FAQs - Recordkeeping and Reporting
Q. What are the recordkeeping requirements of Section 3 recipient agencies?
Documentation of actions taken to comply with the employment, training and contracting requirements of Section 3, the results of actions taken and impediments encountered. Recipient agencies should maintain records of job vacancies, solicitation for bids or proposals, selection materials, and contract documents (including scope of work and contract amount), in accordance with Federal or State procurement laws and regulations. The documentation should demonstrate efforts taken towards the achievement of the Section 3 numerical goals.
Q. Who is required to submit Section 3 reports?
Each direct recipient of Section 3 covered HUD financial assistance shall submit an annual report for the purpose of determining the effectiveness of Section 3. Section 3 summary reports, form HUD 60002, are required even if the recipient agency did not undertake any activities that triggered the requirements. Subrecipients, developers, and contractors should not submit Section 3 annual reports directly to the Department.
Q. Where should Section 3 summary reports (Form HUD 60002) be submitted?
The Department has developed an online reporting system to allow grantees to submit Section 3 reports (form HUD 60002) directly to FHEO. Reports should be submitted online at: hud.gov/section3 from the Section 3 website.
Q. After an agency submits its Section 3 report online, should a hard copy of the form also be submitted to HUD by fax, email, or mail?
No. Since the Department has an online reporting system, it s not necessary for agencies to submit hard copies (or paper copies) of reports to FHEO. The Department is making an effort to go "paperless" and wants to reduce paper submissions of Section 3 reports.
However, it is recommended that grantees retain a copy of their completed Section 3 reports on file and optionally submit them as an attachment to their annual performance report if applicable (CAPERS report for CDBG, HOME and ESG Programs).
Q. Are contractors or developers required to submit Section 3 reports directly to HUD?
No. Contractors and/or developers should not submit Section 3 reports to HUD. Only direct recipients (agencies) are required to submit Section 3 reports to HUD. Contractors should maintain adequate documentation to demonstrate compliance with Section 3 and forward information to the direct recipient (i.e., the agency that awarded them a covered contract) as directed or upon request.
Q. Should recipient agencies establish a reporting system for their contractors and subcontractors?
Yes, reports complied by contractors and subcontractors will assist the recipient agency in gathering the necessary data for submission to HUD.
Q. When are Section 3 annual reports (Form HUD 60002) due?
Depending on the source of funding, annual reports should be submitted at one of three times:
- At the time the recipient submits an annual performance report;
- By January 10 of each year if no program annual performance report is required; or
- Within ten (10) days of project completion, whichever is earlier.
- PHAs should submit form HUD60002 by January 10th.
- Grantees Awarded funding for Section 202/811 should submit form HUD 60002 by January 10th.
- Grantees Awarded funding for CDBG, HOME and/or ESG should submit form HUD 60002 at the same time they submit the CAPER report.
- Grantees Awarded funding for lead abatement activities should submit form HUD 60002 with their annual reports no later than September 30th.
Q. Where can I find instructions for completing form HUD 60002?
Instructions for completing form HUD 60002 can be found on the Section 3 website at hud.gov/section3. Additional technical assistance for completing form HUD 60002 can be obtained by submitting an email request to HUD Section 3.
Q. How can a recipient agency request a copy, make corrections, or delete its own Section 3 annual report?
The recipient agency should submit an email request to [email protected]. Requests should contain the agency's name along with the year, grant number, and dollar amount of the report in question.
Q. How can I obtain copies of 60002 reports for another local recipient agency?
Copies of 60002 reports for local recipient agencies for which you are not affiliated with can be obtained by completing and submitting a Freedom of Information Act (FOIA) request at: hud.gov/program_offices/administration/foia/requests
Q. Are agencies required to submit Form HUD 2516 to demonstrate compliance with Section 3?
No. Agencies are not required to submit Form HUD 2516 to demonstrate compliance with Section 3. In addition, while Form HUD 2516 does capture some Section 3 data, it is not sufficient to demonstrate overall compliance to the Department. The only form that should be submitted for Section 3 reporting requirements is form HUD 60002.