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

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HOI, or NFIP. The amount of DOB will be obtained from the third party from whom the benefit is derived. In some cases, if after sufficient attempts it is considered unlikely to obtain and verify third party data, an affidavit or inspection may be used in its place as necessary. All applicable claims (including insurance payments, unpaid claims, lawsuits and settlements) paid to applicants not included in the original benefit determination calculation and/or after their closing appointment, must be subrogated to the CDBG Disaster Recovery Program to prevent a duplication of benefits. In addition, documentation of possible duplication of benefits must be included in each applicant file even if no funds were received from FEMA, SBA, HOI, NFIP or any other source. A copy of this documentation must be provided to the CDBG Disaster Recovery Program as part of the application documentation. All applicants will be required to sign a Subrogation agreement upon application to the program. Applicant awardees must subrogate any additional funds received for damage caused by the flood disaster back to the City. CDBG-DR funding must be funding of last resort and if additional funds are paid to applicant awardees for the same purpose as the housing assistance award they receive through City CDBG-DR funding (i.e., repair or replacement of the damaged structure) after the City has completed repair/rehabilitation project of the housing unit, those funds must be returned to the City of San Marcos. DOB includes any payments or potential payments made to the grantee by identified parties that represent disaster assistance for activities reimbursable by, or for which funds are made available for the same loss that the CDBG Disaster Recovery Program is providing assistance, which is not limited to flooding recovery payments. Any portion of the DOB that has been determined to be funds spent by the grantee on "Allowable Activities" will reduce the amount considered to be a DOB. The CDBG Disaster Recovery Program should receive, as part of the grantee file, documentation of a review of possible duplication of benefits from sources such as FEMA, SBA and HOI, among others. This review extends to instances where no funds were received. C. Internal Audit Policy To ensure that fraud, waste, and misuse of funds does not occur, effective controls will be in place and monitored for compliance. Part of that control process includes the City hiring an internal auditor to perform independent audit functions for the CDBG Disaster Recovery Program. The internal auditor will audit the disaster funds to certify that all expenditures are for eligible CDBG Disaster Recovery uses as defined in 24 CFR 570. Audit results will be reported directed to the City Council. An independent single audit, as required by 2 CFR 200, will be conducted annually to certify that all grant funds are used in accordance with program requirements. °�°�vf IIL III IIL IW e n fifi c,a fl o n of II' ,J! ;,, fi o n ,,, III ';,,;1 III �Y), 111 � y c fi v � y , iii l d Ill,,,,,, III iii g iii III �Y)III � y A c,";;,iii vffi e A. Administration In order to effectively administer the Funding, consistent with these federal requirements, and to make sure that the necessary safeguards are provided, and monitoring processes and procedures are Last Updated 3/03/20 Page 46 of 63