Per correspondence from the U.S. Treasury this week, cities that have not yet registered to file their required American Rescue Plan (ARP) report with the Treasury should wait for further guidance before doing so. The first deadline to file a report on the use of ARP funds for the 525 municipalities deemed “non-entitlement units” (NEUs) is Oct. 31. U.S. Treasury indicated this week that they would be publishing a user guide for the filing of that report in early October, and that all municipalities should wait and review that user guide before taking steps to register with the portal to file that report. For now, the best information on reporting is the U.S. Treasury’s previously published Compliance and Reporting Guidance.
As a reminder, while Oct. 31 is a reporting deadline, it is not an expenditure deadline. The Oct. 31 report filed can state that your municipality has not yet spent any of its ARP funds, so there is not any pressure to make ARP spending decisions by Oct. 31.