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

The Connecticut Individual Development Account Initiative and

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Page 1: The Connecticut Individual Development Account Initiative and

The ConnecticutIndividual DevelopmentAccount Initiative and

Housing Trust Fund

Technical PolicyManual

Page 2: The Connecticut Individual Development Account Initiative and

Date: 08-26-2013 13-02 Section: 1000Topic: Table of Contents and Appendices

Table of Contents

1000 Table of Contents1010 Introduction1020 Mission, Goals, Objectives1030 Authority and Purpose1040 Definitions

1100 Program Eligibility1110 Household Income Determination1120 Earned Income Documentation1130 SSI, SSDI and PASS Plans1140 Geographic Area

1200 Repeat Individual Development Account Participant

1300 IDA Training for Participants - Financial Education, Asset Specific Trainingand Monthly Savings Clubs

1400 Six Month Enrollment Requirement

1500 Personally Identifiable Information (PII)

1600 Lump Sum Deposits

1700 Allowable Asset Purchases1705 Using IDA Funds to Reconstruct a Home1710 Mobile (Manufactured) Homes1715 IRS Ruling on IDA Homebuyer Assistance Programs1720 Home Asset Purchase with a Person who is Not an IDA Participant1725 Small Business Capitalization1730 Education - On-line Courses1735 Education - Computer Purchase1740 Education - Spouse, Sibling1745 Education - Prepaying Tuition1750 Education - Multiple Education Asset Purchases1755 Education - 529 Plans1760 Lease Deposit for a Primary Residence1765 Purchase of Vehicle for Employment1770 Pre-Owned Vehicles1775 Purchase of a Replacement Vehicle

Page 3: The Connecticut Individual Development Account Initiative and

DEPARTMENT OF LABORINDIVIDUAL DEVELOPMENT ACCOUNT PROGRAM

TECHNICAL POLICY MANUAL

Date: 05-29-2015 15-03 Section: 1000Topic: Table of Contents and Appendices

Table of Contents continued

1800 Local Reserve Fund1800 Interest Earned1810 Co-Mingling of IDA Matching Funds

1900 Unclaimed Property Procedures

2000 Record Retention

2100 IDA Program Certification

Appendices

A) 80% Area Median Income Chart - 2015B) Federal Poverty Guidelines - 2015C) Access Database InstructionsD) Grant Closeout - 2012E) Pilot Policy for Transferring Participants Among Connecticut Individual

Development Account (IDA) Programs – 6/5/2012F) Tumbleweed Secure Email Desk Aid

Page 4: The Connecticut Individual Development Account Initiative and

DEPARTMENT OF LABORINDIVIDUAL DEVELOPMENT ACCOUNT PROGRAM

TECHNICAL POLICY MANUAL

Date: 08-01-2012 12-01 Section: 1010Topic: Introduction

Introduction

This technical policy manual provides guidance to the Individual Development Account(IDA) program operators awarded grants by the Connecticut Department of Labor (CTDOL). It was developed by the CT DOL and the Clearinghouse liaison in response totechnical questions generated from program operation and the answers to those questions.

Although other programs such as the federal Assets for Independence Act (AFIA) arereferenced in this manual, the policy and procedures in this manual are limited to theConnecticut Individual Development Account programs.

This manual supplements, but does not replace, the Connecticut Individual DevelopmentAccount Initiative Policies and Procedures Manual. However, due to the evolving natureof the IDA program, the need for additional policies or modifications to existing policieswill occur. As these additions or modifications occur, this manual will be revised. Thismanual contains the most recent guidance on IDA policies.

Page 5: The Connecticut Individual Development Account Initiative and

DEPARTMENT OF LABORINDIVIDUAL DEVELOPMENT ACCOUNT PROGRAM

TECHNICAL POLICY MANUAL

Date: 08-01-2012 12-01 Section: 1020Topic: Mission, Goals, Objectives

Mission

The Connecticut IDA Initiative intends to strengthen families and communities byfacilitating self-sufficiency and economic stability through financial education and assetdevelopment.

Goals

1. To invest in communities by providing opportunities for community-basedorganizations to offer financial education and matched savings accounts as assetdevelopment tools for low-income and moderate-income families.

2. To invest in low-income and moderate-income families by providing grants forcommunity-based organizations to prepare and assist families to purchase andmaintain assets through six qualified purchases: Education or job training; Homeownership; Small business capitalization; Lease deposit on a primary residence;Vehicle purchase to obtain or maintain employment; Education or job training for adependent 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 moderate-

income 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 effectiveway.

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.

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DEPARTMENT OF LABORINDIVIDUAL DEVELOPMENT ACCOUNT PROGRAM

TECHNICAL POLICY MANUAL

Date: 08-01-2012 12-01 Section: 1030Topic: Authority and Purpose

Authority and Purpose

Pursuant to State of Connecticut Public Act No. 00-192, CT DOL shall serve as the stateadministrator of the Connecticut Individual Development Account Initiative(“Connecticut IDA Initiative”). The purpose of the Connecticut IDA Initiative is toprovide eligible individuals with opportunities to establish individual developmentaccounts for matched earned income savings, through “Certified State IDA Programs.”The Connecticut IDA Initiative is subject to applicable Federal, State or local governmentlaws and regulations concerning the establishment, administration and delivery of IDAprograms; including but not necessarily limited to banking practices and standards, andapplicable US Public Law 105-285 Title IV, Assets for Independence Act requirementsand standards.

CT DOL implemented the Connecticut IDA Initiative through adoption of IDAregulations and competitive procurement of Certified State IDA Programs for local areas.CT DOL established and administers a non-lapsing, Central Individual DevelopmentAccount Reserve Fund (IDA Reserve Fund) for the Initiative; and an IDA Clearinghousefor information on Certified State IDA Program funding, establishment, localadministration 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 ofa household located in Connecticut, have earned income, and whose adjusted grossincome does not exceed 80% of the Area Median Income as derived for Connecticuttowns by CT DOL per USDHUD Area Median Income figures and formulas. The earnedincome requirement does not apply to Qualified Disabled Individuals. Program operatorsmust make every good effort to ensure that at least 30% of the IDA accountholders in anystate-funded Certified IDA Program have earned income at or below 200% of the FederalPoverty 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 InternalRevenue Code of 1986 or any subsequent corresponding IRS code of the U.S asamended. CT DOL has the discretion to adopt additional eligibility criteria for CertifiedState IDA program bidders/providers through IDA regulations.

CT DOL adopted regulations for the Connecticut IDA Initiative in concert with theOffice of the Treasurer (OTT). CT DOL releases Request for Proposals (RFP) to solicit,review, accept, or reject proposals from community-based organizations seeking tooperate “Certified” State IDA programs on a not-for-profit basis. The regulations adoptedby CT DOL contain the processes and requirements for: the competitive procurement

Date: 08-01-2012 12-01 Section: 1030

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Topic: Authority and Purpose

Authority and Purpose continued

process; the establishment of IDA reserve funds; the establishment of the IDAClearinghouse; the criteria for “certification” of IDA Programs; and other aspects of theConnecticut IDA Initiative, pursuant to CT PA 00-192 Section 9.

Amounts appropriated by the State for the Connecticut IDA Initiative will be deposited inthe Central IDA Reserve Fund administered by CT DOL. The Central IDA Reserve Fundwill hold grants, donations, contributions, and other sources of revenue received for theIDA Initiative.

CT DOL uses amounts from the Central IDA Reserve Fund for the following: to providegrants to CBOs to operate Certified State IDA Programs; to assist organizations toprovide training, counseling, and case management for program participants; and forprogram administration purposes at the state and local levels. CT DOL will provide grantfunds for the preceding purposes from the CT DOL Central IDA Reserve Fund fordeposit into local reserve funds established and managed by the CBOs that are awardedgrants by CT DOL to provide local Certified IDA Program services. CBOs will establishand maintain local reserve funds, trust or custodial accounts for participants’ IDAs, andparallel accounts for individual matching contributions through partnering agreementswith insured financial institutions.

Certified State IDA Programs provide IDA services that include but are not necessarilylimited to the following: outreach; uniform application procedures and approved SavingsPlan development; case management and financial counseling; financial educationtraining; training and counseling specific to the approved expenses for which IDAparticipants are saving; crisis intervention services to prevent premature or emergencywithdrawals of IDA savings; and follow-up after approved expense purchase.

CT DOL monitors and evaluates Certified State IDA Programs established through CTDOL contracts to ensure ongoing compliance, to track performance, and to measure theextent to which asset-based policy affects civic, social, and economic improvement andstability for families and communities.

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Date: 08-01-2012 12-01 Section: 1040Topic: 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 withrespect to any taxable year, as determined for federal income tax purposes and asproperly reported on such person's federal income tax return.

Approved Plan means a plan (Savings Plan Agreement) prepared jointly by the accountholder and the community-based organization that defines savings goals, programrequirements and permissible uses of the individual development account and itsmatching funds pursuant to sections 31-51xx to 31-51aaa, inclusive, and regulationsadopted pursuant to section 31-51ddd. The approved plan shall be a contract between theaccount holder and the community-based organization.

Area Median Income (AMI) means area median household income as determined fromtime to time by the United States Department of Housing and Urban Development.

Calendar Year means January to December (regardless of enrollment date, initial deposit date or contract date).

Certified State IDA Program means a program of matched savings accounts that has beencertified by the department in accordance with regulations adopted pursuant to section31-51ddd.

Clearinghouse means a service to provide organizations interested in establishing, orwhich have established, individual development account programs with literature onfederal, state and other sources of funding, guidelines for best practices and programstandards, and information regarding the establishment and maintenance of certified stateIDA programs.

Community-Based Organization means an organization exempt from taxation pursuant tosection 501(c)(3) of the Internal Revenue Code of 1986 or any subsequent correspondinginternal revenue code of the United States, as from time to time amended, which meetsthe 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, orlegal ward who, at the commencement of the account holder’s participation in a certifiedstate IDA program is: (a) under twenty-one (21) years of age and wholly or mainly

Date: 08-01-2012 12-01 Section: 1040

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Topic: Definitions

Definitions continued

supported by the account holder; or (b) mentally or physically impaired and, because ofsuch 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, earningsfrom 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 institutionor specialized college or school legally authorized to grant degrees, or (B) any relatededucational program approved by the community-based organization and the department.

Vocational-technical education - The Perkins Act defines vocational-technicaleducation as organized educational programs offering sequences of coursesdirectly related to preparing individuals for paid or unpaid employment in currentor emerging occupations requiring other than a baccalaureate or advanced degree.Programs include competency-based applied learning which contributes to anindividual's academic knowledge, higher-order reasoning, problem solving skills,and the occupational-specific skills necessary for economic independence as aproductive and contributing member of society. For more information on the CarlD. Perkins Act, go to: http://www2.ed.gov/offices/OVAE/CTE/perkins.html

Emergency Withdrawal means a withdrawal, by an account holder from those fundsdeposited by the account holder in his/her individual development account, due to apersonal crisis, including but not limited to, illness, eviction, potential foreclosure, jobloss or urgent family reasons.

Entrepreneurial Activity means the purchase of or investment in a small business, asdefined in subsection (a) of section 4-168a, in Connecticut in which, upon such purchaseor investment, the account holder will be a principal.

Small Business ((a) of section 4-168a) - means a business entity, including itsaffiliates, that (A) is independently owned and operated and (B) employs fewerthan seventy-five full-time employees or has gross annual sales of less than fivemillion dollars, provided that an agency, in adopting regulations in accordancewith the provisions of this chapter, may define small business to include a greaternumber of full-time employees, not to exceed applicable federal standards or fivehundred, whichever is less, if necessary to meet the needs and address specificproblems of small businesses.

Date: 08-01-2012 12-01 Section: 1040Topic: Definitions

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Definitions continued

Federal Poverty Level (FPL) means the most recent poverty income guidelines publishedby 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, federalcredit union or an out-of-state bank that maintains in this state a branch as definedin 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 atwhich fiduciary or trust powers are exercised.

Household means all individuals who share use of a dwelling unit as primary quarters forliving and eating separate from other individuals. (Federal Assets for Independence Act,P.L. 105-23)

Individual Development Account (IDA) means a savings account, maintained in aprogram that is established pursuant to section 31-51xx that is held in a financialinstitution, for the sole purpose of holding the funds of the account holder for one of thepurposes described in subsection (a) of section 31-51xx.

Individual Development Account Reserve Fund means a non-lapsing fund administeredby the department for the purposes of providing matching funds for individualdevelopment accounts in certified state IDA programs, and for funding costs incurred bycommunity-based organizations in the operation and administration of such programs andthe department's administrative costs for the Connecticut IDA Initiative.

Job Training means a program for job entrance or skill development approved by thecommunity-based organization and the department.

Qualified Disabled Individual means a disabled individual eligible for assistance to thedisabled pursuant to chapter 319mm.

Persons With Disabilities (Chapter 319mm) shall mean persons having disabilitieswhich (1) are attributable to a mental or physical impairment or a combination ofmental and physical impairments; (2) are likely to continue indefinitely; (3) resultin functional limitations in one or more of the following areas of major life

Date: 08-01-2012 12-01 Section: 1040Topic: Definitions

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Definitions continued

activity: Self care, receptive and expressive language, learning, mobility, self-direction, 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 lifelongor 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 Chapter319mm of the Connecticut General Statutes; or

The individual provides confirmation by any other agency deemedcomparable by DOL of the individual’s disability.

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Date: 08-01-2012 12-01 Section: 1100Topic: 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 isnot in excess of eighty per cent of the area median income for the area in which theindividual resides and shall:

(1) have earned income; or

(2) be a qualified disabled individual as defined by the Regulations of ConnecticutState Agencies.

Page 13: The Connecticut Individual Development Account Initiative and

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Date: 08-01-2012 12-01 Section: 1110Topic: 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 unionfunds, worker’s compensation, veteran’s payments, public assistance (includingTANF, SSI and SSDI), training stipends, alimony, child support, and militaryfamily allotments.

Private pensions, government employee pensions (including military retirementpay), regular insurance or annuity payments.

Dividends, interest, net rental income, net royalties, periodic receipts from estatesor 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 ofwages, and federal non-cash benefit programs such as Medicare, Medicaid, foodstamps, school lunches, housing and other emergency assistance.

Any portion of Social Security benefits deducted to pay Medicare premiums thatwill not be reimbursed.

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Date: 08-01-2012 12-01 Section: 1120Topic: 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 isnot in excess of eighty per cent of the area median income for the area in which theindividual 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 creditreport 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. Thefollowing 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

Page 15: The Connecticut Individual Development Account Initiative and

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Date: 08-01-2012 12-01 Section: 1130Topic: 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 bythe Social Security Administration (SSA). It pays a cash benefit to individuals who areaged, blind, or have disabilities and who have limited income and assets.

Social Security Disability Insurance (SSDI) is a federally-funded benefits program thatprovides aid to people who are unable to achieve gainful employment due to a permanentdisabling 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 aPASS plan is currently the only way a person receiving SSI can participate in an IDAwithout reaching the asset limits.

Since issues of SSI/SSDI and asset limits are complicated and can change, be sure tocontact the Connect to Work Benefits Specialist (800-773-4636) and/or the SocialSecurity Administration in your area for assistance to avoid conflicts that could adverselyimpact an individual’s benefits.

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Date: 08-01-2012 12-01 Section: 1140Topic: Geographic Area

Geographic Area

An individual living in a city/town that has an existing IDA program that does not haveany openings can be referred to an IDA program outside his/her geographic area if thatIDA program has openings.

On rare occasions, an individual might live in one town and work in another, and it wouldbe more convenient for him/her to join an IDA program near where they work. This canbe permitted, after consultation with DOL and with the program operator in the townwhere the participant lives.

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Date: 08-01-2012 12-01 Section: 1200Topic: 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 participanthas left a CT IDA program, either because they have successfully purchased an asset orbecause they have been terminated from the program because of other reasons, theycannot be admitted as a participant to another CT IDA program. There are so few IDAslots available in the state and so many people who could benefit from an IDA, it istherefore not allowable to re-enroll or enroll a CT IDA participant in multiple CT IDAprograms.

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Date: 08-01-2012 12-01 Section: 1300Topic: IDA Training for Participants - Financial Education, Asset Specific Training andMonthly Savings Clubs

IDA Training for Participants -- Financial Education, Asset Specific Training andMonthly 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 issaving for. The training can be performed during monthly Savings Club meetingsor referrals to training offered by another agency or group (e.g., first-timehomeownership training given by a local housing counseling agency). If aparticipant attends asset-specific training outside your agency, they are excusedfrom the monthly Savings Club meetings for the month(s) that they are attendingthe training.

Monthly Savings Clubs - Each program should have a meeting once a month fortheir participants. Savings Clubs should be held at least 10 months during theyear (some programs skip December and one month in the summer). Participantsare required to attend at least 70% of the monthly meetings. Monthly SavingsClubs can cover a variety of topics: Asset-specific training, work-related issues,parenting, or other issues of concern to participants. (NOTE: If you have aspeaker presenting on a particular asset at a meeting, your participants who aresaving for a different asset should still be required to attend.)

For more information, please see the section on Asset-Specific Training/Savings Clubs inthe IDA Policies and Procedures Manual.

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Date: 08-01-2012 12-01 Section: 1400Topic: Six Month Enrollment Requirement

Six Month Enrollment Requirement

The CT IDA program shall ensure that no earlier than six months after the initial depositby an account holder into an IDA, funds may be withdrawn for qualified expenses forpurchase of an allowable asset, provided that the account holder has reached his/hersavings goal and met all program requirements. Therefore, participants must be enrolledin the program for six months before taking a matched withdrawal.

Individuals eligible for the IDA program often find themselves in low-income situationsfor a variety of reasons including a history of poor money management choices. IDAinitiatives encourage programs to target economically-disadvantaged individuals. Thisemphasis, coupled with the allowable savings goals, makes it unlikely that low-incomeindividuals would realize an appropriate and desirable savings objective in less than sixmonths. The purpose of this provision is to encourage accountholders to plan long-termand discourage impulse purchases. Participants who remain in the program longer thansix months and who save regularly, work to repair their credit and develop a savingshabit, are more likely to be successful.

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Date: 08-26-2013 13-02 Section: 1500Topic: Personally Identifiable Information (PII)

Personally Identifiable Information (PII)

The Connecticut Department of Labor requires all IDA program operators to protect theconfidentiality 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’sidentity, either alone or when combined with other personal or identifying informationthat is linked or can be linked to a specific individual. See OMP Memorandum M-07-17,dated 5/22/07, for more information:http://www.whitehouse.gov/sites/default/files/omb/memorandum/fy2007/m07-16.pdf

There are two types of PII:

Protected PII: This is information that, if disclosed, could result in harm to theindividual whose name or identity is linked to that information (e.g., Social Securitynumbers, credit card and bank account numbers, home addresses, home telephonenumbers, ages, birthdates, marital status, spouses’ names, educational history, biometrics(fingerprints, voice prints, etc.) medical history, financial information, computerpasswords, etc.).

Non-Protected PII: This is information that if disclosed, by itself, could not reasonablybe expected to result in personal harm (e.g., first and last names, e-mail addresses,business addresses, business telephone numbers, general education credentials, gender,race, etc.). However, depending on the circumstances, a combination of several items ofNon-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, remoteterminal, 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 therequirements governing Protected PII and/or improperly use or disclose PII for anunauthorized purpose.

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Date: 08-26-2013 13-02 Section: 1500Topic: Personally Identifiable Information (PII)

Personally Identifiable Information (PII) continued

Failure to comply with the requirements may result in one or more of the followingconsequences:

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

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Date: 08-26-2013 13-02 Section: 1600Topic: 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 thingstake time. A regular deposit of earned income into an IDA account on a monthly basis inaccordance 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 aparticipant’s EITC refund. The Department does not endorse (or allow) the practice ofannual 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 incompliance with their monthly savings goal as agreed to in their Savings PlanAgreement.

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Date: 08-01-2012 12-01 Section: 1700Topic: Allowable Asset Purchases

Allowable Asset Purchases

The CT IDA initiative provides an eligible individual with an opportunity, through acertified state IDA program, to establish an individual development account from whichfunds may be used by the account holder for one of the following purposes as specified inthe approved savings plan:

(1) The costs of education or job training:

(A) Education costs for an account holder are all costs which are necessaryfor 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 arenecessary for the enrollment and successful completion of a job trainingprogram, including but not limited to tuition, fees, books, supplies andequipment.

(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 areapurchase price applicable to such residence, and may include but not be limited tothe costs of acquiring, constructing, or reconstructing a residence, including anyusual or reasonable settlement, financing, or other closing costs.

(3) The participation in or development of a new or existing entrepreneurialactivity for which a business plan has been developed with the direct or indirectassistance of the community-based organization.

(4) The purchase of an automobile for the purpose of obtaining or maintainingemployment.

(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 accountholder.

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Date: 08-01-2012 12-01 Section: 1705Topic: 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 orreconstructing a residence (not for renovation of an existing home). Reconstructionrefers to very serious repairs on the house and not refurbishment or renovations of anykind. The law is interpreted to mean that participants may use their IDA savings andmatch to do any fix-up that is needed to make a participant's newly-purchased homelivable, (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 afterthe 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, apayment to make the home livable at (or near) the time of purchase. A good rule ofthumb is that if the building inspection raises an issue concerning a repair that needs to bedone, then that would be allowed under the definition of "reconstruction.” IDA programoperators are required to discuss a participant's request to use IDA savings and matchingfunds for reconstruction with CT DOL before approving funds to be used in this way. CTDOL always recommends spending IDA funds on costs that are clearly allowable, suchas down payment or closing costs.

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Date: 08-01-2012 12-01 Section: 1710Topic: Mobile (Manufactured) Homes

Mobile (Manufactured) Homes

The following items need to be taken into consideration if an IDA participant wants topurchase 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 usegood judgment when counseling AFI IDA project participants. It is anticipated thatgrantees will help their participants make wise investment choices – for example, topurchase a home that is in good shape, that will serve their needs, and that is likely toappreciate in value. Asset counseling needs to compare a new mobile home purchasewith a comparable home, showing appreciation vs. depreciation over time. AFI stronglydiscourages grantees from counseling their participants to purchase a low-quality home,whether it is “manufactured” or other. Many lenders will NOT finance a used mobilehome or a home in a park. AFI discourages the purchase of a home that is notpermanently affixed to land that the participant owns. This holds true for the CT IDAProgram.

For IDA programs in rural areas, most IDA homebuyers will be eligible for USDA RuralDevelopment (RD) subsidized mortgages. However, RD will only finance new mobilehomes permanently affixed to owned land. Mobile home financing can sometimes bepredatory and is often subprime, so asset counselors also need to talk with buyers aboutwhat predatory lending is, what to look for, and what to avoid. IDA participants shouldbe strongly encouraged to opt for a stick built or modular home.

The CFED website provides useful information on manufactured homes:http://cfed.org/programs/idas/

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Date: 08-01-2012 12-01 Section: 1715Topic: IRS Ruling on IDA Homebuyer Assistance Programs

The IRS Ruling 2006-27 on IDA Homebuyer Assistance Programs

First, the ruling finds that most traditional IDA homebuyer assistance programs (as wellas certain builders and developers of low-income housing also offering down paymentassistance) qualify as 501(c)(3) tax-exempt. Second, the ruling holds that organizationsmerely passing through seller-financed purchase assistance to buyers do not qualify as501(c)(3) tax-exempt. Finally, the ruling also finds that traditional IDA down paymentassistance funds qualify as gifts under IRC section 102 and as cost basis in the homeunder section 1012. The IRS ruling: http://www.irs.gov/pub/irs-drop/rr-06-27.pdf

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Date: 08-01-2012 12-01 Section: 1720Topic: 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 theco-owner. This is allowable; however, the sustainability of the purchase for the IDAparticipant is the primary concern for the integrity of the IDA program. Therefore, thefollowing procedure must be followed:

Ensure that the non-IDA participant attends financial education classes and asset-specific classes with the IDA participant.

Inform the bank/mortgage company and attorney that the individuals are notrelated 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 ofthe mortgage payment.

Call the CT DOL technical assistance provider for assistance with this and otherunusual circumstances.

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Date: 08-01-2012 12-01 Section: 1725Topic: Small Business Capitalization

Small Business Capitalization

After the participant has met the requirements of the program (including asset-specifictraining and the development of a business plan, preferably with the assistance of amicro-enterprise development program) the program operator can deposit theparticipant's IDA funds and matching funds into a business capitalization account. Thisallows the participant to use those funds for initial start-up, for costs related tolicensing/LLC set-up, to purchase equipment, and for other costs related to the set-up andoperation of his/her business.

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Date: 08-01-2012 12-01 Section: 1730Topic: Education - On-line Courses

On-line Courses

Paying for on-line courses with an IDA is allowable, provided the educational institutionmeets the qualifications for an eligible post-secondary educational institution as definedin the IDA regulations. The same requirements apply as for any traditional assetpurchase for post-secondary education. Funds can be used for tuition, books and otherfees, provided the check from the IDA and matching funds is made out to the educationalinstitution.

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Date: 08-01-2012 12-01 Section: 1735Topic: Education - Computer Purchase

Computer Purchase

Grantees may allow participants to purchase supplies and equipment required by aschool, however, the IDA funds can only be used for expenses paid directly to an eligibleeducational institution.

If the school sells computers or can special order computers through its campusbookstore, then your participant could use his/her IDA savings to make that purchase. Ifthe school’s bookstore does not sell computers, research whether some other departmentin the school sells computers or works through a computer vendor (or other supplier). Ifthe school has a special vendor agreement to buy its own equipment, perhaps it will allowthe student to order a computer through that agreement. If none of these options areavailable, there may be other eligible educational institutions in the area that do sellcomputers. If so, explore whether the participant could purchase the equipment from thatschool.

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Date: 08-01-2012 12-01 Section: 1740Topic: Education - Spouse, Sibling

Education for Spouse

The CT IDA Program does not allow an account holder to pay for the education of theirspouse. According to the Connecticut IDA regulations, “education costs for an accountholder” or “educational costs for a dependent child of an account holder” are allowableassets. If an account holder’s spouse wants to pursue education through the CT IDAprogram, 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 theeducational costs of a dependent child. In no case can IDA funds be used for a sibling'seducation.

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Date: 08-01-2012 12-01 Section: 1745Topic: Education - Prepaying Tuition

Prepaying Tuition

It is important for program operators to work with education institutions on the processfor returning any prepaid funds to the IDA Project if the participant prepays but laterdecides not to attend that institution. In any event, IDA funds must be expended beforethe end of the Project period and may not be returned to the grantee or participant afterthe close of the Project.

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Date: 08-26-2013 13-02 Section: 1750Topic: Education - Multiple Education Asset Purchases

Multiple Education Asset Purchases

An IDA participant can take multiple matched withdrawals to pay for on-goingeducational expenses (i.e. tuition, fees, books, supplies and equipment).

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Date: 08-01-2012 12-01 Section: 1755Topic: Education - 529 Plans

529 Plans

A 529 Plan is a tax-advantaged investment plan designed to encourage saving for thefuture higher education expenses of a designated beneficiary (in this case, the dependentchild of an IDA account holder). The Plans are named after Section 529 of the InternalRevenue Code and are administered by state agencies and organizations.

529s were designed to help families contribute funds for future college costs by offeringspecial tax benefits to Plan participants. Any earnings are federally tax deferred and ifused 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 theirplan. The following website www.collegesavings.org, provides each state’s 529 plan byfeatures (such as state tax benefits, fees, etc.).

Often, the home state’s 529 Plan has advantages for in-state residents. In Connecticut the529 Plan is called the Connecticut Higher Education Trust (CHET). Connecticutresidents who enroll in CHET may claim a Connecticut state income tax deduction fortheir contributions to the Plan. To find more information about CHET go to:www.aboutchet.org.

Asset Specific Training:

There is important information that must be shared with IDA participants who are savingfor 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 www.collegesavings.org andwww.aboutchet.org. Questions about CHET can be answered by calling the toll freenumber: (888)799-CHET.

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Date: 08-01-2012 12-01 Section: 1760Topic: 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 ofobtaining the primary residence, including first and last month’s rent and/or securitydeposit.

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Date: 08-01-2012 12-01 Section: 1765Topic: 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 thatparticipants can save for under the Connecticut IDA Initiative Program. The law andregulations make it very clear: A vehicle can only be purchased through the IDAProgram 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 theparticipant’s file.

A participant who has saved in order to purchase a vehicle for employment purposes canuse their IDA savings and matching funds to pay for registration of the auto and for thevehicle’s insurance, as long as the insurance is paid at or close to the time of vehiclepurchase.

NOTE: Special care should be taken by those agencies operating Youth IDA Programsunder the CT IDA Initiative, so as not to allow participants to save for a vehicle unlessthey will be at least 17 years of age by the time they are ready to make their assetpurchase, and can prove that they will need the vehicle to obtain or maintainemployment. Cases of youth saving for a vehicle will be scrutinized carefully by CTDOL. The preferable asset goal for youth is post-secondary education, as long as fundscan be expended for the education asset by the time the program ends.

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Date: 08-01-2012 12-01 Section: 1770Topic: Pre-Owned Vehicles

Pre-Owned Vehicles

Certified pre-owned cars can be a prudent and affordable alternative to new cars. Whenpurchased from a reputable licensed dealer, pre-owned cars often provide protections andwarranties that add a level of protection for the asset purchase.

IDA Program staff should require participants interested in purchasing a pre-ownedvehicle to research qualified auto dealers in the area. It is the IDA Program’sresponsibility to make sure that IDA auto purchases are lawful and prudent. Purchase ofa pre-owned vehicle from a private individual is not permitted under the CT IDAprogram. The check for the purchase of the pre-owned vehicle must be written to alicensed auto dealer.

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Date: 08-01-2012 12-01 Section: 1775Topic: Purchase of a Replacement Vehicle

Purchase of a Replacement Vehicle

Except in very extenuating circumstances, if a participant has a serviceable car the CTIDA 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 toprovide reliable, entry-level transportation to enable people to get or keep a job.Programs around the country that assist low-income families/individuals in purchasingvehicles, 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 140,000miles.* It is this average that is reasonable for our participants. To trade this car in toacquire a newer one does not adhere to the spirit of the IDA program.

*National Economic Development and Law Center

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Date: 08-26-2013 13-02 Section: 1800Topic: 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 eachindividual account holder up to two dollars for every one dollar deposited in theindividual development account by the account holder, not to exceed $3,000 per accountholder for the duration of the account holder's participation in the program. It is policythat the interest participants earn on the funds they deposit into their IDAs should also bematched. For example, if a participant in a 2:1 program saves up to $1,500, the interestearned on the savings will be matched 2:1 as well as the savings amount. In a 1:1program, the interest on a participant’s savings up to $3,000 will be matched 1:1 as wellas the savings amount.

Interest attributable to IDA matching contributions does not compound over time, but isassessed 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 intotheir account will not exceed $1,500 if they are in a 2:1 program (or $3,000 ifthey 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 theparticipant to open up a savings account in their own name and deposit theextra money there. (It is always a good idea for IDA participants to have anextra savings account that they can use for emergencies or for additionalexpenses 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 LocalReserve Funds (that will not be used to match the interest on the participants' IDAs) shallbe used to benefit IDA programs and participants/account holders in such programs.

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Date: 08-26-2013 13-02 Section: 1800Topic: 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 butare not necessarily limited to: provision of childcare and meals during financial educationclasses and Savings Club meetings; payment of stipends to guest speakers for financialeducation and Savings Clubs; provision of emergency loans for crisis interventions thatprevent withdrawals of IDA savings or from IDA programs; and payment of programcosts to ensure continuance of participant/account holder support throughout the durationof 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 usesdecreases as savings goal achievements and asset purchases increase.

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Date: 08-01-2012 12-01 Section: 1810Topic: 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 ofConnecticut require IDA funds to be held in separate accounts. The lead agency (in thiscase, DOL) can utilize one Central Reserve Fund for the receipt of AFIA, CT IDA andHTF grant funds. For CBOs operating CT IDA grants, the CT IDA Initiative fundscannot be co-mingled in the Local Reserve Fund with other IDA grant funds, with theexception of non-DOL funds from a private funder that are used to supplementparticipants’ match. A separate Local Reserve Fund must be used for each IDA grant.

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Date: 08-01-2012 12-01 Section: 1900Topic: Unclaimed Property Procedures

Unclaimed Property Procedures

If a participant leaves the IDA program and unclaimed funds remain in their IDA thecommunity-based organization (CBO) must contact their local bank to negotiate theprocess 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 notcharge fees. After 3 years the funds would be turned over to the Office of theTreasurer (OTT) as unclaimed property. (See Treasurer’s website foradditional information: http://www.state.ct.us/ott/aboutucp.htm)

2.) Less ideal would be that the bank converts the IDAs to regular accounts andcharges fees. After three (3) years any remaining funds would be turned overto OTT as unclaimed property. Many accounts would have been service-charged out of existence at this point.

3.) Worst case scenario, the bank would not turn the funds over to OTT andwould 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, perhapsseveral years down the road looking for their money, the original account number theyhave will be the old IDA custodial account number and not the new savings accountnumber. How will the bank ensure that the participant will be able to “find” theiraccount?

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Date: 08-01-2012 12-01 Section: 2000Topic: Record Retention

Record Retention

An agency operating an IDA program under the CT Department of Labor has to maintainrecords for a period of three years. The retention period starts from the date ofsubmission of the final expenditure report. Records that must be maintained include:“books, records, documents, program and individual service records and other evidenceof accounting and billing procedures and practices which sufficiently reflect all direct andindirect 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, therecords must be retained until the litigation, audit or chain has been finally resolved.

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Date: 08-01-2012 12-01 Section: 2100Topic: IDA Program Certification

IDA Program Certification

Agencies operating a CT DOL IDA programs are already certified. A community-basedorganization seeking certification of its existing or proposed IDA program (not part of theCT IDA Initiative) should submit its request and appropriate documentation to theDepartment of Labor.

The State certification process applies to all existing IDA programs -- Federal, State andprivate programs. Certification is similar to a license that guarantees the programoperates consistent with certain minimal quality standards. Ideally, such certificationshould 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 ourweb site (www.ctdol.state.ct.us/ida/dir/idaprogdertif.html). A CBO seeking certificationof its existing or proposed IDA program needs to submit its request to DOL. TheDepartment will review each request for certification and notify the community-basedorganization whether the organization’s request for certification has been approved ordisapproved.

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Appendix A

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2015 80% HUD Area Annual Median Income based on a Family Size of…Town 1 2 3 4 5 6 7 8 9 10

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

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

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

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

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Appendix B

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2015 Poverty Guidelines

The following figures are the 2015 HHS poverty guidelines which are scheduled to bepublished in the Federal Register on January 22, 2015.

2015 POVERTY GUIDELINES FOR THE 48 CONTIGUOUSSTATES

AND THE DISTRICT OF COLUMBIA

Persons infamily/household Poverty guideline

1 $11,7702 15,9303 20,0904 24,2505 28,4106 32,5707 36,7308 40,890

For families/households with more than 8 persons,add $4,160 for each additional person.

Source: http://aspe.hhs.gov/poverty/15poverty.cfm

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Appendix C

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CTDOL Access Database Instructions

ENTERING NEW CLIENTS1. From the Main Menu, click the “Add New Client” button2. Enter in as much information as possible on all of the tabs listed (“General Client

Information,” “Registration Information,” “Demographics" and “GeneralAccount.”)

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 anyinformation 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 torecord 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 anysingle entry. If a lump sum deposit is greater than $500 it will need to be entered as morethan 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 forSeptember 2007 and another $100 also for September 2007.)

Entering Emergency Withdrawal PaybackDue to state laws which limit annual matching amounts, we use the following process tomaximize 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 dropdown 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

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Asset WithdrawalsWhen recording an asset purchase in the “Assets Withdrawal” tab, only enter the amountwith- drawn from the participant’s IDA in the “Amount of Withdrawal from IDA forAsset Purchase” column. Do not include the match amount; the database willautomatically 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” tabas a negative deposit. (For example, if a participant deposits $600 in one year [assuminga 2:1 match], you will need to have them withdraw $100. Enter -$100 in the “Total $Amount of Deposits” column.)

Emergency Withdrawals1. 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 appearin the “Emergency Withdrawals” tab.

Exiting Clients1. 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 beentered to show the account as zero.

Leave of Absence1. 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 Transaction1. Click the arrow to the left of the transaction line and hit the “Delete” key.

or2. 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 EntryDOL requests that each agency assign one person to do the data entry for the IDAProgram, and that all data entry be done by this person.

For technical assistance contact Marie Hawe ([email protected] or (860) 832-9438x2202).

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Appendix D

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Grant Closeout - 2012

CLOSEOUT TIMEFRAME:

Project Period: __________ through ____________

Closeout Period must end by _______________.

FINAL REPORTS:

Grantees must submit to CTDOL the following reports by _________________: Final Financial Status Reports

Final Program Progress Reports1. 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 specialproblems encountered or expected.)

3. Significant findings and events: (Describe any major accomplishments,noteworthy events or best practices.)

4. Dissemination activities: (Describe project inquiries and informationdissemination activities carried out over the reporting period. Itemize and includea copy of any newspaper, newsletter, magazine articles or other publishedmaterials considered relevant to project activities, or used for project informationor public relations purposes.)

5. Other Activities: Grantees must submit to CTDOL the following database reportsby _______________:

Financial Information: Amount

1. The balance of the Local Reserve Fund at the beginning ofthis reporting period

2. The amount of Local Reserve Funds disbursed during thisreporting period

3. The amount of Local Reserve Fund interest accrued duringthis reporting period

4. The amount of Administrative Funds disbursed during thisreporting period

5. The balance of the Local Reserve Fund at the end of thisreporting period (to be returned to CTDOL)

6. Copy of Local Reserve Fund bank statement this reporting period

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Final Database Reports

Remitting Project Grant Funds

CAAs must liquidate all obligations incurred under the award by the end of the CloseoutPeriod ___________ 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 orreview conducted after the project Closeout. Any state funds paid to the recipient inexcess of the amount to which the recipient is finally determined to be entitled under theTerms and Conditions of the award constitute a debt to the State government. If not paidwithin 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 anyoverdue debt in accordance with federal regulations.

NOTICE OF FINAL CLOSEOUT AND RECORDS RETENTION

In general, Grantee must retain all financial reports, supporting documents, statisticalrecords, and all other records pertinent to an award for a period of three years from thedate they submit the final Financial Status Report. (For nonprofit Grantee, see 45 C.F.R.Part 74.72. For State, local, and Tribal government Grantee, see 45 C.F.R. Part 92.42.)

IDA PROJECT CLOSEOUT CHECKLIST

Closeout Activities / Milestones Completed / DatePrepare and submit the Final Financial StatusReport.Prepare and submit the Final Program ProgressReport.Prepare and submit all Project Database Reports.Remit grant funds remaining in the ReserveAccount to CTDOL via check.

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Appendix E

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Revision Date 5/14/15

PILOT POLICY FOR TRANSFERRING PARTICIPANTS AMONGCONNECTICUT INDIVIDUAL DEVELOPMENT ACCOUNT (IDA)

PROGRAMSEffective 6/5/2012

DEFINITIONS

Grantee – An organization that receives funding from the ConnecticutDepartment of Labor to operate a CT IDA Program.

CT IDA Program – An IDA Program supported by a grant from the CT Department ofLabor. This can be either a CT IDA Initiative Program or a CTHousing Trust Fund (HTF) IDA Program.

Project Participant – An individual who is enrolled in either a CT IDA InitiativeProgram or a CT Housing Trust Fund IDA Program.

BACKGROUND

On certain occasions, there may be a justification for moving an IDA participant fromone Department of Labor Individual Development Account Program to another. Thiscould be from one CTIDA Initiative Program to another CTIDA Initiative Program, fromone CT Housing Trust Fund IDA Program to another CT Housing Trust Fund IDAProgram, or between a CTIDA Initiative Program and a CT Housing Trust Fund IDAProgram. 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 programswithout first getting approval from the Connecticut Department of Labor([email protected])

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.

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With DOL permission, grantees may allow an eligible IDA participant to be transferredfrom one CT DOL IDA Program to another administered by that grantee withoutrequiring the participant to re-enroll in financial literacy courses or other training, exceptfor 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. Atransferred participant may withdraw funds for allowable uses from an IDA started underthe new CT IDA program after the participant has been enrolled (i.e. account opened) ineither 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 inthe most appropriate IDA grant to maximize success and minimize the need to transferthe 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 afterwithdrawing funds.

REQUIRED PROCEDURES

A grantee must do the following when a participant is transferred from one IDA Programto another:

1) Retain “matching” funds that had been set aside for the participant in the originalproject’s Reserve Account.

2) Allocate “matching” funds in the new project’s Reserve Account for thetransferred participant. (These funds must be available before the grantee maytransfer 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.

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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.

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Appendix F

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State of Connecticut Tumbleweed Secure email for IDA data1. You will be receiving an email from David Fernandes indicating that a package

from the sender (David) is on the Tumbleweed server and ready for pickup. Youwill need to click on “Pick up Package.”

2. You will be prompted for a password. If you have not signed onto the Tumbleweedserver with this email 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 bycontacting the BEST Helpdesk at [email protected].

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3. The Secure email is now displayed on the Tumbleweed server. In order to sendyour data through this secure format, click on “Reply” (and “Reply All,” whenavailable) from this email.

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4. To attach your Exportqry.xls file to this secure email, click on the “Browse” or“Choose File” button. Go to where you saved your Exportqry.xls file and select itby 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 .mdbfile 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.

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5. Open the IDA database as you would normally do. When you click on the “SendData Export” button in the database, you will have the opportunity to save theExportQry file to a different location on your computer. (NOTE: Each time yousave your Exportqry file, be sure to name it differently to prevent overwriting yourfile each time. When saving the file, the extension will be changed automatically toan .xls file.) Afterwards, click “Okay” to save the file and then continue withattaching your Exportqry.xls file to the Tumbleweed email.

6. When the name of the file appears under “Filename,” click on the “Add” button.

7. Then click on the “send” button.

This Secure Email Expires after 30 days and can be responded up to 5 times.