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Committee raises capacity, compliance questions about Tulsa Immigrant Community Development Corporation CDBG application

2247155 · February 6, 2025
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Summary

Grants administration told the committee the immigrant‑serving applicant would need a fiscal sponsor, must meet federal inspection and environmental review requirements, and that the city’s CDBG rules do not require checking immigration status. The applicant said it will hire staff and has private matching funds.

Committee members and grants administration staff pressed Tulsa Immigrant Community Development Corporation (TICDC) representatives about organizational capacity and eligibility after TICDC applied for CDBG funding to support home‑repair work.

Grants administration staff (Rhys Williams) told the committee “there are... no requirements in the CDBG program to check immigration status,” and that HUD CPD programs were not subject to the federal provision discussed by some members. Williams also outlined operational concerns: TICDC is not a 501(c)(3) and the application indicated two staff members; therefore any subrecipient agreement would need to be executed with Tulsa Community Foundation (TCF) as fiscal sponsor. Grants administration staff said federal CDBG‑funded housing repair programs require trained inspectors (including lead‑based paint requirements), environmental tier reviews, income verification intake, open bidding for contractors, and financial and invoice oversight.

Louisa Croag, identifying herself as the executive director of the applicant organization, said the application was submitted when an interim director was on loan from the George Kaiser Family Foundation (GKFF). Croag told the committee TICDC currently has two employees but is “in the process of posting a position for, a program coordinator that would manage this program,” and that GKFF provided matching funds of about $55,000 to support program staffing and associated costs. Croag said TCF provides extensive back‑office support and experience with federal fund administration.

Committee members asked whether the program would serve people who are undocumented. Croag said her understanding after discussion with GKFF was that the organization planned to include verification steps and “we would probably just go ahead and assume that that might change at some point and so would, include that verification in our process.” A member seeking clarity asked for confirmation that the committee’s funds would be used for people in the country legally; Croag repeatedly said the organization intended to include verification for this project and that other non‑CDBG funds might be used for persons who do not meet those criteria.

Grants administration staff reiterated that jurisdictions can require verification in subrecipient agreements even where CDBG does not mandate it. Staff also noted intake work (income verification) and environmental clearances are time‑ and staff‑intensive and cautioned about awarding federal funds to organizations lacking demonstrated capacity to manage contracting, bidding and lead‑hazard compliance.

Committee members said the clarifications were helpful and left the item in the packet for consideration alongside other funding recommendations; staff said they would follow up with contract and capacity clarifications should the committee move to fund the program.