Good morning: I am sending this email to the diversity group, the immigration group, the federal funding group, and the homelessness group to avoid multiple emails. I wanted to alert you to a few items. 1. A copy of the noncompliance letter sent to a member related to the Shelter and Services Program. I understand that a number of you have received this or a nearly identical letter. Note the references to withholding of payments but also 8 USC 1324, which we have been following with the immigration group. 1. I was also alerted to new conditions on HUD's Continuum of Care Program Grant Agreement. These include certifying that the entity does not operate any DEI programs that violate federal anti-discrimination laws; a False Claims Act certification (that compliance with anti-discrimination laws is "material" for the purposes of 3729b4 of title 31 of the US Code, and several immigration related requirements as well. I've pasted the text that was provided to me below my signature. 1. Here is a motion filed by Democracy Forward (representing the coalition of nonprofits in the federal funding freeze case in DC) related to the federal government withholding 3.6 billion in HUD Continuum of Care funding. https://democracyforward.org/wp-content/uploads/2025/03/NCN-Motion-to-Clarify-Funding-Freeze-3.4.25.pdf. Here's a summary of the dispute between the parties as to the scope of the injunction in that case; "There is no dispute that the preliminary injunction does not apply to NOFOs where no grant recipient has even been selected and the grant has not been awarded. And there is no dispute that the injunction does apply to open awards that have already been obligated, where disbursements have begun. This motion addresses a different type of open award that Defendants have sought to exclude from the reach of the Court's order: where a grant has been awarded, but funds have not yet been disbursed." 1. In addition, here is a news article about Montgomery County, PA's grant being withheld under the Continuum of Care program; https://patch.com/pennsylvania/norristown/montco-ghosted-federal-government-5m-key-funding-withheld. This is specifically referenced in the above motion to clarify the funding freeze. Which lends further support for my reading of the PI order in that case as being on a nationwide basis on not merely applying to the named plaintiffs. That said, an appeals court could always limit the scope of the injunction. 1. The federal government's response to the motion by democracy forward related to the open awards issue. Note that the motion discusses the HUD Continuum of Care program and the requirement of those that are awarded the grant to comply with conditions the government imposes on it. Thanks, Amanda [logo]<https://imla.org/> [facebook icon]<https://www.facebook.com/InternationalMunicipalLawyersAssociation/>[twitter icon]<https://twitter.com/imlalegal>[linkedin icon]<https://www.linkedin.com/company/international-municipal-lawyers-association-inc./> Amanda Karras (she/her) Executive Director / General Counsel International Municipal Lawyers Association P: (202) 466-5424 x7116 D: (202) 742-1018 51 Monroe St. Suite 404 Rockville, MD, 20850 Plan Ahead! See IMLA's upcoming events<https://imla.org/events/>, calls and programming. [cid:image007.png@01DB94CD.A7528050]