Reporting Requirements: 11.3 Maintaining Records

Grantees must establish a system for record keeping that assists CDFA with the review of files for compliance. In other words, records should be kept in a manner that clearly tells the whole story of a Community Development Block Grant (CDBG) project from beginning to end.

The grantee is responsible for maintaining all records pertinent to a grant, including supporting documentation, for three years after the date CDFA closes out the applicable program year with HUD.
Because this required record retention period could exceed ten years, the CDFA will notify grantees when a program year has been closed with HUD and include the end date of the record retention period.
This chapter identifies major file categories and the materials that should be maintained in each file. This list is not all-inclusive; therefore, refer to applicable laws and regulations as well as the other chapters for more detailed information.

The following suggestions are provided as procedural guidelines to be considered when designing a grantee’s filing system:

  • Separate files should be maintained for each grant contract
  • Files should be coded for each area of compliance to allow for easier access
  • Responsibility for file-keeping should be delegated to a specific individual to provide consistency
  • Files should be secured at all times


11.3.1 Application and Grant Contract File

  • Copy of original application
  • Grant Agreement
  • All correspondence/info prior to the signing of the grant agreement, including comments from other state agencies application/project revisions (if applicable)
  • Approved Implementation Plan and Budget (and evisions)


11.3.2 National Objectives
Grantees must maintain records that funded activities meet one of the national objectives. Depending on the objective, the files must contain the specific documentation below. This documentation can also be used in reporting performance measures information.

  • Low/Mod Area Benefit
  • Boundaries of service area
  • Census data including total persons and percentage low/mod
  • Evidence area is primarily residential
  • Survey documentation (if applicable)
  • Low/Mod Limited Clientele
  • Documentation that the beneficiaries are low/mod or presumed to be low/mod (by category)
  • Low/Mod Housing
  • Income verification of households (using the Section 8 definition) including source documentation
  • Low/Mod Job Creation and Retention
  • Number of jobs created or retained
  • Type and title of jobs created or retained
  • Income of persons benefiting from the jobs created or retained
  • Slum and Blight
  • Area designation (e.g., boundaries, evidence area meets State slum/blight requirements)
  • Documentation and description of blighted conditions (e.g., photographs, structural surveys, or development plans)
  • If applicable, evidence that the property meets spot designation requirements (e.g., inspections)
  • Urgent Need
  • Documentation of threat to health and safety
  • Documentation of recent origin
  • Certification that other financing resources were unavailable and CDBG had to be used (including ability to borrow, etc.)


11.3.3 Citizen Participation File

  • Citizen Participation Plan (and Housing and Community Development Plan)
  • Evidence that citizens were furnished appropriate information (as required in application process)
  • Publishers Affidavit or tear sheet of the notices of public hearings
  • Minutes from both public hearings
  • Citizen outreach techniques, including evidence of marketing effort for direct benefit activities such as housing rehabilitation
  • Citizen complaints and relevant correspondence (if applicable)


11.3.4 Environmental Review Record (ERR)
For all projects:

  • Scope of Work for Project/Activity
  • Copy of any environmental studies (e. g. archaeological surveys, etc.)
  • Copy of all maps and drawings, if any
  • Copy of signed Request for Release of Funds (RROF), if any
  • Copy of Authority to Use Grant Funds – release of funds from CDFA, if any


Exempt and Categorically Excluded Not Subject To (CENST) Activity Projects

  • Copy of the signed Environmental Review for Exempt or CENST Activity


Categorically Excluded Subject To (CEST) Projects

  • Copy of signed Environmental Review for CEST Activity and supporting documentation (including written determinations from relevant agencies such as SHPO and NH Department of Environmental Services)
  • Copy of all consultation letters and responses
  • Copy of Floodplain Process documentation (if applicable)
  • If CEST activity converts to Exempt (skip all below)
  • Copy of the Notice of Intent to Request Release of Funds (NOI/RROF) advertisement (and Floodplain if applicable)
  • Copy of Publishers Affidavit for Floodplain NOI/RROF
  • Copies of any letters received and responses following the NOI/RROF


Environmental Assessment Projects

  • Copy of Determination of Environmental Assessment Form and supporting documentation (including written determinations from relevant agencies such as SHPO and NH Department of Environmental Services)
  • Copy of all consultation letters and responses
  • Copy of Floodplain Process documentation (if applicable)
  • Copy of the Combined Notice of Intent with “Finding of No Significant Impact” (FONSI) advertisement (and Floodplain if applicable)
  • Copy of Publishers Affidavit for Floodplain / NOI/ROFF / FONSI
  • Copies of any letters received and responses following the NOI/RROF/FONSI


11.3.5 Fair Housing & Civil Rights

  • Local Fair Housing Resolution
  • Documentation of completion of the required Fair Housing Activity
  • A copy of the provisions for nondiscrimination given to developers, contractors, etc.
  • Demographic statistics on all beneficiaries and denied applicants of site-specific activities (i.e., housing rehab)
  • Documentation that contractors complied with the Civil Rights/Equal Employment requirements as explained at the Pre-Construction Conference
  • Documentation of all other efforts to further local fair housing and equal opportunity


11.3.6 Financial

  • Cash Receipts Journal
  • Cash Disbursement Journal
  • General Ledger
  • Property Management Register
  • Subsidiary Ledger on Rehabilitation Loans
  • Journal Entry Voucher (optional)
  • Federal Cash Control Register (optional)
  • Expenditure Summary Report (optional)

Payment File

    • Copies of all Contractor/Consultant/Vendor Invoices
    • Copies of Payment Requests in Chronological order
    • Approved Cost Summary (and revisions)
    • Authorized Signature for Request for Payment form
    • Original Project Expenditure Account Agreement

Audit File

        • Copy of Audit Reports (if applicable)
        • Responses to Audit Findings (if applicable)


11.3.7 Procurement
All Procurements utilizing CDBG funds

        • Documentation of Cost Reasonableness Estimate for all procurements
        • Copy of the Contractor/Subcontractor Verification form (not debarred)


        • Copy of Request for Quotation (RFQ) (email, telephone notes, etc.)
        • Documentation of Notice/Solicitation for M/WBE participation and amounts procured
        • Documentation of all quotes received
        • Justification of selection

Professional Services

        • Copy of the Request for Proposal (RFP) or Request for Qualifications (RFQ)
        • Copy of the RFP/RFQ newspaper advertisement
        • Documentation of notification/solicitation for M/WBE participation
        • M/WBE contracts and amounts procured
        • List of companies who submitted Statements of Qualifications or Proposals
        • RFP/RFQ evaluation and scoring documents
        • List of short-listed firms and documentation of interview process
        • Short-listed firms evaluation and scoring documents
        • Justification for selection of contractor

Construction and Related Services

        • Copy of Invitation for Bid (IFB)
        • Copy of IFB newspaper advertisement
        • Section 3 Plan
        • Certified mail receipts from M/WBE and Section 3 firms
        • M/WBE and Section 3 contracts and amounts procured
        • Minutes from public meeting where IFB’s were opened
        • Copy of the bid tabulation sheet, certified by the project architect/engineer
        • Justification of selection


11.3.8 Contract File
Professional Services

        • Notice of Contract Award
        • Copy of Contract with the required federal contract provisions (outlined in the CDFA Grant Agreement)
        • Disclosure Report for each contract

Construction – Related Services

        • Notice of Contract Award
        • Copy of Contract with the required federal contract provisions (outlined in the CDFA Grant Agreement)
        • Copy of the Pre-construction Meeting Checklist – signed by all attendees
        • Copy of the Bid Guarantee
        • Copy of the Performance Bond
        • Copy of the Payment Bond
        • Copy of contractor(s) insurance policy
        • Disclosure Report for each contract
        • Proof of the established Retainage Account (if applicable)
        • Documentation on all Change Orders


11.3.9 Acquisition and Relocation Files
A separate file must be maintained for each property acquired and must include:

        • Property owner name and address
        • Address of property to be acquired
        • For property valued under $10,000, a copy of market estimate and document real estate broker’s license
        • Document Appraiser’s license and certification (when applicable)
        • Preliminary Acquisition Notice to Owner Invitation to accompany appraiser Appraisal Reports
        • Review of Appraisal
        • Copy of written purchase offer
        • Purchase agreement
        • Copy of donation/waiver forms (if applicable)
        • The deed to the property to be acquired
        • All notices sent to property owner, business owner(s), and tenant(s), if any

Replacement Units

        • Copy of Notice to HUD and public that documents the number and nature of replacement housing units required by Section 104(d) due to demolition or conversion of low-income housing units
        • One Replacement Summary Grantee Performance Reports
        • Documentation of local housing needs if replacement includes smaller units than those demolished or converted

A separate file must be maintained for each household relocated and must include:

        • A household survey, which should include the names, ages and demographic information (including income verification) of the household to be relocated
        • A description of the nature of the advisory services offered, including the dates they were offered and any brochures or pamphlets explaining their rights
        • Evidence of correspondence concerning the rights and payments available to displaced persons
        • 90 day advance Relocation Notice (and evidence of delivery)
        • 30 day Displacement Notice (and evidence of delivery)
        • Evidence of at least three referrals to comparable units and Comparable Replacement Dwelling (HUD Form 40061)Inspection report on referral units

Documentation on the types and amounts of benefit payments made, including:

        • Claim for Rental Assistance or Down Payment Assistance (HUD Form 40058)
        • Residential Claim for Moving and Related Expenses (HUD Form 40054)
        • Claim for Temporary Relocation Expenses-Residential Moves (HUD Form 40030)
        • Claim for Replacement Housing Payment for 90-Day Homeowner-Occupant (HUD Form 40057)
        • Claim for Actual Reasonable Moving and Related Expenses –Nonresidential (HUD Form 40055)
        • Claim for Fixed Payment in Lieu of Payment for Actual Nonresidential Moving and Related Expenses (HUD Form 40056)
        • Evidence that payment was made (canceled check or the like) and payment schedule
        • All notices sent to property owner, business owner(s), and tenant(s) if any.


11.3.10 Labor Standards

        • Copy of Wage Determination Notice
        • Copy of Wage Determination Lock-in Notice
        • Justification of Wage Determination effective other than at bid opening (if applicable)
        • Copy of Pre-Bid Conference Sign-in sheet (if applicable)
        • Copy of the construction-related contract(s) with the HUD 4010 form and Federal Construction Contract Provisions referenced or attached
        • Copy of the Pre-Construction Conference Checklist – signed by all attendees
        • Copy of contractor(s) fringe benefit programs
        • Copy of any apprenticeship certification programs, if applicable
        • Copy of Contractor(s) Certification forms, if applicable
        • Copy of Subcontractor(s) Certification forms, if applicable
        • Copy of all weekly Certified Payroll Reports for contractor(s)/subcontractor(s) and any Correction Certified Payroll Reports
        • Copy of all employee interviews
        • Documentation of any wage deficiencies and copies of restitution payments, ifany, including employee-signed affidavits acknowledging receipt of restitution.
        • Copy of any Section 5.7 Enforcement Reports (if applicable)
        • Copy of all Semi-Annual Labor Standards Enforcement Report – HUD Form 4710
        • Section 3 Resident employment records


11.3.11 Reporting File

        • Copies of CDFA Semi-Annual Progress Reports
        • Copy of HUD Disclosure Form 2880 Updates (if applicable)


11.3.12 Monitoring File and Closeout

        • Closeout Certification and Documentation Form
        • Closeout Agreement
        • CDFA monitoring letter
        • Evidence of corrective actions in relation to CDFA findings (if applicable)
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