Loading...
HomeMy WebLinkAboutMINUTES - 01172006 - C.68 Contra Y' 42. 1 Costa TO: BOARD OF SUPERVISORS ` COUnty „:,... Cou FROM: Dennis M. Barry, AICPI Community Development Director c • DATE, January 17, 2006 SUBJECT: PERFORMANCE REVIEW OF COMMUNITY DEVELOPMENT BLOCK GRANT AND HOME INVESTMENT PARTNERSHIPS ACT PROGRAMS BY THE U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT SPECIFIC REQUEST(S) OR RECOMMENDATIONS(S) & BACKGROUND AND JUSTIFICATION RECOMMENDATION 1. ACCEPT letters from the U.S. Department of Housing and Urban Development (HUD) regarding the County's FY 2004/05 Consolidated Annual Performance and Evaluation Report (CAPER) and the results of HUD's monitoring of the County's CDBG and HOME Investment Partnerships Act (HOME) programs FISCAL IMPACT N/A CONTINUED ON ATTACHMENT: _X_YES SIGNATURE: LAECOMMENDATION OF COUNTY ADMINISTRATOR' RECOM ENDATION O BOARD COMMITTEE ./APPROVE OTHER SIGNATURE(S): ACTION OF AREYQAPPROVED AS RECOMMENDED V"-OT ER VOTE OF SUPER S I HEREBY CERTIFY THAT THIS IS A /UNANIMOUS (ABSENT ` 67�,� ) TRUE AND CORRECT COPY OF AN AYES: NOES: I ACTION TAKEN AND ENTERED ON THE ABSENT: ABSTAIN: MINUTES OF THE BOARD OF SUPERVISORS ON THE DATE SHOWN. Source: Bob Calkins, CDBG Program Manager (925) 335-7220 ATTESTE"TENj, Orig. Dept. Community Development - CDBG JOHN SjR OF cc: County Administrator THE BORVISORS Auditor - Controller AND COUNTY ADMINISTRATOR County Counsel BY , DEPUTY BACKGROUND /REASONS FOR RECOMMENDATIONS The Community Developmelnt Department has recently received two very positive evaluations of its administration and implementation of the CDBG and HOME programs: These assessments are worthy of sharing with the Board. They are a small indicator of the quality of work of the CDBG and HOME program staff. At the end of each fiscal year, the County submits the Consolidated Annual Performance and Evaluation Report (CAPER) to HUD. The CAPER reports on the progress the County has made in achieving the goals and objectives for the CDBG and HOME programs. HUD uses the CAPER to assess the County's ability to manage these funds and assess the performance of the County in meeting national and local objectives. HUD also conducted an on-site monitoring of the County's CDBG and HOME programs during the week of August 9,1 2005. The monitoring focused on the County's oversight responsibilities of its CDBG and HOME-funded subrecipients, and ensuring compliance with approved program objectives, as well as, applicable regulatory and statutory requirements. CAPER Letter Dated December 22, 2005: In summary, HUD has determined that the "County has the continuing capacity to implement and administer" its CDBG and HOME programs in a timely manners Excerpts from HUD's letter include: "We are pleased to see the County's support of the effort to create a County-wide Housing Trust Fund to support the development of affordable housing." "The County's efforts to ensure affordable housing need are met are commendable." "We commend the County for the steps it has taken to address homelessness." "We are pleased to note that the County, along with its partners, is carrying out programs that enable low- and moderate-income persons obtain jobs." "We are pleased that t the County indicated 98 percent of persons assisted were very low and low-income." "We commend County staff for consistently meeting the requirements for ensuring the funds are expended in a timely manner to ensure timely delivery of service to low- and moderate-income persons." Monitoring Letter Dated December 30, 2005: HUD's monitoring visit resulted in no findings or concerns. Excerpts from HUD's letter include: "County staff has a comprehensive monitoring plan in place and utilizes a well thought out checklist to ensure the subrecipient is meeting its goals, serving those intended (low- and moderate-income clientele), and meeting a national objective and other requirements of the CDBG program." "The County funded projects that meet the eligibility requirements of the CDBG and HOME programs, as well as, met the national objective requirements of the CDBG program." "Our review of subrecipient agreements indicated that the County is in compliance with CDBG and HOME program requirements." "The County met the timeliness threshold for FY 2004." "A review of the County's documentation for tracking match obligations and contributions(under the HOME program)supports the County's compliance with this requirement." Q'pMENTpTH U.S.Department of Housing and Urban Development San Francisco Regional Office-Region IX o*QIIIIIII*? 600 Harrison Street I San Francisco,California 94107-1387 °+x DEVV�0Q wWw.hud.gov espanol.hud.gov Ms. Gayle Uilkema Chairperson, Board of Supervisors Contra Costa County 651 Pine St. Martinez, CA 94553-0095 Dear Ms. Uilkema: SUBJECT: Contra Costa County, California Annual Community Assessment Report Program Year 2004 Our office has completed the review of Contra Costa County's Program Year(PY) 2004 Consolidated Annual Performance and Evaluation Report(CAPER). Based upon this review, our office has drafted an assessment of the County's performance as it relates to the Consolidated Plan (Con Plan), the PY 2004 Annual Action Plan(AAP), and other pertinent information and events that may have occurred during PY 2004. This evaluation is done to assess the management of funds made available under programs administered by HUD, compliance with the County's Con Plan and AAP, the extent to which the County is preserving and developing decent, affordable housing, creating a suitable living environment, and expanding economic opportunities, principally for low- and moderate-income persons. The County continued to make progress utilizing its HUD resources to address priority needs and carry out the programs described in the Con Plan. The Con Plan/AAP activities comply with the requirements of the Housing and Community Development Act and other applicable laws and regulations. lBased on our review of the CAPER and other available information, we have determined that the County has the continuing capacity to implement and administer its Community Development Block Grant (CDBG), HOME Investment Partnership. Program(HOME), andEmergency Shelter Grants (ESG)programs in a timely manner. The activities funded were found to be consistent with the goals and objectives contained in the Con Plan. County projects received $226.2 million in resources and matching funds for use in accomplishing housing and non-housing community development activities. This included approximately $11.3 million in CDBG, HOME, HOPWA, ESG, and CDBG program income. Other funds utilized were County Redevelopment Agency, FEMA, LIHTC, and other Federal, State, and local funds. 2 Since PY 2004 is the final year in the County's PYs 2000-2004 five-year Con Plan, this assessment will cover the County's progress in accomplishing the goals in the Con Plan, including PY 2004 accomplishments. The following is our assessment of the County's performance. Affordable Housing The County successfully increased the supply of affordable housing and preserved existing affordable housing throughout the County during the 2000-2004 Con Plan cycle. Projects completed during the year resulted in the acquisition, rehabilitation,or new construction of 155 affordable housing units. Projects completed included Emerson Arms in Martinez, Presidio Village in Pittsburg, and three Habitat for Humanity projects. Completing these projects was significant, as these'communities have limited affordable housing opportunities. The County exceeded its five-year goal to provide 1,295 units of affordable rental housing as 1,367 units were completed, and 657 units are underway. The majority of the households served had incomes that were 31 to 50 percent of the average median income (AMI). In PY 2004,the County carried out owner-occupied housing rehabilitation programs that provided zero/low-interest loans and small grants for owner-occupied housing, and first-time homebuyer assistance. The County's five-year goal was to provide owner-occupied rehabilitation assistance to 250 homeowners, and first-time homebuyer assistance to 130 households. To date, 405 homes were purchased or rehabilitated, including 180 homeowner rehabilitation loans and 225 homebuyers assisted. Homebuyer assistance was achieved with HOME, CDBG, and Mortgage Credit Certificates. Also, during this Con Plan cycle,the County supported the Individual Development Account(IDA)program that provides matched savings to assist qualified low- and moderate- income households to acquire their first home. During PY 2004, five participants enrolled in the program, with one participant graduating and purchasing a home. We are also pleased to see the County's support of the effort to create a County-wide Housing Trust Fund to support the development of affordable housing. The only five-year housing goal the County did not meet was the development of 150 units of special needs housing (i e., housing for persons with physical disabilities or housing for persons with HIV/AIDS). ThereI were only 32 units completed. An additional 69 units/beds are described in the Continuum of Care discussion below. Because it is increasingly difficult to provide new affordable housing, as the prices continue to escalate for land and construction,the County's efforts to ensure affordable housing needs are met are commendable. Continuum of Care The receipt of additional special Demonstration Program funding, such as the Housing for People who are Homeless and Addicted to Alcohol (HHAA),is the direct result of the collaborative efforts of the County, the nonprofits and other partners in carrying out its 3 Continuum of Care strategy. For example, Contra Costa Health Services was successful in receiving a Federal Collaborative Grant for Project Coming Home that provided funding for an additional 40 S+C units for those who are considered chronically homeless, and a grant under the HHAA program,which will provide an additional 40 S+C units. Additionally, the Housing Authority of Contra Costa County received Shelter Plus Care (S+C)renewal funds that provided tenant-based rental assistance and supportive services to individual/families. During P 2003,the County Board of Supervisors adopted a 10-year plan to end homelessness. To this end, as mentioned above, the County was successful in receiving HUD Supportive Housing Program (SHP) grants, and utilizing CDBG and HOME funds,to construct new supportive permanent housing projects, such as the 28-unit Garden Parks Apartments and the 12-units within the 124—unit Lakeside Apartments. In future CAPERS, we look forward to hearing the results of implementation of the 10-year plan. Also, several activities were funded with CDBG funds to assist/prevent homeless. Some of the projects included a 24-hour homeless hotline, and programs that provided referrals, food, clothing, personal items, household goods, housing counseling, assistance in finding and maintaining housing, and operation of two emergency shelters. HOPWA and Ryan White CARE funds were available to address the needs of low- income persons with HIV/AIDS.I Construction is nearly completed on the 51-unit Bella Monte Apartments,where five units will be reserved for persons with HIV/AIDS. Funds were also awarded to Catholic Charities and Shelter, Inc. to provide various housing advocacy services. The County used ESG funds to support the County's emergency shelters and the Rollie Mullen Center for battered women. REACH Plus provided rental assistance and supportive services to homeless families and individuals. Also, in PY 2004,41 units of transitional housing, 28 units of permanent supportive housing, and other facilities were provided assistance. A total of 161 emergency beds were rehi bilitated during the five-year Consolidated Plan period. In conclusion, utilizing HUD funds and other resources, the County and its non-profit partners continued to take steps to provide housing and services that reduced homelessness and other needs of the homeless. The County met its goals to provide permanent and transitional housing, emergency shelters, and services. We commend the County for the steps it has taken to address homelessness. Economic Development The County utilized CDBG, State, local and private resources to assist microenterprises, train low-income persons to become healthcare and childcare providers, and assist in training and job placement. Approximately 302 businesses/persons were served during the year. As an example,the County utilized CDBG funds for the Small Business and Microenterprise Loan Program and made two loans to businesses, with the condition that the businesses hire new low- income employees. Another program, Strengthening Neighborhoods, sponsored by the West Contra Costa Business Development Center, was funded and provided assistance to 103 aspiring start-up and established small businesses. As a result, 13 new businesses, such as graphic 4 design, consulting, sales, photography,printing, food related, landscaping, beauty shop and auto related opened, and 23 new jobs were created in the Urban County. Rubicon Programs Inc. was provided CDBG funds to carry out two programs that resulted in 66 low-income persons being placed in jobs where wages exceeded the minimum wage. The Contra Costa Childcare Council assisted 111 low-income persons become licensed family daycare operators.. Beginning PY 2005, the County has new performance measurements in place, which document outcomes of projects. We are interested to see how many of those licensed to become daycare operators actually opened a business, and the number of those still in business. We understand these outcomes will be reported in future CAPERS. Providing job opportunities is one way of enabling low- and moderate-income persons to obtain and retain affordable housing and improve their qualify of life. As an example, CDBG and Youthbuild funds were utilized in North Richmond to provide on-the-job construction training to very-low and low-income youth. As a result, 11 graduates were placed in jobs. During the past five years, 570 people were served and 647 businesses were assisted through economic development programs. We are pleased to note that the County, along with its partners, is carrying out programs that enable low- and moderate-income persons obtain jobs. Public Services To meet its public service goals, CDBG, Federal, State, local, and private resources were awarded to local non-profit agencies to assist low-income youth, seniors, families, and others with special needs. These activities included care and counseling for victims of physical and sexual abuse, educational and health programs, food provision services, and homeless and crisis counseling. Over 22,000 persons received assistance. The County's goal was to ensure that a minimum of 75 percent of the persons receiving the assistance were very low-and low-income persons. We are pleased that they County indicated 98 percent of the persons assisted were very low-and low-income. We are also pleased that the County continued to strongly support the County-wide VITA efforts to assist in the preparation of income tax returns for low- and moderate-income persons. North Richmond Neighborhood Revitalization Strategy Area (MRSA) The coordinated and sustained efforts in North Richmond continue to provide benefits to the residents. The majority of the projects originally identified in the NRSA have been completed and continue to provide services, such as the Self-sufficiency through licensed family day care project, Project YES that provided tutoring and mentoring to Verde School students, and The Service Integration Team that provided case management and employment assistance to Cal Works clients. These projects are just three of the 14 projects that continued to provide a variety of services to residents in the NRSA. An update to the Plan is currently being developed. Please forward a copy of the new Plan once it is complete. 5 Expenditure of Funds According to the CDBG regulations, each grantee may not have more than 1.5 times the annual grant amount in its line of credit (LOC) balance 60 days prior to the end of the current program year. Participating jurisdictions also have to meet the requirements for committing and expending HOME funds in a timely manner. Also ESG funds must be expended within the 24- month requirement. We commend County staff for consistently meeting the above requirements ensuring that funds are expended in a timely manner to ensure timely delivery of service to low- and moderate-income persons. We look forward to continuing our partnership with the County to assist it in achieving its affordable housing and community development goals. If you have questions or need assistance,please call Cathy Thrash, Community Planning and Development Representative, on (415) 489-6570. Sincerely, Steven B. Sachs Director, Community Planning and Development Division cc: Ms. Kara Douglas, Affordable Housing Program Manager Mr. Robert Calkins, CDBG Program Manager bcc: official file—CCC final 2004 ACA ltr chron file 9ADM1 —Thrash 9ADMl:CEThrash:cet 1/3/06 file: g:/cet/CCC draft 2004 ACA ltr concurrence: 9ADM 1 Thrash Prater >"MENT, U.S.Department of Housing and Urban Development y�N San Francisco Regional Office-Region IX Q*IIOII 600 Harrison Street San Francisco,California 94107-1387 www.hud.gov espanol.hud.gov Mr. James Kennedy December 30, 2005 Director, Redevelopment Agency Contra Costa County 2530 Arnold Drive, Suite 190 Martinez, CA 94553 Dear Mr. Kennedy: SUBJECT: Monitoring Visit Contra Costa County, California Community Development Block Grant(CDBG) Program HOME Investment Partnership Program This transmits the results of our monitoring of the County's CDBG and HOME program. Cathy Thrash, Community Planning and Development Representative, conducted the review on August 9-10, 2005, and August 5, 2005. The monitoring focused on the County's oversight responsibilities of its CDBG and HOME-funded subrecipients, and ensuring compliance with approved program objectives, as well as, applicable regulatory and statutory requirements. There were no findings or concerns. The enclosed report provides a summary of our monitoring. Please extend a special thanks to Kara Douglas,Robert Calkins, Sara Welch,Kristen Alcaraz, and Gabriel Lemus for their cooperation and assistance provided to Ms. Thrash during her visit. If you have any questions regarding this monitoring report,please feel free to contact Ms. Thrash, on(415) 489-6570. Sincerely, Jimmy L. Prater Deputy Director, Community Planning and Development Division Enclosure cc: 'Kara Douglas, Affordable Housing Program Manager Robert Calkins, CDBG Program Manager CONTRA COSTA COUNTY, CA MONITORING REPORT MONITORING VISIT: AUGUST 9TH, 10TH AND 15TH,2005 Contra Costa County is the recipient of CDBG and HOME ds. During Program Year (PY) 2004, 67 sfun subrecipients received CDBG funding who carried out activities such as public service, micro-enterprise assistance, economic development, and public facilities improvements. The CDBG monitoring review focused on economic development activities that assisted county residents to achieve economic self- sufficiency, provide small businesses with a loan for expansion and job creation, or an organization funded for the first time. Because completion of HOME-funded affordable housing can take several years, monitoring did not focus on PY 2004 alone,but included tours of affordable housing projects that were completed during past PYs or currently under construction. Projects visited included Bella Monte Apartments in Bay Point, Gateway Apartments in Rodeo, Hercules Senior Housing, and Victoria Green Apartments in Hercules. Definitions of Findings and.Concerns Findings are a deficie cy in program performance, based on statutory or regulatory requirements, for which sanctions or other corrective actions may be subject to HUD discretion. A concern 1Js a deficiency in program performance that is not based on a statutory or regulatory requirement. While sanctions or corrective actions are not authorized for a concern, HUD may call the concern to the grantee's attention and, where appropriate, may recommend actions to address the concern and/or provide technical assistance. There were no findings or concerns. Subrecioient Management The County's Consolidated Plan/Action Plan includes policies for monitoring standards and procedures to ensure compliance with CDBG/HOME program requirements. All new subrecipients are required to attend a mandatory meeting to become familiar with program standards, local requirements, and federal regulations. The County requires agencies to provide quarterly and final closeout reports to measure success in meeting national objective and programmatic goals. Program and financial staff review the reports, as well as demands for payment,to ensure goals are being met, costs are eligible and the required back-up documentation is submitted. Appropriate resource materials, (e.g., regulations, OMB Circulars, HUD Policy Notebook, CPD Notices, Subrecipient manual) are passed out to subrecipients at kickoff and subrecipient meetings. To ensure financial management systems are kept in accordance with HUD's regulations,the County's Financial Officer reviews annual audits, sources and uses statements, and demands forlreimbursement. Also, affordable housing development projects (e.g., acquisition, rehabilitation, new construction)submit annual compliance reports throughout the required period of affordability. Through these methods, County staff ensures subrecipients meet and apply the CDBG/HOME program requirements. 1 e A CDBG checklist, developed by the Contra Costa County Consortium, is utilized by County staff when performing on-site monitoring. The checklist covers items such as, program eligibility, national objective,program performance, and recordkeeping. While on-site, County staff interviews subrecipient managers and staff and discuss such subjects as program description and how clients are served. Client files are reviewed to ensure the required documentation is being kept, as well as client eligibility. HOME projects are monitored as required,particularly for rental housing projects. Annual compliance reports are required throughout the period of affordability. The reports are designed to ensure continued compliance with federal regulations, affordability and use restrictions, and other requirements as specified in the project loan documents. In addition, all HOME-assisted projects are subject to on-site inspections to ensure continued compliance with federal housing quality standards and tenant's annual income determinations. Technical assistance (TA)/training was available and provided throughout the program year for all subrecipients. TA/training is accomplished through avenues such as quarterly newsletters distributed to each subrecipient, one-on-one TA, and subrecipient meetings. Conclusion: County staff has a comprehensive monitoring plan in place and utilizes a well thought out checklist to ensure the subrecipient is meeting its goals, serving those intended (low- and moderate iincome clientele), and meeting a national objective, and other requirements of the CDBG program. Annual monitoring of HOME projects is also taking place by County staff to ensure compliance with requirements of the HOME program. The County is monitoring its subrecipients and issuing monitoring letters. Eligibility and National Obiective requirements Based on our review, it was determined that the CDBG activities monitored were eligible under the program at Sections 570.201(e) and 570.203(b) and (c), and were determined to have a met a national objective as described under Section 570.208. HOME funds may,be used by a participating jurisdiction for projects described at Section 92.205 of the regulations. Projects may include development and support of affordable rental housing and homeownership affordability through the acquisition (including assistance to homebuyers), new construction, reconstruction, or rehabilitation. The HOME projects reviewed were eligible projects as described at Section 92.205 of the HOME regulations. CDBG subrecipients monitored included two public service activities and two economic development activities. 1 . Subrecipient: Contra Costa Service Integration Program. Project name: Bay Point Works—Community Career Center 2 This subrecipient received$18,000 in CDBG funds, during PY 2004,to carry out this public service activity within an area where 68.1 percent of the residents are low- and moderate-income. The purpose of this program is to promote the economic self- sufficiency of Bay Point families by improving employability and job-readiness of residents accessing Community Career Center services. Available services included, computer internet access, assistance in preparing job resumes, set up individual email accounts, develop business cards/flyers, and use phones. The goal of the program was to provide services to a minimum of 240 persons. The goal was achieved. Six client files were randomly selected and jointly reviewed by County and HUD staff. 2. Subrecipient: Moss Beach Homes Inc. Project name: Welcome Home Baby—Urban County This subrecipient received $10,000 in CDBG funds, during PY 2004, to carryout this public service activity. The purpose of the program was to provide assistance and counseling to low-income first-time mothers on how to create and maintain a positive, safe, and stable home environment for their new born babies, and also assist in locating affordable housing, as necessary. The subrecipient's goal was to provide service to 50 persons. At the end of the 4 quarter, 26 persons received assistance. During the year, the subrecipient encountered,problems understanding CDBG reporting requirements and integrating those with the requirements of other funders. The subrecipient also had a problem with decreased funding and increased difficulty locating safe and affordable housing for clients. County staff,throughout the year to clarify reporting requirements of the CDBG program, provided TA. Six client files were randomly selected and jointly reviewed by County and HUD staff. 3. Subrecipient: Rubicon Programs, Inc. Project Name: Allied Health Career Ladders—Homecare/Healthcare Career Training. Rubicon Programs, Inc., received $100,000 in CDBG funds to carryout this economic development activity. Training and job placement was provided to extremely low- and very low-income persons for career planning and development that lead to economic self-sufficiency through careers in the health care profession. This program provided training to 50 persons and placed 40 graduates into healthcare jobs. Four client files were randomly selected and jointly reviewed by County and HUD staff. 4. Subrecipient: Fire Dietection Unlimited Project Name: Fire Detection Unlimited CDBG funds were provided in PY 2002 and 2004. Two separate loans in the amount of$75,000 were provided for expansion of the company. The loans were to increase stock so the company could be more competitive by having stock on hand and ready-to-go. Also,to assist the company's success, a Consultant provided by the County provided guidance on financial management, day-to-day operations, and staffing aspects of starting a company. Part lof the contract was that three jobs had to be provided for 3 each loan. The contract terms have been met and the company is doing very well and expanding its area of business. It is located in Martinez and also has a satellite office in San Francisco. Conclusion: The County funded projects that met the eligibility requirements of the CDBG and HOME pr ams,I as well as, met the national objective requirements of the CDBG program. Subrecipient Agreements—,CDBG and HOME Programs Before disbursing an+ y CDBG funds, an executed written agreement with the subrecipient must be in place in accordance with 24 CFR 570.503. The agreement shall remain in effect during any period that the subrecipient has control over CDBG funds, including program income. These agreements must include a statement of work, suspension and termination provisions, program income requirements, record and report requirements, a process for the reversion of assets, and other program requirements described in subpart K of the CDBG regulations. Also, executed agreements under the HOME program were found to contain required program elements as described under 24 CFR 92.504. Conclusion: Our review of subrecipient agreements indicated that the City is in compliance with CDBG and HOME program requirements. Expenditure of HOME and CDBG funds Prior to the on-site(monitoring visit, an in-house review was performed by HUD staff to determine if the County met the CDBG timeliness standard and the HOME commitment and disbursement requirements. Timeliness of CDBG funds expenditures: The CDBG program regulations at 570.902 state that 60 days prior to the end of the grantee's current program year (April 301h),the amount of entitlement grant funds available to the recipient under grant agreements, but undisbursed by the U.S. Treasury, may not be more than 1.5 times the entitlement grant amount for its current program year. Conclusion: The County met the timeliness threshold for PY 2004. HOME—Commitments and Disbursements: The HOME Final Rule at 92.500(d)(1)(B) and(C) requires each Participating Jurisdiction(PJ)to commit program funds within two years and disburse funds within five years of execution of a HOME grant agreement. A review was performed of the County's 2002 and 2003 Program Years for commitment, and PYs 1999 and 2000 for disbursement. 4 Conclusion: The County consistently meets the CDBG timely expenditure of funds requirements. As far as meeting HOME expenditure requirements,the County met the two-year requirement to commit its PY 2002 and 2003 HOME funds, and has also met the five-year disbursement rule for its Program Year 1999 and 2000 HOME funds. HOME Program -Match Prior to the on-site monitoring visit, an in-house review was performed by HUD staff to determine if the County was meeting the HOME program match requirement. The HOME program, at Section 92.218-92.222, requires each PJ to make match contributions equaling 25 percent of the HOME funds it expends for certain housing activities each program year. IThe match must be a permanent contribution from non- Federal public and private sources, such as local and state government, charitable organizations/foundations and private sector lenders. Conclusion: A review of the County's documentation for tracking match obligations and contributions supports the County's compliance with this requirement. 5