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b. Require that grantee or subrecipient employees,officers and agents not accept gratuities,favors <br /> or anything of monetary value from contractors potential contractors or parties to subagreements; <br /> and <br /> c. Stipulate provisions for penalties,sanctions or other disciplinary actions for violations of <br /> standards. <br /> A conflict would arise when any of the following has a financial or other interest in a firm selected for <br /> award: <br /> a. An employee,agent or officer of the grantee or subrecipient; <br /> b. Any member of an employee's,agent's or officer's immediate family; <br /> c. An employee's,agent's or officer's partner;or <br /> d. An organization that employs or is about to employ an employee,agent or officer of the grantee or <br /> subrecipient. <br /> In cases not covered by the above,the CDBG regulations at 24 CFR 570.611 governing conflict-of- <br /> interest apply. These provisions cover employees,agents,consultants,officers and elected or <br /> appointed officials of the city or subrecipient The regulations state that no person covered who <br /> exercises or has exercised any functions or responsibilities with respect to CDBG activities or who is <br /> in a position to participate in decisions or gain inside information: <br /> a. May obtain a financial interest or benefit from a CDBG activity; <br /> b. Have an interest in any contract,subcontract or agreement for themselves or for persons with <br /> business or family ties. <br /> This requirement applies to covered persons during their tenure and for one year after leaving the city <br /> or subrecipient entity. <br /> Upon written request,exceptions to these provisions may be granted by HUD on a case-by-case basis <br /> only after the city has: <br /> a. Disclosed the full nature of the conflict and submitted proof that the disclosure has been made <br /> public,and <br /> b. Provided a legal opinion from the city stating that there would be no violation of state or local law <br /> if the exception were granted. <br /> 6. ENVIRONMENTAL REVIEW <br /> The city is responsible for undertaking environmental reviews in accordance with the Environmental <br /> Handbook. The Environmental Review must be completed before funds are committed. <br /> 7. FLOOD INSURANCE <br /> Section 202 of the Flood Disaster Protection Act of 1973(42 USC 4106)requires that CDBG funds <br /> shall not be provided to an area that has been identified by the Federal Emergency Management <br /> Agency(FEMA)as having special flood hazards unless: <br /> a. The community is participating in the National Flood Insurance Program,or it has been less than <br /> a year since the community was designated as having special flood hazards;and <br /> b. Flood insurance is obtained. <br /> 8. DISPLACEMENT,RELOCATION,ACQUISITION AND REPLACEMENT OF <br /> HOUSING <br /> Projects involving acquisition,rehabilitation or demolition may be subject to the provisions of the <br /> Uniform Relocation Act. <br /> Forgivable Loan Policy and Application P O M [ R 1 U of <br /> INAWREE] <br /> Page 8 of 20 <br />