CITY OF FREMONT
Single Audit Report
For the Year Ended June 30, 2025
CITY OF FREMONT
Single Audit Reports
For the Year Ended June 30, 2025
Table of Contents
Page
Independent Auditor’s Report on Internal Control Over Financial Reporting and on Compliance and Other Matters Based on an Audit of Financial Statements Performed in Accordance With Government Auditing Standards ............................................................. 1
Independent Auditor’s Report on Compliance For the Major Federal Program; Report on Internal Control Over Compliance; and Report on Schedule of Expenditures of Federal Awards Required by the Uniform Guidance .................................. 3
Schedule of Expenditures of Federal Awards ............................................................................................... 7
Notes to the Schedule of Expenditures of Federal Awards ........................................................................... 9
Schedule of Findings and Questioned Costs ............................................................................................... 10
Summary Schedule of Prior Audit Findings ............................................................................................... 13
Corrective Action Plan ................................................................................................................................ 14
www.mgocpa.com Macias Gini & O’Connell LLP
2121 N. California Boulevard, Suite 750
Walnut Creek, CA 94596
1 Independent Auditor’s Report on Internal Control Over Financial Reporting and on Compliance and Other Matters Based on an Audit of Financial Statements Performed in Accordance With Government Auditing Standards
Honorable Mayor and Members
of the City Council
City of Fremont, California
We have audited, in accordance with the auditing standards generally accepted in the United States of America and the standards applicable to financial audits contained in Government Auditing Standards , issued by the Comptroller General of the United States (Government Auditing Standards ), the financial statements of the governmental activities, each major fund, and the aggregate remaining fund information of the City of Fremont, California (City), as of and for the year ended June 30, 2025, and the related notes to the financial statements, which collectively comprise the City’s basic financial statements, and have issued our report thereon dated December 19, 2025.
Report on Internal Control Over Financial Reporting
In planning and performing our audit of the financial statements, we considered the City’s internal control over financial reporting (internal control) as a basis for designing audit procedures that are appropriate in the circumstances for the purpose of expressing our opinions on the financial statements, but not for the purpose of expressing an opinion on the effectiveness of the City’s internal control. Accordingly, we do not express an opinion on the effectiveness of the City’s internal control.
A deficiency in internal control exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, misstatements on a timely basis. A material weakness is a deficiency, or a combination of deficiencies, in internal control such that there is a reasonable possibility that a material misstatement of the entity’s financial statements will not be prevented, or detected and corrected , on a timely basis. A significant deficiency is a deficiency, or a combination of deficiencies, in internal control that is less severe than a material weakness, yet important enough to merit attention by those charged with governance.
Our consideration of internal control was for the limited purpose described in the first paragraph of this section and was not designed to identify all deficiencies in internal control that might be material weaknesses or significant deficiencies . Given these limitations, during our audit we did not identify any deficiencies in internal control that we consider to be material weaknesses. However, material weaknesses or significant deficiencies may exist that were not identified.
Report on Compliance and Other Matters
As part of obtaining reasonable assurance about whether the City’s financial statements are free from material misstatement, we performed tests of its compliance with certain provisions of laws, regulations, contracts, and grant agreements, noncompliance with which could have a direct and material effect on the financial statement s. However, providing an opinion on compliance with those provisions was not an objective of our audit, and accordingly, we do not express such an opinion. The results of our tests disclosed no instances of noncompliance or other matters that are required to be reported under Government Auditing Standards.
2 Purpose of this Report
The purpose of this report is solely to describe the scope of our testing of internal control and compliance and the result s of that testing, and not to provide an opinion on the effectiveness of the entity’s internal control or on compliance. This report is an integral part of an audit performed in accordance with Government Auditing Standards in considering the entity’s internal control and compliance. Accordingly, this communication is not suitable for any other purpose.
Walnut Creek, California
December 19, 2025
w
ww.mgocpa.com Macias Gini & O’Connell LLP
2121 N. California Boulevard, Suite 750
Walnut Creek, CA 94596
3 Independent Auditor’s Report on Compliance for the Major Federal Program; Report on Internal Control Over Compliance; and Report on Schedule of Expenditures of Federal Awards Required by the Uniform Guidance Honorable Mayor and Members
of the City Council
City of Fremont, California
Report on Compliance for the Major Federal Program
Opinion on the Major Federal Program
We have audited the City of Fremont, California’s (City) compliance with the types of compliance requirements identified as subject to audit in the OMB Compliance Supplement that could have a direct and material effect on the City’s major federal program for the year ended June 30, 2025. The City’s major federal program is identified in the summary of auditor’s results section of the accompanying schedule of findings and questioned costs.
In our opinion, the City complied, in all material respects, with the compliance requirements referred to above that could have a direct and material effect on its major federal p rogram for the year ended June 30, 2025.
Basis for Opinion on the Major Federal Program
We conducted our audit of compliance in accordance with auditing standards generally accepted in the United States of America (GAAS); the standards applicable to financial audits contained in Government Auditing Standards issued by the Comptroller General of the United State s ( Government Audit ing Standards); and the audit requirements of Title 2 U.S. Code of Federal Regulation s Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Our responsibilities under those standards and the Uniform Guidance are further described in the Auditor’s Responsibilities for the Audit of Compliance section of our report.
We are required to be independent of the City and to meet our other ethical responsibilities, in accordance with relevant ethical requirements relating to our audit. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion on compliance for the major federal program. Our audit does not provide a legal determination of the City’s compliance with the compliance requirements referred to above.
Responsibilities of Management for Compliance
Management is responsible for compliance with the requirements referred to above and for the design, implementation, and maintenance of effective internal control over compliance with the requirements of laws, statutes, regulations, rules and provisions of contracts or grant agreements applicable to the Cit y’s federal programs.
4 Auditor’s Responsibilities for the Audit of Compliance Our objectives are to obtain reasonable assurance about whether material noncompliance with the compliance requirements referred to above occurred, whether due to fraud or error, and express an opinion on the City’s compliance based on our audit. Reasonable assurance is a high level of assurance but is not absolute assurance and therefore is not a guarantee that an audit conducted in accordance with GAAS, Government Auditing Standards , and the Uniform Guidance will always detect material noncompliance when it exists. The risk of not detecting material noncompliance resulting from fraud is higher than for that resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control. Noncompliance with the compliance requirements referred to above is considered material if there is a substantial likelihood that, individually or in the aggregate, it would influence the judgment made by a reasonable user of the report on compliance about the City’s compliance with the requirements of the major federal program as a whole.
In performing an audit in accordance with GAAS, Government Auditing Standards , and the Uniform Guidance, we:
• Exercise professional judgment and maintain professional skepticism throughout the audit. • Identify and assess the risks of material noncompliance, whether due to fraud or error, and design and perform audit procedures responsive to those risks. Such procedures include examining, on a test basis, evidence regarding the City’s compliance with the compliance requirements referred to above and performing such other procedures as we considered necessary in the circumstances. • Obtain an understanding of the City’s internal control over compliance relevant to the audit in order to design audit procedures that are appropriate in the circumstances and to test and report on internal control over compliance in accordance with the Uniform Guidance, but not for the purpose of expressing an opinion on the effectiveness of the City’s internal control over compliance. Accordingly, no such opinion is expressed.
We are required to communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and any significant deficiencies and material weaknesses in internal control over compliance that we identified during the audit.
Other Matters
The results of our auditing procedures disclosed an instance of noncompliance which is required to be reported in accordance with the Uniform Guidance and which is described in the accompanying schedule of findings and questioned costs as item 2025-001. Our opinion on the major federal program is not modified with respect to this matter.
Government Auditing Standards requires the auditor to perform limited procedures on the City’s response to the noncompliance finding identified in our compliance audit described in the accompanying schedule of findings and questioned costs. The City’s response was not subjected to the other auditing procedures applied in the audit of compliance and, accordingly, we express no opinion on the response.
Report on Internal Control Over Compliance
Our consideration of internal control over compliance was for the limited purpose described in the Auditor’s Responsibilities for the Audit of Compliance section above and was not designed to identify all deficiencies in internal control over compliance that might be material weaknesses or significant deficiencies in internal control over compliance and therefore material weaknesses or significant deficiencies may exist that were not identified . We did not identify any deficiencies in internal control over compliance that we consider to be material weaknesses. However, as discussed below, we did 5 identify a certain deficiency in internal control over compliance that we consider to be a significant deficiency.
A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. A material weakness in internal control over compliance is a deficiency, or a combination of deficiencies, in internal control over compliance, such that there is a reasonable possibility that material noncompliance with a type of compliance requirement of a federal program will not be prevented, or detected and corrected, on a timely basis. A significant deficiency in internal control over compliance is a deficiency, or a combination of deficiencies, in internal control over compliance with a type of compliance requirement of a federal program that is less severe than a material weakness in internal control over compliance, yet important enough to merit attention by those charged with governance. We consider the deficienc y in internal control over compliance described in the accompanying schedule of findings and questioned costs as item 2025-001 to be a significant deficiency.
Our audit was not designed for the purpose of expressing an opinion on the effectiveness of internal control over compliance. Accordingly, no such opinion is expressed.
Government Auditing Standards requires the auditor to perform limited procedures on the City’s response to the internal control over compliance findings identified in our compliance audit described in the accompanying schedule of findings and questioned costs. The City’s response was not subjected to the other auditing procedures applied in the audit of compliance and, accordingly, we express no opinion on the response.
The purpose of this report on internal control over compliance is solely to describe the scope of our testing of internal control over compliance and the results of that testing based on the requirements of the Uniform Guidance. Accordingly, this report is not suitable for any other purpose.
Report on Schedule of Expenditures of Federal Awards Required by the Uniform Guidance We have audited the financial statements of the governmental activities, each major fund, and the aggregate remaining fund information of the City , as of and for the year ended June 30, 2025, and the related notes to the financial statements, which collectively comprise the City’s basic financial statements.
We issued our report thereon dated December 19, 2025, which contained unmodified opinions on those financial statements. Our audit was performed for the purpose of forming opinions on the financial statements that collectively comprise the City’s basic financial statements. The accompanying schedule of expenditures of federal awards is presented for purposes of additional analysis as required by the Uniform Guidance and is not a required part of the basic financial statements. Such information is the responsibility of management and was derived from and relates directly to the underlying accounting and other records used to prepare the basic financial statements. The information has been subjected to the auditing procedures applied in the audit of the financial statements and certain additional procedures, including comparing and reconciling such information directly to the underlying accounting and other records used to prepare the basic financial statements or to the basic financial statements themselves, and other additional procedures in accordance with auditing standards generally accepted in the United States of America. In our opinion, the schedule of expenditures of federal awards is fairly stated, in all material respects, in relation to the basic financial statements as a whole.
Walnut Creek, California
March 25, 2026
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CITY OF FREMONT
Schedule of Expenditures of Federal Awards
For the Year Ended June 30, 2025
7 Assistance Grant Identifying Number or Federal Amount Passed t o Federal Grantor/Pass-Through Grantor/Federal Program Title Listing Number Pass-Through Entity Number Expenditures Subrecipients U.S. Department of Agriculture
Direct Program:
SNAP Cluster:
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program 10.561 24-7009 12,698 $ - $
Total U.S. Department of Agriculture 12,698 - U.S. Department of Housing and Urban Development
Direct Programs:
Community Development Block Grant Cluster Entitlement/Special Purpose Grants:
Community Development Block Grants/Entitlement Grants 14.218 B-09-MC-06-0011 40,461 40,461 Community Development Block Grants/Entitlement Grants 14.218 B-10-MC-06-0011 52,642 52,642 Community Development Block Grants/Entitlement Grants 14.218 B-20-MC-06-0011 102,650 - Community Development Block Grants/Entitlement Grants 14.218 B-21-MC-06-0011 48,005 11,939 Community Development Block Grants/Entitlement Grants 14.218 B-23-MC-06-0011 6,268 - Community Development Block Grants/Entitlement Grants 14.218 B-24-MC-06-0011 1,590,596 470,400 COVID-19 - Community Development Block Grants/Entitlement Grants 14.218 B-20-MW-06-0011 30,280 - Subtotal Community Development Block Grant Cluster Entitlement/ Special P urpose Grants 1,870,902 575,442
Emergency Solutions Grant Program 14.231 E-22-MC-06-0601 43,693 - Emergency Solutions Grant Program 14.231 E-23-MC-06-0601 153,361 - Emergency Solutions Grant Program 14.231 E-24-MC-06-0601 46,664 - Subtotal Emergency Solutions Grant Program 243,718 - Pass-Through Alameda County Housing and Community Development:
Home Investment Partnerships Program 14.239 M-25-DC-06-0001 217,340 45,054 Direct Program:
Economic Development Initiative, Community Project Funding, and Miscellaneous Grants 14.251 B-22-CP-CA-0045 250,000 250,000 Economic Development Initiative, Community Project Funding, and Miscellaneous Grants 14.251 B-24-CP-CA-0248 182,225 - Economic Development Initiative, Community Project Funding, and Miscellaneous Grants 14.251 B-24-CP-CA-0148 65,900 - Subtotal Economic Development, Initiative, Community
Project Funding, and Miscellaneous Grants 498,125 250,000 Total U.S. Department of Housing and Urban Development 2,830,085 870,496 U.S. Department of Justice
Direct Program:
Public Safety Partnership and Community Policing Grants 16.710 n/a 253,351 - Pass-Through Alameda County Sheriff's Office:
Edward Byrne Memorial Justice Assistance Grant Program 16.738 15PBJA-21-GG-01242-JAGX 7,782 - Edward Byrne Memorial Justice Assistance Grant Program 16.738 15PBJA-22-GG-02093-JAGX 30,113 - Edward Byrne Memorial Justice Assistance Grant Program 16.738 15PBJA-23-GG-03188-JAGX 32,434 - Subtotal Edward Byrne Memorial Justice Assistance Grant Program 70,329 - Total U.S. Department of Justice 323,680 -
U.S. Department of Transportation
Pass-Through State of California Department of Transportation:
Highway Planning and Construction 20.205 04-5322 611,872 - Highway Safety Cluster:
National Priority Safety Programs 20.616 PT24073 3,588 - National Priority Safety Programs 20.616 PT25164 38,669 - National Priority Safety Programs 20.616 TR24013 14,500 - Subtotal Highway Safety Cluster 56,757 -
Total U.S. Department of Transportation 668,629 - U.S. Department of Treasury
Direct Programs:
Volunteer Income Tax Assistance (VITA) Matching Grant Program 21.009 V13076 50,000 - COVID-19 - Emergency Rental Assistance Program 21.023 ERA2-0154 446,948 - Pass-Through State of California
COVID-19 - Coronavirus Capital Projects Fund 21.029 n/a 220,258 - Total U.S. Department of Treasury 717,206 -
CITY OF FREMONT
Schedule of Expenditures of Federal Awards
For the Year Ended June 30, 2025
8 Assistance Grant Identifying Number or Federal Amount Passed to Federal Grantor/Pass-Through Grantor/Federal Program Title Listing Number Pass-Through Entity Number Expenditures Subrecipients U.S. Department of Health and Human Services
Pass-Through Alameda County Area Agency on Aging:
Aging Cluster:
Special Programs for the Aging, Title III, Part D, Disease Prevention and Health Promotion Services 93.043 900111 80,000 - Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.044 900111; 901939 105,630 - National Family Caregiver Support, Title III, Part E 93.052 900111 100,061 - Subtotal Aging Cluster 285,691 -
Pass-Through Alameda County - Oakland Community Action Partnership:
Community Services Block Grant 93.569 23F-4002 38,550 - Pass-Through Alameda County Behavioral Health Care Services:
Block Grants for Prevention and Treatment of Substance Abuse 93.959 900111 455,994 - Pass-Through State of California Department of Health and Human Services:
Medicaid Cluster:
Grants to States for Medicaid:
Targeted Case Management - Linkages 93.778 01-19EVRGRN 198,819 - Targeted Case Management - Community 93.778 01-19EVRGRN 249,607 - Alameda County Health Care Services - Medi-Cal Administrative Activities 93.778 19-96008 860,631 - Pass-Through State of California Department of Aging:
Grants to States for Medicaid:
Multipurpose Senior Services Program 93.778 MS-2223-37 507,993 - Subtotal Medicaid Cluster 1,817,050 -
Total U.S. Department of Health and Human Services 2,597,285 - U.S. Department of Homeland Security
Direct Program:
Disaster Grants - Public Assistance (Presidentially Declared Disasters) 97.036 FEMA-4683-DR-CA 94,489 - Disaster Grants - Public Assistance (Presidentially Declared Disasters) 97.036 FEMA-4699-DR-CA 23,610 - Subtotal Disaster Grants - Public Assistance (Presidentially Declared Disasters) 118,099 -
Assistance to Firefighters Grant 97.044 EMW-2021-FG-05855 2,137 - Pass-Through Alameda County Sheriff's Office:
Homeland Security Grant Program 97.067 2023-0042; 2024-5088 282,454 - Pass-Through County of Alameda:
Homeland Security Grant Program:
FEMA- CERT 97.067 2018-0054 39,233 -
Subtotal Homeland Security Grant Program 321,687 - Total U.S. Department of Homeland Security 441,923 - Total Expenditures of Federal Awards 7,591,506$ 1,051,732$
CITY OF FREMONT
Notes to the Schedule of Expenditures of Federal Awards For the Year Ended June 30, 2025
9 (1) GENERAL
The accompanying Schedule of Expenditures of Federal Awards (SEFA) presents the activity of the federal award programs of the City of Fremont, California (City). The City’s repor ting entity is defined in Note 1 to its basic financial statements. The information in the SEFA is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The SEFA includes all federal awards received directly from federal agencies and federal awards passed - through other governmental agencies.
(2) BASIS OF ACCOUNTING
The accompanying SEFA is presented using the modified accrual basis of accounting for grants as described in Note 1 to the City’s basic financial statements . The City did not elect to use the de minimis cost rate as covered in 2 CFR section 200.414 Indirect (F&A) costs.
As a result of the COVID -19 pandemic, many new federal programs have been established and funding has been added to existing federal programs. Expenditures funded from the following acts are denoted by the prefix COVID-19 in the federal program title in the SEFA (as applicable):
• Coronavirus Preparedness and Response Supplemental Appropriations Act • Families First Coronavirus Response Act
• Coronavirus Aid, Relief, and Economic Security Act (CARES Act) • Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) • American Rescue Plan Act (ARP)
(3) RELATIONSHIP TO THE BASIC FINANCIAL STATEMENTS
Expenditures of federal awards are reported in the City’s basic financial statements as expenditures in the governmental funds. Federal award expenditures agree or can be reconciled with the amounts reported in the City’s basic financial statements.
(4) RELATIONSHIP TO FEDERAL FINANCIAL REPORTS
Amounts reported in the SEFA agree to or can be reconciled with the amounts reported in the related federal financial reports.
CITY OF FREMONT
Schedule of Findings and Questioned Costs
For the Year Ended June 30, 2025
10 Section I Summary of Auditor’s Results
Financial Statements
Type of auditor’s report issued on whether the financial statements audited were prepared in accordance with U.S.
GAAP:
Unmodified
Internal control over financial reporting:
Material weakness(es) identified? No
Significant deficiency(ies) identified? None reported Noncompliance material to the financial statements noted? No
Federal Awards
Internal control over major programs:
Material weakness(es) identified? No
Significant deficiency(ies) identified? Yes
Type of auditor’s report issued on compliance for the major federal programs:
Unmodified
Any audit findings disclosed that are required to be reported in accordance with Uniform Guidance?
Yes
Identification of major federal programs:
Assistance
Listing Numbers
Name of Federal Program or Cluster
14.218 Community Development Block Grants / Entitlement Grants
Dollar threshold used to distinguish between type A
and type B programs:
$750,000
Auditee qualified as a low-risk auditee? Yes
Section II Financial Statements Findings
None reported.
CITY OF FREMONT
Schedule of Findings and Questioned Costs
For the Year Ended June 30, 2025
11 Section III Federal Awards Findings and Questioned Costs
Reference Number:
2025-001
Federal Program Title: Community Development Block Grants / Entitlement Grants
Federal Assistance Listing Number: 14.218
Federal Agency: U.S. Department of Housing and Urban
Development (HUD)
Pass-Through Entity: N/A
Federal Award Number and Year: B-24-MC-06-0011; 2024
Name of Department: Human Services
Category of Finding: Reporting
Type of finding: Instance of Noncompliance; Significant Deficiency in Internal Control over Compliance
Criteria:
In accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 170 – Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 – Award Term, Section I(a), prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000.
Condition:
The City did not comply with the Federal Funding Accountability and Transparency Act (FFATA) reporting requirements. The City did not submit the required FFATA subaward report into the FSRS system within the required timeframe, which is no later than the end of the month following the month in which the subaward was made. The City submitted the report after the required deadline as outlined in the table below.
Transactions Tested
Subaward not
reported
Report not
timely
Subaward
amount incorrect
Subaward missing
key elements
7 0 3 0 0
Dollar Amount of
Tested Transactions
Subaward not
reported
Report not
timely
Subaward
amount incorrect
Subaward missing
key elements
$1,382,685 $0 $1,047,859 $0 $0
Cause:
The City had varying interpretations of the FFATA reporting timeline, which resulted in subaward reports being submitted outside the required reporting window. This occurred, in part, because stakeholders relied on differing interpretations of the timing requirements based on their understanding of the available guidance.
CITY OF FREMONT
Schedule of Findings and Questioned Costs
For the Year Ended June 30, 2025
12 Questioned Costs:
Questioned costs were not identified.
Context:
Seven subawards requiring the submission of a n subaward report were selected for testing from a total population of seven subrecipient awards. Three of the seven tested reports were not submitted in a timely manner.
Effect:
Because the required submission was not completed by the applicable due date, the City was not in compliance with the provisions of the FFATA reporting requirements.
Recommendation:
The Human Services Department which oversees this program should develop and document a standardized process to identify, track , and report all subaward agreements and modifications executed during the fiscal year that are subject to FFATA reporting requirements.
Views of Responsible Officials and Planned Corrective Action:
Management’s response is reported in the “Corrective Action Plan” section of this report.
CITY OF FREMONT
Summary Schedule of Prior Audit Findings
For the Year Ended June 30, 2025
13 No prior audit findings were reported.
Finance Department
3300 Capitol Avenue, P.O. Box 5006, Fremont, CA 94537-5006 510 494-4610 ph | 510 494-4611 fax | www.fremont.gov
14 Corrective Action Plan
For the City Fiscal Year Ended June 30, 2025
Reference Number: 2025-001
Awarding Agency: U.S. Department of Hous ing and Urban Development Program Name: Community Development Block Grants/Entitlement Grants Assistance Listing Number: 14.218
Award Number: B-24-MC-06-0011
Federal Award Year: Fiscal Year Ended June 30, 2024
Category of Finding: Reporting
Type of Finding: Instance of Noncompliance; Significan t Deficiency in Internal Control Over Compliance
1. Person responsible: CDBG Administrator
2. Corrective Action Plan:
The City of Fremont agrees with the finding and recommendation. To strengthen compliance with FFATA reporting requirements, program staff will pr ovide the subrecipient or contractor with the FFATA reporting notice, including the request for the five most highly compensated officers, at the same time the contract is sent for signature . Aligning these documents will improve tracking, as the subrecipient or contractor will return both the signed contract and the FFATA reporting notice together. Once staff receives the fully ex ecuted contract, the FFATA reporting system will be updated promptly. A screenshot showing the date and time of the submission will be retained in the contract file to document timely reporting and ensure continued compliance.
3. Anticipated implementation date: April 1, 2026