Section 3 Owner Compliance Checklist
Last Updated: April 2026
As a Recipient of U.S. Department of Housing and Urban Development (HUD) assistance exceeding $300,000, you are required to comply with Section 3 of the Housing and Urban Development Act of 1968 and Code of Federal Regulations, title 24, part 75 (together, “Section 3”). Section 3 requires that you and all Contractors and Subcontractors associated with the Section 3 Project (Project) take steps so that Low- and Very Low-Income Persons and Section 3 Business Concerns have an opportunity to benefit from the Project.
Instructions: Return this completed and signed checklist to Minnesota Housing via the Multifamily Customer Portal for approval prior to releasing the Project bid package. Additionally, collect the completed and signed checklist from the general Contractor and submit to Minnesota Housing either prior to releasing the Project bid package or shortly after selecting the general Contractor.
Retain copies of all Section 3 related documentation referenced below for later review by Minnesota Housing, HUD, and/or its representatives in accordance with all recordkeeping requirements outlined in 24 C.F.R. 75.31.
Capitalized terms are defined in Appendix B of the Multifamily Division Section 3 Compliance Guide. This guide and all Section 3 forms referenced can be found on Minnesota Housing’s HOME Investment Partnerships and National Housing Trust Fund webpage.
Section 3 Project Name:      
Project Development Number: D     
Company Name:      
Below are the requirements you must meet to help ensure that you comply with Section 3 and against which Minnesota Housing will evaluate your performance. Initial next to each item acknowledging you understand and will comply with the provisions.
1.	      Comply with Section 3 requirements in your operations and in the operations of your Contractors and Subcontractors.
2.	      Notify potential Contractors of the Section 3 requirements found in 24 C.F.R. 75 by providing the Multifamily Division Section 3 Compliance Guide and all appendices before bidding.
3.	      Review and include Minnesota Housing’s Section 3 Clause in all Contracts and bid packages. Contracts and bid packages must be submitted to Minnesota Housing for approval via the Due Diligence Checklist in the Multifamily Customer Portal prior to the execution of any Contracts or release of the Project bid package.
4.	      Require that all Contractors and Subcontractors provide you copies of subcontracts showing inclusion of Minnesota Housing’s Section 3 Clause.
5.	      Take steps to meet or exceed the current HUD Section 3 Benchmarks as defined below:
a.	Section 3 Workers: 25% or more of the total number of labor hours worked by all workers on a Section 3 Project.
b.	Targeted Section 3 Workers: 5% or more of the total number of labor hours worked by all workers on a Section 3 Project.
6.	      Certify to follow the prioritization requirements found in 24 C.F.R. 75.19.
7.	      Implement procedures designed to notify Section 3 Workers about training and Employment Opportunities and Section 3 Business Concerns about contracting opportunities generated by Section 3 covered assistance.
8.	      Complete and submit the Section 3 Qualitative Efforts Reporting Form to Minnesota Housing via the Post-Construction Due Diligence Checklist in the Multifamily Customer Portal prior to Project Completion.
9.	      Require that Contractors and Subcontractors complete and submit the Section 3 Qualitative Efforts Reporting Form to you. These forms must then be submitted to Minnesota Housing prior to Project Completion2.
10.	      Require that Contractors and Subcontractors identify all eligible Section 3 Workers, Targeted Section 3 Workers, and Section 3 Business Concerns and submit copies of all certification forms collected to the general Contractor. These forms must then be submitted to Minnesota Housing prior to beginning work onsite. 
11.	      If new Subcontractors are hired after the start of construction, help ensure that they promptly identify all eligible Section 3 Workers, Targeted Section 3 Workers, and Section 3 Business Concerns and submit copies of all certification forms collected to the general Contractor. These forms must then be submitted to Minnesota Housing prior to beginning work onsite.
12.	      Help ensure that Contractors and Subcontractors identify all eligible Section 3 Workers and Targeted Section 3 Workers and enter their labor hours worked on a weekly basis in LCPtracker during Project construction. If labor hours are not required to be entered into LCPtracker, then labor hours must be documented using the Labor Hours Certification Form and submitted monthly to Minnesota Housing.
I,       (Name), as the       (Title) of       (Company), hereby certify that I am authorized to sign on behalf of       (Company), have been supplied with a copy of and have read Minnesota Housing’s Multifamily Division Section 3 Compliance Guide, including all appendices, and fully understand and acknowledge, on behalf of       (Company), the obligation to strictly comply with the requirements set forth therein and above.
     	     
Authorized Signatory Printed Name	Title
     	     
Authorized Signature	Date