​​On December 10, 2020, NRECA filed comments in response to FEMA’s draft closeout policy.  The comments criticize FEMA’s view that electric cooperatives not eligible for the protections afforded by Section 1216c of the 2018 Disaster Recovery Reform Act (“DRRA”), the section that limits the time under which FEMA may deobligate or take back funds from recipients and subrecipients.  The comments also criticize FEMA’s proposal to give itself the ability to toll the statute of limitations.  Finally, we recommended that, given the importance of this draft policy, FEMA should conduct a formal rulemaking process pursuant to the Administrative Procedures Act to adopt the draft policy.