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CHDO as a Subrecipient

CHDOs may play the role of a "subrecipient," which undertakes all other HOME-eligible activities. Activities performed as a subrecipient cannot be undertaken with, nor do they count toward, the 15 percent CHDO set-aside.

  • Being a HOME subrecipient is not the same as being a subrecipient in the Community Development Block Grant Program.
    • A HOME subrecipient is an entity selected by the PJ to administer:
  1. aspects of a HOME Program (i.e., screen projects, market activities, review and certify tenant income, counsel potential homebuyers), or
  2. an entire HOME activity (i.e., manage a tenant based rental assistance program or review requests for HOME funds for the rental housing production set-aside).

Unlike CDBG, an entity that receives an investment of HOME funds for an eligible HOME project only is not considered a HOME subrecipient.

  • When a CHDO is acting in the capacity of a HOME subrecipient, it may not also receive HOME funds to develop, sponsor, or own housing funded through the subrecipient activity it is administering. Doing so constitutes a conflict of interest for the CHDO.
    • For example, if a CHDO is distributing funds for a rental program for a PJ (as a subrecipient), the CHDO may not grant itself money for rental projects it is developing

Examples of CHDOs as subrecipients

  • A CDBG-funded youth job corps managed by a CHDO provides construction assistance on HOME-assisted projects in a single-family rehabilitation program. This is not a set-aside activity.
  • Homeville has selected a qualified CHDO, Housing Now, to administer its $570,000 rental production set-aside program. As per the terms of their HOME subrecipient agreement, Housing Now will have responsibility for reviewing proposals submitted for rental production set-aside loans and grants, and making funding recommendations to Homeville. Housing Now may not serve as a developer, sponsor, or owner for any of the rental production set-aside monies it is involved in administering.
  • The Tri-County Consortium has selected a qualified CHDO, Adams County Housing Endeavors (ACHE), to administer its HOME Program in areas of the Consortium outside Adams County. Under the terms of their HOME subrecipient agreement, ACHE will solicit and review all proposals for HOME grants and loans for the consortium's homeownership and rental housing development activities. If adequate systems are in place to ensure that ACHE will not have influence over HOME funding decisions by the consortium for projects in Adams County, ACHE may develop, sponsor, or own HOME-assisted affordable housing within Adams County.

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