Local Assistance and Tribal Consistency Fund (LATCF) Reporting
For those counties that were eligible to receive Local Assistance and Tribal Consistency Fund (LATCF) revenues as a provision of the American Rescue Plan Act (link to eligible counties here), the first reporting deadline is soon approaching. Specifically, those counties that received their first LATCF payment during Calendar Year 2022 have until March 31, 2023, to submit the first annual report. Recipients that received their first payment after December 31, 2022, will be required to submit their first annual report by March 31, 2024.
What is required?
Recipients are required to report annually on obligations and expenditures made using their LATCF award. Specifically, recipients are required to report on (i) current period obligations, (ii) cumulative obligations, (iii) current period expenditures, and (iv) cumulative expenditures for each government purpose category for which the funding was utilized. Data may be reported on a cash, accrual, or modified accrual basis, as long as the methodology is consistently applied throughout the covered period and until reporting is no longer required.
As a general matter, recipients may use funds to cover costs incurred on any eligible use, including costs incurred from March 15, 2021. Recipients may use funds to cover costs of administering the LATCF program, including costs of consultants to support effective management and oversight as well as compliance with legal, regulatory, and other program requirements.
Treasury has provided a non-exhaustive list of examples that fulfill a governmental purpose in the Guidance for the Local Assistance and Tribal Consistency Fund. As pointed out in the guidance on Treasury’s website, the eligible uses are wide-ranging:
The Local Assistance and Tribal Consistency Fund provides flexible support for eligible revenue sharing counties and eligible Tribal governments to meet their jurisdiction’s needs. Specifically, the statute directs that recipients may use funds for any governmental purpose other than a lobbying activity.
As a general matter, recipients may treat these funds in a similar manner to how they treat funds generated from their own revenue. Programs, services, and capital expenditures that are traditionally undertaken by a government are considered to fulfill a “governmental purpose.”
All funds are available to recipients until expended or returned to Treasury.
Additional information regarding the reporting requirements can be found in the Treasury Reporting Guidance for the Local Assistance and Tribal Consistency Fund. Counties will also be required to submit a certification that no LATCF funds were used for lobbying activities. Please reach out to your County Government Consultant if you have any questions.