3TODAY’S WORKSHOP:Will provide a brief overview of the chapters located within the Strategic Investment Process (SIP) Compliance Manual focusing specifically on CDBG.Will focus on educating you on how these items will tie into the monitoring of your award. Letting you know what to expect and what we expect when we monitor.Will be brief. As a recipient or potential recipient of CDBG funds, the expectation is that you will read, review, get familiar, and ask questions after the fact about things that you are unsure of for your award.At the conclusion of this afternoon’s workshop will respond to any questions, comments, or concerns you may have.
4Chapter One: Policy Requirements Strategic Investment Priority RequirementsCompliance Auditor will check at monitoring to ensure threshold requirements were metMatch/Leverage RequirementsFor CDBG, 10% of total funds drawn minus administration costsNo requirement for CDBG-DBanked LeverageOnly eligible on awards made in1999 or laterBanked leverage generated on a CDBG or CDBG-D award cannot be used as match on a future HOME awardBanked match generated on a HOME award may be used as leverage on a future CDBG or CDBG-D awardProgram IncomeGross income received by a state, local unit of government, or a subrecipient that was generated from the use of CDBG fundsPage 7 of the SIP Compliance Manual outlines what is considered program income and how it should be treatedCDBG Public Hearing RequirementsRequired at application submission and program completion
5Chapter one: Policy requirements Legal notice(s) must be published (Sample notice found in Exhibit C)Copies of publisher’s affidavit(s), minutes, and sign-in sheet must be retainedRental Project RequirementsRent and Income RestrictionsUtility AllowancesInformation regarding IHCDA utility allowances can be found on our website atLease Language/Program AgreementsMinimum requirements & prohibited language can be found on pages 11 – 12 of the SIP Compliance ManualOwner-Occupied Rehabilitation RequirementsEligible forms of ownershipFee simple title99 year leaseholdCondominium ownershipMembership in a cooperative or mutual housing projectMaintains an equivalent form of ownership approved by HUDIneligible forms of ownershipLife estatesLand contracts/contracts for deedsDuplication of Benefits Certification (CDBG-D ONLY)Must be completed and kept on file for each beneficiary
6Chapter two: Lead Based Paint Requirements The primary cause of childhood lead poisoning is deteriorating lead-based paint and lead-contaminated dust and soil in older housing units. Although lead was banned from residential house paint in 1978 by the Consumer Product Safety Commission (CPSC), an estimated 57 million older homes still contain some lead-based paint.In most cases, LBP work should be the highest priority for rehabilitation in a home.Key ItemsBrochures – ensure that the right people receive them and/or that they are posted in the appropriate locationFor contractors and subcontractors“Lead Paint Safety – A Field Guide for Painting”For homeowners and renters“Protect Your Family from Lead in Your Home”“Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools”For organizationsThe “Runs Better Unleaded” Poster must be displayed at the offices of the recipient, subrecipient, and administrator
7Chapter two: lead based paint requirements Lead Hazard Testing and Clearance ProcessDetermine whether or not property is exempt from testingIndentify the “Approach to Lead Hazard Evaluation and Reduction”Varies depending on the level of assistance to the unitConduct the Lead Hazard EvaluationPaint TestingRisk AssessmentsNotify the occupant of the Lead Hazard EvaluationMust be notified within fifteen (15) days after the results have been determinedComplete Lead Hazard Reduction activities as directed according to the level of assistance and the results of the Lead Hazard EvaluationSafe Work PracticesPaint StabilizationInterim ControlsAbatementConduct the Lead Hazard Reduction and Clearance TestMust be conducted by a licensed lead-based paint inspector, risk assessor, or clearance technician
8Chapter two: Lead Based Paint Requirements 7. Provide the occupant with the Notification of Hazard Reduction and ClearanceMust provide occupants with the “Notification of Lead Hazard Reduction and Clearance” within fifteen (15) days of completion.8. Complete and submit the “Lead Form for Set-up and Clearance” (see Chapter 12, Funds Management – CDBG-D, Exhibit C)Other things to considerRelocationOn-Going Lead Based Paint compliance (rental only)Annual requirements regarding lead-based paint$25,000 in federal assistance triggers abatementLead Hazard reduction activities that are part of the federal assistance do not count towards this limitExample - $27,000 in rehab work on home…..$10,000 of this $27K is related to lead reduction activities…..in this case only count $17,000.
9Chapter three: accessibility Recipients cannot discriminate against an otherwise qualified individual with disabilities, solely by reason of his or her disability, with regards to participation in any program or activity receiving CDBG funds.This chapter defines the recipient’s responsibilities in terms of physical and program accessibility of their CDBG program.Recipients must include the accessibility logo on all client related materials
10Chapter three: accessibility (cont.) New ConstructionSubstantial RehabilitationRehabilitation5 or more unitsRequired minimum of 5% of the units or at least one unit accessible for mobility impairments; Minimum of 2% or at least one unit accessible for hearing or vision impairmentsRecommended minimum of 5% of the units or at least one unit accessible for mobility impairments; recommended minimum of 2% or at least one unit accessible for hearing or vision impairments15 or more units
11Chapter four: Uniform relocation act "Each award recipient shall provide for reasonable benefits to any person involuntarily and permanently displaced as a result of the use of assistance received….Owner-Occupied RehabilitationAward recipients are required to provide temporary relocation assistance in the event that a unit becomes temporarily unlivable during rehabilitationCan be provided in the form of paying for meals, hotel, housing participants in another unit, etc.Participation is voluntary so participants are not eligible for permanent relocation assistanceParticipants are not required to receive relocation advisory notices but should be informed that relocation might occur during the initial eligibility review.Rental HousingProperty Acquisition – Willing Buyer/Seller Transaction
12Chapter four: uniform relocation act (cont.) Once negotiations begin the Voluntary Acquisition Disclosure to Seller notice (Exhibit I) should be sent.Notice must be sent via certified mail or hand-delivered with signed receiptIf purchasing with federal funds cannot exceed the appraised fair market valueWilling buyer/seller transactions are ineligible for relocation assistance However, any tenants residing in the building(s) are eligible for relocation assistanceProperty Acquisition – Non-Willing Buyer/Seller TransactionProperty Owner NotificationSend a notice to the seller as soon as feasibleInclude HUD booklet 1041-CPD, When a Public Agency Acquires Your Property (Exhibit S) with this noticeThis packet of information must be sent via certified mail or hand-delivered with signed receiptDetermine the Value of the PropertyIf below $10,000, a licensed real estate appraiser may determine valueIf above $10,000, a fee appraisal by a licensed real estate appraiser must be obtainedFor properties that have been damaged and are located within the 100-year floodplain, both a fee and review appraisal must be completed
13Chapter four: uniform relocation act Property owner must be notified of the time and date of the appraisal as they can attend if they chooseNotify property owner of offer after completion of the market valuation or appraisalsShould be sent via certified mail or hand delivered with a signed receiptSign the purchase offerIf this is done prior to the ER release of funds and Section 106 clearance, you should enter into a purchase option that documents the completion of these processes as a condition of saleComplete the Recipient Questionnaire (Exhibit A – Acquisition-Relocation Summary Form)Property Acquisition with Rental TenantsGeneral Information Notices must be provided as soon as feasibleResidential Tenant that will not be Displaced (Exhibit B)Residential Tenant to be Displaced (Exhibit C)If displacement is possible, HUD Booklet 1042-CPD, Relocation Assistance to Tenants Displaced from their Homes (Exhibit T)Other Notices to be providedNotice to Tenants Moving in After Application (Exhibit R)Notice must be issued to each prospective tenant BEFORE the tenant agrees to move into the development.
14Chapter four: uniform relocation Act Notice of Non-displacement (Exhibit D)For residents who will remain in the project after completionTemporary Relocation NoticeFor tenants who are not required to move permanentlyMust receive “reasonable” advance written noticeNotice of Eligibility for Relocation Assistance (Exhibits F, G, & H)Issued to residents who will be displaced90 (and 30 Day) NoticesMust specify the date by which the property must be vacatedURA to Displaced HouseholdsReplacement HousingDifferent types depending on whether the resident is a homeowner or rental tenant as well as how long they have lived in the propertyMoving and Related ExpensesURA to Remaining HouseholdsSuitable HousingAffordable HousingTemporary Relocation Assistance
15Chapter five: fair housing and Civil Rights The Fair Housing Act states that it is illegal to discriminate against any person because of race, color, religion, sex, disability, familial status, or national originAll CDBG award recipients are required to take an action to affirmatively further fair housingThe action must reach the general community at-large and not be limited to low-moderate income residents onlyCDBG rental projects with 5 or more assisted units must complete an Affirmative Fair Housing Marketing Plan using HUD Form 935.2A (Exhibit B)Award recipients, subrecipients, and administrators are required to post the Fair Housing Equal Opportunity Poster in their officesAward recipients must include the Fair Housing logo on all client related materialsAward recipients must provide all beneficiaries with a copy of the HUD brochure entitled “You May Be A Victim Of…”
16Chapter Six: Conflict of Interest Persons CoveredProvisions apply to any person who is an employee, agent, consultant, officer, or elected official or appointed official of the state, or of a unit of general local government, or of any designated public agencies, or sub-recipients which are receiving CDBG funds.Conflicts ProhibitedNo person who exercises or have exercised any functions or responsibilities with respect to CDBG activities.Persons in a position to participate in a decision-making process or gain inside information.Persons that may obtain a financial interest or benefit from the activity, or have an interest or benefit from the activity.Persons that have an interest in any contract, subcontract or agreement.
17Chapter Six: Conflict of Interest Conflict of interest requests should be submitted in writing and contain the following:A request for an exception to the conflict of interest prohibition.A copy of the minutes from a public meeting denoting that the affected person has publicly disclosed the conflict and has stated that he/she has withdrawn from functions or responsibilities with respect to the assisted activity in question.An opinion from the recipient’s attorney that the interest for which an exception is sought would not violate state or local law.Uniform Conflict of Interest Disclosure Statement (Exhibit A)If an exception is allowed, this document must be completed and submitted within fifteen (15) days to the following parties:Indiana Housing and Community Development AuthorityState Board of AccountsClerk of the Circuit Court of the county in which the contract was executed
18Chapter seven: Section 3 Applicability of Section 3Recipients of HUD Community Planning & Development construction funding in excess of $200,000 in a program yearContractors and subcontractors that receive contracts in excess of $100,000 for Section 3 covered projects/activitiesThe Section 3 language (Exhibit B) must be included in or attached to such contractsRequirementsAttempt to offer 30% of new employment opportunities to Section 3 residentsAttempt to award 10% of the total dollar amount of all covered construction contracts to Section 3 businessesMandatory Reporting RequirementsWhether or not an IHCDA award generated a need for new employment or contracts, the recipient must still submit Section 3 quarterly reports to IHCDA indicating this information.Quarterly reports are due February 1, May 1, July 1, and November 1Recipients are also asked to submit their own annual report directly to HUD on Form HUD (Exhibit A)
19Chapter seven: section 3 DefinitionsSection 3 Residents are one of the following:Residents of Public and Indian Housing; orIndividuals that reside in the metropolitan area or nonmetropolitan county in which the Section 3 covered assistance is expended and show income does not exceed the local HUD income limits set forth for low- or very low-income householdsSection 3 Business Concerns are one of the following:Businesses that are fifty-one percent (51%) or more owned by Section 3 residents; orBusinesses whose permanent, full-time employees include persons, at least thrity (30%) of whom are currently Section 3 residents, or within three (3) years of the date of first employment with the firm were Section 3 residents; orBusinesses that provide evidence of a commitment to subcontract in excess of twenty-five percent (25%) of the dollar amount of all subcontracts to be awarded to businesses that meet the qualifications described above.
20Chapter Eight: Income verification All households must be income eligible to receive assistanceEach applicant must receive an income verificationIHCDA uses the Part 5 definition of income which looks at the gross household income anticipated for the coming 12-month periodOwner-Occupied RehabilitationHouseholds must be income eligible at the time the construction contract is executedRental ProjectsHouseholds must be income eligible at the time the lease is executedWhen do income verifications expire?Income verifications are good for 6 months from the date of the initial certification.If more than 6 months lapse, the household income must be re-verifiedFor rental developments funded in conjunction with LIHTC’s, income verifications are good for 120 days from the date of initial certification.If more than 120 days lapse, the household income must be re-verifiedFor rental projects, tenant income must also be re-verified on an annual basis
21Chapter Eight: Income verification Record KeepingRecipients are expected to keep the following information in each beneficiary/tenant file:Beneficiary application for assistanceTenant Eligibility Questionnaire (Exhibit D)Tenant Income Certification Form (Exhibit C)All sources of income w/ supporting documentation (wages, Social Security, child support, etc.)3rd party verifications are preferredWhen utilizing paycheck stubs as support documentation, you must obtain the number of paystubs that cover three (3) consecutive months of paymentsAll sources of assets w/ supporting documentation (checking, savings, CD’s, etc.)Receipt of the applicable brochures (Fair Housing, Lead Based Paint)Initial and subsequent leases (Rental Only)For tenants receiving rental assistance, a copy of the contract showing the amount of rental assistance being receivedAny other documentation verifying the beneficiaries’ eligibility (i.e. joint custody of a child documentation, all management clarification documents, etc.)After 3rd party verifications are preferred bullet point….discuss 2nd party verifications and self-certifications.
22Chapter Eight: Income verification Income Inclusions/ExclusionsPages of the SIP Compliance ManualAsset Inclusions/ExclusionsPage of the SIP Compliance ManualTreatment of AssetsImputed Income from Assets vs. Actual Income from AssetsImputed Income from AssetsIf the total cash value of all assets is greater than $5,000, multiply that amount by the HUD passbook savings rate which is currently 2%Actual Income from AssetsThe actual income generated by the asset through interest, dividends, etc.The greater of the imputed income from assets and the actual income from assets is the figure used in the total household income calculationRent and Income LimitsThe current rent and income limits can be found on our website at
23Chapter Nine: Labor Standards (Davis Bacon) Applicability of Davis Bacon Requirements1) The rehabilitation or new construction of a residential property containing eight (8) or more units in a CDBG undertakingTherefore, if CDBG funds finance only a portion of the construction work, labor standards are applicable to the entire projectProperty is defined as one or more buildings on an undivided lot or on contiguous lots or parcels, which are commonly owned and operating as one rental, cooperative, or condominium project2) The construction, alteration and/or repair, or painting of a public building or facilityAny construction work on non-residential property valued at more than $2,000Additionally, all migrant seasonal farm worker housing projects are required to pay Davis Bacon prevailing wage ratesTypes of Wage DecisionsResidential ConstructionIncludes the construction, alteration, or repair of single-family houses, apartment buildings of no more than 4 stories in height
24Chapter nine: Labor Standards (davis bacon) Building ConstructionIncludes construction of sheltered enclosures with walk-in access for the purpose of housing persons, machinery, and equipment or suppliesHeavy/Highway ConstructionThese are projects that do not typically fall under residential or building constructionExamples include work on bridges, water and sewer line projects, alteration or repair of roads, streets, highwaysMay be applicable to residential developments of five stories or moreRequesting a Wage Decision/Additional ClassificationsRequest a wage decision from your compliance auditor using Exhibit BWhen requesting additional classifications we need the following info:Job titleWage rate and fringe benefits you are seeking for this classificationDetailed description of type of work being completedUse of Apprentices and TraineesMust be registered in a bona fide apprenticeship or training program registered with the US Department of Labor or a Department of Labor –recognized State Apprenticeship Council
25Chapter nine: Labor Standards (davis Bacon) The allowable ratio of apprentices and trainees to journeymen on the job site is the allowable ratio under the approved programWeekly Certified Payroll ReportsMust be kept on Department of Labor payroll form WH-347 (Exhibit M)Must be completed every week by every contractor/subcontractor working on the project through completionMust show every employee and trade that worked on the project for every week through completionFringe BenefitsEligible and ineligible fringe benefits can be found on pages of the SIP Compliance ManualEmployee InterviewsIHCDA requires a minimum of 10% of each trade working on the project be interviewed using Form HUD-11 (Exhibit O)
26Chapter Nine: Labor Standards (Davis-Bacon) Interim monitoring requirementsHalfway through the award term or at 50% of funds drawn, whichever is sooner, IHCDA will conduct an interim monitoring to ensure compliance with the labor standards provisionsAny issues found must be addressed before additional claims to IHCDA will be released for paymentRestitution RequirementsOutlined on page 89 of the SIP Compliance ManualRetainage RequirementsIHCDA will hold the final $5,000 of your award until the final monitoring has been completed and all findings and concerns associated with it have been resolved.Other important informationLabor Standards OfficerThis is the person your organization will select to administer and enforce the Federal labor standards provisions (Exhibit A)
27Chapter Nine: Labor Standards (Davis Bacon) Pre-Bid ConferenceShould be held by the recipient/architect approximately three (3) weeks prior to bid openingShould discuss the Davis Bacon requirements as well as the construction/rehabilitation that needs to be completed with all contractors planning to bid on the projectPre-Construction ConferenceMust be conducted prior to any construction work beginningWill be given by your IHCDA Compliance AuditorEvery contractor/subcontractor must be presentWage Decision UpdateThe day prior to bid opening, submit the wage decision update verification form (Exhibit D) to your IHCDA Compliance Auditor to verify the wage decision has not been modifiedAll contracts must include the following documents:Federal Labor Standards Provisions (Exhibit C)Wage DecisionAny additional classifications (if applicable)Federal Contract Provisions (Exhibit F)Davis Bacon Contract Provisions (Exhibit G)
28Chapter nine: labor standards (davis bacon) Rules to ConsiderContract Work Hours and Safety Standard Act - requires that workers receive “overtime” compensation at a rate of 1 1/2 times their regular hourly wage after they have worked 40 hours in one week.Copeland “Anti-Kickback” Act – employees paid once a week. Employer must submit weekly payroll and compliance documentationDavis Bacon Act - requires that workers receive no less than the prevailing wages being paid for similar work
29Chapter eleven: procurement Any procurement action that takes place for the award regardless of the funding source must follow the outlined procurement process.Local Units of Government (LUG) are governed by the following laws:Applicable Federal RegulationsCFR Part 85OMB Circular A-110OMB Circular A-87Applicable Indiana Procurement LawsPublic Purchases Law (IC )Public Works Law (IC )If the LUG is the award recipient, the local unit of government’s procurement standards must be followed.A subrecipient or award administrator working on behalf of the LUG must still utilize these procurement standards.Procurement Methods for LUGsCompetitive Sealed BidsCompetitive Negotiation MethodSmall Purchase ProceduresNon-Competitive & Sole Source Purchases
30Chapter ten: procurement Competitive Sealed BidsAll construction contracts procured by a LUG must be solicited through this methodSolicited through formal advertisingTechnical Bid Specifications, Terms, and ConditionsBidder’s List (if applicable)Bid OpeningAll bids should be read aloud and the contract awarded at a public meetingMust maintain evaluation of bids and minutes of this meetingContract is awarded to the lowest/most responsive bidderCompetitive Negotiation MethodPreparation of RFPRequest proposals from at least two qualified firmsThe RFP must be publicizedEvaluate the proposalsEstablish criteria prior to evaluationScoring encouraged for objectivityNegotiate with at least two firmsEstablish a Contract File
31Chapter Ten: procurement Small Purchase ProceduresFor services, supplies, and materials under $25,000At least two quotes – at least one from MBE/WBE firmNon-Competitive & Sole Source PurchasesMay only be used under the following circumstances:When public urgency prohibits delays in the competitive bid processThe needed material or service is available from only one sourceCompetition is determined inadequate after a number of sources have been solicitedProcurement by Not-for-Profit OrganizationsGoverned by the following federal requirements:CFR Part 84OMB Circular A-110Required to follow competitive procurement proceduresMay choose to follow their own procurement standards or the local unit of government procurement standardsIf utilizing your own procurement standards they MUST be pre-approved by IHCDA
32Chapter ten: procurement Procurement by For-Profit OrganizationsSole-Source ProcurementA cost-price analysis must be done to ensure that the bid is in line with reasonable and customary charges for similar workCompetitive ProcurementAwards made as grants or forgivable loansMay be done by competitive negotiation and does not require publicationAwards made as loansFollows the same process as is outlined for grants, however, if the for-profit wishes to select a bid other than the lowest and most responsive they must pay the difference between the lowest and most responsive received and the bid actually selectedException to Procurement by For-Profit and Not-for-Profit OrganizationsHOME, CDBG, and Development Fund projects funded in conjunction with Section 42 Rental Housing Tax Credits (RHTCs).Other RequirementsMBE/WBEAt least 2 MBE/WBE firms must be solicited with each procurement action
33Chapter ten: Procurement InsuranceAward recipients will be required to provide proof of adequate builder’s risk insurance during construction and property insurance following construction for the assisted property throughout the affordability period of the awardBonding RequirementsApplicable to any construction contracts or subcontracts exceeding $100,000 and require:A bid guarantee from each bidder equivalent to 5% of the bid priceA performance bond on the part of the contractor for 100% of the contract priceA payment bond on the part of the contractor for 100% of the contract price; ORIn lieu of acquiring the payment and performance bonds, IHCDA will accept an irrevocable line of credit equal to the greater of the award amount or 25% of the total construction contractRequired Contract ProvisionsPages of the SIP Compliance ManualContractor VerificationPrior to bid award, grantees must verify that all contractors that are bidding on the project are not listed on the HUD debarred lists (Exhibit C)
34Chapter eleven: Environmental and Section 106 Historic Reviews Guidance on completing the Environmental and Section 106 Historic Reviews can be found in Chapter 11 of the SIP Compliance ManualExhibit A – Environmental Review ProcessExhibit B – Environmental Review FormsThe Section 106 Historic Review is now found within the forms (Exhibit G, Part 3-5) and is no longer a separate processExhibit G exception for OOR projectsPart 3 – Sample NoticesExhibit D – Resources ListKeep in mind that both of these processes MUST be completed prior to executing any contracts.An IHCDA release of funds letter will not be issued until the Environmental Review process is complete. This means:For not-for-profit and for-profit recipients IHCDA has approved your Environmental Review record, the legal notice has been published, and a release of funds from HUD has been receivedFor local unit of government recipients IHCDA has approved your Environmental Review Record, the legal notice has been published, and the comment period in that legal notice has expired
35Chapter thirteen: modifications Possible reasons for requesting a modifications:Change an award ending dateChange in project activities, site or areaReallocation of funds budgeted between approved activitiesChange in the use of principal and interest payments received by the recipientChange in private sector participants, investments, or housing goalsChange in any conditions listed in your award agreementThese requests should be sent to your Real Estate Production Analyst
36Chapter fourteen: construction standards All housing that is constructed or rehabilitated must meet the stricter of the Indiana State Building Code, local building code, or manufacturer’s instructionsRequirements for Physical Inspections on assisted propertiesMust be inspected twice during the award termThe first inspection will occur at the completion of the documented scope of work and prior to the IHCDA inspector’s final physical inspectionThis inspection must be completed by a licensed home inspector, engineer, or architectIf the paid staff of the recipient completes the work on the home, an outside third party inspector must be usedIf an outside contractor is procured to complete the work then the staff of the recipient will be permitted to complete the inspectionThe second inspection will be conducted upon completion of the construction of the award by your IHCDA InspectorWho can conduct third party inspections?The required inspection must be completed by a licensed residential housing inspector, engineer, or architect who has a current license with the State of Indiana Professional Licensing Agency (PLA).For information on who is licensed, how to become licensed, or how to renew/update your license, please visit the PLA website atFor OOR projects only a waiver may be requested
37Chapter fifteen: lien and restrictive covenants & affordability requirements Affordability Period - The period of time that an assisted unit must remain affordable to identified levels of low- or moderate-income persons.Begins on the date of closeoutAffordability periods can be found on pages 118 – 119 of the SIP Compliance ManualSubsidies must be secured by a written, legally binding, recorded Lien and Restrictive Covenant Agreement (LRCA).Will be given to you with your award documentsThe recipient is responsible for filing the LRCA and any amendments hereto in the Office of the Recorder of the County in which the project is locatedOwner-Occupied Rehabilitation projectsThe final claim of the recipient will be held until IHCDA receives a copy of the executed and recorded LRCA for all assisted units under the awardRental projectsIHCDA will not issue a release of funds letter until a copy of the executed and recorded LRCA has been receivedRental Housing Compliance and ReportingGuidance on rental housing compliance and ongoing reporting requirements can be found in the compliance manuals available on our website at
38Chapter sixteen: Program monitoring and record retention IHCDA Closeout MonitoringThis is completed by an IHCDA Compliance Auditor prior to the closeout of your award to ensure compliance with federal and state rules and regulationsIHCDA will hold the final $5,000 of an award until both the final monitoring and final inspection have been completed and all findings and concerns associated with them have been resolvedIHCDA Interim MonitoringWill be required for Davis-Bacon projects halfway through the award term or at 50% of funds drawn, whichever is soonerMay also be required on a case-by-case basis if IHCDA deems necessaryOngoing Compliance MonitoringAll rental projects will be subject to ongoing compliance monitoring throughout their affordability period. Will consist of:A review of annual owner certifications of compliancePeriodic onsite or desktop tenant file auditsRecord Retention and Custodial RequirementsFinancial Records, supporting documents, statistical records, and all other records pertinent to an award shall be retained for a period of five (5) years