CPD Notice 14-016, issued October 2014, provides guidance on the use of Community Development Block Grant (CDBG) funds for code enforcement activities. The Notice unintentionally omitted a discussion on the possible applicability of the Uniform Relocation and Real Property Acquisition Policies Act of 1970 (URA) and Section 104(d) of Housing and Community Development Act of 1974 (section 104(d)) to code enforcement activities.
Although the URA and section 104(d) are not automatically triggered by code enforcement activities, grantees should be mindful that in some cases the URA and section 104(d) could apply. For example, for purposes of the URA, if the code enforcement action is undertaken to evict persons for a federally-assisted project involving acquisition, rehabilitation or demolition; or for purposes of section 104(d), if the code enforcement is being conducted “in connection with” an anticipated development project involving demolition or conversion. See HUD Handbook 1378 Chapters 1-4 J.3 and 7-4 A.3 for guidance on this issue.
If you have additional questions, please contact your local HUD Regional Relocation Specialist for additional assistance.