Build America, Buy America (BABA) requirements now apply in full to HUD-funded multifamily housing of five or more units, and the proof burden sits with whoever certifies each project. A domestic-content certification that cannot be backed by supplier evidence becomes an expensive liability: funding clawbacks, rip-and-replace costs, debarment from future federal work, and False Claims Act exposure that can attach even to a careless certification. The requirement flows down to every subcontract, purchase order, and supplier tier, which is why manual tracking in spreadsheets breaks the moment thresholds shift or an auditor asks for records on demand. Getting Buy America compliance for HUD housing right means mapping component-level BOMs to the correct domestic-content thresholds, collecting supplier certifications across every tier, and keeping audit-ready Buy America proof current as agency rules change. That is a documentation and automation problem before it is a sourcing problem. Ce
