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D. Record Keening <br />Sufficient records must be established and maintained to enable the CITY and HUD to determine <br />whether the ESG-CV requirements are being met. Record keeping requirements must conform to <br />the policies and procedures as established by the CITY. All accounting records, reports, all <br />evidence pertaining to costs, expenses, and ESG-CV Funds of the SUBRECIPIENT, and all <br />documents related to this AGREEMENT shall be maintained and kept available at the <br />SUBRECIPIENT'S office or place of business for the duration of the AGREEMENT and <br />thereafter for five (5) years post -completion of an audit in conformity with the ESG-CV <br />requirements, except as hereinafter provided relating to retention of any records or documentation <br />existing, created, or maintained in compliance with Lead -based Paint regulations, which likely <br />require longer retention as outlined below. Records which relate to (a) complaints, claims, <br />administrative proceedings or litigation arising out of the performance of this AGREEMENT, or <br />(b) costs and expenses of this AGREEMENT to which the CITY or any other governmental <br />agency takes exception, shall be retained beyond the five (5) years until complete resolution or <br />disposition of such appeals, litigation claims, or exceptions. All said records must be retained for <br />the greater of the aforementioned duration or the periods specified in 24 CFR 576.500(y). All <br />records relating to, or created or maintained in compliance with, the Lead -Based Paint regulations <br />shall be retained and maintained by the SUBRECIPIENT indefinitely, including without <br />limitation, all inspection report(s), disclosure statement(s), and clearance report(s). Copies made <br />by microfilming, photocopying, or similar methods may be substituted for the original records. <br />The CITY, HUD and auditors shall have the right to access all the SUBRECIPIENT records for <br />as long as the records are retained by the SUBRECIPIENT. In the event the SUBRECIPIENT does <br />not make the above -referenced documents available within the City of Santa Ana, California, the <br />SUBRECIPIENT agrees to pay all necessary and reasonable expenses incurred by the CITY in <br />conducting any audit at the location where said records and books of account are maintahned. <br />The SUBREOPIENT agrees to meet the requirements set forth in 24 CFR § 576.500. <br />E. Homeless Management Information Systems (HMIS) <br />(1) Generally. The SUBRECIPIENT must ensure that data on all persons served and all <br />activities assisted under ESG-CV are entered into the applicable community -wide HMIS in the <br />area in which those persons and activities are located, or with the express knowledge and written <br />consent of the CITY, a comparable database, in accordance with IIUD's standards on <br />participation, data collection, and reporting under a local HMIS. <br />(2) 11MIS Agency Agreement. The SUBRECIPIENT shall have an agreement in place with <br />the I MIS lead agency to participate in the regionally HMIS system. A copy of the <br />SUBRECIPIENTS agreement with the HMIS lead agency shall be attached to this agreement as <br />Exhibit F. In the case of Domestic Violence service providers or other agencies prohibited from <br />entering data into HMIS, documentation from the I4MIS lead agency certifying that the <br />SUBRECIPIENT is using a comparable database shall be attached to this agreement as Exhibit <br />E. <br />(3) HMIS Interagency Data Sharing Agreement. The SUBRECIPIENT shall enter into an <br />Interagency Data Sharing Agreement with the HMIS Lead Agency where the SUBRECIPIENT <br />15 <br />