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American Rescue Plan Act, CSLFRF, HUDAre there forms for tracking, contracting and reporting on ARPA funds used to create loans for Affordable housing?
The U.S. Department of the Treasury (“Treasury”) Coronavirus State and Local Fiscal Recovery Fund (“CSLFRF”) Final Rule includes considerable regulatory reference to the U.S. Department of Housing and Urban Development (“HUD”) and HUD provisions, which reflects that Treasury anticipated the use of CLFRF funding for affordable housing projects and programs.[1]
Collaboratively, Treasury and HUD developed an affordable housing guide which may provide additional insight and direction regarding the administration of affordable housing projects which utilize ARPA funding.[2]
However, for reporting purposes, Treasury and HUD provide guidance independent of one another to entities requiring direction about the use of CLFRF to support affordable housing loan programs and projects.
In the CSLFRF Compliance and Reporting Guidance, Treasury provides specific, programmatic, and reporting requirements for housing-related expenditures under Negative Economic Impacts, categories 2.15 through 2.18.[3] Additionally, the CSLFRF Project and Expenditure Report User Guide provides access to and instructions for use of Treasury reporting templates, including the Bulk Upload Template for the expenditure categories referenced above can also be found in the user guide.[4]
There are no Treasury-issued, CSLFRF-specific housing project forms outside of those which are contained in Treasury’s reporting portal to be used specifically for portal data submission. Municipalities which utilize HUD funding for affordable housing projects, should consult all appropriate HUD resources including consulting their HUD representative for official reporting guidance.
Last Updated: June 22, 2023
[1] Treas. Reg. 31 CFR 35, available at: https://home.treasury.gov/system/files/136/SLFRF-Final-Rule.pdf.
[2] Department of Treasury, Affordable Housing How-To Guide: How to Use State and Local Fiscal Recovery Funds or Affordable Housing Production and Preservation (as of July 2022), available at: https://home.treasury.gov/system/files/136/Affordable-Housing-How-To-Guide.pdf.
[3] Department of Treasury, Compliance and Reporting Guidance: State and Local Fiscal Recovery Funds, (as of June 6, 2023), at 33 available at: https://home.treasury.gov/system/files/136/SLFRF-Compliance-and-Reporting-Guidance.pdf.
[4] Department of the Treasury, Project and Expenditure Report User Guide: State and Local Fiscal Recovery Funds (as of January 24, 2023), at 49, available at: https://home.treasury.gov/system/files/136/Project-and-Expenditure-Report-User-Guide.pdf.