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OIG No. 25-10 Investigation of Community Development Block Grant
TO: FROM: DATE: RE: Joseph M. Centorino, Inspector General Honorable Mayor and Members of the City Commission Joseph Centorino, Inspector General June 23, 2025 Investigation of Community Development Block Grant-Corona Virus Funds Recipient Early Childhood Quality Consultants OIG No.: 25-10 Executive Summary The Miami Beach Office of the Inspector General (OIG) has concluded its investigation into allegations of violations of the Community Development Block Grant - Coronavirus (CDBG-CV) Agreement between the City of Miami Beach Small Business COVID-19 Program and Grant Recipient Early Childhood Quality Consultants, LLC, (ECQC) owned and operated by Jeannette Egozi. The City's Economic Development Department (EDD) administered the program. The OIG substantiated the allegation that ECQC made fraudulent representations in support of a required Duplication of Benefits Affidavit that the City relied upon to approve and subsequently issue ECQC a $10,000.00 Small Business grant during the pandemic. The OIG found that the EDD accepted the applicant's self-generated profit and loss statements as proof of the expenditure of the duplicative funds received by ECQC without the supporting bank statements, cancelled checks, or electronic funds transfers required by the Memorandum of Understanding between the EDD and the City's Office of Housing and Community Development as well as the Agreement between the City and the applicant. The OIG was informed by Rickelle Williams, Assistant City Manager and interim EDD Director at the time of the interview, that, if the Department had known that ECQC made fraudulent representations to obtain the funds, the City would not have issued ECQC the $10,000.00 grant. The investigation commenced upon the OIG's receipt of allegations that ECQC had (1) falsified documents in conjunction with a grant received; (2) an ECQC employee whose salary was fully funded by the Children's Trust was being used to collect grant money from the City; and (3) ECQC received funding illegally from two grants for employee salaries, afterschool programs, rent and utilities. The OIG learned that ECQC had received substantial funding from the Children's Trust and referred that aspect of the complaint to the Miami-Dade Office of the Inspector General (MDOIG) in June 2021. The Children's Trust is an entity created by voter referendum and is a "dedicated source of revenue derived from property taxes, committed to making a positive impact on the lives of children and families in Miami-Dade County," and is within the MDOIG's jurisdiction rather than that of the City of Miami Beach OIG. The MDOIG reported that ECQC received a yearly grant Page 1 of 10 budget from the Children's Trust in excess of $451,000.Due to the significance of the Children's Trust commitment to the ECQC and the importance and sensitivity of the MDOIG investigation, the Miami Beach OIG kept its investigation on the COBO-CV grant open until the MDOIG completed its work and issued its report. On January 27,2025,the Miami-Dade OIG issued its report of investigation,which found (1)that ECQC employees,whose salaries were fully funded by the Children's Trust,also functioned as employees for Ms.Egozi's CBD +More store,which was co-located with ECQC's administrative office";(2)"ECQC improperly requested reimbursement from the Children's Trust for its office space by categorizing the expense as program space,in contravention of the budget guidelines provided by the Children's Trust";and (3)"ECQC made misrepresentations when applying for a City of Miami Beach grant and used an employee whose salary was fully funded by the Children's Trust to retain the City's grant funds." On November 14,2023,the Children's Trust advised ECQC that their application for funding under Request for Proposals #2023-01 and the requisite certifications were deficient,and the Trust rescinded its funding award to ECQC. The Miami Beach OIG's investigation focused on the CDBG-CV Small Business grant program processes as they pertained to ECQC's compliance with its agreement with the City,which was entered into on September 9,2020.The details of its findings are contained herein. The OIG appreciates the cooperation of former Assistant City Manager Rickelle Williams,the EDD staff,the Information Technology Department,and the MDOIG during the investigation. OIG Authority Section 2-256 of the Code of Miami Beach provides that the City of Miami Beach Office of Inspector General is created as an independent body to perform investigations,audits,reviews, and oversight of municipal matters,including city contracts,programs,projects,and expenditures, to identify efficiencies and to detect and prevent fraud,waste,mismanagement,misconduct,and abuse of power.That Code section provides that the organization and administration of the office shall be sufficiently independent to assure that no interference or influence external to the office adversely affects the independence and objectivity of the Inspector General.The Code also provides that the OIG has the power to require reports from the City Manager,City departments, City agencies,boards,and committees,and City officers and employees,regarding any matter within the jurisdiction of the Inspector General,as well as the power to subpoena witnesses, administer oaths,and require the production of records regarding any matter within the jurisdiction of the office. Investigation Overview The OIG's investigation involved the review of substantial documentation,including,but not limited to,City resolutions,Letters to Commission (LTC),Memorandum of Understanding between.the City's Office of Housing and Community Development and its EDD,CDBG-CV agreement between the City and ECQC,emails,ECQC documents,bank records,public records, open source data,interviews conducted by MDOIG,and the interview of Rickelle Williams,former Assistant City Manager,Heather Shaw,Assistant Director,Economic Development,and Luis Wong,Administrative Services Manager,Economic Development. Page 2 of 10 In May 2020,the City Commission approved Resolution 2020-31256,allocating $200,000 of Community Development Block Grant -Coronavirus (CDBG -CV)funds for its Small Business COVID--19 Relief Program (the "Program")administered by the City's EDD.The program's purpose was to provide short-term assistance for qualified business expenses'by awarding up to $10,000.00 to eligible small businesses which agree to employ and/or retain at least one qualified low and moderate income employee2 continuously for one year from the date the City verifies employment for the qualified employee,hereinafter the "compliance period." On June 15,2020,Jeannette Egozi submitted a small business grant application in the name of Early Childhood Quality Consultants,LLC (ECQC)dba Playing the Game of Life,and was subsequently selected in the lottery as an eligible business.On September 9,2020,Jeannette Egozi executed an agreement with the City to (1)be awarded CDBG-CV funds not to exceed $10,000.00 for qualified expenses (see footnote 1)and,(2)to employ and/or retain at least one qualified employee (see footnote 2)for the compliance period under the provisions of the agreement.(Exhibit 1) During an interview with the OIG,Ms.Rickelle Williams advised,and Mr.Wong concurred,that no stipulation in the agreement required the reimbursement of the business expenses to be specific to the employee who was qualified with the City for the twelve-month compliance period. However,the award of the funds was contingent upon ECQC executing a Duplication of Benefits Affidavit and maintaining the employment of the selected qualified employee for the twelve-month compliance period. Duplication of Benefits Affidavit Exhibit "A"of the agreement under "Duplication of Benefits"states, To comply with HUD regulations,the City shall require the Grantee to complete a Duplication of Benefits form as a method of assessing whether the use of CDBG- CV funds will duplicate financial assistance that is already received or is likely to be received for COVID-19 related losses.By accepting these CDBGCV Funds, Grantee agrees to repay any portion of the Funds determined by the City to be duplicative Funds. The agreement further states that the Duplication of Benefits Affidavit will be used as a, method of assessing whether the use of CDBG-CV funds will duplicate financial assistance that is already received or is likely to be received for COVID-19 related losses.By accepting these CDBG-CV Funds,Grantee agrees to repay any portion of the funds determined by the City to be duplicative Funds. 1 Qualified Business Expense is defined in Exhibit "A"ofthe agreement between the City and the Grantee as "any operational costs such as payroll,utilities,rents,or mortgage interest (for business accounts in existence as ofat least February 1,2020),etc.and/or COVID-19 related expenditures." 2 Low and Moderate Income Employee is defined in Exhibit "A"of the agreement between the City and the Grantee as "a full-time employee who resides in Miami Beach and whose household earns at or under 80%ofArea Medium Income (AMI).A qualified employee is considered a full-time employee if retained at 40 hours per week,or any combination ofpart-time positions combining for40 hours per week.The employee must be a U.S.citizen or legal resident,and the employee must also reside in the City of Miami Beach." Page 3 of 10 On November 23,2020,ECQC provided the EDD via an email attachment,Jeannette Egozi's executed Duplication of Benefits Affidavit dated October 6,2020 (Exhibit 2).The affidavit required the applicant to identify assistance received from other sources,as follows:(1)received from other recovery assistance programs;(2)insurance assistance received for disaster-related losses;and (3)Government,bank,and any other funding received by businesses for disaster- related losses.The Affidavit did not contemplate receipt offunds from other sources such as those provided by the Children's Trust that were not provided for disaster relief.On her Affidavit, Jeannette Egozi disclosed that ECQC received a federal Paycheck Protection Program (PPP) loan in the amount of $33,200.273. By executing the affidavit,Ms.Egozi acknowledged that she understood that it was a violation of federal law to make materially false statements or use any false writing or document knowing it contained any fictitious or fraudulent representations.In support of the affidavit,ECQC provided via email attachments an Amerant Bank statement showing the deposit of the PPP loan and an ECQC prepared profit and loss statement for June 1 through November 15,2020,totaling $30,200.27,to show the expenditure of the PPP loan proceeds (Exhibit 3). On December 7,2020,EDD informed Ms.Egozi via email that the documents she provided regarding the PPP loan of $33,200.27 and its expenditure of $30,200.27 identified a balance of $3,000.00 of unspent PPP loan funds.The remaining balance would need to be spent before the City would process a reimbursement request.The aforementioned email was sent at 12:51 p.m., and 25 minutes later,EDD received an email with a second ECQC-generated profit and loss statement (Exhibit 4)that simply added $3,000.00 to the Senior Program Manager salary line that was represented on the initial statement (Exhibit 3). The purpose of the statement was to show that the full amount of the PPP loan received by ECQC was spent.The representation on the statement of $33,200.27 of expenses was the exact amount of the PPP loan,including the 27 cents of interest.The EDD did not request,nor was it provided, supporting bank transactions for the expenses represented on either of the profit and loss statements. A review of bank records submitted by ECQC to the City identified that ECQC's business account was with JP Morgan Chase Bank,N.A.The OIG found that Amerant Bank,N.A.was the lender for the PPP loan,and that Jeannette Egozi established a business money market account with Amerant for the distribution of the PPP loan proceeds. The Economic Development Department accepted the Amerant bank statement and the profit and loss statements prepared by ECQC as proof that they expended all of the PPP loan funds received without requiring any supporting documentation that the funds were deposited or expended from ECQC's JP Morgan Chase business account.The EDD relied on the documents submitted with fraudulent representations to subsequently issue grant funds to ECQC for $10,000.00. A review of publicly accessible PPP loan tracking information identified that Ms.Egozi and ECQC were approved for a PPP loan for $33,200.00 through Amerant Bank on May 14,2020.Ms. Egozi's Amerant Bank records showed that the ECQC business money market account was established on May 21,2020,and that she was the sole signatory on the account. 3 The PPP loan was for $33,200.00.The 27 cents represented interest earned on the loan funds. Page 4 of 10 A review of Amerant Bank statements from May 2020 through May 2022 revealed that the PPP loan for $33,200.00 was deposited into the account on May 29,2020.A second PPP loan for $34,740.00 was deposited into the Amerant account on February 26,2021.The proceeds from both PPP loans totaling $67,940.00 remained in the Amerant account until May 11,2022,when the funds were wire transferred to Ms.Egozi's JP Morgan Chase ECQC business checking account (Composite Exhibit 5). The OIG found that Jeannette Egozi made fraudulent representations in support of the Duplication of Benefits Affidavit that she submitted to the EDD to obtain $10,000.00 in CDBG-CV grant funds.The OIG also found that the Economic Development Department approved and issued the grant funds based on the deposit of the PPP loan funds into Ms.Egozi's Amerant Bank (PPP loan lender)account and the profit and loss statements self-generated by ECQC without any supporting documentation showing that the funds were deposited and expended from ECQC's JP Morgan Chase business account. As identified earlier in this report,Ms.Rickelle Williams stated that had she known,or the EDD staff had been aware,that ECQC obtained the grant funds through fraudulent representations, the City would not have issued the $10,000.00 to Ms.Egozi and ECQC.Notwithstanding this fact, the following sections address the additional requirements of the agreement for the Qualified Employee and the proper expenditure of the grant funds. Qualified Employee and the Compliance Period As a provision of the agreement,ECQC was required to employ and/or retain a full-time employee who resides in Miami Beach and whose household earns at or under 80%Area Median Income (AMI).ECQC hired Tinike Bennett to fulfill this requirement.ECQC provided an executed Employee Income Certification Form and a Source of Income Documentation form completed by and signed by Tinike Bennett on November 20,2020,along with a 2019 tax return,two paychecks, three bank statements,and a proof of residence to verify that she was a Miami Beach resident and met the required AMI.Ms.Egozi submitted an Employment Verification Form signed and dated November 23,2020,showing Ms.Bennett's date of hire as September 22,2020. According to the Scope of Services,Exhibit "A"of the agreement,the 12-month compliance period begins upon the City's verification of the employment of the qualified employee.Exhibit "A"also states, At the conclusion of the 12-month Qualification Period,the business must verify compliance by submitting payroll documentation.If the Grantee is unable to prove compliance,then Grantee shall repay the Funds to the City,immediately upon receiving a demand for payment. The EDD informed Jeannette Egozi in an email dated June 3,2021, Just so you are aware,since Ms.Bennett was never transitioned to a W-2 Full- Time employee per the program requirements,and I was not informed ofthis back in January,she would be ineligible and does not count towards your 12 month period of retaining/creating a position for a low to moderate income Miami Beach resident. Page 5 of 10 The email also stated,"I received the information for Elmase on 5/19/21 with paystubs dating back to March 2021,so please ensure this employee remains employed for a period of 12 months (Feb 2022)." According to email correspondence reviewed by the OIG,Elmase Hoffman was an Administrative Program Coordinator at ECGC. On May 19,2021,an email was sent from ECQC to the EDD with attachments that included an Employee Income Certification Form and Sources of Income Documentation Form signed and dated by Elmase Hoffman on May 19,2021,along with two paystubs for March and April 2021, and a payroll summary report for Elmase Hoffman for March through May 2021 to verify that Ms. Hoffman was a resident of Miami Beach and met the required AMI.The EDD accepted Elmase Hoffman as the qualified employee for the 12-month compliance period going forward.ECQC provided payroll information for Elmase Hoffman from March 2021 through November 2021. Luis Wong from the City EDD informed the OIG that he recently contacted the City's former Redevelopment Specialist managing the ECQC process,and the Redevelopment Specialist acknowledged that Ms.Egozi was advised in an email that Ms.Hoffman's 12-month compliance period would extend to February 2022.However,the Redevelopment Specialist received verbal approval from the City's Housing and Community Services Department that Ms.Bennett's 1st quarter reporting would count towards ECQC's 12-month compliance requirement. On February 10,2022,the EDD sent an email to the Housing and Community Service CDBG Projects Coordinator with the subject "CDBG-CV Round 1 -Progress Report &LMJ -January 2022"that listed ECQC as having completed its 12-month compliance period.Records obtained from the Florida Department of Revenue show that Ms.Hoffman received quarterly income from ECQC from 2012 through March 31,2024. Disbursement of Grant Funds Under a provision of the Agreement,ECQC could request reimbursement of business expenses, including any operational costs such as payroll,utilities,rents,mortgage Interest,and/or COVID- 19-related expenses that occurred after July 10,2020,the date ECQC was selected in the lottery. On December 16,2020,ECQC submitted via email a reimbursement request for $10,000.00.A Small Business Assistance Reimbursement Request Approval form was completed and signed by the EDD Program Monitor,Department Director,and Financial Analyst on December 16,2020, for $10,000.00,identifying that the full amount of the grant awarded to ECQC was used for "Payroll Expenses."In support of the request,ECQC provided payment records for Tinike Bennett for $10,000.00,as depicted in the chart below. EARLY CHILDHOOD QUALITY CONSULTANTS SALARY PMTS TO TINIKE BENNETT SEPTEMBER 2020 -DECEMBER 2020 DATE CHECK#AMOUNT 09/30/20 5655 $1,157.74 10/30/20 5672 $3,750.00 11/30/20 5699 $3,116.16 12/15/20 5714 $1,976.10 TOTALSALARY PAID $10,000.00 Page 6 of 10 The reimbursement of the funds by the Economic Development Department to ECQC complied with the requirements of the agreement.Records show that between September 2020 and April 2021,Ms.Bennett received salary checks totaling $21,245.94. Responses to the Draft Report Section 2-256 of the Code states that individuals or entities referenced in an OIG report's findings or recommendations must receive a copy of the report and have 30 working days to submit a written explanation or rebuttal regarding those findings or recommendations before the report is finalized.Any timely written responses will be attached to the finalized report.On April 10,2025, the OIG's draft report on this matter was delivered via email to the City Manager,Assistant City Manager Maria Hernandez,the City Attorney,the Director and Assistant Director of the Economic Development Department,and the Grant Recipient. The OIG received a response from the City's Economic Development Department in the form of a tracked changes Microsoft Word version of the OIG's draft report,which is attached as Appendix A to this report.The OIG also received a response from ECQC's legal representative on behalf of Ms.Jeannette Egozi,which is attached as Appendix B to this report. ECQC/Jeanette Egozi Response The legal representative of Ms.Egozi asserts that, Following a thorough review ofthe relevant documentation provided by Ms.Egozi's accountant,it is our position that the Community Development Block Grant- Coronavirus ("CDBG-CV'')funds in question were properly awarded.Specifically, the applicable Paycheck Protection Program ("PPP'')loan funds had been fully exhausted,thereby entitling Ms.Egozi to the full $10,000.00 City grant. The OIG notes that this response relied on documents provided to the legal representative by Ms. Egozi's unnamed accountant.The response did not include any exhibits that support the conclusion that the "applicable Paycheck Protection Program ("PPP")loan funds had been fully exhausted."The relevant bank statements obtained by the OIG show that the proceeds from the applicable PPP loan for $33,200.00 and a second PPP loan for $34,740.00,totaling $67,940.00 remained in Ms.Egozi's Amerant (PPP loan lender)account until May 11,2022,when the funds were wire transferred to Ms.Egozi's JP Morgan Chase ECQC business checking account (Composite Exhibit 5).Therefore the PPP loan funds could not have been "fully exhausted"in December of 2020. City Economic Development Department Response The City EDD asserts that it made a good-faith review of Ms.Egozi's application but did not take steps beyond its normal course of review to obtain additional proof of the expenditure of the duplicative funds received by ECQC. The Economic Development Department provided the following responses: Page 7 of 10 The EDD staff performed a due diligence and review of the City of Miami Beach Small Business COVID-19 Program applicant,as required by the Housing and Community Services Department.In addition,ECGC signed a required affidavit affirming the truth and veracity of the information submitted with the application.The EDD staff relied on this affidavit and was not aware ofany fraudulent representation nor aware of any reason or rationale to believe fraud was occurring at the time of the issuance of the grant. The EDD team were not aware of ECQC's actions.Accordingly,the staff had no reason to make additional requests because they did not suspect fraud or misrepresentation.ECQC signed an affidavit that all documents and representations were true and they were aware of the penalties for any misrepresentations as required by the Housing and Community Services Department. The Economic Development Department were not aware of or suspect ECQC of any bad faith or fraud,and had no reason to believe the documents submitted were untrue,false,or a misrepresentation,and acted pursuant to the program guidelines.Had the EDD team suspected fraud, misrepresentation,and/or any other wrongdoing,it would not have issued grant. The Memorandum of Understanding with Housing and Community Services Department and the loan agreement with Ms.Egozi require cancelled checks,electronic funds transfers,and/or bank statements to prove the expenditure of funds.It is concerning to the OIG that the Economic Development Department considers these as "steps beyond their normal course of review."Had the Economic Development Department required proof that the PPP loan funds were deposited into ECQC's operating account and required the aforementioned proof that the funds were expended,they would have known that Ms.Egozi was untruthful. Conclusion and Recommendations The OIG has concluded its investigation into actions taken by Early Childhood Quality Consultants,LLC (ECQC)and its owner,Jeannette Egozi,to obtain a $10,000.00 grant through the City of Miami Beach Small Business COVID-19 Program.The investigation stemmed from the OIG's receipt of allegations that ECQC had (1)falsified documents in conjunction with a grant received;(2)an ECQC employee whose salary was fully funded by the Children's Trust was being used to collect grant money from the City;and (3)ECQC received funding illegally from two grants for employee salaries,afterschool programs,rent and utilities. The Miami Beach OIG referred the information to the Miami-Dade OIG,as the Children's Trust is within their jurisdiction.The Miami-Dade OIG investigated with a primary focus on allegations two and three above.The Miami-Dade OIG's investigative report issued on January 27,2025,found that "ECQC employees,whose salaries were fully funded by the Children's Trust,also functioned as employees for Ms.Egozi's CBD +More store,which was co-located with ECQC's administrative office;ECQC improperly requested reimbursement from the Children's Trust for its office space by categorizing the expense as program space,in contravention of the budget guidelines provided by the Children's Trust;and ECQC made misrepresentations when applying Page 8 of 10 for a City of Miami Beach grant and used an employee whose salary was fully funded by the Children's Trust to retain the City's grant funds. As a result of the Miami-Dade OIG's investigative findings,based on the referral from the Miami Beach OIG,the Children's Trust rescinded ECQC's funding award on November 14,2023. Finding:Fraudulent Representations by ECQC and Jeannette Egozi The OIG substantiated that ECQC,through its owner Jeannette Egozi,made fraudulent representations concerning the Duplication of Benefits Affidavit that was executed and submitted by Ms.Egozi to the City,on which she acknowledged that she understood that it was a violation of federal law to make materially false statements or use any false writing or document knowing it contained fictitious or fraudulent representations (Exhibit 2).In support of the affidavit,ECQC submitted two separate profit and loss statements that purportedly showed the expenditure of the Federal PPP funds that she received from the first PPP loan of $33,200.00(Exhibits 3 &4). The award of the City grant was contingent on ECQC's complete expenditure of the $33,300.00 in PPP loan funds.However,bank statements of the PPP loan lender Amerant Bank revealed that Ms.Egozi received two PPP loans totaling $67,940.00 between May 2020 and February 2021.The statements show that the PPP loan funds remained in Ms.Egozi's account with Amerant Bank until May 11,2022,when the full amount of the two PPP loans was wire transferred to her ECQC business account at JP Morgan Chase (Composite Exhibit 5). All transactions on the Amerant Bank statements were linked to the two PPP loans that Ms.Egozi received.No ECQC business transactions occurred using the Amerant Bank account.Ms.Egozi did not utilize any of the PPP loan proceeds in 2020 or 2021 for the purposes she indicated when she applied for and received the two PPP loans. Finding:Lack of Due Diligence by the Economic Development Department The OIG found that,although the Economic Development Department required proof from ECQC that the $33,200.00 in PPP loan funds were fully expended,it accepted and relied on documents submitted by the applicant that did not provide such proof.Exhibit B of the agreement lists supporting documents to be submitted to document expenses incurred,including electronic payroll ledgers with corresponding bank transactions,bank statements,and cancelled checks. ECQC provided an Amerant Bank statement that showed the deposit of ECQC's first PPP loan of $33,200.00 (Exhibit 3).This account was established with the PPP loan lending bank Amerant by Jeannette Egozi to receive the loan funds.The funds from both of ECQC's PPP loans remained in that account until May 11,2022 (Composite Exhibit 5).The Economic Development Department did not request,nor were they provided,bank statements showing the loan funds deposited into ECQC's JP Morgan Chase business account.ECQC provided two ECQC profit and loss statements (Exhibits 3 &4)that it generated and submitted to show how the funds were expended. The Economic Development Department did not request,nor were they provided,any bank transactions,statements,or cancelled checks from ECQC's JP Morgan Chase business account to show proof of the expenditures represented on the profit and loss statements. As a result,the Economic Development Department accepted and relied on the fraudulent representations of ECQC and Jeannette Egozi to award $10,000.00 through the City of Miami Beach Small Business COVID-19 Program. Page 9 of 10 Recommendations Based on the findings of this report,the OIG recommends that the City consider the following: 1.Identify and pursue all remedies established in the agreement or within the City to a.Recover the funds issued to ECQC based on fraudulent representations,and b.Address whether to consider future applications/requests for City funds by businesses owned and operated by Jeannette Egozi. 2.Establish and execute policy,procedures,and processes to ensure that established and appropriate backup documentation including bank statements,electronic transfers, cancelled checks,and any other source document proof deemed appropriate is. a.received and verified before the expenditure of City funds,and b.is required as proof from a recipient for the expenditure of City funds. This report is presented by the OIG to the City Administration for its review and action as deemed appropriate concerning the findings and recommendations herein. Section 2-256 (d)(3)of the City Code confers upon the Office of the Inspector General the power to require reports from the city manager,city departments,city agencies,boards,and committees, and city officers and employees,regarding any matter within the jurisdiction of the inspector general.The OIG requests that the City Administration provide a status report to the OIG within sixty (60)days of its receipt of this report on the implementation of any of the OIG recommendations. As required by Miami Beach Code Section 2-256(d)8),the final report will be provided to the Small Business Administration Office of Inspector General and the State Attorney's Office for their review and action as they deem appropriate. Respectfully submitted, o/a3/.as Date cc:Eric Carpenter,City Manager Maria Hernandez,Assistant City Manager Steven Anthony,Director,Economic Development Heather Shaw,Assistant Director,Economic Development Felix Jimenez,Inspector General,Miami-Dade County Jeannette Egozi OFFICE OF THE INSPECTOR GENERAL,City of Miami Beach 1130 Washington Avenue,6"Floor,Miami Beach,FL 33139 Tel:305.673.7020 •Hotline:786.897.1111 Email:CityofMiamiBeachOIG@miamibeachfl.gov Website:www.mbinspectorgeneral.com Page 10 of 10 OIG Appendix A RESPONSE OF MIAMI BEACH ECONOMIC DEVELOPMENT DEPARTMENT TO OIG DRAFT REPORT Joseph M.Centorino,Inspector General DRAFT REPORT TO:FROM: DATE: RE: Honorable Mayor and Members of the City CommissionJosephCentorino,Inspector General April 10,2025 Investigation of Community Development Block Grant-Corona Virus Funds Recipient Early Childhood Quality Consultants OIG No.:Pending Executive Summary The Miami Beach Office of the Inspector General (OIG)has concluded its investigation into allegations of violations of the Community Development Block Grant -Coronavirus (CDBG-CV) Agreement between the City of Miami Beach Small Business COVID-19 Program and Grant Recipient Early Childhood Quality Consultants,LLC,(ECQC)owned and operated by JeannetteEgozi.The City's Economic Development Department (EDD)administered the program. The OIG substantiated the allegation that ECQC made fraudulent representations in support of arequiredDuplicationofBenefitsAffidavitthattheCityreliedupontoapproveandsubsequently issue ECQC a $10,000.00 Small Business grant during the pandemic.The OIG found that the EDD made a good faith reviews of the application but did not failedto take steps beyond their normal course of review to obtain additional the requisite proof of the expenditure ofthe duplicative funds received by ECQC.The OIG was informed by Rickelle Williams,Assistant City ManagerandinterimEDDDirector,during an interview that had the Economic Development DepartmentknownthatECQCmadefraudulentrepresentationstoobtainthefunds,the City would not have issued ECQC the_ $10,000.00 grant. •Formatted:Indent:Left:0.08",First line:0",Right: Economic Development Response.The EDD staff performed a due dilioence and review of the o.09",Space Before:o pt City of Miami Beach Smail Business COVIDi9 Rroaram applicant,as required by he Housing and?_,,,,,,,,,,,,Community Seryices Department_In_addition_ECGC_signed a required affidavit_affirming_the_truth Formattes:ont ol,mnaere and yeracity of the_information submitted with_the application._The_EDD_staff_relied on this affidavit and was not aware of any fraudulent representation nor aware of any reason or rationale to believe fraud was occurrin at the time ofthe issuance of the ran The investigation commenced upon the OIG's receipt of allegations that ECQC had (1)falsified documents in conjunction with a grant received;(2)an ECQC employee whose salary was fully funded by the Children's Trust was being used to collect grant money from the City:and (3)ECQC received funding illegally from two grants for employee salaries,afterschool programs,rent and utilities.The OIG learned that ECQC had received substantial funding from the Children's Trust and referred the complaint to the Miami-Dade Office of the Inspector General (MDOIG)in June2021.The Children's Trust is an entity created by voter referendum and is a "dedicated source of revenue derived from property taxes,committed to making a positive impact on the lives of Formatted:Font color:Red children and families in Miami-Dade County,"and is within the MDOIG's jurisdiction.The MDOIGreportedthatECQCreceivedayearlygrantbudgetfromtheChildren's Trust in excess of$451,000. On January 27,2025,the Miami-Dade OIG issued its report of investigation,which found (1)that "ECQC employees,whose salaries were fully funded by the Children's Trust,also functioned as Page 1of 8 employees for Ms.Egozi's CBD +More store,which was co-located with ECQC's administrative office";(2)"ECQC improperly requested reimbursement from the Children's Trust for its office space by categorizing the expense as program space,in contravention of the budget guidelinesprovidedbytheChildren's Trust";and (3)"ECQC made misrepresentations when applying for aCityofMiamiBeachgrantandusedanemployeewhosesalarywasfullyfundedbytheChildren'sTrusttoretaintheCity's grant funds."On November 14,2023,the Children's Trust advised ECQC that their application for funding under Request for Proposals #2023-01 and the requisite certifications were deficient,and the Trust rescinded the funding award. The Miami Beach OIG's investigation focused on the CDBG-CV Small Business grant programprocessesastheypertainedtoECQC's compliance with its agreement with the City,which was entered into on September 9,2020.The details of its findings are contained herein. The OIG appreciates the cooperation of Assistant City Manager Rickelle Williams,the EDD staff,the Information Technology Department,and the MDOIG during the investigation. OIG Authority Section 2-256 of the Code of Miami Beach provides that the City of Miami Beach Office of Inspector General is created as an independent body to perform investigations,audits,reviews,and oversight ofmunicipal matters,including city contracts,programs,projects,and expenditures.to identify efficiencies and to detect and prevent fraud,waste,mismanagement,misconduct,andabuseofpower.That Code section provides that the organization and administration of the office shall be sufficiently independent to assure that no interference or influence external to the office adversely affects the independence and objectivity of the Inspector General.The Code also provides that the OIG has the power to require reports from the City Manager,City departments, City agencies,boards,and committees,and City officers and employees,regarding any matter within the jurisdiction of the Inspector General,as well as the power to subpoena witnesses,administer oaths,and require the production of records regarding any matter within thejurisdictionoftheoffice. Investigation Overview The OIG's investigation involved the review of substantial documentation,including,but not limited to,City resolutions,Letters to Commission (LTC),Memorandum of Understanding between the City's Office of Housing and Community Development and its EDD,CDBG-CV agreement between the City and ECQC,emails,ECQC documents,bank records.public records,open source data,interviews conducted by MDOIG,and the interview of Rickelle Williams, Assistant City Manager,Heather Shaw,Assistant Director,Economic Development,and LuisWong,Administrative Services Manager,Economic Development. In May 2020,the City Commission approved Resolution 2020-31256,allocating $200,000 ofCommunityDevelopmentBlockGrant-Coronavirus (CDBG-CV)funds for its Small BusinessCOVID-19 Relief Program (the Program)administered by the City's EDD.The Pprogram'spurposewastoprovideshort-term assistance for qualified business expenses'by awarding up to$10,000.00 to eligible small businesses which agree to employ and/or retain at least one qualified low and 'Qualified Business Expense is defined in Exhibit A"of theagreement between the Cit and the Grantee as an operational costssuch aspayrolluulities.rents,ormortgage interest (for businessaccountsmn estencc asof at leastFebruary I 2020 etc and/or COVID.1)related moderate income employee'continuously for one yearfrom the datethe City verifies employmentforthequalifiedemployee,hereinafter the compliance period. On June 15,2020,Jeannette Egozi submitted a small business grant application in the name of Early Childhood Quality Consultants,LLC (ECQC)dba Playing the Game of Life and wassubsequentlyselectedinthelotteryasaneligiblebusiness.On September 9,2020,JeannetteEgoziexecutedanagreementwiththeCityto(1)be awarded CDBG-CV funds not to exceed$10,000.00 for qualified expenses (see footnote 1)and,(2)to employ and/or retain at least one qualified employee (see footnote 2)for the compliance period under the provisions of the agreement.(Exhibit 1) During an interview with the OIG,Rickelle Williams advised,and Ms.Shaw and Mr.Wong concurred,that no stipulation in the agreement required the reimbursement of the business expenses to be specific to the employee who was qualified with the City for the twelve-month compliance period.However,the award of the funds was contingent upon ECQC executing aDuplicationofBenefitsAffidavitandmaintainingtheemploymentoftheselectedqualifiedemployeeforthetwelve-month compliance period. Duplication ofBenefits Affidavit Exhibit "A"ofthe agreement under "Duplication of Benefits"states, To comply with HUD regulations,the City shall require the Grantee to complete a Duplication ofBenefits form as a method ofassessing whether the use of CDBG- CV funds will duplicate financial assistance that is already received or is likely to be received for COVID-19 related /asses.By accepting these CDBGCV Funds, Grantee agrees to repay any portion of the Funds determined by the City to be duplicative Funds. The agreement further states that the Duplication of Benefits Affidavit will be used as a, method ofassessing whether the use of CDBG-CV funds will duplicate financial assistance that is already receivedor is likelyto be receivedforCOVID-19 related losses.By accepting these CDBG-CV Funds Grantee agrees to repay any portion ofthe funds determined by the City to be duplicative Funds. On November 23,2020,ECQC provided the EDD via an email attachment,Jeannette Egozi'sexecutedDuplicationofBenefitsAffidavitdatedOctober6,2020 (Exhibit 2).The affidavit requiredtheapplicanttoidentifyassistance,as follows:(1)received from other recovery assistanceprograms;(2)insurance assistance received for disaster-related losses;and (3)Government,bank,and any and all other funding received by businesses for disaster-related losses.TheAffidavitdidnotcontemplateothersourcesoffunding,such as those provided by the Children's Trust that were not provided for disaster relief.On her Affidavit,Jeannette Egozi disclosed thatECQCreceivedafederalPaycheckProtectionProgram(PPP)loan in the amount of $33,200.27 3 By executing the affidavit,Ms.Egozi acknowledged that she understood that itwas a violation Low and Moderate Income Employee isdefined in Exhibit "A"ofthe agreement between theCity and the Grantee as"a full-time employee who residesin Mram Beach and whose household cams at or under 8r of Area Medrum Income AMI A quahficd employee tsconsidereda full-umeemployce retained at4+hours per week orany combination ofpart-tamepositionscombg for40 hoursper wee The employee must be aU.Scizen orlegal resident and theemployee must alsoresidemn the Cit of Miami Beach. 'The PPP loan was for $33.200.00.The27 ems represented interest earned on theloan funds. of federal law to make materially false statements or use any false writing or document knowingitcontainedanyfictitiousorfraudulentrepresentations. In support of the affidavit,ECQC provided via email attachments an Amerant bank statementshowingthedepositofthePPPloanandanECQCpreparedprofitandlossstatementforJune 1 through November 15,2020,totaling $30,200.27,to show the expenditure of the PPP loan proceeds (Exhibit 3). On December 7,2020,EDD informed Ms.Egozi,via email,that the documents she providedregardingthePPPloanof$33,200.27 and its expenditure of $30,200.27 identified a balance of$3,000.00 of unspent PPP loan funds.The remaining balance would need to be spent before theCitywouldprocessareimbursementrequest.The aforementionedat email was sent at 12:51 p.m..and 25 minutes later,EDD received an email with a second ECQC-generated profit and loss statement (Exhibit 4)thatsimplyadded $3,000.00 to the Senior Program Manager salary linethat was represented on the initial statement (Exhibit 3).The purpose of the statement was to show that the full amount of the PPP loan received by ECQC was spent.The representation on the statement of $33,200.27 of expenses was the exact amount of the PPP loan,including the .27centsofinterest.The EDD did not request,nor was it provided,supporting bank transactions fortheexpensesrepresentedoneitherprofitandlossstatement. onse:EDD was not aware of an reason to make Formatted:Font:Bold,Underline zrz-=:razz-=-rzrz:.z1a1zzzzz:.~Eorpatend bntlr ed A review of bank records submitted by ECQC to the City identified that ECQC's business account was with JP Morgan Chase Bank,N.A.The OIG found that Amerant Bank,N.A.was the lender for the PPP loan,and Jeannette Egozi established a business money market account with Amerant for the distribution of the PPP loan proceeds. The Economic Development Department accepted the Amerant bank statement,and the profitandlossstatementspreparedbyECQC,as proof that they expended all of the PPP loan fundsreceivedingoodfaithandhadnoreasontorequestwithoutrequiringanysupportingdocumentationthatthefundsweredepositedorexpendedfromECQC's JP Morgan Chase business account.The EDD relied on the documents submitted.unaware there were with fraudulent representations,_and to subsequently issued grant funds to ECQC for $10,000.00. conomic Develo ment De artment Res onse:The EDD team were not aware of ECQC's Formatted:Font:Bold,Underlineactions.Accordingly,the staff had no reason to make additional requests because they did notsuspectfraudormisrepresentation.ECQC signed an affidavit that all documents andrepresentationsweretrueandtheywereawareofthepenaltiesforanymisrepresentations as requiredbytherousingandCommunityServicesDepartment.,[Formatted:Font color.Red A reviewof publicly accessible PPP loan tracking information identified that Ms.Egozi and ECQC were approved for a PPP loan for $33,200.00 through Amerant Bank on May 14,2020.Ms. Egozi's Amerant Bank records showed that the ECQC business money market account was established on May 21,2020,and that she was the sole signatory on the account. A review of Amerant bank statements from May 2020 through May 2022 revealed that the PPP loan for $33,200.00 was deposited into the account on May 29,2020.A second PPP loan for $34,740.00 was deposited into the Amerant account on February 26,2021.The proceeds from both PPP loans totaling $67,940.00 remained in the Amerant account until May 11,2022,when the funds were wire transferred to Ms.Egozi's JP Morgan Chase ECQC business checking account (Composite Exhibit 5). The OIG found that Jeannette Egozi made fraudulent representations in support of the Duplication of Benefits Affidavit that she submitted tothe EDD to obtain $10,000.00 in CDBG-CV grant funds.The OIG also found that the Economic Development Department approved and issued the grant funds based on the deposit of the PPP loan funds into the Amerant Bank(lender's)account and the profit and loss statements created by ECQC without knowing any supporting documentation would showing that the funds were deposited and expended fromECQC's JP Morgan Chase business account. As identified earlier in this report,Rickelle Williams stated that had she known.or the EDD staff had been aware that ECQC obtained the grant funds through fraudulent representations,the City would not have issued the $10,000.00 to Ms.Egozi and ECQC.Notwithstanding this fact,the following sections address the additional requirements ofthe agreement for the Qualified Employee and the proper expenditure ofthe grant funds. Qualified Employee and the Compliance Period As a provision of the agreement,ECQC was required to employ and/or retain a full-time employee who resides in Miami Beach and whose household earns at or under 80 AMI.ECQC hired Tinike Bennett to fulfill this requirement.ECQC provided an executed Employee Income Certification Form and a Source of Income Documentation form completed by and signed by Tinike Bennett on November 20,2020,along with a 2019 tax return,two paychecks,three bank statements,and a proof of residence to verify that she was a Miami Beach resident and met the required AMI.Ms. Egozi submitted an Employment Verification Form signed and dated November 23,2020. showing Ms.Bennett's date of hire as September 22,2020. According to the Scope of Services,Exhibit "A"of the agreement,the 12-month compliance period begins upon the City's verification of the employment of the qualified employee.Exhibit "A"also states, At the conclusion of the 12-month Qualification Period,the business must verify compliance by submitting payroll documentation.Ifthe Grantee is unable to provecompliance,then Grantee shall repay the Funds to the City,immediately uponreceivingademandforpayment. The EDD informed Jeannette Egozi in an email dated June 3,2021, Just so you are aware,since Ms.Bennett was never transitioned to a W-2 Full- Time employee per the program requirements,and I was notinformed ofthis back in January,she would be ineligible and does not count towards your 12 month period of retaining/creating a position for a low to moderate income Miami Beachresident. The email also stated,"I receivedthe information for Elmase on 5/19121 with paystubs dating back to March 2021,so please ensure thisemployee remains employed fora period of 12months (Feb2022)." According to email correspondence reviewed by the OIG,EImase Hoffman was an Administrative Program Coordinator at ECGC. On May 19,2021,an email was sent from ECQC to the EDD with attachments that included an Employee Income Certification Form and Sources of Income Documentation Form signed and dated by Elmase Hoffman on May 19,2021,along with two paystubs for March and April 2021, and a payroll summary report for Elmase Hoffman for March through May 2021 to verify that Ms. Hoffman was a resident of Miami Beach and met the required AMI.The EDD accepted Elmase Hoffman as the qualified employee for the 12-month compliance period going forward.ECQC provided payroll information for Elmase Hoffman from March 2021 through November 2021. Luis Wong,from the City EDD,informed the OIG that he recently contacted the City's former Redevelopment Specialist managing the ECQC process,and the Redevelopment Specialist acknowledged that Ms.Egozi was advised in an email that Ms.Hoffman's 12-month compliance period would extend to February 2022.However,the Redevelopment Specialist received verbal approval from the City's Housing and Community Services Department that Ms.Bennett's 1 quarter reporting would count towards ECQC's 12-month compliance requirement.On February 10,2022,the EDD sent an email to the Housing and Community Service CDBG Projects Coordinator with the subject "CDBG-CV Round 1-Progress Report &LMJ-January 2022"that listed ECQC as having completed its 12-month compliance period.Records obtained from the Florida Department of Revenue show that Ms.Hoffman received quarterly income from ECQC from 2012 through March 31,2024. Disbursement ofGrant Funds Under a provision of the Agreement,ECQC could request reimbursement of business expenses, including any operational costs such as payroll,utilities,rents,mortgage Interest,and/or COVID- 19-related expenses that occurred after July 10,2020,the date ECQC was selected in the lottery. On December 16,2020,ECQC submitted via email a reimbursement request for $10,000.00.A Small Business Assistance Reimbursement Request Approval form was completed and signed by the EDD Program Monitor,Department Director,and Financial Analyst on December 16,2020. for $10,000.00,identifying thatthethat the full amount of the grant awarded to ECQC was used for "Payroll Expenses."In support of the request,ECQC provided payment records for Tinike Bennett for $10,000.00,as depicted in the chart below. EARLYCHILDHOODQUALITY CONSULTANTS SALARYPMTSTOTINIKEBENNETT SEPTEMBER2020-DECEMBER 2020 DATE CHECK#AMOUNT 09/30/20 5655 $1,157.74 10/30/20 5672 $3,750.00 11/30/20 5699 $3,116.16 12/15/20 5714 SI,976.10 TOTALSALARY PAID $10,000.00 The reimbursement of the funds by the Economic Development Department to ECQC complied with the requirements of the agreement.Records show that between September 2020 and April 2021,Ms.Bennett received salary checks totaling $21,245.94. Conclusion and Recommendations The OIG has concluded its investigation into actions taken by Early Childhood Quality Consultants,LLC (ECQC)and its owner,Jeannette Egozi,to obtain a $10,000.00 grant through the City of Miami Beach Small Business COVID-19 Program.The investigation stemmed from the OIG's receipt of allegations that ECQC had (1)falsified documents in conjunction with a grant received,(2)an ECQC employee whose salary was fully funded by the Children's Trust was being used to collect grant money from the City,and (3)ECQC received funding illegally from two grants for employee salaries,afterschool programs,rent and utilities. The Miami-Beach OIG referred the information to the Miami-Dade OIG,as the Children's Trust is within theirjurisdiction.The Miami-Dade OIG investigated with a primary focus on allegations two and three above.The Miami-Dade OIG's investigative report issued on January 27,2025.found that "ECQC employees,whose salaries were fully funded by the Children's Trust,also functionedasemployeesforMs.Egozi's CBD +More store,which was co-located with ECQC'sadministrativeoffice;ECQC improperly requested reimbursement from the Children's Trust for its office space by categorizing the expense as program space,in contravention of the budget guidelines provided by the Children's Trust;and ECQC made misrepresentations when applying for a City of Miami Beach grant and used an employee whose salary was fully funded by the Children's Trust to retain the City's grant funds. As a result of the Miami-Dade OIG's investigative findings,based on the referral from the Miami Beach OIG,the Children's Trust rescinded ECQC's funding award on November 14,2023. Finding:Fraudulent Representations by ECQC and Jeannette Egozi The OIG substantiated that ECQC,through its owner Jeannette Egozi,made fraudulentrepresentationsconcerningtheDuplicationofBenefitsAffidavitthatwasexecutedandsubmittedbyMs.Egozi to the City,on which she acknowledged that she understood that it was a violationoffederallawtomakemateriallyfalsestatementsoruseanyfalsewritingordocumentknowing it contained any fictitious or fraudulent representations (Exhibit 2).In support of the affidavit, ECQC submitted two separate profit and loss statements that purportedly showed the expenditure ofthe Federal PPP funds that she received fromthe first PPP loan of $33,200.00(Exhibits 3 &4). The award of the City grant was contingent on ECQC's complete expenditure of the $33,300.00 in PPP loan funds.However,bank statements of the PPP loan lender Amerant Bank revealedthatMs.Egozi received two PPP loans totaling $67,940.00 between May 2020 and February 2021.The statements show that the PPP loan funds remained in Ms.Egozi's account withAmerantBankuntilMay11,2022,when the full amount ofthe two PPP loans was wire transferredtoherECQCbusinessaccountatJPMorganChase(Composite Exhibit 5). All transactions represented on the Amerant Bank statements were associated with the two PPP loans that Ms.Egozi received.No ECQC business transactions were made using the Amerant Bank account.None of the PPP loan proceeds were ever used by Ms.Egozi during 2020 or 2021 for the purposes she indicated they would be used when she applied for and was awarded the two PPP loans. Finding:Lack of Due Diligence by the Economic Development Department The OIG found that although the Economic Development Department required proof from ECQC that the $33,200.00 in PPP loan funds were fully expended,it accepted and relied only_on_the documents_submitted by_applicant that did not provide such proof.Exhibit B of the agreementlistssupportingdocumentstobesubmittedtodocumentexpensesincurred,which include electronic payroll ledgers with corresponding bank transactions,bank statements.and cancelled checks. ECQC provided an Amerant Bank statement that showed the deposit of ECQC's first PPP loan of$33,200.00 (Exhibit 3).This account was established with the PPP loan lending bank Amerant byJeannetteEgozitoreceivetheloanfunds.The funds from both of ECQC's PPP loans remained inthataccountuntilMay11,2022 (Composite Exhibit 5).The EconomicDevelopment Department didnotrequest,nor were they able to provided,bank statements showing the loan funds deposited into ECQC's JP Morgan Chase business account.ECQC provided two ECQC profit and lossstatements(Exhibits 3 &4)that itgenerated and submitted to show howthe funds were expended. The Economic Development Department did not request,nor were they a b I e to provided,any bank transactions,statements,or cancelled checks from ECQC's JP Morgan Chase business account to show proof of the expenditures represented on the profit and loss statements. As a result,the Economic Development Department accepted and relied on unbeknownst to the EDD staff.the fraudulent representations of ECQC and Jeannette Egozi to award $10,000.00 through the City of Miami Beach Small Business COVID-19 Program. conomic Development Department Response;The Economic DevelopmentDepartment were not aware of or suspect ECQC of any bad faith or fraud.and had no reason to believe the documents submitted were untrue.false or a misrepresentation,and acted pursuant to the program guidelines.Had the EDD team suspected fraud.misrepresentation and/or any other wrongdoing.ii would not have issued grant. Recommendations Based on the findings ofthis report,the OIG recommends that the City consider the following: 1.Identify and pursue all remedies established in the agreement or within the City to address, a.The funds issued to ECQC based on fraudulent representations;and b.future applications/requests for City funds by businesses owned and operated by Jeannette Egozi. 2.Establish and execute policy,procedures,and processes to ensure that established and appropriate backup documentation is received and verified before the expenditure of City funds. This report is presented by the OIG to the City Administration for its review and action as deemed appropriate concerning the findings and recommendations herein. As required by Miami Beach Code Section 2-256(0)(8),the final report will be provided to the Small Business Administration Office of Inspector General and the State Attorney's Office for their review and action as they deem appropriate. Respectfully submitted, Formatted:Font:Bold,Underline Joseph M.Centorino,Inspector General Dylan Hughes,Investigator Date Date cc:Eric Carpenter,City Manager Maria Hernandez,Assistant City Manager Steven Anthony,Director,Economic Development Heather Shaw,Assistant Director,Economic Development Felix Jimenez.Inspector General,Miami-Dade County Jeannette Egozi OIG Appendix B RESPONSE OF RABIN &LOPEZ,P.A. TO OIG DRAFT REPORT ON BEHALF OF YASMINE JEANETTE BLANCA EGOZI RABIN &LOPEZ,P.A. One SE Third Avenue Suite 2600 Miami,Florida 33131 June 16,2025 Joseph M.Centorino Inspector General City of Miami Beach Office of the Inspector General 1130 Washington Avenue,6"Floor Miami Beach,FL 33139 Via E-mail:CityofMiamiBeachQIG@miamibeachil.gov Tel:(305)358-1064 Fax:(305)372-1644 Email:sir@miamilawyer.com Email:andrea@miamilawyer.com Re:Response to Investigation of Community Development Block Grant- Corona Virus Funds Recipient Early Childhood Quality Consultants OIG No.:Pending Dear Mr.Centorino, This letter is submitted on behalf of Ms.Yasmine Jeannette Blanca Egozi ("Ms.Egozi")in response to the Draft Report issued by your office on April 10,2025,(the "Draft Report"). Following a thorough review of the relevant documentation provided by Ms.Egozi's accountant,it is our position that the Community Development Block Grant-Coronavirus ("CDBG-CV")funds in question were properly awarded.Specifically,the applicable Paycheck Protection Program (PPP")loan funds had been fully exhausted,thereby entitling Ms.Egozi to the full $10,000.00 City grant. We appreciate the opportunity to respond and remain committed to continuing our cooperation with your office. OIG EXHIBIT 1 COMMUNITY DEVELOPMENT BLOCK GRANT-CORONAVIRUS AGREEMENT FOR THE CITY OF MIAMI BEACH SMALL BUSINESS COVID-A19 RELIEF PROGRAM (FISCAL YEAR 2020) BETWEEN THE CITY OF MIAMI BEACH AND EARLY CHILDHOOD QUALITY CONSULTANTS,LLC This Agreement made and entered into this~day of •,2020,by and between the CITY OF MIAMI BEACH,FLORIDA,a Florida municipal corporatio having its principal office at 1700 Convention Center Drive,Miami Beach,Florida,33139,(hereinafter referred to as "City"),and EARLY CHILDHOOD QUALITY CONSULTANTS,LLC,a Florida limited liability company,having its principal place of business at 1205 71 St,Miami Beach,FL 33141(hereinafter referred to as "Grantee"). WHEREAS,on May 13,2020,the City Commission approved Resolution No.2020-31256, approving the allocation of $200,000 for small business assistance through Community Development Block Grant -Coronavirus (CDBG-CV)funding;and WHEREAS,on June 5,2020,the City Commission directed the Economic Development Department to utilize the CDBG-CV funds allocated to the Small Business Assistance Program {the "Program")for qualified Miami Beach small businesses,using two lottery systems,one for businesses that follow the MB Standard,and another for businesses that do not meet those standards,in order to select qualified grant recipients for an award of up to TEN THOUSAND DOLLARS ($10,000.00);and WHEREAS,Grantee applied for the Program and has been selected in the lottery as an eligible business;and WHEREAS,the City desires to provide a grant to Grantee under the terms of the Program. NOW,THEREFORE,in consideration of the mutual benefits contained herein,the City and Grantee agree as follows: Section 1.Agreement Documents:Agreement documents shall consist of this Agreement and the following four (4)exhibits,all of which are attached and incorporated in this Agreement: •Exhibit A-Scope of Services •Exhibit B -Documentation •Exhibit C-Financial Management for CDBG-CV funded activities •Exhibit D -Quarterly Report Form Section 2.Statement of Work:The Grantee agrees to implement the Program in accordance with Exhibits A and B,which Program is summarized as follows: Small Business COVID-19 Relief and Low-Income Employment: Pursuant to the CARES Act,the CDBG-CV funding is intended to "avoid job loss caused by business closures related to social distancing by providing short-term assistance for qualified business expenses"{as defined in Exhibit "A")to eligible small businesses who agree to employ and/or retain at least one (1)qualified low-and moderate-income employee {as defined in Exhibit "A")continuously for a period of one (1)year from the date the City verifies employment for the qualified employee (the "Compliance Period").If Grantee complies with the terms of the Program during the Compliance Period,the Grant Funds shall be forgiven by the City,pursuant to a written notification to Grantee.If Grantee is not able to document compliance with the terms of the Program during the Compliance Section 3.Agreement Amount:The City agrees to make available Community Development Block Grant-Coronavirus (CDBG-CV)funds,in an amount not to exceed TEN THOUSAND DOLLARS (10,000.00)for use by the Grantee during the Term of the Agreement to be spent on any business operational costs such as payroll,utilities,rents,or mortgage interest (for business accounts in existence as of February 1,2020),etc.and/or COVID- related expenditures.Grant money may only be used for those expenses which have occurred after being selected in the Program lottery (hereinafter,the aforestated amount including,without limitation,any additional amounts included thereto as a result of a subsequent amendment(s)to the Agreement,shall be referred to as the "Funds"). Section 4.Alterations:Any change to the Program shall require the prior written approval of the City Manager,which approval,if given at all,shall be at his/her sole reasonable judgment and discretion. Section 5.Reporting Requirements and Method of Payment:In compliance with 24 CFR 570.503 (b)(2),Exhibit B contains a checklist of backup documentation to be used in fulfillment of the quarterly reporting requirement.The Grantee will provide the City with a complete Quarterly Report every three months.The quarterly report will be due on the 10 day following every quarter period.In the event that the 10"of the month lands on a Saturday, Sunday or holiday,the report must be submitted the following business day.The report will detail how Funds are expended and for which type of business expenses.The Quarterly Report must also specify whether the Grantee is complying with the Employee Retentlon Requirement,including acknowledgement that the employee qualifies as a low-income employee.Quarterly reports will be submitted via any of the following methods: •Standard mail •Email Quarterly reports will not be considered acceptable unless the following is met: •Forms are completely and accurately completed including draw number and submittal date •Necessary back-up materials are included (as slated in Exhibit "B" Documentation.) •Reports bear the signature of the person preparing the report and the Grantee's authorized signatory Reports and/or requested documentation not received by the due date shall be considered delinquent and may be cause for default and termination of this Agreement,pursuant to Section 10 hereof.Other reporting requirements may be required by City in the event legislative amendments are enacted or as the City Manager may reasonably deem necessary.The Grantee shall be Informed,ln writing,If any changes become necessary. Section 6.Additional Conditions and Compensation:The parties acknowledge that the Funds originate from CDBG-CV grant funds from HUD,and must be implemented in full compliance with all of HUD's rules and regulations.In the event of curtailment or non- production of said Federal funds,the financial sources necessary to continue to pay the Grantee all or any portions of the Funds will not be available.In that event,the City may terminate this Agreement,which termination shall be effective as of the date that ft is determined by the City Manager,in his/her sole discretion and judgment,that the Funds are no longer available.In the event of such termination,the Grantee agrees that it will not look to,nor seek to hold the City,nor any individual member of the City Commission and/or City Administration,personally liable for the performance of this Agreement,and the City shall be released from any further liability to Grantee under the terms of this Agreement. 2 Section 7.Compliance with Local,State and Federal Regulations -The Grantee agrees to comply with all applicable Federal regulations as they may apply to Program administration as described in 24 CFR 570 and 2 CFR 200 and carry out each activity in compliance with the laws and regulations as described in 24 CFR 570 Subpart K --Other Program Requirements,as same may be amended from time to time.Additionally,the Grantee will comply with all State and local (City and County)laws and ordinances hereto applicable. It shall be the Grantee's sole and absolute responsibility to continually familiarize itself with any and all such applicable Federal,State,County,and City regulations,laws,and/or ordinances. Section 8.Assignment/Subcontract:No part of this Agreement may be assigned or subcontracted without the prior written consent of the City Manager,which consent,if given at all,shall be at the City's sole discretion and judgement. Section 9.Term:This Agreement shall commence retroactively on July 1,2020 and shall terminate at such time as the City determines that Grantee has provided sufficient documentation to establish compliance with all requirements for use of the Funds following disbursement of Funds to the Grantee (the Term). Section 10.Termination of Agreement: 10.1 Termination for Convenience:This Agreement may be terminated by the City,for convenience and without cause,through the City Manager,upon 30 days prior written notice to Grantee.In the event of such termination for convenience,the City shall retain any Funds which were not disbursed to Grantee before the effective date of termination. Grantee shall be solely responsible for immediately returning any unused or unapproved Funds as of the date of termination,and shall also be solely responsible for submitting a final report,as provided in Section 5 hereof,(detailing all Program objectives,activities and expenditures up to the effective date of the termination).Said final report shall be due within five (5)working days following the effective date of termination.Upon timely receipt of Grantee's final report,the City,at its sole discretion,shall determine the amount (if any) of any additional portion of the Funds to be returned to the City as a result of any unapproved or unused Funds,or incomplete Program items,and shall provide Grantee with written notice of any monies due.Said additional monies shall be due and payable immediately upon receipt of such notice by Grantee.Notwithstanding the preceding,the City reserves any and all legal rights and remedies it may have with regard to recapture of all or any portion of the Funds,or any assets acquired or improved in whole or in part with said Funds. 10.2 Termination for Cause:Notwithstanding Subsection 10.1 above,the City may also terminate this Agreement for cause."Cause"shall include,but not be limited to,the following: a.Failure to comply and/or perform,in accordance with the terms of this Agreement,or any Federal,State,County or City law,or regulation. b.Submitting reports to the City which are late,incorrect,or incomplete in any material respect. c.Implementation of this Agreement,for any reason,is rendered impossible or infeasible. d.Failure to respond in writing to any concerns raised by the City,including substantiating documents when required/requested by the City. e.Any evidence of fraud,mismanagement,and/or waste,as determined by the City's monitoring and applicable HUD rules and regulations. 3 The City shall notify the Grantee in writing when the Grantee has been placed in default.Such notification shall include:(i)actions taken by or to be taken by the City,such as withholding of payments;(i)actions to be taken by the Grantee as a condition precedent to curing the default,if applicable;and (Iii)a reasonable cure period,which shall be no less than thirty (30)days from notification date with respect to Subsections 10.2(a),(b),and (d). In the event the Grantee fails to cure a default under Subsections 10.2(a),(b),and (d) within the aforestated cure period,this Agreement shall be considered terminated for cause,without requiring further notice to Grantee. Notwithstanding the foregoing,with respect to Subsection 10.2 (c)and (e),the termination for cause,as described in this section,shall be effective upon receipt of the termination notice,without the opportunity to cure said default. Additionally,if Grantee has committed similar defaults under Subsections 10.2(a), (b),and (d),on two or more occasions during the term of the Agreement,the termination for cause,as described in this section,shall be effective as of the date the second notice is sent to Grantee by the City,without the opportunity to cure said default. Grantee shall be solely responsible for repayment to the City of all or any portion of the Funds disbursed to Grantee,as deemed required by the City,in Its sole and reasonable discretion.Said monies shall be immediately due and payable by Grantee. Notwithstanding the preceding,the City reserves any and all legal rights and remedies it may have with regard to recapture of all or any portion of the Funds,or any assets acquired or improved in whole or in part with said Funds. 10.3 Termination for Lack of Funds:In the event of curtailment of,or regulatory constraints placed on the Funds by HUD,this Agreement will terminate,effective as of the time that it is determined by the City Manager that such Funds are no longer available. Costs of the Grantee incurred after termination are not allowable unless expressly authorized in writing by the City Manager (whether in the notice of termination or subsequent thereto),and,in that case,may only be allowable if,in the sole discretion of the City Manager: a.The costs resulted from obligations which were properly incurred before the effective date of termination,were not in anticipation of ii,and are noncancelable; andb.The costs would be allowable if the Agreement expired normally at the end of its Term. 10.4 Interest and Collection Costs:Any payment made by Grantee after seven (7)days from the due date shall accrue interest at the rate of twelve percent (12%)per annum ("Default Interest").In addition to the Default Interest,Grantee shall pay the City all costs and reasonable attorney's fees incurred by the City in connection with the enforcement of this Agreement. Section 11.Equal Employment Opportunities/No Discrimination:In compliance with 2 CFR 200, Appendix II:Except as otherwise provided under 41 CFR Part 60,all contracts that meet the definition of "federally assisted construction contract"in 41 CFR Part 60-1.3 must include the equal opportunity clause provided under 41 CFR 60-1,4(b),in accordance with Executive Order 11246,"Equal Employment Opportunity"(30 FR 12319,12935,3 CFR Part,1964-1965 Comp.,p.339),as amended by Executive Order 11375,"Amending Executive Order 11246 Relating to Equal Employment Opportunity,"and implementing regulations at 41 CFR Part 60,"Office of Federal Contract Compliance Programs,Equal Employment Opportunity,Department of Labor." 4 Unless otherwise required by applicable laws,in connection with performance of the Services,the Grantee shall not exclude from participation in,deny the benefits of,or subject to discrimination anyone on the grounds of race,color,national origin,sex,age, disability,religion,income or family status. Additionally,Grantee shall comply with the City of Miami Beach Human Rights Ordinance, codified in Chapter 62 of the City Code,as may be amended from time to time,prohibiting discrimination in the employment,housing,public accommodations,or public services,on the basis of actual or perceived race,color,national origin,religion,sex,intersexuality, sexual orientation,gender identity,familial and marital status,age,ancestry,height,weight, domestic partner status,labor organization membership,familial situation,political affiliation,or disability. Section 12.Program Income:The use of program income by the Grantee shall comply with the requirements set forth at 24 CFR 570.504.By way of further limitations,the Grantee may use such income during the contract period for activities permitted under this contract. Section 13.Religious Organization or Owned Property:(Intentionally Omitted) Section 14.Reversion of Assets:In the event of a termination of this Agreement,or upon expiration of the Agreement,and in addition to any and all other remedies available to the City (whether under this Agreement,or at law or in equity),the Grantee shall immediately transfer to the City any Funds on hand at the time of termination (or expiration)and any accounts receivable attributable to the use of CDBG-CV Funds.The City's receipt of any Funds on hand at the time of terminatlon,shall not waive the City's right (nor excuse Grantee's obligation)to recoup all or any portion of the Funds,as the City may deem necessary. Additionally,in the event that Grantee fails to comply with the requirements of the Program,as more particularly described in Exhibits "A"and "B",Grantee shall be required to repay the City all of the Funds paid to Grantee,such sums shall be due and payable Immediately,upon demand. Section 15.Conformity to HUD regulations:The Grantee agrees to abide by guidelines set forth by HUD for the administration and implementation of the CDBG-CV Program,including applicable Uniform Administrative Requirements set forth in 24 CFR 570.502,as amended by 2 CFR 200 and applicable Federal laws and regulations in 24 CFR 570.600,et seq.as now in effect and as may be amended from time to time.In this regard,the Grantee agrees that duly authorized representatives of HUD shall have access to any books,documents, papers and records of the Grantee that are directly pertinent to this Agreement for the purpose ot making audits,examinations,excerpts and transcriptions. a.Subpart A -"Acronyms and Definitions" b.Subpart B -General Provisions c.Subpart C -"Pre-Federal Award Requirements and Contents of Federal Awards" d.Subpart D -"Post-Federal Award Requirements",except for 200.305,200.306, 200.307,200.308,200.311 as detailed below. 1)"Payment"is modified for lump sum drawdown for financing of property rehabilitation activities,in accordance with 570,513. 2)"Program Income"is governed by 570.504 5 3)"Real Properly"does not apply,except as provided in 570.200(j).Real property is governed by §570.505. 4)"Equipment"CDBG-CV Grantees shall follow Section 200.313,except that when the equipment is sold,the proceeds shall be program income.Equipment not needed by the Grantee for CDBG-CV activities shall be transferred to the recipient for the CDBG-CV program or shall be retained after compensating the recipient. 5)Section 200.333 "Retention requirements for records"applies except that: For Grantees: i.The retention period for individual CDBG-CV activities shall be the longer of five (5)years after the expiration or termination of the Grantee agreement under 570.503,or five (5)years after the submission of the annual performance and evaluation report,as prescribed in §91.520 of this title,in which the specific activity is reported on for the final time; ii.Records for individual activities subject to the reversion of assets provisions at 570.503(b)(7)or change of use provisions at $570.505 must be maintained for as long as those provisions continue to apply to the activity;and iii.Records for individual activities for which there are outstanding loan balances,other receivables,or contingent liabilities must be retained until such receivables or liabilities have been satisfied. Section 16.Section 200.343 "Closeout" City will close-out the Federal award when it determines that all applicable administrative actions and all required work of the Federal award have been completed by the Grantee. The following actions must take place to complete this process at the end of the Term. a.The Grantee must submit,no later than 90 calendar days after the end date of the Term,all financial,accomplishment,performance,and other reports as required by the terms and conditions of this Agreement.City may approve extensions when requested by the Grantee. b.Unless City authorizes an extension,Grantee must liquidate all obligations incurred under this Agreement no later than 90 calendar days after the end date of the Term as specified in the terms and conditions of this Agreement. c.City must make prompt payments to the Grantee for allowable reimbursable costs under this Agreement prior to being closeout. d.Grantee must promptly refund any balances of unobligated cash that City paid in advance or paid and that are not authorized to be retained by the Grantee for use in other projects.See 0MB Circular A-129 and see $200.345 Collection of amounts due,for requirements regarding unreturned amounts that become delinquent debts. e.Consistent with the terms and conditions of the Agreement,City must make a settlement for any upward or downward adjustments to the Federal share of costs after closeout reports are received. f.Grantee must account for any real and personal property acquired with Federal funds or received from the Federal Government in accordance with §§200.310 Insurance coverage through 200.316 Property Trust Relationship and 200.329 Reporting on Real Property. g.City should complete all closeout actions for Federal awards no later than one year after receipt and acceptance of all required final reports. 6 Section 17.Examination of Records:The Grantee shall maintain sufficient records in accordance with 24 CFR 570.502,570.503(b)(2)and 570.506 to determine compliance with the requirements of this Agreement,the GDBG-CV Program,and all other applicable laws and regulations.This documentation shall include,but not be limited to,the following. a.Books,records and documents in accordance with generally accepted accounting principles,procedures and practices,which sufficiently and properly reflect all revenues and expenditures of funds provided directly or indirectly by this Agreement,including matching funds and Program Income.These records shall be maintained to the extent of such detail as will properly reflect all net costs,direct and indirect labor,materials,equipment,supplies and services,and other costs and expenses of whatever nature for which reimbursement is claimed under the provisions of this Agreement; b.Time sheets for employees related to the Employee Retention Requirement;and c.How the Statutory National Objective(s)as defined in 24 CFR 570.208 and the eligibility requirement(s)under which funding has been received,have been met. These also include special requirements such as necessary and appropriate determinations as defined in 24 CFR 570.209,income certifications,and written Agreements with Grantees,where applicable. The Grantee is responsible for malntaln!ng and storing all records pertinent to this Agreement in an orderly fashion in a readily accessible,permanent and secured location for a period of five (5)years after expiration of this Agreement,with the following exception:if any litigation,claim or audit is started before the expiration date of the five (5)year period,the records will be maintained until all litigation,claims or audit findings involving these records are resolved.The City shall be informed in writing after closeout of this Agreement,of the address where the records are to be kept. Sectlon 18.Audits and Inspections: 18.1 At any time during normal business hours,and as often as the City (and/or its representatives)may deem necessary,the Grantee shall make available all records, documentation,and any other data relating to all matters covered by the Agreement, for review,inspection or audit. If this Agreement is closed-out prior to the receipt of an audit report,the City reserves the right to recover any disallowed costs identified in an audit after such closeout. 18.2 Inspector General Audit Rights. a.Pursuant lo Section 2-256 of the Code of the City of Miami Beach,the City has established the Office of the Inspector General which may,on a random basis, perform reviews,audits,inspections and investigations on all City contracts, throughout the duration of said contracts.This random audit is separate and distinct from any other audit performed by or on behalf of the City. b.The Office of the Inspector General is authorized to investigate City affairs and empowered to review past,present and proposed City programs,accounts, records,contracts and transactions.In addition,the Inspector General has the power to subpoena witnesses,administer oaths,require the production of witnesses and monitor City projects and programs.Monitoring of an existing City project or program may include a report concerning whether the project is on time, within budget and in conformance with the contract documents and applicable law. The Inspector General shall have the power to audit,investigate,monitor,oversee, 7 inspect and review operations,activities,performance and procurement process including but not limited to project design,bid specifications,(bid/proposal) submittals,activities of the Grantee,its officers,agents and employees,lobbyists, City staff and elected officials to ensure compliance with the contract documents and to detect fraud and corruption.Pursuant to Section 2-378 of the City Code, the City is allocating a percentage of its overall annual contract expenditures to fund the activities and operations of the Office of Inspector General. c.Upon ten (10)days written notice to the Grantee,the Grantee shall make all requested records and documents available to the Inspector General for inspection and copying.The Inspector General is empowered to retain the services of independent private sector auditors to audit,investigate,monitor,oversee,inspect and review operations activities,performance and procurement process including but not limited to project design,bid specifications,(bid/proposal)submittals, activities of the Grantee its officers,agents and employees,lobbyists,City staff and elected officials to ensure compliance with the contract documents and to detect fraud and corruption. d.The Inspector General shall have the right to inspect and copy all documents and records in the Grantee's possession,custody or control which In the Inspector General's sole judgment,pertain to performance of the contract,including,but not limited to original estimate files,change order estimate files,worksheets,proposals and agreements from and with successful subcontractors and suppliers,all project- related correspondence,memoranda,instructions,financial documents, construction documents,(bid/proposal)and contract documents,back-change documents,all documents and records which involve cash,trade or volume discounts.insurance proceeds,rebates,or dividends received,payroll and personnel records and supporting documentation for the aforesaid documents and records. e.The Grantee shall make available at its office at all reasonable times the records, materials,and other evidence regarding the acquisition (bid preparation)and performance of this Agreement,for examination,audit,or reproduction,until three (3)years after final payment under this Agreement or for any longer period required by statute or by other clauses of this Agreement.In addition: i.If this Agreement is completely or partially terminated,the Grantee shall make available records relating to the workterminated until three (3)years after any resulting final termination settlement;and ii.The Grantee shall make available records relating to appeals or to litigation or the settlement of claims arising under or relating to this Agreement until such appeals,litigation,or claims are finally resolved. f.The provisions in this section shall apply to the Grantee,its officers,agents, employees,subcontractors and suppliers.The Grantee shall incorporate the provisions in this section in all subcontracts and all other agreements executed by the Grantee in connection with the performance of this Agreement. 8 g.Nothing in this section shall impair any independent right to the City to conduct audits or investigative activities.The provisions of this section are neither intended nor shall they be construed to impose any liability on the City by the Grantee or third parties. Section 19.Indemnification/Requirements:The Grantee shall indemnify and hold harmless the City, its officers,employees and agents,from any and all claims,liability,losses and causes of action which may arise out of an act,omission,negligence or misconducton the part of the Grantee,or any of its agents,officers,servants,employees,contractors,patrons,guests, clients,licensees,invitees,or any persons acting under the direction,control,or supervision of Grantee,pursuant to this Agreement and/or the Program.The Grantee shall pay all claims and losses of any nature whatsoever in connection therewith and shall defend all suits in the name of the City,and shall pay all costs (including attorney's fees) and judgements which may issue thereon.This Indemnification shall survive the termination and/or expiration of this Agreement. Section 20.Conflict of Interest:The Grantee covenants that no person under its employ who presently exercises any functions or responsibilities in connection with Community Development Block Grant-Coronavirus (CDBG-CV)funded activities has any personal financial interests,direct or indirect,in this Agreement.The Grantee covenants that in the performance of this Agreement,no person having such conflicting interest shall be employed.The Grantee covenants that it will comply with all provisions of 24 CFR 570.611 "Conflict of Interest",and State,County and City of Miami Beach statutes,regulations, ordinances or resolutions governing conflicts of interest.The Grantee shall disclose,in writing,to the City any possible conflicting interest or apparent impropriety that is covered by the above provisions.This disclosure shall occur immediately upon knowledge of such possible conflict.The City will then render an opinion,which shall be binding on both parties. Section 21.Venue:This Agreement shall be governed by,and construed in accordance with,the laws of the State of Florida,both substantive and remedial,without regard to principles of conflict of laws.The exclusive venue for any litigation arising out of this Agreement shall be Miami-Dade County,Florida,if in State court,and the U.S.District Court,Southern District of Florida,if in Federal court.BY ENTERING INTO THIS AGREEMENT,CITY AND GRANTEE EXPRESSLY WAIVE ANY RIGHTS EITHER PARTY MAY HAVE TO A TRIAL BY JURY OF ANY CIVIL LITIGATION RELATED TO,OR ARISING OUT OF,THIS AGREEMENT. Section 22.Notices:All notices required under this Agreement shall be sent to the parties at the following address: City: With copy to: Economic Development Director City of Miami Beach 1700 Convention Center Drive Miami Beach,FL 33139 City Manager City of Miami Beach 1700 Convention Center Drive Miami Beach,FL 33139 9 With copy to: Grantee: City Manager City of Miami Beach 1700 Convention Center Drive Miami Beach,FL 33139 Jeannette Egozi Early Childhood Quality Consultants,LLC 1205 71St Miami Beach,Florida,33141 In the event that the Grantee changes the above-referenced business officer during the term of the Agreement,such change must be notified in writing to the City within 15 days of such change. Section 23.Limitation of Liability:The City desires to enter into this Agreement only if in so doing the City can place a limit on City's liability for any cause of action for money damages due lo an alleged breach by the City of this Agreement,so that its liability for any such breach never exceeds the sum of $5,000.Grantee hereby expresses its willingness to enter into this Agreement with Grantee's recovery from the City for any damage action for breach of contract to be limited to a maximum amount of $5,000. Accordingly,Grantee hereby agrees that the City shall not be liable to Grantee for damages in an amount in excess of $5,000,for any action or claim for breach of contract arising out of the performance or nonperformance of any obligations imposed upon the City by this Agreement.Nothing contained in this subparagraph or elsewhere in this Agreement is in any way intended to be a waiver of the limitation placed upon City's liability as set forth in Florida Statutes,Section 768.28. Section 24.Florida Public Records Law: a.Grantee shall comply with Florida Public Records law under Chapter 119,Florida Statutes,as may be amended from time to time. b.The term "public records"shall have the meaning set forth in Section 119.011(12), which means all documents,papers,letters,maps,books,tapes,photographs,films, sound recordings,data processing software,or other material,regardless of the physical form,characteristics,or means of transmission,made or received pursuant to law or ordinance or in connection with the transaction of official business of the City. c.Pursuant to Section 119.0701 of the Florida Statutes,if the Grantee meets the definition of "Contractor·as defined in Section 119.0701(1)(a),the Grantee shall: 1)Keep and maintain public records required by the City to perform the service; 2)Upon request from the City's custodian of public records,provide the City with a copy of the requested records orallow the records to be inspected or copied within a reasonable time at a cost that does not exceed the cost provided in Chapter 119, Florida Statutes or as otherwise provided by law; 3)Ensure that public records that are exempt or confidential and exempt from public records disclosure requirements are not disclosed,except as authorized by law, for the duration of the contract term and following completion of the Agreement if 10 disclosure requirements.If the Grantee keeps and maintains public records upon completion of the Agreement,the Grantee shall meet all applicable requirements for retaining public records.All records stored electronically must be provided to the City,upon request from the City's custodian of public records,in a format that is compatible with the information technology systems of the City. d.Request for Records;Noncompliance 1)A request to inspect or copy public records relating to the City's contract for services must be made directly to the City,If the City does not possess the requested records,the City shall immedlately notify the Grantee of the request, and the Grantee must provide the records to the City or allow the records to be inspected or copied within a reasonable time. 2)Grantee's failure to comply with the City's request for records shall constitute a breach of this Agreement,and the City,at Its sole discretion,may:(I)unilaterally terminate the Agreement;(ii)avail itself of the remedies set forth under the Agreement;and/or (iii)avail itself of any available remedies at law or in equity. 3)A Grantee who fails to provide the public records to the City within a reasonable time may be subject to penalties under s.119.10. e.Civil Action 1)If a civil action is filed against a Grantee to compel production of public records relating to the City's contract for services,the court shall assess and award against the Grantee the reasonable costs of enforcement,including reasonable attorneys' fees,if: i,The court determines that the Grantee unlawfully refused to comply with the public records request within a reasonable time;and ii.At least 8 business days before filing the action,the plaintiff provided written notice of the public records request,including a statement that the Grantee has not complied with the request,to the City and to the Grantee. 2)A notice complies with subparagraph (1)(ii)if it is sent to the City's custodian of public records and to the Grantee al the Grantee's address listed on its contract with the City or to the Grantee's registered agent.Such notices must be sent by common carrier delivery service or by registered,Global Express Guaranteed,or certified mail,with postage or shipping paid by the sender and with evidence of delivery,which may be in an electronic format. 3)A Grantee who complies with a public records request within 8 business days after the notice is sent is not liable for the reasonable costs of enforcement. f.IF THE GRANTEE HAS QUESTIONS REGARDING THE APPLICATION OF CHAPTER 119,FLORIDA STATlJTES, TO THE GRANTEE'S DUTY TO PROVIDE PUBLIC RECORDS RELATING TO THIS AGREEMENT,CONTACT THE CUSTODIAN OF PUBLIC RECORDS AT: 11 CITY OF MIAMI BEACH ATTENTION:RAFAEL E.GRANADO,CITY CLERK 1700 CONVENTION CENTER DRIVE MIAMI BEACH,FLORIDA 33139 E-MAIL:RAFAELGRANADO@MIAMIBEACHFL.GOV PHONE:305-673-7411 Section 25.This Agreement shall be binding upon all parties hereto and their respective heirs, executors,administrators,successors and assigns. [SIGNATURES TO FOLLOW] 12 IN WITNESS WHEREOF,the parties hereto have caused this Agreement to be executed by their duly authorized officials on the day and date first above indicated. EARLY CHILDHOOD QUALITY CONSULTANT,LLC, a Florida Limited Liability Company Jfore.Dall.(oo- Print Name Date T ATTEST: Signature Rafael E_Granado,City Clerk Print Name Date •l Fri were aanue 7'1/54\10° CITY OF MIAMI BEACH,FLORIDA, a Florida municipal corporation 2. Signature Dan Gelber,Mayor Print Name APPROVED AS TO FORM &LANGUAGE3±#,d 13 EXHIBIT "A" "SCOPE OF SERVICES" Statement of Work:Miami Beach Small Business COVID-19 Rellef Program In compliance with 24 CFR 570.503 (b)(1),Grantee agrees to provide the following. Grantee Name:EARLY CHILDHOOD QUALITY CONSULTANTS,LLC Federal Award Identification: DUNS Number: Federal Award:FY 2020 CDBG-CV Funds Subaward Period of Retroactive to August 1,2020 -September 30,2021Performance: Budget:$10,000.00 Total Amount of Federal Funds $10,000.00 Obliaated: Federal Awarding U.S.Department of Housing and Urban Development (HUD)Agency: Pass-through Entity:City of Miami Beach -Department of Economic Development Reports Due:Prior to the 10 of every month starting the month after contract execution: •Progress •Accomplishments•Financial Limited Clientele:At least one employee must qualify as low-to moderate-income clientele as oroven bv the income aualifications. Service Location:Miami Beach Program:Miami Beach Small Business COVID-19 Relief Program activities,including employment of one (1)low-income Miami Beach employee Deliverables:•Quarterly reporting Benchmarks:•Employment and or retention of at least one (1)qualified employee The Grantee is a Miami Beach-based small business of no more than five (5)employees. Quarterly Disbursement_Request.Grantee may request reimbursement of "qualified business expenses", as defined herein,in an amount of up to the Grant Amount of $10,000,by submitting detailed expense records and the required documentation listed in Exhibit "8".Grantee may submit multiple receipts for reimbursements,up to the Grant Amount.As referred to herein,"qualified business expenses"shall mean any operational costs such as payroll,utilities,rents,or mortgage interest (for business accounts in existence as of at least February 1,2020),etc.and/or COVID-19 related expenditures.Only those expenses which have occurred after Grantee was selected in the lottery are eligible for reimbursement.The City will issue payment lo Grantee within thirty (30)days from the date the City receives the required documentation to verify that the expenses requested are eligible for reimbursement under the Program. Employee Status and Retention Requirement.As consideration for receipt of the Grant Amount,Grantee agrees,to hire and/or retain a qualified employee,as defined herein,continuously,during the 12-month Compliance Period.If Grantee already employs a qualified employee at the time of expense reimbursement, Grantee must submit required employee documentation with the Quarterly disbursement request. Otherwise,within three (3)months following reimbursement,Grantee must create a job for a qualified employee and submit the required employee documentation.The 12-month Compliance Period begins only upon the City's verification of employment of the qualified employee.A qualified employee,as 14 referenced herein shall mean a fulltime employee who resides in Miami Beach and whose household earns at or under 80%AMI A qualified employee is considered a full-time employee if retained at 40 hours per week,or any combination of part-time positions combining for 40 hours per week.The employee must be a U.S.citizen or legal resldent,and the employee must also reside in the City of Miami Beach. LowIncome Employee.HUD's income limits are based on Median Family Income estimates and Fair Market Rent area definitions for the Miami-Dade County metropolitan area.Low income is defined as earning 80% of the median family income for Miami-Dade County.The 2020 income limits applicable for the household of the employee of the applicant business are: e- Household 1-Person 2-Person 3-Person 4-Person 5-Person 6-Person 7.Person 8-PersonSize low-Income $51,200 $58,500 $65,800 $73,100 $78,950 $84,800 $90,650 $96,500(80%)AMI At the conclusion of the 12-month Qualification Period,the business must verify compliance by submitting payroll documentation.If Grantee is unable to prove compliance,then Grantee shall repay the Funds to the City,immediately,upon receiving a demand for payment.Grantee will not be required to repay the Funds to the City,if the Grantee,throughout the Compliance Perlod retains or creates one (1)full-time employee that resides in a low-income City of Miami each household. Duplication of Benefits.To comply with HUD regulations,the City shall require the Grantee to complete a Duplication of Benefits form,a copy of which is incorporated herein by reference and attached hereto as Exhibit A-1,as a method of assessing whether the use of CDBG-CV funds will duplicate financial assistance that is already received or is likely to be received for COV)D-19 related losses.By accepting these CDBG- CV Funds,Grantee agrees to repay any portion of the Funds determined by the City to be duplicative Funds. Applicable Rules and Regulations: 1.Environmental Review: In compliance with 24 CFR 570.604 Environmental Standards,the City is responsible for undertaking Environmental Reviews in accordance with the requirements imposed on "recipients"in 24 CFR 58. The Program is an Economic development activity,and therefore,it falls under Categorically Excluded Activity not subject to 24 CFR 58.5.Pursuant to 24 CFR 58.35(b)4)that states that the Program is a categorically excluded activity that would not alter any conditions that would require a review or compliance determination under the Federal laws and authorities cited in $58.5. 2.Compliance with_National_objectiye At least 51%of the City's Program Grantees must be low-to moderate-income individuals,therefore, each Grantee is responsible for employing and/or retaining at least one (1)low-income qualified employee during the Qualification Period. Income Verification Grantee will follow the guidelines provided by 24 CFR Part 5.609,Annual Income to ensure eligibility of Program participants;maintain evidence that activities assisted with CDBG-CV funds comply with the primary National Objective,"Benefit to Low-and Moderate-Income Persons"and provide services or activities that benefit at least 51%low-and moderate-income persons.A low-or moderate-income household is defined as:a household having an income equal to or less than the limits cited below based on the unit size. The Clty recommends using the CDP Income Eligibility Calculator provided at https://www.hudexchange.info/incomecalculator/to determine Household eligibility.This form contains all the required certifications and warnings.It should be noted that the City does not allow the use of a self-certification approach to income documentation. 15 3. 4. Low-Income Household Limits HUD Low-Income (80%of Median Income)for FY2020 Household 1-Person 2-Person 3-Person 4-Person 5 -Person 6-Person 7.Person 8-PersonSlze L.ow- Income $51,200 $58,500 $65,800 $73,100 $78,950 $84,800 $90,650 $96,500(80%)AMI Evaluation In its continuing effort to ensure contract compliance and performance,the City will evaluate the Grantee in its fulfillment of the terms of this Agreement including,but not limited to,the following measures: •Agreement compliance •Accuracy and timeliness of Quarterly Reports •Adherence to Program timelines and Technical Assistance and Grantee Instructions •Fulfillment of prescribed outcomes Monitoring&Performance Reviews In compliance with 2 CFR 200.331(d)and (e),the City reserves the right to inspect,monitor and/or audit the Grantee,al least once a year,to ensure contractual compliance.City will notify Grantee a minimum of three (3)business days prior to a monitoring visit. 16 EXHIBIT "B" "Documentation" The Grantee agrees to provide the following documents as part of its reporting requirements: To document Employee Retention Requirement: •Income Verification forms must include: •Name •Date of birth •Employee's Miami Beach address •Demographic information as required in the CDBG-CV Income Verification Form •Verify information on family size and income so that it is evident that the household's family income does not exceed the low and moderate income limit. •Annual income is the gross amount of income anticipated by all adults in a family during the 12 months following the effective date of the determination. To calculate annual income,the Grantee may choose among definitions of income, listed below;however,the same income definition must be used for all Grantees. o Annual income as defined under the Section 8 Housing Assistance Payments Program (24 CFR 5.609);• o Adjusted gross income as defined for purposes of reporting under IRS Form 1040 (long form)for Federal individual income tax purposes. •To determine if program applicants are income-eligible,Grantees have several options: a)Obtain evidence that the household/person assisted qualified under another program having income qualification criteria at least as restrictive as that used in the definitions of LMI household/person,such as public housing and welfare programs;or b)Obtain evidence that the assisted person is homeless;or c)Obtain a verifiable certification from lhe assisted person that his/her family income does not exceed the applicable income limit according to the definition of income under 24 CFR 570.3: o Estimate the annual income of a family or household by projecting the prevailing rate of income of each person at the time assistance is provided for the individual,family,or household (as applicable).Estimated annual income shall include Income from all family or household members,as applicable. 1.Obtain verification of employment for each household member over the age of 18 by obtaining one of the following,as appropriate: a.Proof of entitlement payments;and/or b.Three (3)most current pay-stubs for those who are employed; and/or c.Verification of Self-Employment Tax Deposits for those who are self-employed. 2.Obtain verification offinancial assets for each household member over the age of 18 obtaining,as applicable,the following documents: a.The last 30 days of saving account statements; b.The last 30 days of checking account statements;and c.The last 30 days of mutual funds accounts 3.In the event that a household member over the age of 18 does not have employment or financial assets,he/she must complete and notarize the proper affidavits and submit with the application package. •Any additional documents as requested by the City 17 To document expenses incurred: Supporting documents to be submitted with the Quarterly Report are as follows: •Salary related expenses: •Electronic payroll ledgers with corresponding bank transactions (statement) •Cancelled checks •Form 941-Employer's Quarterly Federal Tax Return •Unemployment payment •Any additional documents as requested by the City •Fringe Benefits related expenses: •Bank statements •Worker's Compensation invoice,policy and cancelled check •Any additional documents as requested by the City 18 EXHIBIT "C" "Quarterly Report Forms" 19 OIG EXHIBIT 2 From: To: Cc: Subject: Date: Attachments: Importance: elmase@ecqc.biz Rivera,Michael Egozi Jeannette;accounting@ecac.biz CDBG SB Grant Additional Documents Required 01 Monday,November 23,2020 4:35:44 PM top.letterhead 2019-1120-S US INCOME TAX RETURN FOR AN S CORPORATION EALRY CHILHOOD QUALITY CONSULTANTS, LLC.pdf AUGUST-SEPTEMBER-OCTOBER-UTILITY BILL-EARLY CHILDHOOD QUALITY CONSULTANTS,LLC.pdf CHASE AUGUST-01-2020 BANK STATEMENT-EARLY CHILDHOOD QUALITY CONSULTANTS,LLC.pdf CHASE JULY-01-2020 BANK STATEMENT-EARLY CHILDHOOD QUALITY CONSULTANTS.LLC.pdf CHASE SEPTEMBER-01-2020 BANK STATEMENT-EARLY CHILDHOOD QUALITY CONSULTANTS,LLC.pdf DUPLICATION OF BENEFITS AFFIDAVIT-EARLY CHILDHOOD QUALITY CONSULTANTS,LLC.df EARLY CHILDHOOD QUALITY CONSULTANTS,LLC UTILITIES FOR SEPTEMBER-OCTOBER-NOVEMBER-2020.pdf High [THIS MESSAGE COMES FROM AN EXTERNAL EMAIL -USE CAUTION WHEN REPLYING AND OPENING LINKS OR ATTACHMENTS ] Good Afternoon Michael I hope this finds you well. Due to file size,the documents will be emailed in 3 parts. Part01.Please see attachments for required CDBG SB Grant Additional Documents. 1.Early Childhood Quality Consultants LLC 2019 Tax Return 2.Utilities bills for August,September,and October 2020 3.Chase Bank Statements for July 4.Chase Bank Statements for August 5.Chase Bank Statements for September 6.Duplication of Benefits Affidavit 7.Early Childhood Bill of Payment for Tinnike Bennet Best Regards, Elmase J.Hoffman.MSW,FGC,Intake Worker Administrative Program Coordinator 1205 71st Street Miami Beach,FL 33141 Phone:(305)864-5237 Fax:(305)861-8235 Email Notice -This message may contain privileged and confidential information intended only for the use of the addressee named above.Ifyou are not the intended recipient ofthis message you are hereby notified that any use,dissemination,distribution or reproduction of this message is prohibited.Ifyou have received this message in error please notify EarlyChildhood Quality Consultant dba PlayingThe Game Of Life immediately.Any views expressed in this message are those ofthe individual sender and may not necessarily reflect the views of Early Childhood Quality Consultant dba Playing The Game OfLife©. CITY OF MIAMI BEACH SMALL BUSINESS GRANT DUPLICATION OF BENEFITS AFFIDAVIT As part of the Small Business Grant application process,the Duplication of Benefits (DOB)Affidavit is required to disclose any funding that a business has received for COVID-19 related losses,in order to eliminate any duplication of benefits. INSTRUCTIONS The affidavit requires identification of assistance as follows: 1.Assistance received from other disaster recovery business assistance programs ; 2.Insurance assistance received for disaster related losses;and, 3.Government,bank and any and all other funding received by business for disaster related losses. Source of Funds #1 [Lender/Grant Provider Name JI Purpose Amount Government Loan;1□Nonprofit Grant []Private Loan Source of Funds #2 (Io []Nonprofit Loan []other: Government Forgivable Loan []Nonprofit Forgivable Loan s/c Lender/Grant Provider Name Purpose Amount []Government Loan []Government Grant [Government Forgivable Loan []Nonprofit Grant []Nonprofit Loan []Nonprofit Forgivable Loan []Private Loan [other: Source of Funds #3 Lender/Grant Provider Name Purpose Amount []Government Loan []Government Grant []Government Forgivable Loan []Nonprofit Grant []Nonprofit Loan []Nonprofit Forgivable Loan []Private Loan []other: Signature(s) By executing this Affidavit,Applicant(s)acknowledge and understand that Title 18 United States Code Section 1001:(1)makes it a violation of federal law for a person to knowingly and willfully (a) falsify,conceal,or cover up a material fact;(b)make any materially false,fictitious,or fraudulent statement or representation;OR (c)make or use any false writing or document knowing it contains a materially false,fictitious,or fraudulent statement or representation,to any branch of the United States Government;and (2)requires a fine,imprisonment for not more than five (5)years,or both, which may be ruled a felony,for any violation of such Section. o»too.6""a a 4At zo22 .."iea"e"" Joint Ap cant (Affiant)Signature Print Joint Applicant name (Affiant) OIG EXHIBIT 3 From: To: Cc: Subject: Date: Attachments: Importance: elmase@ecac.biz Rivera,Michael Egozi Jeannette;accounting@ecac.biz CDBG SB Grant Additional Documents Required 03 Monday,November 23,2020 4:37:32 PM to.letterhead PAYROLL REGISTRY FOR EARLY CHILDHOOD QUALITY CONSULTANTANTS,LLC.pdf PPP BANK STATEMENTS FOR EARLY CHILDHOOD QUALITY CONSULTANTS,LLC.df PPP PROFIT-LOSS FOR EARLY CHILDHOOD QUALITY CONSULTANTS,LLC.pdf SMALL BUSINESS ASSISTANCE REIMBURSEMENT REQUEST.pdf STATE OE FLORIDA DIVISION OF CORPORATION EARLY CHILDHOOD QUALITY CONSULTANTS.pdf VALID CITY OF MIAMI BEACH BIR EARLY CHILDHOOD QUALITY CONSULTANTS LLC.pdf High [THIS MESSAGE COMES FROM AN EXTERNAL EMAIL -USE CAUTION WHEN REPLYING AND OPENING LINKS OR ATTACHMENTS ] Good Afternoon Michael I hope this finds you well. Due to file size,the documents will be emailed in 3 parts. Part03.Please see attachments for required CDBG SB Grant Additional Documents. 1.Pay Roll Registry for Early Childhood Quality Consultants,LLC 2.PPP Bank Statements for Early Childhood Quality Consultants,LLC 3.PPP Pfroffit and Loss Early Childhood Quality Consultants,LLC 4.Small Business Assistance Reimbursement Request 5.State of Florida Division of Corporation for Early Childhood Quality Consultants,LLC 6.Valid City of Miami Beach BTR for Early Childhood Quality Consultants,LLC Best Regards, EImase J.Hoffman.MSW,FGC,Intake Worker Administrative Program Coordinator 1205 71st Street Miami Beach,FL 33141 Phone:(305)864-5237 Fax:(305)861-8235 Email Notice -This message may contain privileged and confidential information intended only for the use of AMERAANT P0,Box 229015 Miami,FL33222-9015 Statement Ending 05/31/2020 Page 1 of4 ADDRESS SERVICE REQUESTED > EARLY CHILDHOOD QUALITY CONSULTANTS,LLC 7144 BYRON AVE MIAMI BEACH FL 33141-3027 ±Telephone:1 (305)629-1212 Toll Free:1-888-629-0810:..12496 N.W.25th StreetMailingAddress.Miami,Florida 33182 @ Hours:amerantbank.com/locations How Can We Help? I[[ii[/llllllnlilblqll[4Ill Summary of Accounts Chat with a representative online through your Amerant TreasuryConnect%M,Simply login,click on the orange chat icon located on the lower left hand,enter the information and click send.Available Monday to Friday from 8:00 AM EST to 6:00 PM EST. Account Type Account Number Ending Balance Business Money Market 8201768606 $33,200.27 Business Money Market - Account Summary Description Beginning Balance 2 Credit(s)This Period 0 Debit(s)This Period 05/31/2020 Ending Balance Date 05/27/2020 Amount $0.00 $33,200.27 $0.00 $33,200.27 Interest Summary Description Amount Interest Earned From 05/26/2020 Through 05/31/2020 Annual Percentage Yield Earned Interest Days Interest Earned Interest Paid This Period Interest Paid Year-to-Date Interest Withheld Year-to-Date Average Ledger Balance 0.10% 6 $0.27 $0.27 $0.27 $0.00 $16,600.00 Other Credits Date Description 05/29/2020 140393563 New Loan Amount $33,200.00 05/29/2020 Interest Earned $0.27 Daily Ledger Balance Summary Date Balance Date Balance 05/26/2020 $0.00 05/29/2020 $33,200.27 Be MemberFDIC amerantbank.com Grt004t09r,LENDER 3:02 PM 11/23/20 Cash Basis Early Childhood Quality Consultantants Profit &Loss June 1 through November 15,2020 PPP TOTAL Expense Personnel Expenses Salaries &Wages Officer Salary Sr Prog Mgr 952.38 952.38 Total Officer Salary 952.38 952.38 Other Prog Coord 9,100.00 9,100.00 Prog Asssit 7,800.00 7,800.00 Total Other 16,900.00 16,900.00 Total Salaries &Wages 17,852.38 17,852.38 Fringe Benefits Health Insurance 276.77 276.77 Total Fringe Benefits 276.77 276.77 Total Personnel Expenses 18,129.15 18,129.15 Utilities Electric 352.79 352.79 Equipment -Lease 346.78 346.78 Telecommunications Land lines 477.70 477.70 Cell Phone 207.36 207.36 Telecommunications -Other 307.95 307.95 Total Telecommunications 993.01 993.01 Water &Sewer 50.00 50.00 Total Utilities 1,742.58 1,742.58 Space -Rent 10,328.54 10,328.54 Total Expense 30,200.27 30,200.27 Net Income -30,200.27 -30,200.27 Page 1 OIG EXHIBIT 4 From: To: Cc: Subject: Date: Attachments: accounting@ecgc.biz Rivera,Michael;ieannette@ecac.biz elmase@ecac.biz RE:CDBG SB Grant Additional Documents Required 03 Monday,December 7,2020 2:16:46 PM PPP PLJob PPP 6-1to 11-15-20.pdf Tinike Bennett November Pay Stub.pdf [THIS MESSAGE COMES FROM AN EXTERNAL EMAIL -USE CAUTION WHEN REPLYING AND OPENING LINKS OR ATTACHMENTS ] Good afternoon Michael, Attached you will find the P&L with the correct amount,my apology for the previous report. And addition please see attachment for Tinike's November 2020 pay stub. Please feel free to call or email me about any questions that might arises. Best regards, Florencia Dalla Torre Account Payables/Receivables P:305-864-5237 .F:305-861-8235 1205 71st Street Miami Beach,FL 33141 www.PlayingTheGameOfLife.com Email Notice -This message may contain privileged and confidential information intended only for the use of the addressee named above.If you are not the intended recipient of this message you are hereby notified that any use,dissemination,distribution or reproduction of this message is prohibited.If you have receivedthismessageinerrorpleasenotifyEarlyChildhoodQualityConsultantdbaPlayingTheGameOfLife© immediately.Any views expressed in this message are those of the individual sender and may not necessarily reflect the views of Early Childhood Quality Consultant dba Playing The Game Of Life • --------Original Message -------- Subject:RE:CDBG SB Grant Additional Documents Required 03 From:"Rivera,Michael"<MichaelRivera@miamibeachfl.gov> Date:Mon,December 07,2020 12:51 pm To:"jeannette@ecac.biz"<jeannette@ecqc.biz> Cc:"elmase@ecqc.biz"<elmase@ecac.biz>,"accounting@ecac.biz" <accounting@ecac.biz> Also, The PPP payment copy I received showed that a deposit of $33,200.27 was made to your business.As of 11/15/2020 $30,200.27 of it was spent leaving a balance of $3,000. Unfortunately it will need to be spent and I will need an updated copy of how it was spent before I can process the expense reimbursement on our end. From:Rivera,Michael 11:09 AM 11/24/20 Accrual Basis Early Childhood Quality Consultantants Profit &Loss by Job-PPP 6/1-11/15/2020 June 1 through November 15,2020 PPP TOTAL Expense Personnel Expenses Salaries &Wages Officer Salary Sr Prog Mgr 3,952.38 3,952.38 Total Officer Salary 3,952.38 3,952.38 OtherProg Coord 9,100.00 9,100.00ProgAsssit7,800.00 7,800.00 Total Other 16,900.00 16,900.00 Total Salaries &Wages 20,852.38 20,852.38 Fringe Benefits Health Insurance 276.77 276.77 Total Fringe Benefits 276.77 276.77 Total Personnel Expenses 21,129.15 21,129.15 Utilities Electric 352.79 352.79 Equipment -Lease 346.78 346.78 Telecommunications Land lines 477.70 477.70CellPhone207.36 207.36 Telecommunications -Other 307.95 307.95 Total Telecommunications 993.01 993.01 Water &Sewer 50.00 50.00 Total Utilities 1,742.58 1,742.58 Space -Rent 10,328.54 10,328.54 Total Expense 33,200.27 33,200.27 Net Income -33,200.27 -33,200.27 Page 1 OIG COMPOSITE EXHIBIT 5 AMERANT P.0 B80x229015 -Mar»,FL33222-9015 Statement Ending 05/31/2020 Page 1 of4 ADDRESS SERVICE REQUESTED How Can We Help? EARLY CHILDHOOD QUALITY CONSULTANTS,LLC 7144 BYRON AVE MIAMI BEACH FL 33141-3027 ±Telephone:1 (305)629-1212 Toll Free:1-888-629-0810 M 12496 N.W.25th StreetMailingAddress:Miami,Florida 33182 @ Hours:amerantbank.com/locations Summary ofAccounts Chat with a representative online through your Amerant TreasuryConnec%M.Simply login,click on the orange chat icon located on the lower left hand,enter the information and click send.Available Monday to Friday from 8:00 AM EST to 6:00 PM EST. Account Type Account Number Ending Balance Business Money Market r86o6 $33,200.27 Business Money Market -8@@@ Account Summary Date 05/27/2020 05/31/2020 Description Beginning Balance 2 Credit(s)This Period 0 Debit(s)This Period Ending Balance Amount $0.00 $33,200.27 $0.00 $33,200.27 Interest Summary Description Amount Interest Earned From 05/26/2020 Through 05/31/2020 Annual Percentage Yield Earned Interest Days Interest Earned Interest Paid This Period Interest Paid Year-to-Date Interest Withheld Year-to-Date Average Ledger Balance 0.10% 6 $0.27 $0.27 $0.27 $0.00 $16,600.00 Other CreditsDateDescription Amount 05/29/2020 140393563 New Loan $33,200.00 05/29/2020 Interest Earned $0.27 Daily Ledger Balance Summary Date Balance Date Balance 05/26/2020 $0.00 05/29/2020 $33,200.27 MemberFDIC amerantbank.com @ tteuul+USA,ENDER AMERAANT Statement Ending 03/01/2021 Page 3 of4 Business Money Market ..8_6_0_6 _ Interest Summary Description Amount Interest Earned From 02/01/2021 Through 03/01/2021 Account Summary Date Description Amount 02/01/2021 Beginning Balance $33,196.54 2 Credit(s)This Period $34,741.51 1 Debit(s)This Period $5.00 03/01/2021 Ending Balance $67,933.05 Service Charges $5.00 Annual Percentage Yield Earned Interest Days Interest Earned Interest Paid This Period Interest Paid Year-to-Date Interest Withheld Year-to-Date Average ledger Balance 0.05% 29 $1.51 $1.51 $2.92 $0.00 $37,988.26 Other CreditsDateDescription Amount 02/26/2021 402623263 $34,740.00 03/01/2021 Interest Earned $1.51 Other Debits Date 03/01/2021 Description Amount Statement Mailing Fee -$5.00 Daily Ledger Balance Summary DateBalance DateBalance DateBalance01/31/2021S33.196.54 02/26/2021 S67,936.54 03/01/2021$67.933.05 Overdraft and Returned Item Fees Total for this period Total year-to-date Total Overdraft Fees $0.00 $0.00 Total Returned Item Fees $0.00 $0.00 Service Charge Summary Description Amount Statement Mailing Fe $5.00 Service Chg Waived $5.00 AMERANT Statement Ending 05/31/2022 Page3of4 Business Money Market -8@o6_con"wee) Other CreditsDateDescription Amount 05/31/2022 Interest Earned $0.93 Other DebitsDate Description 05/11/2022 EARLY CHILDHOOD QUALITY CONSUL Amount -$67,902.55 Wire Out-Domestic-Manual 05/31/2022 Statement Mailing Fee -$0.93 Daily Ledger Balance Summary Date Balance Date Balance 04/30/2022 $67,902.55 05/11/2022 $0.00 Overdraft and Returned Item Fees Total for this period Total year-to-date Total Overdraft Fees $0.00 $0.00 Total Returned Item Fees $0.00 $0.00 Service Charge Summary Description Amount Statement Mailing Fe $0.93 Service Chg Waived $9.07 WIRE TRANSFER FROM ECQC AMERANT BANK PPP LOAN ACCOUNT TO ECQC CHASE BANK BUSINESS ACCOUNT MAY 11,2022 Wire Date Account No Amount Beneficiary Originator Recv Name Sender Name 05/11/2022 8606 67,902.55 EARLY CHILDHOOD QUALITY EARLY CHILDHOOD QUALITY JPMCHASE A MERA NT BANK CONSULTANTS CONSULTANTS ----onkFEDNote:..,, REU:Template:W Amt:07.902.55 USD v Source:BDW v Type:1000 Prod Code:CTR Ads: sod-.oo: AMERANT BANK S v Ref m V 5352008 value Dte:5/11/2022 g±].a, 0 so. .., Ml , Bankp Code:V CC:us Charge:V JPMCHASE ors]]snr ]I l Originator DD AC sos Beneficiary ID AC v ls;0 I EARLY CHILDHOOD QUALITY CONSUL 1205 71ST STREET MAMI BEACH FL 33141 EARLY CHILDHOOD QUALITY CONSULTANTS LLC 1205 71ST STREET MAMI BEACH FL 33141 Reference: