Section 3 Certification

Effective November 30, 2020, HUD updated its Section 3 regulations to create incentives for employers to do the following:

  • retain and invest in low- and very low-income workers.
  • streamline reporting requirements.
  • provide program-specific oversight.
  • clarify the obligations of entities that are covered by Section 3.

The Division of Grants Monitoring & Administration conducted a Section 3 training on the new regulations per the final rule that went into effect on November 30, 2020.

The Individual and Business concern certification forms and the new regulations are listed below. They are also posted on the Policies and Procedures page along with the Section 3 CPD Notice 21-07(PDF, 225KB) and FAQs.

Key Changes to Section 3

Focus on labor hours instead of new hires.

  • Threshold for reporting housing and community development financial assistance is $200,000; and $100,000 when assistance is from Lead Hazard Control and Healthy Homes (LHCHH) programs.
  • Two Safe Harbor Benchmark Goals
    • 25% or more of the total number of labor hours worked by all workers on a Section 3 project are from Section 3 workers;
    • 5% or more of the total number of labor hours worked by all workers on a Section 3 project are from Targeted Section 3 workers, as defined at 24 CFR Part 75.21.
  • Safe Harbor via Qualitative Efforts 
    • Any subrecipient or contractor that does not meet the Section 3 benchmarks must demonstrate why meeting the benchmarks were not feasible. They must provide evidence that they have made qualitative efforts to assist low and very low-income persons with employment and  training opportunities.

Benefits of Section 3 Certification

There are benefits to attaining a Section 3 Certification because of the economic and employment opportunities associated with it. The City of San Antonio receives HUD sourced funding for rehabilitation, housing construction, and other public construction projects that exceed $200,000. HUD requires significant efforts toward hiring Section 3 workers for construction work on those types of projects so the City of San Antonio makes concerted efforts to support certified businesses and individuals. All you have to do is get certified!

The GMA Section 3 Coordinator will maintain a listing of certified businesses and it will be available upon request.

Section 3 Labor Hours & Projects

Labor Hours

Labor hours are the number of paid hours worked by persons on a Section 3 project or by persons employed with funds that include public housing financial assistance.

In addition to employees working directly on the construction project, core employees also include but are not limited to the following: administrative, clerical, planning, bookkeeping, information technology (IT), and any other non-construction position not requiring an advanced degree or professional license.

Labor Hours' Exclusions

Non-construction services that require an advanced degree or professional licensing, are excluded from being counted towards the total number of Section 3 hours.

Professional services include but are not limited to, contracts for legal services, financial consulting, accounting services, environmental assessment, architectural services, and civil engineering services.

HUD wants to prioritize low- and very low-income workers and allows this category of exempted workers from reporting given the challenge to hire low- and very low-income workers with those types of degrees and licensing.

Section 3 Project

A Section 3 project is a housing rehabilitation, housing construction, or other public construction project assisted under HUD programs that provide housing and community development financial assistance.

The project is the site or sites together with any building(s) and improvements located on the site(s) that are under common ownership, management, and financing.

Business Certification

Step 1.Check if You Qualify

In order to be a Section 3 Certified Business Concern you must meet one of the following requirements:

  • 51% or more of business is owned and controlled by low- or very low-income persons, or
  • 51% or more of business is owned and controlled by current public housing residents or residents who currently live in Section 8-assisted housing, or
  • 75% of labor hours performed by business during prior three-month period were performed by Section 3 workers.

Step 2.Fill Out the Certification Form

Once the form is completed, please email to the address at the bottom of the form. The GMA Section 3 Coordinator will initiate the certification process, review each form, and contact you for any additional required documentation. The certification process will be held in a pending status until any missing documentation or information is provided and approved.

Certification Form(PDF, 217KB)

Step 3.Receive Certification

After all documentation has been reviewed by staff, the GMA Section 3 Coordinator will notify you of the status of your certification. Whether or not you meet one of the three definitions of a Business Concern the GMA Section 3 Coordinator can still provide you the contact information of certified Section 3 Workers. This may be beneficial as it can help you to meet Section 3 Benchmarks for HUD funded City construction projects.

Contact the GMA Section 3 Coordinator with any questions you may have.

Worker Certification

Step 1.Check if You Qualify

In order to qualify as a Section 3 Worker, you must be one of the following:

  • An individual who earned $46,450 or less in 2022, or
  • An employee of a Section 3 Business Concern, or
  • A participant of a YouthBuild Program.

Step 2.Fill Out the Certification Form

Once the form is completed, please email to the address at the bottom of the form. The GMA Section 3 Coordinator will begin the certification process, review each form, and contact you for any missing information, if necessary.

Certification Form(PDF, 2MB)

NOTE: If you live within one mile or less of one of these ongoing construction projects you would be considered a Targeted Section 3 Worker. If so, be sure to check off your status as a Targeted Section 3 Worker on your Certification form. It is essential that contractors hire eligible Targeted Section 3 Workers.

Step 3.Receive Certification

After your certification from has been reviewed, the GMA Section 3 Coordinator will contact you to let you know if your certification form is complete and if you are eligible as a Section 3 Worker. If eligible, your certification will be forwarded to construction contractors and program partners who may contact you about potential construction and/or construction-related administrative positions. See Section 3 Worker Information.

Contact the GMA Section 3 Coordinator for the most up to date project information or any questions you may have.

Section 3 Worker Information

Construction Positions

Examples of construction positions include but are not limited to the following:

  • painting
  • architecture
  • bricklaying
  • carpentry
  • cement/masonry
  • drywall
  • electrical
  • plastering
  • plumbing
  • tile setting
  • demolition
  • heating
  • iron works
  • machine operation
  • surveying
  • tile setting

Construction-Related Administrative Positions

Examples of construction-related administrative positions include but are not limited to the following:

  • administrative
  • clerical
  • planning
  • bookkeeping
  • information technology (IT)
  • other non-construction positions on a construction project not requiring an advanced degree or professional license

Construction Projects

We recommend applying for construction jobs with our contractors and program partners for the following projects that are under construction:

  • Country Club Village Apartments
  • Arbors at West Avenue Apartments
  • Rancho Carlota/Watson Road Subdivision
  • Viento Apartments (Zarzamora Street)
  • Crosspoint Women's Wellness Campus