Emergency Justification Memo - Monthly Reporting

DEPARTMENT OF THE TREASURY
WASHINGTON, D.C. 20220

TO:

Alex Goodenough, Office of Information and Regulatory Affairs

FROM:

Ryan Law, Deputy Assistant Secretary
Office of Privacy, Transparency, and Records

SUBJECT:

Justification for Emergency Processing: Emergency Rental Assistance (ERA2)
Interim Reporting Guidance

Pursuant to the Office of Management and Budget (OMB) procedures established at 5 C.F.R. §
1320.13, the Department of the Treasury (Treasury) requests emergency processing for an
Emergency Rental Assistance (ERA2) program information collection request, revising OMB
Control Number 1505-0270.
On March 11, 2021, the President signed the American Rescue Plan Act of 2021 (the “Act”),
Pub. L. No. 117-2. Title III, Subtitle B, Section 3201 of the Act authorized the Emergency
Assistance (ERA 2) program and provides $21.55 billion for the U.S. Department of the
Treasury (Treasury) to make payments to States (defined to include the District of Columbia),
U.S. Territories (Puerto Rico, U.S. Virgin Islands, Guam, Northern Mariana Islands, and
American Samoa), and certain local governments with more than 200,000 residents (collectively
the “eligible grantees”) to provide financial assistance and housing stability services to eligible
households, and cover the costs for other affordable rental housing and eviction prevention
activities for eligible households.
Treasury is seeking approval for brief (two-question) monthly reports and the monthly reporting
requirements for ERA2 recipients to submit summary information on their utilization of ERA2
award funds to fulfill Treasury’s statutory reporting requirements and to effectively monitor the
ERA grantees’ compliance with the requirements of the ERA award. The brief monthly reports
would contain information on ERA grantees’ programmatic and financial activity.
Due to the need to prepare these monthly reports expeditiously as required by statute, Treasury
requests emergency processing and approval of the monthly report and guidance by July 2, 2021
in order to make the interim report and guidance available on July 5, 2021 for ERA2 grantees’
use. Given the inability to seek public comment during such a short timeframe, Treasury requests
a waiver from the requirement to publish notice in the Federal Register seeking public comment.