me spent conduc:ng inspec:ons for CDBG purposes in CDBG eligible areas. Slide 20 ELIGIBLE CODE ENFORCEMENT COSTS (CONT.) Enforcement of Codes • Legal and code enforcement hearings. • Cost of processing and issuing cita:ons. • Collec:on and processing of fines assessed. • Hearing Officers’ salaries in propor:on to the amount of :me spent hearing and deciding appeals from code enforcement cita:ons or fines from CDBG-‐ assisted code inspec:ons and enforcement. • Legal fees paid to aiorneys by grantees as part of the legal proceedings. Slide 21 INELIGIBLE CODE ENFORCEMENT COSTS • Public or private improvements, rehabilita:on, or services provided that are expected to arrest the decline of areas inspected under the authority of 24 CFR 570.202(c). – – – – Public improvements may be eligible under 24 CFR 570.201(c). Private improvements may be eligible under 24 CFR 570.203. Rehabilita:on may be eligible under 24 CFR 570.202(a). Services such as neighborhood cleanup campaigns may be eligible under 24 CFR 570.201(e), public services. Public services are subject to the 15 percent public service cap. • Conduc:ng code enforcement inspec:ons in every neighborhood in a jurisdic:on. • General government expenses (code enforcement carried out in non-‐ CDBG eligible areas or non-‐deteriorated/deteriora:ng areas). Slide 22 CDBG-‐ELIGIBLE CODE ENFORCEMENT AREAS • Areas inspected with CDBG funds must meet the local or state law defini:on of deteriorated/deteriora:ng. • The standards at 24 CFR 570.208(b)(1) for En:tlements and 24 CFR 570.483(c)(1) for States may be used to determine if an area is deteriorated/deteriora:ng, with limita:ons. – For example, a determina:on that public improvements are in a general state of deteriora:on would not sufficiently jus:fy conduc:ng code enforcement inspec:ons in private property in certain neighborhoods. – Local or state defini:ons of deteriorated/deteriora:ng may contain criteria that have nothing to do with the physical condi:on of the built environment (such as undeveloped land or inappropriately zoned parcels). Slide 23 NATIONAL OBJECTIVE COMPLIANCE • Benefit to low-‐ and moderate-‐income persons on an area basis – 24 CFR 570.208(a)(1) for En:tlements and 24 CFR 570.483(b)(1) for States. – Inspec:ons may be conducted on single or mul:family housing units, commercial buildings, and other publicly-‐ or privately-‐owned buildings. – The buildings inspected must be located in a primarily residen:al area where a minimum of 51 percent of the residents in the area are low-‐ and moderate-‐ income. Slide 24 NATIONAL OBJECTIVE COMPLIANCE (CONT.) • Preven:on or elimina:on of slum/blight on an area basis – 24 CFR 570.208(b)(1) for En:tlements and 24 CFR 570.483(c)(1) for States. – The area designated as slum/blighted must meet the defini:on of a slum, blighted, deteriorated, or deteriora:ng area under State or local law, AND – At least 25 percent of the proper:es throughout the area must have physical deteriora:on of buildings or improvements; abandonment of proper:es; or chronic high occupancy turnover rates or chronic high vacancy rates in commercial or industrial buildings; significant declines in property values or abnormally low property values rela:ve to other areas in the community; or known or suspected environmental contamina:on; OR – The public improvements throughout the area are in a general state of deteriora:on. – Note that an area iden:fied as deteriorated/deteriora:ng by a grantee may not qualify the area as slum or blighted for the purpose of mee:ng this na:onal objec:ve. – Area does not have to be primarily residen:al. – Redetermina:on of the area must be carried out every 10 years for the area to con:nue to be designated as slum/blighted. Slide 25 NATIONAL OBJECTIVE COMPLIANCE (CONT.) Ac:vi:es designed to meet community development needs having a par:cular urgency – 24 CFR 570.208(c) for En:tlements and 24 CFR 570.483(d) for States. – Code enforcement inspec:ons may be conducted in areas that experienced non-‐ Presiden:ally declared disasters or areas that experienced Presiden:ally declared disasters for which FEMA funds were exhausted. – En:tlement grantees must cer:fy that exis:ng condi:ons pose a serious and immediate threat to the health and welfare of the community. – The disastrous occurrence must be of recent origin (18 months or fewer before the grantee’s cer:fica:on) or recently became urgent. Slide 26i NATIONAL OBJECTIVE COMPLIANCE (CONT.) – The grantee must cer:fy it is unable to finance the ac:vity on its own and that no other funding resources are available. – In the State program, the unit of general local government cer:fies, and the states determines, that the same condi:ons exist. – Grantees must be able to document that the inspec:ons for code viola:ons and enforcement of codes were designed to address the urgent need, met the :ming requirement regarding the serious condi:on, and have evidence that no other financial resources were available to address the urgent need. Slide 27 FAIR HOUSING AND CIVIL RIGHTS CONSIDERATIONS • Sec:on 109 of the HCDA prohibits CDBG grantees and subrecipients from discrimina:ng on the basis of race, color, na:onal origin, religion or sex in the par:cipa:on in any program or ac:vity funded in whole or in part with federal financial assistance. • Grantees and subrecipients must also comply with the Fair Housing Act, :tle VI of the Civil Rights Act of 1964, and Sec:on 504 of the Rehabilita:on Act of 1973. • All CDBG-‐assisted ac:vi:es, including code enforcement, cannot discriminate on the basis of race, color, religion, sex, disability, familial status, or na:onal origin. • CDBG fund recipients must take reasonable steps to ensure meaningful access to their programs and ac:vi:es to limited English proficient individuals. • CDBG grantees and subrecipients must also affirma:vely further fair housing in their use of CDBG funds. Slide 28 WHAT IS CODE ENFORCEMENT? • As defined at 24 CFR 570.202(c) for En:tlement grantees: Costs incurred for inspec:on for code viola:ons and enforcement of codes (e.g., salaries and related expenses of code enforcement inspectors and legal proceedings, but not including the cost of correc:ng the viola:ons) in deteriora:ng or deteriorated areas when such enforcement together with public or private improvements, rehabilita:on, or services to be provided may be expected to arrest the decline of the area. TREATMENT OF REVENUE FROM CODE INSPECTIONS AND ENFORCEMENT OF CODES defined at Sec:on 105(a)(3) for States: the use of CDBG funds for code • As enforcement in deteriorated or deteriora:ng areas in which such enforcement, together with the public or private improvements or services to be provided, may be expected to arrest the decline of the area. Slide 29 REVENUE FROM CODE INSPECTIONS AND ENFORCEMENT OF CODES • Fines may be assessed to the owners of proper:es that incurred the code viola:ons. How are these fines treated in the CDBG program? • Fines are not program income as defined at 24 CFR 570.500(a). • Fines may be treated as applicable credits or general revenue. • Depends on the intended purpose of the fines. Slide 30 REVENUE FROM CODE INSPECTIONS AND ENFORCEMENT OF CODES (CONT.) • 2 CFR 200.406 defines applicable credits as receipts or reduc:ons of expenditure type transac:ons that offset or reduce expense items allocable to Federal awards. To the extent that such credits accruing to or received by the governmental unit relate to allowable costs, they shall be credited to the Federal award either as a cost reduc:on or cash refund, as appropriate. • To be considered applicable credits: – the cost of the inspec:ons for code viola:ons and enforcement of codes, which may include the inspectors’ salaries, must have been wholly or par:ally paid for with CDBG funds, and – the intended purpose of the code enforcement fine, as reflected in local law, handbook, manual, etc., is to recover the costs incurred for the code enforcement ac:vi:es without regard to the source of funds for payment of the code enforcement ac:vity. Slide 31 REVENUE FROM CODE INSPECTIONS AND ENFORCEMENT OF CODES (CONT.) • Code enforcement fines should be treated as general revenue if: – the purpose of the fine is not to recover the cost of the code inspec:ons and enforcement; – the costs of carrying out the code inspec:ons and enforcement were not paid with CDBG funds; or – the amount of the fine exceeds the costs paid with CDBG funds. Slide 32 WHAT IS CODE ENFORCEMENT? • As defined at 24 CFR 570.202(c) for En:tlement grantees: Costs incurred for inspec:on for code viola:ons and enforcement of codes (e.g., salaries and related expenses of code enforcement inspectors and legal proceedings, but not including the cost of correc:ng the viola:ons) in deteriora:ng or deteriorated areas when such enforcement together with public or private improvements, rehabilita:on, or services to be provided may be expected to arrest the decline of the area. 2012 STATUTORY PROVISION ON CODE ENFORCEMENT • As defined at Sec:on 105(a)(3) for States: the use of CDBG funds for code enforcement in deteriorated or deteriora:ng areas in which such enforcement, together with the public or private improvements or services to be provided, may be expected to arrest the decline of the area. Slide 33 2012 STATUTORY PROVISION ON CODE ENFORCEMENT • Sec:on 105(a) of the Housing and Community Development Act of 1974 was amended by :tle II of the Moving Ahead for Progress in the 21st Century Act (MAP-‐21) to add a new Sec:on 105(a)(27) to the HCDA. • This provision permiied CDBG funds to be used to supplement exis:ng state or local funding for administra:on of building code enforcement by local building code enforcement departments, including: • • • • • Increasing staffing; Providing staff training; Increasing staff competence and professional qualifica:ons; Suppor:ng individual cer:fica:on or departmental accredita:on; and Capital expenditures specifically dedicated to the administra:on of the building code enforcement department. Slide 34 2012 STATUTORY PROVISION ON CODE ENFORCEMENT (CONT.) • MAP 21 required that CDBG assistance provided under Sec:on 105(a) (27) be matched using non-‐federal funds: • for building code enforcement departments serving an area with a popula:on of more than 50,000, not less than 50 percent of the total amount of CDBG funds provided for this ac:vity; • for building code enforcement departments serving an area with a popula:on of between 20,001 and 50,000, not less than 25 percent of the CDBG funds provided for this ac:vity; and • for building code enforcement departments serving an area with a popula:on of less than 20,000, not less than 12.5 percent of the CDBG funds provided for this ac:vity. Slide 35 2012 STATUTORY PROVISION ON CODE ENFORCEMENT (CONT.) • MAP 21 allowed training for code enforcement staff to be treated as an ac:vity delivery cost rather than a program administra:on cost. • The MAP 21 provisions sunset on July 6, 2014, so CDBG assistance allowed via this authority is no longer eligible. However, there may be grantees that undertook code enforcement ac:vi:es under MAP 21. • Note that 24 CFR 570.202(c) and Sec:on 105(a)(3) of the HCDA also allow CDBG funds to be used to pay salaries of code enforcement inspectors. • Training in code enforcement procedures and prac:ces and paying for courses to increase inspectors’ abili:es to carry out efficient and proper code inspec:ons and enforcement are eligible as ac:vity delivery costs of CDBG-‐assisted code enforcement ac:vi:es under these same provisions. • No match is required, and there is no sunset for these provisions. Slide 36 WHAT IS CODE ENFORCEMENT? • As defined at 24 CFR 570.202(c) for En:tlement grantees: Costs incurred for inspec:on for code viola:ons and enforcement of codes (e.g., salaries and related expenses of code enforcement inspectors and legal proceedings, but not including the cost of correc:ng the viola:ons) in deteriora:ng or deteriorated areas when such enforcement together with public or private improvements, rehabilita:on, or services to be provided may be expected to arrest the decline of the area. RECORDKEEPING REQUIREMENTS • As defined at Sec:on 105(a)(3) for States: the use of CDBG funds for code enforcement in deteriorated or deteriora:ng areas in which such enforcement, together with the public or private improvements or services to be provided, may be expected to arrest the decline of the area. Slide 37 RECORDKEEPING REQUIREMENTS • The En:tlement CDBG program regula:ons at 24 CFR 570.506 iden:fy records that must be kept by grantees carrying out CDBG-‐assisted ac:vi:es, including code enforcement ac:vi:es. • The State CDBG program regula:ons at 24 CFR 570.490(a) and (b) iden:fy records that states and units of general local government must maintain and provides that the content of records maintained by the state shall be as jointly agreed upon by HUD and the states. • Records to be maintained when carrying out CDBG-‐assisted code enforcement include: – The state and local law defini:ons of deteriorated/deteriora:ng and a descrip:on of the condi:ons of the areas in which CDBG funds are used for code enforcement that show that these areas meet the state local law defini:on of deteriorated/deteriora:ng. – . Slide 38 RECORDKEEPING REQUIREMENTS ( CONT.) – If the low/moderate income area benefit na:onal objec:ve criterion is used, the boundaries of the areas in which CDBG funds are used for code enforcement that demonstrate compliance. – If the slum/blight area na:onal objec:ve criterion is used, the grantee’s delinea:on of the areas inspected as slum/blighted under state or local law; a determina:on that a minimum of 25 percent of the buildings in the delineated area have either physical deteriora:on, property abandonment, chronic high occupancy turnover rates, and/or significant declines in property values or abnormally low property values rela:ve to other areas in the community; and documenta:on of known or suspected environmental contamina:on. – If the urgent need na:onal objec:ve is used, for en:tlement grantees, a cer:fica:on that the buildings inspected posed a serious and immediate threat to the health and welfare of the community, the disastrous occurrence was of recent origin (18 months before the grantee’s cer:fica:on, and that no other funding resources were available to assist the ac:vity. For the State CDBG program, the unit of general local government makes the cer:fica:on, and the State determines, that the criterion above was met. Slide 39 RECORDKEEPING REQUIREMENTS ( CONT.) – Iden:fica:on of other ac:vi:es to be carried out (whether CDBG-‐assisted or not) that will arrest the decline of the areas and their funding sources. – Grantees should also maintain salary records of code enforcement inspectors paid with CDBG funds and the descrip:on of areas they are responsible for inspec:ng. – Costs for legal proceedings must be documented. – Salary costs should be supported by :me distribu:on records. Slide 40 HELPFUL LINKS Accessing CPD No:ce 14-‐016 on Code Enforcement online: hip://portal.hud.gov/hudportal/HUD?src=/program_offices/administra:on/ hudclips/no:ces/cpd List of excep:on grantees: hip://www.hud.gov/offices/cpd/systems/census/lowmod/excep:on.cfm Limited English Proficient Persons (LEP) informa:on and guidance: www.jus:ce.gov/crt/lep/guidance/HUD_guidance_Jan07.pd www.hud.gov/offices/veo/promo:ngv/lep.cfm State CDBG program guidance on recordkeeping: hip://portal.hud.gov/hudportal/documents/huddoc?id=DOC_16372.pdf Slide 41 HELPFUL LINKS CDBG En:tlement Program hips://www.hudexchange.info/cdbg-‐en:tlement/ CDBG State Program hips://www.hudexchange.info/cdbg-‐state/ Community Planning and Development Program Formula Alloca:ons for FY 2015 hip://portal.hud.gov/hudportal/HUD?src=/program_offices/comm_planning/ about/budget/budget15 CDBG Contacts hip://portal.hud.gov/hudportal/HUD?src=/program_offices/ comm_planning/communitydevelopment/programs/contacts CPD Field Offices hips://www.hudexchange.info/manage-‐a-‐program/cpd-‐field-‐office-‐ Slide 42 directory/ HELPFUL LINKS CDBG Program Laws and Regula:ons hips://www.hudexchange.info/community-‐development/cdbg-‐laws-‐and-‐ regula:ons Slide 43 QUESTIONS? 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