Hi again,
I come bearing additional updates from the FAA and HUD. We can also talk about these on tomorrow's federal funding call.
FAA. From the FAA, we have a FY2025 Grant Template, which you can access here: https://www.faa.gov/airports/aip/grantapportion_data/fy-25-grant-agreement-template. Some changes on the FAA website are highlighted in yellow. From what I am initially seeing, they have added new language about termination on p. 3. Then beginning on p. 31 of the PDF, which is p. 2 of the Assurances, you can see new general funding requirements, including new executive orders. (The reason I said "some" changes are highlighted is because the highlights appear to not catch all the changes. For example, I see on p. 3 of the Assurances lists of new EOs that are not highlighted in yellow including Unleashing American Energy, Ending Radical and Wasteful Government DEI Programs and Preferencing, among others. There are also changes to the certifications on p. 56-58 of the PDF that are not in yellow highlights but it lists out the new EOs. So if these grants will apply to you, you will want to review the new template carefully).
HUD. I am attaching two HUD documents dated 4/22/25 with new conditions and requirements for grant recipients. Note that under "other presidential executive actions affecting federal financial assistance programs," it lists a number of EOs but then specifically says the list is non-exhaustive and links to the white house presidential action page.
Here is some relevant information / additions to the General Administrative, National, and Departmental Policy Requirements and Terms for HUD's Financial Assistance Programs:
Compliance with Immigration Requirements
The recipient must administer its award in accordance with all applicable immigration restrictions and requirements, including the eligibility and verification requirements that apply under title IV of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996, as amended (8 U.S.C. 1601-1646) (PRWORA) and any applicable requirements that HUD, the Attorney General, or the U.S. Citizenship and Immigration Services may establish from time to time to comply with PRWORA, Executive Order 14218, or other Executive Orders or immigration laws.
No state or unit of general local government that receives HUD funding under may use that funding in a manner that by design or effect facilitates the subsidization or promotion of illegal immigration or abets policies that seek to shield illegal aliens from deportation.
Subject to the exceptions provided by PRWORA, the recipient must use SAVE, or an equivalent verification system approved by the Federal government, to prevent any Federal public benefit from being provided to an ineligible alien who entered the United States illegally or is otherwise unlawfully present in the United States.
Other Presidential Executive Actions Affecting Federal Financial Assistance Programs
Recipients of Federal Awards must comply with applicable existing and future Executive Orders, as advised by the Department, including but not limited to the following:
Executive Order (EO) 14219, Ensuring Lawful Governance and Implementing the President's "Department of Government Efficiency" Deregulatory Initiative, requires agencies to focus its limited enforcement resources on regulations authorized by constitutional Federal statutes.
EO 14218, Ending Taxpayer Subsidization of Open Borders, prohibits taxpayer resources and benefits from going to unqualified aliens.
EO 14202, Eradicating Anti-Christian Bias, establishes a taskforce to eradicate Anti-Christian bias within the U.S. Department of Justice. EO 14205, Establishment of the White House Faith Office, establishes the White House Faith Office within the Executive Office of the President to empower faith-based entities.
EO 14182, Enforcing the Hyde Amendment, prohibits the use of Federal taxpayer dollars to fund or promote elective abortion.
EO 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity, requires Federal agencies to terminate all discriminatory and illegal preferences.
EO 14168, Defending Women From Gender Ideology Extremism and Restoring Biological Truth to the Federal Government, sets forth U.S. policy recognizing two sexes, male and female.
EO 14151, Ending Radical and Wasteful Government DEI Programs and Preferencing, requires the OMB Director assisted by the Attorney General and the OPM Director to coordinate the termination of all discriminatory programs and activities.
EO 14148, Initial Rescission of Harmful Executive Orders and Action, revokes 67 EOs that were each issued between January 20, 2021, and January 16, 2025; and 11 Presidential memoranda issued between March 13, 2023, and January 14, 2025, to advance fairness, safety, and improve the economy.
Here is some relevant information from the General Statutory and Regulatory Requirements Affecting Eligibility for HUD's Financial Assistance Programs
- Mandatory Disclosure Requirement.
Pursuant to 2 CFR 200.113, each applicant or recipient of a Federal award must promptly disclose in writing to the Office of Inspector General (OIG) and to the awarding HUD Program Office, whenever it has credible evidence of any of the following in connection with the award or any activities or subawards under the award: (a) any violation of Federal criminal law involving fraud, conflict of interest, bribery, or gratuity violations under Title 18 of the United States Code (U.S.C.); or (b) any violation of the civil False Claims Act (31 U.S.C. 3729-3733). Recipients of a Federal award that includes or incorporates the Award Term and Condition for Recipient Integrity and Performance Matters (Appendix XII to 2 CFR part 200) must also report certain civil, criminal, or administrative proceedings to SAM.gov, as stated in the award term and condition. Failure to make required disclosures can result in any of the remedies described in § 200.339. See also 2 CFR part 180 and 2424, 31 U.S.C. 3321 note; and 41 U.S.C. 2313.
[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 eventshttps://imla.org/events/, calls and programming.
Hi again,
I come bearing additional updates from the FAA and HUD. We can also talk about these on tomorrow's federal funding call.
FAA. From the FAA, we have a FY2025 Grant Template, which you can access here: https://www.faa.gov/airports/aip/grantapportion_data/fy-25-grant-agreement-template. Some changes on the FAA website are highlighted in yellow. From what I am initially seeing, they have added new language about termination on p. 3. Then beginning on p. 31 of the PDF, which is p. 2 of the Assurances, you can see new general funding requirements, including new executive orders. (The reason I said "some" changes are highlighted is because the highlights appear to not catch all the changes. For example, I see on p. 3 of the Assurances lists of new EOs that are not highlighted in yellow including Unleashing American Energy, Ending Radical and Wasteful Government DEI Programs and Preferencing, among others. There are also changes to the certifications on p. 56-58 of the PDF that are not in yellow highlights but it lists out the new EOs. So if these grants will apply to you, you will want to review the new template carefully).
HUD. I am attaching two HUD documents dated 4/22/25 with new conditions and requirements for grant recipients. Note that under "other presidential executive actions affecting federal financial assistance programs," it lists a number of EOs but then specifically says the list is non-exhaustive and links to the white house presidential action page.
Here is some relevant information / additions to the General Administrative, National, and Departmental Policy Requirements and Terms for HUD's Financial Assistance Programs:
Compliance with Immigration Requirements
The recipient must administer its award in accordance with all applicable immigration restrictions and requirements, including the eligibility and verification requirements that apply under title IV of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996, as amended (8 U.S.C. 1601-1646) (PRWORA) and any applicable requirements that HUD, the Attorney General, or the U.S. Citizenship and Immigration Services may establish from time to time to comply with PRWORA, Executive Order 14218, or other Executive Orders or immigration laws.
No state or unit of general local government that receives HUD funding under may use that funding in a manner that by design or effect facilitates the subsidization or promotion of illegal immigration or abets policies that seek to shield illegal aliens from deportation.
Subject to the exceptions provided by PRWORA, the recipient must use SAVE, or an equivalent verification system approved by the Federal government, to prevent any Federal public benefit from being provided to an ineligible alien who entered the United States illegally or is otherwise unlawfully present in the United States.
Other Presidential Executive Actions Affecting Federal Financial Assistance Programs
Recipients of Federal Awards must comply with applicable existing and future Executive Orders, as advised by the Department, including but not limited to the following:
Executive Order (EO) 14219, Ensuring Lawful Governance and Implementing the President's "Department of Government Efficiency" Deregulatory Initiative, requires agencies to focus its limited enforcement resources on regulations authorized by constitutional Federal statutes.
EO 14218, Ending Taxpayer Subsidization of Open Borders, prohibits taxpayer resources and benefits from going to unqualified aliens.
EO 14202, Eradicating Anti-Christian Bias, establishes a taskforce to eradicate Anti-Christian bias within the U.S. Department of Justice. EO 14205, Establishment of the White House Faith Office, establishes the White House Faith Office within the Executive Office of the President to empower faith-based entities.
EO 14182, Enforcing the Hyde Amendment, prohibits the use of Federal taxpayer dollars to fund or promote elective abortion.
EO 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity, requires Federal agencies to terminate all discriminatory and illegal preferences.
EO 14168, Defending Women From Gender Ideology Extremism and Restoring Biological Truth to the Federal Government, sets forth U.S. policy recognizing two sexes, male and female.
EO 14151, Ending Radical and Wasteful Government DEI Programs and Preferencing, requires the OMB Director assisted by the Attorney General and the OPM Director to coordinate the termination of all discriminatory programs and activities.
EO 14148, Initial Rescission of Harmful Executive Orders and Action, revokes 67 EOs that were each issued between January 20, 2021, and January 16, 2025; and 11 Presidential memoranda issued between March 13, 2023, and January 14, 2025, to advance fairness, safety, and improve the economy.
Here is some relevant information from the General Statutory and Regulatory Requirements Affecting Eligibility for HUD's Financial Assistance Programs
4. Mandatory Disclosure Requirement.
Pursuant to 2 CFR 200.113, each applicant or recipient of a Federal award must promptly disclose in writing to the Office of Inspector General (OIG) and to the awarding HUD Program Office, whenever it has credible evidence of any of the following in connection with the award or any activities or subawards under the award: (a) any violation of Federal criminal law involving fraud, conflict of interest, bribery, or gratuity violations under Title 18 of the United States Code (U.S.C.); or (b) any violation of the civil False Claims Act (31 U.S.C. 3729-3733). Recipients of a Federal award that includes or incorporates the Award Term and Condition for Recipient Integrity and Performance Matters (Appendix XII to 2 CFR part 200) must also report certain civil, criminal, or administrative proceedings to SAM.gov, as stated in the award term and condition. Failure to make required disclosures can result in any of the remedies described in § 200.339. See also 2 CFR part 180 and 2424, 31 U.S.C. 3321 note; and 41 U.S.C. 2313.
[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.