Response From HUD:
Under the statute, employers receiving funds are required to make employment opportunities available to low- and very low-income individuals.
So, if a contractor receives Section 3 funds, that contractor would need to reevaluate the current workforce and possibly certify existing workers as Section 3 workers OR hire Section 3 workers to meet benchmarks.
Again, if benchmarks are unable to be met, the recipient can show qualitative measures to meet safe harbor. §75.15(b) and §75.25(b)