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guidance to their NEUs to operationalize the 75 percent budget cap. Given the variance in local <br />financial accounting, this updated definition will better facilitate states' and territories' <br />distribution of SLFRF funds to NEUs. <br />Allocations and Eligibility <br />Public Comment: Many commenters provided feedback on specific allocation <br />calculations and eligibility of local governments for NEU funding. Commenters addressed how a <br />locality was classified as an NEU or metropolitan city, deviations between Treasury's allocation <br />calculations and earlier estimates from other sources, treatment of unincorporated areas, sources <br />for population data, and Treasury's allocation of NEU funding to states and territories based on <br />the population of a state and territory outside of its metropolitan cities. Two commenters <br />proposed that Treasury provide an appeal process for localities that were not identified on the <br />List of Local Governments used by states and territories as part of the process in which a state or <br />territory determines the eligibility of an NEU in accordance with Treasury guidance, or for <br />Minor Civil Divisions (MCDs) that were denied funding as part of a facts -and -circumstances test <br />undertaken by a weak-MCD state. <br />Treasury Response: Neither the interim final rule nor the final rule addresses eligibility or <br />allocations issues, and comments on these topics are outside the scope of this rulemaking. These <br />questions are addressed in other Treasury guidance, including the Guidance on Distribution of <br />Funds to Non -entitlement Units of Local Government and Non -entitlement Unit of Local <br />Government Definitional and Data Methodology guidance documents available on Treasury's <br />352 <br />