Emergency Rental Assistance (ERA2): Closeout Resource
Summary
This Treasury resource is for recipients of Emergency Rental Assistance (ERA2) awards on closing out those awards. It states that the period of performance for ERA2 awards ends on September 30, 2025, and that obligations must be paid in full within 120 calendar days after that date. Subrecipients must submit final financial and performance reports to recipients within 90 calendar days after September 30, 2025, and recipients must submit a Final Report to Treasury. The liquidation period runs October 1, 2025 to January 28, 2026, and the Notification of Completion generally will be issued within one year of the period of performance end date.
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“Emergency Rental Assistance (ERA2): Closeout Resource.”
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U.S. Department of the Treasury
Emergency Rental Assistance (ERA2): Closeout Resource
The following information is to be used as a resource by ERA2 recipients (“recipients”) 1 for
closeout of their Emergency Rental Assistance (ERA2) awards. The period of performance for
ERA2 awards ends on September 30, 2025.
• Section I of this document details closeout information and resources.
• Section II of this document provides additional post-closeout compliance reminders.
Recipients are advised to monitor the ERA2 Guidance and ERA2 Reporting pages on Treasury’s
ERA programs’ website for additional compliance resources.
Section I: Closeout Information and Resources
General Closeout Overview
The purpose of award closeout is to ensure that:
• Recipients have completed the ERA2 award objectives.
• The ERA2 Final Report indicates that ERA2 award funds were expended on allowable
costs.
• Any balances of unobligated and unexpended funds remaining on the ERA2 award are
returned to Treasury.
• A proper accounting of any real and tangible personal property, as applicable, purchased
with ERA2 award funds is submitted.
• Recipients certify that the data submitted in the ERA2 Final Report complies with the
terms and conditions of the ERA2 Award Terms. 2
The period of performance (POP) for ERA2 awards ends on September 30, 2025 (end of the
award term), which marks the last day that recipients may obligate ERA2 award funds for
administrative and program expenses, and such obligations must be paid in full within 120
calendar days after September 30, 2025 to facilitate inclusion of those transactions in the Final
Report. As such, ERA2 recipients may cover only rent, utility and home energy expenses, arrears
1
ERA2 Guidance also refers to ERA2 recipients as “ERA2 Grantees.” These terms may be used interchangeably.
2
Note ERA2 Award Terms stipulate federal regulations applicable to this award include Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance), 2 C.F.R. Part
200, other than such provisions as Treasury may determine are inapplicable to this award and subject to such
exceptions as may be otherwise provided by Treasury. ERA2 recipients continue to be subject to the November 12,
2020 version of 2 C.F.R. Part 200 in effect at the time that the ERA2 Award Terms were executed by ERA2
recipients, unless otherwise specified. See CFR :: 2 CFR Part 200 (Nov. 12, 2020) -- Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards. See also page 8 of this document for
more on the 2024 revised 2 CFR 200.313(e) regarding equipment disposition and 2 CFR 200.314(a) regarding
supplies that now apply to ERA2 awards per Treasury’s Notification to ERA2 grantees on August 13, 2025.
ERA2 Program Closeout Resource
for rent, utility and home energy costs, other expenses related to housing, expenses for housing
stability services, affordable rental housing projects, and eviction prevention activities arising
before September 30, 2025. ERA2 recipients may not provide prospective assistance for rent,
utility and home energy expenses, other expenses related to housing, expenses for housing
stability services, or affordable rental housing projects, and eviction prevention activities for a
period beyond September 30, 2025.
For the purposes of this document, please note the following distinctions:
• Recipients that have not initiated award closeout and the award POP has not expired will
be referred to as having “open awards.”
• Recipients that submitted the Final Report to Treasury for closeout of their ERA2 award
within 120 calendar days after September 30, 2025 are in “standard closeout.”
• Recipients may choose to initiate the award closeout process before September 30, 2025
and those that do so are engaged in “early closeout.”
• “Closed awards” refer to recipients for which Treasury has completed its closeout
process on their award and issued a Notification of Completion to the recipients.
Figure 1: General Closeout Process
Recipient Recipient
conducts award Recipient returns Treasury
Treasury
closeout submits Final unspent or sends
Closeout
activities Report disallowed Notification of
Review
funds to Completion*
See sections on
“standard” or
Treasury
“early” closeout for
details.
No further award expenditures are permitted.
*Generally, the Notification of Completion will be issued within one year of the POP end date (September 30,
2025) or, in the case of early closeout, one year from the date the recipient submitted the Final Report to Treasury.
All recipients are required to submit their Final Report to Treasury to close out their ERA2
award. The “Final Report” mirrors the ERA2 Quarterly Report, but also includes special sections
regarding real and tangible personal property, as applicable, purchased with the ERA2 award. 3
Treasury reserves the right to request additional documents to support the Final Report. Failure
to submit a timely and accurate Final Report may result in administrative closeout of your
ERA2 award and affect receipt of future federal funding by the ERA2 recipient. 4 Treasury
3
Please see pages 8-9 for more details.
4
If the recipient fails to submit a timely and accurate Final Report, Treasury may proceed with administrative
closeout of the ERA2 award in accordance with 2 CFR 200.344(h) and the recipient will be deemed noncompliant
with the ERA2 Award Terms.
2
ERA2 Program Closeout Resource
may also pursue other remedial actions per 2 CFR 200.339. No later than 120 calendar days after
September 30, 2025, recipients must complete the following closeout activities:
• Reconcile financial expenditures associated with the ERA2 award.
• Liquidate all ERA2 award obligations incurred by September 30, 2025.
• Determine whether any balances of unobligated and unexpended funds remain on the
ERA2 award.
• Determine the status of all real and tangible personal property, and unused supplies
purchased with ERA2 award funds.
• Prepare and submit the required Final Report to Treasury.
After the submission (or submission deadline) of a recipient’s Final Report, Treasury will
implement a Closeout Review of ERA2 awards (see page 10 for more details). Upon the
completion of closeout actions and resolution of any outstanding matters regarding the ERA2
awards, Treasury will send a Notification of Completion.
“Early Closeout” Process
Recipients that complete all award objectives, including administrative actions (which include
any final operational activities), on their ERA2 award prior to September 30, 2025 may request
to initiate “early closeout” of their ERA2 awards. 5
Recipients initiate early closeout by submitting the Final Report. Any financial obligations 6
entered into prior to submission of the Final Report to Treasury must be liquidated (expenses
charged or billed against the award including contracts must be paid in full) and operational
activities associated with the award must be completed prior to submitting the Final Report to
Treasury. Once the recipient has submitted the Final Report to Treasury, the recipient may not
obligate or expend any remaining award funds for any purpose. Once the recipient submits the
Final Report, the recipient is also no longer required to submit regular ERA2 quarterly reports.
The recipient will remain subject to records retention and audit requirements (see pages 14-16).
5
Per 2 CFR 200.340, the early closeout of an ERA2 award can be triggered by one of the following circumstances:
(1) termination of the ERA2 award by Treasury with the consent of the recipient prior to the end of the POP, in
which case the two parties must agree upon the termination conditions (see 2 CFR 200.340(a)(3));(2) termination of
the ERA2 award by the recipient prior to the end date of the POP because it is no longer able to carry out the
objectives of the award (see 2 CFR 200.340(a)(4)); (3) termination of the ERA2 award by Treasury prior to the end
date of the POP because the recipient failed to comply with the requirements of the ERA2 Award Terms
(termination for cause, see 2 CFR 200.340(a)(1)); (4) termination of the ERA2 award by Treasury prior to the end
date of the POP because the award no longer effectuates the program goals or agency priorities (termination for
convenience, see 2 CFR 200.340(a)(2)). In addition, early closeout can be triggered by the recipient when it has
expended all its award funds and completed all the objectives of the ERA2 award, including administrative actions,
prior to the end of the award POP. See 2 CFR 200.344.
6
Per 2 CFR 200.1, the term, “financial obligation” is defined as “orders placed for property and services, contracts
and subawards made, and similar transactions that require payment by a recipient or subrecipient under a Federal
award that will result in expenditures by a recipient or subrecipient under a Federal award.”
3
ERA2 Program Closeout Resource
Treasury has established a review process to help support a successful early closeout (Figure 2):
1. Recipient determines that it will soon be ready to initiate early closeout, self-
identifying the completion of award objectives and expenditures, including administrative
actions like final operational activities.
2. Recipient requests to closeout its award early through Treasury’s Portal.
3. Treasury will review the early closeout request and consult with the recipient, if
needed.
4. Treasury will notify and provide the recipient access to the Final Report through
Treasury’s Portal, if Treasury determines that the recipient may proceed with early
closeout.
5. The recipient submits the Final Report to Treasury to initiate the award closeout
process. Note that the recipient must continue to submit all regular quarterly reports until
the Final Report is submitted to Treasury. 7
In general, Treasury will begin to review the Final Report within 180 days after receiving
the Final Report. Treasury will work with the recipient to finalize the award closeout,
generally within one year of the submission of the Final Report.
Figure 2: “Early Closeout” Process
Program POP
Recipient Recipient Treasury Treasury Recipient
•Forecasts •Requests •Reviews the •Grants the •Submits Final
completion of early closeout early closeout recipient access Report to
award through request, which to the Final Treasury Treasury’s
objectives and Treasury's may include a Report through
expenditures, Portal. consultation Treasury's Note: the recipient Early Closeout
must continue to
including with the Portal once submit quarterly Review Begins*
administrative recipient. Treasury reports until the
actions. verifies the Final Report is
recipient is submitted to
Treasury.
ready for
closeout.
Recipient may obligate and expend funds according to the various
requirements of the ERA2 award; all obligations must be liquidated No further award expenditures are
prior to submitting the Final Report to Treasury. permitted.
*Please refer to Figure 1: General Closeout Process for process steps following the start of Treasury’s Closeout
Review process.
7
Treasury retains the right to reject the submission of a recipient’s Final Report. In this case, the recipient must
continue to submit regular quarterly and annual reports through the end of the award POP.
4
ERA2 Program Closeout Resource
“Standard” Closeout Process and Timelines
The end of the award term marks the beginning of the “standard” closeout process for all
recipients of ERA2 awards that did not initiate early award closeout. Recipients will have 120
calendar days after September 30, 2025 to submit their Final Report to Treasury via Treasury’s
Portal. Subrecipients must submit their final financial and performance reports, as applicable, to
the recipients no later than within 90 calendar days after September 30, 2025 (Figure 3).
Recipients must obligate award funds by September 30, 2025 to cover administrative costs
for closeout activities carried out during the liquidation period (October 1, 2025 - January 28,
2026). 8 Obligations incurred by September 30, 2025 for allowable administrative and program
expenses must be paid in full prior to the end of the liquidation period and those transactions
must be included in the Final Report, which must be submitted to Treasury by January 28, 2026. 9
Figure 3: “Standard Closeout” Process and Timeline
Liquidation Period
October 1, 2025 Recipient
Start of the
December 29, 2025
submits Treasury’s
January 28, 2026
liquidation period Subrecipient's final Final Closeout
Award POP following the end of financial and
the Period of Recipient's Final
performance Reports Report is due to Report Review
Performance are due to recipient Treasury
(monitored by the
Begins*
recipient)
Recipient may Recipient may expend funds obligated by 9/30/2025 for
allowable administrative and program activities; all No further award
obligate and
obligations must be liquidated prior to submitting the expenditures are permitted.
expend funds.
Final Report to Treasury.
*Please refer to Figure 1: General Closeout Process for process steps following the start of Treasury’s Closeout
Review process.
8
Note that ERA2 award funds received through reallocation are subject to the same closeout timeline requirements
as funds received as part of the recipient’s initial allocation.
9
Note that obligations incurred by subrecipients by September 30, 2025, must be paid in full within 90 calendar
days after September 30, 2025 for allowable administrative and program expenses or an earlier date as agreed upon
by subrecipient and recipient.
5
ERA2 Program Closeout Resource
Standard Closeout Liquidation Period: Prohibited and Allowable Operations
After September 30, 2025, recipients are prohibited from using ERA2 award funds for the
following program activities:
• New obligations of funds to support administrative activities.
• Assessment of applicant eligibility for ERA2 services and assistance.
• New obligations of funds or payment for provision of housing stability services or
eviction diversion services to renters for a period beyond September 30, 2025.
• New obligations of funds or payments for provision of prospective assistance, for
example, recipients are prohibited from prospectively providing financial assistance for
rent, utility and home energy expenses, arrears for rent, utility and home energy costs,
and other expenses related to housing to renters for a period beyond September 30, 2025.
• Affordable rental housing and eviction prevention purposes, as defined in FAQ 46.
Affordable rental housing purposes include, the acquisition, construction, rehabilitation,
or preservation of affordable rental housing projects serving very low-income families,
predevelopment activity, as well as the operation of affordable rental housing projects
serving very low-income families that were constructed, rehabilitated, or preserved using
ERA2 funds. Eviction prevention purposes are defined in the same manner as housing
stability services under FAQ 23; however, services provided with funds made available
for eviction prevention purposes must serve very low-income families.
Allowable administrative and program activities using ERA2 award funds must be obligated by
September 30, 2025. Continued expenditures of those obligated award funds during the standard
closeout liquidation period may include:
• Administrative expenses to support closeout activities (including administrative support
services and other direct and indirect expenses that support administrative activities
provided through staffing costs, subawards, contracts, preparation of Final Report and
documents, etc.).
• Payment processing for:
o Approved ERA2 applicants; this would include payment processing for rental
payments, utilities, or other allowable expenses incurred for a period prior to
September 30, 2025. Note that the provision of prospective program assistance
(e.g. prospective rental payments, utility bills, housing stability services, etc.)
after September 30, 2025 is prohibited. For example, ERA2 award funds cannot
pay October 2025 rent for a tenant under any circumstances.
o Housing counseling, eviction prevention, or other housing stability services that
occurred prior to September 30, 2025.
• Documentation, assessment, and retention activities. See page 8 for details on obligating
and expending funds for this purpose.
• Data security measures and protection of personally identifiable information, which may
include appropriate measures to ensure that the privacy of renters is protected and
provide confidentiality protections for data collected about any renters who are survivors
of intimate partner violence, sexual assault, or stalking.
• Review and reconciliation of general ledger, accounting, reporting, bank reconciliation,
program policies, procedures, and controls to prevent fraud and improper payments,
6
ERA2 Program Closeout Resource
which may involve follow-up with end-beneficiaries (e.g., renters, landlords, utility
companies, etc.) to reconcile documentation, as needed.
• Continued internal auditing of approved applications for potential duplication of
assistance and associated remedial activities, as appropriate.
• Single audits or program-specific audits required per 2 CFR Part 200, Subpart F, Audit
Requirements, if applicable.
Preparing to Submit Final Report
Recipients must submit Final Report with cumulative financial information, performance
information and as applicable, real property and tangible personal property information. For
general reporting requirements, the ERA2 Final Report User Guide, and other reporting
resources, please see ERA2 Reporting webpage.
The following considerations and questions can help support an accurate report and clear
communications as recipients work through the closeout process:
• Does the data align with ERA2 program guidance? For instance:
o Does the total amount expended for administrative expenses fall within the limit of
15% of the total ERA2 award amount as set forth in the ERA2 Guidance? 10
o Does the total amount expended on housing stability and eviction prevention services
fall within the standard limit of 10% of the total ERA2 award amount as set forth in the
ERA2 Guidance?
If the recipient is reporting investment in these services beyond the initial 10%, are those
additional investments reported as an Eviction Prevention Projects and in compliance with
the requirements set forth in FAQ 46? 11
o Are funds used for affordable rental housing purposes reported as Affordable Rental
Housing Projects and complies with the requirements outlined in FAQ 46?
• Does the Final Report accurately reflect the recipient’s aggregate financial and
programmatic data throughout the award POP? Recipients should check:
o Whether total expenditures and obligations align with the total (net) award.
o Whether there are any unobligated balances by the end of the POP or unliquidated
obligations by the end of the closeout period; if yes, see pages 10-13 for more
information about repaying of ERA2 award funds.
o The completeness and accuracy of the project data and participant demographics (as
applicable), as submitted in the Final Report.
o Activities associated with any real property or tangible personal property, supplies, or
other assets purchased with ERA2 award funds for the provision of allowed activities to
support the housing stability of eligible tenants were complete (installed or completed
in accordance with the description of the reported Affordable Rental Housing Project)
10
See FAQ 29 for guidance on using ERA2 award funds for administrative expenses.
11
See “Reporting Decision Tree: Housing Stability & Eviction Prevention Services” in ERA2 Reporting Resource
and Housing Stability Services Overview (pages 28) for tips on reporting housing stability services in Table 5 under
“Rental Assistance Project” and reporting similar activities as “Eviction Prevention Projects.”
7
ERA2 Program Closeout Resource
prior to the expiration of the POP (in the case of standard closeout) and prior to the
recipient submitting the Final Report (in the case of early closeout).
• Have you accounted for record retention requirements? The ERA2 Award Terms stipulate
that recipients must retain records pertaining to the ERA2 award for 5 years after the end of
the period of performance (September 30, 2025 or when the recipient submits the Final
Report to Treasury).
o Any administrative funds utilized to support record retention requirements:
• Must be reasonable and consistent with the recipient’s policies and procedures
regarding the standard for retaining such records and the amount of money the
recipient would have paid for retaining its non-federal records.
• Must not exceed the limit for administrative costs which is 15% of the total
ERA2 award amount.
• Should not be the cost of maintaining a financial system for its Federal awards.
• Must be obligated by September 30, 2025, end of the award POP and such record
retention obligation must be paid in full during the closeout period (120 calendar
days after September 30, 2025) and prior to the recipient’s submission of its
Final Report to Treasury to the extent that the record retention expense is within
the 15% limit on administrative costs.
o Treasury encourages recipients to ensure that the method of record retention used
for ERA2 award records is secure and it sufficiently protects the personally identifiable
information and other sensitive information the recipients collected from renters and
others to implement their ERA2 award.
• Did you purchase equipment or supplies with your ERA2 award that will need to be
reported? All ERA2 recipients must report on tangible personal property (equipment and
supplies) acquired with ERA2 award funds during the award POP. 12 Recipients are
responsible for reporting on behalf of their subrecipients if their subrecipients used ERA2
award funds to acquire equipment or supplies, or both.
Tangible personal property that needs to be reported in the Final Report include:
o Acquired equipment with an acquisition cost of $10,000 or more.
o Residual inventory of unused supplies with a total aggregate fair market value greater than
$10,000.
Per the Uniform Guidance, 2 CFR 200.1, tangible personal property includes equipment and
supplies. It does not include copyrights, patents, or securities. A computing device is
considered a supply if the acquisition cost is less than $10,000 per unit, regardless of the
length of its useful life.
Consistent with the Uniform Guidance, 2 CFR 200.313(e)(1) and 2 CFR 200.314(a),
equipment acquired with ERA2 award funds with a current per unit fair market value of
12
On August 13, 2025, Treasury notified ERA2 Recipients that Treasury will apply the 2024 revised 2 CFR
200.313(e) regarding equipment disposition and 2 CFR 200.314(a) regarding supplies to all ERA2 awards.
8
ERA2 Program Closeout Resource
$10,000 or less at the end of the award period of performance may be retained, sold, or
otherwise disposed of by ERA2 recipients with no further responsibility to Treasury.
Supplies acquired with ERA2 award funds with the total aggregate value of $10,000 or less
at the end of the award POP may also be retained by ERA2 recipients with no further
responsibility to Treasury. Additionally, Treasury permits recipients with equipment with a
per unit fair market value of more than $10,000 or unused supplies that have a total
aggregate value of more than $10,000 to be retained by the recipient if it is needed for
another Federal award or for activities for non-federally funded programs or projects for
the government entities which have similar objectives as the ERA2 program. The recipient
or subrecipient must also notify Treasury of any loss, damage, or theft of any equipment
acquired with the ERA2 award. If the equipment is sold, Treasury may permit the recipient
or subrecipient to retain from the Federal share $1000 of the proceeds to cover expenses
associated with the selling and handling of the equipment (2 CFR 200.313(e)(2)).
• Did you use ERA2 award funds for affordable rental housing purposes that will require
reporting on real property? ERA2 recipients that used funds for affordable rental housing
purposes must prepare to report on real property. The Final Report includes questions that
align with the SF-429 Real Property Status Report. ERA2 recipient should also plan to
report on their plans for eventual disposition of the real property. They should also plan to
maintain and update property records when there is a change in the status of the property
pursuant to 2 CFR 200.313(d)(1). Treasury will provide additional clarifying information in
future iterations of this document.
ERA2 affordable rental housing projects must serve very low-income families by ensuring
that the household income of occupants of units funded by ERA2 funds is limited to the
maximum income applicable to very low-income families, as such term is defined in
section 3(b) of the United States Housing Act of 1937 (42 U.S.C. 1437a(b)) and such
income limitation is imposed through a covenant, land use restriction agreement (LURA),
or other enforceable legal requirement for a period of at least 20 years. Further, uses of
ERA2 award funds for affordable rental housing purposes must align and meet the
requirements of one of the federal programs listed in FAQ 46.
In the Final Report, ERA2 recipients that used award funds for affordable rental housing
purposes must indicate the estimated useful life of the affordable rental housing project,
provide information on the status of affordable rental housing projects (i.e., if the entire
project is completed, or if not completed, the estimated date of completion with the other
funding sources) and maintain records regarding the affordable rental housing projects
pursuant to paragraph 7.c. of the ERA2 Award Terms and comply with the requirements
specified in FAQ 46 for a period of at least 20 years or the estimated useful life of the
affordable rental housing project (if longer than 20 years), subject to further audits by
Treasury during that period of time.
9
ERA2 Program Closeout Resource
Closeout Review of ERA2 Awards by Treasury
After the submission (or submission deadline) of a recipient’s Final Report, Treasury will
implement a Closeout Review of ERA2 awards, which may include:
• Requesting verification of award closeout information from recipients.
• Engaging recipients to resolve any issues found in their Final Report; if a report requires
revision, Treasury may send instructions to revise and resubmit the Final Report or an
Information Document Request (IDR) for the recipient to provide further clarity.
• Requesting information from recipients with Affordable Rental Housing Projects to
determine if there was any program income earned during the ERA2 award period of
performance but not used or will not be used for ERA2 eligible activities by September
30, 2025 (see page 13 for details).
• Notification of disallowed costs, as applicable.
• Sending repayment instructions to recipients.
• Initiating or proceeding with applicable remediation actions.
For each of these activities, Treasury will communicate specific instructions and deadlines to
recipients. This may include revising the submitted reports or responding to an Information
Document Request (IDR) in order to clarify certain aspects of the submitted Final Report.
Notification of IDRs are sent to the ERA2 Portal contacts via an email notice but can also be
found in “messages” within Treasury’s ERA Portal. ERA2 recipients should make sure to keep
their designated points of contact updated within the Portal to support effective communications.
Treasury may engage in further compliance activities, closeout review, and communication with
recipients, as needed and in alignment with applicable provisions of the Uniform Guidance (2
CFR Part 200), Treasury’s guidance, and the ERA2 Award Terms . If a recipient does not
resolve outstanding issues, Treasury will provide a formal opportunity to remedy the
noncompliance prior to initiating administrative closeout of the ERA2 award and the recipient
being found noncompliant with the requirements set forth in the ERA2 Award Terms.
Upon the completion of closeout actions and resolution of any outstanding matters regarding the
ERA2 awards, Treasury will send a Notification of Completion, informing each recipient that
its award has been closed out and no further action is required other than its compliance with
certain terms and conditions of the ERA2 award that extend beyond the closeout period. 13
Repayment of ERA2 Award Funds to Treasury
Following receipt and review of the recipient’s Final Report, the recipient will enter “financial
closeout” where Treasury reviews unliquidated obligations and unexpended award funds to
determine any adjustments following the submission of the Final Report and/or repayment
amounts.
Following this review, Treasury may send a notice to the ERA2 recipient to verify financial
information which may involve updating Treasury on total unobligated balances reported in the
13
Examples of the ERA2 Award Terms that extend beyond the closeout period include record retention
requirements, compliance-monitoring, and, if applicable, resolution of audit findings after award closeout.
10
ERA2 Program Closeout Resource
SF-425 in the Final Report. Reasons for updating unobligated balances may include landlords or
vendors returning funds after the ERA2 recipient submitted its Final Report or Treasury
determining that there are disallowed costs during the Closeout Review.
Figure 4: Calculating Final Returns to Treasury
* See page 13 for more details on the timing related to expending program proceeds or income, as well
as eligible uses of these funds.
If a recipient owes money to Treasury due to, for instance, excess funds, unobligated balances,
improper use of funds, or other noncompliance issues under the ERA2 award, Treasury will send
repayment instructions and deadlines for the recipient to make payments, as appropriate (also
referred to as a “pre-debt notice”), and if repayment is not made timely Treasury may seek
other legally available remedies. The ERA2 recipient should wait until receiving this payment
request before returning ERA2 award funds. Recipients will then have 30 calendar days to repay
funds to avoid debt collection. Once the recipient enters into debt collection, Treasury will issue
a demand letter that outlines escalating penalties for non-payment per 31 U.S.C. 3717. See
Figure 5 below for an illustration of the repayment process.
11
ERA2 Program Closeout Resource
Figure 5: Repayment Process
Treasury review of Final
Report; Treasury may request
Recipient submits additional information as
Final Report. needed to determine
repayment amounts during
Financial Closeout.
Recipient returns funds in full
Treasury sends repayment
within 30 calendar days of pre-
instructions with return
debt notice to avoid debt
deadline (pre-debt notice). collection.
DEBT COLLECTION AFTER 30 DAYS OF
NONPAYMENT,
If outstanding amount remains, Treasury will begin assessing
Treasury initiates debt collection and escalating penalties and
and issues a demand letter. interest on delinquent debts.
In general, the conclusion of financial closeout is often the last step in Treasury’s closeout
process and may be followed by Treasury sending the recipient a Notification of Completion
(see Figure 1). Please note that after the Notification of Completion, Treasury retains the right to
engage in a post-closeout adjustment to disallow costs and recover funds on the basis of a later
audit or other review pursuant to 2 CFR 200.345.
If Treasury determines that a recipient is not in compliance with repayment instructions and/or
have other outstanding issues, Treasury may also put a “financial hold” on the recipient’s
ERA2 award, which may result in withholding of payments remaining on its other awards
under Treasury programs or take other remedial actions. 14
14
See 2 CFR 200.339(a).
12
ERA2 Program Closeout Resource
Repayment of recovered or returned ERA2 Award Funds
Recipients may receive recovered or returned award funds during or after the ERA2 award
period of performance ends, for instance financial assistance sent back to the recipient from
landlords, utility companies, or other end beneficiaries due to the tenant moving, etc.
For most recovered or returned funds, recipients with open awards may redeploy any of these
funds for ERA2 program purposes. Once a recipient enters the closeout process, recipients must
repay those funds to Treasury.
For those recipients using ERA2 award funds for affordable rental housing purposes, they may
retain program income earned after the award period of performance ends on September 30,
2025, and use such program income for affordable rental housing purposes or eviction
prevention purposes in accordance with ERA FAQ 46. Further, such program income must not
be mixed with other funding sources in a revolving loan fund. Note that program income earned
during the ERA2 award period of performance but not expended by September 30, 2025 must
be returned to Treasury.
Figure 6: Repayment Requirements for Returned or Recovered Funds
*Interest earned on the ERA2 award is not program income. See 2 CFR 200.1.
Following the Notice of Completion, if an ERA2 recipient has any further repayments to make to
Treasury (for instance, in the case of returned award funds) recipients should contact Treasury
about the reason and the timing of the return and use the previously provided repayment
instructions for any further repayments to Treasury, unless otherwise instructed.
13
ERA2 Program Closeout Resource
Section II. Post-Closeout Compliance Reminders
Following the submission of the Final Report and the Notification of Completion, Treasury may
continue to engage in further compliance activities, closeout-review, and communication with
recipients, as needed and in alignment with applicable provisions of the Uniform Guidance (2
CFR Part 200), Treasury’s guidance, and the ERA2 Award Terms.
The following is a non-exhaustive list of post-closeout recipient responsibilities:
Ongoing Returns and Financial Adjustments
Per 2 CFR 200.345, the closeout of a Federal award does not affect any of the following:
• The right of the Federal awarding agency or pass-through entity to disallow costs and
recover funds on the basis of a later audit or other review. The Federal awarding agency
or pass-through entity must make any cost disallowance determination and notify the
non-Federal entity within the record retention period.
• The requirement for the non-Federal entity to return any funds due as a result of later
refunds, corrections, or other transactions including final indirect cost rate adjustments.
• The ability of the Federal awarding agency to make financial adjustments to a previously
closed award such as resolving indirect cost payments and making final payments.
For more information see “Repayment of recovered or returned ERA2 award funds” on page 13.
Records Retention & Documentation
Per the ERA2 Award Terms , financial records, supporting documents, statistical records, and all
other non-Federal entity records pertinent to the ERA2 award must be retained for a period of
five years after the end of the period of performance (September 30, 2025 or in cases when
a recipient sought early award closeout, the record retention period begins after the
recipient submits its Final Report to Treasury). 15 If an audit, litigation, or other action
involving the ERA2 records starts before the end of the appropriate retention period of five
years, the records should be maintained until the end of the appropriate retention period or until
the audit, litigation, or other action is completed, whichever is later.
Documentation of Compliance with Federal Civil Rights Statutes and Regulations:
Recipients are required to comply with federal civil rights statutes and regulations, including
Title VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, the Age
Discrimination Act of 1975, and the Fair Housing Act (Title VIII of the Civil Rights Act of
1968) as outlined in the ERA2 Award Terms executed by the recipients in connection with their
ERA2 awards.
15
Please note that 2 CFR 200.334 provides that pass-through entities (i.e., recipients) that receive Federal awards
must not impose any other record retention requirements on non-Federal entities (i.e., subrecipients), except those
outlined in 2 CFR 200.334(a)-(f).
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Information about the recipients’ civil rights obligations can be found in Treasury’s Civil Rights
Toolkit. 16
Real Property: Ongoing Reporting and Audit Requirements
When using ERA2 award funds for affordable rental housing purposes, recipients are expected to
retain all relevant documentation for each project for a period no less than twenty years.
Documentation may be requested by Treasury during audits or reviews.
Documentation that ERA2 recipient might need retain includes, but is not limited to, the
following:
• Purchase agreements
• Title reports
• Environmental reviews
• Architectural and engineering designs
• Contractor or Subrecipient agreements
• Construction scope of work
• Project budgets and pro formas
• Site surveys
• Appraisals that comply with the standards set by the Uniform Relocation Assistance and
Real Property Acquisition Policies Act (Yellow book), 42 U.S.C. 4601(13), and the
implementing regulation, 49 CFR § 24.2(a)(3)
• Assurance of no displacement statement, per the Yellow Book
• Evidence of seller’s clear title to the property (title insurance policy, title search, or title
opinion).
• Settlement statement.
• Recorded deed of trust or other conveyance document
• Pre-acquisition Land Cost Summary Statement
• Historic reviews
• Certified certificates of completion from architects or engineers
• Project construction pictures / Activity completion pictures
• Permits
• Cost estimates
• Change orders
Documentation of material updates to the project such as changes in contractor and sub-
contractor agreements, change orders, etc. should be maintained by the recipient over the record
retention period for the ERA2 award.
16
On March 4, 2026, Treasury rescinded its Guidance to Federal Financial Assistance Recipients Regarding Title VI
Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons for consistency
with Executive Order 14224, titled, “ Designating English as the Official Language of the United States and dated
March 1, 2025, which revoked Executive Order 13166, titled Improving Access to Services for Persons with
Limited English Proficiency. See 70 Fed. Reg. 6067. As such, Treasury revised the ERA2 Program Closeout
Resource on March 30, 2026 to remove all references to Treasury’s rescinded guidance regarding language access
services to Limited English Proficient Persons.
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Treasury will provide further information about maintenance, documentation, and disposition
requirements in later iterations of this document.
Audit Requirements
Thoughtful and thorough work related to award closeout can help support an accurate and
effective audit. Audit activities may fall outside of the timelines associated with closeout
activities. However, recipients with open awards may use ERA2 award funds towards single
audit or program-specific audit costs, as applicable and within the administrative costs limit, for
annual single or program-specific audits, as applicable, until fiscal year 2025 and in accordance
with 2 CFR 200.425 and 2 CFR Part 200, Subpart F – Audit Requirements, as long as the costs
are obligated before the end of the award POP and expended within 120 calendar days (or 90
calendar days in the case of subrecipients) after September 30, 2025 per 2 CFR 200.344(a).
Please note that, in the case of a recipient engaging in early closeout, ERA2 award funds may
only be expended to support Single Audit activities that occur after the recipient submits its Final
Report to Treasury if the recipient expended ERA2 award funds prior to submitting the Final
Report and during its current fiscal year that will be audited.
Detailed information regarding single audits and program-specific audits can be found in 2 CFR
Part 200, Subpart F, Audit Requirements. Here is some basic information regarding auditee
responsibilities (2 CFR 200.508) to help recipients plan:
• Recipients that expend $1,000,000 or more in Federal awards during their fiscal year that
begins on or after October 1, 2024 are required to undergo either a single audit or
program-specific audit for that fiscal year. 17
• Recipients are responsible for procuring or otherwise arranging for audits and ensuring
the auditor has the necessary experience to perform this type of audit in accordance with
2 CFR 200.509.
o Information with instructions for how auditors must perform these audits can be
found at 2 CFR 200.514 through 2 CFR200.520 and in the ERA2 2024
Compliance Supplement published by the Office of Management and Budget.
o Recipients are advised to continue to check the ERA2 Guidance page on
Treasury’s website for additional compliance resources, e.g., Compliance
Supplements.
• Recipients must prepare their financial statements and other materials required by their
auditors to perform their audits and provide the auditors with all necessary
documentation (e.g., records).
• Recipients are expected to take prompt corrective action following any audit findings.
17
With the 2024 revision of 2 CFR Part 200, the expenditure threshold that requires a recipient to conduct a single
audit or a program-specific audit increased from $750,000 to $1,000,000 in federal funds for (see 2 CFR 200.501).
This new threshold applies to recipients whose fiscal year begins on or after October 1, 2024.
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• Recipients must submit and certify their single audit Report to Federal Audit
Clearinghouse “within the earlier of 30 calendar days after receipt of an auditor’s
report(s), or nine months after the end of the audit period” per 2 CFR 200.512(a)(1). The
audit period is a recipient’s fiscal year.
• Recipients with audit findings must work with Treasury, as appropriate, to resolve those
findings.
APPENDIX A: Definitions
Administrative activities generally include activities to support closing out the award in
accordance with 2 CFR 200.344, including, but not limited, to administrative support services
and other direct and indirect expenses that support administrative activities provided through
staffing costs, subawards, contracts, preparation of Final Report and documents, etc.
Administrative closeout occurs if the Final Report has not been submitted and Treasury initiates
the closeout process on behalf of the participant, per 2 CFR 200.344 (h)-(i).
Closeout refers to the process by which the Federal awarding agency or pass-through entity
determines that the recipient (or subrecipient) has completed all applicable administrative actions
and required work of the Federal award have been completed. The Federal awarding agency,
recipient, and subrecipient, as applicable, must take the actions described in 2 CFR 200.344.
Financial Closeout refers to the review of unliquidated obligations and unexpended award funds
by the end of the award term POP and closeout period. Financial closeout determines whether
that amount will be repaid to Treasury and includes recoupment of any disallowed or ineligible
costs.
Grantee/recipients means states, the District of Columbia, U.S. territories, and units of local
government that participated in the Emergency Rental Assistance (ERA2) program established
by the American Rescue Plan Act, 2021. In the case of this document, "recipient" and "grantee"
may be used interchangeably. These terms do not include subrecipients (e.g. vendor, contractor,
nonprofit partner, etc.) or beneficiaries of the award (e.g. renters, landlords, utility companies,
etc.).
Liquidation period describes the 120 calendar days after the end date of the period of
performance and the date that the Final Report is due; during this period grantees may not
obligate any award funds for programmatic or administrative activities, but they may expend
previously obligated funds to close out their ERA2 award.
Period of performance means the total estimated time during which the recipient and
subrecipient must perform and complete the work authorized under the Federal award; it is the
interval between the start of an initial Federal award and the planned end date.
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Post-closeout adjustment describes activities that occur after a Federal awarding agency closes
out an award pursuant to 2 CFR 200.345. These activities include: (1) The right of the Federal
awarding agency or pass-through entity to disallow costs and recover funds on the basis of a later
audit or other review; (2) The requirement for the recipient to return any funds due as a result of
later refunds, corrections, or other transactions including final indirect cost rate adjustments; (3)
The ability of the Federal awarding agency to make financial adjustments to a previously closed
award such as resolving indirect cost payments and making final payments; (4) Audit
requirements; (5) Property management and disposition requirements; and (6) Record retention
requirements.
Remediation actions refer to activities pursued to correct a recipient’s noncompliance with
statutes, regulations, or the terms and conditions of their award agreement.
Subrecipient means an entity that receives a subaward from a pass-through entity (e.g. a ERA2
recipient) to carry out part of a Federal award; but does not include an individual that is a
beneficiary (e.g. renters, landlords, utility companies, etc.) of such award.
Unexpended obligations mean the amount of funds that have been obligated by the recipient
under a Federal award but not paid; may also be referred to as unliquidated obligations.
Unobligated balance means the amount of funds under a Federal award that the recipient has not
obligated.
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APPENDIX B: Highlighted FAQs
This list is non-exhaustive. See FAQ webpage for full list of FAQs and language. Note that, to
the extent that the FAQs do not provide specific guidance on a particular issue, a grantee should
have established its own policy or procedure that is consistent with the statutes and followed it
consistently.
Applicant eligibility requirements:
• Establishing and documenting eligibility; implementing controls to support fraud
prevention and compliance: FAQ #1, FAQ #47, FAQ #48, FAQ #49, and FAQ #50
• Financial hardship due to the COVID-19 pandemic; use of self-attestation: FAQ #2
• Risk of experiencing homelessness or housing instability; use of self-attestation: FAQ #3
• Income eligibility; use of self-attestation, categorical eligibility, and fact-specific proxies:
FAQ #4
• Imposing additional eligibility criteria: FAQ #44
• Prioritization of applications: FAQ #22
• Tribal members and Tribal lands: FAQ #16 and FAQ #17
Expenditure requirements:
• Administrative expenses: FAQ #29
o Use of contractors, subrecipients, or intergovernmental cooperation agreements:
FAQ #21
o Written agreements with other entities to support more efficient payments: FAQ
#42
• Housing stability services and eviction prevention: FAQ #23, FAQ #36, FAQ #46
• Limitations on financial assistance: FAQ #10 and FAQ #11
• Documentation of rental residence, rent, and rental arears; written attestation: FAQ #5
o Landlord outreach requirements: FAQ #12
o Additional payments to landlords: FAQ #41
o Preventing evictions during period covered by ERA assistance: FAQ #32
o Vacated units: FAQ #40
• Utilities and home energy costs: FAQ #6 and FAQ #19
• Bulk payments to landlords/utility companies: FAQ #38
• Documenting “other expenses”: FAQ #7
o Security deposits: FAQ #39
• Other living situations:
o Displaced households living in hotels or motels: FAQ #26
o Rent-to-own agreements: FAQ #27
o Manufactured housing: FAQ #28
o Additional payments to landlords for “hard to house” populations: FAQ #41
o Relocation and tenants without a preexisting rental obligation: FAQ #35
• Option for tenants to apply directly for ERA assistance: FAQ #30
• Documentation that funds are used for permissible purposes: FAQ #31
• Affordable rental housing and eviction prevention purposes: FAQ #46
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Other: Data, Compliance, and Recoupment:
• Data collection requirements, including privacy and security requirements: FAQ #14
• Subsidized housing, civil rights, and fair housing: FAQ #15
• Title VI of the Civil Rights Act and Treasury’s Title VI implementing regulations at 31
CFR Part 22: FAQ #37
• Source-of-income protection laws: FAQ #43
• Collaboration between ERA2 grantees: FAQ #33
• Interest earned on ERA payments: FAQ #24
• Recoupment: FAQ #25
Reference to “Promising Practices” and “Program Service and Design” Resources:
Treasury’s resources provided through Promising Practices and Program Service and Design can
also serve as illustrations that grantees might have considered when developing their program
policies and infrastructure, though all such policy development must proceed in accordance with
the governing legal authorities and published policy guidance. Reference to these resources
should not be construed as (i) altering these requirements or (ii) confirming that any specific
grantee’s program policies or administrative practices have been fully reviewed and found
compliant.
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