Questions and Answers regarding the 2001 RFP for alternative loan programs.
STATE AGENCY
1. Question: Does the state agency have to be the same one that receives Title I funds?
Answer: No. The state agency does not have to be the same entity that receives Title I funds.
2. Question: Does the Governor actually have to designate either the state agency or the community-based organization, as in Title I
Answer: No. The Governor does not have to designate the state agency or the community-based organization.
COMMUNITY-BASED ORGANIZATION
3. Question: Does the "community-based organization" need to be a specific 501c3 non-profit or can it be a coalition of community representatives that is organized for the specific purpose of operating an AT Loan program?
Answer: The community-based organization does not need to be a 501C3 non-profit. It may be a coalition of community representatives as long as it meets the requirements as outlined in the statute and the priority.
DATA COLLECTION
4. Question: What type of reporting is required?
Answer: These are one-year grants. There is one report required at the end of the grant period. However, most of the information needed for the annual report will be collected through monthly data input on individual loan applications and project activities via a web-based data collection instrument available to all AFPs through the AFP technical assistance project. NIDRR encourages all grantees to continue collecting data after the 12-month grant period for as long as the program is in operation.
RECEIVING FEDERAL FUNDS
5. Question: How will the state actually receive the funds?
Answer: The Federal funds will be placed in an account identified by the DUNS number. The grantee will be able to "draw down" from that account as is done with other Federal grants. The Alternative Loan Program (AFP) may draw down the federal funds and obligate them in an interest bearing, permanent, separate account. The State may draw down all of the Federal funds and place them in a separate, interest-bearing account as a one-time obligating event. This is authorized because of the unique nature of the AFP statute, which created a permanent funding mechanism for a one-year grant program.
MATCH
6. Question: The priority states that the 25% matching funds must be cash, not in-kind funds. What form can the cash commitment be in?
Answer:
- The letter of guidance should clarify the nature of the match requirement.
- To clarify the 25% matching funds requirement; the state must provide 25% of the total program costs in matching dollars. For example, if the applicant proposes to establish a $1,000,000 program, the Federal share would be $750,000 with a $250,000 match from the applicant. Or, if the applicant requests $1,000,000 of Federal funds, the assumption would be made that the total program is $1.33 million. The Federal share will always be 75% of the total program costs.
- On the Application for Federal Education Assistance, ED 424, under 14, it is suggested that the applicant provide the total program cost next to g. TOTAL, and then request 75% of that number next to a. FEDERAL. The matching amount or the minimum 25% would be indicated next to b., c., d., or e.
7. Question: When can state appropriations to an existing alternative financing program be used as match?
Answer: State appropriations can be used as a match as long as it is "new" money that supplements rather than supplants existing public funding for the alternative financing program. Section 303 (b) (4). State monies that have been appropriated but not obligated for a specific activity may be obligated for the loan program.
8. Question: Can match dollars be used last in expenditures for a program, e.g. all of the federal funding expended first?
Answer: Match dollars and federal dollars should be expended at the same rate as the match ratio during the grant award period. So if the match ratio is 3:1, the federal dollars and match dollars should be expended/obligated at about that same rate during the 12-month grant period. The 3:1 ratio is applicable if both the Federal and match money are being used interchangeably for the same or similar activities. However, this ratio may not be applicable if, for example, one set of funds is used to make loans and the other set of funds is used as the loan guarantee. All Federal and matching funds must be obligated during the one-year grant period and any extensions.
9. Question: Do match dollars need to be placed in a specific type of account by any set date or can they continue to be held, used, invested by the matching source until needed for expenditures?
Answer: At the time of application and grant award, the match dollars may be "promised", but there must be one or more "obligating events" prior to the end of the grant award period for all dollars claimed as match. Dollars claimed as match can be obligated through:
- placing the match dollars into a permanent separate account; or
- some other legally binding arrangement whereby the match is obligated to the alternative financing program.
If the obligating event involves making a loan, all of the rights to that loan, including the return of principal, interest, and the underlying loan documents, must be the property of the grantee and, as appropriate, be placed in a permanent separate account
10. Question: Do match dollars need to be expended within a set time period, or could they theoretically never be expended?
Answer: Match dollars must be obligated within the original one-year project period, including any extensions. Once the project period has ended and all unexpended match dollars are obligated (as described previously), actual expenditure of those dollars can occur at any time for allowable costs.
