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project on behalf of the recipient, the individual or entity is acting as a subrecipient. Acting as a <br />subrecipient, the individual or entity is subject to subrecipient monitoring and reporting <br />requirements. Conversely, if the recipient is providing funds to the individual or entity for the <br />purpose of directly benefitting the individual or entity as a result of experiencing a public health <br />impact or negative economic impact of the pandemic, the individual or entity is acting as a <br />beneficiary. Acting as a beneficiary, the individual or entity is not subject to subrecipient <br />monitoring and reporting requirements. <br />d. USES OUTSIDE THE SCOPE OF THIS CATEGORY <br />Summary of the Interim Final Rule and Final Rule Structure <br />In the interim final rule, Treasury noted that certain uses of funds are not permissible <br />under the eligible use category of responding to the public health and negative economic impacts <br />of the pandemic. In the final rule, these uses remain impermissible, but Treasury has re - <br />categorized where they are addressed to increase clarity. <br />Specifically, the interim final rule provided that the following uses of funds are not <br />eligible under this eligible use category: contributions to rainy day funds, financial reserves, or <br />similar funds; payment of interest or principal on outstanding debt instruments; fees or issuance <br />costs associated with the issuance of new debt; and satisfaction of any obligation arising under or <br />pursuant to a settlement agreement, judgment, consent decree, or judicially confirmed debt <br />restructuring plan in a judicial, administrative, or regulatory proceeding, except to the extent the <br />judgment or settlement requires the provision of services that would respond to the COVID-19 <br />public health emergency. These uses of funds remain ineligible under the final rule; Treasury has <br />re -categorized these issues to the section Restrictions on Use, which describes restrictions that <br />211 <br />