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Docusign Envelope ID:8EB6DDAC-ED8E-4C5E-8B6E-93915DB01 CF6 <br /> 8. I am funding a project with CDBG funds that were obligated(i.e.,the grant agreement <br /> was signed by HUD)before November 15,2022.Does the BAP apply? <br /> No,the BAP does not apply to HUD funds that were obligated before November 15,2022. <br /> HUD defines the date of obligation as the date that HUD signed the agreement with the <br /> grantee. The BAP will apply to CDBG funds used for iron or steel that were obligated on or <br /> after November 15, 2022. <br /> There is an additional consideration. If FY funds for which BABA applies are added to this <br /> infrastructure project, BABA then will apply to the entire project. <br /> 9. I am a grantee funding a project with CDBG funds that were obligated(i.e., the grant <br /> agreement was signed by HUD) on or after November 15,2022.Does the BAP apply? <br /> If the CDBG funds used in your infrastructure project were obligated on or after November <br /> 15, 2022,the BAP will apply to all iron or steel used in the project, unless a waiver applies <br /> to the project. If these BABA funds are applied to an infrastructure project that does not <br /> have a BAP,the addition of these funds will attach BABA to the entire project. BABA <br /> would apply as described in HUD's Phased Implementation Waiver unless there is a <br /> project-specific waiver approved by the MIAO. <br /> 10. I am funding a public facilities project with total FFA of$2,500,000. $400,000 of <br /> CDBG funds are being used for engineering and administration fees of a project. <br /> Other federal funding will pay for the remaining construction activities. Is the BAP <br /> applicable to this project? <br /> Yes,the total project cost is over$250,000 and the project is construction of an <br /> infrastructure project. The total cost of a project must not exceed$250,000 from all sources <br /> to qualify for an exemption of the BAP under HUD's general waiver for small projects. <br /> Documentation and Grant Management <br /> 11. Does the BAP apply to subrecipients or contractors? <br /> In most cases,yes,the BAP requirements apply to subgrantees, including subrecipients, <br /> contractors, and developers who are awarded Federal financial assistance for use in public <br /> infrastructure projects. The BAP requirements apply to all FFA and do not distinguish <br /> between the end user of the federal funds. The BAP applies as long as the funding is derived <br /> from a Federal agency, even if they are a pass-through entity unless a particular section of <br /> the terms and conditions of the Federal award specifically indicates otherwise. <br /> 23 <br />