40 CFR § 35.4100
Can my group incur any costs prior to the award of our grant?
June 9, 2020
(a) The only costs you may incur prior to the award of a grant from EPA are costs associated with incorporation but you do so at your own risk.
(b) If you are awarded a TAG, EPA may reimburse you for preaward incorporation costs or allow you to count the costs toward your matching funds requirement if the costs are:
(1) Necessary and reasonable for incorporation; and
(2) Incurred for the sole purpose of complying with this subpart's requirement that your group be incorporated as a nonprofit corporation.