Management Response: COR3 has already undertaken proactive measures to strengthen oversight, streamline procedures, and provide tailored guidance to support Subrecipients effectively. Efforts to Promote Compliance and Support Subrecipients. During the past years, COR3 has undertaken significant efforts to assist Subrecipients in meeting regulatory requirements and adhering to COR3 policies and procedures. This has been achieved through tailored guidance provided via individual phone calls and meetings, ensuring that Subrecipients receive direct and actionable support to navigate compliance challenges effectively.Amendments to Chapter 7 (Payments & Cash Management) and SOPs. Recognizing the unique circumstances in Puerto Rico, including challenges related to construction permits and the shortage of construction services, COR3 has proactively amended Chapter 7 (Payments & Cash Management) of its policies and procedures, along with the corresponding Standard Operating Procedures (SOPs). These updates have been thoughtfully designed within COR3’s regulatory authority to account for the realities faced by Subrecipients, addressing delays in project completion and documentation submission. The changes to Chapter 7 include the following enhancements: Added requirement of the submittal of a 90-day spend plan through the Disaster Recovery System (DRS) to the Request for Capital Advance (RFCA) Pilot Program, notating what the advanced funds will be used for Eliminated proration selection from the RFCA reconciliation process – Subrecipients will no longer be able to defer the reconciliation of the RFCA. Revised the term to reconcile the RFCA on or before 180 days from disbursement (RFCA Initial Term), up to a maximum of 12 months from disbursement. Added requirement to submit monthly RFCA reconciliation RFRs if total reconciliation is not completed within RFCA Initial Term. Removed requirement to submit a status report within 90 days of RFCA disbursement. Added Project/RFCA status report requirement within 180 days of RFCA disbursement if total reconciliation is not completed within RFCA Initial Term. Added percentage range to RFCA Requests in 5% increments up to a maximum of 25%, thereby ensuring that funds being advanced are tailored to the subrecipients’ needs. Introduced a 25% minimum amount for reconciliation of RFRs to ensure that the advance is reconciled in a consistent manner; certain exceptions apply. Modified RFR Threshold amounts as recommended but not required. Implemented yearly notification requirements for interest earned on advances. Additionally, COR3 is amending the Advance Requirement Compliance Protocol (SOP No. 022) to address the non-compliant Subrecipients (1) with a backlog of RFR’s reconciliations, among other related matters. The primary objective of the procedure is to establish clear communication channels and procedures between COR3 and Subrecipients who are not adhering to required policies and procedures. For example, for Subrecipients with RFCAs disbursed 12 months or more which have yet to be reconciled, COR3’s Finance Division will take a series of actions to address noncompliance, starting with a request for documentation such as bank certifications or account statements. Subrecipients will have an additional 30 days to reconcile the RFCA. Failure to do so will result in a recoupment letter demanding the return of unreconciled funds or suspension of disbursements. If noncompliance persists, the Finance Division will issue a final warning letter, detailing the outstanding RFCAs and implementing the suspension of disbursements until the issue is resolved. These comprehensive amendments reflect COR3's commitment to promoting clarity, accountability, and efficiency while supporting Subrecipients in achieving their project goals within the established regulatory framework. Impact of These Efforts COR3’s initiatives have resulted in Subrecipients being better informed about their obligations in managing federal funds, as a result several Subrecipients have voluntarily returned advance payments that were not utilized or reconciled within the required timeframe. These actions illustrate COR3’s strategies in promoting accountability and compliance among Subrecipients and fostering a cooperative environment for financial and operational transparency. This reflects COR3’s ongoing efforts to support Subrecipients in achieving their project goals within the regulatory framework. Corrective Action Plan: Implement and monitor the updates made to Chapter 7 and approve the amendments and implement the new SOP (Advance Requirement Compliance Protocol (SOP No. 022)), to achieve a cooperative environment with our subrecipients for financial and operational transparency. Contact Person: María Cardec, Grants Director Anticipated Completion Date: Completed as of February 28, 2026