What are Civil Rights and who is the Civil Rights Officer?
Every applicant has Civil Rights requirements. They are not part of a Grant Application because they are even more fundamental than the Application itself. They are a pre-requisite, i.e., a requirement for eligibility even to Submit an Application at all.
Compliance with Civil Rights requirements is checked when an Agency wants to Submit an Applications. The Regional Office's Civil Rights Officer is in charge of the agencies' compliance. That Officer has to approve every agency's eligibility to be an FTA Grantee before its Applications can even be accepted for review.
The requirements for an Application are much easier to meet than the requirements for being eligible even to Submit an Application. Application requirements can almost always be taken care of during the application review dialogue between FTA and your agency.
Your agency's eligibility requirements can almost always not be taken care of during the application review dialogue. They require more than merely a compliance review, application checklist or administrative process. Eligibility requirements require the substantive involvement of non-application staff members, attorneys, planners, other government agencies, etc.