Alpha Covenant Holdings · Duty Sheet · generated 2026-10-25 17:45 UTC · free · all sheets

Construction lending and title — the public-record read at each draw request (lender's own draw conditions; no statutory duty asserted)

Applies to: Construction lenders, mezzanine and private-credit funds, title and escrow companies and loan administrators who release periodic draws to a general contractor and its subcontractors · Rule text: https://www.osha.gov/enforcement

The question the rule asks

At this draw, what did SAM.gov Exclusions, OSHA's enforcement file, the DOL Wage and Hour enforcement file, EPA ECHO, OFAC and the contractor's state registry print under the exact name and keys — and which did not answer? OSHA and WHD actions reach their public files weeks to months after the event, so a receipt bounds what was published by its file date; it cannot promise that nothing happened in the last 30 days. Whether to release, hold or ask is the lender's condition and the lender's call.

The party this sheet is about

Wellpath LLC · keys supplied: UEI JL99G1YPJKK9 · matching: screening-2026-06f: every check is an exact-name (or exact-UEI / exact-NPI / exact-EIN / exact-CIK) lookup against the official file named on the line; nothing is inferred from similar names, owners or affiliates

Receipt r_58e1c48ea3ce44d6 · read 2026-10-25 17:45:11 UTC · SHA-256 cb5c11cd7bb387a6fd582e9a1b9750b58ad2edbccde2d479ae41a370c7f4916c · verify: https://alphacovenantholdings.com/r/r_58e1c48ea3ce44d6

The official files that answer it, as read on that date

Source	Role	State	Records	What it printed
SAM.gov Exclusions — Public Extract V2 (GSA, daily)	answers the question	answered	0	No entry under this exact name/UEI in the SAM extract fetched 2026-10-25 (SAM_Exclusions_Public_Extract_V2_26298.ZIP).
OSHA inspection records (DOL Enforcement API — inspections opened in the last five years, by establishment name as OSHA prints it)	answers the question	answered	2	2 OSHA inspection(s) opened since 2021-10-25 under this exact printed establishment name (0 with no close date printed); 3 establishment name(s) containing these words listed as candidates, not counted
EPA ECHO (Enforcement and Compliance History Online) — facility records	supporting	answered	0	ECHO returned 3 facility record(s) for a name search on 'Wellpath LLC'; 0 carry this exact printed name. Each row links to EPA's own Detailed Facility Report.
U.S. Treasury OFAC — Specially Designated Nationals and Blocked Persons List (SDN.CSV)	supporting	answered	0	No entry under this exact name or listed alias on the SDN list fetched 2026-10-24.
HHS Office of Inspector General — LEIE (monthly downloadable file)	supporting	answered	0	No entry under this exact name in the OIG file fetched 2026-10-25.
Consolidated Screening List (trade.gov) — BIS, State and Treasury lists, OFAC SDN excluded here because it is read directly	supporting	answered	0	0 export-control or sanctions list entries (BIS, State, Treasury non-SDN) under this exact printed name
USAspending.gov (recipient name equals this name)	supporting	answered		1 registered recipient(s) equal this name; 24 active prime award(s), $3,830,809 obligated
SAM.gov entity registration	cross-source	did not answer — nothing stands in for it
State checkbooks & UCC (VT, DE, CT)	cross-source	answered	2	VT $105,557,157 over 17 payments; CT $5,064 over 3 payments

What to record in the file

One dated receipt per contractor per draw with the draw number in the reference field (or POST /api/ap/check with partner_reference = the draw); the two facts a workflow can branch on — all_list_sources_answered and exact_rows_total — with a silent source routed to a person, never read as zero. The release decision is recorded by the lender's officer as a decision record, not by the platform.

What this sheet does not decide

The receipt does not decide eligibility, responsibility, identity or compliance. It records what each official file printed for an exact key or exact printed name on a date. A same-name row is a candidate to be resolved by the reader, not a match. Answering the form's question is the applicant's or reviewer's act; this sheet puts the dated record beside it.

Full receipt (all sources, known limits, print record): screening record · Methodology: https://alphacovenantholdings.com/methodology · Corrections (free, public log): https://alphacovenantholdings.com/corrections