When were CSLFRF funds received by recipients? Is there a date by which these funds must be allocated/used?

The U.S. Department of the Treasury’s (“Treasury”) Final Rule provides guidance for municipalities’ receipt and use of Coronavirus State and Local Fiscal Recovery Funds (“CSLFRF”).  Treasury’s CSLFRF website lists allocations to municipalities, as well as Treasury’s methodology used to determine allocated amounts. Treasury also clarifies on the CSLFRF page of its website how CSLFRF funds will flow to each level of government:

Local governments will receive funds in two tranches, with 50% provided beginning in May 2021 and the balance delivered approximately 12 months later. States that have experienced a net increase in the unemployment rate of more than 2 percentage points from February 2020 to the latest available data as of the date of certification will receive their full allocation of funds in a single payment; other states will receive funds in two equal tranches.[1]

The Final Rule clarifies that Treasury “expects to make all second tranche payments to states available beginning 12 months from the date that funding was first made available by Treasury (May 10, 2021) regardless of when each individual state submitted its initial certification.”[2] To qualify for the second tranche payment, Treasury requires that states certify for this payment and file all required reports.[3]

Use of CSLFRF Funds

Regarding the timeline for the use of CSLFRF funds, the Final Rule sets forth an obligation period and an expenditure period:

The deadline for costs to be incurred – which the final rule clarifies means obligated December 31, 2024, is specified in the [ARP]statute, and Treasury will retain December 31, 2026, as the end of the period of performance to provide a reasonable amount of time for recipients to liquidate obligations incurred by the statutory deadline.[4]

Funds must be obligated by December 31, 2024, with the period of performance for projects and expenditures extending until December 31, 2026.[5]