Res 2021-064/approving Substantial Amendment No. 10 to the Community Development Block Grant-Disaster Recovery (CDBG-DR) Action Plan

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of federal dollars. The City will develop monitoring mechanisms and compliance guidelines the make sure that all assisted applicants and property owners comply with flood insurance requirements. A. Quality Assurance Plan The City plans to remain in compliance with applicable CDBG-DR rules, regulations and requirements, including non -duplication of benefits. The City staff and Program Manager staff will monitor the compliance of applicants. The City will also build monitoring components within all contracts executed with vendors — professional services and construction contractors. Program staff will provide a Quality Assurance / Quality Control function that will serve as an internal checks -and- balance. Upon identification of priorities and activities the City will undertake as identified in the Action Plan, the City will devise a Quality Assurance Plan. The Quality Assurance Plan will outline the activities that will be monitored and the compliance parameters for each activity, including frequency of monitoring. The City envisions that it will monitor project activities no less than quarterly to certify compliance and timely expenditure of funds. The plan will also include ongoing completeness reviews of project files to confirm adequate documentation, accounting reviews of cost documentation to certify accuracy of all expenditures, compliance reviews for Fair Housing and Equal Opportunities laws, Section 504, Lead Based Paint, Davis- Bacon Standards, Environmental Standards and other rules or guidelines as applicable. B. Duplication of Benefits Duplication of Benefits (DOB) is strictly prohibited. In general, Section 312 of the Robert T. Stafford Disaster Assistance and Emergency Relief Act (42 U.S.C. 5155), as amended, prohibits any person, business concern, or other entity from receiving financial assistance with respect to any part of a loss resulting from a major disaster as to which he/she has received financial assistance under any other program or from insurance or any other source. In order to comply with this law, the City will require that each activity provides assistance to a person or entity only to the extent that the person or entity has a disaster recovery need that has not been met. Further explanation of the duplication of benefits requirements can be found in Federal Register notice 76 FR 71060 (published November 16, 2011). To avoid DOB, housing awards will be reduced by the following if such benefits were or will be paid to the household toward any of the activities included in the housing award: • Federal Emergency Management Agency (FEMA) grants; • Small Business Administration (SBA) loans identified by SBA; and • Homeowner Insurance (HOI) proceeds • National Flood Insurance Program (NFIP) • Amounts received from other funding sources, such as non-profit entities, in which the intent of the funding has been identified as duplicative FEMA, SBA, HOI, and NFIP are considered to be a DOB and will be deducted from the construction starting values if the aforementioned assistance was not utilized/spent as it was intended by FEMA, SBA, Last Updated 3/03/20 Page 45 of 63