What does "Local Government" Actually Mean under CARES Act?

H(
HariNarayan (Huddy) K. Grandy
Fri, Apr 3, 2020 9:27 PM

All:

The CARES Act Title VI defines local government as the following:

"'unit of local government' means a county, municipality, town, township, village, parish, borough, or other unit of general government below the State level with a population that exceeds 500,000."

I believe this definition could actually mean that any "town" or "village" must have a population of at least 500,000 to qualify for its own funding.

If this is the case, not a single political subdivision of my state would qualify for this relief - it would all go to the state.

Is this the correct interpretation? Has anyone received firm guidance on this?

HariNarayan (Huddy) K. Grandy

Attorney

603.792.7433 Direct

HGrandy@dwmlaw.commailto:HGrandy@dwmlaw.com

670 N. Commercial Street, Suite 207, Manchester, NH 03101

800.727.1941 | 603.716.2899 Fax | dwmlaw.comhttp://www.dwmlaw.com

[DrummondWoodsum]http://www.dwmlaw.com/

Please note that our Manchester office has moved.  As of Monday, December 9th, our new address is 670 N. Commercial Street, Suite 207, Manchester, NH 03101. Thank you.

The information transmitted herein is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material.  Unintended transmission shall not constitute waiver of any privilege, including, without limitation, the attorney-client privilege if applicable.  Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons or entities other than the intended recipient is prohibited.  If you received this in error, please contact the sender and delete the e-mail and any attachments from any computer.

All: The CARES Act Title VI defines local government as the following: "'unit of local government' means a county, municipality, town, township, village, parish, borough, or other unit of general government below the State level with a population that exceeds 500,000." I believe this definition could actually mean that any "town" or "village" must have a population of at least 500,000 to qualify for its own funding. If this is the case, not a single political subdivision of my state would qualify for this relief - it would all go to the state. Is this the correct interpretation? Has anyone received firm guidance on this? HariNarayan (Huddy) K. Grandy Attorney 603.792.7433 Direct HGrandy@dwmlaw.com<mailto:HGrandy@dwmlaw.com> 670 N. Commercial Street, Suite 207, Manchester, NH 03101 800.727.1941 | 603.716.2899 Fax | dwmlaw.com<http://www.dwmlaw.com> [DrummondWoodsum]<http://www.dwmlaw.com/> Please note that our Manchester office has moved. As of Monday, December 9th, our new address is 670 N. Commercial Street, Suite 207, Manchester, NH 03101. Thank you. The information transmitted herein is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Unintended transmission shall not constitute waiver of any privilege, including, without limitation, the attorney-client privilege if applicable. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact the sender and delete the e-mail and any attachments from any computer.
KW
Karen White
Fri, Apr 3, 2020 10:00 PM

That is correct and it knocks out everybody in LA from direct funding, too.  The money goes to the state, who then must allocate 45% of it to locals according to rules/processes that they promulgate.  We have joined NLC and other state leagues to fight hard for direct access to funding without population threshold in the 4th stimulus package.

Karen White

Get Outlook for Androidhttps://aka.ms/ghei36


From: Disasterrelief disasterrelief-bounces@lists.imla.org on behalf of HariNarayan (Huddy) K. Grandy HGrandy@dwmlaw.com
Sent: Friday, April 3, 2020 4:27:59 PM
To: 'disasterrelief@lists.imla.org' disasterrelief@lists.imla.org
Subject: [Disasterrelief] What does "Local Government" Actually Mean under CARES Act?

All:

The CARES Act Title VI defines local government as the following:

“‘unit of local government’ means a county, municipality, town, township, village, parish, borough, or other unit of general government below the State level with a population that exceeds 500,000.”

I believe this definition could actually mean that any “town” or “village” must have a population of at least 500,000 to qualify for its own funding.

If this is the case, not a single political subdivision of my state would qualify for this relief – it would all go to the state.

Is this the correct interpretation? Has anyone received firm guidance on this?

HariNarayan (Huddy) K. Grandy

Attorney

603.792.7433 Direct

HGrandy@dwmlaw.commailto:HGrandy@dwmlaw.com

670 N. Commercial Street, Suite 207, Manchester, NH 03101

800.727.1941 | 603.716.2899 Fax | dwmlaw.comhttp://www.dwmlaw.com

[DrummondWoodsum]http://www.dwmlaw.com/

Please note that our Manchester office has moved.  As of Monday, December 9th, our new address is 670 N. Commercial Street, Suite 207, Manchester, NH 03101. Thank you.

The information transmitted herein is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material.  Unintended transmission shall not constitute waiver of any privilege, including, without limitation, the attorney-client privilege if applicable.  Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons or entities other than the intended recipient is prohibited.  If you received this in error, please contact the sender and delete the e-mail and any attachments from any computer.

That is correct and it knocks out everybody in LA from direct funding, too. The money goes to the state, who then must allocate 45% of it to locals according to rules/processes that they promulgate. We have joined NLC and other state leagues to fight hard for direct access to funding without population threshold in the 4th stimulus package. Karen White Get Outlook for Android<https://aka.ms/ghei36> ________________________________ From: Disasterrelief <disasterrelief-bounces@lists.imla.org> on behalf of HariNarayan (Huddy) K. Grandy <HGrandy@dwmlaw.com> Sent: Friday, April 3, 2020 4:27:59 PM To: 'disasterrelief@lists.imla.org' <disasterrelief@lists.imla.org> Subject: [Disasterrelief] What does "Local Government" Actually Mean under CARES Act? All: The CARES Act Title VI defines local government as the following: “‘unit of local government’ means a county, municipality, town, township, village, parish, borough, or other unit of general government below the State level with a population that exceeds 500,000.” I believe this definition could actually mean that any “town” or “village” must have a population of at least 500,000 to qualify for its own funding. If this is the case, not a single political subdivision of my state would qualify for this relief – it would all go to the state. Is this the correct interpretation? Has anyone received firm guidance on this? HariNarayan (Huddy) K. Grandy Attorney 603.792.7433 Direct HGrandy@dwmlaw.com<mailto:HGrandy@dwmlaw.com> 670 N. Commercial Street, Suite 207, Manchester, NH 03101 800.727.1941 | 603.716.2899 Fax | dwmlaw.com<http://www.dwmlaw.com> [DrummondWoodsum]<http://www.dwmlaw.com/> Please note that our Manchester office has moved. As of Monday, December 9th, our new address is 670 N. Commercial Street, Suite 207, Manchester, NH 03101. Thank you. The information transmitted herein is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Unintended transmission shall not constitute waiver of any privilege, including, without limitation, the attorney-client privilege if applicable. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact the sender and delete the e-mail and any attachments from any computer.