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2. Cost Principles <br />The Subrecipient shall administer its program in conformance with OMB Circulars A -122, <br />"Cost Principles for Non - Profit Organizations," or A -21, "Cost Principles for Educational <br />Institutions," as applicable. These principles shall be applied for all costs incurred <br />whether charged on a direct or indirect basis. <br />B. Documentation and Record Keeping <br />The City of San Marcos is governed by the Texas Public Information Act, Chapter 552 of <br />the Texas Government Code. This Agreement and all written information generated <br />under this agreement may be subject to release under this Act. <br />Records to be Maintained <br />The Subrecipient shall maintain all records required by the Federal regulations specified <br />in 24 CFR 570.506 that are pertinent to the activities to be funded under this Agreement. <br />Such records shall include but not be limited to: <br />a. Records providing a full description of each activity undertaken; <br />b. Records demonstrating that each activity undertaken meets one of the <br />National Objectives of the CDBG program; <br />C. Records required to determine the eligibility of activities; <br />d. Records required to document the acquisition, improvement, use or <br />disposition of real property acquired or improved with CDBG assistance; <br />e. Records documenting compliance with the fair housing and equal <br />opportunity components of the CDBG program; <br />f. Financial records as required by 24 CFR 570.502, and 24 CFR 84.21 -28; <br />and <br />g. Other records necessary to document compliance with Subpart K of 24 <br />CFR Part 570. <br />2. Retention <br />The Subrecipient shall retain all financial records, supporting documents, statistical <br />records, and all other records pertinent to the Agreement for a period of four (4) years. <br />The retention period begins on the date of the submission of the City's annual <br />performance and evaluation report to HUD in which the activities assisted under the <br />Agreement are reported on for the final time. Notwithstanding the above, if there is <br />litigation, claims, audits, negotiations or other actions that involve any of the records <br />cited and that have started before the expiration of the four -year period, then such <br />records must be retained until completion of the actions and resolution of all issues, or <br />the expiration of the four -year period, whichever occurs later. <br />3. Client Data <br />(a) The Subrecipient shall maintain client data demonstrating client eligibility for services <br />provided. Such data shall include, but not be limited to, client name, address, income <br />level or other basis for determining eligibility, and description of service provided. <br />Such information shall be made available to City monitors or their designees for <br />review upon request. <br />Format approved 2014 Page 7 <br />