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Agenda - Council - 09/13/2022
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Agenda - Council - 09/13/2022
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3/14/2025 2:38:06 PM
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Meetings
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Meeting Type
Council
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09/13/2022
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assistance. Commenters also requested that Treasury acknowledge that engagement directly with <br />nonprofit organizations in low-income communities and communities of color may allow the <br />recipient to better assess economic harms in these areas. <br />Treasury Response: Beneficiaries and Subrecipients: Treasury recognizes that many <br />nonprofits play important roles in their communities, and some may have experienced public <br />health or negative economic impacts during the pandemic. As such, under the interim final rule <br />and the final rule, nonprofits may be impacted by the pandemic and receive assistance as a <br />beneficiary, as described above, and/or be a subrecipient providing services on behalf of a <br />recipient.231 <br />Specifically, the interim final rule also allowed for, and the final rule maintains, the <br />ability for the recipient to transfer, e.g., via grant or contract, funds to nonprofit entities to carry <br />out an eligible use on behalf of the recipient. Treasury notes that recipients may award SLFRF <br />funds to many different types of organizations to carry out eligible uses of funds and serve <br />beneficiaries on behalf of a recipient government (e.g., assisting in a vaccination campaign, <br />operating a job training program, developing affordable housing). When a recipient provides <br />funds to an organization to carry out eligible uses of funds and serve beneficiaries, the <br />organization becomes a subrecipient. In this case, a nonprofit need not have experienced a <br />negative economic impact in order to serve as a subrecipient. <br />In the context of SLFRF, nonprofits of all types may be subrecipients. Treasury is not <br />restricting the types of nonprofits that can operate as subrecipients, rather allowing recipients to <br />decide what form best meets the needs of their community. Therefore, a "nonprofit" that is <br />231 Note, this response is meant to clarify the difference between nonprofits as beneficiaries and nonprofits as <br />subrecipients. It is not meant to limit the types of relationships that a recipient may enter into with a nonprofit as <br />permitted under the Uniform Guidance. <br />158 <br />
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