1. Regency Apartments Project Number: 12019 Compliance Requirements September 2012

2. Overview Components of Compliance Important Terms Davis Bacon Certified Payroll (WH-347) Requesting an Additional Wage Classification Daily Sign-In Sheets City of Cleveland Reporting OEO/Fannie Lewis Section 3 Project Requirements Critical Items Marous Brothers Construction Contact Information

3. Important Contractual ($) Terms: MBE: Minority Business Enterprise FBE: Female Business Enterprise CSB: Cleveland Small Business A certified Section 3 Business is one or more of the following: 51% or more owned by a Section 3 resident OR At least 30% of employees need to be Section 3 residents within 3 years of being employed OR Commit to subcontracting 25% of total dollar award to Section 3 Businesses

4. Important Workforce (hours) Terms: Minority Female Section 3 Resident: A low-income individual Low-Income: person whose permanent residence is in the City of Cleveland and their total household income last year was not greater than 80% of the median income for the area based on the number of persons in their family (refer to Section 3 income verification form) Residency: Individuals living in The City of Cleveland Fannie Lewis Low Income: Very low income person that lives in Cleveland (income guideline is lower than Section 3)

5. Davis-Bacon Prevailing Wage (Certified Payroll) Required due to project funding sources. Requires that Federal rates for the specific project be paid in accordance to an assigned wage decision, or appropriate union scale, whichever rate is higher. Employees may not be 1099, unless they are a certified independent company. Requires that a Certified Payroll Report (WH-347) be completed each week along with a Daily Sign-In Sheet attached. Please ensure that the Daily Sign-In Sheets match the corresponding Certified Payroll. The hours listed on each will be compared. If your company currently uses a custom payroll report it can be used as long as it includes all required information. Certified Payrolls & Daily Sign-In Sheets get submitted weekly

6. Example Wage Decision: Wage decision number. Date of wage decision. Classification Base Wage rate Fringe rate Rate paid to employees must be greater than or equal to Rates + Fringes. Modification #

7. Requesting Additional Wage Classifications Some wage decisions do not include all the required classifications for the specific project. When your company’s work classification is not listed, you will need to fill out a Department of Labor Additional Wage Classification request. The process of getting an additional classification approved by the Department of Labor can take about 4 to 6 weeks. No one is exempt from following Prevailing Wage. This is a one time form that only gets filled out if needed.

8. Requesting an Additional Wage Classification Date Completed Keep this information filled in.

9. Requesting an Additional Wage Classification Suggested wage rate. Return Form to Marous Brothers Construction when completed. Project information. Information regarding the requested classification. Work classification being requested. Enter Project address: 1560 Ansel Road Cleveland, OH 44106 Suggested Wage Rate

10. Payroll Authorization – City of Cleveland This portion must be signed by the owner of the company in blue ink. Name of person signing payrolls. If you have multiple Payroll Officers you must complete additional forms. This form only needs to be completed one time for each authorized signer. Regency Apartments Actual Project address: 1560 Ansel Rd. Cleveland, OH 44106 Name of your company. Address of your company. Name of your company.

11. Certified Payroll: WH-347 Project or Contract No: 12019 Contractor/Subcontractor: your company’s name and check appropriate box. Payroll Number: Week #1 is your company’s first week on site. Please mark this initial. Mark the last week on site as final. Week Ending: This should be the last day pay period week. Pay weeks should be Sunday through Saturday. If you are not on site you still must turn in a “No Work Performed” payroll. Payrolls need to be submitted WEEKLY until “Final” is submitted. Address: Your company’s address. Project Name & Location: Regency Apartments Cleveland, OH

12. Certified Payroll: WH-347 (1) Name, Address, & Social Security Number of Employee: Employee's full name & last 4 digits of SS# must be shown on each weekly payroll submitted. Employees full address (including zip) must be listed. Also include race & gender (ex: C/M) (3) Work Classifications: Complete work classification (Ex: Carpenter JRNY, Carpenter App, etc). Be certain to consult project specific wage decision (4) Day and Date: Weeks start on Sunday end up Saturday no matter what your pay date is. O = Overtime S = Straight time (6) Rate of Pay: Where fringe benefits are paid to approved plans, funds, or programs, you will only need to list the base rate paid. Where fringes are paid in cash, wage must match the base rate and fringe rate being paid total. (7) Gross Amount Earned: The top portion is for the gross amount earned on this specific project. The bottom portion is the gross amount earned from all projects this week.

13. Certified Payroll (WH-347) (4A) Check this box if the employees benefits are paid into a union or a bona fide plan. Fill in the proper information for your company and the specific project. Child support, Vacation, Garnishments get listed here. Name of person who signs your company’s payrolls.

14. Certified Payroll: WH-347 Name and signature of person reviewing this payroll. Must sign in blue ink (4b) Check this box if fringes are paid in cash, and not to a union or approved plan. Owner, Non Working Admin, and Supervisor who are exempt

15. Daily Sign-In Sheets Each employee must sign in and out daily. Enter Project Name and Address: Regency Apartments 1560 Ansel Rd. Cleveland, OH 44106 Week Ending Date Your Company name Marous Brothers Construction, Inc. Please ensure these 3 fields are accurately completed for each employee daily Enter correct date

16. City of Cleveland Office of Equal Opportunity (OEO)/Fannie Lewis  There are two components to OEO  The contractual ($) portion consists of:  15% of contract values be set aside for MBE certified companies.  7% of contracts be set aside for FBE certified companies.  8% CSB contracts  The workforce (hours) portion consists of:  16.1% Minority participation  6.9% Female participation  20% of hours being performed by a City of Cleveland resident.  4% of the 20% should be very low income residents. The OEO workbook is required electronically in Excel as well as paper originals signed in blue ink. All of the paperwork is in one spreadsheet with 4 SEPARATE WORKSHEETS.

17. OEO Reporting Summary and Affidavit Name of Project Name of your Company Will pull from the Invoice and Payment Summary (Tab 2) Will populate from the Worker Hour Reporting Form. (Tab 3) Will pull from the Invoice and Payment Summary (Tab 2) This is a monthly form.

18. OEO Reporting Summary and Affidavit Must be notarized or will not be accepted. Fill in the information for the person reviewing this form. This is a monthly form.

19. OEO Invoice and Payment Summary Fill in the project name. Fill in the name of your company. Fill in the amount of the listed contract awards. Fill in the proper information regarding your company’s contract. This is a monthly form.

20. OEO Invoice and Payment Summary Fill in the subcontractor’s company name. Keep the proper certifications listed. Type out the invoice number. Fill in the amount of money that was paid. Fill in the type of work that the company performs. Need to turn in cancelled checks for all subs and suppliers. This is a monthly form. Fill in the actual amount of the check. Fill in the check number. Fill in the date the check was issued.

21. Resident Worker Hour Report Your company’s name Employee’s last name Employee’s first name Last 4 digits of SSN Employee’s Gender Employee’s Race “x” if employee is a Cleveland resident “x” if employee is a low income individual. Will populate from the data you enter below. This is a monthly form.

22. Resident Worker Hour Report Week ending dates Will populate from the data you enter to the right.. Hours by week ending dates. This is a monthly form.

23. OEO Contact Information Fill out the proper information for the individual who should be contacted regarding this paperwork for this project. This is a one time form due the first month your company is on site.

24. Fannie Lewis Income Verification Employer needs to fill out this information Must check off appropriate box. Employer needs to fill out this information Must fill in accordingly.

25. Fannie Lewis Income Verification Employee needs to fill out this information Employee Signs Employer Signs Please check which supporting document you have attached You must provide one of the documents listed here in addition to the supporting documentation below.

26. Section 3  The purpose of Section 3 is to ensure that employment and other economic opportunities created by HUD assistance to construction and rehabilitation is directed to low-income persons that reside in Cleveland.  Only subcontractors who’s contract value is $100,000 or greater need to complete Section 3 forms.  There are two components to Section 3.  The contractual ($) portion consists of:  At least 10% of total “Construction” awards must be given to Section 3 Businesses  At least 3% of total “Non-Construction” awards must be given to Section 3 Businesses  The workforce (hours) portion consists of:  30% of new hires on this project must be Cleveland Section 3 Low Income individuals.

27. Section 3 Core Employee List Fill in employee name. Employee hire date. Check the box if a Section 3 employee. Fill in job title of employee. Fill in this box with your company’s information. List ALL employees employed by your company, not just the ones that will work on this project. This is a one time form submitted before work on site begins.

28. Section 3 Clause Fill out information pertaining to the project this paperwork applies to. Check off which quarter this paperwork applies to. Document only needed one time, with your Core Employee List.

29. Section 3 Clause Have this portion signed by the owner of the company in blue ink. Read and acknowledge all information on the Section 3 Clause form before signing.

30. Section 3 Core Construction and Non-Construction Contract Awards Form Fill in all fields listed and check the correct quarter. This form is due quarterly. Two hard copies are to be mailed and the Excel file must be emailed. Fill in the year

31. Section 3 Core Construction and Non-Construction Contract Awards Form Sub or Suppliers name. Sub or Suppliers address. Sub or Suppliers city. Sub or Suppliers state. Sub or Suppliers zip code. Subs = construction Suppliers = non-construction This form is due quarterly. Two hard copies are to be mailed and the Excel file must be emailed.

32. Section 3 Core Construction and Non-Construction Contract Awards Form Sub or Suppliers tax ID # or individual SS# Sub or Suppliers contract amount Sub or Suppliers contract amount if they are Section 3 Certified Fill in “yes” or “no” to answer if business is certified. M = Male Owned F = Female Owned Fill in Ethnicity of the Business Owner. This form is due quarterly. Two hard copies are to be mailed and the Excel file must be emailed.

33. Section 3 Workforce Utilization Check off which quarter this paperwork applies to. Fill out information pertaining to the project this paperwork applies to. This form is due quarterly. Two copies are to mailed. Write in Correct Year

34. Section 3 Workforce Utilization Fill in the name and address of any new employee hired in the quarter you are reporting for. Only new hires who are not on your Core Employee List should be listed here. Fill in the job classification of the employee listed. Check the box if the employee is a Sec 3 resident. If you check this box be sure to include a Resident Income Verification for the employee. Fill in the hire date for the employee listed. This form is due quarterly. Two copies are to be mailed.

35. Section 3 Resident Income Verification This form is due as needed and should be attached to the Section 3 Workforce report. Be sure to fill out company information completely. Check the box that applies to the employees classification Check the box the applies to the employees household residents and income amount for the previous year this form is being filled out. Be sure to fill out employee information completely. Make sure the employee signs!

36. Job Requirements Contractual  A percentage of the total contract value must be spent as follows:  15% MBE  7% FBE  8% CSB  10% Construction & 3% Non – Construction Section 3 Awards * Must be on City of Cleveland certified list. Workforce  A percentage of project hours worked must be as follows:  16.1% Minority  6.9% Female  30% of new hires must be Section 3  20% Cleveland residents  4% of the Cleveland residents must be low income

37. Critical Points: In order to receive payments we must first receive the following information: Core Employee List Section 3 Clause & Narrative Form A Core Construction & Non-Construction Awards Payroll Authorization Subcontractor List All Certified Payroll must be completely filled out and submitted with signatures in BLUE ink. Must turn in 4 ORIGINALS of Certified Payroll weekly w/Daily Sign-In sheets attached. Must be current with all monthly and quarterly reporting. Missing paperwork = NO MONEY!!!!! NOTE: MAROUS BROTHERS CONSTRUCTION IS REQUIRED TO SUBMIT ALL COMPLIANCE PAPERWORK WITH EACH PAY APPLICATION. IF ANY INFORMATION IS MISSING, OUR PAY IS WITHELD, AND CONSEQUENTLY YOUR PAY IS WITHELD.

38. ReportRequirements Core Employee List1 Time Section 3 Clause & Narrative1 Time Payroll Authorization1 Time Subcontractor Information Sheet1 Time OEO Contact Information1 Time Certified PayrollWeekly Daily Sign-In SheetsWeekly OEO Report & Monthly AffidavitMonthly OEO Invoice and Payment SummaryMonthly OEO Resident Worker Hour ReportMonthly Section 3 Form A Core Construction/Non-Construction AwardsQuarterly Section 3 Workforce UtilizationQuarterly Section 3 Income VerificationsAttached to Quarterly Workforce Report Fannie Lewis Income VerificationSubmitted with monthly OEO Report Apprenticeship AgreementsAs Needed Additional Classification RequestAs Needed Regency Apartments

39. Subcontractor Information Sheet Enter person responsible for completing any Compliance paperwork. Please be sure to complete all fields. Enter any Certifications your 2 nd Tier holds by any Entity. Example City MBE, CMHA FBE. Enter Project Name Enter the date their Certification expires PLEASE ATTACH A COPY OF CERTIFICATE

40. Subcontractor/Supplier Information Sheet PLEASE ATTACH A COPY OF CERTIFICATE Enter the date your Certification expires Please be sure to complete all fields. Enter person responsible for completing any Compliance paperwork. Enter Company Name of any 2 nd Tier Subcontractor or Supplier Enter any Certifications your company holds by any Entity. Example City MBE, CMHA FBE. Enter company 2 nd Tier Subcontractor or Supplier is contracted to.

41. Marous Contact Information  Tina Brenenstuhl  Phone: 440-391-5353  Email: tbrenenstuhl@marousbrothers.com tbrenenstuhl@marousbrothers.com  Diana Correa  Phone: 440-391-5427  Email: dcorrea@marousbrothers.comdcorrea@marousbrothers.com  Melissa McCollister  Phone: 440-391-5520  Email: mmccollister@marousbrothers.com mmccollister@marousbrothers.com  Ed Hallis  Phone: 440-391-5527  Email: ehallis@marousbrothers.com  Fax Number: 440-951-4580  Mailing Address: Marous Brothers Construction Attn: Compliance Department 1702 Joseph Lloyd Pkwy Willoughby Oh, 44094