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HUD-4010

HUD-4010 Federal Labor Standards Provisions — Davis-Bacon on HUD-assisted construction

Davis-Bacon and related acts on federally funded construction (29 CFR 5) — the steps as written

#StepWhoWhenRecordCitation
1Put the wage determination and the labor standards clauses into the contract and every subcontract.contracting agency; prime for subsat solicitation and subcontractcontract and subcontract29 CFR 5.5(a); 29 CFR 5.6(a)(1)
2 ●Do not award to a person or firm on the WHD ineligible (debarred) list; check SAM Exclusions as well where federal funds flow.contracting agency; prime for subsbefore award and before each subcontractthe dated SAM read; the WHD list is printed 'not read' with its official link because DOL refuses automated reads29 CFR 5.12(a)(1); 2 CFR 180.300; FHWA-1273 §XI
3Each contractor and subcontractor submits a weekly payroll with a signed Statement of Compliance.contractor and each subcontractorweekly, within 7 days of the pay dateWH-347 or equivalent with Statement of Compliance29 CFR 5.5(a)(3)(ii)
4The agency reviews payrolls and conducts employee interviews.contracting agencyduring performancepayroll review and interview records29 CFR 5.6(a)(3)
5Retain payrolls and basic records three years after completion.contractor3 yearspayroll records29 CFR 5.5(a)(3)(i)

● a dated receipt is the record at this step.

Keeping the file

#StepRecordWhere
F1At each ● step, pull the dated receipt under the party's exact name or UEI and file its receipt id with the transaction record.receipt id (r_…) on the procurement, subaward or payment recordhttps://alphacovenantholdings.com/screening
F2Anchor your own document for the step — the signed check, the certification, the memo — by its SHA-256 beside the receipt. The document stays with you; only its hash is logged.anchor id (a_…) in the same log as the receipthttps://alphacovenantholdings.com/r/{receipt_id} → Anchor
F3Note the retention line the file sits under and, once the trigger date is known, the date the period runs to.the rule's own words and date (FAR 4.703/4.705 or 2 CFR 200.334)https://alphacovenantholdings.com/api/retention/rules
F4At period end, keep the signed file statement for the organization: every receipt and anchor, the sources read and which did not answer, the log head they chain to.one signed page per UEI; its hash and signature verify without Alpha Covenanthttps://alphacovenantholdings.com/file/{uei}

How the dated records are kept, not what they prove. A receipt shows what the official file printed on the read date; an anchor shows a document existed in that exact form on that date; the file statement lists what the file holds. None of them states that a step was done correctly or that the organization is eligible or compliant.

How the auditor tests it

The steps as the regulation and the auditor's program state them, each with its citation. Nothing here is advice or a determination; the agency's text controls. A dated receipt is the record at the marked steps — it shows what the official file printed on the read date, not that the step was done correctly.

Not legal advice, not a compliance determination, not a statement that any filer's certification is true or false. Form numbers and line numbers are as published on the date noted and may be renumbered by their agencies; the official page controls. Audit findings quoted are the auditor's words as filed at the Federal Audit Clearinghouse, cited by report id; they describe a documentation gap, not a conclusion about any party.