The Connecticut Individual Development Account Initiative and Housing Trust Fund. Technical Policy Manual

Transcription

1 The Connecticut Individual Development Account Initiative and Housing Trust Fund Technical Policy Manual

2 Date: Section: 1000 Topic: Table of Contents and Appendices 1000 Table of Contents 1010 Introduction 1020 Mission, Goals, Objectives 1030 Authority and Purpose 1040 Definitions 1100 Program Eligibility 1110 Household Income Determination 1120 Earned Income Documentation 1130 SSI, SSDI and PASS Plans 1140 Geographic Area Table of Contents 1200 Repeat Individual Development Account Participant 1300 IDA Training for Participants - Financial Education, Asset Specific Training and Monthly Savings Clubs 1400 Six Month Enrollment Requirement 1500 Personally Identifiable Information (PII) 1600 Lump Sum Deposits 1700 Allowable Asset Purchases 1705 Using IDA Funds to Reconstruct a Home 1710 Mobile (Manufactured) Homes 1715 IRS Ruling on IDA Homebuyer Assistance Programs 1720 Home Asset Purchase with a Person who is Not an IDA Participant 1725 Small Business Capitalization 1730 Education - On-line Courses 1735 Education - Computer Purchase 1740 Education - Spouse, Sibling 1745 Education - Prepaying Tuition 1750 Education - Multiple Education Asset Purchases 1755 Education Plans 1760 Lease Deposit for a Primary Residence 1765 Purchase of Vehicle for Employment 1770 Pre-Owned Vehicles 1775 Purchase of a Replacement Vehicle

3 Date: Section: 1000 Topic: Table of Contents and Appendices Table of Contents continued 1800 Local Reserve Fund 1800 Interest Earned 1810 Co-Mingling of IDA Matching Funds 1900 Unclaimed Property Procedures 2000 Record Retention 2100 IDA Program Certification Appendices A) 80% Area Median Income Chart B) Federal Poverty Guidelines C) Access Database Instructions D) Grant Closeout E) Pilot Policy for Transferring Participants Among Connecticut Individual Development Account (IDA) Programs 6/5/2012 F) Tumbleweed Secure Desk Aid

4 Date: Section: 1010 Topic: Introduction Introduction This technical policy manual provides guidance to the Individual Development Account (IDA) program operators awarded grants by the Connecticut Department of Labor (CT DOL). It was developed by the CT DOL and the Clearinghouse liaison in response to technical questions generated from program operation and the answers to those questions. Although other programs such as the federal Assets for Independence Act (AFIA) are referenced in this manual, the policy and procedures in this manual are limited to the Connecticut Individual Development Account programs. This manual supplements, but does not replace, the Connecticut Individual Development Account Initiative Policies and Procedures Manual. However, due to the evolving nature of the IDA program, the need for additional policies or modifications to existing policies will occur. As these additions or modifications occur, this manual will be revised. This manual contains the most recent guidance on IDA policies.

5 Date: Section: 1020 Topic: Mission, Goals, Objectives Mission The Connecticut IDA Initiative intends to strengthen families and communities by facilitating self-sufficiency and economic stability through financial education and asset development. Goals 1. To invest in communities by providing opportunities for community-based organizations to offer financial education and matched savings accounts as asset development tools for low-income and moderate-income families. 2. To invest in low-income and moderate-income families by providing grants for community-based organizations to prepare and assist families to purchase and maintain assets through six qualified purchases: Education or job training; Home ownership; Small business capitalization; Lease deposit on a primary residence; Vehicle purchase to obtain or maintain employment; Education or job training for a dependent child. Objectives 1. To provide Individual Development Account opportunities for the purposes of: a. Increasing home ownership opportunities for low- and moderate-income families. b. Increasing access to post-secondary education and career training for low- and moderate-income families. c. Developing micro-enterprise ownership opportunities for low- and moderateincome families. d. Improving access to rental opportunities for low- and moderate-income families. e. Supporting employment transportation for low- and moderate-income families. 2. To facilitate financial education opportunities that will provide participants with the knowledge necessary to build their assets and use these assets in the most effective way. 3. To develop life-long savings habits among participant families. 4. To encourage decision-making and long-range planning among participant families. 5. To familiarize IDA participants with financial institutions and increase their comfort level in doing business with those institutions.

6 Date: Section: 1030 Topic: Authority and Purpose Authority and Purpose Pursuant to State of Connecticut Public Act No , CT DOL shall serve as the state administrator of the Connecticut Individual Development Account Initiative ( Connecticut IDA Initiative ). The purpose of the Connecticut IDA Initiative is to provide eligible individuals with opportunities to establish individual development accounts for matched earned income savings, through Certified State IDA Programs. The Connecticut IDA Initiative is subject to applicable Federal, State or local government laws and regulations concerning the establishment, administration and delivery of IDA programs; including but not necessarily limited to banking practices and standards, and applicable US Public Law Title IV, Assets for Independence Act requirements and standards. CT DOL implemented the Connecticut IDA Initiative through adoption of IDA regulations and competitive procurement of Certified State IDA Programs for local areas. CT DOL established and administers a non-lapsing, Central Individual Development Account Reserve Fund (IDA Reserve Fund) for the Initiative; and an IDA Clearinghouse for information on Certified State IDA Program funding, establishment, local administration and delivery, and best practices. CT DOL performs oversight, monitoring, and evaluation functions as the state administrator of the Connecticut IDA Initiatives. Individuals eligible to participate in state-funded Certified IDA Programs are members of a household located in Connecticut, have earned income, and whose adjusted gross income does not exceed 80% of the Area Median Income as derived for Connecticut towns by CT DOL per USDHUD Area Median Income figures and formulas. The earned income requirement does not apply to Qualified Disabled Individuals. Program operators must make every good effort to ensure that at least 30% of the IDA accountholders in any state-funded Certified IDA Program have earned income at or below 200% of the Federal Poverty Level. Eligible bidders for Certified State IDA Programs are community-based organizations (CBOs), i.e. organizations exempt from taxation pursuant to Sec. 501(c)(3) of the Internal Revenue Code of 1986 or any subsequent corresponding IRS code of the U.S as amended. CT DOL has the discretion to adopt additional eligibility criteria for Certified State IDA program bidders/providers through IDA regulations. CT DOL adopted regulations for the Connecticut IDA Initiative in concert with the Office of the Treasurer (OTT). CT DOL releases Request for Proposals (RFP) to solicit, review, accept, or reject proposals from community-based organizations seeking to operate Certified State IDA programs on a not-for-profit basis. The regulations adopted by CT DOL contain the processes and requirements for: the competitive procurement Date: Section: 1030

7 Topic: Authority and Purpose Authority and Purpose continued process; the establishment of IDA reserve funds; the establishment of the IDA Clearinghouse; the criteria for certification of IDA Programs; and other aspects of the Connecticut IDA Initiative, pursuant to CT PA Section 9. Amounts appropriated by the State for the Connecticut IDA Initiative will be deposited in the Central IDA Reserve Fund administered by CT DOL. The Central IDA Reserve Fund will hold grants, donations, contributions, and other sources of revenue received for the IDA Initiative. CT DOL uses amounts from the Central IDA Reserve Fund for the following: to provide grants to CBOs to operate Certified State IDA Programs; to assist organizations to provide training, counseling, and case management for program participants; and for program administration purposes at the state and local levels. CT DOL will provide grant funds for the preceding purposes from the CT DOL Central IDA Reserve Fund for deposit into local reserve funds established and managed by the CBOs that are awarded grants by CT DOL to provide local Certified IDA Program services. CBOs will establish and maintain local reserve funds, trust or custodial accounts for participants IDAs, and parallel accounts for individual matching contributions through partnering agreements with insured financial institutions. Certified State IDA Programs provide IDA services that include but are not necessarily limited to the following: outreach; uniform application procedures and approved Savings Plan development; case management and financial counseling; financial education training; training and counseling specific to the approved expenses for which IDA participants are saving; crisis intervention services to prevent premature or emergency withdrawals of IDA savings; and follow-up after approved expense purchase. CT DOL monitors and evaluates Certified State IDA Programs established through CT DOL contracts to ensure ongoing compliance, to track performance, and to measure the extent to which asset-based policy affects civic, social, and economic improvement and stability for families and communities.

8 Date: Section: 1040 Topic: Definitions Definitions Account Holder means a participant in a certified state IDA program. Adjusted Gross Income (AGI) means the adjusted gross income of a natural person with respect to any taxable year, as determined for federal income tax purposes and as properly reported on such person's federal income tax return. Approved Plan means a plan (Savings Plan Agreement) prepared jointly by the account holder and the community-based organization that defines savings goals, program requirements and permissible uses of the individual development account and its matching funds pursuant to sections 31-51xx to 31-51aaa, inclusive, and regulations adopted pursuant to section 31-51ddd. The approved plan shall be a contract between the account holder and the community-based organization. Area Median Income (AMI) means area median household income as determined from time to time by the United States Department of Housing and Urban Development. Calendar Year means January to December (regardless of enrollment date, initial de posit date or contract date). Certified State IDA Program means a program of matched savings accounts that has been certified by the department in accordance with regulations adopted pursuant to section 31-51ddd. Clearinghouse means a service to provide organizations interested in establishing, or which have established, individual development account programs with literature on federal, state and other sources of funding, guidelines for best practices and program standards, and information regarding the establishment and maintenance of certified state IDA programs. Community-Based Organization means an organization exempt from taxation pursuant to section 501(c)(3) of the Internal Revenue Code of 1986 or any subsequent corresponding internal revenue code of the United States, as from time to time amended, which meets the requirements set forth in regulations pursuant to section 31-51ddd. Department means the Connecticut Labor Department. Dependent Child means the account holder s natural child, adopted child, stepchild, or legal ward who, at the commencement of the account holder s participation in a certified state IDA program is: (a) under twenty-one (21) years of age and wholly or mainly Date: Section: 1040

9 Topic: Definitions Definitions continued DEPARTMENT OF LABOR supported by the account holder; or (b) mentally or physically impaired and, because of such impairment, wholly or mainly supported by the account holder. Earned Income means any compensation payable by an employer to an employee, including but not limited to wages, salaries, commissions, bonuses, and tips, earnings from self-employment or contractual agreements, and Earned Income Tax Credit refunds. Education means (A) a post-secondary program of instruction provided by a college, university, community college, area vocational-technical school, professional institution or specialized college or school legally authorized to grant degrees, or (B) any related educational program approved by the community-based organization and the department. Vocational-technical education - The Perkins Act defines vocational-technical education as organized educational programs offering sequences of courses directly related to preparing individuals for paid or unpaid employment in current or emerging occupations requiring other than a baccalaureate or advanced degree. Programs include competency-based applied learning which contributes to an individual's academic knowledge, higher-order reasoning, problem solving skills, and the occupational-specific skills necessary for economic independence as a productive and contributing member of society. For more information on the Carl D. Perkins Act, go to: Emergency Withdrawal means a withdrawal, by an account holder from those funds deposited by the account holder in his/her individual development account, due to a personal crisis, including but not limited to, illness, eviction, potential foreclosure, job loss or urgent family reasons. Entrepreneurial Activity means the purchase of or investment in a small business, as defined in subsection (a) of section 4-168a, in Connecticut in which, upon such purchase or investment, the account holder will be a principal. Small Business ((a) of section 4-168a) - means a business entity, including its affiliates, that (A) is independently owned and operated and (B) employs fewer than seventy-five full-time employees or has gross annual sales of less than five million dollars, provided that an agency, in adopting regulations in accordance with the provisions of this chapter, may define small business to include a greater number of full-time employees, not to exceed applicable federal standards or five hundred, whichever is less, if necessary to meet the needs and address specific problems of small businesses. Date: Section: 1040 Topic: Definitions

10 Definitions continued Federal Poverty Level (FPL) means the most recent poverty income guidelines published by the United States Department of Health and Human Services. Financial Institution means a financial institution, as defined in section 36a-330: Financial Institution (36a-330) - means a bank, Connecticut credit union, federal credit union or an out-of-state bank that maintains in this state a branch as defined in section 36a-410; Branch (36a-410) - means a domestic branch as defined in 12 USC Section 1813, as from time to time amended, except that branch includes any branch bank, branch office, branch agency, additional office, or any branch place of business at which fiduciary or trust powers are exercised. Household means all individuals who share use of a dwelling unit as primary quarters for living and eating separate from other individuals. (Federal Assets for Independence Act, P.L ) Individual Development Account (IDA) means a savings account, maintained in a program that is established pursuant to section 31-51xx that is held in a financial institution, for the sole purpose of holding the funds of the account holder for one of the purposes described in subsection (a) of section 31-51xx. Individual Development Account Reserve Fund means a non-lapsing fund administered by the department for the purposes of providing matching funds for individual development accounts in certified state IDA programs, and for funding costs incurred by community-based organizations in the operation and administration of such programs and the department's administrative costs for the Connecticut IDA Initiative. Job Training means a program for job entrance or skill development approved by the community-based organization and the department. Qualified Disabled Individual means a disabled individual eligible for assistance to the disabled pursuant to chapter 319mm. Persons With Disabilities (Chapter 319mm) shall mean persons having disabilities which (1) are attributable to a mental or physical impairment or a combination of mental and physical impairments; (2) are likely to continue indefinitely; (3) result in functional limitations in one or more of the following areas of major life Date: Section: 1040 Topic: Definitions

11 Definitions continued DEPARTMENT OF LABOR activity: Self care, receptive and expressive language, learning, mobility, selfdirection, capacity for independent living or economic self-sufficiency; and (4) reflect the person's need for a combination and sequence of special, interdisciplinary or generic care, treatment or other services which are of lifelong or extended duration and individually planned and coordinated. (Sec. 17b-608) Qualified Disabled Individual means: The individual is receiving Supplemental Security Income or Social Security Disability; or The individual is receiving Medicaid on the basis of a disability; or The individual is participating in rehabilitation services under Chapter 319mm of the Connecticut General Statutes; or The individual provides confirmation by the Bureau of Rehabilitative Services that such individual is eligible for assistance pursuant to Chapter 319mm of the Connecticut General Statutes; or The individual provides confirmation by any other agency deemed comparable by DOL of the individual s disability.

12 Date: Section: 1100 Topic: Program Eligibility To participate in a certified state IDA program, an individual, at the time of application, shall be a member of a household located in Connecticut whose adjusted gross income is not in excess of eighty per cent of the area median income for the area in which the individual resides and shall: (1) have earned income; or (2) be a qualified disabled individual as defined by the Regulations of Connecticut State Agencies.

13 Date: Section: 1110 Topic: Household Income Determination Household Income Determination Household income to determine program eligibility includes the following: Wages and salaries before any deductions. Net receipts from self-employment (receipts from one s own business after deductions for business expenses). Regular payment from the Social Security Administration (gross benefits), railroad retirement, unemployment compensation, strike benefits from union funds, worker s compensation, veteran s payments, public assistance (including TANF, SSI and SSDI), training stipends, alimony, child support, and military family allotments. Private pensions, government employee pensions (including military retirement pay), regular insurance or annuity payments. Dividends, interest, net rental income, net royalties, periodic receipts from estates or trusts, and net gambling or lottery winnings. Payments to Native Americans from gaming revenues (e.g., casino profit sharing). Do not include the following in determining eligibility: Capital gains. Any withdrawal from a bank; the sale of property, a house or a car. Tax refunds, gifts, loans, lump sum inheritances or one-time insurance payments. Non-cash benefits such as employer-paid or union-paid portion of health insurance or other employee fringe benefits, food or housing received in lieu of wages, and federal non-cash benefit programs such as Medicare, Medicaid, food stamps, school lunches, housing and other emergency assistance. Any portion of Social Security benefits deducted to pay Medicare premiums that will not be reimbursed.

14 Date: Section: 1120 Topic: Earned Income Documentation Earned Income Documentation To participate in a certified CT IDA program, an individual, at the time of application, shall be a member of a household located in Connecticut whose adjusted gross income is not in excess of eighty per cent of the area median income for the area in which the individual resides and shall have earned income. CT IDA eligibility documents to determine earned income: Most recent year s income tax returns Last two (2) pay stubs Proof of any other income (e.g., other government assistance, pensions, child support) Bank account statements Information on any investments or 401k accounts Other documents to assist in program eligibility: Copies of past due bills Social Security Card Other ID Proof of other benefits (e.g., Social Security, SSI, SSDI, housing supplements, Section 8, etc.) Immigration documentation Copies of these documents are to be kept in the participant s file. Agencies have also found it advantageous to have applicants bring a copy of their credit report to the interview with the program operator. Important note: CT IDA eligibility differs from the federal AFI eligibility. For example, the AFI program requires a net worth test while the CT IDA initiative does not. The following are examples of AFI IDA eligibility documents. AFI IDA eligibility documents: Verification of being a current TANF recipient Copy of deed to house, if applicable Copy of title to car, if applicable Proof of business ownership, if applicable

15 Date: Section: 1130 Topic: SSI, SSDI, and PASS Plans Supplemental Security Income (SSI) and Social Security Disability Insurance (SSDI) Supplemental Security Income (SSI) is a Federal needs-based program administered by the Social Security Administration (SSA). It pays a cash benefit to individuals who are aged, blind, or have disabilities and who have limited income and assets. Social Security Disability Insurance (SSDI) is a federally-funded benefits program that provides aid to people who are unable to achieve gainful employment due to a permanent disabling condition. Plan for Achieving Self-Support (PASS) A Plan for Achieving Self-Support or PASS plan is a work incentive for people on SSI. Including a non-federal IDA (such as those provided under a CT IDA Program) into a PASS plan is currently the only way a person receiving SSI can participate in an IDA without reaching the asset limits. Since issues of SSI/SSDI and asset limits are complicated and can change, be sure to contact the Connect to Work Benefits Specialist ( ) and/or the Social Security Administration in your area for assistance to avoid conflicts that could adversely impact an individual s benefits.

16 Date: Section: 1140 Topic: Geographic Area Geographic Area An individual living in a city/town that has an existing IDA program that does not have any openings can be referred to an IDA program outside his/her geographic area if that IDA program has openings. On rare occasions, an individual might live in one town and work in another, and it would be more convenient for him/her to join an IDA program near where they work. This can be permitted, after consultation with DOL and with the program operator in the town where the participant lives.

17 Date: Section: 1200 Topic: Repeat Individual Development Account Participant Repeat Individual Development Account Participant The IDA participant is eligible for a maximum match of $3,000. Once an IDA participant has left a CT IDA program, either because they have successfully purchased an asset or because they have been terminated from the program because of other reasons, they cannot be admitted as a participant to another CT IDA program. There are so few IDA slots available in the state and so many people who could benefit from an IDA, it is therefore not allowable to re-enroll or enroll a CT IDA participant in multiple CT IDA programs.

18 Date: Section: 1300 Topic: IDA Training for Participants - Financial Education, Asset Specific Training and Monthly Savings Clubs IDA Training for Participants -- Financial Education, Asset Specific Training and Monthly Savings Clubs IDA Program Operators are required to provide several kinds of training for participants: Financial Education - Course is a minimum of 12 hours. Asset-Specific Training - This training pertains to the asset the participant is saving for. The training can be performed during monthly Savings Club meetings or referrals to training offered by another agency or group (e.g., first-time homeownership training given by a local housing counseling agency). If a participant attends asset-specific training outside your agency, they are excused from the monthly Savings Club meetings for the month(s) that they are attending the training. Monthly Savings Clubs - Each program should have a meeting once a month for their participants. Savings Clubs should be held at least 10 months during the year (some programs skip December and one month in the summer). Participants are required to attend at least 70% of the monthly meetings. Monthly Savings Clubs can cover a variety of topics: Asset-specific training, work-related issues, parenting, or other issues of concern to participants. (NOTE: If you have a speaker presenting on a particular asset at a meeting, your participants who are saving for a different asset should still be required to attend.) For more information, please see the section on Asset-Specific Training/Savings Clubs in the IDA Policies and Procedures Manual.

19 Date: Section: 1400 Topic: Six Month Enrollment Requirement Six Month Enrollment Requirement The CT IDA program shall ensure that no earlier than six months after the initial deposit by an account holder into an IDA, funds may be withdrawn for qualified expenses for purchase of an allowable asset, provided that the account holder has reached his/her savings goal and met all program requirements. Therefore, participants must be enrolled in the program for six months before taking a matched withdrawal. Individuals eligible for the IDA program often find themselves in low-income situations for a variety of reasons including a history of poor money management choices. IDA initiatives encourage programs to target economically-disadvantaged individuals. This emphasis, coupled with the allowable savings goals, makes it unlikely that low-income individuals would realize an appropriate and desirable savings objective in less than six months. The purpose of this provision is to encourage accountholders to plan long-term and discourage impulse purchases. Participants who remain in the program longer than six months and who save regularly, work to repair their credit and develop a savings habit, are more likely to be successful.

20 Date: Section: 1500 Topic: Personally Identifiable Information (PII) Personally Identifiable Information (PII) The Connecticut Department of Labor requires all IDA program operators to protect the confidentiality of any Participant data categorized as Personally Identifiable Information (PII). PII is defined as information that can be used to distinguish or trace an individual s identity, either alone or when combined with other personal or identifying information that is linked or can be linked to a specific individual. See OMP Memorandum M-07-17, dated 5/22/07, for more information: There are two types of PII: Protected PII: This is information that, if disclosed, could result in harm to the individual whose name or identity is linked to that information (e.g., Social Security numbers, credit card and bank account numbers, home addresses, home telephone numbers, ages, birthdates, marital status, spouses names, educational history, biometrics (fingerprints, voice prints, etc.) medical history, financial information, computer passwords, etc.). Non-Protected PII: This is information that if disclosed, by itself, could not reasonably be expected to result in personal harm (e.g., first and last names, addresses, business addresses, business telephone numbers, general education credentials, gender, race, etc.). However, depending on the circumstances, a combination of several items of Non-Protected PII could potentially be categorized as Protected PII. ALL Protected PII must be handled in a manner that will: Protect the confidentiality of the data Prevent unauthorized persons from retrieving such data by computer, remote terminal, or any other means. (Data may not be downloaded to, or maintained on, portable storage or mobile devices.) An IDA grantee will be held in non-compliance if they fail to comply with the requirements governing Protected PII and/or improperly use or disclose PII for an unauthorized purpose.

21 Date: Section: 1500 Topic: Personally Identifiable Information (PII) Personally Identifiable Information (PII) continued Failure to comply with the requirements may result in one or more of the following consequences: The termination or suspension of the grant The imposition of special conditions Any such other actions that the Connecticut Department of Labor may deem necessary to protect the privacy of participants or the integrity of the data

22 Date: Section: 1600 Topic: Lump Sum Deposits Lump Sum Deposits The IDA program is a long-term savings program to help participants change (or start) savings behaviors and habits as well as to fix and repair credit issues, etc. These things take time. A regular deposit of earned income into an IDA account on a monthly basis in accordance with the Savings Plan Agreement is the primary focus of the IDA program. The only time that a lump sum can be deposited in an IDA is if the funds are from a participant s EITC refund. The Department does not endorse (or allow) the practice of annual EITC deposits as the only deposits to meet the program goal of asset purchase. Please Note: EITC lump sum deposits will not be allowed for participants that are not in compliance with their monthly savings goal as agreed to in their Savings Plan Agreement.

23 Date: Section: 1700 Topic: Allowable Asset Purchases Allowable Asset Purchases The CT IDA initiative provides an eligible individual with an opportunity, through a certified state IDA program, to establish an individual development account from which funds may be used by the account holder for one of the following purposes as specified in the approved savings plan: (1) The costs of education or job training: (A) Education costs for an account holder are all costs which are necessary for the enrollment and successful completion of a program of education, including but not limited to tuition, fees, books, supplies and equipment. (B) Job training costs for an account holder are all costs which are necessary for the enrollment and successful completion of a job training program, including but not limited to tuition, fees, books, supplies and equipment. (2) The costs of purchasing a home as the account holder s primary residence, which costs shall not exceed one hundred-twenty percent of the average area purchase price applicable to such residence, and may include but not be limited to the costs of acquiring, constructing, or reconstructing a residence, including any usual or reasonable settlement, financing, or other closing costs. (3) The participation in or development of a new or existing entrepreneurial activity for which a business plan has been developed with the direct or indirect assistance of the community-based organization. (4) The purchase of an automobile for the purpose of obtaining or maintaining employment. (5) The purchase of a lease deposit on the account holder s primary residence. (6) The costs of education or job training for a dependent child of the account holder.

24 Date: Section: 1705 Topic: Using IDA Funds to Reconstruct a Home Using IDA Funds to Reconstruct a Home An account holder may use his/her IDA for the costs of acquiring, constructing or reconstructing a residence (not for renovation of an existing home). Reconstruction refers to very serious repairs on the house and not refurbishment or renovations of any kind. The law is interpreted to mean that participants may use their IDA savings and match to do any fix-up that is needed to make a participant's newly-purchased home livable, (e.g. new roof, new windows, new carpeting, new water heater, new furnace, etc.) not to purchase furnishings or appliances. The reconstruction would have to happen after the closing, since we do not want to encourage anyone to fix up a house they do not own. Reconstruction must be done in the context of the purchase of a new home; that is, a payment to make the home livable at (or near) the time of purchase. A good rule of thumb is that if the building inspection raises an issue concerning a repair that needs to be done, then that would be allowed under the definition of "reconstruction. IDA program operators are required to discuss a participant's request to use IDA savings and matching funds for reconstruction with CT DOL before approving funds to be used in this way. CT DOL always recommends spending IDA funds on costs that are clearly allowable, such as down payment or closing costs.

25 Date: Section: 1710 Topic: Mobile (Manufactured) Homes Mobile (Manufactured) Homes The following items need to be taken into consideration if an IDA participant wants to purchase a manufactured home: A manufactured home must be well-built and installed on a proper foundation. The financing must be fair and affordable (mobile home financing can sometimes be predatory and is often subprime). Homeowners should own the land underneath the home. According the federal Assets for Independence program, grantees are encouraged to use good judgment when counseling AFI IDA project participants. It is anticipated that grantees will help their participants make wise investment choices for example, to purchase a home that is in good shape, that will serve their needs, and that is likely to appreciate in value. Asset counseling needs to compare a new mobile home purchase with a comparable home, showing appreciation vs. depreciation over time. AFI strongly discourages grantees from counseling their participants to purchase a low-quality home, whether it is manufactured or other. Many lenders will NOT finance a used mobile home or a home in a park. AFI discourages the purchase of a home that is not permanently affixed to land that the participant owns. This holds true for the CT IDA Program. For IDA programs in rural areas, most IDA homebuyers will be eligible for USDA Rural Development (RD) subsidized mortgages. However, RD will only finance new mobile homes permanently affixed to owned land. Mobile home financing can sometimes be predatory and is often subprime, so asset counselors also need to talk with buyers about what predatory lending is, what to look for, and what to avoid. IDA participants should be strongly encouraged to opt for a stick built or modular home. The CFED website provides useful information on manufactured homes:

26 Date: Section: 1715 Topic: IRS Ruling on IDA Homebuyer Assistance Programs The IRS Ruling on IDA Homebuyer Assistance Programs First, the ruling finds that most traditional IDA homebuyer assistance programs (as well as certain builders and developers of low-income housing also offering down payment assistance) qualify as 501(c)(3) tax-exempt. Second, the ruling holds that organizations merely passing through seller-financed purchase assistance to buyers do not qualify as 501(c)(3) tax-exempt. Finally, the ruling also finds that traditional IDA down payment assistance funds qualify as gifts under IRC section 102 and as cost basis in the home under section The IRS ruling:

27 Date: Section: 1720 Topic: Home Asset Purchase with a Person Who is Not an IDA Participant Home Asset Purchase with a Person who is Not an IDA Participant An IDA participant may request to purchase a home with a non-ida participant as the co-owner. This is allowable; however, the sustainability of the purchase for the IDA participant is the primary concern for the integrity of the IDA program. Therefore, the following procedure must be followed: Ensure that the non-ida participant attends financial education classes and assetspecific classes with the IDA participant. Inform the bank/mortgage company and attorney that the individuals are not related family members to ensure that the correct mortgage instrument is used. Ensure that the IDA participant is listed on both the mortgage and the deed. Ensure that the IDA participant has enough income to carry the whole mortgage in the event that the non-ida participant is no longer providing his/her share of the mortgage payment. Call the CT DOL technical assistance provider for assistance with this and other unusual circumstances.

28 Date: Section: 1725 Topic: Small Business Capitalization Small Business Capitalization After the participant has met the requirements of the program (including asset-specific training and the development of a business plan, preferably with the assistance of a micro-enterprise development program) the program operator can deposit the participant's IDA funds and matching funds into a business capitalization account. This allows the participant to use those funds for initial start-up, for costs related to licensing/llc set-up, to purchase equipment, and for other costs related to the set-up and operation of his/her business.

29 Date: Section: 1730 Topic: Education - On-line Courses On-line Courses Paying for on-line courses with an IDA is allowable, provided the educational institution meets the qualifications for an eligible post-secondary educational institution as defined in the IDA regulations. The same requirements apply as for any traditional asset purchase for post-secondary education. Funds can be used for tuition, books and other fees, provided the check from the IDA and matching funds is made out to the educational institution.

30 Date: Section: 1735 Topic: Education - Computer Purchase Computer Purchase Grantees may allow participants to purchase supplies and equipment required by a school, however, the IDA funds can only be used for expenses paid directly to an eligible educational institution. If the school sells computers or can special order computers through its campus bookstore, then your participant could use his/her IDA savings to make that purchase. If the school s bookstore does not sell computers, research whether some other department in the school sells computers or works through a computer vendor (or other supplier). If the school has a special vendor agreement to buy its own equipment, perhaps it will allow the student to order a computer through that agreement. If none of these options are available, there may be other eligible educational institutions in the area that do sell computers. If so, explore whether the participant could purchase the equipment from that school.

31 Date: Section: 1740 Topic: Education - Spouse, Sibling Education for Spouse The CT IDA Program does not allow an account holder to pay for the education of their spouse. According to the Connecticut IDA regulations, education costs for an account holder or educational costs for a dependent child of an account holder are allowable assets. If an account holder s spouse wants to pursue education through the CT IDA program, they must become an active IDA account holder themselves. Education for Sibling IDAs may only be used to pay for an account holder s educational costs or the educational costs of a dependent child. In no case can IDA funds be used for a sibling's education.

32 Date: Section: 1745 Topic: Education - Prepaying Tuition Prepaying Tuition It is important for program operators to work with education institutions on the process for returning any prepaid funds to the IDA Project if the participant prepays but later decides not to attend that institution. In any event, IDA funds must be expended before the end of the Project period and may not be returned to the grantee or participant after the close of the Project.

33 Date: Section: 1750 Topic: Education - Multiple Education Asset Purchases Multiple Education Asset Purchases An IDA participant can take multiple matched withdrawals to pay for on-going educational expenses (i.e. tuition, fees, books, supplies and equipment).

34 Date: Section: 1755 Topic: Education Plans 529 Plans A 529 Plan is a tax-advantaged investment plan designed to encourage saving for the future higher education expenses of a designated beneficiary (in this case, the dependent child of an IDA account holder). The Plans are named after Section 529 of the Internal Revenue Code and are administered by state agencies and organizations. 529s were designed to help families contribute funds for future college costs by offering special tax benefits to Plan participants. Any earnings are federally tax deferred and if used for qualified expenses are free of federal and state income tax. Most states offer 529 Plans and many allow people from other states to invest in their plan. The following website provides each state s 529 plan by features (such as state tax benefits, fees, etc.). Often, the home state s 529 Plan has advantages for in-state residents. In Connecticut the 529 Plan is called the Connecticut Higher Education Trust (CHET). Connecticut residents who enroll in CHET may claim a Connecticut state income tax deduction for their contributions to the Plan. To find more information about CHET go to: Asset Specific Training: There is important information that must be shared with IDA participants who are saving for this asset: What is a 529 Plan? Is a 529 Plan right for you? Choosing the right 529 Plan How to decide what investment options are right for you. How to enroll in a 529 Plan. Information on these topics can be found at and Questions about CHET can be answered by calling the toll free number: (888)799-CHET.

35 Date: Section: 1760 Topic: Lease Deposit for a Primary Residence Lease Deposit for a Primary Residence The intent of the lease goal is for the account holder to obtain a primary residence. Therefore, the lease deposit can include items required by the landlord as a condition of obtaining the primary residence, including first and last month s rent and/or security deposit.

36 Date: Section: 1765 Topic: Purchase of Vehicle for Employment Purchase of Vehicle for Employment The purchase of a vehicle if needed for employment is one of the allowable assets that participants can save for under the Connecticut IDA Initiative Program. The law and regulations make it very clear: A vehicle can only be purchased through the IDA Program if the vehicle is necessary for the purchaser to obtain or maintain employment. This necessity of the vehicle for employment should be clearly documented in the participant s file. A participant who has saved in order to purchase a vehicle for employment purposes can use their IDA savings and matching funds to pay for registration of the auto and for the vehicle s insurance, as long as the insurance is paid at or close to the time of vehicle purchase. NOTE: Special care should be taken by those agencies operating Youth IDA Programs under the CT IDA Initiative, so as not to allow participants to save for a vehicle unless they will be at least 17 years of age by the time they are ready to make their asset purchase, and can prove that they will need the vehicle to obtain or maintain employment. Cases of youth saving for a vehicle will be scrutinized carefully by CT DOL. The preferable asset goal for youth is post-secondary education, as long as funds can be expended for the education asset by the time the program ends.

37 Date: Section: 1770 Topic: Pre-Owned Vehicles Pre-Owned Vehicles Certified pre-owned cars can be a prudent and affordable alternative to new cars. When purchased from a reputable licensed dealer, pre-owned cars often provide protections and warranties that add a level of protection for the asset purchase. IDA Program staff should require participants interested in purchasing a pre-owned vehicle to research qualified auto dealers in the area. It is the IDA Program s responsibility to make sure that IDA auto purchases are lawful and prudent. Purchase of a pre-owned vehicle from a private individual is not permitted under the CT IDA program. The check for the purchase of the pre-owned vehicle must be written to a licensed auto dealer.

38 Date: Section: 1775 Topic: Purchase of a Replacement Vehicle Purchase of a Replacement Vehicle Except in very extenuating circumstances, if a participant has a serviceable car the CT IDA Program will not permit that participant to trade their car in for a newer model. The primary purpose of allowing IDA Program participants to purchase a vehicle is to provide reliable, entry-level transportation to enable people to get or keep a job. Programs around the country that assist low-income families/individuals in purchasing vehicles, typically lease or sell vehicles that have retail values ranging from $2,000 to $5,000 and are generally from 8 to 14 years old, with a maximum of 100,000 to 140,000 miles.* It is this average that is reasonable for our participants. To trade this car in to acquire a newer one does not adhere to the spirit of the IDA program. *National Economic Development and Law Center

39 Date: Section: 1800 Topic: Local Reserve Fund - Interest Earned in Local Reserve Account Interest Earned in Local Reserve Account The Connecticut IDA regulations require that matching funds be made on behalf of each individual account holder up to two dollars for every one dollar deposited in the individual development account by the account holder, not to exceed $3,000 per account holder for the duration of the account holder's participation in the program. It is policy that the interest participants earn on the funds they deposit into their IDAs should also be matched. For example, if a participant in a 2:1 program saves up to $1,500, the interest earned on the savings will be matched 2:1 as well as the savings amount. In a 1:1 program, the interest on a participant s savings up to $3,000 will be matched 1:1 as well as the savings amount. Interest attributable to IDA matching contributions does not compound over time, but is assessed as a point in time calculation upon withdrawal for asset purchase. To Summarize: If a participant has direct deposit, you must be sure that the amount going into their account will not exceed $1,500 if they are in a 2:1 program (or $3,000 if they are in a 1:1 program). If a participant deposits more than $1,500 into their IDA in a 2:1 program (or $3,000 in a 1:1 program), you must have them remove the excess. Urge the participant to open up a savings account in their own name and deposit the extra money there. (It is always a good idea for IDA participants to have an extra savings account that they can use for emergencies or for additional expenses associated with their asset purchase.) With regard to interest earned in local reserve accounts: Interest income on CT IDA grant funds and non-state contributions deposited into Local Reserve Funds (that will not be used to match the interest on the participants' IDAs) shall be used to benefit IDA programs and participants/account holders in such programs.

40 Date: Section: 1800 Topic: Local Reserve Fund - Interest Earned in Local Reserve Account Interest Earned in Local Reserve Account continued Examples of uses that benefit IDA programs and participants/account holders include but are not necessarily limited to: provision of childcare and meals during financial education classes and Savings Club meetings; payment of stipends to guest speakers for financial education and Savings Clubs; provision of emergency loans for crisis interventions that prevent withdrawals of IDA savings or from IDA programs; and payment of program costs to ensure continuance of participant/account holder support throughout the duration of the program, such as case management costs or other direct service costs. It is understood that the amount of interest available for program or administrative uses decreases as savings goal achievements and asset purchases increase.

41 Date: Section: 1810 Topic: Local Reserve Fund - Co-Mingling of IDA Matching Funds Co-Mingling of IDA Matching Funds Co-mingling of IDA grant funds is not allowed. The Federal Government and the State of Connecticut require IDA funds to be held in separate accounts. The lead agency (in this case, DOL) can utilize one Central Reserve Fund for the receipt of AFIA, CT IDA and HTF grant funds. For CBOs operating CT IDA grants, the CT IDA Initiative funds cannot be co-mingled in the Local Reserve Fund with other IDA grant funds, with the exception of non-dol funds from a private funder that are used to supplement participants match. A separate Local Reserve Fund must be used for each IDA grant.

42 Date: Section: 1900 Topic: Unclaimed Property Procedures Unclaimed Property Procedures If a participant leaves the IDA program and unclaimed funds remain in their IDA the community-based organization (CBO) must contact their local bank to negotiate the process of handling the inactive IDA account. The CBO s negotiation with the financial institution should center on the following three (3) issues: 1.) Ideally, the bank would convert the IDAs to regular savings accounts and not charge fees. After 3 years the funds would be turned over to the Office of the Treasurer (OTT) as unclaimed property. (See Treasurer s website for additional information: 2.) Less ideal would be that the bank converts the IDAs to regular accounts and charges fees. After three (3) years any remaining funds would be turned over to OTT as unclaimed property. Many accounts would have been servicecharged out of existence at this point. 3.) Worst case scenario, the bank would not turn the funds over to OTT and would just let the account be service-charged out of existence. A problem to be resolved with the bank is: When a participant goes to the bank, perhaps several years down the road looking for their money, the original account number they have will be the old IDA custodial account number and not the new savings account number. How will the bank ensure that the participant will be able to find their account?

43 Date: Section: 2000 Topic: Record Retention Record Retention An agency operating an IDA program under the CT Department of Labor has to maintain records for a period of three years. The retention period starts from the date of submission of the final expenditure report. Records that must be maintained include: books, records, documents, program and individual service records and other evidence of accounting and billing procedures and practices which sufficiently reflect all direct and indirect costs of any nature in the performance of the contract. If any litigation or audit is begun or if a claim is instituted involving the contract, the records must be retained until the litigation, audit or chain has been finally resolved.

44 Date: Section: 2100 Topic: IDA Program Certification IDA Program Certification Agencies operating a CT DOL IDA programs are already certified. A community-based organization seeking certification of its existing or proposed IDA program (not part of the CT IDA Initiative) should submit its request and appropriate documentation to the Department of Labor. The State certification process applies to all existing IDA programs -- Federal, State and private programs. Certification is similar to a license that guarantees the program operates consistent with certain minimal quality standards. Ideally, such certification should make a program more competitive when applying for funds (public or private). Please note that programs are certified, not the agency that operates them. Therefore, each program within an agency would need to apply for separate certification. DOL implemented the certification process and published the application process on our web site ( A CBO seeking certification of its existing or proposed IDA program needs to submit its request to DOL. The Department will review each request for certification and notify the community-based organization whether the organization s request for certification has been approved or disapproved.

45 Appendix A

46 % HUD Area Annual Median Income based on a Family Size of Town Andover $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Ansonia $52,360 $59,840 $67,320 $74,800 $80,784 $86,768 $92,752 $98,736 $104,720 $110,704 Ashford $40,264 $46,016 $51,768 $57,520 $62,122 $66,723 $71,325 $75,926 $80,528 $85,130 Avon $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Barkhamsted $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 Beacon Falls $52,360 $59,840 $67,320 $74,800 $80,784 $86,768 $92,752 $98,736 $104,720 $110,704 Berlin $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Bethany $46,704 $53,376 $60,048 $66,720 $72,058 $77,395 $82,733 $88,070 $93,408 $98,746 Bethel $62,944 $71,936 $80,928 $89,920 $97,114 $104,307 $111,501 $118,694 $125,888 $133,082 Bethlehem $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 Bloomfield $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Bolton $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Bozrah $48,776 $55,744 $62,712 $69,680 $75,254 $80,829 $86,403 $91,978 $97,552 $103,126 Branford $46,704 $53,376 $60,048 $66,720 $72,058 $77,395 $82,733 $88,070 $93,408 $98,746 Bridgeport $49,840 $56,960 $64,080 $71,200 $76,896 $82,592 $88,288 $93,984 $99,680 $105,376 Bridgewater $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 Bristol $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Brookfield $62,944 $71,936 $80,928 $89,920 $97,114 $104,307 $111,501 $118,694 $125,888 $133,082 Brooklyn $40,264 $46,016 $51,768 $57,520 $62,122 $66,723 $71,325 $75,926 $80,528 $85,130 Burlington $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Canaan $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 Canterbury $40,264 $46,016 $51,768 $57,520 $62,122 $66,723 $71,325 $75,926 $80,528 $85,130 Canton $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Chaplin $40,264 $46,016 $51,768 $57,520 $62,122 $66,723 $71,325 $75,926 $80,528 $85,130 Cheshire $46,704 $53,376 $60,048 $66,720 $72,058 $77,395 $82,733 $88,070 $93,408 $98,746 Chester $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Clinton $57,456 $65,664 $73,872 $82,080 $88,646 $95,213 $101,779 $108,346 $114,912 $121,478 Colchester $58,912 $67,328 $75,744 $84,160 $90,893 $97,626 $104,358 $111,091 $117,824 $124,557 Colebrook $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 Columbia $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Cornwall $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 Coventry $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Cromwell $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Danbury $62,944 $71,936 $80,928 $89,920 $97,114 $104,307 $111,501 $118,694 $125,888 $133,082 Darien $71,624 $81,856 $92,088 $102,320 $110,506 $118,691 $126,877 $135,062 $143,248 $151,434 Deep River $57,456 $65,664 $73,872 $82,080 $88,646 $95,213 $101,779 $108,346 $114,912 $121,478 Derby $52,360 $59,840 $67,320 $74,800 $80,784 $86,768 $92,752 $98,736 $104,720 $110,704 Durham $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 East Granby $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 East Haddam $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 East Hampton $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 East Hartford $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 East Haven $46,704 $53,376 $60,048 $66,720 $72,058 $77,395 $82,733 $88,070 $93,408 $98,746 East Lyme $48,776 $55,744 $62,712 $69,680 $75,254 $80,829 $86,403 $91,978 $97,552 $103,126 East Windsor $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Eastford $40,264 $46,016 $51,768 $57,520 $62,122 $66,723 $71,325 $75,926 $80,528 $85,130

47 Easton $49,840 $56,960 $64,080 $71,200 $76,896 $82,592 $88,288 $93,984 $99,680 $105,376 Ellington $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Enfield $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Essex $57,456 $65,664 $73,872 $82,080 $88,646 $95,213 $101,779 $108,346 $114,912 $121,478 Fairfield $49,840 $56,960 $64,080 $71,200 $76,896 $82,592 $88,288 $93,984 $99,680 $105,376 Farmington $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Franklin $48,776 $55,744 $62,712 $69,680 $75,254 $80,829 $86,403 $91,978 $97,552 $103,126 Glastonbury $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Goshen $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 Granby $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Greenwich $71,624 $81,856 $92,088 $102,320 $110,506 $118,691 $126,877 $135,062 $143,248 $151,434 Griswold $48,776 $55,744 $62,712 $69,680 $75,254 $80,829 $86,403 $91,978 $97,552 $103,126 Groton $48,776 $55,744 $62,712 $69,680 $75,254 $80,829 $86,403 $91,978 $97,552 $103,126 Guilford $46,704 $53,376 $60,048 $66,720 $72,058 $77,395 $82,733 $88,070 $93,408 $98,746 Haddam $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Hamden $46,704 $53,376 $60,048 $66,720 $72,058 $77,395 $82,733 $88,070 $93,408 $98,746 Hampton $40,264 $46,016 $51,768 $57,520 $62,122 $66,723 $71,325 $75,926 $80,528 $85,130 Hartford $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Hartland $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Harwinton $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 Hebron $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Kent $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 Killingly $40,264 $46,016 $51,768 $57,520 $62,122 $66,723 $71,325 $75,926 $80,528 $85,130 Killingworth $57,456 $65,664 $73,872 $82,080 $88,646 $95,213 $101,779 $108,346 $114,912 $121,478 Lebanon $58,912 $67,328 $75,744 $84,160 $90,893 $97,626 $104,358 $111,091 $117,824 $124,557 Ledyard $48,776 $55,744 $62,712 $69,680 $75,254 $80,829 $86,403 $91,978 $97,552 $103,126 Lisbon $48,776 $55,744 $62,712 $69,680 $75,254 $80,829 $86,403 $91,978 $97,552 $103,126 Litchfield $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 Lyme $48,776 $55,744 $62,712 $69,680 $75,254 $80,829 $86,403 $91,978 $97,552 $103,126 Madison $46,704 $53,376 $60,048 $66,720 $72,058 $77,395 $82,733 $88,070 $93,408 $98,746 Manchester $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Mansfield $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Marlborough $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Meriden $46,704 $53,376 $60,048 $66,720 $72,058 $77,395 $82,733 $88,070 $93,408 $98,746 Middlebury $37,632 $43,008 $48,384 $53,760 $58,061 $62,362 $66,662 $70,963 $75,264 $79,565 Middlefield $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Middletown $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Milford $52,360 $59,840 $67,320 $74,800 $80,784 $86,768 $92,752 $98,736 $104,720 $110,704 Monroe $49,840 $56,960 $64,080 $71,200 $76,896 $82,592 $88,288 $93,984 $99,680 $105,376 Montville $48,776 $55,744 $62,712 $69,680 $75,254 $80,829 $86,403 $91,978 $97,552 $103,126 Morris $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 Naugatuck $37,632 $43,008 $48,384 $53,760 $58,061 $62,362 $66,662 $70,963 $75,264 $79,565 New Britain $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 New Canaan $71,624 $81,856 $92,088 $102,320 $110,506 $118,691 $126,877 $135,062 $143,248 $151,434 New Fairfield $62,944 $71,936 $80,928 $89,920 $97,114 $104,307 $111,501 $118,694 $125,888 $133,082 New Hartford $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 New Haven $46,704 $53,376 $60,048 $66,720 $72,058 $77,395 $82,733 $88,070 $93,408 $98,746 New London $48,776 $55,744 $62,712 $69,680 $75,254 $80,829 $86,403 $91,978 $97,552 $103,126 New Milford $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 Newington $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600

48 Newtown $62,944 $71,936 $80,928 $89,920 $97,114 $104,307 $111,501 $118,694 $125,888 $133,082 Norfolk $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 North Branford $46,704 $53,376 $60,048 $66,720 $72,058 $77,395 $82,733 $88,070 $93,408 $98,746 North Canaan $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 North Haven $46,704 $53,376 $60,048 $66,720 $72,058 $77,395 $82,733 $88,070 $93,408 $98,746 North Stonington $48,776 $55,744 $62,712 $69,680 $75,254 $80,829 $86,403 $91,978 $97,552 $103,126 Norwalk $71,624 $81,856 $92,088 $102,320 $110,506 $118,691 $126,877 $135,062 $143,248 $151,434 Norwich $48,776 $55,744 $62,712 $69,680 $75,254 $80,829 $86,403 $91,978 $97,552 $103,126 Old Lyme $48,776 $55,744 $62,712 $69,680 $75,254 $80,829 $86,403 $91,978 $97,552 $103,126 Old Saybrook $57,456 $65,664 $73,872 $82,080 $88,646 $95,213 $101,779 $108,346 $114,912 $121,478 Orange $46,704 $53,376 $60,048 $66,720 $72,058 $77,395 $82,733 $88,070 $93,408 $98,746 Oxford $52,360 $59,840 $67,320 $74,800 $80,784 $86,768 $92,752 $98,736 $104,720 $110,704 Plainfield $40,264 $46,016 $51,768 $57,520 $62,122 $66,723 $71,325 $75,926 $80,528 $85,130 Plainville $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Plymouth $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 Pomfret $40,264 $46,016 $51,768 $57,520 $62,122 $66,723 $71,325 $75,926 $80,528 $85,130 Portland $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Preston $48,776 $55,744 $62,712 $69,680 $75,254 $80,829 $86,403 $91,978 $97,552 $103,126 Prospect $37,632 $43,008 $48,384 $53,760 $58,061 $62,362 $66,662 $70,963 $75,264 $79,565 Putnam $40,264 $46,016 $51,768 $57,520 $62,122 $66,723 $71,325 $75,926 $80,528 $85,130 Redding $62,944 $71,936 $80,928 $89,920 $97,114 $104,307 $111,501 $118,694 $125,888 $133,082 Ridgefield $62,944 $71,936 $80,928 $89,920 $97,114 $104,307 $111,501 $118,694 $125,888 $133,082 Rocky Hill $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Roxbury $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 Salem $48,776 $55,744 $62,712 $69,680 $75,254 $80,829 $86,403 $91,978 $97,552 $103,126 Salisbury $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 Scotland $40,264 $46,016 $51,768 $57,520 $62,122 $66,723 $71,325 $75,926 $80,528 $85,130 Seymour $52,360 $59,840 $67,320 $74,800 $80,784 $86,768 $92,752 $98,736 $104,720 $110,704 Sharon $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 Shelton $49,840 $56,960 $64,080 $71,200 $76,896 $82,592 $88,288 $93,984 $99,680 $105,376 Sherman $62,944 $71,936 $80,928 $89,920 $97,114 $104,307 $111,501 $118,694 $125,888 $133,082 Simsbury $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Somers $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 South Windsor $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Southbury $37,632 $43,008 $48,384 $53,760 $58,061 $62,362 $66,662 $70,963 $75,264 $79,565 Southington $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Sprague $48,776 $55,744 $62,712 $69,680 $75,254 $80,829 $86,403 $91,978 $97,552 $103,126 Stafford $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Stamford $71,624 $81,856 $92,088 $102,320 $110,506 $118,691 $126,877 $135,062 $143,248 $151,434 Sterling $40,264 $46,016 $51,768 $57,520 $62,122 $66,723 $71,325 $75,926 $80,528 $85,130 Stonington $48,776 $55,744 $62,712 $69,680 $75,254 $80,829 $86,403 $91,978 $97,552 $103,126 Stratford $49,840 $56,960 $64,080 $71,200 $76,896 $82,592 $88,288 $93,984 $99,680 $105,376 Suffield $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Thomaston $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 Thompson $40,264 $46,016 $51,768 $57,520 $62,122 $66,723 $71,325 $75,926 $80,528 $85,130 Tolland $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Torrington $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 Trumbull $49,840 $56,960 $64,080 $71,200 $76,896 $82,592 $88,288 $93,984 $99,680 $105,376 Union $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Vernon $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600

49 Voluntown $48,776 $55,744 $62,712 $69,680 $75,254 $80,829 $86,403 $91,978 $97,552 $103,126 Wallingford $46,704 $53,376 $60,048 $66,720 $72,058 $77,395 $82,733 $88,070 $93,408 $98,746 Warren $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 Washington $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 Waterbury $37,632 $43,008 $48,384 $53,760 $58,061 $62,362 $66,662 $70,963 $75,264 $79,565 Waterford $48,776 $55,744 $62,712 $69,680 $75,254 $80,829 $86,403 $91,978 $97,552 $103,126 Watertown $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 West Hartford $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 West Haven $46,704 $53,376 $60,048 $66,720 $72,058 $77,395 $82,733 $88,070 $93,408 $98,746 Westbrook $57,456 $65,664 $73,872 $82,080 $88,646 $95,213 $101,779 $108,346 $114,912 $121,478 Weston $71,624 $81,856 $92,088 $102,320 $110,506 $118,691 $126,877 $135,062 $143,248 $151,434 Westport $71,624 $81,856 $92,088 $102,320 $110,506 $118,691 $126,877 $135,062 $143,248 $151,434 Wethersfield $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Willington $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Wilton $71,624 $81,856 $92,088 $102,320 $110,506 $118,691 $126,877 $135,062 $143,248 $151,434 Winchester $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 Windham $40,264 $46,016 $51,768 $57,520 $62,122 $66,723 $71,325 $75,926 $80,528 $85,130 Windsor $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Windsor Locks $49,000 $56,000 $63,000 $70,000 $75,600 $81,200 $86,800 $92,400 $98,000 $103,600 Wolcott $37,632 $43,008 $48,384 $53,760 $58,061 $62,362 $66,662 $70,963 $75,264 $79,565 Woodbridge $46,704 $53,376 $60,048 $66,720 $72,058 $77,395 $82,733 $88,070 $93,408 $98,746 Woodbury $48,720 $55,680 $62,640 $69,600 $75,168 $80,736 $86,304 $91,872 $97,440 $103,008 Woodstock $40,264 $46,016 $51,768 $57,520 $62,122 $66,723 $71,325 $75,926 $80,528 $85,130

50 Appendix B

51 2015 Poverty Guidelines The following figures are the 2015 HHS poverty guidelines which are scheduled to be published in the Federal Register on January 22, POVERTY GUIDELINES FOR THE 48 CONTIGUOUS STATES AND THE DISTRICT OF COLUMBIA Persons in family/household Poverty guideline 1 $11, , , , , , , ,890 For families/households with more than 8 persons, add $4,160 for each additional person. Source:

52 Appendix C

53 CTDOL Access Database Instructions ENTERING NEW CLIENTS 1. From the Main Menu, click the Add New Client button 2. Enter in as much information as possible on all of the tabs listed ( General Client Information, Registration Information, Demographics" and General Account. ) 3. The client will NOT be added unless the SSN is entered and the Savings Goal, Match Ratio, and Max Match are all entered. NEVER DELETE CLIENTS unless they were accidentally entered. EDITING CLIENT INFO 1. From the Main Menu screen, click on the client s name, change any information as required. ENTERING CLIENT ACCOUNT ACTIVITY Deposits/Interest (except Emergency Withdrawal Payback) 1. From the Main Menu screen, click on the client s name. 2. The General Client Information screen will come up. 3. Choose the year for which you want to input data from the Choose A Year of Account History drop down menu. (So if it is September 2012 and you want to record a December 2011 transaction, you would enter the year 2011.) 4. Click the View Account Data button. 5. Using the drop down menu, choose the month for which you will be entering data. 6. IMPORTANT you must record the Month of the transaction on the first screen ( Deposit/Interest ) in order to have that month appear in the other tabs. 7. After recording the Month in the Deposit/Interest tab you can switch tabs, if necessary. 8. Move to different columns by hitting the tab key or the arrows on your keyboard. NOTE: The system will not allow you to record a deposit of more that $500 in any single entry. If a lump sum deposit is greater than $500 it will need to be entered as more than one deposit. The deposit date should stay the same. (For example, if there was a $600 deposit in September, 2007, you would have to record it as two entries: $500 for September 2007 and another $100 also for September 2007.) Entering Emergency Withdrawal Payback Due to state laws which limit annual matching amounts, we use the following process to maximize the matching available to a client and apply current paybacks to prior years. 1. From the Deposit/Interest tab, choose the Emer Pay Back option in the drop down box (do NOT apply an Emergency Withdrawal Payback to a month). 2. Enter in the rest of the transaction as if it were a deposit

54 Asset Withdrawals When recording an asset purchase in the Assets Withdrawal tab, only enter the amount with- drawn from the participant s IDA in the Amount of Withdrawal from IDA for Asset Purchase column. Do not include the match amount; the database will automatically calculate it. Withdrawals (other than Asset Withdrawals and Emergency Withdrawals) To record a withdrawal for this purpose you need to enter it on the Deposit/Interest tab as a negative deposit. (For example, if a participant deposits $600 in one year [assuming a 2:1 match], you will need to have them withdraw $100. Enter -$100 in the Total $ Amount of Deposits column.) Emergency Withdrawals 1. Go to the Emergency Withdrawals tab and enter information. REMEMBER: The month has to be entered in the Deposits/Interest tab in order for it to appear in the Emergency Withdrawals tab. Exiting Clients 1. From the Main Menu click on the client s name, choose the Exit/Leave Info tab and complete the Exit information. 2. Participant accounts that are closed and exited must also have any remaining funds zeroed out from the account upon exit. A negative deposit will need to be entered to show the account as zero. Leave of Absence 1. From the Main Menu click on the client s name, choose the Exit/Leave Info tab and complete the Leave of Absence information. Erasing/Deleting a Transaction 1. Click the arrow to the left of the transaction line and hit the Delete key. or 2. You can just change the data in the line to $0. It won t delete the line but it will have the same result. 3. You may have to Close the screen and re-open it for the deletion to record properly. Data Entry DOL requests that each agency assign one person to do the data entry for the IDA Program, and that all data entry be done by this person. For technical assistance contact Marie Hawe (marie@cafca.org or (860) x2202).

55 Appendix D

56 CLOSEOUT TIMEFRAME: Grant Closeout Project Period: through Closeout Period must end by. FINAL REPORTS: Grantees must submit to CTDOL the following reports by : Final Financial Status Reports Financial Information: 1. The balance of the Local Reserve Fund at the beginning of this reporting period 2. The amount of Local Reserve Funds disbursed during this reporting period 3. The amount of Local Reserve Fund interest accrued during this reporting period 4. The amount of Administrative Funds disbursed during this reporting period 5. The balance of the Local Reserve Fund at the end of this reporting period (to be returned to CTDOL) 6. Copy of Local Reserve Fund bank statement this reporting period Amount Final Program Progress Reports 1. Major activities and accomplishments during this period: (Describe overall activity and project accomplishments.) 2. Problems: (Describe any deviations or departures from the original project plan including actual/anticipated slippage in task completion dates, and special problems encountered or expected.) 3. Significant findings and events: (Describe any major accomplishments, noteworthy events or best practices.) 4. Dissemination activities: (Describe project inquiries and information dissemination activities carried out over the reporting period. Itemize and include a copy of any newspaper, newsletter, magazine articles or other published materials considered relevant to project activities, or used for project information or public relations purposes.) 5. Other Activities: Grantees must submit to CTDOL the following database reports by :

57 Final Database Reports Remitting Project Grant Funds CAAs must liquidate all obligations incurred under the award by the end of the Closeout Period and remit to CTDOL any funds that remain unobligated. POST CLOSEOUT AUDIT CTDOL retains the right to disallow costs and recover funds on the basis of an audit or review conducted after the project Closeout. Any state funds paid to the recipient in excess of the amount to which the recipient is finally determined to be entitled under the Terms and Conditions of the award constitute a debt to the State government. If not paid within a reasonable period after the demand for payment, State may reduce the debt by: Taking action permitted by statute. The State will charge interest on any overdue debt in accordance with federal regulations. NOTICE OF FINAL CLOSEOUT AND RECORDS RETENTION In general, Grantee must retain all financial reports, supporting documents, statistical records, and all other records pertinent to an award for a period of three years from the date they submit the final Financial Status Report. (For nonprofit Grantee, see 45 C.F.R. Part For State, local, and Tribal government Grantee, see 45 C.F.R. Part ) IDA PROJECT CLOSEOUT CHECKLIST Closeout Activities / Milestones Prepare and submit the Final Financial Status Report. Prepare and submit the Final Program Progress Report. Prepare and submit all Project Database Reports. Remit grant funds remaining in the Reserve Account to CTDOL via check. Completed / Date

58 Appendix E

59 PILOT POLICY FOR TRANSFERRING PARTICIPANTS AMONG CONNECTICUT INDIVIDUAL DEVELOPMENT ACCOUNT (IDA) PROGRAMS Effective 6/5/2012 DEFINITIONS Grantee CT IDA Program Project Participant An organization that receives funding from the Connecticut Department of Labor to operate a CT IDA Program. An IDA Program supported by a grant from the CT Department of Labor. This can be either a CT IDA Initiative Program or a CT Housing Trust Fund (HTF) IDA Program. An individual who is enrolled in either a CT IDA Initiative Program or a CT Housing Trust Fund IDA Program. BACKGROUND On certain occasions, there may be a justification for moving an IDA participant from one Department of Labor Individual Development Account Program to another. This could be from one CTIDA Initiative Program to another CTIDA Initiative Program, from one CT Housing Trust Fund IDA Program to another CT Housing Trust Fund IDA Program, or between a CTIDA Initiative Program and a CT Housing Trust Fund IDA Program. Possible reasons for a transfer might be: To give a participant more time to save. To allow a participant to purchase an asset not allowed by the original program in which they were enrolled. To transfer a participant nearing completion of the program to an older existing grant with open slots so that a slot can be opened up in a newer grant. POLICY GUIDANCE NOTE: No grantee is allowed to transfer participants between IDA programs without first getting approval from the Connecticut Department of Labor (david.fernandes@ct.gov) The request for transfer must be sent to DOL in writing and must include: The reason for requesting the transfer (see above list of possible reasons) The name of the participant to be transferred The grants between which you are requesting to transfer the participant Amount of savings in the participant s IDA at the time of the transfer Amount of matching funds retained in the original Program s Reserve Account as a result of the transfer. Revision Date 5/14/15

60 With DOL permission, grantees may allow an eligible IDA participant to be transferred from one CT DOL IDA Program to another administered by that grantee without requiring the participant to re-enroll in financial literacy courses or other training, except for additional asset-specific training if the participant has changed his/her savings goal. Grantees may choose to require participants to attend additional training, if needed. A transferred participant may withdraw funds for allowable uses from an IDA started under the new CT IDA program after the participant has been enrolled (i.e. account opened) in either of the CT IDA Programs for at least a combined total of six months. Limitations: Every effort must be made to ensure the participant is initially screened and enrolled in the most appropriate IDA grant to maximize success and minimize the need to transfer the participant to another grant as a back-up strategy. The participant is in good standing with the IDA Program and is eligible for transfer. The participant is current with the financial literacy training requirements. The participant has a consistent record of saving according to the Savings Plan Agreement. The participant is abiding with other program requirements. (The grantee may establish specific criteria for determining when a participant is in good standing.) The participant has been enrolled (i.e. account opened) in either of the CT IDA Programs for at least a combined total of six months. The participant understands that he/she can only be transferred once. The participant has not withdrawn any funds for emergency expenses or for qualified purchases from his or her IDA. A participant may not be transferred after withdrawing funds. REQUIRED PROCEDURES A grantee must do the following when a participant is transferred from one IDA Program to another: 1) Retain matching funds that had been set aside for the participant in the original project s Reserve Account. 2) Allocate matching funds in the new project s Reserve Account for the transferred participant. (These funds must be available before the grantee may transfer a participant.) 3) Update participant Savings Plan Agreement (Grant, Savings Goal, etc.). 4) Record details of the transfer in both project files and program narratives for review by program officials, evaluators, auditors, and others: a) Date of the transfer; b) Participant s or grantee s reason for requesting the transfer; c) Amount of savings in the participant s IDA at the time of the transfer; d) Amount of matching funds retained in the original Program s Reserve Account as a result of the transfer. Revision Date 5/14/15

61 4) Record the transferred account as Transferred/Closed in the original project file. 5) Record the transferred account as Transferred/Opened in the new project file. 6) Report details about the transfer, as noted in #4 above, on the yearly Narrative Report of both the original and the new IDA Program. Revision Date 5/14/15

62 Appendix F

63 State of Connecticut Tumbleweed Secure for IDA data 1. You will be receiving an from David Fernandes indicating that a package from the sender (David) is on the Tumbleweed server and ready for pickup. You will need to click on Pick up Package. 2. You will be prompted for a password. If you have not signed onto the Tumbleweed server with this account before, you will need to create a password now. Click on log in. If you have forgotten your password, a reset can be done by contacting the BEST Helpdesk at BEST.Helpdesk@ct.gov.

64 3. The Secure is now displayed on the Tumbleweed server. In order to send your data through this secure format, click on Reply (and Reply All, when available) from this .

65 4. To attach your Exportqry.xls file to this secure , click on the Browse or Choose File button. Go to where you saved your Exportqry.xls file and select it by clicking on Open or Choose. If your file has the extension.mdb instead of.xls, you will not be able to send the file due to its size. You must convert the.mdb file to.xls before you can send it. To do that, go to step 5. If the extension ends in.xls, you may move to step 6.

66 5. Open the IDA database as you would normally do. When you click on the Send Data Export button in the database, you will have the opportunity to save the ExportQry file to a different location on your computer. (NOTE: Each time you save your Exportqry file, be sure to name it differently to prevent overwriting your file each time. When saving the file, the extension will be changed automatically to an.xls file.) Afterwards, click Okay to save the file and then continue with attaching your Exportqry.xls file to the Tumbleweed When the name of the file appears under Filename, click on the Add button. 7. Then click on the send button. This Secure Expires after 30 days and can be responded up to 5 times.