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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