Comment Submitted by Amber Lewis, Iowa Finance Authority

Regarding the proposed 60-day obligation requirement. As the state grantee for ESG, we grant funds directly to service providers. This helps to serve the significant rural portions of Iowa, helps ensure consistency in program implementation, and reduces the administrative layers that would exist if we instead granted out all funds to local government agencies for later distribution. However, this also makes the 60-day obligation requirement extremely tight, since we hold a competition for these funds and typically receive about 120 requests. Our request is that if a state government agency is distributing funds directly to service providers, could it follow the 120-day obligation schedule proposed in the regulations for intermediary local government agencies, rather than the 60-day schedule?