Are all contractors required to provide their project workforce (Employee list) at the start of the project or award of contract to lock in all anticipated staff? If so, and they do not have any, or the number of Section 3 employees to come close to or begin to meet the 25% and 5%, what exactly are the requirements when they are filling any newly created positions? Is any sort of notice required to Section 3 persons/businesses before they fill the positions/sub-contracts?

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Response From HUD:

No. Total labor hours are assessed at project completion and some program areas will require periodic reporting and compliance updates. 

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