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bo Subgrantee will submit requests for cash to coincide with immediate cash needs and assure that no excess cash is on deposit in their accounts or the accounts of any sub-contracting service provider in accordance with procedures established by the Subgrantor. Failure to adhere to these provisions may result in funds being provided through a reimbursement process Co The Subgrantor retains the authority to adjust specific amounts requested if the Subgrantor's records and subsequent verification with the Subgrantee indicates that the Subgrantee has an excessive amount of cash in its account. Income (including interest income) generated as a result of the receipt of WIA activities, will be utilized in accordance with policy and procedures established by the Subgrantor. Subgrantee will account for any such generated income separately. Subgrantee shall not be required to maintain a separate bank account but shall separately account for WIA funds on deposit. All funding under this agreement, will be made by check or wire transfer payable to the Subgrantee for deposit in Subgrantee's bank account or city and county governmental bank accounts. To provide for the necessary and proper internal controls, funds should be withdrawn and disbursed by no less than two representatives of the Subgrantee. The Subgrantor will have a lien upon any balance of WIA funds in these accounts which will take priority over all other liens or claims. f. Failure to adhere to the reporting requirements in item 12 of this agreement will result in funds not being released. 11. Records All participants served under this contract shall be entered into the electronic National Jobs for America's Graduates Database Management System (e-NDMS), including all student profile, student activities, and placement and follow-up information. Subgrantee will retain all records pertinent to this agreement for a period of three years from the date of final payment of this agreement. If, at the end of three years, there is litigation or an audit involving those records, the Subgrantee will retain the records until the resolution of such litigation or audit. The Subgrantor and/or the California Employment Development Department and the U. S. Department of Labor, or their designee, will have access to and right to examine, monitor and audit all records, documents, conditions and activities related to programs funded by this agreement. Subgrantee's performance under the terms and conditions herein specified will be subject to an evaluation by the Subgrantor of the adequacy of the services performed, timeliness of response and a general impression of the competency of the firm and its staff. '12. Reporting Subgrantee will compile and submit reports of activities, expenditures, status of cash and closeout information by the specified dates as prescribed by the Subgrantor. ~13. Grievance and Complaint System Subgrantee will establish and maintain a grievance and complaint procedure in compliance with WIA, federal regulations and State statutes, regulations and policy. 10