CM-2026-095 - 4/10/2026 FIRST AMENDMENT
TO THE
COMMUNITY DEVELOPMENT BLOCK GRANT AGREEMENT
This First Amendment("First Amendment")is to that one certain Community Development Block
Grant Agreement("Agreement")entered into on the ID day of Apr i I ,2026 by and among
the City of Round Rock, Texas ("City") and Opportunities for Williamson-Burnet Counties,
collectively the"Parties".
RECITALS
WHEREAS,the Parties entered into the Agreement on the 2'day of January,2026;and
WHEREAS, the Parties have determined that it is in each of their best interests to modify and
amend the Agreement, adding additional Policy Requirements;
NOW THEREFORE, pursuant to Section 7.6 of the Agreement, the Parties agree to amend and
modify the Agreement as follows:
I.
1.01 Section 10.5 PY 2025 Federal Policy Provisions is added to read as follows:
A. Purpose and Authority
This Agreement shall include the Policy Requirements contained in the attached Exhibit"X," "FY
2025 Federal Policy Clauses."The Policy Requirements set forth in Exhibit"X"were issued pursuant to
Executive Orders 14168, 14182, 14154, 14218, and related federal statutes and regulations. These policy
provisions are binding on all recipients and subrecipients of CDBG funds.
B. Incorporation by Reference
The attached Exhibit "X" is made part of this Agreement as if fully stated herein and may be
administratively updated by the City as HUD issues subsequent guidance or additional Policy
Requirements.
C. Applicability and Flow-Down
SUBRECIPIENT shall comply with all requirements stated in Exhibit"X," and shall ensure that
its employees,contractors,and consultants likewise comply with those requirements for all activities funded
in whole or in part with CDBG funds. These provisions shall"flow down"to all covered agreements.
D. Compliance and Enforcement
Compliance with the policies in Exhibit "X" is a material condition of this Agreement and of
SUBRECIPIENT'S eligibility for reimbursement. The City may require SUBRECIPIENT to provide
program materials (including flyers, outreach publications, or participant documentation) to verify
compliance. Failure to comply may result in corrective action, suspension of payments, or termination of
this Agreement in accordance with 2 CFR 200.339-343.
00425399/ss2 c M ._ 2O2. eq5
E. Relationship to Other Federal Requirements
These FY 2025 policy provisions are in addition to, and do not supersede, other Federal
requirements applicable to this Agreement. In the event of a conflict,the more restrictive provisions shall
apply unless HUD provides written direction otherwise.
F. Reference Authorities
The policy provisions contained in Exhibit"X"implement the following federal authorities:
a. Executive Order 14168 —Defending Women from Gender Ideology Extremism and
Restoring Biological Truth to the Federal Government
b. Executive Order 14173 —Ending Illegal Discrimination and Restoring Merit-Based
Opportunity
c. Executive Order 14182—Enforcing the Hyde Amendment
d. Executive Order 14154—Unleashing American Energy
e. Executive Order 14218—Ending Taxpayers Subsidization of Open Borders
f Executive Order 14205—Establishment of the White House Faith Office
g. 8 U.S.C. § 1601 et seq.(PRWORA—Immigration Eligibility and Verifiaction)
h. 31 U.S.C. § 3729(b)(4)(False Claims Act—Material Compliance Provision)
II.
2.01 To the extent necessary to effect the terms and provisions of this First Amendment, the
Agreement is hereby amended and modified. In all other respects, the aforesaid Agreement is
hereby ratified and confirmed.
2.02 This First Amendment may be executed in countererparts, each of which shall be an
original and all of which together shall constitute buy one and the same instrument.
[Signatures on the following page.]
2
I1 WITNESS WHEREOF,this Agreement is entered into to be effective as of the to day of
` ,2026.
SUBRECIPIENT:
Opportunities for,Williamson-Burnet Counties
By:
Name:
Marco Cruz
Title: Executive Director
CITY:
City of Round Rock x
Broo s ennett, City Manager
Approved as to Form:
Stephanie L. Sandre,City Attorney
3
EXHIBIT X: PY 2025 FEDERAL POLICY CLAUSES (CDBG PROGRAM)
NOTE: This document is provided for informational purposes only and does not constitute legal
advice. HUD has not yet issued formal implementation guidance on Addendum 1. Jurisdictions should
consult their legal counsel and HUD Field Office for clarification and maintain documentation of all
interpretive decisions and communications.
This Exhibit sets forth the Federal policy requirements that apply to the Subrecipient as a condition
of participation in the CDBG Program for Program Year 2025. These provisions are incorporated
into and made a material part of the Sub recipient Agreement.
Section 1. Prohibition on Use of Funds to Promote "Gender Ideology"
1.1 Policy Requirement. In accordance with Executive Order (E.O.) 14168, Defending Women from
Gender Ideology Extremism and Restoring Biological Truth to the Federal Government, the
Subrecipient shall not use any CDBG funds to promote "gender ideology."
1.2 Definitions. For purposes of this section:
a. "Gender ideology" means any theory or policy asserting that sex is determined by
subjective identity rather than biological reality, as defined in Section 2(f) of E.O. 14168
and any subsequent HUD or OMB guidance.
b. For the purposes of this section, "Promote" means to publicly advocate, endorse, distribute,
advertise, or otherwise support, through funded publications, events, or materials, the
prohibited ideology.
1.3 Agency Forms and Data Collection. All forms, applications, surveys, or data-collection
instruments developed or used by the Subrecipient for CDBG-funded activities that request
information on an individual's sex shall list only the options "Male" or "Female."
a. Such forms shall not include questions or fields requesting or recording gender identity,
gender expression, or similar classifications.
b. Existing forms containing such fields shall be modified or replaced for CDBG-funded
purposes to ensure compliance with E.O. 141 68.
1.4 Grantee Review. At the request of the Grantee, the Sub recipient shall provide advance copies
of flyers, brochures, social-media posts, or other public materials related to CDBG-funded
activities for Grantee review to ensure compliance with this provision prior to release or posting.
1.5 Consistency with Existing Civil Rights Requirements. Nothing in this section shall be construed to
limit or modify the Subrecipient's obligations under any other law protecting individuals from
unlawful discrimination.
Section 2. Compliance with Federal Anti-Discrimination Laws and False Claims Act Provisions
2.1 General Requirement. The Subrecipient shall comply in all respects with all applicable Federal
anti-discrimination laws, including Title VI of the Civil Rights Act of 1 964 (42 U.S.C. 2000d et seq.)
3
2.2 Material Compliance under the False Claims Act. Pursuant to E.O. 14173 and 31 U.S.C. §
3729(b)(4), the Subrecipient acknowledges that compliance with Federal civil-rights and anti-
discrimination laws is material to the U.S. Government's payment decisions under the False Claims
Act.
2.3 Certification. By execution of this Agreement, the Subrecipient certifies that it does not and will
not operate any program in violation of these laws and shall promptly report to the Grantee any
filed or pending civil-rights complaint, investigation, or finding of non-compliance related to any
CDBG-funded activity.
Section 3. Prohibition on Use of Funds for Elective Abortions
3.1 Policy Requirement. Pursuant to E.O. 14182, Enforcing the Hyde Amendment, the Subrecipient
shall not use any CDBG funds to fund or promote elective abortions.
3.2 Definition. For purposes of this section, "Promote" means to publicly advocate, endorse,
distribute, advertise, or otherwise support, through funded publications, events, or materials, the
performance of elective abortions.
3.3 Grantee Review. At the request of the Grantee, the Subrecipient shall provide advance copies
of flyers, brochures, or other outreach materials for Grantee review to ensure compliance with this
provision.
Section 4. Environmental Considerations
4.1 Policy Requirement. Notwithstanding any prior Notice of Funding Opportunity (NOFO) or
application materials, this Agreement shall not be governed by orders revoked by E.O. 14154,
Restoring the Rule of Law in Federal Administration, including E.O. 14008, Tackling the Climate Crisis
at Home and Abroad.
4.2 NEPA Unchanged. Nothing in this section shall alter or exempt the Subrecipient from compliance
with existing environmental-review requirements under 24 CFR Part 58 or the National
Environmental Policy Act (NEPA), 42 U.S.C. § 4321 et seq. If the NEPA statute or its implementing
regulations—including those at 24 CFR Part 58—are amended or superseded during the term of
this Agreement, this provision shall be automatically deemed amended to reflect and require
compliance with such updated authority, as interpreted by HUD or other applicable Federal
agencies.
Section 5. Immigration Status Verification and SAVE System Compliance
5.1 Policy Requirement. To ensure implementation and compliance with Title IV of the Personal
Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA, 8 U.S.C. §§ 1601—
1 646) and E.O. 14218,Ending Taxpayer Subsidization of Open Borders,the Subrecipient shall assist
the Grantee in ensuring that CDBG assistance is not provided to ineligible aliens.
5.2 Subrecipient Role. Subrecipients serving as program administrators shall assist the Grantee in
ensuring compliance with PWRORA. Subrecipients may collect intake information and supporting
documentation. The Subrecipient shall transmit collected documentation to the Grantee for
4
verification through the Systematic Alien Verification for Entitlements (SAVE) Program or an
equivalent verification system approved by the Federal Government.
5.3 Grantee Role and Determinations. The Grantee shall perform all SAVE verifications and
maintain the official verification record. Any denial decisions issued by the Grantee based on
SAVE results or Federal guidance are final and binding on the Subrecipient.
5.4 Prohibitions. No Subrecipient shall use CDBG funds in a manner that, by design or effect,
facilitates the subsidization or promotion of illegal immigration or shields illegal aliens from
deportation, including by maintaining policies or practices that materially impede enforcement of
Federal immigration laws.
Section 6. Equal Treatment for Faith-Based Organizations
6.1 Policy Requirement. Faith-based organizations are eligible to participate as Subrecipients on
the same basis as any other organization, consistent with E.O. 14205.
6.2 Prohibition on Religious Activities. No CDBG funds may be used for inherently religious activities
such as worship, instruction, or proselytization. Any such religious activities must be separate in time
or location from HUD-funded activities and voluntary for participants.
6.3 Non-Discrimination. The Subrecipient shall not, in the selection of contractors, vendors, or
beneficiaries, discriminate on the basis of religious character, affiliation, or exercise.
5