General Record-Keeping Requirements. Every subrecipient is required to establish and maintain at least three major categories of records: • Administrative records: These are files and records that apply to the overall administration of the subrecipient’s CDBG activities. They include the following: • Personnel files. • Property management files. • General program files: files relating to the subrecipient’s application to the grantee, the Subrecipient Agreement, program policies and guidelines, correspondence with grantee and reports, etc. • Legal files: articles of incorporation, bylaws of the organization, tax status, board minutes, contracts and other agreements. • Financial records: These include the chart of accounts, a manual on accounting procedures, accounting journals and ledgers, source documentation (purchase orders, invoices, canceled checks, etc.), procurement files, bank account records, financial reports, audit files, etc. • Project/case files: These files document the activities undertaken with respect to specific individual beneficiaries, property owners, and/or properties. Since previous chapters of this handbook have provided information about the elements necessary for financial and general administrative records, this chapter focuses primarily on CDBG requirements as they relate to project files or case files. Exhibit 5-1 at the end of the chapter provides a checklist of the most important files that should be maintained by both subrecipients and grantees for monitoring purposes. The general CDBG standard for record keeping is that records must be accurate, complete and orderly. A grantee must establish the specific requirements for record keeping in its Subrecipient Agreement (24 CFR 570.503(b)(2)). Grantees frequently specify record keeping requirements for their subrecipients that are very similar to those found in 24 CFR 570.506, so that for the activities undertaken by subrecipients, the grantee will be able to demonstrate compliance with all applicable program requirements. Therefore, a subrecipient should anticipate having to maintain records sufficient to: Provide a full description of each activity assisted with CDBG funds, including the location where the activities occur, the amount of CDBG funds budgeted, obligated, and expended for the activity and the regulatory provision under which the activity is eligible. • Demonstrate that each activity undertaken meets one of the National Objectives for the CDBG program (24 CFR 570.208 and particularly the record-keepin...
