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MWBE & Section 3

Utilization plans, subcontractor tracking, hiring and reporting — the obligations that are judged on evidence rather than intention.

Two obligations, one discipline

Both are measured, and both are reported.

Section 3 is HUD's requirement that economic opportunity created by covered assistance flows, to the greatest extent feasible, to low- and very low-income persons and to businesses that employ them. It attaches to construction and to other covered work, and it is reported against.

MWBE programs set participation goals for minority and women-owned business enterprises on public contracts. The specifics vary by jurisdiction and agency, and New York City and New York State each run their own.

The two are different obligations with a shared practical problem: the effort happens across a project and the evidence has to be assembled continuously, because it cannot be reconstructed afterwards.

Talk it through
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What we do

From plan to reported outcome.

01

Planning

  • Utilization plans and participation goals
  • Identifying the covered scope on a project
  • Outreach strategy to certified firms
  • Contract language that carries the obligation down the chain
02

Delivery

  • Subcontractor solicitation and documentation of outreach
  • Section 3 worker and targeted worker identification
  • Hiring, training and qualification records
  • Payment and participation tracking against goals
03

Reporting

  • Periodic reporting in the format the agency requires
  • Evidence packages that survive an audit
  • Good-faith-effort documentation where goals are not met
  • Responses to agency questions and findings
04

Certification support

  • MWBE certification applications and renewals
  • Coordinating certification with PASSPort and SAM.gov profiles
  • Maintaining supporting documentation

Good-faith effort is a documented thing, not a felt thing. Where participation goals are not met, what protects the contractor is a record of outreach — who was contacted, when, how, and what came back. Assembled at the end, that record is thin. Assembled as it happens, it is the difference between a finding and a closed item.

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