Our NC-2009 project it's a 16,000sqf office building located in California.

The project has been finished and occupied 3 years ago. However, the Commissioning activities were never performed.

We are now ready for making the LEED submittal and the only thing missing is the Cx Report for EAp1. The Commissioning Agent is working on it and he has hired several contractors for performing the different tests on the installed equipment. The Cx agent will witness the testing and craft a Cx Report.

My questions are:

1) Is there any problem with the testing and Cx Report being performed 3 years after occupancy? How would the GBCI review this?

2) Among the contractors performing the tests on the equipment, one of them will be the main contractor of the project (just for the electrical systems testing). Unluckily, in the city where the project is located, there aren't other options. The contractor will just perform the testing and the Cx will write the report. Is there any problem about this? 

Thanks in advance for your help!