Comment Submitted by Gail Hammond, NYS Housing Trust Fund Corporation - Office of Community Renewal

The current and proposed program income requirements are very burdensome and create inefficiencies for states. Tracking program income for the life of the program income is not an efficient or effective way for states to spend their already limited administrative and financial resources nor is it the best way for HUD to track funds and the accomplishments of CDBG funding. States could spend months and years trying to capture information from grantees that no longer have grants with the state, yet they have program income at a level that narrowly exceeds the threshold. Reporting on program income for an unspecified period of time is a waste of resources. Additionally, a conditional closeout process would prevent states from formally closing out a grant year with HUD. This would be another administrative nightmare for the states as well as HUD. Allowing states the authority to capture all program income or a portion thereof for reallocation to eligible CDBG projects is a more efficient way to track funds and their accomplishments. Program income should be re-granted as a new grant to new or existing grantees. States should have the authority to develop new and innovative programs that best meet the needs of the State and units of local governments. These grants would be tracked and reported in the same manner as any CDBG project. These program income requirements do not support our County’s efforts to conserve and the Federal governments Paperwork Reduction Act. To reiterate, our recommendation is for the states to determine the best way to track and report program income, which may be to recapture all or a portion of program income for reallocation to new projects and or grantees. States should be provided the flexibility to determine the best method to address program income, which could be one of the following: 1. Request all program income be returned to the state, which would be those funds that have exceeded the threshold. 2. Request all income generated from grants returned to the state (funds less than $50,000). 3. Request income generated that exceeds a certain amount (defined by the state) returned to the state.