Disclosure of the Conflict of Interest- CDBG Program ParticipationCopyrighted
April 7, 2025
City of Dubuque CONSENT ITEMS # 7.
City Council
ITEM TITLE: Disclosure of the Conflict of Interest- CDBG Program
Participation
SUMMARY: City Manager transmitting information to formally disclose a
conflict of interest concerning Dale Campbell, a member of
the Community Development Advisory Commission, in
relation to his application for a Community Development
Block Grant (CDBG) funded microenterprise grant
administered by the City's Economic Development
Department and Fountain of Youth.
SUGGUESTED Receive and File
DISPOSITION:
ATTACHMENTS:
1. MVM Memo
2. Staff Memo
Page 121 of 386
THE CITY OF
Dubuque
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TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
SUBJECT: Disclosure of the Conflict of Interest- CDBG Program Participation
DATE: April 2, 2025
Housing & Community Development Director Alexis Steger is transmitting information to
formally disclose a conflict of interest concerning Dale Campbell, a member of the
Community Development Advisory Commission, in relation to his application for a
Community Development Block Grant (CDBG) funded microenterprise grant
administered by the City's Economic Development Department and Fountain of Youth.
Dale Campbell, an appointed Commissioner of the Community Development Advisory
Commission, applied for and was deemed eligible for the CDBG microenterprise
program, which provides up to $5,000 in funding for business -related expenses. While
the Commission did not participate in reviewing or approving individual applications, it
was responsible for approving the microenterprise program's allocation.
To maintain transparency, this conflict has been publicly disclosed through City Council
Consent Agenda items and official correspondence. The City awaits HUD's
determination on the exception request and will comply with all further
recommendations to ensure compliance with applicable regulations.
Y
Mic ael C. Van Milligen
MCVM:sv
Attachment
cc: Crenna Brumwell, City Attorney
Cori Burbach, Assistant City Manager
Alexis Steger, Housing & Community Development Director
Page 122 of 386
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TO: Michael C. Van Milligen, City Manager
FROM: Alexis M. Steger, Housing and Community Development Director
SUBJECT: Disclosure of the Conflict of Interest- CDBG Program Participation
DATE: March 31, 2025
Introduction
This memorandum transmits information to formally disclose a conflict of interest
concerning Dale Campbell, a member of the Community Development Advisory
Commission, in relation to his application for a Community Development Block Grant
(CDBG) funded microenterprise grant administered by the City's Economic
Development Department and Fountain of Youth.
Discussion
Dale Campbell, an appointed Commissioner of the Community Development Advisory
Commission, applied for and was deemed eligible for the CDBG microenterprise
program, which provides up to $5,000 in funding for business -related expenses. While
the Commission did not participate in reviewing or approving individual applications, it
was responsible for approving the microenterprise program's allocation.
In compliance with 24 CFR 570.611, an exception to the conflict of interest provisions
will be requested from the U.S. Department of Housing and Urban Development (HUD).
This request is based on the following factors:
• Public Benefit: The grant will support a low- and moderate -income
microenterprise owner, aligning with the CDBG program's economic
development goals.
• No Unfair Advantage: The application process was conducted impartially by the
Economic Development Department, which was unaware of Mr. Campbell's
Commission role at the time of review.
• Community Development Participation: The Commission has two vacant
seats, and denying the exception could discourage engagement from business
owners who could benefit from such programs.
• Safeguards and Compliance: Oversight mechanisms, including compliance
monitoring by the Community Development Specialist, will ensure proper
administration and adherence to regulations.
Page 123 of 386
To maintain transparency, this conflict has been publicly disclosed through City Council
Consent Agenda items and official correspondence. The City awaits HUD's
determination on the exception request and will comply with all further
recommendations to ensure compliance with applicable regulations.
Recommendation
I respectfully submit this memo as informational only.
Prepared by: Mary Bridget Corken-Deutsch, Community Development Specialist
Page 124 of 386