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(1) Records providing a full description of each activity undertaken; <br />(2) Records demonstrating that each activity undertaken meets one of the National <br />Objectives of the CDBG program set forth in 24 CFR Part 570.208; <br />(3) Records required determining the eligibility of activities; <br />(4) Records required to document the acquisition, improvement, use or disposition of <br />real property acquired or improved with CDBG assistance; <br />(5) Records documenting compliance with the fair housing and equal opportunity <br />components of the CDBG program; <br />(6) Financial records as required by 24 CFR Part 570.502, and Part 84; and <br />(7) Other records necessary to document compliance with Subpart K of 24 CFR 570. <br />b, Retention. The Subrecipient shall retain all records pertinent to expenditures incurred under <br />this contract for a period of four (4) years after the termination of all activities funded under this agreement, or after <br />the resolution of all Federal audit findings, whichever occurs later. Records for non-expendable property acquired <br />with funds under this contract shall be retained for four (4) years after final disposition of such property. Records for <br />any displaced person must be kept for four years after he/she has received final payment. <br />7.3 Client Data. The Subrecipient shall maintain client data demonstrating client eligibility for services <br />provided. Such data shall include, but not be limited to, client name, address, income level or other basis for <br />determining eligibility, and description of service provided. Such information shall be made available to City of San <br />Leandro monitors or their designees for review upon request. <br />7.4 Disclosure. The Subrecipient understands that client information collected under this contract is <br />private and the use or disclosure of such information, when not directly connected with the administration of the City <br />of San Leandro's or Subrecipient's responsibilities with respect to services provided under this contract, is prohibited <br />by law unless written consent is obtained from such person receiving service and, in the case of a minor, that of a <br />responsible parent/guardian. <br />7.5 Property Records. The Subrecipient shall maintain real property inventory records that clearly <br />identify properties purchased, improved or sold. Properties retained shall continue to meet eligibility criteria and <br />shall conform with the "changes in use" restrictions specified in 24 CFR Parts 570.503(b)(8). <br />7.6 National Objectives. The Subrecipient agrees to maintain documentation that demonstrates that <br />the activities carried out with funds provided under this contract meet one or more of the CDBG program's national <br />objectives: (a) benefit low/moderate income persons, (b) aid in the prevention or elimination of slums or blight, (c) <br />meet community development needs having a particular urgency (as defined in 24 CFR Part 570.208). <br />7.7 Performance Monitoring. The City of San Leandro will monitor the performance of the <br />Subrecipient against goals and performance standards required herein. Substandard performance as determined <br />by the City of San Leandro will constitute non-compliance with this agreement. If action to correct such substandard <br />performance is not taken by the Subrecipient within a reasonable period of time after being notified by the City of <br />San Leandro, contract suspension or termination procedures will be initiated. <br />7.8 Close-Outs. Subrecipient obligation to the City of San Leandro shall not end until all closeout <br />requirements are completed. Activities during this closeout period shall include, but are not limited to: making final <br />payments, disposing of program assets (including the return of all unused materials, equipment, unspent cash <br />advances, program income balances, and receivable accounts to the City of San Leandro), and determining the <br />custodianship of records. <br />7.9 Audits and Inspections. All Subrecipient records with respect to any matters covered by this <br />agreement shall be made available to the City of San Leandro, grantor agency, their designees or the Federal <br />-9- <br />Agreementfor ECHO Fair Housing Services, FY 2008-09 <br />G: I COMMUNITYDEVELOPMEN7lffOUSING SERVICES DIVISIOMCDBGISUBRECIPIENTSIECHOIFY08-091Fair HousinglFY08-09 ECHO CDBG Subrecipient <br />,4greement - Fnir Housing Counseling.doc <br />