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EXHIBIT 2 <br />35 <br />held reserves account. HUD may take action, including suspension and debarment, against a <br />PHA or any party that has used HAP funds and/or the HAP RNP/HUD-held reserves account <br />fornon-HAP purposes. <br />20.UsesofAdministrativeFees.ForproperusesandreportingofAdministrativeFeesand <br />-17:Use and Reporting of Administrative Fee <br />Reserves. <br />21.VMS/FASSReportingandDataIntegrity.PHAsmustcontinuetosubmitrequired <br />financialdocumentsincluding,butnotlimitedto,monthlyVMSandannualFASSelectronic <br />submissions.PHAsthatdonotsubmittherequireddatabythereportingdeadlinemaybe <br />sanctionedasprovidedby24CFR982.152(d),andinaccordancewiththeproceduresoutlined <br />inPIHNotice2021-08oranysuccessornotice.PHAsthatfailtomeetthesubmission <br />requirementsmaybesubjecttoadministrativeactions,includingbutnotlimitedto,an <br />impositionofapenaltyagainstthemonthlyadministrativefeesuntilthePHAcomplies <br />withtheserequirements.ThispenaltyrepresentsapermanentreductionforthecurrentCYthat <br />shallnotbereversed. <br />22.Prohibition on Over-leasing. The 2021 Act prohibits the use of appropriated HAP funds <br />by any PHA, except for PHAs in the MTW demonstration, to lease units above their CACC <br />baseline units during any CY, even if the PHA has sufficient budget authority (BA) and/or <br />RNP to support the additional units. If a PHA engages in over-leasing, it must identify other <br />eligible sources to pay for the over-leasing, and the PHA must take immediate steps to <br />eliminate any current over-leasing. Renewal funding allocations will not include over-leased <br />units. Renewal funding eligibility will be reduced based on the number of over-leased unit <br />months and the average PUC during the re-benchmark period. PHAs must still report all over- <br />leasinginVMSandmust alsoreport$0 HAPsin theappropriatecategoriesinVMS. <br />23.Use of Outside Sources of Funds. HUD issuedPIH Notice 2013-28,Guidance on the Use <br />of Outside Sources of Funds in the HCV Program. HUD recommends that all PHAs carefully <br />reviewtheinformation contained in thenotice. <br />24.Paperwork Reduction Act. The additional information collection requirements contained <br />in this document are approved by the Office of Management and Budget (OMB) under the <br />Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520). The OMB control number is 2577- <br />0169.InaccordancewiththePaperworkReductionAct,HUDmaynotconductorsponsor, <br />and a person is not required to respond to, a collection of information unless the collection <br />displaysacurrently valid OMBcontrol number. <br /> <br />