Grantees of CD Programs: Check Your Consolidated/Action Plans for EO Compliance

Deadlines for action plans and consolidated plans for HUD community development programs are quickly approaching. Grantees that have submitted or are in the process of submitting plans should check them over to make sure that they are in compliance with presidential Executive Orders (EOs).

For grantees of the Community Development Block Grant (CDBG) program, HOME Investment Partnerships (HOME) program, Housing Trust Fund (HTF), Emergency Solutions Grants (ESG) and Housing Opportunities for Persons With AIDS (HOPWA) program, deadlines depend on your start date with the final deadline being August 16, 2025. As grantees submit their plans, HUD may provide notification informing a grantee to revise their plans due to a violation or violations of one or more EOs.  In some cases, HUD may provide as little as one day for a grantee to revise and replace language that relates to a violation of an EO. Failure to address HUD’s concerns may result in disapproval of a plan.

In a letter provided to the Council of State Community Development Agencies (COSCDA) and National Community Development Association (NCDA), HUD provides some examples for grantees of how their plans should conform “…with applicable Administration priorities and executive orders.” However, HUD has not provided official guidance as it relates to specific EOs. Additionally, HUD affirms that they do not have any plans at this time to update Notice CPD-25-02, which is the official guidance on submitting action plans and consolidated plans for fiscal year 2025.

Some EOs that may have a direct effect on your plans include the following:

• Executive Order 14151 | “Ending Radical and Wasteful Government DEI Programs and Preferencing”;
• Executive Order 14173 | “Ending Illegal Discrimination and Resorting Merit Based Opportunity”;
• Executive Order 14224 | “Designating English as the Official Language of the United States”;
• Executive Order 14148 | “Additional Rescissions of Harmful Executive Orders and Actions”; and
• Executive Order 14218 | “Ending Taxpayer Subsidization of Open Borders.”