Arkansas Administrative Code › Agency 109 - Arkansas Development Finance Authority › Division 04 - Multi-Family Housing › Rule 109.04.10-004 - Compliance Monitoring Policies and Procedures for the HOME Program

Current through Register Vol. 49, No. 6, June, 2024
Chapter 1
: HOME Monitoring Basics
Section 1.
What is Monitoring?
Monitoring refers to the process and tools that HOME
				participating jurisdictions (PJs), including ADFA, use to ensure that
				compliance is achieved and maintained. Monitoring can be done internally to
				ensure that an organization itself is in compliance and it can be external,
				involving various types of reviews of organizations and projects typically
				using monitoring tools such as checklists. The end result of monitoring is an
				understanding of which areas are in compliance with applicable rules and
				requirements and which are not.
A.
Parties to Monitor
It is ADFA's responsibility to monitor all entities that
				receive HOME funds (generally referred to as Recipients). The various
				Recipients ADFA must monitor include the following:
> State Recipients.
State Recipients are units
				of local government designated by ADFA to receive HOME funds from its HOME
				allocation. ADFA, as the State PJ, is responsible for monitoring its State
				Recipients. State Recipients are monitored for administrative, financial,
				program, and project-related compliance.
> Subrecipients.
Subrecipients are public
				agencies or nonprofit organizations selected by ADFA to administer HOME Program
				activities. Subrecipients may be other public agencies, public housing
				authorities or nonprofit organizations. State recipients that receive funds are
				also considered subrecipients. Subrecipients are monitored for administrative,
				financial, and program and project-related compliance.
> Community Housing Development Organizations (CHDOs).
CHDOs are special nonprofits that own, sponsor, and/or develop
				affordable rental or homebuyer housing under minimum of 15 percent of ADFA's
				HOME Program funds. To be considered a CHDO, the nonprofit must meet certain
				qualifying criteria. CHDOs are not subject to Federal uniform administrative
				requirements, except for §84.21 which dictates general financial
				management standards. Finally, they are eligible for operating assistance and
				pre-development loans. ADFA is required to monitor CHDOs for all of the
				above.
> Owners, Developers, and Sponsors.
Owners/developers/sponsors may either be for-profit or nonprofit
				organizations that receive funds to undertake affordable housing projects. They
				do not administer programs, but simply receive HOME funds to develop a project.
				If they are not CHDOs, they are monitored for compliance with project activity
				requirements only. ADFA and its Recipients monitor developers, owners, and
				sponsors, and primarily focus on performance and regulatory compliance
				(including eligible costs, labor standards, etc.). These entities differ
				slightly from CHDOs, but some of the same monitoring occurs.
> Contractors.
Contractors are entities that
				are competitively procured to carry out a specified scope of work for a
				specified price. They can administer programs and/or provide necessary goods
				and services to ADFA or one of ADFA's Recipients. Contractors must maintain
				records and reports demonstrating compliance with HOME Program regulations and
				written agreements. ADFA monitors contractors for performance under agreements
				as well as compliance with applicable requirements.
Exhibit 1-1: ADFA Monitoring
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