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4 <br /> <br />10. May a grantee provide assistance to households for which the grantee is the landlord? <br />Yes, a grantee may provide assistance to households for which the grantee is the landlord provided that <br />the grantee complies with the all provisions of the statute and this guidance and that no preferences <br />beyond those outlined in the statute are given to households that reside in the grantee’s own properties. <br />11. May a grantee provide assistance for arrears that have accrued before the date of enactment of <br />the statute? <br />Yes, but not before March 13, 2020, the date of the emergency declaration pursuant to section 501(b) of <br />the Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. 5191(b). <br />12. May a grantee provide assistance to a renter household with respect to utility or energy costs <br />without also covering rent? <br />Yes. A grantee does not need to provide assistance with respect to rent in order to provide assistance with <br />respect to utility or energy costs. The limitations in section 501(c)(2)(B) of Division N of the Act limiting <br />assistance for prospective rent payments do not apply to the provision of utilities or home energy costs. <br />13. May a grantee provide ERA assistance to homeowners to cover their mortgage payment, <br />utilities, or energy costs? <br />No. The statute requires that ERA assistance be provided only to eligible households, which is defined to <br />include only households that are obligated to pay rent on a residential dwelling. <br />14. The statute provides that ERA funds may be used for “other expenses” as related to housing <br />incurred due, directly or indirectly, to COVID-19, as defined by the Secretary. What are some <br />examples of these “other expenses”? <br />The Secretary has not made such a determination at this time. <br />EXHIBIT 3EXHIBIT 1