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Real Property Here and Now. Region 3 Fiscal Forum. OMB Circulars. Revised May 10, 2004 Consistency among Circulars Changes A-87, Attachment B, Item 15 A-122, Attachment B, Item 15 A-21, Section J, Item 18 Capital assets charged in the year of acquisition. Impact of Change.

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real property here and now

Real PropertyHere and Now

Region 3 Fiscal Forum

omb circulars
OMB Circulars
  • Revised May 10, 2004
  • Consistency among Circulars
  • Changes
    • A-87, Attachment B, Item 15
    • A-122, Attachment B, Item 15
    • A-21, Section J, Item 18
  • Capital assets charged in the year of acquisition
impact of change
Impact of Change
  • Amortization is not an option
    • Without specific waiver from Grant Officer
  • Applicability to new acquisitions
  • Applicability to current agreements
  • Repayment of Reed Act funds
tegl 07 04
TEGL 07-04
  • Issued October 20, 2004
  • Applies to both SWA and WIA real property
  • Addresses procedures and accounting for use of buildings with Federal equity
  • Requires action by SWA and WIA
    • Compliance with requirements by 12/31/04
allowable premises costs
Allowable Premises Costs
  • Represent cost of occupying space
  • Do not require prior approval
  • Depreciation or use allowances
    • Excludes cost of land
  • Allocable interest costs
  • Operation & maintenance costs (O&M)
ownership issues
Ownership Issues
  • Equity arrangements
  • Capital leases vs. amortization
  • Disposition requirements
    • Uniform administrative requirements
    • Including use of proceeds for both UI and WP programs
disposition of real property
Disposition of Real Property
  • Request Disposition Instructions
  • Three Viable Alternatives
    • Retention of Title
    • Sale of Property
    • Transfer of Title
replacement property
Replacement Property
  • New property to replace existing property
  • Expanding or enlarging existing property
  • Capital improvements on existing property
one stop occupancy by partners
One-Stop Occupancy by Partners
  • One-Stop system occupancies under WIA Section 193 (a)
  • Cost-free occupancy not permitted
  • Amortization vs. Allowable Premises Costs
  • Capital lease issues
  • Fully amortized buildings
wia funded capital improvements
WIA-funded Capital Improvements
  • Repairs, renovations and alterations
  • OMB Circular A-87, Attachment B
    • Current operating costs
    • Maintenance, operations and repairs
    • Renovations & other capital improvements
  • Allowable costs
prior approval requirements
Prior Approval Requirements
  • SWAs must obtain prior approval
    • Acquisitions of real property
    • Capital expenditures
    • W-P, UI or TAA funds
  • Improvements to leaseholds
    • Allowable if conditions met
    • $100,000 threshold for prior approval
action required
ACTION Required
  • Review amortization arrangements
    • Update amortization schedules
    • Request exceptions as needed
  • Examine real property procedures and update for compliance with TEGL
  • Update real property records
    • Costs of land, buildings, etc.
    • Fund sources used for acquisition
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