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Municipal Finance: Interpreting the American Rescue Plan Final Rule

Greater Flexibility, Lost Revenue Provision, Infrastructure, Non-Federal Matching

Recording of a 90-minute CLE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Tuesday, May 10, 2022

Recorded event now available

or call 1-800-926-7926

This CLE webinar will offer municipal attorneys much needed direction about the Final Rule promulgated under the American Rescue Plan Act in connection with Coronavirus State and Local Fiscal Recovery Funds (SLFRF), as well as offer strategies for taking full advantage of its benefits.


The SLFRF provides more than $2.2 billion in local fiscal recovery funds, but it also raises tricky questions about expenditure eligibility, timing, accounting, reporting requirements, and other issues. Consequently, eligible funds have gone unused due to fear of violating use restrictions.

The Final Rule takes effect on Apr. 1, 2022. One of the most important changes is to the revenue loss category by offering a standard allowance for revenue loss of $10 million, allowing recipients to fund any "government services." States must act quickly to use these funds for unemployment compensation trust fund replenishment.

The Final Rule expands the guidance of allowed projects and expands the list of critical sectors and occupations eligible for premium pay, but many other eligibility requirements remain. Additionally, the Final Rule lists categories of capital projects that are presumptively ineligible.

Listen as this experienced panel discusses how the Final Rule is different from the Interim Rules and how municipal attorneys can advise their clients on the legal use of these funds.



  1. Introduction
  2. Required uses of funds
  3. Changes in Final Rule
    1. Public health response
    2. Assistance to households
    3. Assistance to small businesses and nonprofits
    4. Aid to impacted industries such as tourism, travel, and hospitality
    5. Unemployment compensation trust fund replenishment
  4. Tax mandate prohibition
  5. Tribal recipients


The panel will review these and other critical issues:

  • How does the Final Rule differ from the Interim Rule?
  • When can municipalities begin disbursing funds under the Final Rule?
  • What additional households and communities are presumed to be impacted?
  • What changes were made to the timeline under which recipients must obligate and spend funds?


Moore, Michael
Michael Moore

Deputy Chief of the Municipal Finance Division
New York Law Department

Mr. Moore is the Deputy Chief of the Municipal Finance Division for the New York City Law Department and has worked at...  |  Read More

Welsh, Pamela
Pamela Welsh

Squire Patton Boggs

Ms. Welsh is a Principal at Squire Patton Boggs with over two decades experience advancing municipalities’...  |  Read More

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