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ARPA – The "Obligation" Interim Final Rule (IFR) & VLCT's Recommendations

November 20, 2023

image of the U.S. Treasury bulding from an official engraving

The U.S. Department of the Treasury has issued the Obligation Interim Final Rule (IFR) to address funding recipients’ questions and comments regarding the definition of obligation. The Obligation IFR revises the definition of obligation in Treasury’s implementing regulations for the SLFRF/ARPA program and provides related guidance to give additional flexibility and clarity to recipients to support their use of SLFRF/ARPA funds. We advise referring to Treasury's two-page “Quick Reference Guide” which informally summarizes the seventeen-page Obligation IFR and Obligation IFR slide presentation.

What are VLCT's additional recommendations as you contemplate your municipality's next steps for using its local ARPA award? Don't wait - obligate all your ARPA funds by March 31, 2024 so you can include this in your required annual reporting due by April 30th. Learn the details in VLCT's ARPA Update and Recommendations – November 2023.