We have a fixed price subcontract on a grant that the city has from HUD
under the "Public and Assited Housing Drug Elimination Program."  The city
stated in the subcontract that equipment purchases must be approved by the
city.  We had budgeted $2,500 for computer equipment for the use by clients
of the project and we expended it.  The contract does not address title to
the equipment.  I assume that, since this is a fixed price contract with
equal payments over time for deliverables, unless HUD regs say otherwise,
title to the equipment technically vests with us.  Is this a correct
assumption?  I can't find a copy of the HUD regs on the Web that cover this
program.  Is anyone familiar enough with the regs to tell me if there is
anything specific that states that HUD holds title to equipment purchased
on this kind of grant?  Thanks in advance for your input.

Barbara H. Gray                            Telephone:   803-953-5673
Director of Sponsored Programs      Fax:            803-953-6577
College of Charleston                     e-mail:         xxxxxx@cofc.edu
Charleston, SC  29424