Good Morning experts.

Need your help to understand the code on whole house mechanical ventilation for New York State.

From what I gathered one could use bathroom fans as vehicle for exhaust and whole house ventilation as spelled in M15054.4 per NY state residential code.
From the code below, I read it as it is not mandatory to have fresh supply air.

The whole-house ventilation system shall consist of one or more supply or exhaust fans, or a combination of such, and associated ducts and controls. Local exhaust or supply fans are permitted to serve as such a system. Outdoor air ducts connected to the return side of an air handler shall be considered as providing supply ventilation.

https://up.codes/viewer/new_york/irc-2018/chapter/15/exhaust-systems#M1505.4.3

The question I have is, does this kind of system need make-up air. Engineer says the source is leaks into the building from construction. 
Thank you.