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Agenda 06/08/2021 Item #16D 1 (Budget Amendment & Approval of revised Award terms for American Rescue Plan from US Dept. of Treasury)
06/08/2021 EXECUTIVE SUMMARY Recommendation to accept the second allocation of Emergency Rental Assistance from the American Rescue Plan from the U.S. Department of Treasury in the amount of $9,088,102, approve the after the fact execution of award terms, notify the Board of revised certification of award terms for ERA 1, revise program terms, authorize, and extended and increase temporary full-time staff and extend existing assistance center lease; and authorize the necessary Budget Amendment. OBJECTIVE: To continue to provide grant funding to Collier County residents unable to pay rent and utilities due to the impacts of the COVID-19 pandemic. CONSIDERATIONS: On January 5, 2021, the U.S. Department of Treasury announced funding available to state and local governments to provide financial support to residents that are unable to pay rent and utilities due to the impacts of the COVID-19 pandemic. Collier County was eligible for this funding since our resident population exceeds 200,000 and per the Consolidated Congressional Act of 2021. The Emergency Rental Assistance (ERA) Program made available $25 billion to assist nationwide. On January 26, 2021, Agenda Item #16D7, the Board of County Commissioners (Board) accepted the ERA 1 funding in the amount of $11,622,381. On March 25, 2021, the County was notified that the US Treasury had modified our award terms, extending the award and administrative cost terms. The revised certification of terms includes: a. Section 3 is amended by replacing “December 31, 2021” with "September 30, 2022”. b. Section 4 is deleted in its entirety and replaced with the following: 4. Administrative costs. a. Recipient may use funds provided to the Recipient to cover both direct and indirect costs. b. The total of all administrative costs, whether direct or indirect costs, may not exceed ten (10) percent of the total amount of the total award. On March 11, 2021, President Biden signed the American Rescue Plan (ARP). As part of the ARP, the County will receive an additional ERA 2 award in the amount of $9,088,102. These funds will be received by the County no later than May 10, 2021. These funds have a fifteen percent (15%) administration allocation and must be expended by September 30, 2025. This program will be similar to the initial ERA program awarded in January 2021, however US Treasury guidance will determine program eligibility. Individual Assistance (Rental, and Utilities Payment) Emergency Rental Assistance 1 and 2 criteria states residents are eligible to receive these payments based on the following US Treasury and County criteria: 1. Resident qualifies for unemployment or has experienced a reduction in household income, incurred significant costs, or must have had a loss of employment or reduced hours due to COVID-19; or experienced a financial hardship due to COVID-19. · Priority is given to households that include an individual who has been unemployed for ninety (90) days prior to application for assistance and households with income at or below fifty percent (50%) of the area median. 2. Resident demonstrates a risk of experiencing homelessness or housing instability; and 3. Resident has a household income at or below eighty percent (80%) of the area median. · Household income is determined as the household’s total income for calendar year 2020 or 16.D.1 Packet Pg. 1572 06/08/2021 the household’s monthly income at the time of application. Household income determined monthly must be re-determined every three (3) months in order to remain eligible for assistance. · Payments will be made directly to the landlord, and/or utility company unless the landlord refuses to participate payments may be made to the applicant. · Applicants must be Collier County residents or maybe a Landlord on behalf of an eligible household. · At least one person in the household must be a US citizen or an eligible non-citizen · Eligible households may receive up to twelve (12) months of assistance, plus an additional three (3) months for ERA 1 and six (6) months for ERA 2, if the County determines the extra months are needed to ensure housing stability and funds are still available. Households that are at risk of eviction will take payment priority. · Assistance must be provided to reduce an eligible household’s rental arrears before the household may receive assistance for any future rent payments. · Once the rental arrears are reduced, the County may only commit to future assistance for up to three months at a time and a household may receive additional assistance for a total of 15 months for ERA 1 and 18 months for ERA 2. 4. Recipients will not be required to provide documentation that may be a barrier to participation in the program i.e. applicants may verify income eligibility by any reasonable fact-specific proxy, such as the average income of the neighborhood they live in Staff is offering an offsite application center and opened the application portal in March. The lease for the location will need to be extended for staff to continue to offer this service to the community. Approval of the amended lease will allow continued community outreach and accessible in person service. Implementation of a $20.7 million-dollar federal grant program is extremely complex and requires additional staff to oversee and administer. In addition to the administrative-accounting and processing for internal costs, high demand is expected for any external assistance programs that are implemented. Since activating a similar program through CARES, staff had received thousands of applications for assistance. As such, the award allows for administrative expense. Two (2) temporary full-time employees are being requested to provide management oversight and fiscal support, in addition to utilizing a temporary staffing contract. Staff previously received approval for COVID staff and is requesting approval to ut ilize those positions for all COVID programs and approval to retain these temporary positions through 2025 or when all administrative funds are exhausted, whichever comes first. The associated payroll expenses for employees whose services are necessary to administer and account for this program are fully reimbursable and will be used to expedite and track any payments and compliance measures necessary. The additional temporary staff being extended will include: (1) Federal and State Grant Manager and (1) Financial and Operational Support Manager and Temporary contracted staff, as needed. The US Treasury announcement for ERA 2 was made on May 6, 2021. Staff timely submitted the executed award terms by deadline of May 10, 2021. Due to the short, turnaround, CMA #5330 authorizes the County Manager to approve the submittal of grant applications, acceptance of funding and related documents. FISCAL IMPACT: A Budget Amendment is required to recognize grant funding from the U.S. Department of Treasury under the America Rescue Plan Act in the amount of $9,088,102, Project 33761 in Housing Grant Fund (705). There is no match required for this grant program. 16.D.1 Packet Pg. 1573 06/08/2021 GROWTH MANAGEMENT IMPACT: There is no Growth Management impact associated with this Item. LEGAL CONSIDERATIONS: The new terms are a condition of the award and by accepting the payment, the County is automatically deemed to have accepted the terms. As such, the Chairman's signature is not required to accept new terms. This item is approved for form and legality and requires a majority vote for Board action. -JAB RECOMMENDATION: To accept the second allocation of Emergency Rental Assistance from the American Rescue Plan from the U.S. Department of Treasury in the amount of $9,088,1 02, notify the Board of revised certification of award terms, authorize, and extended temporary full-time staff; extend existing assistance center lease and authorize the necessary Budget Amendment. Prepared By: Kristi Sonntag, Director, Community and Human Services ATTACHMENT(S) 1. US Treasury Agreement Amendment (PDF) 2. US Treasury Agreement (PDF) 3. AGRMT 2021 05-10 DOT ERA2-0347 (PDF) 16.D.1 Packet Pg. 1574 06/08/2021 COLLIER COUNTY Board of County Commissioners Item Number: 16.D.1 Doc ID: 15477 Item Summary: Recommendation to accept the second allocation of Emergency Rental Assistance from the American Rescue Plan from the U.S. Department of Treasury in the amount of $9,088,102, notify the Board of revised certification of award terms, authorize, and extended temporary full-time staff; and authorize the necessary Budget Amendment. Meeting Date: 06/08/2021 Prepared by: Title: – Community & Human Services Name: Jennesse Delgado 04/02/2021 3:09 PM Submitted by: Title: Manager - Federal/State Grants Operation – Community & Human Services Name: Kristi Sonntag 04/02/2021 3:09 PM Approved By: Review: Operations & Veteran Services Geoffrey Willig Additional Reviewer Skipped 05/18/2021 5:32 PM Public Services Department Todd Henry Public Services Department Completed 05/19/2021 7:40 AM Public Services Department Dan Rodriguez PSD Department Head Completed 05/25/2021 11:00 AM Community & Human Services Lisa Carr Additional Reviewer Completed 04/02/2021 3:15 PM Community & Human Services Kristi Sonntag CHS Review Completed 04/02/2021 6:33 PM Community & Human Services Maggie Lopez Additional Reviewer Completed 04/08/2021 1:42 PM County Attorney's Office Jennifer Belpedio Level 2 Attorney of Record Review Completed 04/14/2021 10:44 AM Grants Erica Robinson Level 2 Grants Review Completed 04/16/2021 3:52 PM Office of Management and Budget Debra Windsor Level 3 OMB Gatekeeper Review Completed 04/27/2021 11:55 AM Budget and Management Office Ed Finn Additional Reviewer Completed 04/28/2021 5:37 PM County Attorney's Office Jeffrey A. Klatzkow Level 3 County Attorney's Office Review Completed 04/29/2021 1:08 PM Grants Therese Stanley Additional Reviewer Completed 05/17/2021 2:50 PM County Manager's Office Sean Callahan Level 4 County Manager Review Completed 05/17/2021 6:27 PM Board of County Commissioners Geoffrey Willig Meeting Pending 06/08/2021 9:00 AM 16.D.1 Packet Pg. 1575 U.S. DEPARTMENT OF THE TREASURY EMERGENCY RENTAL ASSISTANCE March 26, 2021 Effective as of the date hereof, the award terms accepted by Recipient as a condition to the receipt of payment from Treasury pursuant to section 501 of Subdivision N of the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260 (Dec. 27, 2020) are amended as follows: Section 3 is amended by replacing “December 31, 2021” with “September 30, 2022”. Section 4 is deleted in its entirety and replaced with the following: 4. Administrative costs. a. Recipient may use funds provided to the Recipient to cover both direct and indirect costs. b. The total of all administrative costs, whether direct or indirect costs, may not exceed 10 percent of the total amount of the total award. Attached hereto are the award terms restated to reflect this amendment. 16.D.1.a Packet Pg. 1576 Attachment: US Treasury Agreement Amendment (15477 : US Department of Treasury Amendment) 2 U.S. DEPARTMENT OF THE TREASURY EMERGENCY RENTAL ASSISTANCE Use of Funds. Recipient understands and agrees that the funds disbursed under this award may only be used for the purposes set forth in Section 501 of Division N of the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260 (Dec. 27, 2020) (referred to herein as “Section 501”). Repayment and reallocation of funds. a. Recipient agrees to repay excess funds to Treasury in the amount as may be determined by Treasury pursuant to Section 501(d). Such repayment shall be made in the manner and by the date, which shall be no sooner than September 30, 2021, as may be set by Treasury. b. The reallocation of funds provided by Section 501(d) shall be determined by Treasury and shall be subject to the availability of funds at such time. Availability of funds. a. Recipient acknowledges that, pursuant to Section 501(e), funds provided under this award shall remain available only through September 30, 2022, unless, in the case of a reallocation made by Treasury pursuant to section 501(d), Recipient requests and receives from Treasury an extension of up to 90 days. b. Any such requests for extension shall be provided in the form and shall include such information as Treasury may require. c. Amounts not expended by Recipient in accordance with Section 501 shall be repaid to Treasury in the manner specified by Treasury. Administrative costs. a. Recipient may use funds provided to the Recipient to cover both direct and indirect costs. b. The total of all administrative costs, whether direct or indirect costs, may not exceed 10 percent of the total amount of the total award. Reporting. a. Recipient agrees to comply with any reporting obligations established by Treasury, including the Treasury Office of Inspector General, as relates to this award, including but not limited to: (i) reporting of information to be used by Treasury to comply with its public reporting obligations under section 501(g) and (ii) any reporting to Treasury and the Pandemic Response Accountability Committee that may be required pursuant to section 15011(b)(2) of Division B of the Coronavirus Aid, Relief, and Economic Security Act (Pub. L. No. 116-136), as amended by Section 801 of Division O of the Consolidated Appropriations Act, 2021 (Pub. L. No. 116-260). Recipient acknowledges that any such information required to be reported pursuant to this section may be publicly disclosed. b. Recipient agrees to establish data privacy and security requirements as required by Section 501(g)(4). 16.D.1.a Packet Pg. 1577 Attachment: US Treasury Agreement Amendment (15477 : US Department of Treasury Amendment) 3 Maintenance of and Access to Records a. Recipient shall maintain records and financial documents sufficient to support compliance with Section 501(c) regarding the eligible uses of funds. b. The Treasury Office of Inspector General and the Government Accountability Office, or their authorized representatives, shall have the right of access to records (electronic and otherwise) of Recipient in order to conduct audits or other investigations. c. Records shall be maintained by Recipient for a period of five (5) years after all funds have been expended or returned to Treasury. Cost Sharing. Cost sharing or matching funds are not required to be provided by Recipient. Compliance with Applicable Law and Regulations. a. Recipient agrees to comply with the requirements of Section 501 and Treasury interpretive guidance regarding such requirements. Recipient also agrees to comply with all other applicable federal statutes, regulations, and executive orders, and Recipient shall provide for such compliance in any agreements it enters into with other parties relating to this award. b. Federal regulations applicable to this award include, without limitation, the following: i. Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 C.F.R. Part 200, other than such provisions as Treasury may determine are inapplicable to this Award and subject to such exceptions as may be otherwise provided by Treasury. Subpart F – Audit Requirements of the Uniform Guidance, implementing the Single Audit Act, shall apply to this award. ii. Universal Identifier and System for Award Management (SAM), 2 C.F.R. Part 25 and pursuant to which the award term set forth in Appendix A to 2 C.F.R. Part 25 is hereby incorporated by reference. iii. Reporting Subaward and Executive Compensation Information, 2 C.F.R. Part 170, pursuant to which the award term set forth in Appendix A to 2 C.F.R. Part 170 is hereby incorporated by reference. iv. OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement), 2 C.F.R. Part 180 (including the requirement to include a term or condition in all lower tier covered transactions (contracts and subcontracts described in 2 C.F.R. Part 180, subpart B) that the award is subject to 2 C.F.R. Part 180 and Treasury’s implementing regulation at 31 C.F.R. Part 19. v. Recipient Integrity and Performance Matters, pursuant to which the award term set forth in 2 C.F.R. Part 200, Appendix XII to Part 200 is hereby incorporated by reference. vi. Governmentwide Requirements for Drug-Free Workplace, 31 C.F.R. Part 20. vii. New Restrictions on Lobbying, 31 C.F.R. Part 21. 16.D.1.a Packet Pg. 1578 Attachment: US Treasury Agreement Amendment (15477 : US Department of Treasury Amendment) 4 c. Statutes and regulations prohibiting discrimination applicable to this award, include, without limitation, the following: i. Title VI of the Civil Rights Act of 1964 (42 U.S.C. §§ 2000d et seq.) and Treasury’s implementing regulations at 31 C.F.R. Part 22, which prohibit discrimination on the grounds of race, color, or national origin under programs or activities receiving federal financial assistance; ii. The Fair Housing Act, Title VIII-IX of the Civil Rights Act of 1968 (42 U.S.C. § 3601 et seq.), which prohibits discrimination in housing on the basis of race, color, national origin, sex, familial status, or disability; iii. Section 504 of the Rehabilitation Act of 1973, as amended (29 U.S.C. § 794), which prohibits discrimination on the basis of handicap under any program or activity receiving or benefitting from federal assistance; iv. The Age Discrimination Act of 1975, as amended (42 U.S.C. §§ 6101 et seq.) and Treasury’s implementing regulations at 31 C.F.R. Part 23, which prohibit discrimination on the basis of age in programs or activities receiving federal financial assistance; and v. The Americans with Disabilities Act of 1990, as amended (42 U.S.C. §§ 12101 et seq.), which prohibits discrimination on the basis of disability under programs, activities, and services provided or made available by state and local governments or instrumentalities or agencies thereto. False Statements. Recipient understands that false statements or claims made in connection with this award may result in fines, imprisonment, debarment from participating in federal awards or contracts, and/or any other remedy available by law. Publications. Any publications produced with funds from this award must display the following language: “This project [is being] [was] supported, in whole or in part, by federal award number [enter project FAIN] awarded to [name of Recipient] by the U.S. Department of the Treasury.” Debts Owed the Federal Government. a. Any funds paid to Recipient (1) in excess of the amount to which Recipient is finally determined to be authorized to retain under the terms of this award; (2) that are determined by the Treasury Office of Inspector General to have been misused; or (3) that are not repaid by Recipient as may be required by Treasury pursuant to Section 501(d) shall constitute a debt to the federal government. b. Any debts determined to be owed the federal government must be paid promptly by Recipient. A debt is delinquent if it has not been paid by the date specified in Treasury’s initial written demand for payment, unless other satisfactory arrangements have been made. Interest, penalties, and administrative charges shall be charged on delinquent debts in accordance with 31 U.S.C. § 3717 and 31 C.F.R. § 901.9. Treasury will refer any debt that is more than 180 days delinquent to Treasury’s Bureau of the Fiscal Service for debt collection services. c. Penalties on any debts shall accrue at a rate of not more than 6 percent per year or such other higher rate as authorized by law. Administrative charges, that is, the costs of processing and handling a delinquent debt, shall be determined by Treasury. 16.D.1.a Packet Pg. 1579 Attachment: US Treasury Agreement Amendment (15477 : US Department of Treasury Amendment) 5 d. Funds for payment of a debt must not come from other federally sponsored programs. Disclaimer. a. The United States expressly disclaims any and all responsibility or liability to Recipient or third persons for the actions of Recipient or third persons resulting in death, bodily injury, property damages, or any other losses resulting in any way from the performance of this award or any other losses resulting in any way from the performance of this award or any contract, or subcontract under this award. b. The acceptance of this award by Recipient does not in any way constitute an agency relationship between the United States and Recipient. Protections for Whistleblowers. a. In accordance with 41 U.S.C. § 4712, Recipient may not discharge, demote, or otherwise discriminate against an employee as a reprisal for disclosing information to any of the list of persons or entities provided below that the employee reasonably believes is evidence of gross mismanagement of a federal contract or grant, a gross waste of federal funds, an abuse of authority relating to a federal contract or grant, a substantial and specific danger to public health or safety, or a violation of law, rule, or regulation related to a federal contract (including the competition for or negotiation of a contract) or grant. b. The list of persons and entities referenced in the paragraph above includes the following: i. A member of Congress or a representative of a committee of Congress; ii. An Inspector General; iii. The Government Accountability Office; iv. A Treasury employee responsible for contract or grant oversight or management; v. An authorized official of the Department of Justice or other law enforcement agency; vi. A court or grand jury; and/or vii. A management official or other employee of Recipient, contractor, or subcontractor who has the responsibility to investigate, discover, or address misconduct. c. Recipient shall inform its employees in writing of the rights and remedies provided under this section, in the predominant native language of the workforce. Increasing Seat Belt Use in the United States. Pursuant to Executive Order 13043, 62 FR 19217 (April 8, 1997), Recipient should and should encourage its contractors to adopt and enforce on-the-job seat belt policies and programs for their employees when operating company-owned, rented or personally owned vehicles. Reducing Text Messaging While Driving. Pursuant to Executive Order 13513, Recipient should encourage its employees, subrecipients, and contractors to adopt and enforce policies that ban text messaging while driving, and Recipient should establish workplace safety policies to decrease accidents caused by distracted drivers. 16.D.1.a Packet Pg. 1580 Attachment: US Treasury Agreement Amendment (15477 : US Department of Treasury Amendment) 16.D.1.bPacket Pg. 1581Attachment: US Treasury Agreement (15477 : US Department of Treasury Amendment) Ā² ³ǚSHT#1lHIǚ nëǚżïCǚŽ1C#Jp1qǚ Clê1íHIçqǚ1HIû#ðǚ#J kúÿôGCǚ ÔÏ pǚ ĐǚìƷcǚ - ǚ2ǚ ǚǚ ǚħǚĠǚ K 9ǚ"ǚ 'ĬǚNJ( ǚǚ ǚǚě"ǚǚ 9 ǚ:ǚĜ"ǚ ĭǚJ*ǚ ÝÐǚ!ǚjdž*Įǚmǚ!ǚǚG[ # žszǚ #ǚ ǚTa ´ǚñgǚI µǚi<f<ǚ;é¶ǚáǚ 0ǚ ;ſĘ9ƀǚ ǚ(ǚǚ `*ũ 60 Øg oŵǓŢǚǚ\E į ǚ !ǚġ· r¸-+ ǚƁǚǚƂ ǚNǚĢǚǚ F ǚ}ǚ:Ĩǚ%ǚǚ%ǚ ǚ&İ. ǚ"(ǚ 5ƃ.ǚ&ǚ *ǚQŖ/b¹ǚ uǚ >ǚ\ǚ ǚ=ǚ$ǚ3'ǚŪƄǚ ǚuǚ ǚ +ǚDLǚ ǚǚ ƅǚ3'ūǚJ &ţ "ǚP¡ǚi¢ǚǚǚ ǚǚ ǚü"ǔº Ą»ǚ ]Yǚ !ǚģǚ ƟLJǚ ǚ ı ǚ60ǚ'Řǚ ǚ@=zǚ Ǖǚ)^ǚ ]]ǚ ǚ5 ŕ_ǚ& ǚǚ,ʼnE $[Ʀǚ!ǚĤǚǚ5ǚ$%¼ Ù½ #LjŊř ŋŚ4ǖǚUǚĖDŽO ā¾-IJ ǚ A\ǚ£ǚ (ǚ ǚ 7ǚQ/¤ǚėDžŬǚ 2*ǚ>Ɔǚ'ǚA)Č śǚ(%7ǚ,+ ŗǚ ǚ3Ƈ yǚS% ƈǚÚÑdǚ¥ǚƸ>Y¦ǚijǚ'ǚǚ!ǚǚE Ĵ Ťǚ ǚ ?ƹ(ǚ ƺƉǚ 4 ǚ +ǚ 6Zdǚ ù {ǚ ƊMƻǚ ǚ Ƌ,ǚ ğ = 2ǚǚ$ ǚ!ǚ ǚǚãǚO ą¿ #ǚ Ƽvǚ2Mǚĝ)ǚǐ ǚƥLDǚ ǚ ?,Xǚ8ǚvǚ V)ǚ ǚwǚ|tLǚW }.Ğƌ=Ƨ8 ǚ ǚý2ǚ%ǚ)MFƍh ĈÀ å= ǚ ǚ N ǚ ǚ -$ ǚ ǚ@>ǚ7ĩǚ 8 ŭǚ 6ǚ 'LŜǚ ǚ ĵǚ: )FƎǚĶǚ'ǚťǚ +ęǚ ǚ29Á Û #$,ǚ à rh Rķ"ĸ,ǚN ǚ!ǚ-K Ĺǚ%Ǘǚ ǚƏǚǚ(ǚ:§ǚ ƨǚ-Ō 4ǚ%ǘǚ 3 ƐǚXōƠǚ :ǚ a>ǚ &ǚĥǚ ,ĺčǚǚǚNjƑ¨ǚǚ-Ŏ K.ǚǚ 4ǚ D 7ǚ 4+ǚĻļƒǚǚƓƩǚǚ4ǚA)Ä ĆÅ ǚ aǚ!ǚ'ǚ ǚ UǚWǚAƔĎǚǑ ǚǚx8ǚ`Ă $[~ƪǚ ƕ,Ľĉǚ9 ǚ ľ ǚ ÞZB/PBǚ Ůǚ xǚ ǚ đǚWǚ nj(ǚ ǒ ǚ ǚ Ŀơƫŀǚ @Ł ǚǚ 3$ůǚ6;B;6ǚǚŰ ƬǚNǚǚ 2ƭǚ !ǚ'ǚ _YǚǍ?Æ ßÇ -Ŷ)ƮĦe È o ǚ9ǚǚ% ǚǎ&ĪǚǚƖ 47.ǚ `łűǚ ŏǚ ǚþƽ© ǚyǚƗ5ƘǚnĒĚǚ !ǚkŷ?ǚîªǚǚƙ&ǚǚ'ŃǚǏƚ«ǚŝ5ńŲ ǚų &ǚŐ%ǚäǚ/Bǚ )>ǚ!ǚV@ ǚǚ ǚFǚ ǚ""ǚ ǚ= EǚA*wǚ$ ƾ *ǚ" (+ǚ Ş8: ǚǚ* ǚ6Z/ǚăǚő70ǚǚƛ ^ƯKǚǚƜFǚ ǚ ÷sŦǚ1 ǚ# ƿ |şǚè %&ưǚǚǚ ǚŹ+?ǚ ^ǀ4ǚ: Ċ3ǚQÕ0/0ǚŴUǚSŒljŅǚæǚēǚǚG@ .$(ǚR¬ǚ1E!ǚǚC %8ǚ ǁƢƱǙ #&ǚ/øǂ ÉǚòÊǚm ËǚÖ<±ÒP<B®ǚǚŧďǚ ǚ ņǚâǚĔǚj*,ǚöǚ ĕǚ3ǚG 8Ʋ R Ÿ( Ɲ$.ǚ#¯ǚ ǚ;T cǚóÌǚõ °ǚ×<f<0Íǚ 1 3ǚ.ADǚī_ǚǚċ V9+ ǚ?ź57)ǚ ǚ ǚ2 @&ǚ 5ǚǚ ƳŇǚt ǚǚ ǚ Šœšǚ~D Î O -* {.ƴǚ"ǚ ǚ +ǚƵǚ "$,ǚǚ ǃ)ňǚƞŻŔƣŨ&ǚǚ"M5Ƥǚćǚ ƶX àÓ;0/Übe 16.D.1.b Packet Pg. 1582 Attachment: US Treasury Agreement (15477 : US Department of Treasury Amendment) Ô5 í njĀnjnj njnj&R ¤& ģ nję;nj@,9 nj njnjč rŊnjţ Y njƵĊ njnjZ"'njŗ"Őx ĤƟnj( ĥ+nj<ŋI nj L njqnj28A02njnjmnjmƶþ5 0%=nj= ƷD$nj ñċnj1nj ç+ 'njã nj nj nj i[ nj Ƹ#nj òČ njű : nj ŤŲANjnjųQŴG[Knj O;njnjnj 93nj 1nj njnjE nj \Ō Dnj+ Ơnjānj/ nj njŵnjnj Z nj ơnjnjŶnj ĦBŝ¥ %/njĚ{őnjnjħnj#nj7Ĩ"8njĐ njnjŷnj1njĎnj<Jnj$njąƴFnj2NnjĆnjnDŽ nj4ŧnj njUYnj3nj='Ɨ$5 g¦nj(T ė§nj njnjnjPƢ ?ĩnjĂnj njnjŸsŹnjnjnj Īnj#nj7,¨ Ö©ŘŨōī njnj ũŪ2ŀ 0;njënj nj&ĘĬ _ ª& 8M .njźnjnj "y#njAonjnjůVnj1nj(ƣtnj<dnj njóŻ$nj:, ż. r~nj SŽ9nj njCĭTŞ«nj *uB njnj njnj û"z#nj :ěnj Onj |x Ŏnjćž;njnj ƹĮnj nj4įnj nj nj7LQ .njĜnjſ đnjƺ nj 2Ł nj nj #nj} nj v,nj nj @nj Ƥ?nj nj " nj NW njnjİ ¬ njƀnj"QŒł Nnjnjnj njı ;njƻWnjXnj nj>œŔIJ Ù %l:ĒƁřnjw ijnj&ŰƘ Knjnj) "nj njÚĴnj/CƼƙnj> Ƃnj ÿnj!nj`®*Ânj) nj!nj 3nnj ?njnjūĵ njnj=ƃƚ#nj# FP9 nj nj{ njnjƥĢ8njdž nj nj 0Ň njƦnj nj4"HĶşnjnj$nj Eķnj nj#njôƄ'$¯nj (njnj ¢Ûwnj&Cƽ ƛ 3nj1njHnjöēD iY njŬ nj,pnj(ĸ2njunjKnjpŕŖnj$njƧnjĝĹnj % 6 lŠ9Unjåƨ ďnj+nj($ŚnjĔVnjnjî .nj\(knj!nj°%*6nj)ƩnjÏÓnj FƾGnjƪnjĺnj nj nj nj njăťDƫ?nj@nj Ü4njnjƬnj!nj±_/Ãnj)njÐ<njt Ğ$nj Fƅƭnj#njƆĈƇ ü% ŃMń6 & nj(ƿ0 nj nj á4 nj šnjæĕƈPAnjÑnj²³*Änj-Ɖ3njcg HnjƮnjLJğ njnjLjƊnj nj .nj>Hnjnj ""NJnjnjnj!nj´%/µnj-'njdÕnjB Ġ $njĻ 'Ɯ,nj0#nj Ƌ1' ¶ [·ÉïÝnj jŅ+nj nj nj nj äDžEśŢ .ļnj ßúƌ nj nj (ǀŭ J nj!nj ¸a*Ånj)Ưnj ÊhnjInjnjƍC '}njnjv ýznjnj, njƎ Bnjnjy|njnj @Unjnj + nj I3Snjnjǁ+Gnj Ə: Ľnj!nja%&Ænj -GnjËh^nj njÞJnjo,nj nj Tnj8njň njnj!nj¹º*%nj)'nj e×nj+ õ #njŮưnjǂO njWnjfenj65*»nj-ƐnjÌؼ b & ľnjèƝņ$nj nj-Ė njkƱƑ]njZnjnjnjġnjSnjXƒŜnj. ĄŦRƲqnj nj !nj ½%*6nj)'nj !^nj "s4njøéênjnj )Ɠnj!njnjƔ#nj~ Xnj$ VĉE¾ b j Ƴljnj&M nj>njàƕǃ£âƖnj÷ ʼn"ŏ ¡njfÍnj¿À/Çnj-nj!% L %ðnj7ƞĿ njnjì$]njÒÎnj5Á7`nj-ùRnj!cÈ 16.D.1.b Packet Pg. 1583 Attachment: US Treasury Agreement (15477 : US Department of Treasury Amendment) Î #0ǪȐ Ȑ /ƜŦ Ȑƿŧ @_ Ȑ B Ʊ ȐƝŨ &Ȑ ȐũȐ Lj°Ȑ ) &/± geȐƓ eŪ²Ȑ-ȐŘ3bĐ n ūDȐxsȐ$ȐȐ?+ƔȐ( ǫȐȐ|Ȑõ1ąýȐ¦þ÷Ȑ\å#=?>ȐEEȐ ,"""ȐȐJRPȐ Ȑlj/h Hƞ Ȑ4& ȐȐ87Ȑ?ÏZS(æȐ[*Ȑ,,jȐ-ȐNJA HȐŬǟƕŭ Ȑ Ȑ 0Ȑ$Ȑ³ȐĻ´Ȑ *Ȑ Ů ȐƶȐN'Ȑ ȐȐ !2<ȐNjůȄ@ ŋ &Ȑœ%bȐ 2Ē ç ȐĞ2*ȐġŰȐµȐ<cȐxtĤĥÍĢĮȐ$Ȑ9ȐX2!Ȑ(ű-DȐȐŃȐUČWpȐ§VøȐ\Ð#FXFȐȋȐúW"o ǬȐ DžTP¶Ȑ 9ȐǀŲ Ȑ4IųȐȐOŴȐȐ ŞȐ Ȑ ńȐ*jȐ ļb'· ƟȐnj¸Ȑȇ¹ȐGĵcƠȐºȐ*Ȑŵ ē #Ŷ Ȑ Ă"VȐ$ȐȐĨ @ IƽȐȐ$ȐöĎćû»Ȑ Ȑ Ȑ ¨,1ȐwlĩmĚÑȐȌȐ Ĉ1ÿP¼Ȑŷ 6 ŸǧȐ]^ ]Ȑ ȐȐ )Ȑ}Ȑd ȐƷCȐ ȐLKȐ :Ȑ ȅ !ƸȐ;Ȑ Gƙ_ ȐGǣȐŌ*Ȑ Ĕ +>ȐȐYŹ.źǭ ȐǮȐŅȐUďĉă½Ȑ Ȑ Ȑ©VùȐ ĬÒ#F?=ȐȍEȐĆU"ìȐȐJ>iȐ K /Ǧ¤Ȑ %ơ. ǯȐ BOŻȐ Ȑ 87Ȑ ěÓZT(èȐ [;Ȑ ,8¾Ȑ AȐ Ǡ-% ż ) Ȑ Ȑ Ȑ Ȑ {ȐȐ )ȐCǡȐ KȐ !ŽȐ +žȐ ō ŔȐ ) ĕȐ +>Ȑ*ſ ƹȐ 9Ȑĝ 2ƪƖȐȐņȐo11"¿ȐȐ Ȑ ªĀ,Ȑ\Ô#ÕXÖȐEȎȐí,î"ïȐ J×QÀȐ -Ȑ:şƀ ȐƁǥ. % Ȑ Ȑ <Ȑ Ȑ{ȐƂ 3%Ȑ 'Ȑ 5 Á <ƃ+ÂȐ ȐȂȐ!ȐȐ Ȑ !^ƫ ƢȐ ȐǰȐ Ȑ Ȑ!6 'ȐOƲDAȐȐ ȐǍDZØ čÃȐ q3Ȑ# mȐvǁƄ DzȐ0* Ȑ Ȑʼn3Ȑ .ǨȐ:ȐĿ3]Ȑ.Ȑ Ȑƺzƅ Ȑ eȐ Ȑ 4Ȑ Ȑ0ƣȐH ȐŕÄȐƆƳǂ_ÅȐ L. 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