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Are construction, repair projects funded with QSCBs subject to the Buy American, National Environmental Policy Act, reporting, and whistle-blower requirements?

April 26, 2017American buy Construction Environmental National Projects qscbs Repair Subject

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Are construction, repair projects funded with QSCBs subject to the Buy American, National Environmental Policy Act, reporting, and whistle-blower requirements?

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No. (Response received from Office of the General Counsel, USDE) QSCBs are not subject to the provisions in Division A because they are authorized in Division B of the Recovery Act. Davis-Bacon prevailing wage requirements are in both divisions. I have heard that the Treasury folks may be consulting with the Department of Labor on that issue. If you need more technical advice on other terms and conditions, as well as the Davis-Bacon terms, I suggest you contact Branch 5 of the Internal Revenue Service, Office of Associate Chief Counsel (Financial Institutions and Products) (202-622-3980).