Comment Submitted by Lloyd Schmeidler (3rd Comment)

Re. matching provisions for the ESG grants: I would encourage HUD to require that recipients make a minimal match, e.g. 25%, of ESG grants, if they disburse the funds to sub-recipients. I believe doing so could increase the recipients’ investment in implementing strong ESG programs to benefit homeless people and strengthen the partnership between HUD, the recipient, and any sub-recipients. This also could result in an overall increase in funds available for ESG activities, if recipients were allowed to continue to require sub-recipients to match funds they receive up to 100%. For example, if recipients matched an ESG grant to 25% of it, and sub-recipients were required to match 100% of a sub-recipient grant, the total amount spent on ESG activities would be 250% of the HUD ESG allocation, not 200% as is now the case. Such matching requirements could be helpful, too, during this time when the ESG eligible activities are being expanded to include homeless prevention and rapid rehousing work.