Maintaining public disclosure while eliminating duplicative reporting requirements will streamline the bureaucracy and eliminate the trigger for additional federal requirements on some SRF loans.
What is FFATA?
The Federal Funding Accountability and Transparency Act of 2006 established a single, searchable website for recipients of federal funding, www.USASpending.gov, to provide greater transparency on government spending.
Since 2010, federal law has required SRFs to report each loan funded by the annual federal capitalization grant into the FFATA database. Since 2014, each project entered into FFATA is required to comply with the entire suite of federal requirements. See EPA Memo.
What's the problem?
The reporting requirement is duplicative. SRFs are already required to report project information for all SRF loans into multiple other databases.
Projects entered into FFATA must comply with additional federal requirements, including:
Single Audit Act (2 CFR Part 200)
Environmental Crosscutters (federal requirements that "cut across" federal funding programs)
Disadvantaged Business Enterprise Procurement Process
Federal Architectural and Engineering Procurement Process
Public Awareness Enhancement (Signage)
FFATA Executive Compensation Reporting
Selecting certain projects for FFATA and then requiring those projects to comply with the whole suite of additional federal requirements creates disparity among loan recipients, with some loan applicants bearing a greater burden of compliance.
What's the solution?
Allowing SRFs to report the capitalization grant, instead of every loan funded by the grant, into FFATA will reduce the duplicative reporting.
Removing the trigger for additional federal requirements will provide SRFs with greater flexibility to select projects to meet equivalency requirements, which was the process prior to 2015.