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TRANSPARENCY <br />First, the Project Owner should be required <br />to disclose incidents of wage theft, human <br />trafficking, misclassification fraud, child labor <br />and workplace safety violations on all past <br />projects. This would provide critically needed <br />transparency to disincentivize the use of <br />contractors with a track record of issues. <br />Second, the project owner should maintain <br />and make available, directly or via the <br />General Contractor, a list of all contractors <br />and subcontractors that have been or <br />are expected to be employed, is currently <br />employed, or is expected to be employed <br />on a housing project. Many elected officials <br />and members of the public are surprised to <br />learn that project owners are not typically <br />required to provide local officials, agency <br />funders, or interested members of the public <br />with lists of contractors and subcontractors <br />that are employed on construction projects. <br />This lack of transparency makes it easy for <br />contractors to misclassify workers as third - <br />and fourth -tier subcontractors, and difficult <br />for workers to prove or sometimes even know <br />who employed them - leaving the public and <br />sometimes even the developer in the dark. A <br />requirement to list contractors would help to <br />prevent misclassification by making it easier <br />to recognize the illegal use of independent <br />contractors. <br />RESPONSIBLE CONTRACTING <br />Irresponsible contractors that cheat workers <br />or engage in other serious misconduct <br />should not be allowed to work on taxpayer - <br />funded housing projects any more than they <br />should be allowed to participate in public <br />works construction projects. Minnesota's <br />Responsible Contractor Act (RCA) <br />establishes clear guidelines for determining <br />contractor responsibility that could also <br />be applied to taxpayer financed projects <br />to minimize the risk of publicly -subsidized <br />misconduct. <br />PREFERENCE FOR HIGH -ROAD <br />CONTRACTING <br />MHFA uses a wide range of criteria to <br />evaluate funding proposals, including <br />applications for LIHTC funding. But these <br />criteria do not currently include any metrics <br />related to the past performance or present <br />commitments to contracting practices <br />designed to maximize the benefits of <br />construction jobs and careers to low-income <br />communities and residents, or to minimize <br />the risk of wage theft and other forms of <br />exploitation on subsidized projects. MHFA <br />should consider incorporating metrics that <br />recognize the value of family -supporting <br />jobs, health and retirement benefits, <br />registered apprenticeship career pathways, <br />and worker protections resulting from <br />collective bargaining and worker -driven <br />social responsibility programs. <br />3.2 PREVENTION AT THE LOCAL <br />LEVEL <br />Municipalities also have a vital role to play <br />in wage theft prevention on multi -family <br />housing construction projects since local <br />governments grant permits and zoning <br />approvals for new development. Municipal <br />leaders often adopt policies designed to <br />prevent other types of criminal activity <br />in their cities, and they should take wage <br />theft just as seriously. Municipalities could <br />require applicants for construction permits <br />to disclose information on a developer's <br />track record with respect to wage theft and <br />other forms of misconduct, and they could <br />also require transparent reporting on the <br />contractors and subcontractors used during <br />construction. <br />Finally, cities should look for creative ways <br />to increase their enforcement capacity. This <br />is a critical need at the local level. Policy <br />changes alone are insufficient alone without <br />more robust investment in enforcement. <br />One way to increase enforcement capacity <br />is to expand cooperation with neighboring <br />North Star Policy Action 19 <br />