After You Apply for STORM Funds

Loan Fund Administration

Period of Performance

Performance Reporting

Environmental and Historic Preservation

Post-Closeout Report

Corrective Actions

Grant Closeout

A revolving loan fund (RLF) is a funding mechanism where loans are issued from the administering entity to eligible recipients for a project, and then after the project is completed, the loans are repaid to the loan fund with interest.

As local governments repay loans, these funds can be utilized for new loans.

FEMA recognizes that entities will have expenses associated with the management of revolving loan funds prior to receiving payments from loan recipients. Upon award, entities can use the capitalization grant funds to help administer the loan as long as expenses do not exceed whichever of the following amounts is the greatest:

• $100,000 per year;
• 2% of the capitalization grants made to the participating entity in a fiscal year; or,
• 1% of the value of the entity loan fund.

Loan recipients must establish a dedicated source of revenue for repaying their loans. Entities are encouraged to work with local governments to understand potential revenue streams that can support projects and activities that are non-revenue generating.

The entity must publish information about all projects receiving funding. The statutory requirement creates flexibility in the frequency (“periodically”) and the location (“publish”) for the publication of information requirements.

To ensure the easiest approach, FEMA requires entities publish and update information publicly on a preferred platform and at intervals during and after the period of performance most suitable to the entity. The objective of the publication of the information reporting process is to provide the public with knowledge of funded project activities.

FEMA’s verification of the publication of information statutory requirement will be reviewed during quarterly progress reports and or other annual requirements.

The period of performance for the grants is 24 months from the date of award. All loans issued from the capitalization grant must be committed as loans within this time, including the corresponding 10% entity contribution to the entity loan fund.

Projects funded by the loans do not need to be completed within the period of performance for capitalization grants, and loans do not need to be fully repaid during the period of performance. As an entity receives loan and interest payments, they can fund additional projects after the grant’s period of performance ends.

FEMA will monitor the use of funding through annual reporting mechanisms and audits. Annual Intended Use Plan and Project Proposal List submissions will also be required, regardless of whether the grant recipient submits additional grant applications in the following years.

As the loan fund is designed to operate beyond the Period of Performance of the grant, long-term monitoring is needed to verify that the program is operating as intended including monitoring the financial position of the fund and the use of federal dollars. Quarterly Progress Reports and annual audits are not required after the period of performance. Post-closeout reporting by the entity loan fund will be detailed in the closeout agreement.

FEMA will evaluate progress of the loan fund administration, project effectiveness, and equity promotion through its established performance measures. Based on submitted performance reporting, FEMA may make recommendations for or require specific changes to an entity loan fund to improve the effectiveness of the fund.

FEMA uses the Payment and Reporting System (PARS) for financial reporting, which includes the annual submission of the SF-425 Federal Financial Report.

All other reporting requirements and attachments will be submitted in ND Grants System.

FEMA will begin monitoring project implementation through quarterly progress reports (QPR). Entities, as part of a FEMA project management best practice, are to monitor and evaluate the progress of the loan fund and project implementation per the Intended Use Plan through the submission of quarterly reports.

These quarterly performance measures will be evaluated with participating entities in this first year to learn more about funds are being used.

FEMA will update performance measures once there is more data on the project types from the Project Proposal List. 

Checklist for the Quarterly Performance Report

• Recipients must report on the grant’s progress quarterly using the Quarterly Performance Report spreadsheet and upload it to ND Grants System. Information includes partial calendar quarters and periods when no grant award activity occurs. Reports are due within 30 days from the end of the first federal quarter following the initial grant award.
• FEMA will provide participating entities with Quarterly Performance Report templates. During the Period of Performance, FEMA may make recommendations for or require specific changes to an entity loan fund to improve the effectiveness of the fund.
• These progress reports are only required to be submitted to FEMA during the Period of Performance.
• FEMA will evaluate progress of the loan fund administration, project effectiveness, and equity promotion through its established performance measures.
• In closeout agreements, details on measuring and reporting on the performance of the program past the Period of Performance, including metrics captured in the Quarterly Performance Report template and frequency of submission, will be established. 

Audits are undertaken to report on the financial performance of the program and to determine whether funds were properly used and distributed over the course of a year. The audit is conducted to evaluate the financial statements of a loan fund and determine whether those statements adhere to generally accepted accounting principles (GAAP) and are aligned with the intent of the program. Section 200.328 in Title 2 of the Code of Federal Regulations requires an annual audit.

The Biennial Audit is conducted to evaluate the financial statements of a loan fund and determine whether those statements adhere to generally accepted accounting principles (GAAP) and align with the intent of the program.  Section 205(h)(1) of the Robert T. Stafford Disaster Relief and Emergency Assistance Act require biennial audits.

The annual audit will include an audit report containing an audit opinion, as well as any findings.

In general, the audit report will contain the following information: 

• An opinion on whether the financial statements are fairly presented in accordance with GAAP;
• A description and assessment of internal controls relative to the financial statements and other entity loan fund management processes.
• An assessment of entity compliance with laws, regulations, and terms of the grant award; and
• General findings and questioned costs.

Entities will arrange for an independent, annual audit of program operations to document compliance with all necessary authorities, internal controls on loan and program management, and GAAP.

Every other year reports will include a review of how effective the entity loan fund was with respect to meeting the goals and intended benefits described in the intended use plan. The Biennial Audit report contains the following information: 

• An opinion on whether the financial statements are fairly presented in accordance with GAAP;
• Description and assessment of internal controls relative to the financial statements and other entity loan fund management processes;
• Assessment of entity compliance with laws, regulations, and terms of the grant award;
• General findings and questioned costs; and
• Alignment of outputs and outcomes of projects with the goals and objectives stated in the Intended Use Plan.

The Environmental and Historic Preservation review of loan projects occurs after the award of the capitalization grant. For this funding opportunity, FEMA intends to review checklists submitted by entities and loan recipients and conduct Environmental and Historic Preservation reviews for projects awarded under this initial funding opportunity. FEMA will publish a checklist to assist with project compliance reviews that will be available on this webpage.

Entities will be asked to indicate within their grant application materials which projects would require Environmental and Historic Preservation review.

Projects that may impact the environment, including, but not limited to, the construction of communication towers, modification or renovation of existing buildings, structures, and facilities, or new construction including replacement of facilities, must ensure projects participate in the Environmental and Historic Preservation review process.

Project types that don’t require Environmental and Historic Preservation reviews include mitigation planning, building code adoption and enforcement, and zoning and land-use planning.

Additionally, loans may be used as a non-federal cost match for another Hazard Mitigation Assistance (HMA) grant application. In this situation, FEMA will complete the Environmental and Historic Preservation review process following the procedures of the FEMA HMA grant program.

FEMA may delegate responsibility to entities interested in reviewing and ensuring compliance with all applicable Environmental and Historic Preservation laws. FEMA will provide guidance on the delegation process in the future based on coordination with participating entities. 

The Period of Performance Reporting will be achieved through quarterly progress reports, and the annual audits are the primary reporting requirements that will end after the period of performance.

Post-closeout reporting is necessary to evaluate the performance of the fund administration, the effectiveness of projects, and the promotion of equity beyond the Period of Performance.  Consistent with the processes of similar programs from other federal agencies, FEMA’s grant closeout agreement will specify the type and frequency of reporting needed to ensure compliance with the program statute and priorities. 

The Safeguarding Tomorrow RLF program performance measurement process aims to ensure that the program's intended goals are fulfilled through disbursements from the loan fund. As the loan fund is designed to operate beyond the Period of Performance of the grant, long-term monitoring is needed to verify that the program is operating as intended including monitoring the financial position of the fund and the use of federal dollars.  

The Post-Closeout Report differs from the Quarterly Progress Report because it:

• Applies to the terms and conditions of the closeout agreement and allows FEMA to evaluate program objectives beyond the POP and
• Involves long-term financial metrics that require more than two years of performance to evaluate.  

A corrective action may be needed if an entity’s performance measures do not achieve the established performance measure target. FEMA will work directly with the entity to develop corrective actions to support the program objectives and address challenges.

Corrective actions may focus on the financial management of the fund and processes or specific project support guidance. Corrective actions may come in the form of a written report of the performance review findings and actions that the entity must take to address non-compliance. FEMA may notify the entity of the deficiency and request that the issue is corrected following identified procedures. 

However, the program contains post-POP reporting requirements based on the authority of the statute and funding opportunity. The publication of information, annual Intended Use Plan and Project Proposal List submission, and biennial audits are statutory reporting requirements that are mandatory for the existence of the entity loan fund. Revolving loan fund programs are designed to operate for many years beyond the period of performance of the capitalization grant and require long-term resource requirements and reporting.

The Safeguarding Tomorrow RLF program does not require a Project Completion Report to notify FEMA on project closeout for entity loan-funded projects. Performance reporting requirements will include information on details of completed projects, including end date, final cost, and outcomes.

Regarding the closeout reporting requirements for the capitalization grant award (which do not apply to specific projects, but rather, the entity loan fund generally), the requirements are:  

• Within 120 calendar days after the end of the period of performance for the capitalization grant award or after an amendment has been issued to close out an award before the original period of performance ends.
• Recipients must liquidate all financial obligations and must submit a final request for payment, If applicable, using the final Federal Financial Report (SF-425)
• A final progress report detailing all accomplishments (including a narrative summary of the impact of those accomplishments throughout the period of performance) and other documents required in the funding opportunity, terms and conditions of the award, or other FEMA guidance.