ESG Expenditure Deadline

ESG CARES ACT Subrecipient:


Many of you may be aware of a recently posted message from HUD regarding the expenditure deadlines HUD set forth in Notice CPD-21-08. The notice provides that “HUD has determined it will not recapture funds from recipients who do not meet that deadline” and that they are “considering whether it is necessary to establish a later deadline to the replace the March 31, 2022, expenditure for expending 80% of each ESG-CV grant.


As of today, HUD has not issued any further guidance on this matter.  To be clear, OEO/the state of SC is the recipient of the funds and agencies awarded CARES Act funding are the subrecipients. This guidance is related to the expenditure deadlines that HUD has set on OEO/ the state. 


Subrecipients are still under obligations set forth in the grant agreement entered into.   Please refer to page 7, Paragraph 7, Expenditures:


Subgrantee must expend, at a minimum, 80% of the amount awarded for ESG‐CV by March 31, 2022.


OEO may recapture up to 80 percent of a Subgrantee’s total award if the Subgrantee has not expended at least 80 percent of that award by March 31, 2022.


Prior to recapturing funds as described above, Grantee will follow the enforcement process described in 24 CFR 576.501 and provide the Subgrantee with an opportunity to provide a spending plan demonstrating to Grantee’s satisfaction that all of the recipient’s ESG-CV Phase Two funds from will be expended by September 30, 2022.



Also please note under page 9, Paragraph 10 . Reimbursement, that, “Subrecipients are required to submit request for reimbursements at least quarterly.” Please ensure that you are in compliance with this requirement.


Should you have any questions please contact me.



Gregg C. McConkey
ESG Manager, Office of Economic Opportunity

The South Carolina 

Department of Administration

1205 Pendelton Street, Suite 362, Columbia, SC 29201