1. #1
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    Question Use CDBG Funds for Local Match?

    Dear Kurt, Alana, and Brian,
    As the top 3 Fire Grant Gurus in the U.S., I would like to know each of your opinions on whether or not there is anything wrong with a city using some of the money out of its Community Development Block Grant (CDBG) funds to pay for its share of the FIRE Act's requirement's for the awarded city's Local Matching amount?

    [90% Federal contribution share, & 10% Local contribution share is what a city our size is required to pay if awarded; and we were, this year.]

    If it's O.K. to do that, then the city wouldn't really be out any moneys of its own, and no locals (citizens or politicians) could object to this award. Please let me know what the rules are for maybe doing something like this.
    Thank You.
    -Matt

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    Here's a definition used by the AFG for non-federal funds that may be of help.

    Non-Federal Funds - Financial resources provided by sources other than the Federal Government. The term does not include funds provided to a State or local government through a Federal grant, unless the authorizing statute for that grant explicitly allows the funds to be used as a match for other Federal grants.

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    CDBG grants are for specific projects for which a detailed grant app was submitted and approved. Funds are disbursed (- a holdback) to pay for expenses incured in completing the project (and you have to show you are simultaneously expending your required local matching $). How can you have "extra" laying around to spend on any old "other" project? Go to jail time.

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    Quote Originally Posted by neiowa
    CDBG grants are for specific projects for which a detailed grant app was submitted and approved. Funds are disbursed (- a holdback) to pay for expenses incured in completing the project (and you have to show you are simultaneously expending your required local matching $). How can you have "extra" laying around to spend on any old "other" project? Go to jail time.
    I'm pretty sure that neiowa is right. CDBG's come with some fairly tight definitions on usage. There MAY be SOME wiggle room if you were refurbishing your station as part of a downtown facelift....but even then it would need to be tied into the CDBG, and being that AFG's are few and far between in regards to building refurbishing, I can't really see where the connection could be made..... I'm pretty sure that your outta luck on this one.

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    Default A Little More Info On Cdbg's For You

    Excerpt from the HUD website regarding CDBG's....

    Eligible Activities
    Activities funded must be eligible and meet one of the three national objectives:

    benefit to low- and moderate-income persons,
    aid in the prevention or elimination of slums and blight, or
    meet other community development needs having a particular urgency because existing conditions pose a serious and immediate threat to the health or welfare of the community.
    Typically activities funded include: construction of public facilities and improvements, such as water systems, streets, and community centers; rehabilitation of houses and landmark structures; assistance to private, for profit entities to carry out economic development activities (including assistance to micro enterprises); and the provision of public services.

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    Matt,
    Your grant is for a Truck. Therefore, after emailing a few people, I really don't think this is going to work. First, like everyone else has said, the CDBG has SPECIFIC things in which your Community applied for. Unless they apply for an ammendment, there's not alot of lee-way in there for your town to just spend anyway they choose.

    Secondly, when your FD and Town answered the 10 Q's, they had to respond how they planned to meet the match. I'm pretty sure they didn't answer with CDBG funds. More than likely the answer was funds set aside from truck budget or budgeted funds, etc. (Like most departments answer). Funds coming from any other source will be inaccurate info given to them, and if and when (more than likely when, since you're getting an apparatus) they come out for the site visit, they will ask to see your files, etc.

    Your town needs to stick with funding the truck the way they stated in the Q's and how they originally planned to. Just not kosher to pull funding from one source, and pop it into another line item, and you can get into alot of trouble. Some grant programs do allow you to use other federal funding as a match, but UNLESS they specify this, and you have told them up front and both parties know, then it is not a good idea. I'd stay FAR FAR away from this one if I were you....wouldn't want my name on this one.

    *Besides, the point of a match is to show your town's commitment to the project and support of the grant. I don't think it looks good, personally. Just my opinion. YMMV-
    Alana Tomlin Denton
    Freelance Grant Writer/Consultant

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    It looks like it's already been taken care of, but just to lend another voice to it, no. You cannot use one grant's funds to pay for the matching on another. CDBG funds can be used to buy trucks, Houston just did. But these funds can't be used to match AFG. You can borrow from a bank, fundraise, sell investments, etc, etc, but you cannot use any other federal or state grant funds for matching.

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    Well better late than never.....

    Matt, as a prior student of mine I am quite sure you know that the answer to this question is a very strict " NO YOU CAN'T". That would be comingling of funds and not just get you in deep, deep ( read jail time) trouble here with USFA but, a second sentence for fraud from HUD. Having been a grants manager for a HUD agency, I can assure you that this is a prescription for disaster.

    This sounds more like an "inexpereinced Chief or City Manager" asking "what if's" and who has not had much experience in the world of Federal Grant Funding. You would be doing an extreme dis-service to them to not point this out to them, in no uncertain terms, immediately. Your truck was in in excess of $400K in grant funding and I suspect that your city will be in for an OMB133 audit before this next 12 months expires and I guarantee, this will trigger an IG visit and investigation.

    I would distance myself extremely far from any "administrative" actions such as this and paper your "you know what" with written official memos, warning them of the consequences of their actions.


    Fraudulent activity aside, this is bad for the program and all the fire service. What is being proposed has been done before and is part and partial of the reason for Congressional members screaming fraud and wanting to "86" this program.

    They need to buy what they said they would, pay what they said they would pay, or refuse the grant! A decision such as that will not only endanger your department's own chances at future participation in ANY Federal grant programs, but would be bad for the program and your brother departments as well.
    Kurt Bradley
    Public Safety Grants Consultant

    "Never Trade Skill for Luck"

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    Wink Thanks, Everyone.

    Thank you all for taking the time, as well as making the thoughtful efforts, and also for exercising due concern enough to respond to my question. I am personally grateful for the number of replies. Especially to Kurt, who invested considerable time and effort, for me, in his skillful guidance on this and other related matters over the last several days. Kurt, you're a prince Among men!

    However, I am rather puzzled that no one else in this thread thought to ask "Just what kind of townsfolk would have a problem with coming up with just 10% on their own for a half-million dollar truck, anyway?" Perhaps you were all just being too polite to ask. Or, maybe that thought was just beyond the realm of comprehension to any of us.
    Last edited by CptnMatt; 11-14-2005 at 01:27 PM.

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    You're not the first that's had this problem. I've gone to bat for several departments whose purse-string holders were tight after the award came out. I guess that none of them thought the department had a chance, so they thought it was a moot promise. Surprise!

    A bunch of SAFER awards were just put back into the pot for the same reason, to the tune of $4 million. No one could commit to the funding requirements. This is why you need to have the concrete support of the local govt before even submitting the apps, so there's no last minute running around.

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