Record Retention List

The record retention period for CDBG contracts is based in part on the State of Texas CDBG grant from the U.S. Department of Housing and Urban Development (HUD). Each CDBG contract is awarded from a much larger State Grant. The annual State Grant used to fund most TxCDBG contracts is known as the Grant Year; other special funding, such as the Disaster Recovery funds, are awarded through separate State Grants.

Once all contracts awarded under the State Grant have been completed and closed by TxCDBG, TDA will request HUD to close the State Grant. The record retention period for all CDBG contracts included in the State Grant begins on this date (if all other requirements have been satisfied as described below).

Example: State Grant Year 2009 is a $73 million grant awarded to the State of Texas in July 2009 that was used to fund over 320 contracts throughout rural Texas.  The last payment using these funds was completed in May 2021, and HUD confirmed the State Grant closeout in February 2022. The records retention period will begin in February 2022.

Here is a listing of all contracts funded through the newly closed State Grant, along with the date the State Grant was closed. TxCDBG funds hundreds of contracts through each State Grant; therefore, closeout of the State Grant may be completed a number of years after the closeout of an individual contract between the Grant Recipient and the State.

Record Retention Period

The record retention period for a Grant Recipients’s contract does NOT begin when the contract between the Grant Recipients and the State is closed.

All local records relating to a CDBG contract must be maintained for the greater of:

1) four years after close-out of HUD’s grant to the State of Texas as identified in the TxCDBG Record Retention List
2) the date that the final audit is accepted with all audit issues resolved to TXCDBG’s satisfaction, if notified by TDA in writing (Please see date of TXCDBG audit acceptance letter if applicable); or
3) a date consistent with the period required by other applicable laws and regulations as described in 24 CFR 570.487 and 570.488.
     (This date is not typically the final record retention date for CDBG contracts.)

Generally, the record retention periods related to item 2 above will be satisfied prior to the closeout of the State Grant. However, certain contracts may be required to retain records for additional time due to unique circumstances or specific grant-funded activities. If any litigation, claim, or audit is started before the expiration of the record retention period, the records must be kept until the action has been resolved. The acceptance date for the final audit report is the date of the letter notifying the Grant Recipients of its acceptance.

All CDBG contract records must be available for review by HUD until the retention period is satisfied.