accounts (e.g. separate bank accounts for IHBG vs. ICDBG funds etc.) Recommendations: If you are a pass through entity, assess the financial management standards you require of subrecipients to ensure you do not require them to establish separate depository accounts when they have sufficient accounting systems to account for the receipt, obligation and expenditure of funds. Banking §200.305 Payment Implications: Standards – Interest Retained (8) … must maintain advance payments This is new language for HUD/ONAP recipients. Threshold of Federal awards in interest-bearing Also, the Uniform Guidance increases the accounts, unless the following apply: threshold for retained interest from $100 to $500. Total federal awards for year are less than $120,000, or Recommendations: Anticipated interest earnings are less than $500 per year, or Evaluate current accounting procedures and management systems to determine if Minimum balance requirements of sufficient controls are in place to ensure on bank make it not feasible, or going compliance with this requirement. A foreign government or banking system precludes interest bearing accounts. ALSO: (9) …Interest earned amounts up to $500 per year may be retained for administrative expenses. Program Income §200.307 Implications: Per the program specific requirement at Recipients of ICDBG funds should be aware that 24 §1000.26(a)(5) this section of the there are significant modifications of the Uniform Guidance does not apply to the definition and use of program income specified IHBG program in §1003.503. Per program specific requirement at 24 Recommendation: CFR §1003.501(a)(3) this section does Evaluate current accounting procedures and apply to the ICDBG program as modified management systems to determine if by §1003.503. sufficient controls are in place to ensure on going compliance with this requirement. Equipment Title §200.313 Equipment Implications: (a) Title. This is new language for HUD ONAP recipients …Unless a statute specifically authorizes introducing the term “conditional title.” the Federal agency to vest title in the However, COFAR FAQ .313-1 clarifies that “… non-Federal entity without further there is no change intended in the Uniform obligation to the Federal government, Guidance for how non-Federal entities should
accounts (e.g. separate bank accounts for IHBG vs. ICDBG funds etc.) Recommendations: If you are a pass through entity, assess the financial management standards you require of subrecipients to ensure you do not require them to establish separate depository accounts when they have sufficient accounting systems to account for the receipt, obligation and expenditure of funds. Banking Standards – Interest Retained Threshold §200.305 Payment (8) … must maintain advance payments of Federal awards in interest-bearing accounts, unless the following apply: Total federal awards for year are less than $120,000, or Anticipated interest earnings are less than $500 per year, or Minimum balance requirements of bank make it not feasible, or A foreign government or banking system precludes interest bearing accounts. ALSO: (9) …Interest earned amounts up to $500 per year may be retained for administrative expenses. Implications: This is new language for HUD/ONAP recipients. Also, the Uniform Guidance increases the threshold for retained interest from $100 to $500. Recommendations: Evaluate current accounting procedures and management systems to determine if sufficient controls are in place to ensure on going compliance with this requirement. Program Income §200.307 Per the program specific requirement at 24 §1000.26(a)(5) this section of the Uniform Guidance does not apply to the IHBG program Per program specific requirement at 24 CFR §1003.501(a)(3) this section does apply to the ICDBG program as modified by §1003.503. Implications: Recipients of ICDBG funds should be aware that there are significant modifications of the definition and use of program income specified in §1003.503. Recommendation: Evaluate current accounting procedures and management systems to determine if sufficient controls are in place to ensure on going compliance with this requirement. Equipment Title §200.313 Equipment (a) Title. …Unless a statute specifically authorizes the Federal agency to vest title in the non-Federal entity without further obligation to the Federal government, Implications: This is new language for HUD ONAP recipients introducing the term “conditional title.” However, COFAR FAQ .313-1 clarifies that “… there is no change intended in the Uniform Guidance for how non-Federal entities should
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