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Final Transcript

HUD-US DEPT OF HOUSING & URBAN DEVELOPMENT:

Implementing the OMB Uniform Grant Guidelines Refresher

October 4, 2016/2:00 p.m. EDT

SPEAKERS

Robin Booth

Tracy Fields

PRESENTATION

Moderator Ladies and gentlemen, thank you for standing by. Welcome to the

Implementing the OMB Uniform Grant conference call. At this time all

participants in a listen-only mode. Later, there will be an opportunity for

questions. Instructions will be given at that time. [Operator instructions].

As a reminder, today’s call is being recorded.

I would now like to turn the conference over to Tracy Fields. Please go

ahead.

HUD-US DEPT OF HOUSING & URBAN DEVELOPMENT

Host: Kristen Villalvazo


Robin Hello, this is Robin Booth actually, not Tracy Fields, and we’ll be

facilitating the call today. We wanted to first apologize for the delay. We

had technical difficulties in beginning the webinar. Unfortunately, will

not be able to see your online questions through the chat box, however,

you will have other opportunities to ask questions. We thank you for your

patience, and once again, we apologize for the delay.

As the moderator said, all lines are currently on mute. This audio will be

available for this conference call, however, after the conference call.

You’ll be able to go to the HUD exchange to this particular link, and both

the transcript and the PowerPoint will be available generally in two

business days, or 48 hours. The actual list, this OHC Listserv will be sent

out when the archives are posted, so you will be notified once the archives

are posted. However, during this presentation the lines are muted.

Due to the technical difficulties you may or may not have received the

actual presentation prior to the webinar as we historically do. If not, once

again, we’ll ask that HUD will send it to all participants subsequent to this

call so you can have the presentation in PDF format if you have not

already received it, or you can go to the HUD exchange approximately 48

hours after the webinar to retrieve the information.




As far as questions, unfortunately, we will not be able to take the online

chat questions due to the technical difficulties, however, during the call I

will stop and I’ll ask if there are any questions. If you hit, I want to say

star zero, the moderator, she’ll give you directions on how to go into the

queue for a call, we will take calls during the presentation.

After the presentation, if you have questions and we weren’t able to

answer them during the presentation, you can always send them to

[email protected] and include the webinar topic in the

subject line item to make the responses easier to identify. Once again,

unfortunately, the other option of being able to enter a question into the

chat box during the webinar is not currently available.

The moderator has muted the lines for you, but if for some reason your

line isn’t muted, you should be able to hit star six to also mute your line.

Subsequent to the webinar you will be asked to complete a brief survey,

and these surveys are very important. We use those surveys to try to

improve and enhance the webinar training, and to identify potential

webinar training topics.




As far as a certificate of training, if you logged into the webinar, you will

receive a thank you for attending, and that in fact is your certificate. If

you did not log in you will not receive any other type of notification of

participation in a training. The email is the actual certificate; there will

not be an attachment, nor will there be a subsequent email with any

training certificate. We recommend that you either print out and save the

email or save it electronically so you can have this information available.

As we indicated earlier, if you need additional housing counseling

information, please feel free to access the HUD exchange,

www.hudexchange.info\program\housing.counseling and you’ll be able to

get additional information about this and other programs, as well as

training and events. Subsequent to this call, you have the opportunity to

ask any other questions that you have relative to this training. We simply

ask that you send it to [email protected] and include

Implementing the Uniform Grant Guidance Refresher in the subject line

item.

Once again, thank you for participating and attending, and more

importantly, thank you for your patience as we worked through the

technical difficulties.




We do still anticipate completing this training within no more than ten

minutes probably after the 3:00 hour. I know it was scheduled for 2:00 to

3:00 Eastern Standard Time, so we’ll still be able to get through the

training. This training, Implementing the Uniform Grant Guidance

Refresher, is designed to remind you of all of these various new

requirements that became effective with the full implementation of the

Uniform Grant Guidance under the Office of Management and Budget. A

lot of you may have been participating in the various trainings and

implementations to get you ready for the actual uniform grant guidance,

and at this point all grants are subject to these new requirements. A lot of

what we’ll discuss here is more involved in some of the tools and

resources that HUD is also making available to assist you in ensuring that

you fully implemented the requirements.

My name is Robin Booth, our firm, Booth Management Consulting, LLC

is the quality audit and technical assistance contractor for the Office of

Housing Counseling, specifically for the Comprehensive Housing

Counseling Grant. In addition to preparing and performing the training

and the webinars, we also perform the actual financial and administrative




reviews, provide technical assistance, and action plans all through the

request and through the guidance of the Office of Housing Counseling.

Purposes, we want to review the key areas of change based on the new

guidance, really go over some of the proposed resources that HUD is

making available to you to assist you, and implementing the new guidance

while minimizing your administrative burdens in implementing these

requirements. That includes various tool kits and guides, a lot of which

are in process, really about 70% to 80% complete, that which we hope to

have available to you sooner rather than later.

Specifically, some of the proposed implementation materials that we’re

working on with HUD, a financial disclosure and certification checklist,

and each of these proposed materials address a specific area of the new

requirements. It’s specifically those things that were not previously

required under the old OMB circulars. For all of those key areas, we are

proposing or are in the final stages of developing either a checklist, or a

toolkit, or a guide, and other resources to make available to you, as I said,

to minimize the administrative burden of having to fully implement the

requirements.




On this slide, we give you a summary of where we are, and then

throughout this presentation we’ll review in more in depth on what each of

these proposed materials will include, and which areas of the new

guidance they will be addressing.

We have a financial disclosures and certification checklist. Notice that

yes, everything is in HUD review and anticipated status. We have various

calls and meetings set up to review these reference and sources prior to

making them available in HUD exchange.

Another one would be implementing the 10% de minimis rate. We

recognize that this is really new under the grant guidance, and this guide

will provide you with the kind of information that you need so you can

understand how to properly compute the 10% de minimis rate if in fact

your organization is eligible, and meet the criteria for actually taking

advantage or electing to use this rate, and then what you need to make sure

you have in place to assure you comply with the implementation of this

rate.

We have a more extensive sub-grantee award and monitoring toolkit that’s

designed for international intermediaries, some FHFAs and as a parent




[ph]. That’s very specific to those types of organizations, however, if you

are a sub-grantee, it’s also valuable to use so that you have an

understanding of what the increase or the enhanced requirements are as it

relates to sub-grantee award and monitoring. It adds value for you as well.

Updating the personnel activity report guide, that previously was issued by

HUD. Implementing, or making available, or understanding the financial

statements guide, this one is more geared towards once again,

intermediaries and parents because it provides you with the basics for

understanding how to read financial statements submitted and prepared on

behalf of non-profit organizations and government institutes. If you are a

non-profit, it still provides value to you because it gives you an indication

of what type of financial benchmarks and other financial information that

the government, HUD will be using when they evaluate your application,

and that intermediaries will be using when they’re evaluating the financial

capability of sub-grantees.

And now, we’re working on a full financial and administrative review

training course for intermediaries who are required to perform oversight

and monitoring of the various sub-grantees. This is really geared towards

showing you and teaching you how to perform the financial and




administrative reviews of your sub-grantees to meet the requirements and

the mandates under the new grant guidance.

Beginning with financial disclosures and certification, under the new

guidance, whether you’re LHCA, or you’re a pass-through, there are

certain required certifications that your company or your organization has

to self-certify to. They have to deal with financial management,

specifically, your accounting system, whether you have an accounting

system that properly accumulates and charges and invoices time to the

federal government. This including specifically your policies and

procedures. There’s a new requirement for more internal controls, more

consistent with the industry standards for having an effective internal

control system. Under this guidance, it tells you that you have to assert

that you have internal controls in place.

If you’re a non-major non-profit, meaning you have to certify to whether

you are a non-major non-profit, and non-major being that you do $10

million or less or you receive $10 million or less of funding. Then, to a

conflict of interest, that’s probably not very familiar to many of you,

because you have certain conflict of interest requirements now, especially

on the performance review side, but the guidance has made it even more




clear that you have to certify that you have these things in place. The

language for the certification comes straight from the uniform grant

guidance.

If you look at number 4, 5, and 6, just some of the things that you’re

certifying to as it relates to your financial management system, which was

the first set of certifications we discussed. That you have effective control

over and accountability for all funds, that you have written procedures to

implement requirements for payment, that you have a comparison of

expenditures with budget amounts from each federal award. Actually,

under the reporting section of your HUD Grant Agreement where you’re

now required to show actual versus budgeted results on a quarterly basis,

this in fact assists you in making sure that you’re in compliance with these

financial disclosure requirements.

You have to have, number 7 here, written procedures for determining the

allowability of costs. If we go back and look at number 1 and 2,

identification in its account of all federal awards received and extended in

the federal program under which they were received. These are all things

that when we perform the financial and administrative reviews, we verify

that they exist. But as a part of the awarding process, and when you’re




submitting your application, these are the certifications that HUD will

have you do, and if you are a parent organization, that you should have

your sub-grantees do, asserting that yes, we understand that these are the

requirements and we’re certifying that these things are in place. For this

checklist, we actually designed these more to be a certification that can be

signed off on by the organization and submitted to, whether it’s a parent or

to HUD, verifying that they’ve met these requirements.

The next section 200-303 internal controls, there is much more mandate

here on internal controls. In fact, if you look under A in this section, near

the end, it basically says these internal controls should be in compliance of

guidance and standards for internal control in the federal government

issued by the Comptroller General of the United States. They are putting a

much higher requirement on internal controls, so as a part of your

certification, especially during the application and award process, the

government and parents and working with pass-throughs, they have to

have the assurance that you’re aware of these requirements, and in fact

that you have those types of controls in place.

Section 415, another required certification by non-profit organizations, is

as appropriate that did not meet the definition of a major. You have to




certify that you don’t meet a definition of a major non-profit organization.

Most LHCAs are not. If you’re not, then you need to certify to that either

way.

Then the conflict of interest, you must certify that you have policies and

procedures in place for a conflict of interest mitigation plan. The reason

why we’re asking for these certifications up front is generally, especially

for these types of grants, the government and/or the pass-through entity,

they’re not able or in a position to go out and verify that you have these

things in place by doing on-site reviews of your accounting system, or a

full review of your conflict of interest system, or do an analysis or an

assessment of your internal controls. It’s your responsibility through the

self-certification process to say not only do we have this in place, but

we’re aware that this is a federal requirement.

The 10% de minimis rate, the guide that we’ve developed, we tried to

keep it simple and give various scenarios to show you how to compute this

10% de minimis rate. It starts with whether your organization actually

meets the criteria for electing that rate. Just as a reminder, main criteria is

you could never have received a negotiated, indirect cost rate.




The challenge here is that if you have a 100-year organization, you have to

verify internally whether they’ve ever had a NICRA. It may be that from

your perspective or from your knowledge that doesn’t exist, but you need

to verify with accounting and with management there’s never been a

NICRA. Part of the certification is you’re certifying—and one of the

things we put in the guide is an example of the type of certification—

you’re certifying that you meet this eligibility requirement.

Then HUD and/or the parent organization is relying on your certification

and your due diligence that you can verify that you’ve never had a

negotiated indirect rate. You have to use this rate indefinitely, you have to

still comply with factors dealing with allowability of cost, and that goes

into how you compute the 10%. That allowability of cost principle deals

with how you come up with what’s the modified total direct cost amount

is to compute it. And the guide, we actually tell you. We tried to make it

very simple and really designed for this grant and how the funds are

primarily used under this grant, but to be able to compute what your

modified total direct cost is.

Then once elected, you have to consistently use it for all awards. On the

front end, you self-certify that yes, we’ve met all of this criteria. Then the




government and/or the intermediary or parent organization, they’ll accept

your certification. However, on the back end, when we conduct financial

and administrative reviews, we verify that you’ve met this criteria, and

that you were in fact entitled to elect this rate.

What we’ve done, as I said OHC’s done with is we’re developing this

guide that we’ll make available to you. You’re going to have to self-

certify that you comply with the various eligibility criteria to determine if

you’re eligible for that 10% de minimis rate. Then when we do our

financial administrative review, we’re going to verify one, that you met

the eligibility requirements, but also that you correctly determined what

the modified total direct costs are. If you don’t determine that correctly,

then you’ll be applying that 10% to the wrong base or to the wrong

dollars. So we verify that whatever you’ve included in your modified total

direct cost dollars that meets the cost principles and are in compliance

with Sub Part E [ph] that has to deal with the cost principles.

Then we’re also working with HUD staff on how to review your indirect

cost rate submission to make sure in fact, that you have computed the

modified total direct cost correctly. The guide really, as I said, breaks that

down into very clear and precise language, and it deals with the types of




costs that are specific to the HUD grant like labor and salaries, and travel

and training, those predominant costs that we see when we’re looking at

this particular grant.

Some of the frequently asked questions about this 10% rate, what do we

do if some grant contracts do not provide for any indirect costs? The

government or any federal grant, they are forced to allow you to elect the

10% de minimis rate, if in fact, you meet the requirements. If not, you

must have a negotiated indirect cost rate agreement. Those agreements are

negotiated by the agency with which you have the largest dollar amount of

funding. Each agency has its own group or its own review and approval

process that’s usually done by a certain group within the agency that

handles the negotiated and indirect cost rate, but the whole concept of

using the 10% de minimis rate at least, is that the government has to allow

you to use that rate if in fact you meet the minimum criteria.

What agency approves and negotiates the rate? As the circular said,

negotiation approval is done with the agency with which you have the

largest dollar value of federal award. Within HUD, actually if you go

online, you can find who’s responsible for a negotiated indirect cost rate.

Please note that if you’re electing the 10% rate, there’s no negotiations




available. That’s an election that you can make and it doesn’t have to get

approved or go through any kind of an approval process relative to the

10% de minimis rate. This only applies if you are attempting to negotiate

an indirect cost rate that’s not that elected 10%.

Does HUD negotiate indirect cost rates? As I said, they have an

agreement with the Department of Health and Human Services where they

can negotiate. If you look on their website you can find that information.

I’ve actually seen it several times.

Then, if you want to negotiate a rate, if you don’t want this whole 10% de

minimis rate and you want to negotiate a rate, you should reach out to

your HUD POC and have them work with you. If you’re going to attempt

to negotiate an indirect cost rate, all of the information relative to the 10%

de minimis rate doesn’t apply. This is only if you’re going to elect to use

that 10% de minimis rate. Then, in fact the guide that we’re working on

will assist you in making sure you’re computing it correctly and consistent

with the requirements.

If we accept the de minimis rate under this grant, would we now have to

accept the rate for all? Yes, you definitely do. It’s very clear that once




you elect the 10% de minimis rate you have to continue to use the 10% de

minimis rate across federal awards.

If you subsequently decide that hey, we want to go ahead and get a

negotiated indirect cost rate, then you can go negotiate an indirect cost

rate. Once approved, that then would become your rate that you would

use with all federal agencies. You cannot use the 10% de minimis rate

with one agency and then another negotiated rate, whether it be through a

formal negotiated indirect cost rate agreement or via approval of your

budget, with another agency. Once you use that 10%, you have to

continue to use that 10% unless and until you get a negotiated indirect cost

rate agreement.

Can grantees charge insurance equipment or similar costs as direct cost?

This gets into the issue of making sure that you’re not attempting to

include costs that generally are not allowable or are not direct costs in

your budget, and then also ask for the 10% de minimis rate. Although

there’s no defined set of costs that are always direct costs, generally

insurance or similar costs are treated as an indirect expense. What that

means is if you elect a 10% de minimis rate, unless you can clearly show

how the insurance or a similar cost is a direct cost specifically for this




grant. For instance maybe the grant—I can’t see it under the housing

counseling grant, but under another grant—they say that you have to

maintain a certain specific insurance for that grant, or even performance

bonding—which is a type of insurance—and you’re only incurring it for

that grant, and if in fact you don’t have that grant that insurance goes

away. That’s what a direct charge for insurance would be.

Otherwise, if costs like insurance and rent and those other costs, they’re

generally considered indirect costs. If you’re electing the 10% de minimis

rate, that 10% is really incorporating that grant’s share of those costs. If a

cost is in fact indirect, and you’re electing a 10% indirect rate, that’s

where you’re really getting reimbursed for it. You can attempt to include

it in the budget as a direct cost, but then also it’s one of those costs that

really is an indirect cost that you’re really asking the government to

reimburse you for through the 10% de minimis rate.

That’s why the guide we think is really helpful, too, because it makes it

clear on which costs fall where, and how you can make sure you’re not

duplicating, or what we call double-charging or improper payment or

improper charge for costs, both as a direct cost, and then again in that 10%




de minimis rate that you’re being allowed to charge, which is really an

indirect cost rate.

The next question, can the amount of sub awards be included in the

modified total direct cost? Yes they can, but only up to $25,000 of each

sub award. I think this is one of the areas that we spend a lot of time on in

the guide as far as different examples of showing you how to come up

with how much you can include in your modified total direct cost base for

a sub award. Yes you can, but only up to $25,000 per sub-recipient or per

sub award, which his critical. You have to look at each sub award, and

then determine to what extent they exceed $25,000 and exclude any

amounts over $25,000.

Can sub-grantee elect to use the 10%? If so, does the pass-through agency

have to accept? Yes to both questions. Yes, the sub-grantee can elect the

10%; and yes, the pass-through agency has to accept it. They cannot tell

you we’re not accepting the 10% de minimis rate. The regulation that’s

cited here made it clear that the parent, the pass-through, does in fact have

to accept any sub awards request or election to elect that 10% de minimis

rate.




What this pass-through agency may want to do, and that’s part of our

whole certification packet or toolkit, is require that sub awardee to certify

that they meet the eligibility requirement for electing that 10%, therefore

putting the burden on them to show that hey, we know what the

requirements are, we meet those requirements, and so in fact that’s why

we’re requesting or electing that 10% de minimis rate.

Personal activity reporting, which is probably the biggest area everybody’s

concerned with. Under the new uniform grants guidance, you are no

longer required to do a personnel activity report as a separate report or

document that you have to maintain in addition to your timekeeping and

your case management system. However, you still have to maintain

sufficient information regarding personnel activity to determine if in fact

the cost, or whatever the charge or the time was, was consistent with cost

principle requirements.

Think about it this way, you no longer have to have a separate report,

however, there has to be sufficient information for us to determine if the

time being charged by that person is for activities awarded and consistent

or in compliance with the grant agreement. You still have to keep

personnel activity reporting information, the question becomes how do




you maintain this. For those of you who’ve been doing PARS for the last

decade, we strongly encourage you, unless it’s some type of administrative

burden, to continue doing what you’re doing; if it’s not broke then don’t

fix it. You’ll definitely be meeting the requirements.

For others, we looked at potentially modifying, especially if you’re using a

manual time sheet, modifying your time sheet to use activity codes as

cited here, where you’re using activity in the work performed. You may

have narrative, but we’re actually recommending that you set up almost

like activity-based reporting where you have a certain legend. You say

activity 001, that’s direct counseling; activity 002, that’s administrative or

back-end work. Whatever activity codes coincide with the work you’re

performing under the grant, that, too, meets the requirement for personnel

activity reporting.

One of the things we are doing though, is we’re updating the personnel

activity guide that was issued by HUD several years ago to comply with

the new requirements, and to give you various options on how you can

maintain personnel activity reporting now that you don’t have to maintain

this defined personnel activity report.




The goal is to streamline it, to give you various options or scenarios where

you’re meeting the requirements. However, you don’t have to maintain

that separate report, and to provide you with information to make an

informed decision on how you can best meet the requirements within your

organization, and minimize the administrative burden of having to

maintain this type of information.

However, I will say once again if you’re not having any problems with

personnel activity reports now and you’ve been doing them, you can

continue to do them. If you haven’t or you’re new, you may want to look

at how can I maintain the type of documentation that I’m going to need to,

to make sure I’m showing activity so that we can verify during our

compliance review that that activity performed by that person is in

compliance with the grant agreement and regulations.

Part of that, too, all of that though, whatever it is, it has to be documented

in your policies and procedures for personnel activity reporting. This is a

part of that whole internal control requirement. There’s even more

emphasis on policies and procedures because of course, policies and

procedures should be documented and communicated to your staff. This

provides a lot higher level internal control that the various mandates and




policies are being distributed and communicated to the staff and ultimately

being enforced to ensure that the staff are performing consistent with the

policies and procedures. In fact, one of the things that you have to make

sure is you have a good policy and procedure.

Another key area that this federal grantee award and monitoring toolkit

that we’ve been talking about is an extensive tool kit, and yes, this is

designed primarily for pass-through entities. However, if you are a sub

award or maybe you’re considering becoming a pass-through entity, this is

a very good resource for you to understand what the various requirements

are as they have been cited in these particular sections of the uniform grant

guidance. What we did with the toolkit, is using the guidance and the

requirements, we actually tried to give you templates and forms and

checklists that you can use internally to make sure you’re meeting those

requirements.

For instance, under sub-par 200.331, it’s clear what your requirements are

for monitoring. You have to evaluate the sub-grantee’s risk of non-

compliance. That means you have to do a risk assessment. In the toolkit

we actually give you the most common risk factors, and a template for

how you could do your risk assessments.




What are your imposing specific sub award conditions upon your sub-

grantee agreement? We give you recommendations for making sure

certain requirements are in agreement. Looking at if you’re doing—what

type of monitoring are you doing? Are you doing desk reviews, are you

doing on-site, are you doing full reviews? That, along with our full

training program to show pass-through personnel—preferably accounting

personnel—on how to perform these financial reviews, that’s all in the

toolkit. Then, do you have the required enforcement action? So in the

toolkit we make recommendations for the enforcement actions.

The toolkit; we give you guidance, we’re giving you tools from risk

assessments to what has to be in your awarding documents, to then how

you’re going to do your monitoring and oversight. The way that is

organized is we start with of course, your sub-grantee pre-award. That

guide, that’s the first section of it. Then we look at risk assessment. Then

we give you a desk review template. Then if you’re doing an on-site

review. Then a quarterly report template, so that as you’re getting these

quarterly reports from your sub-grantees, if you want to give them more

guidance and instruction on how to standardize it we give you




recommendations for what kind of template you can submit to your sub-

grantees, as well as an invoice template for when they’re billing you.

Like I said, that’s almost like a workbook. It’ll be made available both

electronically and in hard copy, but it’s not just instructions or a guide.

It’s actually giving you the templates, in Excel and Word, in formats that

you can use and implement and customize to your organization.

What the process has been for the sub-grantee award and monitoring

toolkit, is generally, if you are a pass-through entity and you want

assistance with the award and monitoring, there’s a request sent to Gail

Osgood or Tracy Fields. We then do an assessment of your entire sub-

grantee awarding and monitoring. We’re going to look at the tools that

you’ve been using, what you’ve been doing, and then we’re going to

modify the toolkit to ensure that whatever tools that you have are in

compliance and whatever areas you’re not in compliance, to assist you in

bringing all of the areas of your sub-grantee in compliance, including

potentially doing a full-day training on how to do financial and

administrative reviews. This is for your staff or for whomever you

identify that will be performing that type of monitoring on your behalf for

the pass-through.




Other issues, just to make you aware, this becomes very important to pass-

throughs once again that effective for all audits beginning June 1, 2017,

there is an increase in the single audit requirement to $750,000. Now, it’s

whether they’ve been awarded and incurred costs of $750,000 on any

federal grant. There’s now this general procurement standard that all non-

federal entities must use its own documented procurement procedures

which reflect applicable state, local, and tribal. Historically, we only

really dealt with procurement procedures for any purchases of $25,000 or

more.

Now, based under this new guidance all non-federal entities must have

documented its own—and it emphasizes its own—and not just say we

accept the federal acquisition regulations, or we use the same standard as

XY&Z. Even if that is the case, you still have to identify those standards

in your own format, and then verity that that information has been shared

with all the parties that are somehow involved in the procurement process.

That’s another major area of change in the uniform grant guidance.

With that said, I will ask the monitor if there are any questions in the

queue. I think you have to hit star one.




Moderator [Operator instructions].

Robin Unfortunately, as I said, due to technical difficulties we do not have access

to the online chat. However, after the call you still can send questions to

[email protected]. Just be sure to include Implementing

Uniform Grant Guidance Refresher in the subject line item. It just makes

it easier to address and to respond to your questions.

Tracy Robin, it’s Tracy. I do want to add one thing. Everyone, I am filling in

for the person that normally gets our trainings together, they’re out.

Someone did ask a question about the handout. I’m not sure if you all are

able to see that I did attach it on. If not, then we will have that team send

it out to everyone. I think they may send it out in advance, I’m not sure,

but we’ll make sure that everyone gets the handout. That’s it.

Robin Are there any questions in the queue?

Moderator No one has queued up.




Robin Okay, well once again thank you for your time, thank you for your

patience with us as we dealt with the technical difficulties. Please

complete the brief survey after the call, and if you have any other

questions feel free to send them to [email protected]. Thank

you for your time today.

Moderator Ladies and gentlemen, that does conclude our conference for today.

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Housing Counseling Webinar: Implementing ... - HUD Exchange...HUD-US DEPT OF HOUSING & URBAN...

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