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The City, through the Community & Economic Development Office (CEDO),
performs an annual monitoring of CDBG subrecipients. Agencies that have
demonstrated an excellent track record with CDBG compliance may be viewed as
low-risk, and monitored every other year. Agencies in which there have been
findings or other indications of significant concern may be monitored
bi-annually.
Subrecipients are monitored for compliance with CDBG regulations and for
success in carrying out the goals and objectives defined in their CDBG contract.
Each year, program staff determine priority areas for the monitoring program based
on local and national trends and concerns. Specific questions that staff review
include:
- Is the project operating within the approved budget? If not, why not?
- Has there been an audit of the agency? If so, a copy is obtained and reviewed.
If not, why not?
- Where there is program income, what is the process for
reporting and using it?
- Do accounting records adequately identify the use of
CDBG funds?
- Are accounting records supported by source documentation for
vendors oices, purchase orders, time sheets, contracts, etc.)?
- e
agency document use of funds througords such as payroll ledgers, cancelled
checks, receipts ledgers, bank deposit tickets and bank statements, time sheets
and contracts for services?
- Is the information reviewed on a site visit
consistent with the records maintained by the agency and with data previously
provided to the City?
- What procedure does the subrecipient use for
procurement? Is it consistent with Circular A-110 (nonprofits) or A-102
(governmental entities)?
- Are the actual measurable accomplishments of the
project to date proceeding according to contract projections? If not, why not?
- Is the project providing the full scope of services delineated in the
contract? If not, why not?
- What are the number and percentage of low and
moderate income people served by the project?
- How does the project prove that
it serves low and moderate income people?
- Does the project serve minority
populations? What is the method of outreach?
- Is the project on schedule? If
not, why not?
- How does the agency evaluate the effectiveness of the project?
- Does the project conform to any additional terms of the contract?
- Has any
work on the project been subcontracted?
- What effort was made to employ local
residents and use local businesses and contractors?
- Is the agency complying
with equal opportunity requirements?
- Is the agency complying with disability
access and nondiscrimination requirements?
- What provisions does the agency
make for translation/interpretation?
The City, through the Housing Initiatives Program, ensures that subrecipients
comply with statutory and regulatory requirements by means of:
- Contracts between the City and subrecipients.
- Annual review of audits
and project financials.
- Review of income eligibility - as established by the
U.S. Department of Housing & Urban Development (HUD) - of beneficiaries.
- Review of continuing affordability as established by HUD and by the Community
& Economic Development office policy.
- Review to ensure that no permanent
displacement of current occupants results from the investment of CDBG, HOME
and/or Burlington Housing Trust Fund money in a given project.
- Review of
annual income certifications as required by HUD.
- Review of financial
statements and the project pro formas for nonprofit and for-profit borrowers,
and a review of assets and management performance for for-profit landlords.
- Review to ensure that property taxes are current.
- Title searches for loans
exceeding $2,000.
- Mortgages and housing subsidy covenants containing home
restrictions for all loans.
- Appraisals or recent City tax assessment for all
loans.
- Record of compliance by the applicant in meeting fair housing
standards and City ordinances.
- For for-profit landlords, the loan to value
after rehabilitation must be no more than 90%. (Home buyers, homeowners,
nonprofit organizations and limited equity cooperatives may be allowed to go as
high as 100%).
- Debt services coverage ratio for for-profit landlords must be
1:1 or better
- Loans/grant amounts may not exceed more than $30,000 per unit,
although exceptions may be granted on a case-by-case bases. No single loan/grant
may exceed 50% of the annual HOME allocation.
- Rehabilitation standards
require that all buildings containing assisted units conform to Burlington's
minimum housing code and to HUD's housing quality standards. In addition, cost
effective energy conservation improvements may be required.
- Bidding by
contractors in accordance with federal, state and City requirements.
- Lead
paint hazard assessment and abatement through the Vermont Housing &
Conservation Board's Lead Paint Reduction Program.
- Professional asbestos
abatement where there is an obvious hazard of friable asbestos, pipe lagging, or
an asbestos-insulated heating plant.
- Level 1 site assessment where there is
reason to believe that a hazard may exist.
Page last updated May 13, 2003
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