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INDIAN RIVER COUNTY HOUSING COMMUNITY DEVELOPMENT BLOCK GRANT (CDBG) CONFLICT OF INTEREST FORM FFY-2017 PURPOSE: CDBG regulations require Conflict of Interest identification between the Board of County Commissioners (BOCC), Citizens Advisory Task Force (CATF) members, and applicants seeking to utilize CDBG funding for housing rehabilitation assistance. The adherence to the rules and regulations in regard to Conflict of Interest is mandatory. All Applicants that may have a business or familial relationship with a member of the County Commission, CATF, Housing Rehabilitation Specialist (HRS), Program Administrator (PA), or participating construction contractors must fully disclose this relationship on the Application... Applicant names must be disclosed at the regular meeting of the Board of County Commission and the CATF as the application process proceeds and these names must be included in the minutes of both the County Commission and the CATF meetings. County Commission and CATF members must disclose any relationship with an Applicant and must abstain from any vote related to that Applicant. County employees that submit an application for rehabilitation assistance and who are involved in the decision-making process related to the CDBG program or are involved in the financial approvals of this program must identify their conflict of interest at the time of application. Any cases of conflict of interests must be made known at a meeting of the County Commission. Before an Applicant with a potential or real conflict as described in 24 C.F.R.570.489 (h)(2), is given final approval for participation the County must notify FDEO in writing... If this process is not followed the County and/or the Applicant may be liable for returning the funds expended to the program. CONFLICT OF INTEREST DEFINITIONS: The Federal requirements are found in 24 CFR 85.36 (b) (3) and 24 CFR 570.489(h). The State of Florida requirements are found in Chapter 112.311 — 112.3143 of the Florida Statutes. A Conflict of Interest is defined as a relationship or circumstances whereby a person or organization exercises functions or responsibilities for funded activities through which they, their relatives, or know associates obtain or appear to obtain a financial benefit. Two types of conflicts are noted, those being beneficiary and procurement. 1. A beneficiary conflict of interest would involve any direct benefit, such as housing rehab, utility hook-up or fagade renovation. The conflict would occur when benefits are awarded to anyone with a role in the CDBG and or DRI program approval process, to include but not limited to, a member of a CATF, PA, County officials and Commission members. There are however exceptions to this rule which are explained in 24 CFR 570.611 (d). To request a waiver, the Applicant through the HRS and PA must be submitted in writing to the County for approval, who must then submit the request to FDEO for final approval. Any costs incurred prior to FDEO approval are unallowable. There are no retroactive waivers. 2. A procurement conflict of interest exists if there appears to be a relationship between a funded activity and County officers, their employees or agents, any member of their immediate family or any organization that employs or is about to employ, any of the afore -mentioned individuals. This conflict covers all aspects of the procurement, from solicitation, to award, to administration to include the writing of the Applicant Selection Criteria and in the Priority of Assistance, evaluating proposals and negotiating terms. The affected person must not participate in the procurement process in any manner; the level of conflict is irrelevant. Any conflict or appearance of a conflict requires non -participation. A procurement conflict cannot be waived. Page 1 of 2