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City counsel says Treasury guidance allows ARPA reallocations but warns of audit risk

New Orleans City Council · December 1, 2025
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Summary

Outside counsel told the council Treasury guidance permits certain reallocations of ARPA funds obligated by 12/31/2024 if the new use is eligible and funds are spent by 12/31/2026, but cautioned that inadequate documentation could force repayment; councilmembers and community leaders pushed for transparency about repurposing ARPA-funded programs.

The council received legal guidance that under current U.S. Treasury rules it can reallocate ARPA funds that were obligated by Dec. 31, 2024 to other eligible expenses if those expenditures are completed by Dec. 31, 2026. Chris Johnson of Jones Walker told the council the rules now permit some reallocations and cited other jurisdictions that have done so.

Johnson said the city has received $388 million in ARPA funds and that…

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