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2018-128A
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2018-128A
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Last modified
12/30/2020 12:52:10 PM
Creation date
8/3/2018 2:01:26 PM
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Official Documents
Official Document Type
Grant
Approved Date
07/10/2018
Control Number
2018-128A
Agenda Item Number
10.A.1.
Entity Name
Department of Economic Opportunity (DEO)
Subject
Community Development Block Grant (CDBG), Housing Assistance Plan
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potential or real conflict as described in 24 C.F.R.570.489 (h)(2), is given final <br />approval for participation the County must notify FDEO in writing. Prior to the <br />expenditure of housing grant funds, the County must receive written <br />notification of FDEO's approval of the waiver of conflict of interest, in <br />accordance with C.F.R. Section 570.489 (h)(4). If this process is not followed <br />the County and/or the Applicant may be liable for returning the funds <br />expended to the program. <br />County employees that submit an application for rehabilitation assistance and <br />who are involved in the decision making process related to the CDBG <br />program or are involved in the financial approvals of this program must <br />identify their conflict of interest at the time of application. <br />The Federal requirements are found in 24 CFR 85.36 (b) (3) and 24 CFR <br />570.489(h). The State of Florida requirements are found in Chapter 112.311 — <br />112.3143 of the Florida Statutes. A Conflict of Interest is defined as a <br />relationship or circumstances whereby a person or organization exercises <br />functions or responsibilities for funded activities through which they, their <br />relatives, or know associates obtain or appear to obtain a financial benefit. <br />Two types of conflicts are noted, those being beneficiary and procurement. <br />1. A beneficiary conflict of interest would involve any direct benefit, such as <br />housing rehab, utility hook-up or fagade renovation. The conflict would <br />occur when benefits are awarded to anyone with a role in the CDBG and <br />or DRI program approval process, to include but not limited to, a member <br />of a CATF, PA, County officials and Commission members. There are <br />however exceptions to this rule which are explained in 24 CFR 570.611 <br />(d). To request a waiver, the Applicant through the HRS and PA must be <br />submitted in writing to the County for approval, who must then submit the <br />request to FDEO for final approval. Any costs incurred prior to FDEO <br />approval are unallowable. There are no retroactive waivers. <br />2. A procurement conflict of interest exists if there appears to be a <br />relationship between a funded activity and County officers, their <br />employees or agents, any member of their immediate family or any <br />organization that employs or is about to employ, any of the afore- <br />mentioned individuals. This conflict covers all aspects of the procurement, <br />from solicitation, to award, to administration to include the writing of the <br />Applicant Selection Criteria and in the Priority of Assistance, evaluating <br />proposals and negotiating terms. The affected person must not participate <br />in the procurement process in any manner; the level of conflict is <br />irrelevant. Any conflict or appearance of a conflict requires non - <br />participation. A procurement conflict cannot be waived. <br />4. Fair Housing (See the County's Fair Housing Policy) <br />The County and all its Contractors, Consultants and vendors receiving CDBG <br />and/or DRI grant funds shall comply with Title VIII of the Civil Rights Act of <br />[to] <br />
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