JAG 2025-Subrecipient Agreement — Chino City Council, October 6, 2026

San Bernardino County
385 North Arrowhead Avenue
San Bernardino, CA 92415-0120
Law and Justice Group
909-387-5005
Grant
Sub-Award
PAGE 1 OF ϯϬ
AWARD NUMBER: 15PBJA-25-GG-03553-JAGX
SUB-AWARD NUMBER: 15PBJA-23-GG-03189-JAGX-Chino
AWARD DATE 7/31/2026
PREVIOUS AWARD AMOUNT $0
AMOUNT OF THIS AWARD $21,239
TOTAL SUB-AWARD $21,239
__________________________________________________ __________________________________________________

DATE DATE
__________________________________________________ __________________________________________________

SIGNATURE OF APPROVING OFFICIAL SIGNATURE OF AUTHORIZED SUBRECIPIENT OFFICIAL Brent Martin, Chair
San Bernardino County Law and Justice Group

GRANTEE APPROVAL SUBRECIPIENT ACCEPTANCE

TYPED NAME AND TITLE OF APPROVING OFFICIAL TYPED NAME AND TITLE OF AUTHORIZED SUBRECIPIENT Linda Reich, ŝƚǇ Manager
ŝƚǇŽĨChino
Title I of Public Law 90-351 (generally codified at 34 U.S.C. 10101-10726), including subpart 1 of part E (codified at 34 U.S.C. 10151-10158); see also 28 U.S.C. 530C(a)
CATALOG OF DOMESTIC FEDERAL ASSISTANCE (CFDA Number)

16.738 - Edward Byrne Memorial Justice Assistance Grant Program

SPECIAL CONDITIONS

THE ABOVE GRANT PROJECT IS APPROVED SUBJECT TO SUCH CONDITIONS OR LIMITATIONS AS ARE SET FORTH ON THE ATTACHED PAGE(S), WHICH INCLUDE THE AWARD CONDITIONS (PAGES ϮͲϮϲ), AND THE SUBRECIPIENT MONITORING PROCEDURES FOR THE COUNTY OF SAN BERNARDINO LAW AND JUSTICE GROUP (PAGES ϮϳͲϯϬ).

STATUTORY AUTHORITY FOR GRANT

PROJECT TITLE
San Bernardino County and Disparate Jurisdictions 2025 Justice Assistance Grant Projects
SUBRECIPIENT UEI NO.

RGVNGHJR3NV5
SUBRECIPIENT IRS/VENDOR NO. PROJECT PERIOD: FROM 10/01/2024 TO 09/30/2028 95-0930239 BUDGET PERIOD: FROM 10/01/2024 TO 09/30/2028 City of Chino
13220 Central Avenue
Chino, CA 91710-4127
SUBRECIPIENT NAME AND ADDRESS (Including Zip Code)
1 Compliance with general appropriations-law restrictions on the use of federal funds (FY 2025)
The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable restrictions on the use of federal funds set out in federal appropriations statutes. Pertinent restrictions that may be set out in applicable appropriations acts are indicated at
https://ojp.gov/funding/Explore/FY25AppropriationsRestrictions.htm, and are incorporated by reference here.

Should a question arise as to whether a particular use of federal funds by a recipient (or a subrecipient) would or might fall within the scope of an appropriations-law restriction, the recipient is to contact OJP for guidance, and may not proceed without the express prior written approval of OJP.

Compliance with DOJ regulations pertaining to civil rights and nondiscrimination - 28 C.F.R. Part 38
The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable requirements of 28 C.F.R. Part 38.

Among other things, 28 C.F.R. Part 38 states that recipients may not use direct Federal financial assistance from the Department of Justice to support or engage in any explicitly religious activities except when consistent with the Establishment Clause of the First Amendment to the U.S. Constitution and any other applicable requirements. An organization receiving Federal financial assistance also may not, in providing services funded by the Department of Justice or in outreach activities related to such services, discriminate against a program beneficiary or prospective program beneficiary on the basis of religion, a religious belief, a refusal to hold a religious belief, or refusal to attend or participate in a religious practice. Part 38 also sets out rules and requirements that pertain to recipient and subrecipient ("subgrantee") organizations that engage in or conduct explicitly religious activities, as well as rules and requirements that pertain to recipients and subrecipients that are faith-based or religious organizations. In addition, Part 38 states that a faithbased organization that participates in a Department of Justice funded program retains its independence from the Government and may continue to carry out its mission consistent with religious freedom and conscience protections in Federal law.

Recipients and subrecipients that provide social services under this award must give written notice to beneficiaries and prospective beneficiaries prior to the provision of services (if practicable) which shall include language substantially similar to the language in 28 CFR Part 38, Appendix C, sections (1) through (4). A sample written notice may be found at https://www.ojp.gov/program/civil-rights-office/partnerships-faith-based-andother-neighborhood-organizations.

In certain instances, a faith-based or religious organization may be able to take religion into account when making hiring decisions, provided it satisfies certain requirements. For more information, see “Nondiscrimination provisions and the Religious Freedom Restoration Act,” accessible at https://www.ojp.gov/funding/explore/legaloverview2025/civilrightsrequirements. 1 2
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https://justgrants.usdoj.gov/prweb/PRAuth/app/JGITS/3yZ6Bxxi_lpDExTOT4XnAjzjAXmVNevW*/!STANDARD 2 Requirements pertaining to prohibited conduct related to trafficking in persons (including reporting requirements and OJP authority to terminate award) The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable requirements (including requirements to report allegations) pertaining to prohibited conduct related to the trafficking of persons, whether on the part of recipients, subrecipients ("subgrantees"), or individuals defined (for purposes of this condition) as "employees" of the recipient or of any subrecipient.

The details of the recipient's obligations related to prohibited conduct related to trafficking in persons are posted on the OJP web site at https://ojp.gov/funding/Explore/ProhibitedConduct-Trafficking.htm (Award condition: Prohibited conduct by recipients and subrecipients related to trafficking in persons (including reporting requirements and OJP authority to terminate award)), and are incorporated by reference here.

All subawards ("subgrants") must have specific federal authorization The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable requirements for authorization of any subaward. This condition applies to agreements that -- for purposes of federal grants administrative requirements -- OJP considers a "subaward" (and therefore does not consider a procurement "contract").

The details of the requirement for authorization of any subaward are posted on the OJP website at https://ojp.gov/funding/Explore/SubawardAuthorization.htm (Award condition: All subawards ("subgrants") must have specific federal authorization), and are incorporated by reference here.

Specific post-award approval required to use a noncompetitive approach in any procurement contract that would exceed the Simplified Acquisition Threshold
The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable requirements to obtain specific advance approval to use a noncompetitive approach in any procurement contract that would exceed the Simplified Acquisition Threshold, as set forth in the Federal Acquisition Regulations (FAR). See the definition of simplified acquisition threshold in the FAR at 48 CFR part 2, subpart 2.1. This condition applies to agreements that - - for purposes of federal grants administrative requirements -- OJP considers a procurement "contract" (and therefore does not consider a subaward).

The details of the requirement for advance approval to use a noncompetitive approach in a procurement contract under an OJP award are posted on the OJP website at
https://ojp.gov/funding/Explore/NoncompetitiveProcurement.htm (Award condition: Specific post-award approval required to use a noncompetitive approach in a procurement contract (if contract would exceed Simplified Acquisition Threshold)), and are incorporated by reference here.

Federal Civil Rights and Nondiscrimination Laws (certification) The recipient agrees that its compliance with all applicable Federal civil rights 4 5
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https://justgrants.usdoj.gov/prweb/PRAuth/app/JGITS/3yZ6Bxxi_lpDExTOT4XnAjzjAXmVNevW*/!STANDARD 3 and nondiscrimination laws is material to the government's decision to make this award and any payment thereunder, including for purposes of the False Claims Act (31 U.S.C. 3729-3730 and 3801-3812), and, by accepting this award, certifies that it does not operate any programs (including any such programs having components relating to diversity, equity, and inclusion) that violate any applicable Federal civil rights or nondiscrimination laws.

Requirements of the award; remedies for non-compliance or for materially false statements
The conditions of this award are material requirements of the award.

Compliance with any assurances or certifications submitted by or on behalf of the recipient that relate to conduct during the period of performance also is a material requirement of this award.

Limited Exceptions. In certain special circumstances, the U.S. Department of Justice ("DOJ") may determine that a legal notice regarding award requirements is necessary or that it will not enforce, or enforce only in part, one or more requirements otherwise applicable to the award. Any such notice or exception regarding enforcement, including any such notice or exception made during the period of performance, is (or will be during the period of performance) set out through the Office of Justice Programs ("OJP") webpage entitled "Legal Notices: Special circumstances as to particular award conditions" (ojp.gov/funding/Explore/LegalNotices-AwardReqts.htm), and incorporated by reference into the award.

By signing and accepting this award on behalf of the recipient, the authorized recipient official accepts all material requirements of the award, and specifically adopts, as if personally executed by the authorized recipient official, all assurances or certifications submitted by or on behalf of the recipient that relate to conduct during the period of performance.

Failure to comply with one or more award requirements -- whether a condition set out in full below, a condition incorporated by reference below, or an assurance or certification related to conduct during the award period -- may result in OJP taking appropriate action with respect to the recipient and the award. Among other things, the OJP may withhold award funds, disallow costs, or suspend or terminate the award. DOJ, including OJP, also may take other legal action as appropriate.

Any materially false, fictitious, or fraudulent statement to the federal government related to this award (or concealment or omission of a material fact) may be the subject of criminal prosecution (including under 18 U.S.C. 1001 and/or 1621, and/or 34 U.S.C. 10271-10273), and also may lead to imposition of civil penalties and administrative remedies for false claims or otherwise (including under 31 U.S.C. 3729-3730 and 3801-3812).

Should any provision of a requirement of this award be held to be invalid or unenforceable by its terms, that provision shall first be applied with a limited construction so as to give it the maximum effect permitted by law. Should it be held, instead, that the provision is utterly invalid or -unenforceable, such provision shall be deemed severable from this award.

Effect of failure to address audit issues
The recipient understands and agrees that the DOJ awarding agency (OJP or 7 8
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https://justgrants.usdoj.gov/prweb/PRAuth/app/JGITS/3yZ6Bxxi_lpDExTOT4XnAjzjAXmVNevW*/!STANDARD 4 OVW, as appropriate) may withhold award funds, or may impose other related requirements, if (as determined by the DOJ awarding agency) the recipient does not satisfactorily and promptly address outstanding issues from audits required by the Part 200 Uniform Requirements (or by the terms of this award), or other outstanding issues that arise in connection with audits, investigations, or reviews of DOJ awards.

Applicability of Part 200 Uniform Requirements
The Uniform Administrative Requirements, Cost Principles, and Audit Requirements in 2 C.F.R. Part 200, as adopted and supplemented by DOJ in 2 C.F.R. Part 2800 (together, the "Part 200 Uniform Requirements"), including, without limitation, the provisions regarding termination in 2 C.F.R. 200.340, apply to this award from OJP.

For more information and resources on the Part 200 Uniform Requirements as they relate to OJP awards and subawards ("subgrants"), see the OJP website at https://ojp.gov/funding/Part200UniformRequirements.htm.

Record retention and access: Records pertinent to the award that the recipient (and any subrecipient ("subgrantee") at any tier) must retain -- typically for a period of 3 years from the date of submission of the final expenditure report (SF 425), unless a different retention period applies -- and to which the recipient (and any subrecipient ("subgrantee") at any tier) must provide access, include performance measurement information, in addition to the financial records, supporting documents, statistical records, and other pertinent records indicated at 2 C.F.R. 200.334.

In the event that an award-related question arises from documents or other materials prepared or distributed by OJP that may appear to conflict with, or differ in some way from, the provisions of the Part 200 Uniform Requirements, the recipient is to contact OJP promptly for clarification.

Reporting potential fraud, waste, and abuse, and similar misconduct The recipient, and any subrecipients ("subgrantees") at any tier, must promptly refer to the DOJ Office of the Inspector General (OIG) any credible evidence that a principal, employee, agent, subrecipient, contractor, subcontractor, or other person has, in connection with funds under this award-- (1) submitted a claim that violates the False Claims Act; or (2) committed a criminal or civil violation of laws pertaining to fraud, conflict of interest, bribery, gratuity, or similar misconduct.

Potential fraud, waste, abuse, or misconduct involving or relating to funds under this award should be reported to the OIG by--(1) online submission accessible via the OIG webpage at https://oig.justice.gov/hotline/contactgrants.htm (select "Submit Report Online"); (2) mail directed to: U.S.

Department of Justice, Office of the Inspector General, Investigations Division, ATTN: Fraud Detection Office, 950 Pennsylvania Ave., NW, Washington, DC 20530; and/or (3) by facsimile directed to the DOJ OIG Investigations Division (Attn: Grantee Reporting) at (202) 616-9881 (fax).

Additional information is available from the DOJ OIG website at https://oig.justice.gov/hotline.
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https://justgrants.usdoj.gov/prweb/PRAuth/app/JGITS/3yZ6Bxxi_lpDExTOT4XnAjzjAXmVNevW*/!STANDARD 5 Requirements related to "de minimis" indirect cost rate A recipient that is eligible under the Part 200 Uniform Requirements and other applicable law to use the "de minimis" indirect cost rate described in 2 C.F.R. 200.414(f), and that elects to use the "de minimis" indirect cost rate, must advise OJP in writing of both its eligibility and its election, and must comply with all associated requirements in the Part 200 Uniform Requirements. The "de minimis" rate may be applied only to modified total direct costs (MTDC) as defined by the Part 200 Uniform Requirements.

Compliance with applicable rules regarding approval, planning, and reporting of conferences, meetings, trainings, and other events
The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable laws, regulations, policies, and official DOJ guidance (including specific cost limits, prior approval and reporting requirements, where applicable) governing the use of federal funds for expenses related to conferences (as that term is defined by DOJ), including the provision of food and/or beverages at such conferences, and costs of attendance at such conferences.

Information on the pertinent DOJ definition of conferences and the rules applicable to this award appears in the DOJ Grants Financial Guide (currently, as section 3.10 of "Postaward Requirements" in the "DOJ Grants Financial Guide").

Requirement for data on performance and effectiveness under the award The recipient must collect and maintain data that measure the performance and effectiveness of work under this award. The data must be provided to OJP in the manner (including within the timeframes) specified by OJP in the program solicitation or other applicable written guidance. Data collection supports compliance with the Government Performance and Results Act (GPRA) and the GPRA Modernization Act of 2010, and other applicable laws.

Compliance with DOJ Grants Financial Guide
References to the DOJ Grants Financial Guide are to the DOJ Grants Financial Guide as posted on the OJP website (currently, the "DOJ Grants Financial Guide" available at https://ojp.gov/financialguide/DOJ/index.htm), including any updated version that may be posted during the period of performance. The recipient agrees to comply with the DOJ Grants Financial Guide.

Compliance with DOJ regulations pertaining to civil rights and nondiscrimination - 28 C.F.R. Part 42
The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable requirements of 28 C.F.R. Part 42, specifically including 28 C.F.R. § 42.106(d), 28 C.F.R. § 42.405(c), and 28 C.F.R. § 42.505(f), which 11 12
13 14
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https://justgrants.usdoj.gov/prweb/PRAuth/app/JGITS/3yZ6Bxxi_lpDExTOT4XnAjzjAXmVNevW*/!STANDARD 6 contain notice requirements that covered recipients must follow regarding the dissemination of information regarding federal nondiscrimination requirements.

Determination of suitability to interact with participating minors SCOPE. This condition applies to this award if it is indicated -- in the application for the award (as approved by DOJ)(or in the application for any subaward, at any tier), the DOJ funding announcement (solicitation), or an associated federal statute -- that a purpose of some or all of the activities to be carried out under the award (whether by the recipient, or a subrecipient at any tier) is to benefit a set of individuals under 18 years of age.

The recipient, and any subrecipient at any tier, must make determinations of suitability before certain individuals may interact with participating minors. This requirement applies regardless of an individual's employment status.

The details of this requirement are posted on the OJP web site at https://ojp.gov/funding/Explore/Interact-Minors.htm (Award condition:

Determination of suitability required, in advance, for certain individuals who may interact with participating minors), and are incorporated by reference here.

Requirement to disclose whether recipient is designated "high risk" by a federal grant-making agency outside of DOJ
If the recipient is designated "high risk" by a federal grant-making agency outside of DOJ, currently or at any time during the course of the period of performance under this award, the recipient must disclose that fact and certain related information to OJP by email at
[email protected]. For purposes of this disclosure, high risk includes any status under which a federal awarding agency provides additional oversight due to the recipient's past performance, or other programmatic or financial concerns with the recipient. The recipient's disclosure must include the following: 1. The federal awarding agency that currently designates the recipient high risk, 2. The date the recipient was designated high risk, 3. The high-risk point of contact at that federal awarding agency (name, phone number, and email address), and 4. The reasons for the high-risk status, as set out by the federal awarding agency.

Employment eligibility verification for hiring under the award

1. The recipient (and any subrecipient at any tier) must-- A. Ensure that, as part of the hiring process for any position within the United States that is or will be funded (in whole or in part) with award funds, the recipient (or any subrecipient) properly verifies the employment eligibility of the individual who is being hired, consistent with the provisions of 8 U.S.C. 1324a(a)(1).

B. Notify all persons associated with the recipient (or any subrecipient) who are or will be involved in activities under this award of both-- (1) this award requirement for verification of employment eligibility, and 16 17
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https://justgrants.usdoj.gov/prweb/PRAuth/app/JGITS/3yZ6Bxxi_lpDExTOT4XnAjzjAXmVNevW*/!STANDARD 7 (2) the associated provisions in 8 U.S.C. 1324a(a)(1) that, generally speaking, make it unlawful, in the United States, to hire (or recruit for employment) certain aliens.

C. Provide training (to the extent necessary) to those persons required by this condition to be notified of the award requirement for employment eligibility verification and of the associated provisions of 8 U.S.C. 1324a(a)(1).

D. As part of the recordkeeping for the award (including pursuant to the Part 200 Uniform Requirements), maintain records of all employment eligibility verifications pertinent to compliance with this award condition in accordance with Form I-9 record retention requirements, as well as records of all pertinent notifications and trainings.

2. Monitoring
The recipient's monitoring responsibilities include monitoring of subrecipient compliance with this condition.

3. Allowable costs
To the extent that such costs are not reimbursed under any other federal program, award funds may be obligated for the reasonable, necessary, and allocable costs (if any) of actions designed to ensure compliance with this condition.

4. Rules of construction
A. Staff involved in the hiring process
For purposes of this condition, persons "who are or will be involved in activities under this award" specifically includes (without limitation) any and all recipient (or any subrecipient) officials or other staff who are or will be involved in the hiring process with respect to a position that is or will be funded (in whole or in part) with award funds.

B. Employment eligibility confirmation with E-Verify
For purposes of satisfying the requirement of this condition regarding verification of employment eligibility, the recipient (or any subrecipient) may choose to participate in, and use, E-Verify (www.e-verify.gov), provided an appropriate person authorized to act on behalf of the recipient (or subrecipient) uses E-Verify (and follows the proper E-Verify procedures, including in the event of a "Tentative Nonconfirmation" or a "Final Nonconfirmation") to confirm employment eligibility for each hiring for a position in the United States that is or will be funded (in whole or in part) with award funds.

C. "United States" specifically includes the District of Columbia, Puerto Rico, Guam, the Virgin Islands of the United States, and the Commonwealth of the Northern Mariana Islands.

D. Nothing in this condition shall be understood to authorize or require any recipient, any subrecipient at any tier, or any person or other entity, to violate any federal law, including any applicable civil rights or nondiscrimination law.

E. Nothing in this condition, including in paragraph 4.B., shall be understood to relieve any recipient, any subrecipient at any tier, or any person or other entity, of any obligation otherwise imposed by law, including 8 U.S.C. 1324a(a)(1).

Questions about E-Verify should be directed to DHS. For more information 8/4/26, 10:13 AM Funded Award FAW-191077
https://justgrants.usdoj.gov/prweb/PRAuth/app/JGITS/3yZ6Bxxi_lpDExTOT4XnAjzjAXmVNevW*/!STANDARD 8 about E-Verify visit the E-Verify website (https://www.e-verify.gov/) or email EVerify at [email protected]. E-Verify employer agents can email E-Verify at E[email protected].

Questions about the meaning or scope of this condition should be directed to OJP, before award acceptance.

Encouragement of policies to ban text messaging while driving Pursuant to Executive Order 13513, "Federal Leadership on Reducing Text Messaging While Driving," 74 Fed. Reg. 51225 (October 1, 2009), DOJ encourages recipients and subrecipients ("subgrantees") to adopt and enforce policies banning employees from text messaging while driving any vehicle during the course of performing work funded by this award, and to establish workplace safety policies and conduct education, awareness, and other outreach to decrease crashes caused by distracted drivers.

Reclassification of various statutory provisions to a new Title 34 of the United States Code
On September 1, 2017, various statutory provisions previously codified elsewhere in the U.S. Code were editorially reclassified (that is, moved and renumbered) to a new Title 34, entitled "Crime Control and Law Enforcement." The reclassification encompassed a number of statutory provisions pertinent to OJP awards (that is, OJP grants and cooperative agreements), including many provisions previously codified in Title 42 of the U.S. Code.

Effective as of September 1, 2017, any reference in this award document to a statutory provision that has been reclassified to the new Title 34 of the U.S.

Code is to be read as a reference to that statutory provision as reclassified to Title 34. This rule of construction specifically includes references set out in award conditions, references set out in material incorporated by reference through award conditions, and references set out in other award requirements.

Restrictions and certifications regarding non-disclosure agreements and related matters
No recipient or subrecipient ("subgrantee") under this award, or entity that receives a procurement contract or subcontract with any funds under this award, may require any employee or contractor to sign an internal confidentiality agreement or statement that prohibits or otherwise restricts, or purports to prohibit or restrict, the reporting (in accordance with law) of waste, fraud, or abuse to an investigative or law enforcement representative of a federal department or agency authorized to receive such information.

The foregoing is not intended, and shall not be understood by the agency making this award, to contravene requirements applicable to Standard Form 312 (which relates to classified information), Form 4414 (which relates to sensitive compartmented information), or any other form issued by a federal department or agency governing the nondisclosure of classified information.

1. In accepting this award, the recipient--
a. represents that it neither requires nor has required internal confidentiality 19 20
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https://justgrants.usdoj.gov/prweb/PRAuth/app/JGITS/3yZ6Bxxi_lpDExTOT4XnAjzjAXmVNevW*/!STANDARD 9 agreements or statements from employees or contractors that currently prohibit or otherwise currently restrict (or purport to prohibit or restrict) employees or contractors from reporting waste, fraud, or abuse as described above; and
b. certifies that, if it learns or is notified that it is or has been requiring its employees or contractors to execute agreements or statements that prohibit or otherwise restrict (or purport to prohibit or restrict), reporting of waste, fraud, or abuse as described above, it will immediately stop any further obligations of award funds, will provide prompt written notification to the federal agency making this award, and will resume (or permit resumption of) such obligations only if expressly authorized to do so by that agency.

2. If the recipient does or is authorized under this award to make subawards ("subgrants"), procurement contracts, or both--
a. it represents that--
(1) it has determined that no other entity that the recipient's application proposes may or will receive award funds (whether through a subaward ("subgrant"), procurement contract, or subcontract under a procurement contract) either requires or has required internal confidentiality agreements or statements from employees or contractors that currently prohibit or otherwise currently restrict (or purport to prohibit or restrict) employees or contractors from reporting waste, fraud, or abuse as described above; and (2) it has made appropriate inquiry, or otherwise has an adequate factual basis, to support this representation; and
b. it certifies that, if it learns or is notified that any subrecipient, contractor, or subcontractor entity that receives funds under this award is or has been requiring its employees or contractors to execute agreements or statements that prohibit or otherwise restrict (or purport to prohibit or restrict), reporting of waste, fraud, or abuse as described above, it will immediately stop any further obligations of award funds to or by that entity, will provide prompt written notification to the federal agency making this award, and will resume (or permit resumption of) such obligations only if expressly authorized to do so by that agency.

OJP Training Guiding Principles
Any training or training materials that the recipient -- or any subrecipient ("subgrantee") at any tier -- develops or delivers with OJP award funds must adhere to the OJP Training Guiding Principles for Grantees and Subgrantees, available at https://www.ojp.gov/funding/implement/training-guiding-principlesgrantees-and-subgrantees.

Requirement to report potentially duplicative funding
If the recipient currently has other active awards of federal funds, or if the recipient receives any other award of federal funds during the period of performance for this award, the recipient promptly must determine whether funds from any of those other federal awards have been, are being, or are to be used (in whole or in part) for one or more of the identical cost items for which funds are provided under this award. If so, the recipient must promptly notify the DOJ awarding agency (OJP or OVW, as appropriate) in writing of the 22 23
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https://justgrants.usdoj.gov/prweb/PRAuth/app/JGITS/3yZ6Bxxi_lpDExTOT4XnAjzjAXmVNevW*/!STANDARD 10 potential duplication, and, if so requested by the DOJ awarding agency, must seek a budget-modification or change-of-project-scope Grant Award Modification (GAM) to eliminate any inappropriate duplication of funding.

Required training for Grant Award Administrator and Financial Manager The Grant Award Administrator and all Financial Managers for this award must have successfully completed an "OJP financial management and grant administration training" by 120 days after the date of the recipient's acceptance of the award. Successful completion of such a training on or after January 1, 2022, will satisfy this condition.

In the event that either the Grant Award Administrator or a Financial Manager for this award changes during the period of performance, the new Grant Award Administrator or Financial Manager must have successfully completed an "OJP financial management and grant administration training" by 120 calendar days after the date the Entity Administrator enters updated Grant Award Administrator or Financial Manager information in JustGrants. Successful completion of such a training on or after January 1, 2022, will satisfy this condition.

A list of OJP trainings that OJP will consider "OJP financial management and grant administration training" for purposes of this condition is available at https://onlinegfmt.training.ojp.gov/. All trainings that satisfy this condition include a session on grant fraud prevention and detection.

The recipient should anticipate that OJP will immediately withhold ("freeze") award funds if the recipient fails to comply with this condition. The recipient's failure to comply also may lead OJP to impose additional appropriate conditions on this award.

Compliance with 41 U.S.C. 4712 (including prohibitions on reprisal; notice to employees)
The recipient (and any subrecipient at any tier) must comply with, and is subject to, all applicable provisions of 41 U.S.C. 4712, including all applicable provisions that prohibit, under specified circumstances, discrimination against an employee as reprisal for the employee's disclosure of information related to gross mismanagement of a federal grant, a gross waste of federal funds, an abuse of authority relating to a federal grant, a substantial and specific danger to public health or safety, or a violation of law, rule, or regulation related to a federal grant.

The recipient also must inform its employees, in writing (and in the predominant native language of the workforce), of employee rights and remedies under 41 U.S.C. 4712.

Should a question arise as to the applicability of the provisions of 41 U.S.C. 4712 to this award, the recipient is to contact the DOJ awarding agency (OJP or OVW, as appropriate) for guidance.

Potential imposition of additional requirements
The recipient agrees to comply with any additional requirements that may be 24 25
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Requirement to report actual or imminent breach of personally identifiable information (PII)
The recipient (and any "subrecipient" at any tier) must have written procedures in place to respond in the event of an actual or imminent "breach" (OMB M-17- 12) if it (or a subrecipient) -- (1) creates, collects, uses, processes, stores, maintains, disseminates, discloses, or disposes of "Personally Identifiable Information (PII)" (2 CFR 200.1) within the scope of an OJP grant-funded program or activity, or (2) uses or operates a "Federal information system" (OMB Circular A-130). The recipient's breach procedures must include a requirement to report actual or imminent breach of PII to an OJP Program Manager no later than 24 hours after an occurrence of an actual breach, or the detection of an imminent breach.

Requirements related to System for Award Management and Universal Identifier Requirements
The recipient must comply with applicable requirements regarding the System for Award Management (SAM), currently accessible at https://www.sam.gov/.

This includes applicable requirements regarding registration with SAM, as well as maintaining the currency of information in SAM.

The recipient also must comply with applicable restrictions on subawards ("subgrants") to first-tier subrecipients (first-tier "subgrantees"), including restrictions on subawards to entities that do not acquire and provide (to the recipient) the unique entity identifier required for SAM registration.

The details of the recipient's obligations related to SAM and to unique entity identifiers are posted on the OJP web site at
https://ojp.gov/funding/Explore/SAM.htm (Award condition: System for Award Management (SAM) and Universal Identifier Requirements), and are incorporated by reference here.

This condition does not apply to an award to an individual who received the award as a natural person (i.e., unrelated to any business or non-profit organization that he or she may own or operate in his or her name).

Restrictions on "lobbying"
In general, as a matter of federal law, federal funds awarded by OJP may not be used by the recipient, or any subrecipient ("subgrantee") at any tier, either directly or indirectly, to support or oppose the enactment, repeal, modification, or adoption of any law, regulation, or policy, at any level of government. See 18 U.S.C. 1913. (There may be exceptions if an applicable federal statute specifically authorizes certain activities that otherwise would be barred by law.) Another federal law generally prohibits federal funds awarded by OJP from being used by the recipient, or any subrecipient at any tier, to pay any person to influence (or attempt to influence) a federal agency, a Member of Congress, or Congress (or an official or employee of any of them) with respect to the 27 28
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https://justgrants.usdoj.gov/prweb/PRAuth/app/JGITS/3yZ6Bxxi_lpDExTOT4XnAjzjAXmVNevW*/!STANDARD 12 awarding of a federal grant or cooperative agreement, subgrant, contract, subcontract, or loan, or with respect to actions such as renewing, extending, or modifying any such award. See 31 U.S.C. 1352. Certain exceptions to this law apply, including an exception that applies to Indian tribes and tribal organizations.

Should any question arise as to whether a particular use of federal funds by a recipient (or subrecipient) would or might fall within the scope of these prohibitions, the recipient is to contact OJP for guidance, and may not proceed without the express prior written approval of OJP.

Compliance with DOJ regulations pertaining to civil rights and nondiscrimination - 28 C.F.R. Part 54
The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable requirements of 28 C.F.R. Part 54, which relates to nondiscrimination on the basis of sex in certain "education programs." Among other items, 28 C.F.R. § 54.140 contains notice requirements that covered recipients must follow regarding the dissemination of information regarding federal nondiscrimination requirements.

The recipient understands that, in accepting this award, the Authorized Representative declares and certifies, among other things, that he or she possesses the requisite legal authority to accept the award on behalf of the recipient entity and, in so doing, accepts (or adopts) all material requirements that relate to conduct throughout the period of performance under this award.

The recipient further understands, and agrees, that it will not assign anyone to the role of Authorized Representative during the period of performance under the award without first ensuring that the individual has the requisite legal authority.

Verification and updating of recipient contact information The recipient must verify its Grant Award Administrator, Financial Manager, and Authorized Representative contact information in JustGrants, including telephone number and e-mail address. If any information is incorrect or has changed, the award recipient’s Entity Administrator must make changes to contact information through DIAMD. Instructions on how to update contact information in JustGrants can be found at
https://justicegrants.usdoj.gov/training/training-entity-management.

FFATA reporting: Subawards and executive compensation
The recipient must comply with applicable requirements to report first-tier subawards ("subgrants") of $30,000 or more and, in certain circumstances, to report the names and total compensation of the five most highly compensated executives of the recipient and first-tier subrecipients (first-tier "subgrantees") of award funds. The details of recipient obligations, which derive from the Federal Funding Accountability and Transparency Act of 2006 (FFATA), are set forth in 2 C.F.R. part 170, Appendix A (“Award Term”) and are incorporated by reference here.
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https://justgrants.usdoj.gov/prweb/PRAuth/app/JGITS/3yZ6Bxxi_lpDExTOT4XnAjzjAXmVNevW*/!STANDARD 13 This condition, including its reporting requirement, does not apply to-- (1) an award of less than $30,000, or (2) an award made to an individual who received the award as a natural person (i.e., unrelated to any business or nonprofit organization that he or she may own or operate in his or her name).

Note: In early March 2025, the reporting system that had been used for subaward reporting, the FFATA (Federal Funding Accountability and Transparency Act) Subaward Reporting System (FSRS) was retired and functionality moved to SAM.gov. For more information, including steps on how to connect your FSRS account to SAM.gov, visit https://sam.gov/fsrs.

The recipient agrees to comply with OJP grant monitoring guidelines, protocols, and procedures, and to cooperate with BJA and OCFO on all grant monitoring requests, including requests related to desk reviews, enhanced programmatic desk reviews, and/or site visits. The recipient agrees to provide to BJA and OCFO all documentation necessary to complete monitoring tasks, including documentation related to any subawards made under this award.

Further, the recipient agrees to abide by reasonable deadlines set by BJA and OCFO for providing the requested documents. Failure to cooperate with BJA's/OCFO's grant monitoring activities may result in sanctions affecting the recipient's DOJ awards, including, but not limited to: withholdings and/or other restrictions on the recipient's access to grant funds; referral to the Office of the Inspector General for audit review; designation of the recipient as a DOJ High Risk grantee; or termination of an award(s).

Any publication (e.g., curricula, training materials, publications, reports, videos, or any other written, web-based, or audio-visual, or other materials) funded in whole or in part under this award, (with the exception of press releases, websites, and mobile applications), shall contain the following statement: “This project was supported by Grant No. <Award_Number> awarded by the Bureau of Justice Assistance, Office of Justice Programs, U.S. Department of Justice.

Points of view or opinions in this document are those of the author and do not necessarily represent the official position or policies of the U.S. Department of Justice."
Any website or mobile application that is funded in whole or in part under this award must include the following statement where most practicable: "This website [or application] was supported by Grant No. <Award_Number> awarded by the Bureau of Justice Assistance, Office of Justice Programs, U.S.

Department of Justice. Neither the U.S. Department of Justice nor any of its components operate, control, are responsible for, or necessarily endorse, this website [or application] (including, without limitation, its content, technical infrastructure, and policies, and any services or tools provided)." The full text of the foregoing statement must be clearly visible. The statement may also be included through a link, entitled "Notice of Federal Funding and Federal Disclaimer," to the full text of the statement.

Upon specific request by BJA, the recipient must submit to BJA for review and approval (or, for recipients or subrecipients that are institutions of higher education, review and comment) any publication or product developed under this award at least 30 working days prior to the targeted dissemination date.

The current edition of the DOJ Grants Financial Guide provides additional guidance on allowable printing and publication activities. 34 35
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https://justgrants.usdoj.gov/prweb/PRAuth/app/JGITS/3yZ6Bxxi_lpDExTOT4XnAjzjAXmVNevW*/!STANDARD 14 Confidentiality of data
The recipient (and any subrecipient at any tier) must comply with all confidentiality requirements of 34 U.S.C. 10231 and 28 C.F.R. Part 22 that are applicable to collection, use, and revelation of data or information. The recipient further agrees, as a condition of award approval, to submit a Privacy Certificate that is in accord with requirements of 28 C.F.R. Part 22 and, in particular, 28 C.F.R. 22.23 for any applicable project.

The recipient agrees to cooperate with any assessments, national evaluation efforts, or information or data collection requests, including, but not limited to, the provision of any information required for the assessment or evaluation of any activities within this project.

Protection of human research subjects
The recipient (and any subrecipient at any tier) must comply with the requirements of 28 C.F.R. Part 46 and all OJP policies and procedures regarding the protection of human research subjects, including obtainment of Institutional Review Board approval, if appropriate, and subject informed consent.

Compliance with 28 C.F.R. Part 23
With respect to any information technology system funded or supported by funds under this award, the recipient (and any subrecipient at any tier) must comply with 28 C.F.R. Part 23, Criminal Intelligence Systems Operating Policies, if OJP determines this regulation to be applicable. Should OJP determine 28 C.F.R. Part 23 to be applicable, OJP may, at its discretion, perform audits of the system, as per the regulation. Should any violation of 28 C.F.R. Part 23 occur, the recipient may be fined as per 34 U.S.C. 10231(c)-(d).

The recipient may not satisfy such a fine with federal funds.

Justice Information Sharing
Information sharing projects funded under this award must comply with DOJ's Global Justice Information Sharing Initiative (Global) guidelines. The recipient (and any subrecipient at any tier) must conform to the Global Standards Package (GSP) and all constituent elements, where applicable, as described at: https://bja.ojp.gov/program/it/gsp-grant-condition. The recipient (and any subrecipient at any tier) must document planned approaches to information sharing and describe compliance with the GSP and appropriate privacy policy that protects shared information, or provide detailed justification for why an alternative approach is recommended.

Avoidance of duplication of networks
To avoid duplicating existing networks or IT systems in any initiatives funded by BJA for law enforcement information sharing systems that involve interstate 37 38
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https://justgrants.usdoj.gov/prweb/PRAuth/app/JGITS/3yZ6Bxxi_lpDExTOT4XnAjzjAXmVNevW*/!STANDARD 15 connectivity between jurisdictions, such systems shall employ, to the extent possible, existing networks as the communication backbone to achieve interstate connectivity, unless the recipient can demonstrate to the satisfaction of BJA that this requirement would not be cost effective or would impair the functionality of an existing or proposed IT system.

Law enforcement task forces - required training
Within 120 days of award acceptance, each current member of a law enforcement task force funded with award funds who is a task force commander, agency executive, task force officer, or other task force member of equivalent rank, must complete required online task force training.

Additionally, all future task force members must complete this training once during the period of performance for this award, or once every four years if multiple OJP awards include this requirement.

The required training is available free of charge online through the BJA-funded Center for Task Force Integrity and Leadership (www.ctfli.org). The training addresses task force effectiveness, as well as other key issues including privacy and civil liberties/rights, task force performance measurement, personnel selection, and task force oversight and accountability. If award funds are used to support a task force, the recipient must compile and maintain a task force personnel roster, along with course completion certificates.

Additional information regarding the training is available through BJA's web site and the Center for Task Force Integrity and Leadership (www.ctfli.org).

Compliance with National Environmental Policy Act and related statutes Upon request, the recipient (and any subrecipient at any tier) must assist BJA in complying with the National Environmental Policy Act (NEPA), the National Historic Preservation Act, and other related federal environmental requirements in the use of these award funds, either directly by the recipient or by a subrecipient. Accordingly, the recipient agrees to determine if any of the following activities will be funded by the grant prior to obligating funds for any of these purposes. If it is determined that any of the following activities will be funded by the award, the recipient agrees to contact BJA, and follow instructions regarding NEPA compliance.

The activities covered by this condition are:
a. New construction;
b. Minor renovation or remodeling of a property located in an environmentally or historically sensitive area, including properties located within a 100-year flood plain, a wetland, or habitat for endangered species, or a property listed on or eligible for listing on the National Register of Historic Places; c. A renovation, lease, or any proposed use of a building or facility that will either (a) result in a change in its basic prior use or (b) significantly change its size;
d. Implementation of a new program involving the use of chemicals other than chemicals that are (a) purchased as an incidental component of a funded activity and (b) traditionally used, for example, in office, household, recreational, or education environments;
e. Implementation of a program relating to clandestine methamphetamine laboratory operations, including the identification, seizure, or closure of 42 43
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f. Any extraordinary or unusual project with potential to have a significant environmental impact.

The recipient understands and agrees that complying with NEPA may require the preparation of an Environmental Assessment and/or an Environmental Impact Statement, as directed by BJA.

The recipient shall ensure that each DNA analysis conducted under this award will be performed either (1) by accredited government-owned laboratories, or (2) through an accredited fee-for-service vendor. The accreditation must be by an accrediting body that is a signatory to an internationally recognized arrangement and that offers accreditation to forensic science conformity assessment bodies using an accreditation standard that is recognized by that internationally recognized arrangement. Any laboratory conducting STR, YSTR, or mitochondrial DNA testing undergo external audits not less than once every 2 years that demonstrate compliance with the DNA Quality Assurance Standards established by the Director of the Federal Bureau of Investigation.

If award funds are used for DNA testing of evidentiary materials, recipients shall ensure that any resulting eligible DNA profiles must be uploaded to the Combined DNA Index System ("CODIS," the DNA database operated by the FBI) by a government DNA laboratory with access to CODIS, and, where applicable, uploaded to the National DNA Index System (NDIS). Award funds may be used for forensic genetic genealogy in accordance with United States Department of Justice Interim Policy Forensic Genealogical DNA Analysis and Searching and program requirements. With the exception of Forensic Genetic Genealogy, no profiles generated under this award may be entered or uploaded into any non-governmental DNA database without prior express written approval from BJA. Award funds may not be used for the purchase of DNA equipment and supplies unless the resulting DNA profiles may be accepted for entry into CODIS. Booking agencies should work with their state CODIS agency to ensure all requirements are met for participation in Rapid DNA (see National Rapid DNA Booking Operational Procedures Manual).

The recipient shall ensure that each DNA analysis conducted and each DNA profile generated under this award, and each stored DNA sample that results from this award, are maintained in accordance with any applicable federal privacy requirements and restrictions on disclosure.

Recipients utilizing award funds for forensic genealogy testing must adhere to the United States Department of Justice Interim Policy Forensic Genealogical DNA Analysis and Searching
(https://www.justice.gov/olp/page/file/1204386/download), and must collect and report the metrics identified in Section IX of that document to BJA.

Establishment of trust fund
If award funds are being drawn down in advance, the recipient (or a subrecipient, with respect to a subaward) is required to establish a trust fund account. Recipients (and subrecipients) must maintain advance payments of federal awards in interest-bearing accounts, unless regulatory exclusions apply (2 C.F.R. 200.305(b)(11)). The trust fund, including any interest, may not be used to pay debts or expenses incurred by other activities beyond the 44 45
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https://justgrants.usdoj.gov/prweb/PRAuth/app/JGITS/3yZ6Bxxi_lpDExTOT4XnAjzjAXmVNevW*/!STANDARD 17 scope of the Edward Byrne Memorial Justice Assistance Grant (JAG) Program. The recipient also agrees to obligate the award funds in the trust fund (including any interest earned) during the period of performance for the award and expend within 90 days thereafter. Any unobligated or unexpended funds, including interest earned, must be returned to OJP at the time of closeout.

As of the first day of the period of performance for the award, the recipient may choose to incur project costs using non-federal funds, but any such project costs are incurred at the recipient's risk until, at a minimum-- (1) the recipient makes a valid acceptance of the award, and (2) all applicable withholding conditions are removed by OJP (via an Award Condition Modification (ACM)). (A withholding condition is a condition in the award document that precludes the recipient from expending or drawing down all or a portion of the award funds until the condition is removed.) Except to the extent (if any) that an award condition expressly precludes reimbursement of project costs incurred "at-risk," if and when the recipient makes a valid acceptance of this award and OJP removes each applicable withholding condition through an Award Condition Modification (ACM), the recipient is authorized to obligate (federal) award funds to reimburse itself for project costs incurred "at-risk" earlier during the period of performance (such as project costs incurred prior to award acceptance or prior to removal of an applicable withholding condition), provided that those project costs otherwise are allowable costs under the award.

Submission of eligible records relevant to the National Instant Background Check System
Consonant with federal statutes that pertain to firearms and background checks -- including 18 U.S.C. 922 and 34 U.S.C. ch. 409 -- if the recipient (or any subrecipient at any tier) uses this award to fund (in whole or in part) a specific project or program (such as a law enforcement, prosecution, or court program) that results in any court dispositions, information, or other records that are "eligible records" (under federal or State law) relevant to the National Instant Background Check System (NICS), or that has as one of its purposes the establishment or improvement of records systems that contain any court dispositions, information, or other records that are "eligible records" (under federal or State law) relevant to the NICS, the recipient (or subrecipient, if applicable) must ensure that all such court dispositions, information, or other records that are "eligible records" (under federal or State law) relevant to the NICS are promptly made available to the NICS or to the "State" repository/database that is electronically available to (and accessed by) the NICS, and -- when appropriate -- promptly must update, correct, modify, or remove such NICS-relevant "eligible records".

In the event of minor and transitory non-compliance, the recipient may submit evidence to demonstrate diligent monitoring of compliance with this condition (including subrecipient compliance). DOJ will give great weight to any such evidence in any express written determination regarding this condition.

Compliance with trauma kit standards
If the recipient uses funds under this award to purchase trauma kits or trauma kit components, the recipient must ensure that the trauma kits purchased meet 47 48
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https://justgrants.usdoj.gov/prweb/PRAuth/app/JGITS/3yZ6Bxxi_lpDExTOT4XnAjzjAXmVNevW*/!STANDARD 18 the performance standards established consistent with 34 U.S.C. § 10202(d), as such standards are in effect at the time of purchase.

Initial period of performance; requests for extension.

The recipient understands that for award amounts of less than $25,000 under JAG, the initial period of performance of the award will be less than four years.

The recipient further understands that any requests for an extension of the period of performance for an award of less than $25,000 will be approved automatically for up to a total period of performance of four years, pursuant to 34 U.S.C. 10152(f) and in accordance with the Notice of Funding Opportunity (NOFO) associated with this award.

Any request for an extension of the period of performance beyond a four-year award period will require approval, and the approval (if any) will be at the discretion of OJP.

Noninterference (with award funds and within the funded "program or activity") with federal law enforcement: No public disclosure of certain law-enforcementsensitive information SCOPE. This condition applies throughout the entire award period of performance. Its provisions must be among those included in any subaward (at any tier).

1. No use of funds to interfere: No public disclosure of federal law-enforcement information in order to conceal, harbor, or shield.

Consistent with the purposes and objectives of federal law enforcement statutes and federal criminal law (including 8 U.S.C. 1324 and 18 U.S.C. chs. 1, 49, 227), no State or local government entity, agency, or official (including a government-contracted correctional facility) may use funds under this award to make any public disclosure of any federal law-enforcement information in a direct or indirect attempt to conceal, harbor, or shield from detection any fugitive from justice under 18 U.S.C. ch. 49, or any alien who has come to, entered, or remains in the United States in violation of 8 U.S.C. ch. 12— without regard to whether such disclosure would constitute (or could form a predicate for) a violation of 18 U.S.C. 1071 or 1072 or of 8 U.S.C. 1324(a).

2. Noninterference: No public disclosure of federal law-enforcement information in order to conceal, harbor, or shield within the funded “program or activity.”
With respect to the "program or activity" funded in whole or part under this award (including any such program or activity of any subrecipient at any tier), and consistent with federal law as cited in para. 1 of this condition, no State or local government entity, agency, or official (including a government-contracted correctional facility) within the funded program or activity may make any public disclosure of any federal law-enforcement information in a direct or indirect attempt to conceal, harbor, or shield from detection any fugitive from justice under 18 U.S.C. ch. 49, or any alien who has come to, entered, or remains in the United States in violation of 8 U.S.C. ch. 12—without regard to whether such disclosure would constitute (or could form a predicate for) a violation of 18 U.S.C. 1071 or 1072 or of 8 U.S.C. 1324(a).

3. Monitoring. The recipient's monitoring responsibilities include monitoring of subrecipient compliance with this condition.

4. Allowable costs. To the extent that such costs are not reimbursed under any other federal program, award funds may be obligated for the reasonable, necessary, and allocable costs (if any) of actions (e.g., training) designed to ensure compliance with this condition.

5. Rules of construction.
50 51
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https://justgrants.usdoj.gov/prweb/PRAuth/app/JGITS/3yZ6Bxxi_lpDExTOT4XnAjzjAXmVNevW*/!STANDARD 19 A. For purposes of this condition—
(1) the term "alien" means what it means under section 101 of the Immigration and Nationality Act (see 8 U.S.C. 1101(a)(3));
(2) the term "federal law-enforcement information" means law-enforcementsensitive information communicated or made available, by the federal government, to a State or local government entity, agency, or official, through any means, including, without limitation—
(a) through any database,
(b) in connection with any law enforcement partnership or task-force, (c) in connection with any request for law enforcement assistance or - cooperation, or
(d) through any deconfliction (or courtesy) notice of planned, imminent, commencing, continuing, or impending federal law enforcement activity; (3) the term "law-enforcement-sensitive information" means records or information compiled for any law-enforcement purpose; and (4) the term "public disclosure" means any communication or release other than one—
(a) within the recipient, or
(b) to any subrecipient (at any tier) that is a government entity.

B. This condition shall be enforceable to the extent that it does not otherwise contravene any express requirement of any federal law, or of any judicial ruling, governing or applicable to the award.

C. The "Rules of Construction" set out in the "Noninterference (with award funds and within the funded "program or activity") with federal law enforcement: information-communication restrictions; ongoing compliance" award condition are incorporated by reference as though set forth here in full.

Noninterference (with award funds and within the funded "program or activity") with federal law enforcement: information-communication restrictions SCOPE. This condition applies throughout the entire award period of performance. Its provisions must be among those included in any subaward (at any tier).

1. Throughout the entire award period of performance, no State or local government entity, -agency, or -official may use funds under this award (including under any subaward, at any tier) to prohibit or in any way restrict— (1) any government entity or -official from sending or receiving information regarding citizenship or immigration status to or from DHS; or (2) a government entity or agency from sending, requesting or receiving, or exchanging information regarding immigration status to, from, or with DHS, or from maintaining such information.

Any prohibition (or restriction) that violates this condition is an "informationcommunication restriction" under this award.

2. With respect to the "program or activity" funded in whole or part under this award (including any such program or activity of any subrecipient at any tier), throughout the entire award period of performance, no State or local government entity, agency, or official may implement an “informationcommunication restriction.”

3. The recipient's monitoring responsibilities include monitoring of subrecipient compliance with the requirements of this condition.

4. Allowable costs. Compliance with these requirements is an authorized and priority purpose of this award. To the extent that such costs are not reimbursed under any other federal program, award funds may be obligated for the reasonable, necessary, and allocable costs (if any) that the recipient, or any subrecipient at any tier that is a State or local government incurs to implement this condition.

5. Rules of Construction.

A. For purposes of this condition:
(1) "State" and "local government" include any agency or other entity thereof, 52 8/4/26, 10:13 AM Funded Award FAW-191077
https://justgrants.usdoj.gov/prweb/PRAuth/app/JGITS/3yZ6Bxxi_lpDExTOT4XnAjzjAXmVNevW*/!STANDARD 20 but not any public institution of higher education or Indian tribe. (2) "Program or activity" means what it means under title VI of the Civil Rights Act of 1964 (see 42 U.S.C. 2000d-4a).
(3) "Immigration status" means what it means under 8 U.S.C. 1373 and 8 U.S.C. 1644; and terms that are defined in 8 U.S.C. 1101 mean what they mean under that section 1101, except that "State" also includes American Samoa.
(4) “DHS” means the U.S. Department of Homeland Security.

B. Nothing in this condition shall be understood to authorize or require any recipient, any subrecipient at any tier, any State or local government, or any other entity (or individual) to violate any federal law, including any applicable civil rights or nondiscrimination law.

C. This condition shall be enforceable to the extent that it does not otherwise contravene any express requirement of any federal law, or of any judicial ruling, governing or applicable to the award.

Noninterference (with award funds and within the funded "program or activity") with federal law enforcement: Notice of scheduled release SCOPE. This condition applies throughout the entire award period of performance. Its provisions must be among those included in any subaward at any tier.

1. No use of funds to interfere with "removal" process: Notice of scheduled release date and time.

Consonant with federal law enforcement statutes—including 8 U.S.C. 1231 (for an alien incarcerated by a State or local government, a 90-day "removal period" during which the federal government "shall" detain and then "shall" remove an alien from the U.S. "begins" no later than "the date the alien is released from ... confinement"; also, the federal government is expressly authorized to make payments to a "State or a political subdivision of the State ... with respect to the incarceration of [an] undocumented criminal alien"); 8 U.S.C. 1226 (the federal government "shall take into custody" certain criminal aliens "when the alien is released"); and 8 U.S.C. 1366 (requiring an annual report to Congress on "the number of illegal alien[ felons] in Federal and State prisons" and programs underway "to ensure the prompt removal" from the U.S. of removable "criminal aliens")—no State or local government entity, agency, or official (including a government-contracted correctional facility) may use funds under this award to interfere with the "removal" process by failing to provide (as early as practicable (see para. 5.B. below)) advance notice to DHS of the scheduled release date and time for a particular alien, if a State or local government (or government-contracted) correctional facility receives from DHS a formal written request pursuant to the INA that seeks such advance notice.

2. Noninterference with "removal" process: Notice of scheduled release date and time within the funded “program or activity.”
With respect to the "program or activity" funded in whole or part under this award (including any such program or activity of any subrecipient at any tier), and consonant with federal law enforcement statutes as cited in para. 1 of this condition, no State or local government entity, agency, or official (including a government-contracted correctional facility) within the funded program or activity may interfere with the "removal" process by failing to provide (as early as practicable (see para. 4.B. below)) advance notice to DHS of the scheduled release date and time for a particular alien, if a State or local government (or government-contracted) correctional facility receives from DHS a formal written request pursuant to the INA that seeks such advance notice.

3. Monitoring. The recipient's monitoring responsibilities include monitoring of subrecipient compliance with this condition.

4. Allowable costs. To the extent that such costs are not reimbursed under any other federal program, award funds may be obligated for the reasonable, 53 8/4/26, 10:13 AM Funded Award FAW-191077
https://justgrants.usdoj.gov/prweb/PRAuth/app/JGITS/3yZ6Bxxi_lpDExTOT4XnAjzjAXmVNevW*/!STANDARD 21 necessary, and allocable costs (if any) of actions (e.g., training) designed to ensure compliance with this condition.

5. Rules of construction
A. Nothing in this condition shall be understood to authorize or require any recipient, any subrecipient at any tier, any State or local government, or any other entity or individual to maintain (or detain) any individual in custody beyond the date and time the individual otherwise would have been released.

B. Applicability.
(1) Current DHS practice is ordinarily to request advance notice of scheduled release "as early as practicable (at least 48 hours, if possible)." (See DHS Form I-247A (3/17)). If (e.g., in light of the date DHS made such request) the scheduled release date and time for an alien are such as not to allow for the advance notice that DHS has requested, it shall NOT be a violation of this condition to provide only as much advance notice as, in fact, practicable. (2) Current DHS practice is to use the same form for a second, distinct purpose—to request that an individual be detained for up to 48 hours AFTER the scheduled release. This condition does NOT encompass such DHS requests for detention.

C. This condition shall be enforceable to the extent that it does not otherwise contravene any express requirement of any federal law, or of any judicial ruling, governing or applicable to the award.

D. The "Rules of Construction" set out in the "Noninterference (with award funds and within the funded "program or activity") with federal law enforcement: Interrogation of certain aliens" award condition are incorporated by reference as though set forth here in full.

Noninterference (with award funds and within the funded "program or activity") with federal law enforcement: Interrogation of certain aliens SCOPE. This condition applies throughout the entire award period of performance. Its provisions must be among those included in any subaward (at any tier).

1. No use of funds to interfere with statutory law enforcement access to correctional facilities.

Consonant with federal law enforcement statutes and regulations—including 8 U.S.C. 1357(a) (under which certain federal officers and employees "have power without warrant ... to interrogate any alien or person believed to be an alien as to his right to be or to remain” in the United States), and 8 C.F.R. 287.5(a) (under which that power may be exercised "anywhere in or outside” the United States)—no State or local government entity, agency, or official within the funded program or activity may use funds under this award to interfere with the exercise of that power to interrogate "without warrant" (by agents of the United States acting under color of federal law) by impeding access to any State or local government (or government-contracted) correctional facility by such agents for the purpose of "interrogat[ing] any alien or person believed to be an alien as to his [or her] right to be or to remain in the United States."

2. Noninterference with statutory law enforcement access to correctional facilities within the funded “program or activity.”
With respect to the "program or activity" funded in whole or part under this award (including any such program or activity of any subrecipient at any tier), and consonant with federal law enforcement statutes and regulations as cited in para. 1 of this condition, no State or local government entity, agency, or official within the funded program or activity may interfere with the exercise of that power to interrogate "without warrant" (by agents of the United States acting under color of federal law) by impeding access to any State or local government (or government-contracted) correctional facility by such agents for the purpose of "interrogat[ing] any alien or person believed to be an alien as to his [or her] right to be or to remain in the United States." 54 8/4/26, 10:13 AM Funded Award FAW-191077
https://justgrants.usdoj.gov/prweb/PRAuth/app/JGITS/3yZ6Bxxi_lpDExTOT4XnAjzjAXmVNevW*/!STANDARD 22 3. Monitoring. The recipient's monitoring responsibilities include monitoring of subrecipient compliance with this condition.

5. Rules of construction
A. For purposes of this condition:
(1) The term "alien" means what it means under sec. 101 of the Immigration and Nationality Act (INA) (8 U.S.C. 1101(a)(3)), except that, with respect to a juvenile offender, it means “criminal alien.”
(2) The term “juvenile offender” means what it means under 28 C.F.R.

31.304(f) (as in effect on Jan. 1, 2026.)
(3) The term "criminal alien" means, with respect to a juvenile offender, an alien who is deportable on the basis of—
(a) conviction described in 8 U.S.C. 1227(a)(2), or
(b) conduct described in 8 U.S.C. 1227(a)(4).
(4) The term "conviction" means what it means under 8 U.S.C. 1101(a)(48). (Adjudication of a juvenile as having committed an offense does not constitute "conviction" for purposes of this condition.)
(5) The term "correctional facility" means what it means under 34 U.S.C. 10251(a)(7)) as of Jan. 1, 2026.
(6) The term "impede" includes taking or continuing any action, or implementing or maintaining any law, policy, rule, or practice, that— (a) is designed to prevent or to significantly delay or complicate, or (b) has the effect of preventing or of significantly delaying or complicating. (7) "State" and "local government" include any agency or other entity thereof, but not any public institution of higher education or Indian tribe. (8) "Program or activity" means what it means under title VI of the Civil Rights Act of 1964 (see 42 U.S.C. 2000d-4a).

C. This condition shall be enforceable to the extent that it does not otherwise contravene any express requirement of any federal law, or of any judicial ruling, governing or applicable to the award.

The recipient understands and agrees that no award funds may be used for any expenses related to public awareness campaigns for an extreme risk protection program.

Extreme risk protection order (ERPO) programs funded under this award must include, at a minimum: pre-deprivation and post-deprivation due process rights that prevent any violation or infringement of the Constitution of the United States, including but not limited to the Bill of Rights, and the substantive or procedural due process rights guaranteed under the Fifth and Fourteenth Amendments to the Constitution of the United States, as applied to the States, and as interpreted by State courts and United States courts (including the Supreme Court of the United States). Such programs must include, at the appropriate phase to prevent any violation of constitutional rights, at minimum, notice, the right to an in-person hearing, an unbiased adjudicator, the right to know opposing evidence, the right to present evidence, and the right to confront adverse witnesses; the right to be represented by counsel at no expense to the government; pre-deprivation and post-deprivation heightened evidentiary standards and proof which mean not less than the protections 55 56
8/4/26, 10:13 AM Funded Award FAW-191077
https://justgrants.usdoj.gov/prweb/PRAuth/app/JGITS/3yZ6Bxxi_lpDExTOT4XnAjzjAXmVNevW*/!STANDARD 23 afforded to a similarly situated litigant in Federal court or promulgated by the State's evidentiary body, and sufficient to ensure the full protections of the Constitution of the United States, including but not limited to the Bill of Rights, and the substantive and procedural due process rights guaranteed under the Fifth and Fourteenth Amendments to the Constitution of the United States, as applied to the States, and as interpreted by State courts and United States courts (including the Supreme Court of the United States). The heightened evidentiary standards and proof under such programs must, at all appropriate phases to prevent any violation of any constitutional right, at minimum, prevent reliance upon evidence that is unsworn or unaffirmed, irrelevant, based on inadmissible hearsay, unreliable, vague, speculative, and lacking a foundation; and penalties for abuse of the program.

Recipients who plan to use funding to support ERPO programs must submit a Certification Relating to Pub. L. No. 90-351, Title I, Sec. 501(a)(1)(I)(iv), signed by the principal legal officer, certifying that the ERPO program to be funded satisfies each of the listed requirements prior to the use of award funds for ERPO programs. Funds proposed for ERPO programs may be withheld, pending confirmation of compliance with the terms of this award.

No funds may be used for C-UAS except with express prior approval from BJA. To request such approval, the recipient (or subrecipient, at any tier) must submit to BJA a written certification that, among other things, certifies that any C-UAS purchased with award funds will only be procured and used in compliance with all applicable federal, state, and local laws and regulations, including criminal, surveillance, aviation, and communications laws. Any CUAS purchased with award funds will be included on the list of technologies established by subsection (d)(2)(A)(iii) section 210G of the Homeland Security Act of 2002 (6 U.S.C. 124n(d)(2)(A)(iii)) to exercise the authority granted under subsection (a)(2) of such section. The certification also requires that the award recipient consult qualified legal counsel to review the proposed purchase and operation of C-UAS, and that the recipient will complete required trainings and obtain all required approvals, certifications, licenses, and authorizations prior to deployment, and will coordinate with relevant authorities as required. The recipient (or subrecipient) also must assure BJA that it has sufficient policies and procedures regarding privacy, civil liberties, and information technology cybersecurity related to the operation of the C-UAS. Finally, the recipient (or subrecipient) may be required to provide additional documentation to verify purchase and the related policies for the C-UAS. Funds proposed for the purchase of C-UAS may be withheld, pending confirmation of compliance with the terms of this award. Additional information and the required certification form may be found here: https://bja.ojp.gov/funding/uas.

Expenditures prohibited without waiver
No funds under this award may be expended on the purchase of items prohibited by the JAG program statute, unless, as set forth at 34 U.S.C. 10152, the BJA Director certifies that extraordinary and exigent circumstances exist, making such expenditures essential to the maintenance of public safety and good order. Funds proposed for the purchase of prohibited items may be withheld, pending confirmation of compliance with the terms of this award.

No funds may be used for UAS except with express prior approval from BJA.

To request such approval, the recipient (or subrecipient, at any tier) must submit to BJA a written certification that, among other things, certifies that only 57 58
59 8/4/26, 10:13 AM Funded Award FAW-191077
https://justgrants.usdoj.gov/prweb/PRAuth/app/JGITS/3yZ6Bxxi_lpDExTOT4XnAjzjAXmVNevW*/!STANDARD 24 UAS verified by the Defense Contract Monitoring Agency's “Blue UAS Cleared List” or any successor list (available at https://bluelist.appsplatformportals.us/) as not manufactured by a “covered foreign entity” may be purchased or operated under the federal award and, further, that no modifications or additional accessories may be introduced to the UAS funded by the award.

The purchased UAS may not be used to process, store, or transmit Federal information. The recipient (or subrecipient) also must assure BJA that it has sufficient policies and procedures regarding privacy, civil liberties, and information technology cybersecurity related to the operation of the UAS.

Finally, the recipient (or subrecipient) may be required to provide additional documentation to verify purchase and the related policies for the UAS. Funds proposed for the purchase of UAS may be withheld, pending confirmation of compliance with the terms of this award. Additional information and the required certification form may be found here: https://bja.ojp.gov/funding/uas.

In accepting this award, the recipient agrees not to use award funds for purchases of body-worn cameras (BWCs) or related expenses for any agency unless that agency has submitted a certification to BJA that it has policies and procedures in place that reinforce appropriate agency Use of Force policies and training and address technology usage, evidence acquisition, data storage and retention, as well as privacy issues, accountability and discipline.

The recipient must keep signed certifications on file for any subrecipients planning to utilize funds from this award for BWCs or related expenses. Funds proposed for the purchase of BWCs or related expenses may be withheld, pending confirmation of compliance with the terms of this award.

Certification of body armor "mandatory wear" policies, and compliance with NIJ standards
If the recipient uses funds under this award to purchase body armor, the recipient must submit a signed certification that each law enforcement agency receiving body armor purchased with funds from this award has a written "mandatory wear" policy in effect. The recipient must keep signed certifications on file for any subrecipients planning to utilize funds from this award for ballistic-resistant and stab-resistant body armor purchases. This policy must be in place for at least all uniformed officers before any funds from this award may be used by an agency for body armor. There are no requirements regarding the nature of the policy other than it be a mandatory wear policy for all uniformed officers while on duty. Funds proposed for the purchase of body armor may be withheld, pending confirmation of compliance with the terms of this award.

Ballistic-resistant and stab-resistant body armor purchased with award funds may be purchased at any threat level, make or model, from any distributor or manufacturer, as long as the body armor has been tested and found to comply with applicable National Institute of Justice (NIJ) ballistic or stab standards, and is listed on the NIJ Compliant Body Armor Model List. In addition, ballisticresistant and stab-resistant body armor purchased must be uniquely fitted, as set forth in 34 U.S.C. 10202(c)(1)(A). The latest NIJ standard information and the NIJ Compliant Body Armor List may be found by following the links located on the NIJ Body Armor page: https://nij.ojp.gov/topics/equipment-andtechnology/body-armor 60 61
62 8/4/26, 10:13 AM Funded Award FAW-191077
https://justgrants.usdoj.gov/prweb/PRAuth/app/JGITS/3yZ6Bxxi_lpDExTOT4XnAjzjAXmVNevW*/!STANDARD 25 Withholding of funds for Memorandum of Understanding The recipient may not expend or draw down any award funds until BJA has reviewed and approved the required Memorandum of Understanding (MOU), and an Award Condition Modification (ACM) has been issued to remove this condition.

Recipient integrity and performance matters: Requirement to report information on certain civil, criminal, and administrative proceedings to SAM and FAPIIS
The recipient must comply with any and all applicable requirements regarding reporting of information on civil, criminal, and administrative proceedings connected with (or connected to the performance of) either this OJP award or any other grant, cooperative agreement, or procurement contract from the federal government. Under certain circumstances, recipients of OJP awards are required to report information about such proceedings, through the federal System for Award Management (known as "SAM"), to the designated federal integrity and performance system (currently, "FAPIIS").

The details of recipient obligations regarding the required reporting (and updating) of information on certain civil, criminal, and administrative proceedings to the federal designated integrity and performance system (currently, "FAPIIS") within SAM are posted on the OJP website at https://ojp.gov/funding/FAPIIS.htm (Award condition: Recipient Integrity and Performance Matters, including Recipient Reporting to FAPIIS), and are incorporated by reference here.
63 8/4/26, 10:13 AM Funded Award FAW-191077
https://justgrants.usdoj.gov/prweb/PRAuth/app/JGITS/3yZ6Bxxi_lpDExTOT4XnAjzjAXmVNevW*/!STANDARD 26
^ƵďƌĞĐŝƉŝĞŶƚDŽŶŝƚŽƌŝŶŐWƌŽĐĞĚƵƌĞƐ
ŽƵŶƚǇŽĨ^ĂŶĞƌŶĂƌĚŝŶŽ
>ĂǁĂŶĚ:ƵƐƚŝĐĞ'ƌŽƵƉ
'ƌĂŶƚǁĂƌĚͬ^ƵďͲǁĂƌĚWƌŽĐĞƐƐ
tŚĞŶ ƚŚĞ >ĂǁĂŶĚ :ƵƐƚŝĐĞ'ƌŽƵƉ ;>Θ:'Ϳ ŚĂƐ ďĞĞŶ ŶŽƚŝĨŝĞĚ ƚŚĂƚŝƚ ŚĂƐ ďĞĞŶĂǁĂƌĚĞĚĂŐƌĂŶƚ͕Ă ŽĂƌĚ ŐĞŶĚĂ/ƚĞŵƚŽĂĐĐĞƉƚƚŚĞŐƌĂŶƚǁŝůůďĞƉƌĞƉĂƌĞĚĂŶĚƐƵďŵŝƚƚĞĚƚŽƚŚĞŽĂƌĚŽĨ^ƵƉĞƌǀŝƐŽƌƐ;K^ͿĨŽƌ ĂƉƉƌŽǀĂů͘tŚĞƌĞƚŚĞƌĞŝƐĂƐƵďͲĂǁĂƌĚƚŽďĞŐƌĂŶƚĞĚ͕Ă^ƵďͲǁĂƌĚŐƌĞĞŵĞŶƚǁŝůůďĞƉƌĞƉĂƌĞĚďǇƚŚĞ >Θ:' ;ƌĞĐŝƉŝĞŶƚͿĂŶĚĂƉƉƌŽǀĞĚďǇƚŚĞK^ĂŶĚƚŚĞƐƵďƌĞĐŝƉŝĞŶƚ͘dŚĞĂƉƉƌŽƉƌŝĂƚĞŽĨĨŝĐŝĂůƐǁŝůůƐŝŐŶƚŚĞ ƐƵďͲĂǁĂƌĚ ĚŽĐƵŵĞŶƚƐ͘ dŚĞ ^ƵďͲǁĂƌĚ ŐƌĞĞŵĞŶƚ ǁŝůů ŝĚĞŶƚŝĨǇ ƚŚĞ ĨĞĚĞƌĂů ĂǁĂƌĚ ŝŶĨŽƌŵĂƚŝŽŶ ĂŶĚ ĂƉƉůŝĐĂďůĞĐŽŵƉůŝĂŶĐĞƌĞƋƵŝƌĞŵĞŶƚƐ͕ŝŶĐůƵĚŝŶŐĂƉƉůŝĐĂďůĞƐƉĞĐŝĂůĐŽŶĚŝƚŝŽŶƐĨŽƌĞĂĐŚĨĞĚĞƌĂůƐƵďͲĂǁĂƌĚ͘ dŚĞ^ƵďͲǁĂƌĚŐƌĞĞŵĞŶƚǁŝůůŝŶĐůƵĚĞƚŚĞ'ƌĂŶƚǁĂƌĚEƵŵďĞƌ͕ǁĂƌĚĂƚĞ͕ƐƐŝƐƚĂŶĐĞ>ŝƐƚŝŶŐEƵŵďĞƌ ;>EͿŶƵŵďĞƌ͕WƌŽũĞĐƚdŝƚůĞ͕WƌŽũĞĐƚWĞƌŝŽĚ͕ǁĂƌĚŵŽƵŶƚ͕ĂŶĚĂůůĂƉƉůŝĐĂďůĞ^ƉĞĐŝĂůŽŶĚŝƚŝŽŶƐĨŽƌƚŚĞ ƐƵďͲĂǁĂƌĚ͘dŚĞ>Θ:'͛Ɛ^ƵďƌĞĐŝƉŝĞŶƚDŽŶŝƚŽƌŝŶŐWƌŽĐĞĚƵƌĞƐǁŝůůďĞŝŶĐůƵĚĞĚŝŶƚŚĞ^ƵďͲǁĂƌĚŐƌĞĞŵĞŶƚ͘ 'ƌĂŶƚZĞǀĞŶƵĞ
tŚĞŶŶŽƚŝĨŝĞĚƚŚĂƚĂŐƌĂŶƚĂǁĂƌĚŚĂƐďĞĞŶŵĂĚĞ͕ƚŚĞ'ƌĂŶƚŽŽƌĚŝŶĂƚŽƌƌĞƋƵĞƐƚƐĂďƵĚŐĞƚĐŽĚĞĨŽƌƚŚĞ ŐƌĂŶƚĂǁĂƌĚĨƌŽŵƚŚĞƵĚŝƚŽƌͲŽŶƚƌŽůůĞƌͬdƌĞĂƐƵƌĞƌͬdĂǆŽůůĞĐƚŽƌ;dͿ͕ĂŶĚƐƵďŵŝƚƐĂƉƉƌŽƉƌŝĂƚĞďƵĚŐĞƚ ĚŽĐƵŵĞŶƚƐĨŽƌƚŚĞŽĂƌĚŽĨ^ƵƉĞƌǀŝƐŽƌƐĂƉƉƌŽǀĂů͘KŶĐĞƚŚĞďƵĚŐĞƚŝƐĞƐƚĂďůŝƐŚĞĚ͕ƚŚĞ'ƌĂŶƚŽŽƌĚŝŶĂƚŽƌ ǁŝůůĂĚŵŝŶŝƐƚĞƌŐƌĂŶƚĨƵŶĚƐŝŶĂĐĐŽƌĚĂŶĐĞǁŝƚŚƚŚĞƌĞƋƵŝƌĞŵĞŶƚƐŽĨƚŚĞĂǁĂƌĚŝŶŐĂŐĞŶĐǇ͘'ƌĂŶƚĨƵŶĚƐǁŝůů ďĞ ƌĞƋƵĞƐƚĞĚ ƚŚƌŽƵŐŚ ƚŚĞ ĂǁĂƌĚŝŶŐ ĂŐĞŶĐǇ͛Ɛ ĚĞƐŝŐŶĂƚĞĚ ƉƌŽĐĞƐƐ ďĂƐĞĚ ŽŶ ĂůůŽǁĂďůĞ ĞǆƉĞŶĚŝƚƵƌĞƐ ŝŶĐƵƌƌĞĚĂŶĚƐƵƉƉŽƌƚĞĚďǇĂƉƉƌŽƉƌŝĂƚĞĚŽĐƵŵĞŶƚĂƚŝŽŶ͘ƌĂǁĚŽǁŶƌĞƋƵĞƐƚƐǁŝůůďĞĐŽŵƉůĞƚĞĚǁŝƚŚŝŶƚŚĞ ƚŝŵĞĨƌĂŵĞƐƐƉĞĐŝĨŝĞĚďǇƚŚĞĂǁĂƌĚŝŶŐĂŐĞŶĐǇ͘
dŚĞ'ƌĂŶƚ ŽŽƌĚŝŶĂƚŽƌŵĂŝŶƚĂŝŶƐĂ ƌĞĐŽƌĚŽĨŐƌĂŶƚ ƌĞǀĞŶƵĞƐ ƌĞƋƵĞƐƚĞĚĂŶĚ ƌĞĐĞŝǀĞĚ͕ ƌĞĐŽŶĐŝůĞƐŐƌĂŶƚ ƌĞĐĞŝƉƚƐƚŽĞǆƉĞŶĚŝƚƵƌĞƐ͕ĂŶĚĞŶƐƵƌĞƐƚŚĂƚŐƌĂŶƚĨƵŶĚƐĂƌĞĂĚŵŝŶŝƐƚĞƌĞĚŝŶĂĐĐŽƌĚĂŶĐĞǁŝƚŚƚŚĞĂƉƉƌŽǀĞĚ ŐƌĂŶƚďƵĚŐĞƚ͕ĂǁĂƌĚĐŽŶĚŝƚŝŽŶƐ͕ĂŶĚĂƉƉůŝĐĂďůĞĨĞĚĞƌĂůƌĞƋƵŝƌĞŵĞŶƚƐ͘͘ ŝƐďƵƌƐĞŵĞŶƚŽĨ&ƵŶĚƐƚŽ^ƵďƌĞĐŝƉŝĞŶƚƐ
^ƵďƌĞĐŝƉŝĞŶƚƐǁŝůůďĞƌĞŝŵďƵƌƐĞĚĨŽƌĞůŝŐŝďůĞĞǆƉĞŶĚŝƚƵƌĞƐŝŶĐƵƌƌĞĚŝŶĂĐĐŽƌĚĂŶĐĞǁŝƚŚƚŚĞĂƉƉƌŽǀĞĚ^ƵďͲ ǁĂƌĚ ŐƌĞĞŵĞŶƚ͘ ^ƵďƌĞĐŝƉŝĞŶƚƐ ƐŚĂůů ƐƵďŵŝƚ ƌĞŝŵďƵƌƐĞŵĞŶƚ ƌĞƋƵĞƐƚƐ ƚŽ ƚŚĞ >Θ:' ǁŝƚŚ ƐƵĨĨŝĐŝĞŶƚ ƐƵƉƉŽƌƚŝŶŐĚŽĐƵŵĞŶƚĂƚŝŽŶ ƚŽĚĞŵŽŶƐƚƌĂƚĞ ƚŚĂƚĞǆƉĞŶĚŝƚƵƌĞƐĂƌĞĂůůŽǁĂďůĞ͕ƌĞĂƐŽŶĂďůĞ͕ĂůůŽĐĂďůĞ͕ĂŶĚ ŝŶĐƵƌƌĞĚǁŝƚŚŝŶƚŚĞĂƉƉƌŽǀĞĚƉƌŽũĞĐƚƉĞƌŝŽĚ͘
dŚĞ 'ƌĂŶƚ ŽŽƌĚŝŶĂƚŽƌ ǁŝůů ƌĞǀŝĞǁ ƌĞŝŵďƵƌƐĞŵĞŶƚ ƌĞƋƵĞƐƚƐ ĂŶĚ ƐƵƉƉŽƌƚŝŶŐ ĚŽĐƵŵĞŶƚĂƚŝŽŶ ƚŽ ǀĞƌŝĨǇ ĐŽŵƉůŝĂŶĐĞǁŝƚŚƚŚĞĨĞĚĞƌĂůĂǁĂƌĚƌĞƋƵŝƌĞŵĞŶƚƐ͕ĂƉƉůŝĐĂďůĞ:'ŐƵŝĚĞůŝŶĞƐ͕ĂƉƉƌŽǀĞĚƉƌŽũĞĐƚƐĐŽƉĞ͕ĂŶĚ ĂƉƉƌŽǀĞĚďƵĚŐĞƚƉƌŝŽƌƚŽƌĞŝŵďƵƌƐĞŵĞŶƚ͘dŚĞ'ƌĂŶƚŽŽƌĚŝŶĂƚŽƌŵĂǇƌĞƋƵĞƐƚĂĚĚŝƚŝŽŶĂůĚŽĐƵŵĞŶƚĂƚŝŽŶ ŽƌĐůĂƌŝĨŝĐĂƚŝŽŶĨƌŽŵƚŚĞƐƵďƌĞĐŝƉŝĞŶƚƉƌŝŽƌƚŽĂƉƉƌŽǀĂů͘ hƉŽŶ ĂƉƉƌŽǀĂů ŽĨ ƚŚĞ ƌĞŝŵďƵƌƐĞŵĞŶƚ ƌĞƋƵĞƐƚ͕ ƚŚĞ 'ƌĂŶƚ ŽŽƌĚŝŶĂƚŽƌ ǁŝůů ƉƌŽĐĞƐƐ ƚŚĞ ƉĂǇŵĞŶƚ ĚŽĐƵŵĞŶƚĂƚŝŽŶĂŶĚĐŽŽƌĚŝŶĂƚĞƌĞŝŵďƵƌƐĞŵĞŶƚƚŽƚŚĞƐƵďƌĞĐŝƉŝĞŶƚ͘dŚĞƵĚŝƚŽƌͲŽŶƚƌŽůůĞƌͬdƌĞĂƐƵƌĞƌͬdĂǆ ŽůůĞĐƚŽƌ;dͿǁŝůůƉƌŽĐĞƐƐĂƉƉƌŽǀĞĚƉĂǇŵĞŶƚƐ͘
27
dŽŶŽƚŝĨǇƐƵďƌĞĐŝƉŝĞŶƚƐŽĨƚŚĞĨĞĚĞƌĂůĂǁĂƌĚŶƵŵďĞƌ͕ƐƐŝƐƚĂŶĐĞ>ŝƐƚŝŶŐEƵŵďĞƌ͕ĂŶĚĂŵŽƵŶƚŽĨĨĞĚĞƌĂů ĨƵŶĚƐƉƌŽǀŝĚĞĚĂƚƚŚĞƚŝŵĞŽĨƌĞŝŵďƵƌƐĞŵĞŶƚ͕ƚŚĞĨŽůůŽǁŝŶŐƐƚĞƉƐǁŝůůďĞĨŽůůŽǁĞĚ͗ x WĂǇŵĞŶƚĚŽĐƵŵĞŶƚƐǁŝůů ƌĞĨĞƌĞŶĐĞ ƚŚĞ ĨĞĚĞƌĂůĂǁĂƌĚŶƵŵďĞƌ͕ƐƐŝƐƚĂŶĐĞ>ŝƐƚŝŶŐEƵŵďĞƌ͕ĂŶĚ ĂŵŽƵŶƚŽĨĨĞĚĞƌĂůĨƵŶĚƐƌĞŝŵďƵƌƐĞĚ͘
x ŽƌƌĞƐƉŽŶĚĞŶĐĞ ƉƌŽǀŝĚĞĚ ǁŝƚŚ ƌĞŝŵďƵƌƐĞŵĞŶƚ ƉĂǇŵĞŶƚƐ ǁŝůů ŝĚĞŶƚŝĨǇ ƚŚĞ ĂƉƉůŝĐĂďůĞ ĨĞĚĞƌĂů ĂǁĂƌĚŝŶĨŽƌŵĂƚŝŽŶĂŶĚĂŶǇƌĞƋƵŝƌĞĚĐŽŵƉůŝĂŶĐĞŝŶĨŽƌŵĂƚŝŽŶ͘ ^ƵďƌĞĐŝƉŝĞŶƚDŽŶŝƚŽƌŝŶŐZĞƋƵŝƌĞŵĞŶƚ
^ƵďͲĂǁĂƌĚƐǁŝůůďĞŵŽŶŝƚŽƌĞĚŝŶĂĐĐŽƌĚĂŶĐĞǁŝƚŚĂůůĂƉƉůŝĐĂďůĞƐƚĂƚƵƚĞƐ͕ƌĞŐƵůĂƚŝŽŶƐ͕ƚŚĞhŶŝĨŽƌŵ'ƌĂŶƚ 'ƵŝĚĂŶĐĞ͕KDŝƌĐƵůĂƌƐ͕ĂŶĚŐƵŝĚĞůŝŶĞƐ͕ŝŶĐůƵĚŝŶŐƚŚĞKĨĨŝĐĞŽĨ:ƵƐƚŝĐĞWƌŽŐƌĂŵƐ&ŝŶĂŶĐŝĂů'ƵŝĚĞ͘dŚĞ ƌĞĐŝƉŝĞŶƚǁŝůůŝŶĐůƵĚĞƚŚĞĂƉƉůŝĐĂďůĞĐŽŶĚŝƚŝŽŶƐŽĨƚŚŝƐĂǁĂƌĚŝŶĂŶǇƐƵďͲĂǁĂƌĚ͘dŚĞƌĞĐŝƉŝĞŶƚŝƐƌĞƐƉŽŶƐŝďůĞ ĨŽƌƚŚĞĨŽůůŽǁŝŶŐ͗
x
ŶƐƵƌĞƚŚĂƚĞǀĞƌǇƐƵďͲĂǁĂƌĚŝƐĐůĞĂƌůǇŝĚĞŶƚŝĨŝĞĚƚŽƚŚĞƐƵďƌĞĐŝƉŝĞŶƚĂƐĂƐƵďͲĂǁĂƌĚĂŶĚŝŶĐůƵĚĞƐ ĂƉƉůŝĐĂďůĞĐŽŶĚŝƚŝŽŶƐŽĨƚŚĞĨĞĚĞƌĂůĂǁĂƌĚ͘
x
ǀĂůƵĂƚĞ ĞĂĐŚ ƐƵďƌĞĐŝƉŝĞŶƚ͛Ɛ ƌŝƐŬ ŽĨ ŶŽŶĐŽŵƉůŝĂŶĐĞ ǁŝƚŚ ĨĞĚĞƌĂů ƐƚĂƚƵƚĞƐ͕ ƌĞŐƵůĂƚŝŽŶƐ ĂŶĚ ƚŚĞ ƚĞƌŵƐĂŶĚĐŽŶĚŝƚŝŽŶƐŽĨƚŚĞƐƵďͲĂǁĂƌĚĨŽƌƉƵƌƉŽƐĞƐŽĨĚĞƚĞƌŵŝŶŝŶŐƚŚĞĂƉƉƌŽƉƌŝĂƚĞƐƵďƌĞĐŝƉŝĞŶƚ ŵŽŶŝƚŽƌŝŶŐƉƌŽĐĞĚƵƌĞƐ͘
x KǀĞƌƐŝŐŚƚ ŽĨ ƐƵďƌĞĐŝƉŝĞŶƚ ƐƉĞŶĚŝŶŐ ƚŚƌŽƵŐŚ ƌĞǀŝĞǁ ŽĨ ƌĞŝŵďƵƌƐĞŵĞŶƚ ƌĞƋƵĞƐƚƐ͕ ƐƵƉƉŽƌƚŝŶŐ ĚŽĐƵŵĞŶƚĂƚŝŽŶ͕ ĂŶĚ ŵŽŶŝƚŽƌŝŶŐ ŽĨ ƐƉĞĐŝĨŝĐ ŽƵƚĐŽŵĞƐ ĂŶĚ ďĞŶĞĨŝƚƐ ĂƚƚƌŝďƵƚĂďůĞ ƚŽ ƚŚĞ ƵƐĞ ŽĨ ĨƵŶĚƐ͘
x ZĞǀŝĞǁ ƌĞŝŵďƵƌƐĞŵĞŶƚ ĚŽĐƵŵĞŶƚĂƚŝŽŶ ƚŽǀĞƌŝĨǇĞǆƉĞŶĚŝƚƵƌĞƐĂƌĞĂůůŽǁĂďůĞ ƵŶĚĞƌ ƚŚĞ ĨĞĚĞƌĂů ĂǁĂƌĚ͕ ĐŽŶƐŝƐƚĞŶƚ ǁŝƚŚ ƚŚĞ ĂƉƉƌŽǀĞĚ ƉƌŽũĞĐƚ ďƵĚŐĞƚ ĂŶĚ ƐĐŽƉĞ ŽĨ ǁŽƌŬ͕ ĂŶĚ ĂĚĞƋƵĂƚĞůǇ ƐƵƉƉŽƌƚĞĚ͘
x ZĞǀŝĞǁĨŝŶĂŶĐŝĂůĂŶĚƉĞƌĨŽƌŵĂŶĐĞƌĞƉŽƌƚƐ͘
x &ŽůůŽǁͲƵƉĂŶĚĞŶƐƵƌĞ ƚŚĂƚ ƐƵďƌĞĐŝƉŝĞŶƚƐ ƚĂŬĞ ƚŝŵĞůǇĂŶĚĂƉƉƌŽƉƌŝĂƚĞĂĐƚŝŽŶŽŶĂůůĚĞĨŝĐŝĞŶĐŝĞƐ ƉĞƌƚĂŝŶŝŶŐ ƚŽ ƚŚĞ ĨĞĚĞƌĂů ĂǁĂƌĚ ƉƌŽǀŝĚĞĚ ƚŽ ƚŚĞ ƐƵďƌĞĐŝƉŝĞŶƚ ĨƌŽŵ ƚŚĞ ƉĂƐƐͲƚŚƌŽƵŐŚ ĞŶƚŝƚǇ ĚĞƚĞĐƚĞĚƚŚƌŽƵŐŚĂƵĚŝƚƐ͕ŽŶͲƐŝƚĞŵŽŶŝƚŽƌŝŶŐǀŝƐŝƚƐ͕ĂŶĚŽƚŚĞƌŵĞĂŶƐ͘ x /ƐƐƵĞĂŵĂŶĂŐĞŵĞŶƚĚĞĐŝƐŝŽŶĨŽƌĂƵĚŝƚĨŝŶĚŝŶŐƐƉĞƌƚĂŝŶŝŶŐƚŽƚŚĞĨĞĚĞƌĂůĂǁĂƌĚƉƌŽǀŝĚĞĚƚŽƚŚĞ ƐƵďƌĞĐŝƉŝĞŶƚĨƌŽŵƚŚĞƉĂƐƐͲƚŚƌŽƵŐŚĞŶƚŝƚǇĂƐƌĞƋƵŝƌĞĚďǇϮ&ZϮϬϬ͘ϱϮϭDĂŶĂŐĞŵĞŶƚĞĐŝƐŝŽŶ͘ x sĞƌŝĨǇƚŚĂƚĞǀĞƌǇƐƵďƌĞĐŝƉŝĞŶƚǁŚŽŝƐĞǆƉĞĐƚĞĚƚŽĞǆƉĞŶĚΨϳϱϬ͕ϬϬϬŽƌŵŽƌĞŝƐĂƵĚŝƚĞĚĂƐƌĞƋƵŝƌĞĚ ďǇϮ&ZϮϬϬ^ƵďƉĂƌƚ&ƵĚŝƚZĞƋƵŝƌĞŵĞŶƚƐ͘
x ŽŶƐŝĚĞƌ ǁŚĞƚŚĞƌ ƚŚĞ ƌĞƐƵůƚƐ ŽĨ ƚŚĞ ƐƵďƌĞĐŝƉŝĞŶƚ͛Ɛ ĂƵĚŝƚƐ͕ ŽŶͲƐŝƚĞ ŵŽŶŝƚŽƌŝŶŐ ǀŝƐŝƚƐ Žƌ ŽƚŚĞƌ ŵŽŶŝƚŽƌŝŶŐ ŝŶĚŝĐĂƚĞ ĐŽŶĚŝƚŝŽŶƐ ƚŚĂƚ ŶĞĐĞƐƐŝƚĂƚĞ ĂĚũƵƐƚŵĞŶƚƐ ƚŽ ƚŚĞ ƉĂƐƐͲƚŚƌŽƵŐŚ ĞŶƚŝƚǇ͛Ɛ ŽǁŶ ƌĞĐŽƌĚƐ͘
x ŽŶƐŝĚĞƌƚĂŬŝŶŐĞŶĨŽƌĐĞŵĞŶƚĂŐĂŝŶƐƚŶŽŶĐŽŵƉůŝĂŶƚƐƵďƌĞĐŝƉŝĞŶƚƐĂƐĚĞƐĐƌŝďĞĚŝŶϮ&ZϮϬϬ͘ϯϯϴ ZĞŵĞĚŝĞƐ͘
^ƵďƌĞĐŝƉŝĞŶƚDŽŶŝƚŽƌŝŶŐWƌŽĐĞƐƐ
KŶͲƐŝƚĞŵŽŶŝƚŽƌŝŶŐŽĨŐƌĂŶƚͲĨƵŶĚĞĚƉƌŽũĞĐƚƐŵĂǇďĞĐŽŶĚƵĐƚĞĚďǇƚŚĞh͘^͘ĞƉĂƌƚŵĞŶƚŽĨ:ƵƐƚŝĐĞŽƌƚŚĞ ŽƵŶƚǇŽĨ^ĂŶĞƌŶĂƌĚŝŶŽ͘ƚƚŚĂƚƚŝŵĞ͕ƚŚĞŝĚĞŶƚŝĨŝĞĚƐƵďƌĞĐŝƉŝĞŶƚĂŐĞŶĐǇǁŝůůďĞƌĞƋƵŝƌĞĚƚŽƉƌŽǀŝĚĞ ĚŽĐƵŵĞŶƚĂƚŝŽŶ ƐƵƉƉŽƌƚŝŶŐ ƌĞŝŵďƵƌƐĞŵĞŶƚ ƌĞƋƵĞƐƚƐ͕ ĞǆƉĞŶĚŝƚƵƌĞƐ͕ ƉĞƌĨŽƌŵĂŶĐĞ ŵĞĂƐƵƌĞƐ͕ ĂŶĚ ĐŽŵƉůŝĂŶĐĞǁŝƚŚĂƉƉůŝĐĂďůĞĨĞĚĞƌĂůƌĞƋƵŝƌĞŵĞŶƚƐ͘ƉŚǇƐŝĐĂůƌĞǀŝĞǁŽĨŝƚĞŵƐĨƵŶĚĞĚƚŚƌŽƵŐŚƚŚĞŐƌĂŶƚ ŵĂǇĂůƐŽďĞƌĞƋƵĞƐƚĞĚ͘
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dŽ ĞŶƐƵƌĞ ĨƵůů ĐŽŵƉůŝĂŶĐĞ ǁŝƚŚ ƚŚŝƐ ůĞŐŝƐůĂƚŝǀĞ ŵĂŶĚĂƚĞ͕ Ăůů ŐƌĂŶƚ ƌĞůĂƚĞĚ ĚŽĐƵŵĞŶƚĂƚŝŽŶ ƚŽ ŝŶĐůƵĚĞ ƚŝŵĞƐŚĞĞƚƐ͕ŝŶǀŽŝĐĞƐ͕ƉƵƌĐŚĂƐĞŽƌĚĞƌƐ͕ĐĂŶĐĞůĞĚĐŚĞĐŬƐ͕ĂŶĚĐŽŶƚƌĂĐƚƐŵƵƐƚďĞŵĂŝŶƚĂŝŶĞĚŝŶĂůŽĐĂƚŝŽŶ ĂĐĐĞƐƐŝďůĞƚŽƚŚĞƉĞƌƐŽŶƌĞƐƉŽŶƐŝďůĞĨŽƌŵĂŶĂŐŝŶŐƚŚĞƐƵďͲĂǁĂƌĚ͕ĂŶĚƚŚĞĂŐĞŶĐǇ͛ƐĐŚŝĞĨĞǆĞĐƵƚŝǀĞ͘ /ĨŝƚŝƐĚĞƚĞƌŵŝŶĞĚ ĨƵŶĚƐĂƌĞŶŽƚďĞŝŶŐƵƐĞĚ ĨŽƌĂƉƉƌŽǀĞĚƉƵƌƉŽƐĞƐ͕ŽƌŝĨƉƌŽƉĞƌĚŽĐƵŵĞŶƚĂƚŝŽŶŝƐŶŽƚ ŵĂŝŶƚĂŝŶĞĚ͕ƚŚĞĂŵŽƵŶƚŝŶƋƵĞƐƚŝŽŶŵƵƐƚďĞƌĞƚƵƌŶĞĚƚŽƚŚĞh͘^͘ĞƉĂƌƚŵĞŶƚŽĨ:ƵƐƚŝĐĞ͘dŚĞƐƵďƌĞĐŝƉŝĞŶƚ ĂŐĞŶĐǇŵĂǇĂůƐŽďĞĚĞĞŵĞĚŝŶĞůŝŐŝďůĞĨŽƌĨƵƚƵƌĞĨĞĚĞƌĂůĨƵŶĚŝŶŐ͘ KŶͲ^ŝƚĞDŽŶŝƚŽƌŝŶŐ
dŚĞŽƵŶƚǇŽĨ^ĂŶĞƌŶĂƌĚŝŶŽ>Θ:'ŵĂǇĐŽŶĚƵĐƚŽŶͲƐŝƚĞŵŽŶŝƚŽƌŝŶŐ͘dŚĞŵŽŶŝƚŽƌŝŶŐǁŝůůďĞďĂƐĞĚƵƉŽŶ ƉĞƌĨŽƌŵĂŶĐĞ ĂŶĚ ƌĞƉŽƌƚĞĚ ĞǆƉĞŶĚŝƚƵƌĞ ŽĨ ĨƵŶĚƐ͘ dŚĞ ŵŽŶŝƚŽƌŝŶŐ ǁŝůů ďĞ ďĂƐĞĚ ƵƉŽŶ ƉĞƌĨŽƌŵĂŶĐĞ͕ ƚƌĂĐŬĞĚƚŚƌŽƵŐŚƌĞƉŽƌƚƐĂŶĚƌĞŐƵůĂƌĐŽƌƌĞƐƉŽŶĚĞŶĐĞ͘dŚŝƐŵĞƚŚŽĚǁŝůůĞŶƐƵƌĞƚŚĞƐƵďƌĞĐŝƉŝĞŶƚŝŶŐƌĞĂƚĞƐƚ ŶĞĞĚĨŽƌĂƐƐŝƐƚĂŶĐĞŝŶŵĂŶĂŐŝŶŐƚŚĞŝƌĂǁĂƌĚŝƐƉƌŽǀŝĚĞĚƚŚĞŶĞĐĞƐƐĂƌǇƚŽŽůƐƚŽďĞŝŶĨƵůůĐŽŵƉůŝĂŶĐĞǁŝƚŚ h͘^͘ĞƉĂƌƚŵĞŶƚŽĨ:ƵƐƚŝĐĞƌĞƋƵŝƌĞŵĞŶƚƐ͘
/ĨƐĞůĞĐƚĞĚĨŽƌŵŽŶŝƚŽƌŝŶŐ͕ƚŚĞƐƵďƌĞĐŝƉŝĞŶƚǁŝůůďĞŶŽƚŝĨŝĞĚĂƚůĞĂƐƚϮϬĚĂǇƐƉƌŝŽƌƚŽƚŚĞŵŽŶŝƚŽƌŝŶŐ͘dŚĞ ƐƚĂĨĨ ƉĞƌƐŽŶ ƌĞƐƉŽŶƐŝďůĞ ĨŽƌ ŵĂŶĂŐŝŶŐ ƚŚĞ ƐƵďͲĂǁĂƌĚ͕ ƚŚĞ ƐƚĂĨĨ ƉĞƌƐŽŶ ĂƐƐŝŐŶĞĚ ƚŽ ŵĂŶĂŐŝŶŐ ĨŝƐĐĂů ŽƉĞƌĂƚŝŽŶƐ͕ ƚŚĞ ĐŚŝĞĨ ĞǆĞĐƵƚŝǀĞ ŽĨ ƚŚĞ ƐƵďƌĞĐŝƉŝĞŶƚ ĂŐĞŶĐǇ͕ ĂŶĚ ĂŶǇ ŽƚŚĞƌ ĂƉƉůŝĐĂďůĞ ƉĞƌƐŽŶƐ ĚŝƌĞĐƚůǇ ŝŶǀŽůǀĞĚŝŶƚŚĞŽǀĞƌƐŝŐŚƚŽĨŐƌĂŶƚĨƵŶĚƐǁŝůůďĞĂƐŬĞĚƚŽĂƚƚĞŶĚ͘ƉƉƌŽƉƌŝĂƚĞĚŽĐƵŵĞŶƚĂƚŝŽŶǁŝůůĂůƐŽďĞ ƌĞƋƵĞƐƚĞĚ ĨŽƌ ƌĞǀŝĞǁ͘ ƵƌŝŶŐ ƚŚĞŵŽŶŝƚŽƌŝŶŐ͕ ƚŚĞ ĨŽůůŽǁŝŶŐ ŝƚĞŵƐǁŝůů ďĞ ƌĞǀŝĞǁĞĚ ĂŶĚͬŽƌ ĚŝƐĐƵƐƐĞĚ͗ ŝŶǀŽŝĐĞƐ͕ ƚŝŵĞƐŚĞĞƚƐ͕ ĐĂŶĐĞůĞĚ ĐŚĞĐŬƐ͕ĞƋƵŝƉŵĞŶƚ ƉƵƌĐŚĂƐĞĚ͕ ƉŽůŝĐŝĞƐ ĂŶĚ ƉƌŽĐĞĚƵƌĞƐ͕ ĨŝŶĂŶĐŝĂů ƐƚĂƚƵƐ ƌĞƉŽƌƚƐ͕ƉĞƌĨŽƌŵĂŶĐĞƌĞƉŽƌƚƐĂŶĚŐƌĂŶƚĨŝůĞƐ͘
/Ĩ ƚŚĞƐƵďƌĞĐŝƉŝĞŶƚŝƐŶŽŶͲĐŽŵƉůŝĂŶƚǁŝƚŚĂǁĂƌĚ ƌĞƋƵŝƌĞŵĞŶƚƐ͕ƚŚĞ ĨŽůůŽǁŝŶŐĂĐƚŝŽŶƐǁŝůůďĞ ƚĂŬĞŶ͗dŚĞ ŽƵŶƚǇ ŽĨ ^ĂŶ ĞƌŶĂƌĚŝŶŽ ǁŝůů ĂƐƐŝƐƚ ƚŚĞ ƐƵďƌĞĐŝƉŝĞŶƚ ǁŝƚŚ ƚŚĞ ƌĞƐŽůƵƚŝŽŶ ŽĨ ŝĚĞŶƚŝĨŝĞĚ ŝƐƐƵĞƐ͕ Ă ƌĞĐŽŵŵĞŶĚĂƚŝŽŶ ƚŽ ƚŚĞh͘^͘ĞƉĂƌƚŵĞŶƚ ŽĨ :ƵƐƚŝĐĞ ĨŽƌĂ ĨĞĚĞƌĂůŵŽŶŝƚŽƌŝŶŐ ŽĨ ƚŚĞ ƐƵďͲĂǁĂƌĚǁŝůů ďĞ ŵĂĚĞ͕ ĨƵƚƵƌĞ ƉĂǇŵĞŶƚƐ ǁŝůů ďĞ ǁŝƚŚŚĞůĚ ƵŶƚŝů Ăůů ŝƐƐƵĞƐ ĂƌĞ ƌĞƐŽůǀĞĚ͕ ĂŶĚ ĐůŽƐĞƌ ŽǀĞƌƐŝŐŚƚ ŽĨ ƚŚĞ ƐƵďƌĞĐŝƉŝĞŶƚďǇ^ĂŶĞƌŶĂƌĚŝŶŽŽƵŶƚǇǁŝůůďĞŝŵƉůĞŵĞŶƚĞĚ͘ WƌŽũĞĐƚĐĐŽƵŶƚŝŶŐĂŶĚZĞĐŽƌĚ<ĞĞƉŝŶŐ
ĚĞƋƵĂƚĞĐŽŶƚƌŽůŽĨ ĨƵŶĚƐƌĞĐĞŝǀĞĚƚŽĞŶƐƵƌĞĐŽŵƉůŝĂŶĐĞǁŝƚŚ ĨĞĚĞƌĂůĂŶĚƐƚĂƚĞƌĞŐƵůĂƚŝŽŶƐĂŶĚŐƌĂŶƚ ƐƵďͲĂǁĂƌĚĐŽŶĚŝƚŝŽŶƐǁŝůůďĞĂĐĐŽŵƉůŝƐŚĞĚ͘^ĞƉĂƌĂƚĞƌĞĐŽƌĚƐĂƌĞŵĂŝŶƚĂŝŶĞĚĨŽƌĞĂĐŚƉƌŽũĞĐƚƚŽĂǀŽŝĚ ĐŽŵŵŝŶŐůŝŶŐ ŽĨ ƉƌŽũĞĐƚ ĨƵŶĚƐ ǁŝƚŚ ŽƚŚĞƌ ĨƵŶĚƐ͘ ZĞĐŽƌĚƐ ŵĂŝŶƚĂŝŶĞĚ ƐŚĂůů ŝŶĐůƵĚĞ ƌĞŝŵďƵƌƐĞŵĞŶƚ ƌĞƋƵĞƐƚƐ͕ ƐƵƉƉŽƌƚŝŶŐ ŝŶǀŽŝĐĞƐ ĂŶĚ ĚŽĐƵŵĞŶƚĂƚŝŽŶ͕ ĂƉƉƌŽǀĂůƐ͕ ƉĂǇŵĞŶƚ ƌĞĐŽƌĚƐ͕ ĐŽƌƌĞƐƉŽŶĚĞŶĐĞ͕ ƉĞƌĨŽƌŵĂŶĐĞƌĞƉŽƌƚƐ͕ĂŶĚŽƚŚĞƌĚŽĐƵŵĞŶƚĂƚŝŽŶŶĞĐĞƐƐĂƌǇƚŽĚĞŵŽŶƐƚƌĂƚĞĐŽŵƉůŝĂŶĐĞǁŝƚŚĨĞĚĞƌĂůĂǁĂƌĚ ƌĞƋƵŝƌĞŵĞŶƚƐ͘
KďůŝŐĂƚŝŽŶĂŶĚ
ǆƉĞŶĚŝƚƵƌĞŽĨ&ƵŶĚƐ
ůů'ƌĂŶƚĨƵŶĚƐŵƵƐƚďĞŽďůŝŐĂƚĞĚďǇƚŚĞƚĞƌŵŝŶĂƚŝŽŶĚĂƚĞŽĨƚŚĞƉƌŽũĞĐƚ͘ 'ƌĂŶƚĨƵŶĚƐůĞŐĂůůǇŽďůŝŐĂƚĞĚďǇƚŚĞƚĞƌŵŝŶĂƚŝŽŶĚĂƚĞŵƵƐƚďĞĞǆƉĞŶĚĞĚǁŝƚŚŝŶƚŚĞƚŝŵĞĨƌĂŵĞƐƉĞĐŝĨŝĞĚ ǁŝƚŚŝŶƚŚĞ'ƌĂŶƚŽŶƚƌĂĐƚ͕ŐƌĞĞŵĞŶƚ͕Žƌ^ƵďͲǁĂƌĚŐƌĞĞŵĞŶƚ͘:ƵƐƚŝĐĞƐƐŝƐƚĂŶĐĞ'ƌĂŶƚĨƵŶĚƐŵƵƐƚďĞ ĞǆƉĞŶĚĞĚďǇƚŚĞĞŶĚŽĨƚŚĞƉƌŽũĞĐƚƉĞƌŝŽĚ͘
ZĞƉŽƌƚŝŶŐZĞƋƵŝƌĞŵĞŶƚƐ
^ƵďŵŝƐƐŝŽŶŽĨĨŝŶĂŶĐŝĂůĂŶĚƉĞƌĨŽƌŵĂŶĐĞƌĞƉŽƌƚƐǁŝůůďĞĂĐĐŽŵƉůŝƐŚĞĚŝŶĂĐĐŽƌĚĂŶĐĞǁŝƚŚƚŚĞŐƵŝĚĞůŝŶĞƐ ƐƉĞĐŝĨŝĞĚ ŝŶ ƚŚĞ 'ƌĂŶƚ ŽŶƚƌĂĐƚ͕ ŐƌĞĞŵĞŶƚ͕ Žƌ ^ƵďͲǁĂƌĚ ŐƌĞĞŵĞŶƚ͘ ^ƵďƌĞĐŝƉŝĞŶƚƐ ƐŚĂůů ƉƌŽǀŝĚĞ ĞǆƉĞŶĚŝƚƵƌĞŝŶĨŽƌŵĂƚŝŽŶ͕ƐƵƉƉŽƌƚŝŶŐĚŽĐƵŵĞŶƚĂƚŝŽŶ͕ĂŶĚƉĞƌĨŽƌŵĂŶĐĞĚĂƚĂŶĞĐĞƐƐĂƌǇĨŽƌƚŚĞŽƵŶƚǇƚŽ ŵĞĞƚĨĞĚĞƌĂůƌĞƉŽƌƚŝŶŐĂŶĚŵŽŶŝƚŽƌŝŶŐƌĞƋƵŝƌĞŵĞŶƚƐ͘
29 Subrecipient Audits - Uniform Grant Guidance and 0MB Circular A-133 Compliance Subrecipients are required to comply with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR Part 200 (Uniform Grant Guidance) for federal awards made on or after December 26, 2014, or with the 0MB Circular A-133 for federal awards made prior to December 26, 2014.

A single or program specific audit is required in any year that a government expends $750,000 or more a year in federal awards. Both the Uniform Grant Guidance and the 0MB Circular A-133 require audits to be completed and submitted to the Federal Audit Clearinghouse (FAC) no later than nine (9) months after the close of each fiscal year during the term of each grant award. As a condition of the sub-award agreement, the Law and Justice Group will require the subrecipient to submit a copy of the audit, including any corrective action plan within 30 days from the date of submission to the FAC. The Grant Coordinator will review and ensure that the subrecipient audit reports are received and that all audit findings have been resolved. Failure of the subrecipient to have audits performed as required may result in the withholding of new discretionary awards and/or withholding of funds.

Project Closeout
The Grant Coordinator will schedule, monitor, and ensure timely completion of all required closeout activities and final financial reports in conformance with the guidelines required by the awarding agency.

Inventory Control
Subrecipients will maintain an inventory of equipment purchased with grant funds and submit inventory records to the Grants Coordinator if requested. Records shall be retained for a period of three years from the date of the disposition or replacement or transfer at the discretion of the awarding agency. As equipment or other non-expendable property is purchased and received, it will be permanently marked, a property inventory record completed, and the property inventory record will be made part of the permanent grant sub-award file. Disposition of equipment will be done in accordance with the awarding agency's guidelines.

Retention Period
Project records must be maintained for the required period after the awarding agency determines that the grantee has met all the project requirements and the project has been accepted for closeout. Records will be maintained for a minimum of three years. The three-year retention period starts from the date of the submission of the closure of the single audit report which covers the grant period and lasts until completion of any disputes arising prior to the expiration of the three year period, whichever is later.

APPROVED BY:

Brent Martin, Chair
Law and Justice Group
Date
August 3, 2026

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Chino City CouncilOctober 6, 2026

Chino City Council
October 6, 2026