All, Oklahoma Municipalities must obligate the American Rescue Plan Act (ARPA) funds they received by December 31st of this year. If the funds are not obligated by this deadline, municipalities will be required to return the funds. If a municipality has not obligated the funds yet, below are some helpful resources. - Obligation of ARPA Funds Under the U.S. Treasury's final rules for ARPA, "obligation" is defined as placing an order for property and services, or entering into contracts, subawards, or similar transactions that require payment. Obligation does not include: * An adopted budget or budget amendment * Appropriation of SLFRF funds * Executive orders * Resolutions * Written or oral intention to enter a contract * Granting legal authority to enter a contract * Claiming funds under the revenue loss category * Moving SLFRF dollars to a general fund without further establishing an obligation by December 31, 2024 For further details on what classifies as an obligation, see the Treasury's obligation webinar slide deck here<https://home.treasury.gov/system/files/136/Obligation-Webinar-Deck-V1.pdf> and the National League of Cities Article here<https://www.nlc.org/article/2024/10/01/obligate-it-or-lose-it-preparing-for-the-upcoming-arpa-slfrf-obligation-deadline/>. - Standard Allowance for General Government Services Municipalities may use up to $10 million under the “standard allowance” for general government services if they report under the revenue loss category. "Government services" generally include services traditionally provided by a government, as outlined on page 11 of the Treasury's final rule overview here<https://home.treasury.gov/system/files/136/SLFRF-Final-Rule-Overview.pdf>. Additional guidance on government services can be found in FAQ 3.1 and 3.2 on page 24 of the Treasury's FAQ document here<https://home.treasury.gov/system/files/136/SLFRF-Final-Rule-FAQ.pdf>. - Restrictions on Fund Usage ARPA funds cannot be used for the purposes listed on page 41 of the final rule<https://home.treasury.gov/system/files/136/SLFRF-Final-Rule-Overview.pdf>, including: * Paying legal judgments * Paying off debts * Making extraordinary contributions to pension funds - Funding Amounts and Reporting for NEU Municipalities A list of the 520 Oklahoma municipalities classified as NEUs, along with the amount of funding they received, can be accessed here<https://oklahoma.gov/arpa/neu-information/neu-funding.html>. Over 238 million was distributed to NEU municipalities in Oklahoma. NEU municipalities are only required to report annually instead of quarterly, and the reporting portal will open on April 1, 2025. If you have any questions, feel free to send me an email. Thanks, Christian Rinehart DEPUTY GENERAL COUNSEL OKLAHOMA MUNICIPAL LEAGUE 201 Northeast 23rd Street Oklahoma City, OK 73105 (405) 528-7515 [cid:cf09a489-e49b-4f2c-aec8-1ef89fdfe919] The Municipal Inquiry Service provides information based on Oklahoma Statutes and sample policies from other member cities and towns to members of the Oklahoma Municipal League. There may be other facts and details that were unknown to OML or not relayed that may alter the information provided. OML does not provide legal advice or act as a legal advisor. The advice of your municipal attorney, as your legal advisor, should be followed before implementing any policy or making any decisions regarding your legal matters. The OML American Recovery Plan Act service provides information based on the guidance provided by the U.S. Department of the Treasury and the state of Oklahoma. Each Oklahoma municipality is responsible for submitting and verifying the correct budget information, using ARPA funds correctly, and submitting a project and expenditure report by April 30th, 2023. The advice of a municipal attorney, as a legal advisor, should be followed before making any decisions regarding accepting, spending, or reporting on ARPA funds.