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Conflict of Interest

 

Conflict of Interest (Community Development Block Grant)

Per the City of Rockford’s Community and Economic Development Conflict of Interest Policy, conflicts of interest arise when officials or staff stand to benefit either directly themselves or indirectly through business partner or relatives from the awarding or contracting of grant funds.  The City is encouraged to avoid conflicts of interest to the extent possible.  However, this does not mean the City has to deny CDBG assistance.  If when a conflict of interest arises, the City property identifies, discloses and manages it in compliance with Super Circular 2 CFR Part 200.112 Conflict of Interest and 24 CFR Part 570.611 Conflict of Interest for CDBG an exemption may be granted.  In the procurement of supplies, equipment, construction, and services by the City and by subrecipients, the conflict of interest provisions in 2 CFR 200.318 shall also apply.

A conflict of interest is when persons covered gain an actual or perceived direct or indirect, benefit from a CDBG funded activity.  Persons covered are employees, agents, consultants, officer, elected or appointed officials of the recipient, or of any designated public agencies, or of subrecipients that are receiving  CDBG who:

  1. Are in a position to participate in a decision making process or gain inside information with regard to such activities;
  2. May obtain a financial interest or benefit from a CDBG-assisted activity, or
  3. Have a financial interest in any contract, subcontract, or agreement with respect to a CDBG-assisted activity, or with respect to the proceeds of the CDBG-assisted activity, either for themselves or those who they have business or immediate family ties, during their tenure or for one year thereafter.

Immediate family ties include: Spouse, parents, stepparents, children, stepchildren, brother stepbrother, sister, stepsister, grandparents, grandchild, and In-laws.

Conflict of Interest (HOME Investment Partnerships Program)

Conflicts of Interest arise when officials or staff stand to benefit either directly themselves or indirectly through business partners or relative from the awarding or contracting of grant funds.  The City Community and Economic Development Department is encouraged by its Federal funder to avoid conflicts of interest to the extent possible.  However, this does not necessarily mean that any individual acted improperly or illegally, but it does mean that, unless properly handled and addressed, there could be a violation of federal rules.  When conflicts of interest arise, the City must identify, disclose, and manage them in compliance with Super Circular 2 CFR Part 200.12 Conflict of Interest and 24 CFR Part 92.356 HOME Conflict of Interest, an exception request may be made.

A conflict of interest is when covered persons gain an actual or perceived, direct or indirect, benefit from a HOME funded activity.  Covered persons are employees, agents, consultants, officers, elected or appointed officials of the City or a sub-recipient which are receiving HOME funds who:

  1. Exercise or have exercised any functions or responsibilities with respect to HOME asdsisted activities
  2. Are in a position to participated in a decision-making process or gain inside information with regard to HOME assisted activities
  3. May obtain a financial interest or financial benefit from a HOME-assisted activity, or
  4. Have a financial interest in any contract, subcontract, or agreement with respect to the HOME-assisted activity, or the proceeds from such activity, either for themselves or those with whom that have business or immediate family ties, during their tenure or for one year thereafter.

Immediate family ties include the following by blood, marriage, or adoption:  The spouse, parents, stepparents, children, stepchildren, brother, stepbrother, sister, stepsister, grandparents, grandchild, and in-laws of covered persons.