OFFICE OF INSPECTOR GENERAL

SEMIANNUAL REPORT TO CONGRESS

 FOR THE PERIOD ENDING SEPTEMBER 30, 2017

U.S. DEPARTMENT 

OF HOUSING 

AND URBAN 

DEVELOPMENT

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OUR MISSION

To provide independent, objective, and 

impactful oversight of the Department 

to help ensure efficient and effective 

programs and operations.

OUR VISION

To be the Office of Inspector General 

of choice for driving accountability 

and trust in Federal programs.

OUR VALUES 

Accountability

Accountability is taking ownership of our 

decisions and actions. We hold one another 

accountable to a higher standard of conduct.

Courage

Courage is doing what is right, no 

matter how difficult. We ask questions 

and raise concerns when needed.

Respect

Respect is appreciating the uniqueness 

of our workforce. We treat others with 

dignity, civility, and mutual consideration.

Stewardship

Stewardship is accepting our responsibility 

to serve the public good. We care about 

leaving things better than we found them.

Trust

Trust is the result of promises kept. 

We deliver on our commitments and 

communicate honestly with our stakeholders.

HIGHLIGHTS

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A MESSAGE FROM ACTING INSPECTOR GENERAL HELEN M. ALBERT

It is with great pleasure that 

I submit the U.S. Department of 

Housing and Urban Development 

(HUD), Office of Inspector 

General’s (OIG) Semiannual 

Report to Congress for the 

second half of fiscal year 2017. 

This report describes the 

remarkable accomplishments 

of the dedicated employees of HUD OIG. Among 

these are a continuation of OIG’s return on 

investment, which for fiscal year 2017 is 37 to 1 

for every dollar spent on our work. By promoting 

better stewardship and accountability in HUD’s 

programs, HUD OIG staff ensures that we have a 

lasting, positive impact on the Department and our 

communities for the benefit of the American people.

As an example of this impact, our Office of Audit 

produced a number of reports related to disaster 

funding and Federal Housing Administration (FHA) 

single-family programs. One of the more significant 

reports identified that HUD did not ensure that 

funds disbursed for disaster recovery programs 

were always used to acquire eligible and necessary 

products and services at fair and reasonable prices 

with appropriate support. Another report determined 

that HUD did not provide sufficient guidance and 

oversight to ensure that properties approved for 

FHA mortgage insurance had a continuing and 

sufficient supply of safe and potable water. 

In addition, our Offices of Investigation, Audit, and 

Evaluation were assembled to assess concerning claims 

of wrongdoing, mismanagement, and ineffectiveness 

related to HUD’s Section 232 nursing home mortgage 

insurance program. The conduct of the program 

owners and operators, as well as oversight by HUD’s 

Office of Residential Care Facilities, Real Estate 

Assessment Center, and Departmental Enforcement 

Center, were reviewed using a holistic approach to 

ensure effectiveness in the carrying out HUD’s role 

to provide decent, safe, and sanitary facilities for 

the care of our elderly and disabled population. 

Our Office of Investigation continues to have 

a significant impact on the Department through 

its investigative work. In one case, involving HUD 

Community Development Block Grant funds, HUD 

OIG investigated a New Jersey executive director of 

the Newark Watershed Conservation Development 

Corporation along with other conspirators engaged 

in a scheme to defraud a development company by 

accepting bribes and kickbacks from contractors 

and others based on fraudulently inflated invoices 

or being awarded work that was not performed. 

The former executive director, an employee, 

and multiple contractors for a city development 

organization were collectively sentenced in U.S. 

District Court to 20 years imprisonment for their 

role in the kickback scheme and ordered to pay 

$999,683 to the development organization.

In another case in Houston, TX, two lenders, their 

president, and a senior vice president originated loans 

through branches not approved by HUD, made false 

certifications to HUD regarding branch operations, 

submitted fictitious quality control reports to HUD, 

and failed to disclose that the company had been 

sanctioned by regulators and that some employees 

had felony convictions. The lenders violated the 

False Claims Act and the Financial Institutions Reform, 

Recovery, and Enforcement Act of 1989. In November 

2016, a jury awarded the United States more than $92.9 

million in damages. In September 2017, a Federal 

judge elected to triple the jury’s award judgment to 

FHA in the amount of more than $278.9 million.

We have also brought our resources to bear in other 

areas. For example, HUD’s use of legacy information 

technology (IT) systems poses risks. Our recent Office 

of Evaluation work found that 74 of the 85 major 

systems (87 percent) supporting HUD programs were 

comprised of legacy components. These systems are 

so old that it is increasingly difficult for HUD to maintain 

hardware and software and secure data. Authority is 

fragmented among the Office of the Chief Financial 

Officer, Office of the Chief Information Officer, and 

program offices for system planning, design, and 

development. If these key systems became unavailable, 

FHA would be unable to track insurance and pay 

claims, Section 8 payments could not be paid, and HUD 

financial systems would be unable to track expenditures.

Additionally, HUD has historically tried to 

incorporate risk management into its IT processes 

but consistently has not succeeded because its riskbased decisions were made in program offices, not at 

the Department level. Without a cohesive Enterprise 

Risk Management program, HUD is hampered in 

developing an IT strategic plan that is driven by risk. 

Such a plan would allow HUD to make well-informed 

decisions to ensure that its resources are being 

well spent and aligned with business objectives. 

In closing, we in HUD OIG are committed to working 

with Congress and the Department to improve HUD’s 

programs and operations. I also want to reiterate 

my sincere appreciation of the employees of HUD 

OIG for their dedication to the vitally important work 

they undertake every day. Through their collective 

effort, HUD OIG has surpassed its goals and fulfilled its 

mission and responsibilities to our Nation’s citizenry.

Helen M. Albert l Acting Inspector General
PROFILE OF PERFORMANCE

For the period April 1, 2017, to September 30, 2017

AUDIT RESULTS1 THIS REPORTING PERIOD FISCAL YEAR 2017

Recommendations that funds be put to better use $537,844,946 $3,854,174,737

Recommended questioned costs $102,430,550 $246,964,572

Collections from audits $20,189,725 $42,953,295

Administrative sanctions 1 1

Civil actions 1 3

Subpoenas 85 95

Personnel action 0 0

INVESTIGATION RESULTS1 THIS REPORTING PERIOD FISCAL YEAR 2017

Total restitutions and judgments $291,478,639 $487,588,517

Total recoveries and receivables to HUD programs2 $34,189,938 $45,149,855

Arrests 108 265

Indictments and informations 143 297

Convictions, pleas, and pretrial diversions 129 234

Civil actions 23 42

Total administrative sanctions 114 271

 Suspensions 37 105

 Debarments 54 106

 Limited denial of participation 0 1

 Removal from program participation 0 0

 Evictions 8 21

 Other3 15 38

Systemic implication reports 1 3

Search warrants 32 59

Subpoenas 343 685

JOINT CIVIL RESULTS1 THIS REPORTING PERIOD FISCAL YEAR 2017

Recoveries and receivables to HUD programs or 

HUD program participants $88,450,000 $143,204,576

Recoveries and receivables for other entities4 $71,901,944 $84,771,366

Recommendations that funds be put to better use $0 $55,405

Civil actions 5 9

Administrative sanctions 0 18

The Offices of Audit and Investigation and the Joint Civil Division periodically combine efforts and conduct joint civil fraud initiatives. Outcomes from these initiatives are shown in the Joint Civil 

Results profile and are not duplicated in the Audit Results or Investigation Results.

Does not include civil settlements worked jointly with Office of Audit

Includes reprimands, suspensions, demotions, or terminations of the employees of Federal, State, or local governments or of Federal contractors and grantees, as the result of OIG activities

This amount represents funds that relate to HUD programs but were paid to other entities rather than to HUD, such as funds paid to the U.S. Treasury for general government purposes.

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SEMIANNUAL REPORT TO CONGRESS

INSPECTOR GENERAL EMPOWERMENT ACT

BACKGROUND AND SUMMARY

The Inspector General Empowerment Act (Public Law 114-317) (IGEA), enacted in December 2016, mandates 

several reporting requirements in the U.S. Department of Housing and Urban Development, Office of Inspector 

General’s (HUD OIG) Semiannual Report to Congress (SAR). Below are the statutory requirements stipulated in 

the IGEA with hyperlinks to the detailed information as addressed throughout the SAR: 

• Summary of all reports with no establishment comment

o Summary of All Reports With No Establishment Comment (below)

• Summary of all reports with outstanding unimplemented recommendations, including potential cost

savings

o Appendix 5 - Open Recommendations

• Statistical table showing investigative report metrics

o Investigative Statistics and Metrics (below)

• Whistleblower retaliation instances

o Chapter 11 - Whistleblower Programs

• Instances of HUD interference through budget constraints, resistance, or objections

o OIG Independence (below)

• Undisclosed reports

o Appendix 4 - Undisclosed Reports

INVESTIGATIVE STATISTICS AND METRICS

The IGEA requires the SAR to include statistical tables and metrics for investigative cases. For the information

below, the data used in this statistical table were extracted from HUD OIG’s Case Management System. The 

Case Management System and its underlying infrastructure allow for data input and maintain data integrity 

during the complete investigative case cycle, while ensuring data privacy and confidentiality. The system was 

developed in .Net 4.5.1, and the database is SQL 2012. HUD OIG develops queries to extract data from the 

Case Management System to meet business requirements, such as the information used to create this statistical 

table. The following table provides additional guidance pertaining to each requested category of information. 

HUD OIG’s Case Management System is not currently configured to quantify persons referred for prosecution 

or differentiate whether a case or person was referred for Federal prosecution or State or local prosecution.

HUD OIG is currently developing a solution to the system configuration to allow a query to quantify persons 

referred for state and federal prosecution.

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SEMIANNUAL REPORT TO CONGRESS

Investigative statistical table (5(a)(17-18)): 

Requirement Total

A. Total number of investigative reports issued during the reporting period5 231 

B. Total number of persons referred to the U.S. Department of Justice for criminal prosecution

during the reporting period.6 119 

C. Total number of persons referred to State and local prosecuting authorities for criminal

prosecution during the reporting period.7 119 

D. Total number of indictments and criminal informations during the reporting period that

resulted from any prior referral to prosecuting authorities.8 143 

INVESTIGATIONS OF SENIOR GOVERNMENT EMPLOYEES 

The IGEA requires the SAR to summarize each investigation involving a senior government employee when 

allegations of misconduct were substantiated. Listed below are the cases for this reporting period: 

FALSIFICATION OF GOVERNMENT HIRING DOCUMENTS AND GROSS MISMANAGEMENT 

It was alleged that a HUD regional administrator and a former senior advisor committed gross mismanagement and 

created an announcement and rating factors to hire a spouse. It was also alleged that the administrator and former 

advisor rewrote the elements for multifamily presidential management fellows to bring them into the agency at a 

grade higher than that of similar fellows in other divisions. The matter was investigated, but the allegations were 

not substantiated. However, during the investigation, it was found that the regional administrator had given a 

management analyst improper access to HUD’s Time and Attendance system. HUD OIG referred the case to the 

U.S. Attorney’s Office (USAO) on November 9, 2016. The USAO declined criminal prosecution, citing a lack of 

apparent criminal intent. The regional administrator departed HUD during the course of the investigation, and the 

management analyst was directed to take a time and attendance system training.

SEXUAL HARASSMENT 

A HUD administrative specialist reported that he was being harassed by a HUD senior advisor and that the senior 

advisor sent sexually explicit text and voicemail messages on the administrative specialist’s personal cellular 

telephone, as well as instant messages to the administrative specialist’s HUD account, for approximately 18 months. 

The administrative specialist stated that he asked the senior advisor to stop this activity and reported the harassment 

to several supervisors. The administrative specialist also stated that the senior advisor implied that in exchange for 

sexual relations, the senior advisor could help improve the administrative specialist’s professional career. HUD 

5 Includes approved reports of investigations 6 Includes total cases presented for prosecution. HUD OIG's case management system is not currently configured to quantify persons

referred. 7 Includes total cases presented for prosecution. HUD OIG’s case management system is not currently configured to quantify persons

referred. 

8 Includes all charging documents reported: criminal complaints, indictments, informations, and superseding indictments

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SEMIANNUAL REPORT TO CONGRESS

OIG referred the case to the USAO on January 16, 2017. On January 16, 2017, the USAO declined criminal 

prosecution due to available administrative remedies. The HUD employee retired. 

VIOLATION OF CONFLICT OF INTEREST

It was alleged that a HUD director steered contracts and potentially violated the conflict-of-interest statute. The 

matter was investigated, but the allegation was not substantiated.

HUD OIG conducted a preliminary inquiry into potential violations of postemployment restrictions by a former 

senior Federal Housing Administration official. The investigation did not substantiate misconduct by the former 

official, nor did it identify evidence indicating that the former official communicated with Department officials in 

violation of Federal law or regulation. 

HUD OIG received information alleging that a HUD administrative officer owned several apartment buildings,

which were rented to tenants in HUD’s Section 8 program. The investigation did not substantiate misconduct by the 

administrative officer and determined that the subject did not violate any program rules.

SUMMARY OF REPORTS WITH NO ESTABLISHMENT COMMENT

The IGEA requires OIGs to report on each audit and evaluation report for which the Department did not return 

comments within 60 days of HUD OIG’s providing the report to the Department. There are no instances to report

this period. 

OIG INDEPENDENCE

The IGEA requires the SAR to include a detailed description of any attempt by the establishment to interfere with 

the independence of OIG, including incidents in which the establishment has resisted or objected to oversight

activities or restricted or significantly delayed access to information. There are no instances to report this period. 

SUMMARY OF REPORTS WITH OPEN RECOMMENDATIONS

The IGEA requires OIGs to report on each audit and evaluation report for which there are any outstanding 

unimplemented recommendations, including the combined potential cost savings of these recommendations. 

Summaries for the Office of Audit and Office of Evaluation is presented below. The complete details of each open 

recommendation can be found in appendix 5. 

AUDIT

The Department currently has 2,221 outstanding (open) unimplemented recommendations with a combined 

potential cost savings of more than $14 billion. The following table reflects the reasons why they remain

unimplemented: 

• 1,736 recommendations with active corrective action plans in place or valid repayment plans but not

yet fully implemented by HUD.

• 485 recommendations currently without management decisions (agreement between the Department

and OIG). Forty-six recommendations are beyond the 180-day statutory requirements due to

disagreement and were reported in table A of the SAR. The remainder are within the 180-day limit,

during which time management and OIG can arrive at an agreed-upon corrective action plan.

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SEMIANNUAL REPORT TO CONGRESS

• 395 open recommendations with management decisions in place but currently under investigative,

legislative, or judicial action or under a valid repayment plan and, therefore, suspended pending

resolution.

Calendar year Number of open 

recommendations

Cumulative estimated cost savings from 

open recommendations

Pre-2001 6 $3,992,169

2001 1 320,000

2002 7 1,382,626

2003 15 1,920,011

2004 9 9,071,874

2005 5 3,148,423

2006 37 18,334,821

2007 27 6,435,015

2008 40 72,882,242

2009 34 80,204,111

2010 37 54,455,869

2011 68 106,224,496

2012 49 22,862,098

2013 144 490,142,912

2014 241 2,021,971,818

2015 280 1,384,353,383

2016 547 9,189,977,153

2017 674 778,976,256

Total 2,221 $14,246,655,277 

EVALUATION

The following table summarizes Office of Evaluation (OE) reports with open recommendations: 

Reporting period Number of open recommendations

Pre-2013 0

2013 16

2014 25

2015 27

2016 25

2017 21

Total 114

OE conducts evaluations focused on improving departmental process and programs. As of the writing of this SAR, 

OE’s recommendations have not focused on producing direct cost savings but, rather, improving program 

effectiveness and reducing the likelihood of negative outcomes. For example, during this reporting period, some of 

OE’s recommendations addressed how HUD should provide clearer guidance and instruction to disaster grantees to 

assistant then in establishing effective internal audit activities

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TABLE OF CONTENTS

Chapter 1 – Integrity and Compliance Program.............................................................................................1

Chapter 2– Single-Family Programs................................................................................................................ 3

Audit............................................................................................................................................................................................3

Investigation.............................................................................................................................................................................. 7

Chapter 3 – Public and Indian Housing Programs......................................................................................... 9

Audit............................................................................................................................................................................................9

Investigation............................................................................................................................................................................ 15

Chapter 4 – Office of Multifamily Housing and Office of Healthcare Programs...................................... 16

Audit..........................................................................................................................................................................................16

Investigation............................................................................................................................................................................19

Chapter 5 – Community Planning and Development Programs ................................................................ 21

Audit..........................................................................................................................................................................................21

Investigation........................................................................................................................................................................... 26

Chapter 6 – Disaster Recovery Programs ..................................................................................................... 27

Audit..........................................................................................................................................................................................27

Investigation........................................................................................................................................................................... 29

Evaluation................................................................................................................................................................................ 30

Chapter 7 – Other Significant Audits and Investigations ........................................................................... 31

Audit..........................................................................................................................................................................................31

Evaluation.................................................................................................................................................................................32

Chapter 8 – Joint Civil Actions ...................................................................................................................... 34

Chapter 9 – Legislation, Regulations, and Other Directives ...................................................................... 37

Chapter 10 – Audit Resolution....................................................................................................................... 41

Chapter 11 – Whistleblower Programs ......................................................................................................... 59

Appendix 1 – Peer Review Reporting ............................................................................................................ 61

Appendix 2 – Audit Reports Issued................................................................................................................ 62

Appendix 3 – Tables..........................................................................................................................................71

Appendix 4 – Undisclosed Reports................................................................................................................ 95

Appendix 5 – Open Recommendations ......................................................................................................... 97

OIG Telephone Directory .............................................................................................................................. 355

Acronyms and Abbreviations List................................................................................................................. 359

Reporting Requirements............................................................................................................................... 362
SEMIANNUAL REPORT TO CONGRESS

CHAPTER 1 – Integrity & Compliance Program

In October 2015, the U.S. Department of Housing and Urban Development, Office of Inspector General (HUD 

OIG), set out to establish an Integrity & Compliance Program (ICP). This program, modeled after private-sector 

corporate ethics and compliance programs, was developed to provide a framework and foundation for ethical 

decision making and behavior. With the creation of the ICP, we have taken proactive steps to examine how we can 

build and sustain our values-based culture, which is reflected by our Core Values. 

SUMMARY OF PROGRESS

In December 2015, HUD OIG completed a cultural assessment survey that focused strongly on our leadership 

climate and ethical culture. In addition to identifying priorities for HUD OIG, the questions in the survey were 

designed to provide an assessment of employee perceptions of ethical culture and compare our results to national 

benchmarks. 

Based on employee feedback from our cultural assessment survey, we established five Core Values: 

accountability, courage, respect, stewardship, and trust. To communicate these values to our staff, we led an 

internal interactive communications campaign across the workforce.

In December 2016, we took the unprecedented step of developing and disseminating a new Accountability 

Report to all staff. This report listed charges and actions taken regarding misconduct and ethical lapses of OIG 

employees. The release of the report demonstrates the importance of transparency and illustrates how HUD 

OIG holds its staff accountable.

CORE VALUES: DEVELOPING OUR “SPEAK UP – LISTEN UP” CULTURE

The Core Values identified in the survey serve as the foundation for our professional conduct and serve as the 

essential elements toward building a better workplace. We have continued to emphasize the importance of our 

values through a sustained internal interactive communications campaign. Along with a video message from 

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our Deputy Chief Integrity and Compliance Officer, each of our senior leaders has filmed a video message in

which they discuss the personal importance of a particular HUD OIG core value. The communications from 

senior leaders are released monthly to the entire workforce. 

CORE VALUES TRAINING: BRICKS & MORTAR: BUILDING A BETTER WORKPLACE

In June 2017, HUD OIG initiated its second round of manager-led training, entitled “Bricks & Mortar: Building 

a Better Workplace.” The training, geared for all employees, included scenarios based on actual events that 

have occurred within OIG. Staff was encouraged to openly discuss ethical dilemmas and determine possible 

resolutions relative to HUD OIG Core Values. The training sessions were an opportunity to talk openly about 

our challenges, our work environment, and how our Core Values help us build a better workplace. The most 

recent round of training concluded in September 2017. We will continue to conduct this training once per 

quarter. 

NEXT STEPS 

The ICP is designed to strengthen and sustain our culture of compliance and integrity. Our newly established 

Integrity Ambassadors program, in which a diverse group of employees serve as ICP representatives to their 

offices, will further enable our employees to speak up and do the right thing. 

Along with creating a Core Values Award to recognize exemplary employee displays of our Core Values, we 

also plan to conduct a second enterprisewide cultural assessment survey in the spring of 2018 to determine the 

effectiveness of the ICP and identify program priorities moving forward. 

We hope our success will encourage the Department and other Federal agencies to follow our example, but 

more importantly, we hope to become a model for HUD to replicate, because+ such programs are relatively 

uncommon within the Executive Branch.

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CHAPTER 2 – SINGLE-FAMILY PROGRAMS

The Federal Housing Administration (FHA) single-family programs provide mortgage insurance to mortgage 

lenders that, in turn, provide financing to enable individuals and families to purchase, rehabilitate, or construct 

homes. Some of the highlights from this semiannual period are noted below. 

AUDIT

Strategic Initiative 1: Contribute to the reduction of fraud in single-family insurance 

programs

Key program results Questioned costs Funds put to better use

Audit 15 audits $5,299,854 $364,176,108 

REVIEW OF HUD’S OVERSIGHT TO ENSURE THAT FHA-INSURED PROPERTIES HAD 

SAFE WATER 

The U.S. Department of Housing and Urban Development, Office of Inspector General (HUD OIG), audited HUD’s 

oversight of safe water requirements for FHA-insured loans nationwide to determine whether HUD provided 

sufficient guidance and oversight to ensure that properties approved for mortgage insurance had a continuing and 

sufficient supply of safe and potable water.

HUD did not provide sufficient guidance and oversight to ensure that properties approved for mortgage insurance 

had a continuing and sufficient supply of safe and potable water. Of 49 loan files reviewed, from a universe of 

1,432 properties connected to a public water supply for which a notice that it had lead contamination was issued to 

the public, none disclosed the contamination or contained evidence of water testing. As a result, HUD could be 

endorsing loans for properties with contaminants that affect families’ health. Further, if property values decrease 

due to the water quality issues, both HUD and the homeowner face an increased risk of loss. 

OIG recommended that HUD direct the applicable lenders to provide evidence that the properties for 1,383 FHAinsured loans had a safe and potable water source or that the appraisers had not notified them of the water quality 

issue on their appraisals. If they cannot provide this evidence, HUD should direct them to perform water testing and 

any necessary remediation or indemnify HUD against future loss. OIG also recommended that HUD improve its 

guidance and implement policies and procedures to ensure compliance, thereby putting nearly $238.1 million to 

better use. (Audit Report: 2017-PH-0003) 

REVIEW OF HUD’S OVERSIGHT OF SERVICERS’ USE OF LOSS MITIGATION PROGRAMS

HUD OIG audited HUD’s oversight of servicers’ use of loss mitigation programs to determine whether HUD had 

adequate controls to ensure that servicers of single-family FHA-insured loans engaged in loss mitigation as 

required. 

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HUD did not have adequate controls to ensure that servicers of single-family FHA-insured loans properly engaged 

in loss mitigation. More specifically, HUD did not adequately review claim loans that did not have loss mitigation 

default status codes reported to HUD by servicers. From January 1, 2014, to December 31, 2016, there were 14,763 

claim loans, which indicated that servicers did not engage in loss mitigation, and HUD reviewed only 194 (1.3 

percent) of these loans. Also, a review of 90 statistically sampled claims that closed from January 1, 2012, to 

December 31, 2015, determined that 26 had significant servicing deficiencies. This lack of oversight may have put 

borrowers in default at risk of not being able to avoid foreclosure by using HUD’s loss mitigation program and 

resulted in an increased overall risk to the program of a projected more than $120.9 million for losses in which 

servicers did not properly engage in loss mitigation.

OIG recommended that HUD (1) revise its policies and procedures to emphasize increased controls toward claim 

loans for which no loss mitigation evaluation occurred; (2) develop and implement policies and procedures to 

ensure that the Office of Lender Activities and Program Compliance and the Office of Single Family Asset 

Management communicate the results of servicing reviews to each other; (3) implement policies and procedures to 

reinforce guidance to ensure that servicers accurately report the status of loans to HUD; (4) require indemnification 

for the 26 loans that had significant servicing deficiencies, resulting in nearly $1.7 million in questioned costs; (5) 

reinforce guidance to servicers to ensure that they engage in loss mitigation as required; and (6) require the servicers 

with deficiencies to revise their procedures to ensure that they comply with the requirements. (Audit Report: 2017-

LA-0004) 

 

REVIEW OF HUD’S OVERSIGHT OF VOLUNTARY TERMINATIONS OF FHA-INSURED 

LOANS 

HUD OIG audited HUD to determine whether it ensured that lenders properly processed voluntary terminations of 

insurance coverage on single-family FHA loans and disclosed all implications of the terminations to the borrowers. 

HUD did not always ensure that lenders properly processed voluntary terminations of FHA insurance for singlefamily loans and did not ensure that lenders disclosed all implications of voluntary termination of mortgage 

insurance to the borrowers. As a result, borrowers lost the protection of their FHA insurance coverage, overpaid 

FHA premiums, and were not fully informed of the financial impact of the voluntary terminations, and HUD’s 

records were inaccurate.

OIG recommended that HUD (1) investigate the 14 loans with unpaid mortgage amounts totaling more than $3 

million and require the lenders to obtain the borrowers’ consent, reinstate the insurance coverage, or take other 

action as appropriate for each loan; (2) remind lenders that voluntary termination is not the correct termination type 

for recording third-party sales and borrower consent is required to terminate insurance, even if the loans are 

indemnified; (3) improve its procedures to detect and sanction improper voluntary terminations; and (4) update 

HUD Handbook 4000.1 to require that the consent form include an explanation that voluntary termination differs 

from mortgage insurance premium cancellation as well as the disclosure of any outstanding partial claims when 

lenders attempt to voluntarily terminate insurance. (Audit Report: 2017-KC-0003) 

IMPROPER ORIGINATION OF FHA-INSURED LOANS WITH RESTRICTIVE COVENANTS 

HUD OIG audited RMS & Associates in Las Vegas, NV, to determine whether it complied with HUD requirements 

for FHA loan origination. 

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RMS improperly originated 49 FHA loans, which contained prohibited restrictive covenants. As a result, it placed 

the FHA fund at unnecessary risk for potential losses of more than $2.4 million. In addition, HUD paid partial 

claims on two of the 49 active loans, resulting in actual losses of more than $26,000. 

OIG recommended that HUD require RMS to (1) work with HUD to nullify the restrictions on conveyance that 

violate HUD policy or indemnify HUD against future losses for the 49 loans, (2) repay HUD for partial claims paid 

on two FHA loans that contained prohibited restrictive covenants, (3) develop and implement policies and 

procedures to identify prohibited restrictions on conveyance to ensure that it does not originate FHA loans with 

prohibited restrictive covenants, and (4) provide training to its employees regarding HUD’s requirements related to 

prohibited restrictions on conveyance. OIG also recommended that HUD pursue civil and administrative remedies 

regarding improper certifications made to HUD if legally sufficient. (Audit Memorandum: 2017-LA-1803) 

PROPERTY PRESERVATION AND PROTECTION SERVICES WERE NOT PROVIDED BY A 

MANAGEMENT AND MARKETING III PROGRAM COMPANY

HUD OIG audited BLM Companies LLC in Hurricane, UT, regarding its controls and performance under its 

Management and Marketing III program field service manager contract with HUD for area 1D, which included 

HUD real estate-owned and custodial properties in New Mexico, North Texas, Utah, and Colorado. The audit 

objective was to determine whether BLM Companies LLC provided property preservation and protection services in 

area 1D in accordance with its contract and HUD requirements.

BLM did not comply with its HUD area 1D field service manager contract. Observations of properties assigned 

under the contract showed a 71 percent failure rate. As a result, BLM did not protect and preserve HUD-held 

properties in accordance with the contract, increasing the risk to the FHA insurance fund related to health and safety 

hazards and reduced sales prices. HUD paid BLM nearly $497,000 in unearned property management and 

inspection fees over the term of the contract.

OIG recommended that HUD require BLM to (1) repay more than $8,000 in ineligible costs and support or repay 

nearly $489,000 in unearned property management and inspection fees and (2) implement an effective quality 

control system to ensure that it complies with its contract, putting $891,000 to better use. Additionally, HUD 

should assess BLM’s performance at least quarterly and if its performance does not improve, determine whether 

BLM was in default of its contract and take appropriate action if needed. (Audit Report: 2017-FW-1011) 

HUD OIG audited BLM Companies LLC in Hurricane, UT, a contracted field service manager in HUD’s real 

estate-owned Management and Marketing III program, to determine whether BLM provided property preservation 

and protection services in accordance with its contract with HUD and its own requirements. 

BLM did not provide property preservation and protection services in accordance with its contract with HUD and its 

own requirements. Specifically, it did not ensure that it performed adequate initial services before recently acquired 

HUD-owned properties were promoted to ready-to-show status. BLM also did not ensure that HUD-owned and 

custodial properties were maintained in accordance with its contract with HUD. As a result, HUD lacked assurance 

that BLM maintained the properties in a manner that preserved communities and the value of the properties. 

Further, BLM inappropriately received more than $25,000 in management fees for properties that were not 

maintained in accordance with its contract. 

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OIG recommended that HUD require BLM to (1) certify and support that the applicable deficiencies have been 

corrected for 8 of the 109 properties cited, (2) reimburse HUD for properties that did not receive proper preservation 

and protection services, and (3) implement adequate procedures and controls to ensure that all properties comply 

with its contract with HUD and its own requirements to prevent $594,000 in HUD funds from being spent over the 

next year on management fees for properties that are not adequately maintained. Further, OIG recommended that 

HUD assess BLM’s performance at least quarterly and if its performance does not improve, HUD should determine 

whether BLM has defaulted on its contract and take the appropriate actions. (Audit Report: 2017-CH-1011) 

REVIEW OF HUD’S RULEMAKING PROCESS FOR ITS SINGLE-FAMILY NOTE SALES 

PROGRAM 

HUD OIG audited HUD’s single-family note sales program to determine whether HUD conducted the rulemaking 

process for the program.

HUD did not conduct rulemaking or develop formal procedures for its single-family note sales program. HUD 

issued an advance notice of proposed rulemaking in 2006 to solicit comments on the program. However, it did not 

finalize the comment process or prepare the program for a final rule. Additionally, HUD did not develop formal 

guidance or procedures for its note sales program. 

OIG recommended that HUD (1) complete the rulemaking process for its single-family note sales program and (2) 

develop and implement formal procedures and guidance for the program. (Audit Report: 2017-KC-0006) 

REVIEW OF GINNIE MAE’S OVERSIGHT OF NONBANKS

HUD OIG audited the Government National Mortgage Association’s (Ginnie Mae) oversight of nonbanks to 

determine whether Ginnie Mae responded adequately to changes in its mortgage-backed securities issuer base.

Ginnie Mae did not adequately respond to changes in its issuer base. Specifically, it did not implement policies and 

procedures in a timely manner for its account executives to follow in managing issuers, did not develop a written 

default strategy, and did not assess and address the risks posed by nonbanks in a timely manner. As a result, Ginnie 

Mae may not identify problems with issuers in time to prevent default. Additionally, it may not be able to properly 

service loans absorbed in a default and may require additional funds from the U.S. Treasury to pay investors in the 

event of a large issuer default.

OIG recommended that Ginnie Mae develop and implement controls to (1) ensure that policies and procedures for 

account executives are continually reviewed and updated to reflect changes in Ginnie Mae’s operations; (2) 

determine the total impact of a large or multiple-issuer default, the maximum-size default Ginnie Mae can 

adequately execute, and individual issuers’ ability to adapt to changing market conditions; (3) continually assess 

personnel skills required to meet organizational goals; and (4) ensure that employee skill levels are developed to 

meet changing organizational needs. (Audit Report: 2017-KC-0008) 

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INVESTIGATION

Program results

Administrative - civil actions 69 

Convictions - pleas - pretrial diversions 34 

Financial recoveries $265,537,959 

TEN IMPRISONED FOR LOAN MODIFICATION SCAM

Ten employees of a mortgage modification company were sentenced in U.S. District Court in connection with 

earlier guilty pleas to and convictions of wire fraud, mail fraud, and conspiracy to commit wire fraud. Collectively, 

the defendants were sentenced to more than 104 years imprisonment and ordered to pay more than $10.2 million in 

restitution to the victims. The conspirators targeted distressed homeowners, making misrepresentations to induce 

them to make payments of thousands of dollars each in exchange for supposed mortgage modification assistance. 

The defendants did nothing to modify the mortgages and used the victims’ payments for their own personal benefit. 

Victims suffered losses exceeding $11 million. HUD OIG, the Special Inspector General for the Troubled Asset 

Relief Program (SIGTARP), the United States Postal Inspection Service, and the Federal Housing Finance Agency 

(FHFA) OIG conducted this investigation. (Orange County, CA) 

LENDERS AND EXECUTIVES ORDERED TO PAY ALMOST $300 MILLION

A Federal jury found two lenders, their president, and a senior vice president liable for violations of the False 

Claims Act and the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 for misrepresentations in 

connection with the FHA program. A Federal judge in U.S. District Court ordered the defendants to pay more than 

$298.5 million to FHA for those violations. The lenders originated loans through branches not approved by HUD, 

made false certifications to HUD regarding branch operations, submitted fictitious quality control reports to HUD, 

and failed to disclose that the company had been sanctioned by regulators and that some employees had felony 

convictions. HUD OIG, the HUD Office of General Counsel, and the U.S. Attorney’s Office conducted this 

investigation. (Houston, TX)

FIVE SENTENCED FOR LOAN MODIFICATION SCAM 

Five conspirators were sentenced in U.S. District Court in relation to their earlier guilty pleas to conspiracy, wire 

fraud, and submitting false information to HUD for their role in a loan modification scam. The ringleader was 

sentenced to 135 months in prison, and all five were ordered to pay restitution in the cumulative amount of more 

than $2.6 million. The group made a series of false promises to convince more than a thousand distressed 

homeowners seeking relief through government mortgage modification programs to pay thousands of dollars each 

in advance fees to numerous companies owned or controlled by the ringleader. Among other things, the fraudsters 

directed telemarketers and salespeople to lie to distressed homeowner victims by telling them that they were 

preapproved for loan modifications and that they were retaining a law firm and an attorney who would complete 

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their mortgage relief applications and negotiate with the banks to modify the terms of their mortgages. Contrary to 

these representations, the conspirators did little or no work in connection with these fraudulently induced advanced 

fees. HUD OIG, the Federal Bureau of Investigation, and SIGTARP conducted this investigation. (Brooklyn, NY)

FRAUDSTER SENTENCED TO 8 YEARS IN PRISON

A defendant was sentenced in U.S. District Court in connection with his earlier guilty plea to mail fraud, wire fraud, 

impersonating a government official, and false statement to a government official. The convicted offender operated 

under several fictitious businesses and under several fake names, falsely representing himself as a HUD employee 

or attorney to distressed homeowners seeking a reduced interest rate or mortgage payment. He collected payments 

labeled as “appraisal fees and closing costs” as well as monthly mortgage payments from struggling homeowners 

under the pretense that they would be forwarded to the lender and go toward a loan modification. However, no 

money was sent to any lenders. The payments were instead deposited into personal accounts for his own use. The 

defendant was sentenced to 97 months in prison and ordered to pay more than $2.2 million in restitution to the 

victims. HUD OIG, FHFA OIG, SIGTARP, U.S. postal investigators, and the Orange County District Attorney’s 

Office conducted this investigation. (Santa Ana, CA)

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CHAPTER 3 – PUBLIC AND INDIAN HOUSING PROGRAMS

The U.S. Department of Housing and Urban Development (HUD) provides grants and subsidies to more than 3,300 

public housing agencies (PHA) nationwide. Many PHAs administer both public housing and Section 8 programs. 

HUD also provides assistance directly to PHAs’ resident organizations to encourage increased resident 

management entities and resident skills programs. Programs administered by PHAs are designed to enable lowincome families, the elderly, and persons with disabilities to obtain and reside in housing that is safe, decent, 

sanitary, and in good repair. Some of the highlights from this semiannual period are noted below. 

AUDIT

Strategic Initiative 2: Contribute to the reduction of erroneous payments in rental 

assistance

Key program results Questioned costs Funds put to better use

Audit 23 audits $14,999,001 $108,813,272 

REVIEW OF HUD’S HOUSING CHOICE VOUCHER PROGRAM

HUD’s Office of Inspector General (OIG) audited the Louisville Metro Housing Authority in Louisville, KY, 

regarding its Section 8 Housing Choice Voucher program to determine whether the Authority administered its 

program units in accordance with HUD’s and its own requirements. 

The Authority did not administer its program units in accordance with HUD’s and its own requirements. It did not 

ensure that 103 of 106 (97 percent) program units inspected met HUD’s or its own housing quality requirements, 

and 44 of the 103 units were found to be in material noncompliance with the requirements. In addition, for 

abatement of housing assistance payments and determination of rent reasonableness and owner eligibility, the 

Authority did not always comply with HUD’s and its own requirements. As a result, some tenants lived in 

inadequately maintained units, and the Authority disbursed more than $65,500 in housing assistance payments and 

received more than $7,800 in administrative fees for the units in noncompliance with program requirements. 

OIG recommended that HUD require the Authority to (1) reimburse its program more than $73,000 from nonFederal funds, (2) ensure that all violations cited for units failing to meet housing quality standards have been 

corrected and certify that the units meet program requirements, and (3) develop and implement adequate controls 

and written procedures to address deficiencies cited and prevent more than $20.5 million in program funds from 

being spent over the next year on units that do not materially comply with program requirements. (Audit Report: 

2017-AT-1010) 

HUD OIG audited the Housing Choice Voucher program of the Chester Housing Authority in Chester, PA, to 

determine whether the Authority ensured that its Housing Choice Voucher program units met HUD’s housing 

quality standards. 

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The Authority did not always conduct adequate inspections to ensure that its program units met housing quality 

standards. Of 65 program units inspected, 61 did not meet HUD’s housing quality standards. Further, 22 of the 61 

were in material noncompliance with housing quality standards. The Authority disbursed more than $44,000 in 

housing assistance payments and received more than $2,000 in administrative fees for these 22 units. Over the next 

year, if the Authority does not implement adequate procedures to ensure that its program units meet housing quality 

standards, HUD could pay more than $2.6 million in housing assistance for units that materially fail to meet those 

standards.

OIG recommended that HUD require the Authority to (1) certify, along with the owners of the 61 units cited, that 

the applicable housing quality standards violations have been corrected; (2) reimburse its program from non-Federal 

funds for the 22 units that materially failed to meet HUD’s housing quality standards; and (3) develop and 

implement procedures and controls to monitor the inspection process to ensure that program units meet housing 

quality standards. (Audit Report: 2017-PH-1007) 

HUD OIG audited the Housing Choice Voucher and public housing programs at the West Warwick Housing 

Authority in West Warwick, RI, to determine whether (1) procurements were executed in accordance with Federal 

regulations, (2) West Warwick officials established adequate controls over the Housing Choice Voucher and public 

housing programs to ensure compliance with HUD regulations, and (3) purchases and inventory were reasonable 

and adequately supported. 

West Warwick’s procurements did not comply with Federal requirements. Thirteen procurements totaling more 

than $2 million had deficiencies, including no independent cost estimates, no contracts, no record of bids or requests 

for proposals, no price evaluations, no completion certifications, and only one notice to proceed. In addition, its 

credit card charges and petty cash purchases were not supported, and its assets were not protected. 

OIG recommended that HUD require West Warwick to (1) provide support for procurements or repay HUD from 

non-Federal funds, (2) develop and implement controls over its procurement process, (3) develop and implement 

policies and procedures for the Housing Choice Voucher and public housing programs, (4) provide support for 

nearly $19,000 in credit card charges or repay HUD from non-Federal funds, (5) provide support for nearly $5,000 

in petty cash purchases or repay HUD from non-Federal funds, and (6) develop and maintain property records and 

conduct an inventory in accordance with Federal regulations. (Audit Report: 2017-BO-1006) 

HUD OIG audited the Housing Choice Voucher program of the Menard County Housing Authority in Petersburg, 

IL, to determine whether the Authority complied with its own and HUD’s requirements regarding the 

administration of the Authority’s program. 

The Authority did not comply with HUD’s conflict-of-interest requirements. Specifically, it failed to obtain the 

services of a HUD-approved independent third party to perform housing quality standards inspections for units 

owned by entities it substantially controlled. As a result, it paid nearly $303,000 in housing assistance for ineligible 

units and could not support the eligibility of nearly $340,000 in housing assistance payments to the entities. In 

addition, it inappropriately paid nearly $8,000 in program funds and could not support the eligibility of more than 

$18,000 in program funds paid to a contractor for housing quality standards inspection services.

The Authority failed to comply with its own and HUD’s requirements for the Authority’s program. Specifically, it 

did not correctly calculate housing assistance payments and ensure that households resided in affordable units. It 

also failed to issue appropriate voucher sizes based on family composition and appropriately apply payment 

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standards and utility allowances for its program households. As a result, it (1) overpaid nearly $103,000, (2) 

underpaid nearly $9,000, and (3) lacked support for nearly $3,000 in housing assistance. In addition, the 

Authority’s program households contributed more than $3,000 in excess rental payments. 

OIG recommended that HUD require the Authority to (1) reimburse its program nearly $415,000 from non-Federal 

funds for the ineligible payments; (2) seek retroactive approval or reimburse its program nearly $361,000 from nonFederal funds for the inappropriate, overpaid, and unsupported payments; (3) reimburse its program households 

nearly $12,000 from non-Federal funds; and (4) implement adequate procedures and controls to address the findings 

cited. (Audit Report: 2017-CH-1007) 

HUD OIG audited the Housing Choice Voucher program of the Youngstown Metropolitan Housing Authority in 

Youngstown, OH, to determine whether the Authority appropriately managed its Family Self-Sufficiency program 

and Housing Choice Voucher program files in accordance with HUD’s and its own requirements.

The Authority failed to appropriately manage its Family Self-Sufficiency program. As a result, HUD and the 

Authority lacked assurance that (1) program participants benefited from the program or made progress toward selfsufficiency, (2) escrow balances and monthly escrow deposits totaling nearly $60,000 in HUD’s and its own 

systems were accurate and reliable, and (3) more than $400,000 in coordinator grant funds and escrow 

disbursements were used appropriately. In addition, it inappropriately disbursed more than $23,000 in program 

funds for ineligible program graduates. If the Authority does not develop and implement adequate procedures and 

controls for its program, it could inappropriately use nearly $128,000 in coordinator grant funds over the next year. 

Further, the Authority did not always comply with HUD’s and its own requirements for its Housing Choice Voucher 

program. Specifically, it did not always correctly calculate and support housing assistance payments and perform 

household reexaminations in a timely manner. As a result, the Authority inappropriately paid nearly $32,000 in 

ineligible housing assistance and had nearly $2,000 in unsupported housing assistance payments. If the Authority 

does not correct its certification process, it could overpay nearly $323,000 in housing assistance over the next year.

OIG recommended that HUD require the Authority to (1) support or reimburse its programs from non-Federal funds 

for escrow calculations and disbursements, coordinator grant funds, and housing assistance payments; (2) reimburse 

its programs from non-Federal funds for the ineligible escrow disbursements and housing assistance payments; (3) 

ensure that program funds are used effectively; and (4) implement adequate procedures and controls to correct the 

findings cited. (Audit Report: 2017-CH-1002) 

REVIEW OF HUD’S REQUIRED CONVERSION PROGRAM

HUD OIG audited HUD’s required conversion program activities to determine whether HUD ensured that PHAs 

properly evaluated their distressed units and converted them to tenant-based rental assistance programs.

HUD did not adequately implement its required conversion program. Specifically, it did not properly identify 

potential projects requiring conversion and did not follow up to ensure that PHAs took action by conducting proper 

analyses to determine whether listed projects should be converted to tenant-based rental assistance. HUD also did 

not apply available remedies when PHAs did not properly identify projects or implement required conversions. As 

a result, HUD did not require PHAs to identify and convert distressed projects, and more than $75 million in 

operating subsidies and capital funds could continue to be spent on projects that have not been determined to be 

physically viable or less expensive than tenant-based rental assistance.

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OIG recommended that HUD develop and implement policies and procedures to identify potentially distressed 

projects and monitor and enforce the required conversion program. Additionally, OIG recommended that HUD 

determine whether nine PHAs provided appropriate documentation to support whether potentially distressed 

projects should be converted to tenant-based rental assistance. If the conversion is required, it should be 

accomplished in a timely manner, thereby ensuring that more than $75 million is used effectively for projects that 

are cost effective and have long-term viability and that tenants receive other rental assistance. (Audit Report: 2017-

NY-0001) 

REVIEW OF HUD’S FLAT RENT REQUIREMENTS

HUD OIG audited PHA compliance with HUD’s flat rent requirements to determine whether PHAs complied with 

these requirements.

PHAs did not properly implement HUD’s flat rent requirements for more than half of the flat rent tenants reviewed. 

They undercharged flat rents for 18 of 60 statistically sampled tenants, which projects to a total of 10,119 

undercharged flat rent tenants. Additional PHAs used the incorrect methodology to calculate flat rents for 10 

tenants but complied with the minimum requirements, and 4 others incorrectly calculated flat rents but were correct 

for the sampled tenant during December 2016. As a result, PHAs undercharged flat rent tenants by more than 

$527,000 nationwide during December 2016 and could undercharge flat rent tenants by more than $6.3 million 

during the next year if HUD does not correct this problem. PHAs could also improperly collect increased operating 

subsidies from HUD. 

OIG recommended that HUD finalize and implement monitoring procedures to ensure that more than $6.3 million is 

put to better use over the next year. OIG also recommended that HUD clarify guidance to enhance PHAs’ 

understanding of the requirement and follow up with the PHAs sampled to ensure that their rents have been properly 

adjusted. (Audit Report: 2017-KC-0007) 

REVIEW OF HUD’S VARIOUS PUBLIC HOUSING PROGRAMS

HUD OIG audited the public housing and Housing Choice Voucher programs at the Housing Authority of the City 

of Hartford, CT, to determine whether the Authority complied with HUD and Federal procurement requirements 

and the Authority’s procurement policy. 

Authority officials did not always (1) comply with HUD and Federal procurement requirements and their 

procurement policy and (2) ensure that costs did not exceed contract terms. As a result, they paid more than $2.5 

million in unsupported costs and more than $1.5 million in ineligible costs and may pay more than $1.6 million in 

additional funds that may not have been properly awarded. 

OIG recommended that HUD require Authority officials to (1) support that program funds paid were reasonable and 

allowable or repay the unsupported amount from non-Federal funds, (2) repay from non-Federal sources the 

ineligible funds paid when costs exceeded contract terms and were paid on expired contracts, (3) determine that 

additional funds not yet spent on contracts are reasonable and allowable or reallocate the funds to the appropriate 

programs and reprocure the services as necessary, and (4) strengthen internal controls and procedures for 

procurement and establish effective systems for contract administration. (Audit Report: 2017-BO-1007) 

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HUD OIG audited the New Brunswick Housing Authority in New Brunswick, NJ, to determine whether the 

Authority administered its operating and capital funds in accordance with HUD requirements. 

The Authority did not always administer its operating and capital funds in accordance with HUD requirements. 

Specifically, it (1) did not properly procure goods and services totaling more than $1 million; (2) did not support 

more than $187,000 in capital fund obligations; (3) did not meet obligation deadlines for more than $704,000 in 

replacement housing factor funds and disbursed more than $139,000 after the expenditure deadline; (4) charged its 

project more than $87,000 in excessive management fees; and (5) did not ensure that its budget, financial reports, 

and accounting data were accurate and up to date. As a result, HUD did not have assurance that the prices paid for 

capital improvements and professional services were reasonable, capital funds were used for eligible activities in a 

timely manner, operating funds were available for the operations of the Authority’s project, and it had accurate 

information for evaluating the Authority. 

OIG recommended that HUD require the Authority to (1) provide documentation to show that funds paid for goods 

and services were reasonable; (2) provide procurement training to its staff; (3) provide documentation to support 

2013 and 2014 capital fund obligations; (4) reimburse HUD for replacement housing factor funds disbursed after the 

expenditure deadline; (5) improve its controls to ensure that funds are obligated and spent in a timely manner; (6) 

reimburse its project for excessive management fees; (7) submit a request to revise its budget to reflect 

expenditures; and (8) improve its controls to ensure that its budget, financial reports, and accounting data are 

accurate and up to date. Further, OIG recommended that HUD reduce the Authority’s future capital funds as a 

penalty for obligating its replacement housing factor funds after the deadline. (Audit Report: 2017-NY-1013) 

HUD OIG audited Majestic Management, LLC, in St Louis, MO, regarding its management agent activities for the 

public housing program at the East St. Louis Housing Authority to determine whether Majestic Management made 

only eligible and supported payments for payroll, complied with procurement requirements, and properly performed 

initial tenant certifications and annual tenant recertifications.

Majestic Management improperly charged payroll costs to the projects. It transferred more money from the projects 

to itself than was needed to fund payroll, paid employees who were not dedicated solely to Authority operations 

without adequate documentation, improperly paid its employees bonuses, improperly accrued and paid employees 

for leave time, and paid employees while they were suspended without pay. In addition, Majestic Management did 

not comply with procurement requirements. It did not obtain price quotes or maintain adequate records and 

improperly used companies owned by employees or their spouses. As a result, it deprived projects of nearly 

$110,000 in operating subsidies needed to run the projects, and HUD and the Authority had no assurance that the 

projects benefited from more than $1 million spent without adequate support. Further, Majestic Management did 

not properly perform initial tenant certifications and annual recertifications. 

OIG recommended that HUD require the Authority and Majestic Management to support or reimburse the projects 

for the unsupported payroll costs and improper procurements, reimburse the projects for ineligible payroll costs, and 

recompute the tenant rent for the households with exceptions. OIG also recommended that Majestic Management 

be required to improve its controls, train its staff, and repay excessive annual leave. (Audit Report: 2017-KC1003) 

HUD OIG audited the Chukchansi Indian Housing Authority in Oakhurst, CA, regarding its Indian Housing Block 

Grant program to determine whether the Authority accurately reported and supported its tribal enrollment numbers 

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as required by HUD. In addition, OIG wanted to determine whether the Authority administered its program funds 

in accordance with HUD rules and requirements.

The Authority overstated its tribal enrollment numbers on HUD’s formula response form used for its 2015 and 2016 

program funding. In addition, the Authority did not always adequately support the eligibility of program funds 

spent and did not process program expenses with complete documentation in accordance with HUD’s and its own 

rules and requirements. As a result, it received more than $248,000 in excess program funds, awarded more than 

$1.7 million in program funds that could not be verified, and spent more than $500 in program funds without proper 

supporting documentation. 

OIG recommended that HUD recapture the excess program funds from the Authority and require the Authority to 

ensure the accuracy of and support the tribal enrollment numbers in 2015 and 2016 for the unsupported program 

funds. In addition, HUD should require the Authority to (1) establish and implement formal written policies and 

procedures to document the process for obtaining and verifying tribal enrollment numbers, (2) support the eligibility 

of the unsupported costs or repay the program using non-Federal funds, and (3) implement controls to ensure that all 

required documentation for future program expenses is complete. (Audit Report: 2017-LA-1007) 

REVIEW OF HUD’S RENTAL ASSISTANCE DEMONSTRATION PROGRAM 

HUD OIG audited the Lexington Housing Authority in Lexington, NC, regarding its Rental Assistance 

Demonstration program (RAD) conversion to determine whether the Authority administered its program in 

accordance with HUD requirements. Specifically, OIG focused on whether the Authority (1) maintained adequate 

financial records, (2) completed timely annual audits, (3) established a waiting list, and (4) ensured that tenants were 

properly certified. 

The Authority did not maintain auditable books and records, complete timely annual audits, properly establish 

waiting lists, and ensure that tenants were certified and eligible for RAD project-based voucher assistance. As a 

result, the Authority disbursed more than $2.7 million that was not properly supported and spent more than $5,900 

on improper RAD project-based voucher assistance.

OIG recommended that HUD require the Authority to (1) provide documentation for costs or repay the unsupported 

costs from non-Federal funds, (2) ensure that the Authority completes all outstanding annual audits, (3) repay from 

non-Federal funds the ineligible RAD rehabilitation assistance expenditures, (4) develop and implement adequate 

procedures to ensure that its books and records are properly maintained, and (5) properly certify all tenants and 

reimburse any overages paid. (Audit Report: 2017-AT-1011) 

HUD OIG audited the Housing Authority of DeKalb County in Decatur, GA, regarding its RAD conversion and 

Public Housing Capital Fund program to determine whether the Authority properly administered its RAD 

conversion and obligated and authorized capital funds in accordance with HUD requirements. 

The Authority generally administered its RAD conversion in accordance with HUD’s requirements for written 

agreements, project financing sources, reporting of financial data, the expenditure of HUD funding, tenant 

occupancy, the calculation of contract rents, and physical conditions assessments. However, it failed to accurately 

report on the obligation and authorization of its capital funds. Specifically, it inaccurately reported its fiscal year 

2015 capital funds as obligated when binding agreements were not executed and caused some of its fiscal year 2016 

capital funds to be authorized for a previously completed activity. As a result, more than $940,000 in capital funds 

was improperly obligated and authorized. 

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OIG recommended that HUD require the Authority to (1) deobligate more than $542,000 in capital funds until 

binding agreements are executed and reclassify more than $398,000 in capital funds for eligible and reasonable 

activities or coordinate with HUD to terminate its capital funds, including more than $217,000 of its current 

allocation; (2) provide adequate training to its staff; and (3) develop and implement adequate procedures and 

controls to ensure accurate reporting on capital funds. In addition, OIG recommended that the Authority confirm 

that the replacement of program units was appropriate for the number of units demolished at Johnson Ferry East and 

submit a development proposal to construct new public housing units, transfer public housing assistance to another 

PHA, or terminate its annual contributions contract and return all unobligated and unspent capital funds to HUD. 

(Audit Report: 2017-AT-1006) 

INVESTIGATION

Program results

Administrative - civil actions 61 

Convictions - pleas - pretrial diversions 61 

Financial recoveries $5,212,920 

TAX PREPARER SENTENCED TO 7 YEARS IN PRISON

A tax preparer was sentenced in U.S. District Court for her role in fraudulently purchasing properties and renting 

them out under the Section 8 program. The tax preparer was sentenced to 7 years in prison and ordered to pay 

$228,727 in restitution, $107,194 of which is to be paid to a PHA. The fraudster purchased eight single-family 

residences using the name of her mother or an associate. She subsequently rented these properties to tenants 

through the PHA’s Housing Choice Voucher program while reporting that her mother was the Section 8 landlord for 

these properties. In addition, the tax preparer used her Section 8 tenants’ names and Social Security numbers to file

false tax returns to fraudulently receive earned income credit payments. HUD OIG and Internal Revenue Service 

Criminal Investigation (IRS CI) conducted this investigation. (San Diego, CA)

EXECUTIVE DIRECTOR AND SPOUSE SENTENCED FOR KICKBACK SCHEME

A former PHA executive director and her spouse, a PHA maintenance supervisor, were sentenced in U.S. District 

Court in relation to their earlier guilty pleas to bank fraud and money laundering. The couple solicited and accepted 

bribes and kickbacks from local contractors, used PHA funds to pay for work at their personal residence, and used 

the PHA credit cards for personal gain. The executive director was sentenced to 37 months in prison, while the 

maintenance supervisor was sentenced to 24 months in prison. The couple agreed to forfeit $732,177 previously 

seized by the U.S. Government. HUD OIG and IRS CI conducted this investigation. (Little Rock, AR) 

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CHAPTER 4 – MULTIFAMILY HOUSING AND OFFICE OF 

HEALTHCARE PROGRAMS

In addition to multifamily housing developments and Office of Healthcare Programs properties with U.S. 

Department of Housing and Urban Development (HUD)-held or HUD-insured mortgages, HUD subsidizes rents 

for low-income households, finances the construction or rehabilitation of rental housing, and provides support 

services for the elderly and disabled. Some of the highlights from this semiannual period are shown below. 

AUDIT

Strategic Initiative 2: Contribute to the reduction of erroneous payments in rental 

assistance

Key program results Questioned costs Funds put to better use

Audit 10 audits $8,067,927 $23,759,934 

REVIEW OF HUD’S MULTIFAMILY SECTION 8 PROGRAM 

HUD’s Office of Inspector General (OIG) audited HUD’s Office of Multifamily Housing Programs to determine 

whether owners of cooperative housing properties charged more for their Section 8 units than for their non-Section 

8 units. 

Owners of cooperative housing properties generally charged more for their Section 8 units than for their nonSection 8 units. As a result, in 2016, 25 properties received a taxpayer-funded windfall of more than $3.1 million 

for their unsubsidized members. 

OIG recommended that HUD create and implement policies and procedures or change program regulations to 

prevent multifamily housing properties from charging more for Section 8 units than for comparable non-Section 8 

units. (Audit Report: 2017-KC-0005) 

HUD OIG audited the multifamily project-based Section 8 program at the Beverly Place Apartments in Groves, 

TX, to determine whether the owner administered its project-based Section 8 program in accordance with HUD 

regulations and guidance. 

The owner did not administer the project-based Section 8 program at Beverly Place in accordance with HUD 

regulations. It assisted at least 97 tenants who were either ineligible for assistance or whose eligibility could not be 

supported. As a result, HUD paid the owner more than $574,000 in subsidies for ineligible tenants and incurred 

more than $227,000 in subsidies for which the owner could not support the tenants’ subsidy amounts. 

OIG recommended that HUD require the Beverly Place owner to (1) repay HUD more than $574,000 for housing 

subsidies received for ineligible tenants and (2) support or repay HUD more than $227,000 for units for which 

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managers either did not have a tenant file or did not obtain required earned income verification reports to verify 

eligibility. In addition, HUD should require its contract administrator for Beverly Place to ensure that the owner’s 

recently implemented quality control program is working as designed. (Audit Report: 2017-FW-1009) 

REVIEW OF OFFICE OF HEALTHCARE PROGRAMS

HUD OIG audited Mary Scott Nursing Center in Dayton, OH, to determine whether the project’s owner and 

management agents operated the project in accordance with HUD’s requirements and the regulatory agreement.

The owner and management agents used project funds for ineligible expenses and did not provide sufficient 

documentation to support that project funds were used for eligible, reasonable operating expenses or necessary 

repairs of the project. Further, the owner and management agents (1) did not ensure that rental revenue was 

collected for the residents, (2) could not provide sufficient documentation to support that the owner received market 

value for the sale of the operating rights for 10 licensed beds, and (3) were unable to provide documentation to 

support that the owner received approval from HUD before entering into agreements with the management agents. 

In addition, the owner did not make payments on the project’s mortgage in a timely manner. As a result, nearly 

$550,000 in project funds was not available for reasonable or necessary project operations and debt service, HUD 

and the owner lacked assurance that nearly $261,000 in project funds was used for eligible, reasonable operating 

expenses or necessary repairs of the project, and the owner did not receive nearly $391,000 in rental revenue. 

Further, HUD is at risk of paying a claim of nearly $1.6 million on the mortgage. 

OIG recommended that HUD require the owner to (1) reimburse the project from nonproject funds for inappropriate 

disbursements and disposal of resident charges, (2) support disbursements or reimburse the project from nonproject 

funds, and (3) implement adequate procedures and controls to address the weaknesses cited. OIG also 

recommended that HUD work with the owner to develop an action plan to prevent a claim on the mortgage. (Audit 

Report: 2017-CH-1009) 

HUD OIG audited Cypress Meadows Assisted Living in Antioch, CA, to determine whether Cypress Meadows was 

managed in accordance with its regulatory and operating agreements and HUD requirements. 

Cypress Meadows was not administered in accordance with its regulatory and operating agreements and HUD 

requirements. It disbursed nearly $479,000 for ineligible expenses, was unable to support more than $65,000 in 

expenses, and recorded project debt liabilities of nearly $413,000 for ineligible expenses. Also, Cypress Meadows 

did not collect nearly $621,000 in rent from residents and did not deposit more than $163,000 in lease agreement 

charges into its bank account. In addition, Cypress Meadows did not make payments on its mortgage and was $2.8 

million delinquent on its Federal Housing Administration-insured loan.

OIG recommended that HUD pursue civil and administrative remedies against the owner and operator of Cypress 

Meadows and require Cypress Meadows to (1) repay nearly $544,000 for ineligible and unsupported expenses, (2) 

remove nearly $413,000 in improper accrued debt, (3) pay nearly $621,000 in uncollected rent, (4) pay more than 

$162,000 in lease agreement charges not deposited, (5) replace Skyline Crest Enterprises as the operator, and (6) 

develop written policies and procedures including financial policies for cash disbursements and cash receipts. 

(Audit Report: 2017-LA-1004) 

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REVIEW OF MULTIFAMILY PROPERTIES

HUD OIG audited HUD’s resident home-ownership program grant for Lakeview East Cooperative (project) in 

Chicago, IL, to determine whether the Lakeview East Cooperative (Cooperative) and management agent operated 

the project in accordance with HUD’s requirements and HUD’s grant agreement with the 707 Tenants’ Association.

The Cooperative and management agent did not operate the project in accordance with HUD’s requirements and the 

grant agreement. The Cooperative and management agent did not determine the fair market value of memberships 

to support that members did not pay more than the fair market value for their memberships and HUD’s secured 

interest in the memberships was appropriately valued. Further, they could not provide sufficient documentation to 

support that (1) the payments to HUD from initial membership sales were accurate, (2) the Cooperative used its 

share of the proceeds from initial membership sales in accordance with the grant agreement, and (3) housing was 

affordable for all members. In addition, they did not ensure compliance with other requirements of the program. As 

a result, the Cooperative is at risk of having to reimburse HUD more than $18.1 million. 

OIG recommended that HUD require the Cooperative to resolve the issues and implement adequate procedures and 

controls to address the weaknesses cited and make a preliminary determination as to whether the Cooperative is in 

default of the grant agreement. (Audit Report: 2017-CH-1006) 

HUD OIG audited Schwenckfeld Manor in Lansdale, PA, to determine whether the project owner (1) disbursed 

project funds for costs that were reasonable, necessary, and supported for the operation and maintenance of the 

project and (2) properly disclosed identity-of-interest relationships.

The owner of Schwenckfeld Manor (1) may not have disbursed project funds for costs that were supported as 

reasonable and necessary for the operation and maintenance of the project and (2) did not disclose its identity-ofinterest relationships to HUD. Specifically, the owner (1) used project funds to pay nearly $2.1 million in costs that 

may have been for its parent company’s benefit and the benefit of five other non-HUD housing entities the parent 

company owned and (2) did not disclose to HUD its related parties as identity-of-interest entities on its management 

certification and paid nearly $403,000 in management fees to its parent company instead of the approved 

management agent for the project. 

OIG recommended that HUD require the owner to (1) provide documentation to show that payroll and other direct 

costs were reasonable and necessary expenses for the operation of the project or repay the project from nonproject 

funds for any amount that it cannot support; (2) develop and implement controls to ensure that the project complies 

with the regulatory agreement and applicable HUD requirements; (3) submit a project owner’s and management 

agent’s certification for identity-of-interest agents and other required documentation for review and approval; and 

(4) request retroactive approval of the management fees paid to the parent company and if HUD does not approve

the request, repay the project from nonproject funds the amount not approved by HUD. OIG also recommended

that HUD pursue civil money penalties and administrative sanctions, as appropriate, against the owner and its parent

company and their principals for their part in the violations cited. (Audit Report: 2017-PH-1006)

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HUD OIG audited the Yorkville Cooperative in Fairfax, VA, regarding the administration of its HUD-insured 

property and housing assistance contract to determine whether the Cooperative administered its HUD-insured 

property and housing assistance contract according to applicable requirements.

The Cooperative did not always administer its HUD-insured property and housing assistance contract in accordance 

with its regulatory agreement and applicable HUD requirements. Specifically, it (1) did not always obtain the 

required number of written cost estimates or have documentation to support payments for products and services, 

including maintenance and repair work on units totaling more than $1.8 million, and (2) paid nearly $297,000 for 

prohibited legal services. It also did not ensure that it correctly calculated housing assistance payments.

OIG recommended that HUD direct the Cooperative to (1) provide documentation to support payments totaling 

more than $1.8 million or reimburse the project from nonproject funds for amounts that it cannot support and (2) 

reimburse the project nearly $297,000 from nonproject funds for the ineligible legal expenses. Also, from a 

previous audit report, OIG reopened recommendations that HUD direct the Cooperative to develop and implement 

procedures to ensure that (1) disbursements made from its operating account are for expenses that are reasonable, 

necessary, and in accordance with program requirements and (2) housing assistance payments are correctly 

calculated and supported with the required documentation. (Audit Report: 2017-PH-1003) 

INVESTIGATION

Program results

Administrative - civil actions 5 

Convictions - pleas - pretrial diversions 4 

Financial recoveries $17,809,864 

PROPERTY OWNER AND MANAGER SENTENCED FOR FALSIFYING LOAN APPLICATION

A property owner and a former banking executive were sentenced in U.S. District Court after pleading guilty to

making false statements on a loan application, counterfeit securities, and conspiracy to commit bank fraud. The two 

were sentenced to 1 year and 3 years imprisonment, respectively, and ordered to pay $4.2 million and approximately 

$16 million in restitution, respectively. The property owner is also subject to an $18.2 million forfeiture order. The 

two conspired to submit a fraudulent loan application with false occupancy rosters for a HUD-backed mortgage on a 

multifamily housing development. The subjects used embezzled funds to make it appear that units were rented 

when they were not. After approval of the government-backed mortgage, the development’s attendance continued 

to decline, and the mortgage was conveyed to HUD in default. HUD OIG and the Federal Bureau of Investigation 

conducted this investigation. (Waynesville, MO)

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FIVE SENTENCED FOR RENTAL ASSISTANCE SCHEME

Four property managers and a deputy sheriff were sentenced in U.S. District Court for their role in a fraudulent 

rental assistance scheme. Two of the property managers conspired to enroll tenants into the project-based Section 8 

program without their knowledge to receive HUD rental subsidies. The property managers would either collect full 

rent from the individuals enrolled or would use the victims’ information to subsidize a unit occupied by another, 

paying tenant. The other two property managers at a different multifamily development would keep tenants 

enrolled in the Section 8 program after they had submitted notices to vacate. This enabled the property to continue 

to bill HUD for rental subsidies. The property managers also conspired with the deputy sheriff to cash tenants’ 

utility allowance checks through a business account he controlled. The defendants were sentenced to a cumulative 

total of 102 months imprisonment and ordered to pay a total of $772,085 in restitution. HUD OIG and U.S. 

Department of Homeland Security Investigations conducted this investigation. (Beaumont, TX)

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CHAPTER 5 – COMMUNITY PLANNING AND 

DEVELOPMENT PROGRAM

The Office of Community Planning and Development (CPD) seeks to develop viable communities by promoting 

integrated approaches that provide decent housing, suitable living environments, and expanded economic 

opportunities for low- and moderate-income persons. The primary means toward this end is the development of 

partnerships among all levels of government and the private sector. Some of the highlights from this semiannual 

period are shown below. 

AUDIT

Strategic Initiative 3: Contribute to the strengthening of communities

Key program results Questioned costs Funds put to better use

Audit 32 audits9 $70,635,326 $37,791,931

The U.S. Department of Housing and Urban Development, Office of Inspector General (HUD OIG), audited the 

Section 108 Loan Guarantee program, HOME Investment Partnerships program, Special Project and Neighborhood 

Initiative Congressional Grants, Continuum of Care Program, and Community Development Block Grant (CDBG) 

program. 

SECTION 108 LOAN GUARANTEE PROGRAM

HUD OIG audited HUD’s Section 108 Loan Guarantee program to determine whether HUD had adequate oversight 

of Section 108 loans to ensure that funds were effectively used to meet a CDBG national objective and fully 

provided the intended benefits and that borrowers complied with loan contract provisions. 

HUD’s oversight of Section 108 loans was not adequate to ensure that funds were effectively used to meet program 

objectives and that borrowers complied with loan contract provisions. The Section 108 loans were not routinely 

included in HUD’s annual reviews. Specifically, of 14 loans reviewed, 12 totaling more than $102 million had not 

been monitored. For the 12 loans for which adequate oversight was not provided, 2 loans had not fully met a 

national objective of the CDBG program, 2 loans had unused loan commitments, and the borrower of 1 loan used 

loan funds for an activity that HUD had not approved. As a result, HUD had no assurance that more than $24 

million in Section 108 loans fully provided the intended benefits and met program objectives and that borrowers 

complied with program requirements. 

OIG recommended that HUD (1) determine the eligibility of more than $15.8 million in unsupported Section 108 

fund disbursements for activities that did not meet a national objective; (2) require borrowers to use more than $8.6 

9 The total CPD audits, questioned costs, and funds put to better use amounts include any disaster recovery audits conducted in the 

community planning and development area (nine audits). The writeups for these audits may be shown separately in chapter 6 of 

this report. 

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million in unused commitments to meet program objectives; (3) determine the eligibility of $75,000 disbursed for 

an activity without HUD approval; and (4) improve its monitoring policies, procedures, and tracking systems to 

ensure that borrowers comply with all loan contract provisions and that required documents are submitted. (Audit 

Report: 2017-AT-0001) 

HOME INVESTMENT PARTNERSHIPS

HUD OIG audited the City of New Orleans, LA’s HOME Investment Partnerships program to determine the 

validity of complaint allegations and whether the City administered its HOME program in accordance with Federal 

and HUD requirements.

The complaint had merit as the City did not always properly monitor or administer its HOME program in 

accordance with requirements. For 13 projects reviewed, the City did not ensure that 4 projects had regulatory 

agreements, preventing the City from enforcing the affordability and other program requirements. For the 

remaining nine projects, the City did not always ensure that (1) rents remained within rent limits, (2) it performed 

initial tenant income eligibility certifications, and (3) it conducted property inspections and onsite monitoring visits. 

In addition, the City did not track or accurately report unit vacancies and properly report and use its program 

income. As a result, the City failed to protect more than $7.5 million in HOME funds disbursed; detect nearly 

$83,000 in rent overpayments; ensure that affordable housing was available and offered to low-income households; 

and ensure that program participants lived in decent, safe, and sanitary housing. In addition, the City could not 

provide HUD with reasonable assurance that it properly managed its HOME program, putting available HOME 

funds at risk for mismanagement.

OIG recommended that HUD require the City to develop and implement written procedures and take actions to 

better ensure that it spends more than $9.3 million in available HOME funds. In addition, OIG recommended that 

HUD require the City to (1) repay more than $1.8 million; (2) support or repay more than $5.8 million; and (3) 

develop, implement, and revise its written procedures and management controls. (Audit Report: 2017-FW-1012) 

SPECIAL PROJECT AND NEIGHBORHOOD INITIATIVE CONGRESSIONAL GRANTS

HUD OIG audited HUD’s administration of Economic Development Initiative – Special Project and Neighborhood 

Initiative congressional grants to determine whether HUD administered these congressional grants in accordance 

with its requirements; specifically, whether HUD ensured that grantees executed funded projects in accordance with 

applicable agreements and requirements.

HUD did not ensure that congressional grant funds were administered in accordance with HUD requirements. 

Specifically, it did not always ensure that the accuracy of obligated grants and spent grant funds was supported in 

keeping with HUD requirements and internal policies and procedures. In addition, HUD approved a project that 

was not eligible for program funding. As a result, more than $4.1 million in grant funds was unsupported, and 

$343,000 in grant funds was spent on an ineligible project. 

OIG recommended that HUD (1) support the eligibility of the unsupported costs; (2) require one grantee to repay 

HUD from non-Federal funds for incurred ineligible program costs; and (3) improve its monitoring of congressional 

grants through closeout to ensure compliance with grant agreements, objectives, and policies and procedures. 

(Audit Report: 2017-LA-0006) 

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CONTINUUM OF CARE PROGRAM

HUD OIG audited the Travelers Aid Society of Metropolitan Detroit, MI’s Continuum of Care program to 

determine whether Travelers Aid administered its program in accordance with Federal regulations.

Travelers Aid did not always administer its program in accordance with Federal regulations. Specifically, it did not 

maintain sufficient documentation to support that (1) it met its matching contribution requirement for programfunded projects, (2) program administrative funds were used for eligible administrative expenses associated with the 

project for which the funds were drawn, (3) program income was used for the project that generated it and for 

eligible activities, and (4) program funds were used for eligible project expenses for supportive services and leasing. 

As a result, Travelers Aid is at risk of having to repay HUD more than $2.1 million due to a lack of sufficient 

documentation to support that it complied with Federal regulations regarding match contributions. In addition, 

HUD and Travelers Aid lacked assurance that Travelers Aid used nearly $171,000 in program income 

appropriately. 

OIG recommended that HUD require Travelers Aid to (1) support that it met its matching contribution requirement 

associated with the program funds it drew down for supportive services and administrative expenses or reimburse 

HUD from non-Federal funds as appropriate, (2) support or reimburse HUD from non-Federal funds for the 

program income for which it did not provide sufficient documentation to support that the funds were used for the 

project that generated the income and for eligible activities, and (3) implement adequate procedures and controls to 

address the finding cited. (Audit Report: 2017-CH-1008) 

COMMUNITY DEVELOPMENT BLOCK GRANT

HUD OIG audited the City of Fresno, CA’s CDBG program to determine whether the City administered its CDBG 

funds in accordance with HUD requirements, focusing on code enforcement, antigraffiti, and after school program 

activities; monitoring; and program income. 

The City did not administer its program in accordance with HUD requirements. Specifically it (1) did not meet 

HUD’s code enforcement requirements, (2) spent CDBG funds on general government expenses, (3) did not ensure 

that one program met a CDBG national objective, (4) did not properly monitor its subrecipient or City departments, 

(5) used its entitlement funds before its program income, and (6) did not report program income to HUD in a timely

manner. As a result, it used CDBG funds for nearly $164,000 in ineligible costs and more than $7.9 million in

unsupported costs and put more than $428,000 at risk of similar questionable use over the next year.

OIG recommended that HUD require the City to (1) repay the program from non-Federal funds for the ineligible 

costs; (2) support the eligibility of the unsupported costs or repay the program from non-Federal funds; (3) suspend 

funding to its code enforcement program until it can show that it has implemented controls, addressed its capacity 

issues, and understands and abides by HUD requirements; (4) implement policies and procedures to ensure that 

CDBG funds are used in accordance with program requirements; and (5) provide training. (Audit Report: 2017-

LA-1006) 

HUD OIG audited Clark County, NV’s CDBG program to determine whether Clark County followed procurement 

requirements, ensured that CDBG projects met national objectives, and spent CDBG funds on eligible expenses. 

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Clark County did not have appropriate controls to ensure that it used CDBG funds in accordance with HUD 

requirements. Specifically, it (1) did not ensure that it followed HUD procurement requirements, (2) did not ensure 

that one project met a CDBG national objective, and (3) spent CDBG funds on general government expenses. As a 

result, it used CDBG funds for nearly $120,000 in ineligible costs and more than $4.8 million in unsupported costs 

and budgeted an additional nearly $34,000 for an ineligible CDBG activity. 

OIG recommended that HUD require Clark County to (1) repay the program nearly $120,000 for ineligible costs, 

(2) support the eligibility of more than $4.8 million, (3) reallocate nearly $34,000 to an eligible CBDG activity, (4) 

provide proof that the Americans with Disabilities Act (ADA) pool project meets ADA requirements through a third 

party or make the pool ADA compliant, (5) update its policies and procedures for monitoring procurement and 

contracting, and (6) provide training to its staff on program requirements. (Audit Report: 2017-LA-1001) 

HUD OIG audited the City of Albuquerque, NM’s CDBG program to determine whether the City administered its 

CDBG program in accordance with HUD requirements.

The City did not always properly administer and adequately document its CDBG program activities in accordance 

with HUD requirements. Specifically, it did not always follow procurement and conflict-of-interest requirements 

and did not ensure that executed written agreements included the required language. It did not comply with 

environmental reviews of its projects as the environmental records were not completed correctly and lacked 

supporting documentation. In addition, it did not ensure that expenditures were reasonable, eligible, and adequately 

supported as it exceeded allowed residential rehabilitation limits, did not reconcile its timesheet activities, and failed 

to follow Federal travel regulations. Further, it did not maintain documentation supporting that its projects met a 

national objective and did not adequately monitor or report on its subrecipients’ results. As a result, it incurred 

grant costs of more than $2.9 million that were ineligible or unsupported and decreased the effectiveness of the 

CDBG program.

OIG recommended that HUD extend the City’s high-risk grantee designation until the City can show that it has 

implemented an effective program in compliance with all requirements and has repaid the nearly $1.84 million in 

ineligible costs and supported nearly $1.07 million in unsupported costs. (Audit Report: 2017-FW-1010) 

HUD OIG audited the City of Huntington Park, CA’s CDBG program to determine whether the City administered 

its CDBG funds in accordance with HUD requirements, focusing on grant expenditures and procurement. 

The City did not administer its program in accordance with HUD requirements. Specifically, it did not (1) meet 

HUD’s code enforcement requirements, (2) follow its own or HUD’s procurement procedures, (3) properly support 

its cost allocations, and (4) ensure that one project met the CDBG national objective. Overall, this activity resulted 

in the City’s spending more than $7,000 on ineligible costs, not being able to support its use of nearly $814,000, and 

putting nearly $329,000 in CDBG funds at risk for similar questionable use. 

OIG recommended that HUD require the City to (1) repay the program more than $7,000 from non-Federal funds, 

(2) support the eligibility of nearly $814,000 in CDBG costs, (3) implement policies and procedures to ensure that 

nearly $329,000 in CDBG funds is used in accordance with program requirements, and (4) provide training or 

obtain technical assistance on CDBG program requirements. (Audit Report: 2017-LA-1005) 

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HUD OIG audited HUD’s oversight of the disposition of real properties assisted with CDBG funds to determine 

whether HUD had adequate controls over the disposition of real properties assisted with CDBG funds. 

HUD could improve its oversight of the disposition of real properties assisted with CDBG funds. Although HUD’s 

drawdown and reporting system allowed grantees to enter identifying information for assisted properties and its 

field offices performed risk-based monitoring of grantees, HUD’s controls were not always sufficient to ensure that 

grantees (1) entered addresses of assisted properties into its system, (2) provided proper notice to affected citizens 

before changing the use of assisted properties, (3) adequately determined the fair market value of assisted properties 

at the time of disposition, and (4) properly reported program income from the disposition of the properties. Further, 

HUD did not fully implement guidance related to the applicability of change of use requirements after voluntary 

grant reductions. As a result, HUD could not track and monitor its interest in the properties and did not have 

assurance that grantees properly handled changes in use and properly reported program income.

OIG recommended that HUD (1) issue guidance reminding grantees of the requirements to report address 

information for assisted properties and calculate and report program income related to the disposition of these 

properties; (2) develop a process to ensure that grantees properly report address information and properly calculate 

and report program income; (3) require three grantees to provide documentation showing that affected citizens were 

notified of a change in use of the property for one activity, the fair market value of properties for two activities was 

supported, and program income for three activities was properly calculated and reported; (4) document the 

applicability of change of use requirements for one grantee; and (5) issue guidance to clarify the applicability of 

change of use requirements after voluntary grant reductions. (Audit Report: 2017-NY-0002) 

HUD OIG audited the Office of the Commissioner for Municipal Affairs’ (OCMA) Puerto Rico State CDBG 

program to determine whether OCMA effectively used State CDBG funds on a fine arts center that met a national 

objective of the program and fully provided the intended benefits. 

OCMA did not ensure that State CDBG funds used for the construction of San Sebastian’s fine arts center project 

provided the intended benefits and met a national objective of the program. Although the construction of the project 

began in 1996, the contractor filed for bankruptcy and was not able to finish the project. The bonding company 

took over the construction of the arts center, but the Municipality did not accept the project because of construction 

defects. As of March 2017, the project was abandoned and incomplete. As a result, more than $1 million in State 

CDBG funds was not effectively used to meet program objectives.

OIG recommended that HUD (1) reevaluate the feasibility of the project to determine the eligibility of the State 

CDBG funds disbursed and (2) instruct the Office for the Socioeconomic and Community Development to submit a 

plan for how it will proceed with the fine arts center project. (Audit Memorandum: 2017-AT-1802) 

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INVESTIGATION

Program results

Administrative - civil actions 10 

Convictions - pleas - pretrial diversions 9 

Financial recoveries $2,709,357 

SIX SENTENCED FOR KICKBACK SCHEME

The former executive director, an employee, and multiple contractors for a city development organization were 

sentenced in U.S. District Court for their role in a kickback scheme involving HUD CDBG funds. Collectively, the 

six fraudsters were sentenced to more than 20 years imprisonment and ordered to pay back $999,683 to the 

development organization. The executive director, along with other conspirators, engaged in a scheme to defraud 

the development company by accepting bribes and kickbacks from contractors and an employee based on 

fraudulently inflated invoices or being awarded work that was not performed. HUD OIG, the Federal Bureau of 

Investigation, the Social Security Administration OIG, Internal Revenue Service Criminal Investigation, and the 

U.S. Attorney’s Office conducted this investigation. (Newark, NJ) 

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CHAPTER 6 – DISASTER RECOVERY PROGRAMS 

In response to disasters, Congress may appropriate additional funding as Disaster Recovery grants to rebuild the 

affected areas and provide crucial seed money to start the recovery process. Since fiscal year 1993, Congress has 

appropriated $49.2 billion to the U.S. Department of Housing and Urban Development (HUD), from which HUD 

provides flexible grants to help cities, counties, and States recover from presidentially declared disasters. Of the 

$48 billion in active disaster grants, the funds have been allocated nationwide, with nearly $47.7 billion obligated 

and $36.3 billion disbursed as of September 30, 2017. 

Disaster Funds 

allocated Funds disbursed Percentage of funds disbursed

Fiscal year funds 

allocated 

Louisiana, Texas & 

West VA $2.9 billion $61.2 million 2 2016 

Hurricane Sandy 15.1 billion 8.1 billion 54 2013 

Hurricanes Ike, 

Gustav & Dolly 6.1 billion 5.3 billion 86 2008 

Hurricanes Katrina, 

Rita & Wilma 19.7 billion 19.2 billion 98 2006 & 2008 

9-11 3.5 billion 3.1 billion 90 2001-2002 

Other 799 million 599 million 75 Various

Keeping up with communities in the recovery process can be a challenging position for HUD. HUD’s Office of 

Inspector General (OIG) continues to take steps to ensure that the Department remains diligent in assisting 

communities with their recovery efforts.

AUDIT

Strategic Initiative 3: Contribute to the strengthening of communities

Key program results Questioned costs Funds put to better use

Audit 9 audits10 $20,319,955 $18,182,015 

10 Disaster-related audits consist of community planning and development audits. The questioned costs and funds put to better use 

amounts relate only to disaster-related costs.

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HUD OIG audited the State of New York’s Community Development Block Grant Disaster Recovery (CDBGDR)-funded Non-Federal Share Match Program to determine whether the State used disaster recovery funds under 

its program for eligible and supported costs. 

The State did not show that disaster recovery funds allocated to its program were used only for eligible and 

supported costs. Specifically, it did not maintain sufficient documentation to show that nearly $18.8 million used 

for four of the six activities reviewed was spent for eligible and supported costs. For example, the State’s files did 

not always contain detailed invoices, proper records to support labor costs, and proof of payment. Further, analysis 

of the limited documentation maintained by the State showed that nearly $1.2 million may have been used for 

ineligible transitional shelter assistance payments. As a result, HUD did not have assurance that the funds were 

used as intended to assist storm-impacted entities with the cost share associated with other Federal funds and was 

not used to duplicate other benefits. 

OIG recommended that HUD require the State to (1) provide documentation to show that the disaster recovery 

funds used for the four activities were spent for eligible and supported costs and did not duplicate other benefits or 

repay from non-Federal funds any amount that it cannot support; (2) implement procedures to ensure that remaining 

program costs reimbursed with disaster recovery funds are adequately reviewed for eligibility and support, thereby 

putting nearly $9 million to better use; and (3) provide training to its staff on applicable HUD and Federal 

requirements for eligibility, documentation of costs, and duplication of benefits reviews. (Audit Report: 2017-NY1010) 

HUD OIG audited St. Tammany Parish in Mandeville LA, regarding the administration of its CDBG-DR program 

to determine whether the Parish administered its program in accordance with HUD requirements and in line with its 

certifications to HUD for its procurement; detection of fraud, waste, and abuse; and website maintenance. 

The Parish did not always administer its CDBG-DR program in accordance with HUD requirements and in line with 

its certifications to HUD. Specifically, it did not (1) support that it performed an independent cost estimate and 

adequate cost analyses or maintained complete procurement files; (2) maintain a complete monitoring policy and 

finalize and fully implement its policy to aid in detecting fraud, waste, and abuse or have an internal audit function; 

or (3) include all required information on its public website. As a result, the Parish (1) could not provide reasonable 

assurance to HUD that it would properly administer, adequately safeguard, and spend its nearly $8.68 million in 

CDBG-DR funds in accordance with requirements and (2) paid more than $400,000 in questioned costs. 

OIG recommended that HUD require the Parish to develop and implement written procedures and take actions that 

would correct and prevent the deficiencies to better ensure that the Parish spends its nearly $8.68 million in 

accordance with program requirements. In addition, OIG recommended that HUD require the Parish to (1) support 

or repay nearly $452,000, (2) implement an internal audit function, (3) update its website, (4) fully implement or 

revise its policies to reflect current procedures, and (5) obtain additional technical assistance from HUD regarding 

meeting program requirements. (Audit Report: 2017-FW-1004) 

HUD OIG audited the State of New Jersey’s CDBG-DR-funded Sandy Homebuyer Assistance program to 

determine whether the State disbursed disaster funds for its Sandy Homebuyer Assistance program to assist eligible 

home buyers in accordance with applicable program requirements. 

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The State did not always disburse disaster funds for its program to assist eligible home buyers in accordance with 

applicable program requirements. Of 65 home-buyer files reviewed, 12, with loans totaling $600,000, showed that 

the home buyers did not meet all program eligibility criteria; therefore, $558,000 of the $600,000 disbursed was 

ineligible. The State also disbursed nearly $430,000 to nine home buyers in Atlantic County whose income 

exceeded HUD’s low- and moderate-income limits for 2013. As a result, the State’s use of nearly $1 million in 

program funds to assist 21 home buyers was ineligible because the home buyers did not meet all of the program 

eligibility requirements.

OIG recommended that HUD direct the State to repay HUD from non-Federal funds for the disaster funds disbursed 

to the 21 ineligible home buyers. (Audit Report: 2017-PH-1005) 

HUD OIG audited HUD’s oversight of disaster grantee procurement processes to determine whether HUD provided 

sufficient guidance and oversight to ensure that disaster grantees followed proficient procurement processes when 

purchasing products and services. 

HUD did not provide sufficient guidance and oversight to ensure that State disaster grantees followed proficient 

procurement processes. As a result, HUD lacked assurance that State grantees purchased necessary products and 

services competitively at fair and reasonable prices.

OIG recommended that HUD (1) clarify that if a State receives a disaster recovery grant and chooses to certify that 

its procurement process is equivalent to Federal procurement standards, “equivalent” means that its procurement 

process fully aligns with, or meets the intent of, each of the Federal procurement standards; (2) improve its controls 

to ensure that appropriate staff adequately evaluates the proficiency of State grantee procurement processes for 

States that select the equivalency option; (3) clarify and improve its guidance for State grantees to explain what it 

means to have a procurement process that fully aligns with, or meets the intent of, each of the Federal procurement 

standards; and (4) provide procurement training and technical assistance to State grantees to ensure that they 

understand the intent of each of the Federal procurement standards. (Audit Report: 2017-PH-0002) 

INVESTIGATION

Program results

Administrative - civil actions 0 

Convictions - pleas - pretrial diversions 21 

Financial recoveries $208,538 

FRAUDSTER ORDERED TO REPAY MORE THAN $150,000 IN HURRICANE SANDY FUNDS

A Disaster Recovery grant recipient was sentenced in State Superior Court in connection with his earlier guilty plea 

to theft by deception and unsworn statement falsification. The defendant filed false applications following 

Hurricane Sandy for the Rehabilitation, Reconstruction, Elevation, and Mitigation Program; the Homeowner 

Resettlement Program; and Federal Emergency Management Agency (FEMA) assistance to which he was not 

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entitled. The recipient falsely claimed that the damaged property was his primary residence. The recipient was 

sentenced to 2 years probation and ordered to pay $165,471 in restitution. HUD OIG and the New Jersey Attorney 

General’s Office conducted this investigation. (Point Pleasant Beach, NJ)

DISASTER RECIPIENT SENTENCED IN RENTAL ASSISTANCE FRAUD SCHEME

A recipient of Hurricane Sandy and Hurricane Irene disaster relief funds was sentenced in U.S. District Court to 

serve 1 year of home confinement, 36 months of supervised release, and 100 hours of community service in 

connection with his earlier guilty plea to fraud in connection with a major disaster or emergency benefits. The 

defendant was ordered to pay $62,100 in restitution. The recipient applied for rental assistance from FEMA, 

claiming that as a result of damage done to his home during Hurricanes Irene and Sandy, he was displaced and had 

to seek another residence. In reality, his home was not damaged. In addition, the recipient was a Section 8 tenant 

and as such, received the benefit of Section 8 assistance at the same time he received FEMA funds under its

Housing Assistance Program. HUD OIG and the U.S. Department of Homeland Security OIG conducted this 

investigation. (Spring Valley, NY)

EVALUATION

HUD’S INTERNAL AUDIT REQUIREMENT FOR DISASTER RELIEF APPROPRIATIONS ACT 

OF 2013 GRANTEES

HUD OIG examined whether and to what extent grantees were implementing the Office of Community Planning 

and Development’s (CPD) internal audit requirement. CPD manages disaster grants and provides monitoring and 

technical assistance for grantees to ensure that they comply with HUD and Federal requirements. To ensure that 

grantees perform and deliver on the terms of the disaster grants, CPD requires disaster grantees to establish an 

internal audit activity. Internal auditing is an independent, objective assurance and consulting activity designed to 

add value and improve an organization’s operations. 

OIG found that (1) CPD’s guidance for implementing the internal audit requirement was vague and (2) CPD’s level 

of interaction with disaster grantees concerning the internal audit requirement was inconsistent. OIG recommended 

that CPD provide clearer guidance and instruction to Public Law 113-2 disaster grantees to assist them in 

establishing an effective internal audit activity. Such guidance would benefit future disaster grantees required to 

establish an internal audit activity. OIG also recommended that CPD establish a recurring training and discussion 

forum between the Public Law 113-2 grantees and CPD that enables grantees to share ideas and receive guidance 

and information about CPD’s expectations regarding the internal audit requirement. (Evaluation Report: 2016-OE0011S) 

NAVIGATING THE DISASTER ASSISTANCE PROCESS 

OIG identified challenges that citizens (homeowners and businesses) may encounter as they attempt to navigate the 

process for receiving disaster assistance. The disaster assistance process is an indirect path that is not always seen 

as orderly and systematic for citizens to navigate. The path is not linear, and citizens may start at various points 

within the disaster assistance process. Moreover, citizens may encounter challenges throughout the disaster 

navigation process related to potential duplication of benefits, slow disbursement of disaster funding, and delays in 

funding for low- and moderate-income citizens. (Evaluation Report: 2017-OE-0002S) 

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CHAPTER 7 – OTHER SIGNIFICANT AUDITS AND 

EVALUATIONS 

AUDIT

Strategic Initiative 4: Contribute to improving HUD’s execution of and accountability for 

fiscal responsibilities as a relevant and problem-solving advisor to the Department

Key program results Questioned costs Funds put to better use

Audit 6 audits $1,765,615 $3,247,078 

The U.S. Department of Housing and Urban Development, Office of Inspector General’s (HUD OIG) more 

significant audits are discussed below.

AUDIT OF HUD’S PROCESS FOR FORGIVING DEBTS AND TERMINATING DEBT 

COLLECTIONS

HUD OIG audited HUD’s process for forgiving debts and terminating debt collections to determine whether HUD 

complied with applicable requirements when forgiving debts and terminating debt collections. 

HUD did not always follow applicable statutory, regulatory, and policy requirements when forgiving debts and 

terminating debt collections. Specifically, HUD terminated debt collections and forgave debts without ensuring that 

required collection actions were taken and that U.S. Department of Justice (DOJ) approval was obtained when 

required. As a result, HUD officials stopped debt collections and effectively disposed of government receivables 

totaling nearly $4.5 million without appropriate authorization. 

OIG recommended that HUD (1) take appropriate steps to establish eligibility for collection termination or 

compromise for 10 debts totaling more than $1.2 million and reinstate debts with available means of collections and 

(2) conduct a complete analysis of existing procedures to strengthen controls over debt collection, including HUD’s 

Treasury Reports of Receivables reporting, resulting in funds to be put to better use of more than $3.2 million. 

Controls should include additional procedures for ensuring that DOJ approval is obtained when required, all 

appropriate means of collection have been pursued, and all closed debts are tracked and were properly authorized 

for collection termination or forgiveness. (Audit Report: 2017-LA-0005) 

AUDIT OF THE IMPROPER PAYMENTS ELIMINATION AND RECOVERY ACT OF 2010

HUD OIG audited HUD’s fiscal year 2016 compliance with the Improper Payments Elimination and Recovery Act 

of 2010 (IPERA).

For the fourth consecutive fiscal year, HUD did not comply with IPERA. Of the six compliance determination 

requirements, HUD complied with four and did not comply with the remaining two. HUD also did not comply with 

IPERA in fiscal years 2013, 2014, and 2015. Specific areas of noncompliance for fiscal year 2016 were related to 

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HUD’s failure to (1) conduct an annual risk assessment in accordance with Office of Management and Budget 

(OMB) guidance and (2) meet its annual improper payment reduction target. This was the same issue noted in 

OIG’s fiscal year 2015 audit report. Additionally, OIG again found similar issues in fiscal year 2016 concerning (1) 

the completeness and reliability of HUD’s improper payment data reporting, including payment recapture audit 

plans, and (2) the reliability of HUD’s improper payment estimate for its Rental Housing Assistance Programs.

OIG made five new recommendations to address new issues identified, which should help remediate issues 

identified in HUD’s payment recapture audit plans and reporting of improper payment information in its agency 

financial report. (Audit Report: 2017-FO-0006) 

AUDIT OF HUD’S TRANSITION TO NEW CORE FINANCIAL MANAGEMENT 

HUD OIG audited the functionality of HUD’s New Core Financial Management Solution to determine whether 

effective business processes and interface processing controls were in place for the New Core Financial 

Management Solution. 

Transaction processing using the New Core Financial Management Solution had improved, but challenges and 

weaknesses remained. Specifically, (1) transactions were inaccurately posted to the general ledger, and weaknesses 

still existed with transaction processing; (2) HUD had not completed reconciling the differences between the 

subledgers and the general ledger; and (3) the New Core Interface Solution (NCIS) reconciliation tool was not 

effective. 

OIG recommended that HUD update yearend closing procedures, implement a data validation process for crosswalk 

entries, improve the subledger reconciliation process and resolve unreconciled differences, revise the NCIS 

reconciliation status of funds report, and resolve the data reconciliation differences identified between HUD’s 

Centralized Accounting and Program System and Oracle Financials. (Audit Report: 2017-DP-0003) 

EVALUATION

FEDERAL AUDIT EXECUTIVE COUNCIL IT SUBCOMMITTEE FISMA MATURITY MODEL 

DEVELOPMENT

HUD OIG continued its collaboration with CIGIE and the Federal Audit Executive Council IT Subcommittee by 

participating in the ongoing development of the maturity models for the Federal Information Security 

Modernization Act (FISMA) Inspector General metrics. The maturity models allow OMB to measure and report 

Federal agency cybersecurity more consistently. The maturity models have replaced the Inspector General (IG) 

FISMA metrics for the fiscal year 2017 FISMA assessments of Federal agencies. HUD OIG was one of only a 

handful of IG offices to maintain an ongoing volunteer to help develop and update these models.

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OFFICE OF HEALTHCARE PROGRAMS: THE OFFICE OF RESIDENTIAL CARE FACILITIES’ 

USE OF REAL ESTATE ASSESSMENT CENTER SCORES

A complainant from within HUD stated that some residential care facilities (RCF) had received very low physical 

condition inspection scores. Between June 2016 and March 2017, at least 10 RCFs scored 31 or below, out of a 

possible 100. In response, HUD OIG assessed inspection scores of RCFs and examined how HUD’s Office of 

Residential Care Facilities (ORCF) oversees the physical condition of RCFs.

OIG found that the majority of RCFs that received a score scored at least 80 on their last inspection and only a small 

percentage of RCFs scored below 31. However, OIG noticed an overall decline in Real Estate Assessment Center 

(REAC) inspection scores across ORCF’s portfolio from 2000 to 2016. Additionally, OIG found that inspections of 

RCFs had not always been timely. Finally, OIG found that HUD used a standardized inspection process that did not 

account for unique conditions present in RCFs, particularly window restrictions used for patients with Alzheimer’s 

or dementia. As a result, HUD was deducting points from RCFs that had these safety features and potentially 

instructing these RCFs to remove the safety features.

OIG recommended that ORCF (1) identify and implement a method to ensure that eligible RCFs in its portfolio 

receive database adjustments when appropriate under local code, either by working directly with REAC or by 

instructing RCFs to apply for adjustments themselves, and (2) identify and implement a method that ensures the 

expeditious followup inspections of RCFs that have not been inspected in a timely manner after receiving their last 

below-60 REAC score. Finally, OIG recommended that REAC identify and implement a method to ensure that 

HUD does not instruct facilities to negate safety features. As an interim measure during its fieldwork, OIG issued a 

management alert that also related to these instructions. (Evaluation Report: 2017-OE-0011) 

OFFICE OF FIELD POLICY AND MANAGEMENT: ASSESSING HUD PLANS FOR 

EVALUATING URBAN PROMISE ZONES AND HUD GRANT PROGRAMS PARTICIPATING IN 

THE PROMISE ZONES

HUD OIG assessed the Office of Field Policy and Management’s (OFPM) plans for overseeing the promise zones 

as well as the 11 HUD grant programs participating in the promise zone initiative. This initiative was created by 

OMB in 2014. Promise zones were high poverty communities where the Federal Government partners with local 

leaders to increase economic activity, improve educational opportunities, leverage private investment, reduce 

violent crime, enhance public health, and address other priorities identified by the community. OIG made three 

findings concerning OFPM’s need to evaluate HUD’s implementation of, participation in, and contributions to the 

promise zone initiative. OIG made six recommendations to improve data reporting and evaluation of HUD’s 

implementation of the initiative. (Evaluation Report: 2016-OE-0010) 

MANAGEMENT ASSISTANCE REVIEW

HUD OIG management assistance reviews provide the quality assurance mechanism, which ensures that OIG’s 

audit, evaluation, investigative, administrative, and other operations follow established standards, policies, and 

procedures. Management assistance review reports are issued to OIG management to recommend improvements in 

management and operations. During this 6-month period, OIG reported on the information technology, 

Washington, DC, information security and control activities (Evaluation Report: 2017-OE-MAR4) and the 

Financial Audit Division, Washington, DC, audit activities (Evaluation Report: 2017-OE-MAR6).

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CHAPTER 8 – JOINT CIVIL ACTIONS

In recent years, the U.S. Department of Housing and Urban Development, Office of Inspector General (HUD OIG), 

has enhanced its efforts to identify and investigate civil fraud and pursue civil actions and administrative sanctions, 

frequently combining efforts from its multiple disciplines to create teams of auditors, special agents, attorneys, and 

data analysts to conduct civil investigations. The central hub to these efforts is HUD OIG’s Joint Civil Fraud 

Division, a distinct team of forensic auditors and special agents dedicated to investigating fraud and pursuing civil 

and administrative remedies. 

HUD OIG’s joint civil fraud teams work closely with the U.S. Department of Justice (DOJ), U.S. Attorney’s Offices, 

HUD’s Office of General Counsel, and local prosecutors to pursue civil remedies under a variety of statutes and 

regulations, including the False Claims Act; Program Fraud Civil Remedies Act; and Financial Institutions Reform, 

Recovery, and Enforcement Act. HUD OIG also works with HUD’s Departmental Enforcement Center to pursue 

debarments, suspensions, and limited denials of participation when appropriate. 

HUD OIG’s internal joint efforts, in conjunction with partnerships with other enforcement groups, result in civil 

outcomes that are meant to help HUD recover from unwarranted damages sustained due to fraud. Some of the 

highlights from this semiannual period, resulting from these joint civil fraud efforts, are noted below. 

Strategic Initiative 1: Contribute to the reduction of fraud in single-family insurance 

programs

Program Results

Recoveries and receivables to HUD programs 

or HUD program participants $88,450,000 

Recoveries and receivables for other entities $71,901,944 

Recommendations that funds be put to better 

use

$0 

Civil actions 5 

SINGLE FAMILY

HUD OIG assisted DOJ and the U.S. Attorney’s Offices, District of New Jersey, District of Minnesota, and 

Southern District of Florida, in the civil investigation of PHH Corporation, PHH Mortgage Corporation (PHHMC), 

and PHH Home Loans, LLC (PHHHL), collectively referred to as PHH. PHH was a direct endorsement lender 

having its principal place of business in Mount Laurel, NJ. 

On August 3, 2017, PHH entered into a settlement agreement with the Federal Government to pay $65 million in a 

combined settlement amount. The United States attributed $45.5 million to PHHMC and $19.5 million to PHHHL. 

PHH agreed that it engaged in certain conduct related to Federal Housing Administration (FHA)-insured mortgages 

in connection with PHHMC’s and PHHHL’s origination, underwriting, endorsement, and quality control of singlefamily residential mortgage loans insured by FHA between January 1, 2006, and December 31, 2011, that resulted 

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in claims for payment submitted to FHA on or before June 30, 2013. The settlement agreement was neither an 

admission of liability by PHH nor a concession by the United States that its claims were not well founded. 

As a result of PHH’s conduct and omissions, HUD insured loans approved by PHH that were not eligible for FHA 

mortgage insurance under the direct endorsement program and that HUD would not otherwise have insured. HUD 

incurred substantial losses when it paid insurance claims on these loans. Of the total $65 million settlement, HUD 

FHA will receive $42.6 million. (Memorandum: 2017-CF-1806, Joint Civil Fraud Division and Office of 

Investigation Regions 3, 4, and 5) 

HUD OIG assisted DOJ, Washington, DC, and the U.S. Attorney’s Office for the Middle District of Florida in a 

civil investigation of Financial Freedom Acquisition, a division of CIT Bank, N.A. Financial Freedom was 

originally owned by IndyMac Bank until its failure in 2008, when the Federal Deposit Insurance Corporation was 

appointed as conservator. On March 18, 2009, OneWest Bank, N.A., based in Pasadena, CA, acquired the assets 

of Financial Freedom. On August 3, 2015, CIT Group acquired OneWest Bank, including Financial Freedom. The 

home equity conversion mortgage (HECM) servicing operations for Financial Freedom were located in Austin, TX. 

On May 16, 2017, Financial Freedom entered into a settlement agreement with the Federal Government to pay 

nearly $68.3 million to avoid the delay, uncertainty, inconvenience, and expense of lengthy litigation. Financial 

Freedom also had paid HUD more than $21 million related to the covered conduct through HUD’s Supplemental 

Claims system, for a total settlement value of nearly $89.3 million. The Federal Government alleged that Financial 

Freedom sought to obtain insurance payments for debenture interest from HUD and did not disclose on the 

insurance claim forms that the lender was not eligible for such interest payments. The settlement was neither an 

admission of liability by Financial Freedom nor a concession by the United States that its claims were not well 

founded. 

As a result of Financial Freedom’s conduct, lenders on relevant HECMs obtained additional debenture interest that 

they were not entitled to receive. HUD incurred substantial losses when it paid additional debenture interest on 

HECM claims on the loans covered by the settlement agreement. Of the nearly $89.3 million settlement, FHA 

received $41 million, and the remaining amount was paid to other Federal entities. (Memorandum: 2017-CF-1804,

Office of Investigation Region 6 and Joint Civil Fraud Division)

HUD OIG assisted DOJ, Washington DC, and the U.S. Attorney’s Offices of the Northern District of Georgia and 

Northern District of California in the civil investigation of Prospect Mortgage, LLC, Sherman Oaks, CA. 

Based in part on OIG’s review, the Federal Government alleged that Prospect violated the False Claims Act when it 

originated and underwrote FHA mortgage loans that did not meet applicable requirements. The Federal 

Government also alleged that Prospect did not maintain a quality control program that complied with requirements. 

On June 30, 2017, Prospect entered into a settlement agreement with the Federal Government to pay $4.157 million 

to avoid the delay, uncertainty, inconvenience, and expense of lengthy litigation. Of the total settlement of $4.157 

million, HUD FHA was to receive $2.93 million, and the remaining funds will be paid to other Federal entities. 

(Memorandum: 2017-AT-1801, Office of Audit Region 4, Joint Civil Fraud Division, and Office of Investigation 

Regions 1-2, 4, and 9) 

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HUD OIG assisted DOJ and the U.S. Attorney’s Office for the Southern District of New York in a civil 

investigation of Residential Home Funding Corp. Residential Home is an FHA-approved mortgage lender having 

its principal place of business in White Plains, NY. 

On September 18, 2017, Residential Home entered into a settlement agreement with the Federal Government to pay 

$1.67 million. Residential Home endorsed FHA mortgage insurance loans that did not meet the underwriting 

requirements. Between 2004 and 2012, Residential Home knowingly (1) submitted or caused to be submitted to 

HUD false claims for FHA insurance for loans that were ineligible for FHA insurance, (2) submitted false annual 

certifications to HUD attesting to compliance with direct endorsement program rules, and (3) submitted false 

individual loan certifications to HUD attesting that certain loans were eligible for FHA insurance. Also, Residential 

Home did not maintain a quality control program that complied with HUD requirements. (Memorandum: 2017-

CF-1807, Joint Civil Fraud Division and Office of Investigation Region 1-2) 

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CHAPTER 9 – LEGISLATION, REGULATIONS, AND OTHER 

DIRECTIVES

Reviewing and making recommendations on legislation, regulations, and policy issues is a critical part of the Office 

of Inspector General’s (OIG) responsibilities under the Inspector General Act. During this 6-month reporting 

period, OIG has committed more than 420 hours to reviewing 115 issuances. The draft directives consisted of 70 

notices, 7 mortgagee letters, and 38 other directives. OIG provided comments on 30 (or 26 percent) of the 

issuances and nonconcurred on 6 but lifted 4 nonconcurances. Of the 38 other directives, OIG reviewed 4 

(proposed, interim, and final) rules, 24 handbooks, 1 legislative referral memorandum, and 9 congressional and 

annual reports. OIG had no position on the 4 rules. A summary of selected reviews for this 6-month period is 

included below. 

NOTICES, POLICY ISSUANCES, AND FINAL RULES

SINGLE-FAMILY HOUSING

Housing counseling – On May 31, 2017, HUD published a notice of availability of the U.S. Department of Housing 

and Urban Development (HUD) Certified Housing Counselor Examination. This notice follows publication of the 

Housing Counseling: New Certification Requirements final rule, issued on December 14, 2016, which requires that 

HUD announce the availability of the Certified Housing Counselor Examination and start the 36-month period for 

individuals and housing counseling agencies to come into compliance with the final rule’s certification 

requirements. The final rule also noted that HUD would provide notice of any changes to the cost of the Certified 

Housing Counselor Examination. Through this notice, HUD is announcing that the HUD Certified Housing 

Counselor Examination will be available starting on August 1, 2017, and that as of August 1, 2020, housing 

counseling required by or provided in connection with HUD programs may be provided only by HUD-certified 

housing counselors working for participating agencies approved to provide such housing counseling by HUD’s 

Office of Housing Counseling. This notice also announces a reduction in the cost of the Certified Housing 

Counselor Examination. 

Home Equity Conversion Mortgage – On January 19, 2017, the Federal Housing Administration (FHA) published 

the final rule, strengthening the Home Equity Conversion Mortgage (HECM) program. On August 24, 2017, HUD 

issued Mortgagee Letter 2017-11 to highlight requirements specifically related to servicing functions that were 

published in the final rule and support lenders in successfully implementing the rule’s servicing requirements, which 

take effect for all case numbers assigned on or after September 19, 2017. 

Mortgage insurance premium – On August 29, 2017, HUD issued Mortgagee Letter 2017-12, communicating the 

revised initial and annual mortgage insurance premium (MIP) rates and principal limit factors for all HECMs. The 

initial MIP rate is changed to 2 percent of the maximum claim amount. The initial MIP rate is applicable to all 

borrowers and is no longer associated with disbursements made on or on behalf of the borrower at closing or during 

the first 12-month disbursement period. The annual MIP is changed to .5 percent of the outstanding mortgage 

balance. 

PUBLIC AND INDIAN HOUSING

Rental Assistance Demonstration – Notice of Increase in Cap and Rent Setting – On August 23, 2017, HUD 

published a notice, which addresses the increase in the number of public housing units that may be awarded 

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competitively under HUD’s Rental Assistance Demonstration (RAD). On May 5, 2017, the 2017 Appropriations 

Act amended the RAD statute by increasing the unit cap from 185,000 units to 225,000 units and extending the 

period for project applications until September 30, 2020. This notice serves as notification to public housing 

agencies (PHA) that have submitted letters of interest to reserve their position on the RAD waiting list, showing that 

they are eligible for award under this expansion if they submit a completed RAD application, portfolio award, or 

multiphase award for the number of units identified in their letter of interest within 60 days of the publication of this 

notice. The awards are subject to existing eligibility and selection criteria as HUD is not changing such criteria with 

this notice. For commitments to enter into housing assistance payments contracts issued beyond the 185,000-unit 

cap (that is, between 185,001 and 225,000 units) and for any replacement awards made as a result of revocations or 

withdrawals that occur after May 5, 2017, HUD will use rent levels based on fiscal year 2016 public housing 

funding levels (fiscal year 2016 RAD rent base year). Finally, for all existing and future multiphase awards, this 

notice modifies the latest possible date for PHAs to submit an application for the final phase of the project covered 

by the multiphase award to September 30, 2020.

MULTIFAMILY HOUSING

Delayed implementation of the Capital Needs Assessments eTool – On April 19, 2017, HUD published Housing 

Notice H- 2017-04, which amends Housing Notice H-2016-18 by delaying the implementation date for the New 

Capital Needs Assessment (CNA) eTool. Such a delay ensures that users have adequate time to familiarize 

themselves with the updated tool. The broad objectives of the CNA eTool reflect both diligence and capital 

planning purposes, as well as the speed, efficiency, consistency, and accuracy achievable from automated systems.

Indefinite deferral of implementation of the small building risk sharing initiative – On May 1, 2017, HUD published 

Federal Register Notice FR-6017-N-01, which advises the public that HUD is deferring implementation of the 

Small Building Risk Sharing Program, which was to facilitate the financing of small multifamily properties 

authorized by section 542(b) of the Housing and Community Development Act of 1992. While applications were 

received under the July 2015 final notice, HUD did not implement the program. In addition, it is not clear whether 

the program is still needed under current economic conditions. HUD, therefore, indefinitely defers the applicability 

of the final notice implementing the program and will not accept additional applications at this time.

Property inspection-preservation collection of Mark to Market program information – On July 12, 2017, HUD 

published Federal Register Notice FR-6001-N-19, which requires the collection of information regarding 

multifamily properties, and such information will be used to determine the eligibility of FHA-insured multifamily 

properties for participation in the Mark to Market program and the terms on which such participation should occur, 

as well as to process eligible properties from acceptance into the program through closing of the mortgage 

restructure in accordance with program guidelines. The result of participation in the program is the refinancing and 

restructure of the property’s FHA-insured mortgage and, generally, the reduction of Section 8 rent payments and 

establishment of adequately funded accounts to fund required repair and rehabilitation of the property. 

Adoption of methodology changes for estimating fair market rents – On September 1, 2017, HUD published Federal 

Register Notice FR-6021-N-02, which adopts HUD’s May 26, 2017, proposed material changes to the methodology 

for estimating fair market rents (FMR) and notifies interested parties that fiscal year 2018 FMRs are available at 

www.huduser.gov. The primary uses of FMRs are to determine (1) payment standards for the Housing Choice 

Voucher program, (2) initial renewal rents for some expiring project-based Section 8 contracts, and (3) initial rents 

for housing assistance payments contracts in the Moderate Rehabilitation Single Room Occupancy program and (4) 

to serve as rent ceilings for rental units in both the HOME Investment Partnerships program and the Emergency 

Solutions Grants program. HUD also uses FMRs in the calculation of maximum award amounts for Continuum of 

Care Program grantees and in the calculation of flat rents for public housing units. This notice also describes the 

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methods used to calculate the fiscal year 2018 FMRs and enumerates the procedures for PHAs and other interested 

parties to request reevaluations of their FMRs as required by the Housing Opportunities Through Modernization Act 

of 2016. 

COMMUNITY PLANNING AND DEVELOPMENT

Housing Trust Fund – On June 23, 2017, HUD published the funding awards totaling more than $219.1 million for 

the Housing Trust Fund. The Fund was created by Section 1131 of the Housing and Economic Recovery Act of 

2008. The amount included more than $12.7 million in unobligated fiscal year 2016 funds. 

Waivers – On June 28, 2017, HUD published a notice of the waivers it granted from January 1 through March 31, 

2017. HUD granted waivers to the Cities of Daly City, CA, and Sacramento, CA, both participating jurisdictions 

under the HOME program, to establish maximum monthly allowances for utilities and services (excluding 

telephone) and to update their utility allowances annually. HOME requirements for establishing utility allowances 

conflict with HUD regulations prohibiting the use of utility allowances established by local PHAs for HOMEassisted rental projects for which HOME funds were committed on or after August 23, 2013. In granting the 

waiver, HUD recognized that it was not possible to use two different utility allowances to set rents for a single unit. 

Disaster funding – Effective August 7, 2017, HUD published a notice to announce an additional funding allocation 

of $400 million for 2015 and 2016 disasters (Public Law 115-31). The notice announced the allocation of an 

additional $342.2 million in disaster funding to 13 grantees. At least 80 percent of the additional funding is required 

to be used to address unmet needs within the HUD-identified “most impacted and distressed” areas within the 

grantees’ jurisdictions. The State of Louisiana, the City of Moore, OK, and the State of New York were provided 

with waivers to reduce the overall low- and moderate-income benefit requirements and to exclude Community 

Development Block Grant Disaster Recovery expenditures on Rebuild by Design from the calculation of overall 

low- and moderate-income benefit. The notice also extended the expenditure deadline for National Disaster 

Resilience grantees to September 30, 2022. The previous expenditure deadline was within 2 years of the date on 

which HUD obligated the funds to the grantee, unless an extension was requested by the grantee and approved by 

HUD.

ADMINISTRATIVE-OTHER

Final rule and adjustment of civil monetary penalty amounts for 2017 – On May 30, 2017, HUD published a final 

rule, FR-5942-F-02, which makes final the interim final rule, published on June 15, 2016, to amend HUD’s civil 

monetary penalty (CMP) regulations. The interim final rule applied a new methodology to calculate CMP amounts 

as mandated by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, starting with a 

“catch up” adjustment to correct previous inaccuracies; removed three obsolete CMP provisions; and made a 

technical change to the existing codified regulation implementing the Program Fraud Civil Remedies Act. The 

changes from the interim final rule made final by this final rule continue to be effective as of August 16, 2016. In 

addition, this rule provides for 2017 inflation adjustments of CMP amounts required by the Federal Civil Penalties 

Inflation Adjustment Act Improvements Act of 2015 and makes three technical amendments and a conforming 

statutory change. 

Revision of Freedom of Information Act regulation – correction – On May 10, 2017, HUD published Federal 

Register Notice FR-5986-C-02, which makes corrections to the previous final rule and minor technical changes. On 

January 12, 2017, HUD issued a final rule amending HUD’s Freedom of Information Act (FOIA) regulation to 

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implement the FOIA Improvement Act of 2016, which enacted a range of procedural changes, including a change to 

the procedures for withholding information and an amendment to one of the nine FOIA exemptions that authorizes 

an agency to withhold various records from disclosure. After publication, HUD discovered that a portion of the 

regulation was not published as intended. Specifically, the published rule deleted several of the nine statutory FOIA 

disclosure exemptions and duplicated another. HUD also noticed minor technical changes required elsewhere in its 

regulations. This document corrects HUD’s January 12, 2017, final rule and makes the minor technical changes. 

Reducing regulatory burden; enforcing the regulatory reform agenda under Executive Order 13777 – On May 15, 

2017, HUD published Federal Register Notice FR-6030-N-01, which states that it is reviewing its existing 

regulations to assess their compliance costs and reduce regulatory burden. As required by Executive Order 13777, 

HUD is in the process of establishing a Regulatory Task Force charged with identifying agency regulations that 

should be repealed, replaced, or modified. As part of this review, HUD invites public comments to assist in 

identifying existing regulations that may be outdated, ineffective, or excessively burdensome. 

Grants management – In May 2017, HUD OIG reviewed an updated Grants Management Handbook, which 

implements HUD’s administration of grants and cooperative agreements. This handbook gives HUD program and 

administrative offices a uniform set of requirements that staff must follow to fully implement Office of Management 

and Budget directives, Federal statutes, and regulations throughout the grant life cycle. This handbook revised 

HUD Grants Handbook 2210.17, REV-2 (January 23, 1992), and replaced HUD Directives System Handbook 

000.2. OIG nonconcurred on two main issues. The first issue concerned responsibilities that did not apply to HUD 

OIG. In the section concerning HUD OIG’s responsibilities that may impact the administration of HUD grants, 

there were two functions listed that did not apply to HUD OIG. These functions were (1) oversees the work of nonFederal auditors performed with Federal programs and (2) processes exclusions based on the Social Security Act 

and implementing regulations at 42 CFR (Code of Federal Regulations) Part 1001. The Office of Strategic Planning 

and Management (OSPM) agreed and removed those two functions. OIG’s second nonconcur item concerned 

requirements on subrecipient monitoring. Specifically, OIG took issue with direct language that HUD has no 

relationship or responsibility for subrecipients since it is contrary to HUD’s governance and oversight of Federal 

funds. OSPM agreed and revised the section on subrecipient monitoring to reflect the monitoring responsibilities 

HUD has with managing and administering Federal awards. The handbook was issued July 25, 2017. 

CONSUMER ADVISORIES AND ALERTS

As a way to assist in fraud prevention, OIG issues consumer advisories and alerts, as well as industry advisories and 

bulletins, on its website, www.hudoig.gov. The intent of these publications is to provide information about the risks 

and illegal activities associated with certain products and services. These advisories are intended to ensure that 

industry professionals as well as consumers are well informed of the perils associated with emergent frauds and 

other illegal activities that jeopardize the integrity of otherwise legitimate programs. During this semiannual period, 

OIG issued one disaster fraud alert, which is summarized below. 

Hurricane Fraud (issued September 22, 2017) – HUD and OIG warned everyone affected by Hurricanes Harvey, 

Irma, and Maria to be alert for fraud schemes that commonly occur following a disaster. The alert warns 

individuals to protect themselves from fraudsters who will take advantage of the confusing nature of information 

after a major disaster.

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CHAPTER 10 – AUDIT RESOLUTION

In the audit resolution process, Office of Inspector General (OIG) and U.S. Department of Housing and Urban 

Development (HUD) management agree upon needed actions and timeframes for resolving audit recommendations. 

Through this process, OIG strives to achieve measurable improvements in HUD programs and operations. The 

overall responsibility for ensuring that the agreed-upon changes are implemented rests with HUD managers. This 

chapter describes audit reports issued before the start of the period that do not have a management decision, have 

significantly revised management decisions, or have significant management decisions with which OIG disagrees. 

It also provides a status report on HUD’s implementation of the Federal Financial Management Improvement Act 

of 1996 (FFMIA). In addition to this chapter on audit resolution, see appendix 3, table B, “Significant Audit 

Reports for Which Final Action Had Not Been Completed Within 12 Months After the Date of the Inspector 

General’s Report.” 

AUDIT REPORTS ISSUED BEFORE START OF PERIOD WITH NO MANAGEMENT 

DECISION AS OF SEPTEMBER 30, 2017

ADDITIONAL DETAILS TO SUPPLEMENT OUR REPORT ON HUD’S FISCAL YEARS 2013 

AND 2012 (RESTATED) FINANCIAL STATEMENTS, ISSUE DATE: DECEMBER 16, 2013

HUD OIG audited the Office of Public and Indian Housing’s (PIH) implementation of U.S. Treasury cash 

management regulations as part of the annual audit of HUD’s consolidated financial statements for fiscal years 2013 

and 2012. OIG found that HUD’s implementation of the new cash management process for the Housing Choice 

Voucher program departed from the U.S. Department of the Treasury’s cash management requirements and Federal 

generally accepted accounting principles (GAAP). HUD OIG also reported that there were not sufficient internal 

controls over the process to ensure accurate and reliable financial reporting. The weaknesses in the process failed to 

ensure that material financial transactions were included in HUD’s consolidated financial statements and allowed 

public housing agencies (PHA) to continue to hold Federal funds in excess of their immediate disbursing needs, 

which is in violation of Treasury cash management regulations. 

The OIG report included a recommendation (2C) that HUD PIH implement a cost-effective method for automating 

the cash management process to include an electronic interface of transactions to the United States Standard General 

Ledger (USSGL).

HUD issued three proposals to address recommendation 2C. However, OIG rejected all three proposals because 

they were too vague and did not include a high-level plan showing the actions PIH will take until the final action 

date to implement corrective action. Further, the proposals included several contingencies from which OIG cannot 

determine whether PIH is making progress in addressing the recommendation. 

This issue was referred to the Assistant Secretary on June 19, 2014, and September 30, 2014, but as of March 31, 

2015, a new proposal had not been made. Therefore, this issue was referred to the Deputy Secretary on March 31, 

2015. OIG met to brief the Deputy Secretary’s staff on the subject on April 20, 2015. On August 24, 2016, PIH 

indicated that in coordination with the Office of the Chief Information Officer (OCIO), plans were being developed 

to address the recommendation. However, PIH still has not provided a management decision, and it is difficult to 

determine whether or when these new systems will be implemented. OIG followed up with PIH and OCIO on 

September 19, 2017, about entering a management decision to reflect current plans, but as of September 30, 2017, 

OIG had not received a response. (Audit Report: 2014-FO-0003) 

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U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT WASHINGTON, DC, 

IMPROPER PAYMENTS ELIMINATION AND RECOVERY ACT OF 2010, ISSUE DATE: APRIL 

15, 2014 

HUD OIG audited HUD’s fiscal year 2013 compliance with the Improper Payments Information Act of 2002 as 

amended by the Improper Payments Elimination and Recovery Act of 2010 (IPERA). OIG found that HUD did not 

comply with IPERA reporting requirements because it did not sufficiently and accurately report its (1) billing and 

program component improper payment rates; (2) actions to recover improper payments; (3) accountability; or (4) 

corrective actions, internal controls, human capital, and information systems as required by IPERA. In addition, 

HUD’s supplemental measures and associated corrective actions did not sufficiently target the root causes of its 

improper payments because they did not track and monitor processing entities to ensure the prevention, detection, 

and recovery of improper payments caused by rent component and billing errors, which are root causes identified by 

HUD’s contractor studies.

The OIG report included several recommendations that required the Office of Chief Financial Officer (OCFO) to 

work with PIH and the Office of Multifamily Housing Programs to ensure sufficient and accurate IPERA reporting 

in its agency financial report (AFR). The report also recommended that OCFO conduct a current billing study and, 

if not performed annually in future years, report the reason for this in the AFR and update the previous study to 

reflect program and inflationary changes. Similarly, the report recommended a study to assess improper payments 

arising from the Housing Choice Voucher program. Finally, the report also recommended that OCFO report on 

multifamily, public housing, and Section 8 program improper payment rates separately in the AFRs. 

Initially, OCFO disagreed with several of OIG’s recommendations, citing (1) funding issues in conducting current 

billing studies, which it believes do not produce tangible results; (2) disagreement on the need to determine whether 

improper payments exist as the result of changes in the funding of the Housing Choice Voucher program; and (3) 

management’s position that formal policies and procedures for the IPERA reporting process are not necessary. OIG 

generally disagreed with OCFO’s management decisions because they disregarded IPERA reporting requirements 

and Office of Management and Budget (OMB) guidance and the management decisions did not reflect the Chief 

Financial Officer’s responsibility as the lead official for directing and overseeing HUD’s actions to address 

improper payments.

OIG sent a referral memorandum to the Acting Chief Financial Officer on September 23, 2014, regarding the 

disagreement, along with an untimely referral memorandum for two recommendations that had not had management 

decisions entered. Following OIG’s memorandum, OCFO entered management decisions for seven of nine 

recommendations, of which OIG agreed with only one. The remaining six recommendations, along with two 

recommendations for which management had not yet entered a management decision, were referred to the Deputy 

Secretary on March 31, 2015. OIG briefed the Deputy Secretary’s staff on the subject report on April 20, 2015, and 

in August 2015, meetings were held with OCFO to discuss what was needed to come to agreement. As of March 

31, 2016, management decisions had been agreed upon for all recommendations except two. 

OCFO submitted a new management decision for one of these recommendations on March 23, 2016. OIG 

disagreed with the management decision because OCFO believes its contractor is measuring improper payments 

made to deceased tenants, when OIG’s audit work shows that the contractor is not. OIG met with OCFO on March 

29, 2016, to discuss this matter, and OCFO agreed to contact the contractor for clarification. OIG had not heard 

back from OCFO on this matter until a revised management decision was submitted to OIG on March 30, 2017. 

OCFO submitted a management decision for the other recommendation on March 31, 2016. However, OIG 

disagrees with this management decision because it believes that OCFO’s decision gives HUD the option to 

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continue reporting its improper payments in a way that masks the true error rate in certain programs, which is not 

compliant with OMB’s guidance. OIG had not heard back from OCFO on this matter until a revised management 

decision was submitted to OIG on March 30, 2017. 

OIG has since rejected these management decisions because the plan and evidence to provide closure were too 

vague. OCFO met with OIG to explain that it is revamping its entire process to reduce and report on improper 

payments. However, as of September 30, 2017, OCFO had not provided a project plan with milestones to achieve 

its goals. Without a project plan, OIG cannot determine whether OCFO’s new plan will address OIG’s 

recommendations and when it will be implemented. (Audit Report: 2014-FO-0004) 

HUD DID NOT ALWAYS RECOVER FHA SINGLE-FAMILY INDEMNIFICATION LOSSES AND 

ENSURE THAT INDEMNIFICATION AGREEMENTS WERE EXTENDED, ISSUE DATE: 

AUGUST 8, 2014

HUD OIG audited HUD’s controls over its Federal Housing Administration (FHA) loan indemnification recovery 

process to determine whether HUD had adequate controls in place to monitor indemnification agreements and 

recover losses on FHA single-family loans.

HUD did not always bill lenders for FHA single-family loans that had an indemnification agreement and a loss to 

HUD. Specifically, it did not bill lenders for any loans that were part of the Accelerated Claims Disposition (ACD) 

program or the Claims Without Conveyance of Title (CWCOT) program or loans that went into default before the 

indemnification agreement expired but were not in default on the expiration date. There were a total of 486 loans 

from January 2004 to February 2014 that had enforceable indemnification agreements and losses to HUD but were 

not billed. This condition occurred because HUD’s Financial Operations Center was not able to determine loss 

amounts for loans that were part of the ACD program, was not aware of the CWCOT program, and considered the 

final default date for billing only. As a result, HUD did not attempt to recover a loss of $37.1 million for 486 loans 

that had enforceable indemnification agreements.

In addition, HUD did not ensure that indemnification agreements were extended to 64 of 2,078 loans that were 

streamline refinanced. As a result, HUD incurred losses of more than $373,000 for 5 loans, and 16 loans had a 

potential loss to HUD of approximately $1 million. The remaining 43 loans were either terminated or did not go 

into delinquency before the indemnification agreement expired, or the agreement did not state that it would extend 

to loans that were streamline refinanced.

OIG rejected three management decisions proposed by the Offices of Single Family Housing and Finance and 

Budget because they did not follow the plain language explicitly stated in signed indemnification agreements. The 

Offices of Single Family Housing and Finance and Budget disagree with OIG’s determination that HUD should 

have billed lenders for FHA loans that either were in default or went into default during the indemnification 

agreement period.

OIG referred the matter to the Assistant Secretary for Housing – Federal Housing Commissioner on January 8, 

2015. OIG met with the HUD Office of General Counsel and the Offices of Housing, Single Family Housing, and 

Finance and Budget on January 30, 2015. The meeting ended in disagreement; however, the HUD Office of 

General Counsel and OIG Office of Legal Counsel continued discussions. 

Single Family Housing received two legal opinions from HUD’s Office of General Counsel, dated January 26, 

2015, and February 24, 2015, respectively. Combined, the legal opinions support Single Family Housing’s and 

Finance and Budget’s position that they have collected in a manner consistent with longstanding policy that 

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emphasized the definition of the “date of default.” Single Family Housing maintains that its collection practice is 

consistent with FHA’s regulatory definition of “date of default” found in 24 CFR (Code of Federal Regulations) 

203.331, which refers to the first “uncorrected” failure and the first failure to pay that is not satisfied by later 

payments. 

OIG disagrees and believes that Single Family Housing and Finance and Budget have adopted a collection practice 

not supported by the plain language of the indemnification agreements or required by HUD regulations. Based on 

the plain language explicitly stated in signed indemnification agreements, OIG believes that the indemnification 

agreement should be enforced for any loan that “goes into default” during the indemnification agreement term, 

regardless of whether the loan emerged from a default status after the agreement expired. In response to HUD’s 

legal opinions, OIG received its own legal opinion from the OIG Office of Legal Counsel, which supports OIG’s 

position. 

OIG has had discussions with HUD’s Office of General Counsel, Single Family Housing, and Finance and Budget 

regarding the recommendations in question but has not reached agreeable management decisions. On March 31, 

2015, OIG referred the recommendations to the Deputy Secretary for a decision and is awaiting that decision. In 

September 2017, HUD stated that with the change in administration, it will be resuming discussions on the matter in 

the coming months. (Audit Report: 2014-LA-0005) 

GOVERNMENT NATIONAL MORTGAGE ASSOCIATION FISCAL YEARS 2014 AND 2013 

FINANCIAL STATEMENTS AUDIT, ISSUE DATE: FEBRUARY 27, 2015

HUD OIG audited the Government National Mortgage Association’s (Ginnie Mae) fiscal year 2014 stand-alone 

financial statements. OIG conducted this audit in accordance with the Chief Financial Officers Act of 1990 as 

amended. OIG found a number of material weaknesses in Ginnie Mae’s financial reporting specifically related to 

the auditability of several material assets and reserve for loss liability account balances. The audit report had 20 

audit recommendations to (1) correct the financial statement misstatements identified and (2) take steps to 

strengthen Ginnie Mae’s financial management operations. Initially, OIG did not reach consensus with Ginnie Mae 

on the necessary corrective actions for 9 of the 20 audit recommendations and referred the matter to the Deputy 

Secretary for a decision on September 21, 2015. In August 2016, OIG reached an agreement for management 

decision on three of nine management decisions that OIG previously rejected. As a result, there are now six audit 

recommendations without a management decision. OIG’s audit recommendations request that HUD’s Chief 

Financial Officer provide oversight of Ginnie Mae’s financial management operations, but HUD’s corrective action 

plan to provide the oversight of Ginnie Mae lacked specificity. As of September 30, 2017, the Deputy Secretary 

had not provided a decision on the six recommendations referred. (Audit Report: 2015-FO-0003) 

GOVERNMENT NATIONAL MORTGAGE ASSOCIATION FISCAL YEARS 2015 AND 2014 

(RESTATED) FINANCIAL STATEMENTS AUDIT, ISSUE DATE: NOVEMBER 13, 2015

HUD OIG audited Ginnie Mae’s fiscal year 2015 stand-alone financial statements. OIG conducted this audit in 

accordance with the Chief Financial Officers Act of 1990 as amended. This report had new and repeat audit 

findings. Of 11 audit recommendations, OIG did not reach consensus on the necessary corrective actions for 3. 

Ginnie Mae did not provide a response to OIG to explain Ginnie Mae’s refusal to implement one audit 

recommendation related to compliance with the Debt Collection Improvement Act. 

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For the remaining two information technology (IT)-related audit recommendations, Ginnie Mae’s master 

subservicer (MSS) disagreed with one audit recommendation. The MSS believes that it has the proper segregation 

of duties for cash processes, payment processing, and reconciliation of all financial activities. However, OIG 

disagrees and maintains its original position that segregation of duties means that no single person should have 

control of two or more conflicting functions within a transaction or operation. Further, while a security camera 

system, criminal background checks, etc., are helpful, they do not take the place of good internal controls, which 

include the segregation of duties. 

Regarding the second IT audit recommendation, Ginnie Mae’s MSS agreed to regularly review the market discount 

fraction change report and confirm this review in its monthly self-evaluation. However, this response and 

management’s plan of action did not fully address OIG’s recommendation. The methods identified were neither 

sufficient nor adequate to address (1) OIG’s finding “that management had an ineffective monitoring tool in place” 

and (2) OIG’s recommendation that management automate the approval process to include restricting the capability 

to make unauthorized changes unless evidence of approval is present or increase the scope of the “Admin 

Adjustment Report” to include all exceptions and adjustments. The issue was not that a review process was not in 

place but that the review was not meaningful or effective because the tool or report used to review financial 

adjustment changes was limited. The manual approval process also enabled staff to avoid obtaining approval before 

making adjustments because there were (1) no checks and balances and (2) no restrictions in the financial system to 

prevent unauthorized adjustments. Management’s plan of action did not address OIG’s concern. 

OIG referred this matter to the President of Ginnie Mae for a decision on April 21, 2016, and to the Deputy 

Secretary on March 6, 2017. As of September 30, 2017, OIG was awaiting a decision on the remaining three 

recommendations referred to the Deputy Secretary. (Audit Report: 2016-FO-0001) 

ADDITIONAL DETAILS TO SUPPLEMENT OUR FISCAL YEARS 2015 AND 2014 

(RESTATED) U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT FINANCIAL 

STATEMENT AUDIT, ISSUE DATE: NOVEMBER 18, 2015 

HUD OIG audited HUD’s consolidated financial statements and reported on deficiencies, including the areas of (1) 

accounting for liabilities for PIH programs in accordance with GAAP and the Federal Financial Mangers 

Improvement Act (FFMIA) and (2) HUD’s financial management governance structure and internal controls over 

financial reporting. HUD disagreed with several recommendations made in each of these areas, and as a result, OIG

first referred them to the Principal Deputy Assistant Secretary for Public and Indian Housing and the Deputy Chief 

Financial Officer on April 21, 2016. OIG received a response to only one recommendation, and disagreement 

remained on the actions necessary to correct the deficiencies identified in the report. OIG referred the remaining 

recommendations to the Deputy Secretary on September 20, 2016. As of September 30, 2017, OIG had not 

received further proposals from HUD on these matters.

Accounting for liabilities for PIH programs in accordance with GAAP and FFMIA: OIG reported that HUD is not 

recognizing the accounts payables arising from shortages identified in PIH’s cash management reconciliations. 

PIH’s position is that it does not record the payables because the cash management reconciliations are completed 

45-60 days after each quarter. By the time they are conducted, the PHA could have used either restricted or 

unrestricted net position balances or requested frontload funding to cover the shortages. OIG does not agree that 

this complies with GAAP because adjusting the prepaid expense after payables have been paid is not accrual 

accounting. PIH has not submitted a revised position on this matter. OIG believes that this recommendation cannot 

be resolved until PIH’s cash management process is automated, which is discussed in Audit Report 2014-FO-0003 

(discussed above). 

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HUD’s financial management governance structure and internal controls over financial reporting: OIG reported 

on deficiencies found in the financial governance and financial reporting areas. OIG could not accept the proposed 

management decisions because OCFO (1) requested final action target dates that were too far out in the future, (2) 

claimed the deficiencies had been addressed by the new processes implemented by New Core when they had not, or 

(3) did not provide sufficient detail to support that the recommendations would be fully addressed. OIG

communicated these issues to HUD on March 7, 2016. A new proposal was submitted for one recommendation but 

was rejected because management did not understand the intention of the recommendation and did not include an 

action plan to document its processes as indicated in the recommendation. OIG has not received any new proposals 

for the remaining outstanding recommendations. (Audit Report: 2016-FO-0003) 

HUD DID NOT ALWAYS PROVIDE ADEQUATE OVERSIGHT OF PROPERTY ACQUISITION 

AND DISPOSITION ACTIVITIES, ISSUE DATE: JUNE 30, 2016

HUD OIG audited HUD’s Community Development Block Grant (CDBG) program’s property acquisition and 

disposition activities. OIG’s audit objective was to determine whether HUD had adequate oversight of property 

acquisition and disposition activities under its CDBG program. 

OIG found that HUD did not always provide adequate oversight of property acquisition and disposition activities. 

Specifically, of 14 activities reviewed, 7 field offices did not provide adequate oversight of 8 property acquisition 

and disposition activities totaling more than $26.2 million. For the eight activities for which adequate oversight was 

not provided, two activities with draws totaling $6.1 million had outstanding program-related findings that HUD 

had not enforced, and six totaling $20.1 million had not been monitored. Additionally, four of the eight activities 

totaling nearly $11.9 million had not met a national objective. 

These conditions occurred because HUD did not have adequate controls to ensure that it enforced its monitoring 

findings and its grantee risk assessment procedures did not specifically address the oversight of property acquisition 

and disposition activities. 

The OIG report included a recommendation that the Deputy Assistant Secretary for Grant Programs direct field 

offices to include property acquisition and disposition activities as an area of special emphasis when assessing 

grantee risk and establishing their monitoring plans and grantee monitoring strategies. 

The Deputy Assistant Secretary for Grant Programs proposed a management decision in December 2016. However, 

after discussions with HUD, OIG rejected the proposed management decision because it did not directly address 

directing field offices to include property acquisition and disposition activities as an area of special emphasis when 

assessing grantee risk and establishing their monitoring plans and grantee monitoring strategies as recommended. 

For OIG to consider the proposed management decision as an acceptable alternative action, OIG requested 

clarification and documentation from HUD. However, HUD did not provide the requested information and 

documentation, and OIG referred this recommendation to the Acting Assistant Secretary for Community Planning 

and Development on March 30, 2017. HUD proposed another management decision in April 2017; however, OIG 

rejected it because it also did not directly address the intent of the recommendation. OIG referred this 

recommendation to the Deputy Secretary on August 23, 2017, and as of September 30, 2017, had yet to receive a 

response. (Audit Report: 2016-PH-0001) 

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INDEPENDENT ATTESTATION REVIEW: U.S. DEPARTMENT OF HOUSING AND URBAN 

DEVELOPMENT, DATA ACT IMPLEMENTATION EFFORTS, ISSUE DATE: AUGUST 26, 

2016

HUD OIG reviewed HUD’s efforts as of July 15, 2016, to comply with steps 1-4 of the U.S. Department of the 

Treasury DATA Act Playbook to determine whether HUD is positioned to meet the statutory May 2017 deadline. 

Upon completion of the review, OIG concluded that HUD was not on track to provide complete, departmentwide 

reporting by the statutory deadline. 

OIG noted that the implementation issues were a result of HUD’s having three different senior accountable officials 

in a 6-month span and the conclusion that the Digital Accountability and Transparency Act of 2014 (DATA Act) 

applied to FHA and Ginnie Mae was not made until approximately May 2016. These conditions delayed 

implementation efforts and precluded the reasonable expectation that the deadline would be met. In addition to the 

FHA and Ginnie Mae delays, as of July 15, 2016, HUD had not completed its inventory of data elements or the 

mapping of agency data to the DATA Act schema. HUD had also been unable to resolve data quality issues that 

have impeded the complete and accurate reporting of departmental contract, grant, loan, and other financial 

assistance awards in USAspending.gov. Among other issues, OIG recommended that HUD (1) identify the universe 

of all program obligations and disbursements, including the appropriations account level of obligations and outlays 

by program activity and by object class for compliant USASpending.gov reporting, and (2) execute a plan to resolve 

errors already identified in programmatic expenditure information transferred to USASpending.gov before full 

implementation and ensure that similar types of errors are identified in a timely manner and promptly resolved 

before implementation.

In response to these recommendations, OCFO disagreed, indicating the challenges encountered by HUD were not 

unique to HUD and affected all agencies. Additionally, OCFO stated that it is implementing corrective actions 

related to current USASpending data and legacy system data quality issues, which include developing a 

comprehensive plan to lay the groundwork for assessing the completeness and accuracy of financial DATA Act 

submissions. 

OIG did not agree with OCFO’s proposed corrective actions because OIG deemed it necessary for HUD to develop 

procedures to reconcile the complete list of its currently funded appropriations and programs and identify the 

portfolio of funding identified that supports each program. Additionally, to fully address the recommendation, 

OCFO’s corrective action plan should include a reconciliation of (1) the activity of obligations and outlays with 

budget execution reports, (2) the fund balance with Treasury, and (3) its status of funds reports on the performance 

of such reconciliations or similar reconciliations, which are generated from the Oracle Federal Financials system. 

Further, although OCFO stated that HUD had a team working on corrective actions for data quality issues, OIG was

not provided with sufficient evidence and assurance as to how the corrective actions would resolve data relatability 

issues identified during OIG’s review.

OIG referred its disagreement to the Deputy Chief Financial Officer on February 3, 2017. As of March 31, 2017, 

OIG’s disagreement with OCFO had been referred to the Deputy Secretary for decision. As of September 30, 2017, 

HUD had provided no additional information. (Audit Memorandum: 2016-FO-0802) 

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HUD DID NOT ALWAYS PROVIDE ACCURATE AND SUPPORTED CERTIFICATIONS OF

STATE DISASTER GRANTEE PROCUREMENT PROCESSES, ISSUE DATE: SEPTEMBER 

29, 2016

HUD OIG audited HUD’s controls over its certifications of State disaster recovery grantee procurement processes 

to determine whether HUD’s certifications were accurate and supported. OIG found that HUD did not always 

provide accurate and supported certifications of State disaster grantee procurement processes. Specifically, it (1) 

allowed conflicting information on its certification checklists, (2) did not ensure that required supporting 

documentation was included with the certification checklists, and (3) did not adequately evaluate the supporting 

documentation submitted by the grantees. These conditions occurred because HUD did not have adequate controls 

over the certification process. Due to the weaknesses identified, HUD did not have assurance that State grantees 

had proficient procurement processes in place, and the Secretary’s certifications did not meet the intent of the 

Disaster Relief Appropriations Act of 2013.11 

The report included five recommendations for the Deputy Assistant Secretary for Grant Programs. The Acting 

Deputy Assistant Secretary for Grant Programs proposed corrective actions on January 11, 2017, and OIG rejected 

the proposed actions on January 27, 2017. OIG referred the recommendations to the General Deputy Assistant 

Secretary for Community Planning and Development on February 6, 2017. The General Deputy Assistant Secretary 

responded to the referral on February 21, 2017. For all of the recommendations, the General Deputy Assistant 

Secretary stated that OIG’s disagreement regarding the definition of a proficient procurement process, as it relates to 

State disaster grantees, and the meaning of “equivalent” as it relates to a State’s procurement policies and 

procedures being “equivalent to” or “aligned with” the Federal procurement standards, was closed by the Deputy 

Secretary in her decision regarding resolution of recommendations from OIG’s audit of New Jersey’s Sandy 

Integrated Recovery Operations and Management System.12 In the January 10, 2017, decision, the Deputy 

Secretary wrote that the State certified that its procurement standards were equivalent to the Federal standards at 24 

CFR 85.36 and HUD had also certified to the proficiency of the State’s policies and procedures. The Deputy 

Secretary noted that two legal opinions from the Office of General Counsel concluded that the standards at 24 CFR 

85.36 did not apply and, therefore, there was no legal basis for the finding and associated recommendations. The 

General Deputy Assistant Secretary asserted that the legal opinion for the New Jersey audit applied to this audit. 

Based on this information, the General Deputy Assistant Secretary believed it was appropriate to close all of the 

recommendations. 

OIG disagrees with the General Deputy Assistant Secretary’s request to close the recommendations in this audit 

based on the Deputy Secretary’s decision to resolve recommendations from OIG’s audit of New Jersey’s Sandy 

Integrated Recovery Operations and Management System. OIG has two main areas of disagreement with the 

decision: (1) OIG continues to assert that 24 CFR 85.36 was applicable to the State because its procedures needed 

to be equivalent to these Federal standards, and (2) OIG asserts that the applicability of 24 CFR 85.36 was not the 

only basis for the recommendations in the New Jersey audit report and believes that the decision failed to consider 

the other bases of the recommendations. Further, the Deputy Secretary’s decision did not address all of the issues 

with HUD’s process for certifying State disaster grantee procurement processes that were identified in the subject 

audit report. OIG referred these recommendations to the Deputy Secretary on March 31, 2017, and as of September 

30, 2017, had not received a decision. (Audit Report: 2016-PH-0005) 

11 Public Law 113-2, dated January 29, 2013 12 2015-PH-1003, dated June 4, 2015

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AUDIT OF FISCAL YEARS 2016 AND 2015 (RESTATED) FINANCIAL STATEMENTS AUDIT, 

ISSUE DATE: NOVEMBER 14, 2016

HUD OIG audited Ginnie Mae’s fiscal year 2016 stand-alone financial statements. OIG conducted this audit in 

accordance with the Chief Financial Officers Act of 1990 as amended. Of 19 recommendations issued, OIG did not 

reach consensus on the necessary corrective actions for 2. 

The first disagreement was associated with OIG’s recommendation for Ginnie Mae to reverse the accounting 

writeoff of the advances account. In conjunction with the subledger data solution, Ginnie Mae needs to conduct a 

proper analysis to determine whether any of the $248 million balances in the advances accounts are collectible. 

Ginnie Mae believes that it cannot reverse the $248 million residual balance in the advances account. Based on its 

analysis, Ginnie Mae explained that this residual balance should have been charged off by the realized losses 

incurred on liquidated loans from fiscal years 2009 through 2016 but it was not. Therefore, according to Ginnie 

Mae, this residual balance was no longer supportable or collectible after the sale of the mortgage servicing rights. 

Additionally, Ginnie Mae states that it cannot pursue additional collection from its master subservicers based on the 

terms of its settlement with them. OIG has concerns about the reliability of Ginnie Mae’s analysis because when 

OIG attempted to review Ginnie Mae’s support for the advances writeoff, it was unable to validate the accuracy of 

the information used in its analysis. For example, of $248 million, OIG could not validate the $180 million in 

realized losses because this information was based on rough estimates ($50 million) and mastersubservicers’ 

accounting reports that OIG considered unauditable ($130 million). Ginnie Mae could not explain the other $68 

million. Further, OIG’s audit showed that the $248 million residual balance may contain advances related to 

unliquidated nonpooled loans. Specifically, in fiscal year 2016, Ginnie Mae stated that all advance balances 

associated with liquidated loans were removed from the advances account and attached (carried forward) to the 

liquidated loans balance. However, in fiscal year 2017, OIG learned that this was not the case. According to Ginnie 

Mae, the advance balances associated with these loans were not carried forward. Therefore, there are legitimate 

collection action claims that Ginnie Mae can pursue on these unliquidated nonpooled loans. 

The second disagreement was related to OIG’s recommendation for Ginnie Mae to exclude the loan impairment 

allowance on other indebtedness appropriately instead of reporting it as part of the loan impairment allowance on its 

mortgage held for investment (MHI) account. Ginnie Mae partially agreed with OIG regarding the MHI allowance 

issue. Ginnie Mae agreed that it should have excluded from the MHI allowance account the allowance portion 

related to the reimbursable preforeclosure expense but not the nonreimbursable preforeclosure expense portion. 

According to Ginnie Mae, it included the nonreimbursable preforeclosure expense in the MHI allowance calculation 

because the expense was necessary to collect proceeds of the MHI loans. Ginnie Mae cited Accounting Standards 

Codification (ASC) 450-20 and the interagency policy statement on the allowance for loan and lease losses as the 

bases for its conclusion with respect to the issue of nonreimbursable preforeclosure expense. Overall, Ginnie Mae 

concluded that in estimating the MHI allowance, the expected-anticipated recoveries from insurance, as well as the 

expected but not yet incurred preforeclosure costs, will need to be included in determining the collectability of cash 

flows from these loans. Regarding nonreimbursable preforeclosure expenses, OIG does not agree with Ginnie Mae 

that its inclusion in the ASC 450-20 or ASC 310-10 components of the MHI allowance was in accordance with 

GAAP. 

Both disagreements were referred to the Deputy Secretary on August 24, 2017. As of September 30, 2017, OIG 

was awaiting a decision. (Audit Report: 2017-FO-0001) 

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ADDITIONAL DETAILS TO SUPPLEMENT OUR FISCAL YEARS 2016 AND 2015 

(RESTATED) U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT FINANCIAL 

STATEMENT AUDIT, ISSUE DATE: NOVEMBER 15, 2016

OIG audited HUD’s consolidated financial statements and reported on deficiencies in the areas of (1) HUD’s loan 

guarantee balances; (2) HUD’s accounting for its property, plant, and equipment; (3) significant reconciliations not 

completed in a timely manner; (4) HUD’s lack of a policy and procedure framework; and (5) invalid obligations that 

remained on HUD’s books. OIG issued several referrals regarding these management decisions to HUD senior 

management for untimeliness and disagreement between May 31 and July 24, 2017. For recommendations 

regarding HUD’s account for property, plant, and equipment, OCFO submitted management decisions on 

September 21 and 22, 2017, and they are under OIG review. As of September 30, 2017, OIG had not received new 

proposed management decisions for the remaining recommendations. (Audit Report: 2017-FO-0003) 

HUD’S TRANSITION TO A FEDERAL SHARED SERVICE PROVIDER FAILED TO MEET 

EXPECTATIONS, ISSUE DATE: FEBRUARY 1, 2017

HUD OIG audited the effectiveness of the controls over the New Core Interface Solution (NCIS) and PRISMTM and 

the impact of the implementation of release 3 of phase 1 of the New Core Project on the preparation of HUD’s 

financial statements. 

HUD’s transition to a Federal shared service provider (FSSP) did not significantly improve the handling of its 

financial management transactions. Weaknesses identified with the controls over NCIS and PRISMTM contributed 

to this issue. A year after the transition, HUD had inaccurate data resulting from the conversions and continued to 

execute programmatic transactions using its legacy applications. The transition increased the number of batch 

processes required to record programmatic financial transactions and introduced manual processes and delays for 

budget and procurement transactions. In addition, the interface program that allowed for and translated the financial 

transactions between HUD and the Administrative Resource Center was not covered under HUD’s disaster recovery 

plan. These conditions occurred because of funding shortfalls as well as HUD’s decisions to (1) separate phase 1 of 

the project into smaller releases, (2) move forward with the implementation despite unresolved issues, and (3) 

terminate the project before its completion. These system issues and limitations inhibited HUD’s ability to produce 

reliable, useful, and timely financial information. 

While HUD considered its New Core Project implementation successful, it acknowledged that not all of the 

originally planned capabilities were deployed. HUD needs to pursue new process improvement projects to address 

the functionalities that were not achieved with phase 1 of New Core, which will require additional time and funding. 

HUD will also need to pursue process improvements for the functionality planned in the future phases of the 

project. In April 2016, HUD ended the New Core Project and the transition to an FSSP after spending $96.3 

million; however, the transition did not allow HUD to decommission all of the applications it wanted to or achieve 

the planned cost savings. 

HUD OIG made two recommendations within this audit that were directed to the Deputy Secretary. 

1) Recommendation 1A - Reevaluate the functionality initially planned under the New Core Project and 

determine how the agency will implement the functionality needed for budget formulation, cost 

accounting, property management, and the consolidation of HUD’s financial statements.

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2) Recommendation 1B - Take an active role in the implementation of financial management 

improvement initiatives-projects moving forward to ensure collaboration within HUD and that 

adequate funding and governance are in place. 

OIG has not received a response or a proposed management decision related to the two recommendations. OIG 

referred these recommendations to the Deputy Secretary on June 6, 2017. As of September 30, 2017, HUD still had 

not submitted management decisions for these recommendations. (Audit Report: 2017-DP-0001) 

SIGNIFICANTLY REVISED MANAGEMENT DECISIONS

Section 5(a)(11) of the Inspector General Act, as amended, requires that OIG report information concerning the 

reasons for any significantly revised management decisions made during the reporting period. During the current 

reporting period, OIG had five reports in which there were significantly revised management decisions.

THE DATA IN CAIVRS DID NOT AGREE WITH THE DATA IN FHA’S DEFAULT AND CLAIMS

SYSTEMS, ISSUE DATE: JULY 2, 2014

HUD OIG audited the Credit Alert Verification Reporting System (CAIVRS) to determine whether the default and 

claims data in CAIVRS agreed with the data in FHA’s default and claim systems. OIG determined that CAIVRS 

did not contain information on all borrowers’ default, foreclosure, and claim activity. It would incorrectly return 

accept codes for more than 260,000 borrowers who had been in default, foreclosure, or claim within the past 3 

years. As a result, CAIVRS could allow ineligible debtors to obtain new Federal loans and loan insurance 

guarantees. In addition, CAIVRS did not contain information for FHA borrowers with claims older than 3 years. 

Therefore, HUD did not provide other Federal agencies with sufficient information on FHA borrowers with 

delinquent Federal debt to meet the requirements of the Debt Collection Improvement Act of 1996. 

OIG recommended that HUD notify the users of CAIVRS that the system may have incomplete information for 

FHA delinquent debtors and obtain a determination from the Secretary of the Treasury of whether defaulted FHAinsured loans meet the definition of delinquent Federal debt. HUD disagreed with these recommendations. On 

September 29, 2016, the Deputy Secretary issued a decision memorandum that closed these recommendations. 

OIG also recommended that HUD document the selection rules for feeding data to CAIVRS, update the rules to 

provide for complete reporting, and develop and implement system error checks to identify issues. In addition, OIG 

recommended that the selection rules be updated to report debt beyond the 3-year claim period. In its original 

management decision, HUD agreed to take each of the recommended actions. On September 26, 2017, HUD 

submitted a revised management decision, stating that before the September 2016 decision memorandum, HUD was 

unable to proceed with action on these recommendations as they were codependent on what was determined to be 

delinquent Federal debt. It plans to issue a mortgagee letter announcing that CAIVRS will now include only FHA 

borrowers who owe a debt to HUD and the debt is delinquent or in default and that HUD will discontinue CAIVRS 

reporting of all other existing criteria, such as borrowers in default, foreclosure, or claims status. The mortgagee 

letter will notify lenders that FHA’s change to CAIVRS does not affect existing lender requirements to report 

delinquency, default, and foreclosure data and there is no change to the existing borrower eligibility requirements. 

Following publication of this mortgagee letter, HUD will document the selection rules, update the selection rules, 

and develop and implement system error checks so that the system excludes additional credit information 

traditionally reported in CAIVRS and includes only what HUD has deemed to be delinquent Federal debt.

On September 28, 2017, OIG agreed with the revised management decision. (Audit Report: 2014-KC-0002) 

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HUD PAID CLAIMS THAT LACKED CONTACT OR COLLECTION ACTIVITIES WITH 

COBORROWERS, ISSUE DATE: SEPTEMBER 18, 2013

HUD OIG audited FHA insurance claims to determine whether lenders contacted all borrowers on each FHA loan 

before proceeding to claim. OIG determined that HUD paid claims on approximately 2,109 FHA loans when the 

lenders did not contact, attempt collection from, or otherwise include all borrowers during the loss mitigation 

process. Some of the coborrowers were nonoccupying coborrowers, who were added to the loans during 

underwriting so the loans would meet FHA underwriting standards. 

Among other things, OIG recommended that HUD enhance data collection to begin collecting information on 

whether each coborrower will occupy the subject property as well as the addresses and phone numbers of each 

coborrower. In its original management decision, HUD agreed to modify its FHA Connection system to capture the 

additional data. On September 14, 2017, HUD submitted a revised management decision, stating that instead, it had 

partnered with other agencies to revise the Uniform Residential Loan Application (URLA). The revised URLA will 

be implemented on January 1, 2021, and will include the recommended coborrower information. This information 

will be part of the data set captured in its eCase Binder project.

On September 20, 2017, OIG agreed with the revised management decision. (Audit Report: 2013-KC-0004) 

THE CITY OF CLEVELAND, OH, LACKED ADEQUATE CONTROLS OVER ITS HOME 

INVESTMENT PARTNERSHIPS PROGRAM AND AMERICAN DREAM DOWNPAYMENT 

INITIATIVE-FUNDED AFFORD-A-HOME PROGRAM, ISSUE DATE: DECEMBER 27, 2010

THE CITY OF CLEVELAND, OH, LACKED ADEQUATE CONTROLS OVER ITS HOME 

INVESTMENT PARTNERSHIPS PROGRAM-FUNDED HOUSING TRUST FUND PROGRAM 

HOME-BUYER ACTIVITIES, ISSUE DATE: SEPTEMBER 29, 2011

THE CITY OF CLEVELAND, OH, LACKED ADEQUATE CONTROLS OVER ITS HOME 

INVESTMENT PARTNERSHIPS PROGRAM, ISSUE DATE: FEBRUARY 12, 2013

HUD OIG completed three audits of the City of Cleveland, OH’s HOME Investment Partnerships program. The 

objectives of the audits were to determine whether the City complied with (1) HUD’s requirements in its use of 

HOME Investment Partnerships program and American Dream Downpayment Initiative funds to provide interestfree second mortgage loans to home buyers through its Afford-A-Home program and its use of recapture provisions 

for Afford-A-Home program activities, (2) HUD’s requirements in its use of HOME funds to provide interest-free 

second mortgage loans to home buyers through its Housing Trust Fund program and its use of recapture provisions 

for Housing Trust Fund program activities, and (3) to determine whether the City complied with Federal 

requirements and its own policies in the administration of its program.

The City did not comply with HUD’s requirements in its use of HOME and American Dream Downpayment 

Initiative funds to provide interest-free second mortgage loans to home buyers through its Afford-A-Home program 

and its use of recapture provisions for Afford-A-Home program activities. It (1) provided assistance for ineligible 

activities; (2) lacked sufficient documentation to support that activities were eligible; (3) included inappropriate 

recapture provisions in its action plans for program years 2007 to 2008, 2008 to 2009, and 2009 to 2010; (4) did not 

implement appropriate recapture provisions for all of the activities reviewed; and (5) did not ensure that its HOME 

program was reimbursed for HOME funds used to assist home buyers in purchasing homes that were later sold 

through a sheriff’s sale and ownership of the homes had been transferred. OIG recommended that HUD require the 

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City to (1) reimburse its HOME program from non-Federal funds for the $20,000 in program funds inappropriately 

used to assist two activities, (2) provide supporting documentation or reimburse its HOME program $760,000 from 

non-Federal funds, and (3) reimburse its HOME program $30,000 from non-Federal funds for the three homes that 

had been sold through a sheriff’s sale and ownership of the homes had been transferred. 

OIG’s second audit of the City’s HOME program showed that the City did not comply with HUD’s requirements in 

its use of HOME funds to provide interest-free second mortgage loans to home buyers through its Housing Trust 

Fund program and its use of recapture provisions for activities. It (1) provided assistance for an ineligible activity, 

(2) lacked sufficient documentation to support that activities were eligible, (3) did not implement appropriate

recapture provisions for all of the activities reviewed, and (4) did not ensure that its HOME program was

reimbursed for HOME funds used to assist a home buyer in purchasing a home that was later sold through a

sheriff’s sale and ownership of the home had been transferred. OIG recommended that HUD require the City to (1)

reimburse its HOME program from non-Federal funds for the $20,000 in HOME funds inappropriately used to

assist an activity, (2) provide supporting documentation or reimburse its HOME program $775,000 from nonFederal funds, and (3) reimburse its HOME program $20,000 from non-Federal funds for the home that had been

sold through a sheriff’s sale and ownership of the home had been transferred.

OIG’s third audit of the City’s HOME program showed that the City did not comply with Federal requirements or 

its own policies in its contracting processes for housing rehabilitation services and its use of HOME funds for 

Repair-A-Home program projects. The City also did not comply with HUD’s requirements in (1) its reporting of 

HOME program accomplishments in HUD’s Integrated Disbursement and Information System (IDIS), (2) the 

reimbursement of its HOME program from non-Federal funds for homes acquired through home-buyer activities 

that were later sold and ownership of the homes had been transferred, and (3) its use and reporting of its HOME 

program income. OIG recommended that HUD require the City to reimburse its HOME program, for transmission 

to the U.S. Department of the Treasury, more than $220,000 and provide sufficient supporting documentation or 

reimburse its HOME program nearly $249,000. 

HUD’s Office of Community Planning and Development (CPD) agreed with the recommendations and the final 

questioned costs, which totaled more than $3.8 million for all three audits. However, the City disagreed with the 

recommendations. CPD referred the issues to HUD’s Office of General Counsel for collection. In March 2017, 

HUD’s Office of General Counsel entered into a settlement agreement and release with the City that resolved the 

City’s administrative liability concerning the audits for nearly $83,000. In addition, the settlement agreement and 

release did not allow HUD to take any additional actions; therefore, CPD submitted revised management decisions 

and requests for closure of the recommendations. Thus, on September 25, 2017, OIG concurred with the revised 

management decisions to close the audits and denote the more than $3.8 million as uncollectable. (Audit Reports: 

2011-CH-1003, 2011-CH-1014, and 2013-CH-1001) 

SIGNIFICANT MANAGEMENT DECISION WITH WHICH OIG DISAGREES

During the reporting period, OIG had two reports in which the OIG disagreed with the significant management 

decision.

THE HOUSING AUTHORITY OF THE CITY OF EL PASO, TX, DID NOT FOLLOW RECOVERY 

ACT OBLIGATION REQUIREMENTS OR PROCUREMENT POLICIES, ISSUE DATE: APRIL 

12, 2013

HUD OIG audited the Housing Authority of the City of El Paso to meet OIG’s oversight objectives for the 

American Recovery and Reinvestment Act of 2009. Additionally, OIG’s risk assessment of the funding showed 

that as of December 31, 2011, the Authority had spent almost $11 million, or 86 percent, of its formula grant, which 

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left more than $1.7 million to be spent in the 3 months before the expenditure deadline. OIG’s audit objectives were 

to determine whether the Authority properly (1) obligated and spent its formula Recovery Act grant funds, (2) 

obtained its formula Recovery Act contracts, and (3) reported results in an accurate and timely manner.

OIG found that the Authority improperly obligated Recovery Act funds totaling about $2.68 million after the 

statutory obligation deadline. OIG recommended that the Office of Public Housing require the Authority to repay 

more than $2.6 million in 2009 Recovery Act funds to HUD, which will return the funds to the U.S. Treasury, or 

provide eligible costs that it obligated and expensed before the deadlines. HUD should take care to ensure that other 

expended funds are not improperly shifted to Recovery Act funds, as HUD’s policy stated that PHAs must use the 

funds provided in this grant to supplement expenditures, not to supplant expenditures from other Federal, State, or 

local sources or funds independently generated. 

The Office of Public Housing and OIG have disputed recommendation 1A since report issuance. OIG referred the 

disagreement to the Deputy Assistant Secretary of Public Housing in 2013. OIG agreed to allow Public Housing to 

obtain a legal option, with the understanding that OIG reserved the right to disagree with the legal opinion. Public 

Housing obtained the Office of General Counsel’s legal opinion in December 2013 and revised the management 

decisions to requesting closure with no recovery of the funds in February 2014. Lengthy legal discussions occurred 

between the Office of General Counsel and OIG’s Office of Legal Counsel. OIG’s Office of Legal Counsel also 

held discussions with the U.S. Government Accountability Office (GAO). OIG decreased the total $2.6 million 

questioned amount by more than $293,000 for force account labor. After additional discussions with the Office of 

Public Housing and Office of General Counsel, OIG reduced the amount questioned as ineligible to $2.28 million 

relating to eight contracts. 

OIG referred the remaining ineligible contracts to the Assistant Secretary of Public Housing in February 2015. 

Although several verbal discussions took place, OIG did not receive a written response to the referral, even though 

the Office of Public Housing seemed to admit that the Authority needed to repay the Guillen roof contract amount, 

which was a Public Housing Capital Fund program contract. In February 2017, OIG referred the disagreement to 

the Deputy Secretary. In July 2017, the Deputy Secretary issued the final management decision. In it, the Deputy 

Secretary agreed to make the Authority repay nearly $338,000 for the Guillen contract and indicated that she would 

not require a repayment for any of the remaining funds, which totaled more than $1.9 million. The decision was 

based on two assertions that the Office of Public Housing (1) has long allowed PHAs to obligate funds for labor, 

materials, and equipment using the force account method and (2) stated that its grantees could use the longstanding 

rules of the Capital Fund program to obligate, deobligate, and expend its Recovery Act funds.

OIG disagrees with the Deputy Secretary’s final decision. In its response concerning the Authority’s purchase of an 

evaporative cooler and materials using contracts obligated after the Act’s statutory obligation deadline, HUD 

redefined force account to include materials and equipment and ignored the Act’s statutory deadline. In its response 

concerning the reobligation of funds deobligated by the Authority, HUD stated that it was authorized to obligate 

funds for PHAs until September 30, 2011. Thus, HUD’s response misstated that the Act required it to obligate 

Recovery Act public housing formula funds within 30 days of the enactment of the Act, which made the obligation 

deadline March 17, 2010. HUD also stated that the Act did not overrule the existing rules of the Capital Fund 

program, making the Capital Fund’s longstanding definitions of “obligate” and “expend” apply. In making this 

statement, HUD failed to account for the Recovery Act’s strict obligation and expenditure deadlines, which differed 

from the regular Capital Fund program rules. Further, HUD ignored the well-settled traditional rule concerning the 

continued availability of appropriated funds beyond the statutory deadline. When it becomes necessary to terminate 

a contract because of a contractor’s default, some other defect in the contract, or the convenience of the government, 

the funds originally obligated are available, beyond the original period of obligational availability, to engage 

another contractor to complete the unfinished work. Here, however, funds obligated to one project and purpose 

were later reallocated to a totally different project and purpose, such as from roof replacement at Salazar to 

waterline work at Sherman. (Audit Report: 2013-FW-1004) 

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ADDITIONAL DETAILS TO SUPPLEMENT OUR FISCAL YEARS 2015 AND 2014 

(RESTATED) U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT FINANCIAL 

STATEMENT AUDIT, ISSUE DATE: NOVEMBER 18, 2015 

HUD Continued To Not Comply With the Home Investment Partnership Act

HUD OIG audited the HOME Investment Partnerships program during the annual fiscal year 2015 financial 

statement audit. One of the objectives of the audit was to determine whether HUD complied with the applicable 

laws and regulations for commitment, obligation, and disbursement transactions for CPD programs. 

OIG found that HUD continued to not comply with section 218(g) of the HOME Investment Partnership Act (also 

known as the HOME Statute) regarding grant commitment requirements. HUD’s misinterpretation of the plain 

language in the Act, the implementation of the cumulative method and the first-in, first out (FIFO) technique, and 

the current recapture policies continued to result in HUD’s noncompliance with HOME Statute requirements. 

Further, HUD’s corrective action plan to modify IDIS to assess grantee compliance on a grant-by-grant basis for 

fiscal year 2015 and later grants was halted only due to budget shortfalls. As a result, HUD incorrectly permitted 

some Jurisdictions to retain, commit, and disburse HOME grant funds beyond the statutory deadline. OIG

determined that allowing grantees to disburse funds from commitments made outside the 24-month statutory period 

may have caused HUD to incur improper payments. According to OMB Circular A-123, appendix C, an improper 

payment is any payment that should not have been made or that was made in an incorrect amount under statutory, 

contractual, administrative, or other legally applicable requirements.

OIG reported that followup of work performed during the 2013 audit indicated that instances of improper payments 

occurred. OIG identified three grantees during the 2013 audit that committed grant funds beyond the 24-month 

statutory deadline using the noncumulative commitment method. The three grantees were recipients of the fiscal 

year 2010 grant year allocation of HOME program funds, which had a 24-month commitment deadline that fell in 

fiscal year 2012. OIG followed up on the status of these grantees during the fiscal year 2015 audit. OIG obtained 

disbursement data for these three 2010 grantees as of July 31, 2015, and determined that they had disbursed nearly

$950,000 from the commitments they made after their 24-month commitment deadline expired in fiscal year 2012. 

OIG believes that the $950,000 disbursed from commitments outside the 24-month statutory period meets the 

criteria of an improper payment. 

As a result, OIG recommended that the Deputy Chief Financial Officer (1) implement a payment recapture audit for 

the HOME program, specifically to identify and recapture improper payments made as a result of the continued use 

of the cumulative method, and (2) include the HOME program in the next annual improper payment risk assessment 

and ensure that the impact of the cumulative method to meet commitment deadlines is included in the risk 

assessment process to evaluate the susceptibility to significant improper payments.

HUD disagreed with recommendations 12A and 12B and believed that it would be impossible to retroactively 

calculate in a financially supportable manner how HOME funds might have been disbursed and used under 

alternative cumulative commitment rules. Additionally, HUD believed that based on GAO guidance, it was the 

legally appropriate choice to implement these changes prospectively, which includes determining the impact of any 

changes in behavior by the grantee to ensure maximum use and to avoid recapture due to any instances of 

noncompliance against commitment requirements. HUD stated that it planned to seek assistance from a subjectmatter expert to reevaluate the risk assessment process and also argued that the HOME program is already included 

in its risk assessment, since all of HUD’s programs are required to be included in that process. 

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On September 20, 2016, OIG referred the disagreement on the management decisions to the Deputy Secretary for a 

decision as the departmental audit resolution official. On July 11, 2017, the Deputy Secretary provided a final 

decision on management decisions 12A and 12B. It stated that HUD could not implement a payment recapture 

audit for the HOME program for the specific purpose of trying to identify and recapture any improper payments 

made because of the continued use of the cumulative method for the reasons previously stated. Further, HUD will 

include the HOME program in its improper payment risk assessment as is required in the normal course of business, 

without consideration of the Department’s prior use of the cumulative method for the reasons previously stated. 

OIG closed the recommendations with disagreement. HUD’s fiscal year 2016, Improper Payment Risk Assessment 

Report included an evaluation of the HOME program that deemed it high risk. However, it excluded the impact of 

the cumulative method to meet commitment deadlines in the risk assessment for the HOME program. Since the 

cumulative method was excluded from the risk assessment, it was also excluded from the analysis to determine 

whether a recapture audit for the HOME program should be performed. In addition, OIG has not been provided 

with a detailed assessment of the extensive work needed for CPD to estimate the amount of funds that would be 

recaptured due to use of the cumulative versus noncumulative method for commitment requirements. While OIG

acknowledges that the fiscal year 2017 appropriations act suspended the 24-month commitment requirement for 

deadlines in 2016 through 2019, resulting in recaptures not being performed, this law was passed after the fiscal 

year 2016 improper payment risk assessment was performed, and HUD had no knowledge that the suspension of the 

commitment requirement would occur. Therefore, OIG believes the impact of the cumulative method versus the 

noncumulative method should have been considered in the fiscal year 2016 assessment and consideration of 

recapture audits should have been made. Additionally, despite the suspension, OIG is unsure of HUD’s treatment of 

the cumulative method for 2020 and beyond. Therefore, OIG believes HUD did not fully address the 

recommendation at the time the fiscal year 2016 improper payment risk assessment was conducted, as the Deputy 

Secretary’s decision implies. 

HUD Did Not Account for Assets and Liabilities in Its Public and Indian Housing Programs in Accordance With 

GAAP and FFMIA

During HUD’s fiscal year 2015 financial statement audit, OIG determined that invested Indian Housing Block 

Grants (IHBG) were not properly recorded and presented on HUD’s financial statements in accordance with GAAP, 

resulting in misstatements on HUD’s financial statements. Specifically, HUD did not record an advance for the 

funds it disbursed to grantees for investment in advance of programmatic expenses. 

OIG made four recommendations to (1) evaluate the IHBG investment process and implement a proper accounting 

treatment in accordance with Federal GAAP, (2) work with the Office of Native American Programs to calculate the 

amounts advanced to grantees and restate HUD’s financial statements to recognize the prepayments on the financial 

statements, (3) develop standard operating procedures for routinely obtaining information on grantee investment 

activity and accurately reporting amounts in HUD’s general ledger and financial statements, and (4) develop a 

tracking function for the payments advanced to IHBG recipients to facilitate financial reporting and monitoring 

compliance with grant time restrictions. OCFO and PIH disagreed with all four recommendations and used a 

combination of litigation, the Red book, and program regulations to support their position. However, HUD’s 

position was not supported by GAAP. HUD’s position centered solely on the fact that grantees are allowed to keep 

the interest earned on investments and that the Native American Housing Assistance and Self Determination Act 

(NAHASDA) regulations allow for investing. Therefore, HUD believes the recognition of the expense should occur 

when the funds are provided to the grantee. This position does not justify that advanced funds held for investment 

should be expensed at the time of the advance and is not supported by GAAP. According to the American Institute 

of Certified Public Accountants’ Statement of Federal Financial Standards (SFFAS) 1, “advances are cash outlays 

made by a Federal entity to its employees, contractors, grantees, or others to cover a part or all of the receipts’ 

anticipated expenses or as advance payments for the good and services the entity acquires.” Additionally, 

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NAHASDA, Section 204, does not say that investing is a program purpose. Instead, it states, “A recipient may 

invest grant amounts for the purposes of carrying out affordable housing activities in investment securities and 

other obligations as approved by the Secretary.” In other words, while the tribes are allowed to invest, the end goal 

is to achieve the purpose of the Act, which is carrying out affordable housing activities. OIG does not believe the 

purpose of the program was for money to sit in an investment account. To achieve all of the purposes outlined in 

Section 204, the invested funds must be used. Therefore, the expense occurs when the grantee uses the money on 

an eligible activity and should be recognized as an advance before that event, as described in SFFAS 1.

OIG referred the disagreement to the Deputy Chief Financial Officer and Principal Deputy Assistant Secretary for 

Public and Indian Housing on April 21, 2016, and after receiving no response, OIG referred it to the Deputy 

Secretary on September 20, 2016, for a decision.

While these recommendations were awaiting the Deputy Secretary’s decision, HUD’s OCFO resubmitted a 

management decision on March 29, 2017, including an analysis of tribal investments using accounting standards. 

OIG’s evaluation determined that while it did consider accounting standards, it contained fundamental flaws. HUD 

argues that IHBG investments are not assets because they do not meet the following essential characteristics: (1) it 

embodies economic benefits or services that can be used in the future, and (2) the government controls access to 

those economic benefits or services and can obtain or deny or regulate the access to those benefits or services. 

However, OIG determined that (1) the investments do embody economic benefit or service because HUD receives 

its economic benefit or service when the investments are spent on an activity that fulfills HUD’s mission, whereas 

money sitting in an investment account does not fulfill HUD’s mission, and (2) HUD controls access to the 

economic benefits through regulations over the investments, a depository agreement, and regulations on how the 

funds are spent once the investment period is over. These controls are put into place to ensure that HUD will 

receive its economic benefit. While NAHASDA permits investing, it is not a primary objective, and to achieve any 

of the primary objectives, funds must be pulled from the investment account and spent on eligible activities. 

Therefore, OIG rejected this management decision.

On July 11, 2017, the Deputy Secretary provided a final decision, which concluded that since investment is an 

authorized program purpose, HUD’s accounting treatment is correct. The Deputy Secretary did not include any 

reference to GAAP to support the decision. Therefore, OIG does not believe an informed decision was made on this 

issue. 

OIG closed the recommendations with disagreement. As stated above, OIG disagrees with this decision because 

HUD did not adequately evaluate the IHBG program regulations and requirements against GAAP. A professional 

accounting judgement can be made only in the context of the applicable accounting framework, accounting 

standards, or other relevant literature. This decision does not show evidence to support that the accounting 

framework and accounting standards were considered in the decision. It seems that the decision was based solely 

on reference to the GAO Red Book, section 204(b) of NAHASDA, and 24 CFR 1000.58(a). (Audit Report: 2016-

FO-0003) 

FEDERAL FINANCIAL MANAGEMENT IMPROVEMENT ACT OF 1996

In fiscal year 2017, OIG noted continued noncompliance with the three section 803(a) elements of FFMIA within 

HUD’s financial management system. HUD’s continued noncompliance is due to a high volume of material 

weaknesses, ineffective internal controls over financial reporting, and longstanding issues related to legacy 

component and program office system weaknesses that remain unresolved. 

Section 804 of FFMIA requires OIG to report in its Semiannual Reports to Congress instances and reasons when an 

agency has not met the intermediate target dates established in its remediation plan required by FFMIA. Section 

803(a) of FFMIA requires that each agency establish and maintain financial management systems that comply with 

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(1) Federal financial management system requirements, (2) Federal accounting standards, and (3) the USSGL at the 

transaction level. 

HUD has struggled for more than a decade to modernize outdated legacy financial systems. While HUD expected 

its fiscal year 2016 transition to an FSSP to remediate instances of FFMIA noncompliance, significant financial 

management and IT governance weaknesses thwarted planned gains. HUD’s financial systems, many of which 

were developed and implemented before the issuance of current standards, were not designed to provide the range 

of financial and performance data currently required. In fiscal year 2017, HUD took the important step of restarting 

FFMIA system compliance reviews. The compliance reviews, however, identified additional FFMIA 

noncompliance within three Office of Housing systems and one additional CPD system. 

During fiscal year 2017, HUD made limited progress in addressing a multitude of material weaknesses from OIG’s 

fiscal year 2016 financial statement audit. HUD’s material weaknesses include issues related to information 

processing and the completeness and accuracy of data between HUD’s environment, the OCFO NCIS, and the FSSP 

environment. HUD’s implementation of OMB Circular A-123, appendix A, review results this year concluded that 

unresolved material weaknesses previously cited by OIG require a statement of “no assurance” that internal controls 

are in place and operating effectively. HUD will need to address weaknesses related to its IT governance and 

project management practices to remediate system noncompliance with FFMIA.

Additional unremediated prior-year noncompliance with FFMIA requirements is related to CPD’s use of the FIFO 

method to account for grant disbursements within the IDIS application. CPD has yet to complete system 

configuration changes that will partially address FFMIA noncompliance. While CPD plans to complete system 

configuration updates in early fiscal year 2018, full remediation may not be possible for a number of years due to 

management’s decision to implement correct grant accounting prospectively, thereby enabling continued 

noncompliance with laws and regulations. 

As of September 30, 2017, OIG noted continuing FFMIA noncompliance within HUD’s Ginnie Mae component. 

Ginnie Mae’s continued noncompliance is due primarily to unremediated material weaknesses in internal control 

over financial reporting and its inability to properly account for its defaulted issuer loan portfolio and to implement 

effective controls over budgetary accounting. 

In addition to the specific financial system weaknesses identified above, unremediated material weaknesses 

stemming from a lack of systems and deficiencies related to manual processes continue to exist. 

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CHAPTER 11 – WHISTLEBLOWER PROGRAMS 

Whistleblowers play a critical role in keeping government programs honest, efficient, and accountable. The U.S. 

Department of Housing and Urban Development (HUD), Office of Inspector General (OIG), continues to ensure 

that HUD and HUD OIG employees are aware of their rights to disclose misconduct, waste, or abuse in HUD 

programs without reprisal and to assist HUD and HUD OIG employees in seeking redress when employees believe 

that they have been subject to retaliation for whistleblowing. HUD OIG also investigates complaints of 

whistleblower retaliation in government contracts and grants. 

HUD OIG’s Whistleblower Ombudsman Program works with HUD and HUD OIG employees to provide 

information on: 

• employee options for disclosing misconduct, waste, or abuse in HUD programs; 

• statutory protections for Federal employees who make such disclosures; and 

• how to file a complaint under the Whistleblower Protection Act when an employee believes 

he or she has been retaliated against for making protected disclosures. 

The HUD OIG Whistleblower Ombudsman Program continued its focus on staff training and individual assistance. 

HUD OIG employees attended mandatory whistleblower training in September 2016, in conjunction with the OIG 

annual ethics training. All HUD employees received this annual training in October 2016. The training is presented 

live and then posted on HUD’s whistleblower web page. 

Whistleblower training is also incorporated into HUD’s new employee training. HUD OIG’s Whistleblower 

Ombudsman also provided information on an individual basis to several HUD and HUD OIG employees seeking to 

understand their rights and options as whistleblowers. 

Generally, HUD OIG will refer HUD employees with whistleblower retaliation complaints to the Office of Special 

Counsel. HUD OIG does not track these matters unless the Office of Special Counsel requests HUD OIG assistance 

in investigating a complaint. During this semiannual reporting period, HUD OIG did not investigate any 

whistleblower retaliation complaints by HUD employees. 

HUD OIG did receive a number of complaints filed under 41 U.S.C (United States Code) 4712. In December 2016, 

Congress passed the Enhancement of Whistleblower Protection Act. It made the whistleblower protections under 

41 U.S.C. 4712 permanent. Section 4712 extends whistleblower protection to employees of Federal contractors, 

subcontractors, and grantees. If the employee of a grantee or contractor believes he or she has been retaliated 

against for whistleblowing, he or she may file a complaint with OIG, and OIG will investigate the complaint. OIG 

is required to complete its investigation within 180 days unless the complainant agrees to an extension. The chart 

below provides further information on those complaints. 

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Number of complaints received 26 

Number of complainants asserting 

whistleblower status13 26 

Complaints referred for investigation to the 

HUD OIG Office of Investigation (OI) 12 

Complaint investigations opened by OI 21 

Complaints declined by OI 0 

Complaints currently under review by OI 9 

Employee complaint investigations closed by 

OI 3 

13 14 cases were referred to the hotline and determined to not have whistleblower status. Many complainants raise questions regarding 

treatment by public housing agencies (PHA) following alleging wrongdoing by the same PHA. They define themselves as 

whistleblowers but are not employees of the PHA. These complaints are referred to OIG’s hotline for appropriate referral and 

disposition. 

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APPENDIX 1 – PEER REVIEW REPORTING

OFFICE OF AUDIT

BACKGROUND

The Dodd-Frank Wall Street Reform and Consumer Protection Act (Public Law 111-203), section 989C, requires 

inspectors general to report the latest peer review results in their semiannual reports to Congress. The purpose in 

doing so is to enhance transparency within the government. Both the Office of Audit and Office of Investigation are 

required to undergo a peer review of their individual organizations every 3 years. The purpose of the review is to 

ensure that the work completed by the respective organizations meets the applicable requirements and standards. 

The following is a summary of the status of the latest round of peer reviews for the organization. 

PEER REVIEW CONDUCTED ON HUD OIG

The U.S. Department of Housing and Urban Development, Office of Inspector General (HUD OIG), received a 

grade of pass (the highest rating) on the peer review report issued by the Treasury’s Inspector General for Tax 

Administration on September 30, 2015. There were no recommendations included in the System Review Report. 

The report stated: 

In our opinion, the system of quality control for the audit organization of the HUD OIG in effect for the year ended 

March 31, 2015, has been suitably designed and complied with to provide the HUD OIG with reasonable assurance 

of performing and reporting in conformity with applicable professional standards in all material respects. Audit 

organizations can receive a rating of pass, pass with deficiencies, or fail. The HUD OIG has received a peer review 

rating of pass. 

PEER REVIEW CONDUCTED BY HUD OIG ON USPS OIG

HUD OIG conducted an external peer review of the United States Postal Service (USPS) OIG, Office of Audit, and 

issued a final report September 22, 2015. USPS OIG received a peer review rating of pass. A copy of the external 

quality control review report can be viewed at https://www.uspsoig.gov/sites/default/files/document-libraryfiles/2015/2015_HUD-OIG_System_Review_Report.pdf.

OFFICE OF INVESTIGATION

PEER REVIEW CONDUCTED ON HUD OIG BY DHS OIG

The U.S. Department of Homeland Security (DHS) OIG conducted a peer review of the HUD OIG, Office of 

Investigation, and issued a final report on July 3, 2017. DHS OIG determined that HUD OIG was in compliance 

with the quality standards established by the Council of the Inspectors General on Integrity and Efficiency and the 

Attorney General’s guidelines.

PEER REVIEW CONDUCTED BY HUD OIG ON USDA OIG

HUD OIG conducted an external peer review of the U.S. Department of Agriculture (USDA) OIG, Office of 

Investigation, and issued a final report on October 4, 2016. HUD OIG determined that USDA OIG was in 

compliance with the quality standards established by the Council of the Inspectors General on Integrity and 

Efficiency.

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APPENDIX 2 – AUDIT REPORTS ISSUED

Internal Reports

AUDIT REPORTS

CHIEF FINANCIAL OFFICER

2017-DP-0003 New Core Project: Although Transaction Processing Had Improved Weaknesses Remained, 

09/28/2017.

2017-FO-0006 HUD Did Not Comply With the Improper Payments Elimination and Recovery Act of 2010, 

05/11/2017.

2017-KC-0009 Some HUD Employees Used Travel Cards for Potentially Improper Purchases and Purchase Cards 

Without All Required Approvals, 09/26/2017. Questioned: $555,337. Unsupported: $555,337.

2017-LA-0005 HUD Did Not Always Follow Applicable Requirements When Forgiving Debts and Terminating 

Debt Collections, 09/21/2017. Questioned: $1,210,278. Better use: $3,247,078.

COMMUNITY PLANNING AND DEVELOPMENT 

2017-AT-0001

HUD’s Oversight of Section 108 Loans Was Not Adequate To Ensure Compliance With Program 

Requirements, 04/27/2017. Questioned: $15,889,000. Unsupported: $15,889,000. Better use: 

$8,694,000.

2017-FW-0001

HUD’s Office of Community Planning and Development Did Not Appropriately Assess State 

CDBG Grantees’ Risk to the Integrity of CPD Programs or Adequately Monitor Its Grantees, 

07/10/2017.

2017-KC-0004 CPD Did Not Follow the Departmental Clearance Process When It Issued the July 25, 2013, 

Guidance for Duplication of Benefits Requirements, 06/02/2017.

2017-LA-0006

HUD Did Not Administer Economic Development Initiative – Special Project and Neighborhood 

Initiative Congressional Grants in Accordance With Program Requirements, 09/21/2017. 

Questioned: $4,530,560. Unsupported: $4,187,560.

2017-NY-0002

HUD Could Improve Its Controls Over the Disposition of Real Properties Assisted With 

Community Development Block Grant Funds, 09/29/2017. Questioned: $1,078,813. 

Unsupported: $1,078,813.

2017-PH-0001 HUD Can Improve Its Oversight of Community Development Block Grant Direct HomeOwnership Assistance Activities, 09/05/2017. Questioned: $227,260. Unsupported: $227,260.

2017-PH-0002 HUD Did Not Provide Sufficient Guidance and Oversight To Ensure That State Disaster Grantees 

Followed Proficient Procurement Processes, 09/22/2017.

GOVERNMENT NATIONAL MORTGAGE ASSOCIATION

2017-KC-0008 Ginnie Mae Did Not Adequately Respond to Changes in Its Issuer Base, 09/21/2017.

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HOUSING

2017-AT-1012 JPMorgan Chase Complied with the Market Rate Requirement for FHA Home Affordable 

Modification Program Stand-Alone Partial Claims, 09/15/2017.

2017-BO-1005 Health Concepts Ltd’s., Providence, RI, Service Charges at Section 232 Program Nursing Homes 

Did Not Always Comply With Management Agreements, 04/21/2017.

2017-CH-1004

Alpine First Preston Joint Venture II, LLC, Alpine, UT, Did Not Always Comply With Its 

Contract With HUD and Its Own Requirements for the Marketing and Sale of HUD-Owned 

Properties in the State of IL, 08/11/2017.

2017-CH-1005

Stone Terrace Apartments, Chicago, IL, Did Not Always Comply With HUD’s Requirements 

Regarding the Administration of Its Section 8 Housing Assistance Payments Program, 08/25/2017. 

Questioned: $91,710. Unsupported: $6,444. Better Use: $76,673.

2017-CH-1006 The Cooperative and Management Agent Lacked Adequate Controls Over the Operation of 

Lakeview East Cooperative, Chicago, IL, 09/05/2017. Better Use: $18,149,023.

2017-CH-1009

The Owner and Management Agents Lacked Adequate Controls Over the Operation of Mary Scott 

Nursing Center, Dayton, OH, 09/30/2017. Questioned: $1,201,133. Unsupported: $260,785. Better 

Use: $1,976,621.

2017-CH-1011

BLM Companies LLC, Hurricane, UT, Did Not Provide Property Preservation and Protection 

Services in Accordance With Its Contract With HUD and Its Own Requirements, 09/30/2017. 

Questioned: $25,805. Better Use: $594,000.

2017-DE-1003 Baker Tower, Denver, CO, Incorrectly Disbursed Funds and Did Not Correctly Administer the 

Project’s Security Deposit Account, 09/21/2017. Questioned: $15,000.

2017-FW-1009

Beverly Place Apartments, Groves, TX, Subsidized Nonexistent Tenants, Unqualified Tenants, 

and Tenants With Questionable Qualifications, 06/29/2017. Questioned: $802,633. Unsupported:

$227,703.

2017-FW-1011

BLM Companies LLC Failed To Ensure That It Protected and Preserved HUD Properties Under 

Its Field Service Manager Contract for Area 1D, 08/29/2017. Questioned: $496,917. Unsupported: 

$488,883. Better Use: $891,000.

2017-LA-1004

Cypress Meadows Assisted Living, Antioch, CA, Was Not Administered in Accordance With Its 

Regulatory Agreement and HUD Requirements, 06/13/2017. Questioned: $1,327,321. 

Unsupported: $65,232. Better Use: $412,723.

2017-NY-1011 MB Financial Bank, Rosemont, IL, Did Not Always Follow HUD's Underwriting Requirements 

but Generally Complied With Quality Control Requirements, 09/20/2017. Better Use: $178,811.

2017-PH-1003

The Yorkville Cooperative, Fairfax, VA, Did Not Administer Its HUD-Insured Property and 

Housing Assistance Contract According to Applicable Requirements, 05/22/2017. Questioned: 

$2,151,638. Unsupported: $1,850,959.

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2017-PH-1006

The Owner of Schwenckfeld Manor, Lansdale, PA, Did Not Always Manage Its HUD-Insured 

Property in Accordance With Applicable HUD Requirements, 09/25/2017. Questioned: 

$2,478,492. Unsupported: $2,478,492.

PUBLIC AND INDIAN HOUSING

2017-KC-0007 HUD Subsidized 10,119 Units for Tenants Who Were Undercharged Flat Rents, 09/12/2017. 

Better use: $6,324,625.

2017-NY-0001 HUD PIH's Required Conversion Program Was Not Adequately Implemented, 05/18/2017. Better 

use: $75,540,916.

AUDIT-RELATED MEMORANDUMS14

CHIEF FINANCIAL OFFICER

2017-FO-0802

Independent Attestation Review: U.S. Department of Housing & Urban Development, Office of 

Special Needs Assistance Continuum of Care, Regarding Drug Control Accounting for Fiscal Year 

2016, 06/19/2017.

CHIEF PROCUREMENT OFFICER

2017-KC-0801 Limited Review of HUD Government Purchase Card Transactions for Fiscal Year, 2017, 

09/26/2017. 

COMMUNITY PLANNING AND DEVELOPMENT 

2017-CF-0801 HUD Needs To Clarify Whether Illegal-Undocumented Aliens Are Eligible for Assistance Under 

the Housing Opportunities for Persons With AIDS Program, 08/21/2017.

14 The memorandum format is used to communicate the results of reviews not performed in accordance with generally accepted 

government auditing standards; to close out assignments with no findings and recommendations; to respond to requests for 

information; or to report on the results of a survey, an attestation engagement, or civil actions or settlements.

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External Reports

AUDIT REPORTS

COMMUNITY PLANNING AND DEVELOPMENT

2017-AT-1004

Neighborhood Housing Services of South Florida, Miami, FL, Did Not Ensure That NSP2 

Funds Were Used for Eligible Purposes and Sufficiently Supported, 05/08/2017. Questioned: 

$287,560. Unsupported: $228,037.

2017-AT-1005 The Miami-Dade County Homeless Trust Did Not Always Properly Administer Its Continuum 

of Care Program, 05/24/2017. Questioned: $98,433. Unsupported: $98,433.

2017-AT-1007

The City of Atlanta, GA, Did Not Properly Administer the Neighborhood Stabilization 

Program Grants for Its Subrecipient in Accordance With Requirements, 07/17/2017. 

Questioned: $48,985. Unsupported: $48,985. Better use: $248,596.

2017-AT-1008 The City of Birmingham, AL, Did Not Ensure That Adequate Policies and Procedures Were 

Implemented for Its Internal Audits and Procurement Process, 07/21/2017.

2017-AT-1009

Louisville Metro, Louisville, KY, Did Not Always Administer Its HOPWA Program in 

Accordance With HUD’s and Its Own Requirements, 07/21/2017. Questioned: $45,174. 

Unsupported: $31,157.

2017-AT-1013 The City of Chattanooga, TN, Did Not Always Administer Its ESG Program in Accordance 

With HUD’s Requirements, 09/28/2017. Questioned: $13,763. Unsupported: $13,763.

2017-AT-1014 The City of Jacksonville, FL’s HOME Investment Partnerships Program Was Not Always 

Administered in Accordance With HUD Requirements, 09/29/2017.

2017-CH-1008

Travelers Aid Society of Metropolitan Detroit, Detroit, MI, Did Not Always Administer Its 

Continuum of Care Program in Accordance With Federal Regulations, 09/28/2017. 

Questioned: $2,309,247. Unsupported: $2,308,082.

2017-CH-1010

DuPage County, IL, Did Not Always Comply With Federal Requirements Regarding the 

Administration of Its Community Development Block Grant Disaster Recovery Program, 

09/30/2017. Questioned: $98,507. Unsupported: $98,507. Better use: $569,391.

2017-FW-1004

St. Tammany Parish, Mandeville LA, Did Not Always Administer Its CDBG Disaster 

Recovery Grant in Accordance With HUD Requirements or as Certified, 04/06/2017. 

Questioned: $451,894. Unsupported: $451,894. Better use: $8,679,994.

2017-FW-1010

The City of Albuquerque, NM, Did Not Administer Its Community Development Block Grant 

Program in Accordance With Requirements, 08/16/2017. Questioned: $2,902,765. 

Unsupported: $1,067,717. Better use: $9,476.

2017-FW-1012

The City of New Orleans, New Orleans, LA, Did Not Always Properly Administer Its HOME 

Program, 09/06/2017. Questioned: $7,630,732. Unsupported: $5,800,895. Better use: 

$9,339,983.

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2017-FW-1013

The Fort Bend County Community Development Department, Richmond, TX, Did Not 

Always Comply With Office of Community Planning and Development Program 

Requirements, 09/14/2017. Questioned: $240,010. Unsupported: $240,010. Better use: 

$26,173.

2017-LA-1001

Clark County, NV, Did Not Always Use Community Development Block Grant Funds in 

Accordance With HUD Requirements, 04/13/2017. Questioned: $4,960,761. Unsupported: 

$4,841,041. Better use: $33,603.

2017-LA-1003 Mental Health Systems, Inc., San Diego, CA, Did Not Allocate Payroll Costs in Accordance 

With Requirements, 06/02/2017. Questioned: $142,181. Unsupported: $142,181.

2017-LA-1005

The City of Huntington Park, CA, Did Not Administer Its Community Development Block 

Grant Program in Accordance With Requirements, 06/16/2017. Questioned: $821,242. 

Unsupported: $813,919. Better use: $328,918.

2017-LA-1006

The City of Fresno, CA, Did Not Administer Its Community Development Block Grant in 

Accordance With HUD Requirements, 08/09/2017. Questioned: $8,073,084. Unsupported: 

$7,909,529. Better use: $428,373.

2017-LA-1008

The City of Las Vegas, NV, Did Not Administer Its Neighborhood Stabilization Program 3 

Homebuyer Assistance Program in Accordance with HUD Requirements, 09/13/2017. 

Questioned: $1,590. Better use: $500,794.

2017-NY-1009 The Lower Manhattan Development Corporation, New York, NY, Generally Disbursed 

CDBG Disaster Recovery Funds in Accordance With HUD Regulations, 06/13/2017.

2017-NY-1010

The State of New York Did Not Show That Disaster Recovery Funds Under Its Non-Federal 

Share Match Program Were Used for Eligible and Supported Costs, 09/15/2017. Questioned: 

$18,782,054. Unsupported: $18,782,054. Better use: $8,932,630.

2017-NY-1012 The City of New York, NY, Could Improve Its Invoice Review Process Before Disbursing 

Disaster Funds Under Its Public Housing Rehabilitation and Resilience Program, 09/21/2017.

2017-PH-1005 The State of New Jersey Did Not Always Disburse Disaster Funds for Its Sandy Homebuyer 

Assistance Program To Assist Eligible Home Buyers, 08/14/2017. Questioned: $987,500.

2017-SE-1001 The Washington County, OR, Department of Housing Services’ Clover Court Project Was 

Eligible For Continuum of Care Funding, 09/21/2017.

HOUSING

2017-AT-1012 JPMorgan Chase Complied with the Market Rate Requirement for FHA Home Affordable 

Modification Program Stand-Alone Partial Claims, 09/15/2017.

2017-BO-1005 Health Concepts Ltd’s., Providence, RI, Service Charges at Section 232 Program Nursing 

Homes Did Not Always Comply With Management Agreements, 04/21/2017.

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2017-CH-1004

Alpine First Preston Joint Venture II, LLC, Alpine, UT, Did Not Always Comply With Its 

Contract With HUD and Its Own Requirements for the Marketing and Sale of HUD-Owned 

Properties in the State of IL, 08/11/2017.

2017-CH-1005

Stone Terrace Apartments, Chicago, IL, Did Not Always Comply With HUD’s 

Requirements Regarding the Administration of Its Section 8 Housing Assistance Payments 

Program, 08/25/2017. Questioned: $91,710. Unsupported: $6,444. Better Use: $76,673.

2017-CH-1006 The Cooperative and Management Agent Lacked Adequate Controls Over the Operation of 

Lakeview East Cooperative, Chicago, IL, 09/05/2017. Better Use: $18,149,023.

2017-CH-1009

The Owner and Management Agents Lacked Adequate Controls Over the Operation of 

Mary Scott Nursing Center, Dayton, OH, 09/30/2017. Questioned: $1,201,133. 

Unsupported: $260,785. Better Use: $1,976,621.

2017-CH-1011

BLM Companies LLC, Hurricane, UT, Did Not Provide Property Preservation and 

Protection Services in Accordance With Its Contract With HUD and Its Own Requirements, 

09/30/2017. Questioned: $25,805. Better Use: $594,000.

2017-DE-1003 Baker Tower, Denver, CO, Incorrectly Disbursed Funds and Did Not Correctly Administer 

the Project’s Security Deposit Account, 09/21/2017. Questioned: $15,000.

2017-FW-1009

Beverly Place Apartments, Groves, TX, Subsidized Nonexistent Tenants, Unqualified 

Tenants, and Tenants With Questionable Qualifications, 06/29/2017. Questioned: $802,633. 

Unsupported: $227,703.

2017-FW-1011

BLM Companies LLC Failed To Ensure That It Protected and Preserved HUD Properties 

Under Its Field Service Manager Contract for Area 1D, 08/29/2017. Questioned: $496,917. 

Unsupported: $488,883. Better Use: $891,000.

2017-LA-1004 

Cypress Meadows Assisted Living, Antioch, CA, Was Not Administered in Accordance 

With Its Regulatory Agreement and HUD Requirements, 06/13/2017. Questioned: 

$1,327,321. Unsupported: $65,232. Better Use: $412,723.

2017-NY-1011

MB Financial Bank, Rosemont, IL, Did Not Always Follow HUD's Underwriting 

Requirements but Generally Complied With Quality Control Requirements, 09/20/2017. 

Better Use: $178,811.

2017-PH-1003

The Yorkville Cooperative, Fairfax, VA, Did Not Administer Its HUD-Insured Property 

and Housing Assistance Contract According to Applicable Requirements, 05/22/2017. 

Questioned: $2,151,638. Unsupported: $1,850,959.

2017-PH-1006

The Owner of Schwenckfeld Manor, Lansdale, PA, Did Not Always Manage Its HUDInsured Property in Accordance With Applicable HUD Requirements, 09/25/2017. 

Questioned: $2,478,492. Unsupported: $2,478,492.

PUBLIC AND INDIAN HOUSING

2017-AT-1006

The Housing Authority of DeKalb County, Decatur, GA, Generally Administered RAD 

Appropriately but Did Not Accurately Report on Its Capital Fund Program, 06/09/2017. 

Better use: $1,157,864.

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2017-AT-1010

The Louisville Metro Housing Authority, Louisville, KY, Did Not Comply With HUD’s and 

Its Own Section 8 Housing Choice Voucher Program Requirements, 08/04/2017. Questioned: 

$73,484. Better use: $20,566,345.

2017-AT-1011

The Lexington Housing Authority, Lexington, NC, Did Not Administer Its RAD Conversion 

in Accordance With HUD Requirements, 08/21/2017. Questioned: $2,751,164. 

Unsupported: $2,745,252.

2017-BO-1004 The Boston Housing Authority, Boston, MA, Housed Eligible Tenants and Correctly 

Calculated Voucher Subsidies, 04/05/2017.

2017-BO-1006

The West Warwick Housing Authority, West Warwick, RI, Needs To Improve Its Compliance 

With Federal Regulations for Its Housing Choice Voucher and Public Housing Programs, 

08/18/2017. Questioned: $2,089,134. Unsupported: $2,086,382. Better use: $6,100.

2017-BO-1007

The Housing Authority of the City of Hartford, CT, Did Not Always Comply With 

Procurement Requirements, 09/21/2017. Questioned: $4,057,981. Unsupported: $2,533,377. 

Better use: $1,617,680.

2017-CH-1002

The Youngstown Metropolitan Housing Authority, Youngstown, OH, Did Not Always 

Comply With HUD’s and Its Own Requirements Regarding the Administration of Its Housing 

Choice Voucher Program, 07/07/2017. Questioned: $481,063. Unsupported: $413,278. 

Better use: $529,150.

2017-CH-1003

The Housing Authority of the City of Hammond, Hammond, IN, Did Not Always Comply 

With HUD’s Requirements Regarding the Administration of Its Housing Choice Voucher 

Program, 07/14/2017. Questioned: $53,207. Unsupported: $2,843. Better use: $35,548.

2017-CH-1007

The Menard County Housing Authority, Petersburg, IL, Did Not Comply With HUD’s and Its 

Own Requirements Regarding the Administration of Its Housing Choice Voucher Program, 

09/28/2017. Questioned: $901,594. Unsupported: $360,770. Better use: $117,494.

2017-DE-1002 The Denver Housing Authority, Denver, CO, Generally Complied With Procurement 

Regulations, 08/18/2017.

2017-FW-1005

The Hammond Housing Authority’s, Hammond, LA, Administration of Its Housing Choice 

Voucher Program Had Weaknesses, 04/25/2017. Questioned: $34,374. Unsupported: 

$30,183.

2017-FW-1006

The Housing Authority of the City of Jasper, TX, Did Not Operate Its Public Housing 

Programs in Compliance With HUD’s Requirements, 04/26/2017. Questioned: $91,956. 

Unsupported: $45,646.

2017-FW-1007 The Housing Authority of the City of Tulsa, Tulsa, OK, Did Not Always Correctly Compute 

Housing Assistance Payments, 05/17/2017. Questioned: $41,313. Unsupported: $28,574.

2017-FW-1008

The Weslaco Housing Authority, Weslaco, TX, Paid Travel Costs That Did Not Comply With 

Federal, State, and Local Requirements, 06/28/2017. Questioned: $23,138. Unsupported: 

$9,020.

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2017-KC-1003

Majestic Management, LLC, St. Louis, MO, a Management Agent for the East St. Louis 

Housing Authority, Mismanaged Its Public Housing Program, 09/26/2017. Questioned: 

$1,165,110. Unsupported: $1,055,445.

2017-LA-1002

The Inglewood Housing Authority, Inglewood, CA, Generally Ensured the Eligibility of Its 

Housing Choice Voucher Program Participants, 05/11/2017. Questioned: $84. Better use: 

$648.

2017-LA-1007

The Chukchansi Indian Housing Authority, Oakhurst, CA, Did Not Always Follow HUD’s 

Requirements for Its Indian Housing Block Grant Program, 08/24/2017. Questioned: 

$1,747,206. Unsupported: $1,747,206. Better use: $248,222.

2017-NY-1013

The New Brunswick Housing Authority, NJ, Did Not Always Administer Its Operating and 

Capital Funds In Accordance With HUD Requirements, 09/28/2017. Questioned: 

$1,431,873. Unsupported: $1,205,334.

2017-PH-1004 The Loudoun County Department of Family Services, Leesburg, VA, Did Not Always Ensure 

That Its Program Units Met Housing Quality Standards, 06/09/2017. Questioned: $9,715.

2017-PH-1007 The Chester Housing Authority, Chester, PA, Did Not Always Ensure That Its Program Units 

Met Housing Quality Standards, 09/28/2017. Questioned: $46,605. Better use: $2,668,680.

2017-SE-1002

The Housing Authority of Snohomish County, Everett, WA, Did Not Always Administer Its 

Section 8 Project-Based Voucher Program in Accordance With HUD Regulations, 

09/29/2017.

AUDIT-RELATED MEMORANDUMS15

COMMUNITY PLANNING AND DEVELOPMENT

2017-AT-1802

San Sebastian Fine Arts Center, Office of the Commissioner for Municipal Affairs, San Juan, 

PR, State Block Grant Program, 09/15/2017. Questioned: $1,014,211. Unsupported: 

$1,014,211.

GENERAL COUNSEL

2017-AT-1801 Final Civil Action: Prospect Mortgage, LLC, Settled Alleged Violations of Federal Housing 

Administration Loan Requirements, 08/21/2017. Questioned: $2,930,000.

2017-CF-1804

Financial Freedom, a Division of CIT Bank, N.A., Settled Allegations of Failing To Comply 

With HUD’s Federal Housing Administration Servicing Requirements for HECM Claims, 

08/21/2017. Questioned: $41,000,000.

2017-CF-1805 First American Mortgage Trust Settled Allegations of Failing To Comply With HUD’s 

Federal Housing Administration Loan Requirements, 09/18/2017. Questioned: $250,000.

2017-CF-1806 Final Civil Action: PHH Corporation Settled Allegations of Failing To Comply With HUD’s 

Federal Housing Administration Loan Requirements, 09/28/2017. Questioned: $42,600,000.

15 The memorandum format is used to communicate the results of reviews not performed in accordance with generally accepted 

government auditing standards; to close out assignments with no findings and recommendations; to respond to requests for 

information; or to report on the results of a survey, an attestation engagement, or civil actions or settlements. 

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2017-CF-1807 Residential Home Funding Corp. Settled Allegations of Failing To Comply With HUD’s 

Federal Housing Administration Loan Requirements, 09/28/2017. Questioned: $1,670,000.

2017-PH-1802

Final Civil Action Borrower Settled Allegations of Making False Statements to HUD for a 

Home Purchase Under the Federal Housing Administration Mortgage Insurance Program, 

06/28/2017. Questioned: $10,000.

HOUSING

2017-LA-1801 Venta Financial Group, Inc., Las Vegas, NV, Improperly Originated FHA-Insured Loans With 

Restrictive Covenants, 09/20/2017. Questioned: $5,482. Better Use: $418,277.

2017-LA-1802

SecurityNational Mortgage Company, Las Vegas, NV, Improperly Originated FHA Loans for 

Properties With Restrictive Covenants, 09/22/2017. Questioned: $26,472. Better use: 

$381,823.

2017-LA-1803 RMS & Associates, Las Vegas, NV, Improperly Originated FHA-Insured Loans With 

Restrictive Covenants, 09/28/2017. Questioned: $26,242. Better use: $2,434,204.

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APPENDIX 3 – TABLES 

TABLE A

AUDIT REPORTS ISSUED BEFORE START OF PERIOD WITH NO MANAGEMENT 

DECISION AT 9/30/2017 

*Significant audit reports described in previous Semiannual Reports

REPORT NUMBER AND TITLE REASON FOR LACK OF MANAGEMENT 

DECISION ISSUE DATE

* 2014-FO-0003 Additional Details To Supplement

Our Report On HUD's Fiscal Years 2013 and 2012

(Restated) Financial Statements

See chapter 10, page 41 12/16/2013

* 2014-FO-0004 HUD’s Fiscal Year 2013

Compliance With the Improper Payments

Elimination and Recovery Act of 2010

See chapter 10, page 42 04/15/2014

* 2014-LA-0005 HUD Did Not Always Recover

FHA Single-Family Indemnification Losses and

Ensure That Indemnification Agreements Were

Extended

See chapter 10, page 43 08/08/2014

* 2015-FO-0003 Audit of the Government National

Mortgage Association’s Financial Statements for

Fiscal Years 2014 and 2013

See chapter 10, page 44 02/27/2015

* 2016-FO-0001 Audit of Fiscal Years 2015 and

2014 (Restated) Financial Statements See chapter 10, page 44 11/13/2015

* 2016-FO-0003 Additional Details To Supplement

Our Fiscal Years 2015 and 2014 (Restated) U.S.

Department of Housing and Urban Development

Financial Statement Audit

See chapter 10, page 45 11/18/2015

* 2016-PH-0001 HUD Did Not Always Provide

Adequate Oversight of Property Acquisition and

Disposition Activities

See chapter 10, page 46 06/30/2016

* 2016-FO-0802 Independent Attestation Review:

U.S. Department of Housing and Urban

Development, DATA Act Implementation Efforts

See chapter 10, page 47 08/26/2016

* 2016-PH-0005 HUD Did Not Always Provide

Accurate and Supported Certifications of State

Disaster Grantee Procurement Processes

See chapter 10, page 48 09/29/2016

* 2017-FO-0001 Audit of Fiscal Years 2016 and

2015 (Restated) Financial Statements See chapter 10, page 49 11/14/2016

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SEMIANNUAL REPORT TO CONGRESS

REPORT NUMBER AND TITLE REASON FOR LACK OF MANAGEMENT 

DECISION ISSUE DATE

* 2017-FO-0003 Additional Details To Supplement

Our Fiscal Years 2016 and 2015 (Restated) U.S.

Department of Housing and Urban Development

Financial Statement Audit

See chapter 10, page 50 11/15/2016

* 2017-DP-0001 HUD's Transition to a Federal Shared

Service Provider Failed To Meet Expectations

See chapter 10, page 50 02/01/2017

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TABLE B

SIGNIFICANT AUDIT REPORTS FOR WHICH FINAL ACTION HAD NOT BEEN COMPLETED 

WITHIN 12 MONTHS AFTER THE DATE OF THE INSPECTOR GENERAL’S REPORT

REPORT NUMBER REPORT TITLE ISSUE DATE DECISION 

DATE FINAL ACTION

2005-AT-1013

Corporacion para el Fomento Economico 

de la Ciudad Capital, San Juan, Puerto 

Rico, Did Not Administer Its Independent 

Capital Fund in Accordance with HUD 

Requirements

09/15/2005 01/11/2006 Note 1

2007-AT-1010

The Cathedral Foundation of Jacksonville, 

FL, Used More Than $2.65 Million in 

Project Funds for Questioned Costs

08/14/2007 12/03/2007 Note 2

2009-NY-1012

The City of Rome Did Not Administer Its 

Economic Development Activity in 

Accordance With HUD Requirements, 

Rome, NY

05/20/2009 09/23/2009 01/30/2032

2009-CH-1011

The Housing Authority of the City of Terre 

Haute Failed To Follow Federal 

Requirements and Its Employment 

Contract Regarding Nonprofit 

Development Activities, Terre Haute, IN

07/31/2009 11/24/2009 Note 2

2009-AT-0001

HUD Lacked Adequate Controls to Ensure 

the Timely Commitment and Expenditure 

of HOME funds

09/28/2009 03/18/2011 Note 1

2010-AT-1003

The Housing Authority of Whitesburg 

Mismanaged Its Operations, Whitesburg, 

KY

04/28/2010 08/26/2010 11/29/2035

2010-PH-1008

Sasha Bruce Youthwork, Incorporated, Did 

Not Support More Than $1.9 Million in 

Expenditures, Washington, DC

05/11/2010 11/03/2010 Note 2

2010-CH-1008

The DuPage Housing Authority 

Inappropriately Administered Its Section 8 

Project-Based Voucher Program, Wheaton, 

IL

06/15/2010 10/08/2010 10/31/2017

2011-FO-0003

Additional Details to Supplement Our 

Report on HUD's Fiscal Years 2010 and 

2009 Financial Statements

11/15/2010 08/08/2011 Note 1

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REPORT NUMBER REPORT TITLE ISSUE DATE DECISION 

DATE FINAL ACTION

2011-PH-1005

The District of Columbia Did Not 

Administer Its HOME Program in 

Accordance With Federal Requirements, 

Washington, DC

12/23/2010 04/22/2011 Note 1

2011-CH-1006

The DuPage Housing Authority 

Inappropriately Administered Its Section 8 

Housing Choice Voucher Program, 

Wheaton, IL

03/23/2011 07/28/2011 10/31/2017

2011-AT-1006

The Municipality of Mayaguez Did Not 

Ensure Compliance With HOME Program 

Objectives, Mayaguez, PR

04/08/2011 08/05/2011 03/02/2018

2011-NY-1010

The City of Buffalo Did Not Always 

Administer Its CDBG Program in 

Accordance With HUD Requirements, 

Buffalo, NY

04/15/2011 01/25/2012 Note 2

2011-AT-1018

The Municipality of San Juan Did Not 

Properly Manage Its HOME Investment 

Partnerships Program, San Juan, PR

09/28/2011 01/12/2012 09/12/2018

2012-NY-1002

The City of New York Charged 

Questionable Expenditures to Its HPRP, 

New York, NY

10/18/2011 02/16/2012 Note 1

2012-PH-0001

HUD Needed To Improve Its Use of Its 

Integrated Disbursement and Information 

System To Oversee Its CDBG Program

10/31/2011 02/28/2012 Note 1

2012-LA-0001

HUD Did Not Adequately Support the 

Reasonableness of the Fee-for-Service 

Amounts or Monitor the Amounts Charged

11/16/2011 03/27/2012 12/31/2017

2012-AT-1009

The Municipality of Bayamón Did Not 

Always Ensure Compliance With HOME 

Investment Partnerships Program 

Requirements, Bayamon, PR

05/23/2012 09/18/2012 Note 1

2012-PH-1011

Prince George’s County Generally Did Not 

Administer Its HOME Program in 

Accordance With Federal Requirements, 

Largo, MD

08/03/2012 11/30/2012 Note 1

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REPORT NUMBER REPORT TITLE ISSUE DATE DECISION 

DATE FINAL ACTION

2012-CH-1012

The Saginaw Housing Commission Did 

Not Always Administer Its Section 8 

Housing Choice Voucher Program in

Accordance With HUD’s and Its Own 

Requirements, Saginaw, MI

09/27/2012 01/07/2013 01/01/2023

2012-CH-1013

The Flint Housing Commission Did Not 

Always Administer Its Grants in 

Accordance With Recovery Act, HUD’s, 

and Its Own Requirements, Flint, MI

09/27/2012 01/24/2013 01/31/2018

2013-PH-1001

Luzerne County Did Not Properly 

Evaluate, Underwrite, and Monitor a HighRisk Loan, Wilkes-Barre, PA10/31/2012 01/31/2013 Note 1

2013-FO-0003

Additional Details To Supplement Our 

Report on HUD’s Fiscal Years 2012 and 

2011 Financial Statements

11/15/2012 05/15/2013 Note 1 

2013-LA-1003

Bay Vista Methodist Heights Violated Its 

Agreement With HUD When 

Administering Its Trust Funds, San Diego, 

CA

03/14/2013 05/15/2013 Note 1

2013-AT-1003

The Municipality of Arecibo Did Not 

Always Ensure Compliance With CDBG 

Program Requirements, Arecibo, PR

03/22/2013 06/14/2013 Note 1

2013-FW-1004

The Housing Authority of the City of El 

Paso Did Not Follow Recovery Act 

Obligation Requirements or Procurement 

Policies, El Paso, TX

04/12/2013 08/27/2013 07/10/2018

2013-NY-1006

Nassau County Did Not Administer It's 

HOME Investment Partnerships Program in 

Accordance With HUD Requirements, 

Nassau County, NY

05/13/2013 09/06/2013 Note 1

2013-KC-0002

HUD Did Not Enforce the Reporting 

Requirements of Section 3 of the Housing 

and Urban Development Act of 1968 for 

Public Housing Authorities

06/26/2013 10/24/2013 Note 1

2013-LA-1009

The City of Hawthorne Inappropriately 

Used Nearly $1.6 Million in HOME Funds 

for Section 8 Tenants, Hawthorne, CA

09/13/2013 01/06/2014 Note 1

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SEMIANNUAL REPORT TO CONGRESS

REPORT NUMBER REPORT TITLE ISSUE DATE DECISION 

DATE FINAL ACTION

2013-LA-1010

The City of Hawthorne Did Not Administer 

Its CDBG Program Cost Allocations in 

Accordance With HUD Rules and 

Requirements, Hawthorne, CA

09/20/2013 01/06/2014 Note 1

2013-FW-1805

The Malakoff Housing Authority Did Not 

Have Sufficient Controls Over Its Public 

Housing Programs, Including Its Recovery 

Act Funds, Malakoff, TX

09/26/2013 12/19/2013 04/30/2036

2013-NY-1010

The City of Auburn Did Not Always 

Administer Its CDBG Program in 

Accordance With HUD Requirements, 

Auburn, NY

09/26/2013 01/24/2014 Note 1

2013-CH-1009

The Flint Housing Commission Did Not 

Always Administer Its Grant in 

Accordance With Recovery Act, HUD’s, 

and Its Own Requirements, Flint, MI

09/27/2013 01/14/2014 04/30/2018

2013-CH-1010

The City of Toledo Did Not Always 

Administer Its CDBG-R Program in 

Accordance With HUD’s and Its Own 

Requirements, Toledo, OH

09/30/2013 01/15/2014 Note 1

2013-CH-1011

The Michigan State Housing Development 

Authority Did Not Follow HUD’s 

Requirements Regarding the 

Administration of Its Program, Lansing, MI

09/30/2013 01/15/2014 07/31/2029

2013-CH-1012

The Hamtramck Housing Commission Did 

Not Administer Its Grant in Accordance 

With Recovery Act, HUD’s, and Its Own 

Requirements, Hamtramck, MI

09/30/2013 01/21/2014 04/30/2018

2013-DE-1005

The Jefferson County Housing Authority 

Did Not Properly Use Its Disposition Sales 

Proceeds, Wheat Ridge, CO

09/30/2013 01/24/2014 02/28/2020

2014-AT-1001

The Municipality of Arecibo Did Not 

Properly Administer Its HOME Program, 

Arecibo, PR

12/03/2013 01/24/2014 Note 1

2014-FO-0001

Government National Mortgage 

Association Fiscal Years 2013 and 2012 

Financial Statements Audit

12/06/2013 05/02/2014 Note 1

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REPORT NUMBER REPORT TITLE ISSUE DATE DECISION 

DATE FINAL ACTION

2014-FO-0002

Federal Housing Administration Fiscal 

Years 2013 and 2012 Financial Statements 

Audit

12/13/2013 04/14/2014 Note 1

2014-FO-0003

Additional Details To Supplement Our 

Report On HUD's Fiscal Years 2013 and 

2012 (Restated) Financial Statements

12/16/2013 07/09/2014 Note 3

2014-PH-1001 The City of Norfolk Generally Failed To 

Justify Its CDBG Activities, Norfolk, VA 12/17/2013 04/16/2014 Note 1

2014-AT-1004

The State of Mississippi Did Not Ensure 

That Its Subrecipient and Appraisers 

Complied With Requirements, and It Did 

Not Fully Implement Adequate Procedures 

For Its Disaster Infrastructure Program, 

Jackson, MS

12/30/2013 04/15/2014 Note 1

2014-CH-1002

The City of Detroit Lacked Adequate 

Controls Over Its Neighborhood 

Stabilization Program-Funded Demolition 

Activities Under the Housing and 

Economic Recovery Act of 2008, Detroit, 

MI

01/06/2014 05/05/2014 Note 2 

2014-FW-0001

The Boston Office of Public Housing Did 

Not Provide Adequate Oversight of 

Environmental Reviews of Three Housing 

Agencies, Including Reviews Involving 

Recovery Act Funds

02/07/2014 03/17/2015 12/31/2018

2014-NY-0001

HUD Did Not Provide Effective Oversight 

of Section 202 Multifamily Project 

Refinances

02/19/2014 06/10/2014 Note 1

2014-AT-0001

Violations Increased the Cost of Housing’s 

Administration of Its Bond Refund 

Program

03/14/2014 07/11/2014 Note 1

2014-AT-1801

Vieques Sports City Complex, Office of 

the Commissioner for Municipal Affairs, 

Section 108 Loan Guarantee Program, San 

Juan, PR

03/20/2014 07/11/2014 Note 1

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SEMIANNUAL REPORT TO CONGRESS

REPORT NUMBER REPORT TITLE ISSUE DATE DECISION 

DATE FINAL ACTION

2014-FO-0004

HUD’s Fiscal Year 2013 Compliance With 

the Improper Payments Elimination and 

Recovery Act of 2010

04/15/2014 01/07/2015 Note 3

2014-CH-1003

The Hamtramck Housing Commission Did 

Not Always Administer Its Grant in 

Accordance With Recovery Act, HUD’s, or 

Its Own Requirements, Hamtramck, MI

04/30/2014 08/08/2014 04/30/2018

2014-FW-0002

Improvements Are Needed Over 

Environmental Reviews of Public Housing 

and Recovery Act Funds in the Kansas City 

Office

05/12/2014 03/17/2015 12/31/2018

2014-AT-1005

The City of Huntsville, Community 

Development Department, Did Not 

Adequately Account for and Administer 

the Mirabeau Apartments Project, 

Huntsville, AL

05/29/2014 09/23/2014 Note 1

2014-NY-1005

Financial and Administrative Control 

Weaknesses Existed in Middlesex County, 

NJ's HOME Investment Partnerships 

Program, Middlesex County, NJ

06/10/2014 07/17/2014 Note 1

2014-LA-0004

HUD Could Not Support the 

Reasonableness of the Operating and 

Capital Fund Programs’ Fees and Did Not 

Adequately Monitor Central Office Cost 

Centers

06/30/2014 10/20/2014 12/31/2017

2014-KC-0002

The Data in CAIVRS [Credit Alert 

Verification Reporting System] Did Not 

Agree With the Data in FHA’s Default and 

Claims Systems

07/02/2014 10/27/2014 10/12/2018

2014-NY-1008

Palladia, Inc., Did Not Administer Its 

Supportive Housing Program in 

Accordance With HUD Requirements, 

New York, NY

07/25/2014 11/21/2014 Note 1

2014-AT-1007

The Municipality of Carolina Did Not 

Properly Administer Its HOME Program, 

Carolina, PR

08/08/2014 12/05/2014 Note 1

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SEMIANNUAL REPORT TO CONGRESS

REPORT NUMBER REPORT TITLE ISSUE DATE DECISION 

DATE FINAL ACTION

2014-LA-0005

HUD Did Not Always Recover FHA 

Single-Family Indemnification Losses and 

Ensure That Indemnification Agreements 

Were Extended

08/08/2014 12/03/2014 Note 3

2014-CH-1006

The Goshen Housing Authority Failed To 

Follow HUD’s and Its Own Requirements 

Regarding the Administration of Its 

Program, Goshen, IN

08/14/2014 01/21/2015 01/31/2018

2014-LA-1005

The City of Richmond Did Not Administer 

Its NSP (Neighborhood Stabilization 

Program) in Accordance With 

Requirements, Richmond, CA

08/22/2014 12/19/2014 11/30/2017

2014-PH-1008

The State of New Jersey Did Not Fully 

Comply With Federal Procurement and 

Cost Principle Requirements in 

Implementing Its Tourism Marketing 

Program

08/29/2014 09/02/2015 Note 1

2014-NY-0003

Asset Repositioning Fees for Public 

Housing Authorities With Units Approved 

for Demolition or Disposition Were Not 

Always Accurately Calculated

09/04/2014 12/29/2014 12/31/2020

2014-AT-1010

Miami-Dade County Did Not Always 

Properly Administer Its HOME Program, 

Miami, FL

09/11/2014 12/11/2014 Note 1

2014-NY-1009

The City of Jersey City's HOME 

Investment Partnerships Program

Administration Had Financial and 

Administrative Controls Weaknesses, City 

of Jersey City, NJ

09/18/2014 01/13/2015 Note 1

2014-FW-0005

Improvements Are Needed Over 

Environmental Reviews of Public Housing 

and Recovery Act Funds in the Detroit 

Office

09/24/2014 03/17/2015 12/31/2018

2014-LA-1007

The City of Los Angeles Did Not Always 

Ensure That CDBG-Funded Projects Met 

National Program Objectives, Los Angeles, 

CA

09/29/2014 01/27/2015 Note 2

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SEMIANNUAL REPORT TO CONGRESS

REPORT NUMBER REPORT TITLE ISSUE DATE DECISION 

DATE FINAL ACTION

2014-CH-0001

HUD Did Not Always Provide Adequate 

Oversight of Its Property-Flipping Waiver 

Requirements

09/30/2014 03/24/2015 Note 1

2015-DP-0001

Information System Control Weaknesses 

Identified in the Single Family Housing 

Enterprise Data Warehouse

10/21/2014 12/12/2014 Note 1

2015-FO-0001

Audit of the Federal Housing 

Administration's Financial Statements for 

Fiscal Years 2014 and 2013

11/14/2014 04/14/2015 Note 1

2015-NY-1001

The City of New York Did Not Always 

Disburse CDBG Disaster Recovery 

Assistance Funds to Its Subrecipient in 

Accordance With Federal Regulations, 

New York, NY

11/24/2014 03/23/2015 Note 1

2015-AT-1001

The Office of the Commissioner for 

Municipal Affairs Needs To Make 

Improvements in Administering Its Section 

108 Loan Guarantee Program, San Juan, 

PR

12/05/2014 04/03/2015 Note 1 

2015-FO-0002 Interim Report on HUD's Internal Controls 

Over Financial Reporting 12/08/2014 09/28/2015 Note 2

2015-DP-0004 Office of the Chief Financial Officer Loan 

Accounting System 12/09/2014 04/17/2015 Note 1 

2015-PH-1804

Final Civil Action Court Ordered a Former 

Executive Director of the Philadelphia 

Housing Authority To Pay Civil Penalties 

for Violating Federal Lobbying Disclosure 

Requirements and Restrictions

02/19/2015 09/13/2016 Note 2

2015-CH-1001

The Chicago Housing Authority Moving to 

Work Housing Choice Voucher Program, 

Chicago, IL

02/24/2015 06/10/2015 04/01/2018

2015-FO-0003

Audit of the Government National 

Mortgage Association’s Financial 

Statements for Fiscal Years 2014 and 2013

02/27/2015 06/25/2015 Note 3

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SEMIANNUAL REPORT TO CONGRESS

REPORT NUMBER REPORT TITLE ISSUE DATE DECISION 

DATE FINAL ACTION

2015-AT-0001

HUD’s Office of Community Planning and 

Development Did Not Always Pursue 

Remedial Actions but Generally 

Implemented Sufficient Controls for 

Administering Its Neighborhood 

Stabilization Program

03/31/2015 08/28/2015 Note 1 

2015-NY-1005

The City of Paterson, NJ's HOME 

Investment Partnerships Program Controls 

Did Not Ensure Compliance With 

Regulations

04/30/2015 06/03/2015 Note 1

2015-FO-0005 Compliance With the Improper Payments 

Elimination and Recovery Act 05/15/2015 10/02/2015 08/31/2018

2015-NY-1006

First Niagara Bank, Lockport, NY, Did Not 

Always Properly Implement HUD’s Loss 

Mitigation Requirements in Servicing 

FHA-Approved Mortgages

05/22/2015 11/19/2015 Note 2

2015-LA-1004

The Housing Authority of the County of 

San Bernardino, San Bernardino, CA, Used 

Shelter Plus Care Program Funds for 

Ineligible and Unsupported Participants

05/29/2015 09/16/2015 Note 1 

2015-PH-1003

The State of New Jersey Did Not Comply 

With Federal Procurement and Cost 

Principle Requirements in Implementing Its 

Disaster Management System

06/04/2015 10/02/2015 Note 2

2015-FW-0001

HUD Did Not Adequately Implement or 

Provide Adequate Oversight To Ensure 

Compliance With Environmental 

Requirements

06/16/2015 10/07/2015 Note 2

2015-LA-0002

HUD Did Not Provide Adequate Oversight 

of the Section 184 Indian Home Loan 

Guarantee Program

07/06/2015 10/28/2015 12/31/2017

2015-LA-1005

NOVA Financial & Investment 

Corporation’s FHA-Insured Loans With 

Downpayment Assistance Gifts Did Not 

Always Meet HUD Requirements

07/09/2015 09/11/2015 Note 2

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SEMIANNUAL REPORT TO CONGRESS

REPORT NUMBER REPORT TITLE ISSUE DATE DECISION 

DATE FINAL ACTION

2015-PH-0003

HUD Did Not Adequately Oversee 

Enhanced Vouchers Administered by New 

York Agencies

07/29/2015 10/29/2015 10/31/2017

2015-CH-0001

HUD Did Not Always Provide Adequate 

Oversight of Its Section 203(k) 

Rehabilitation Loan Mortgage Insurance 

Program

07/31/2015 11/27/2015 11/17/2017

2015-KC-0002

The Office of Community Planning and 

Development’s Reviews of Matching 

Contributions Were Ineffective and Its 

Application of Match Reductions Was Not 

Always Correct

08/11/2015 12/09/2015 Note 2

2015-AT-0002

HUD’s Office of Multifamily Asset 

Management and Portfolio Oversight Did 

Not Comply With Its Requirements For 

Monitoring Management Agents' Costs

08/21/2015 12/16/2015 Note 1

2015-AT-1008

Broward County, Fort Lauderdale, FL, Did 

Not Properly Administer One of Its 

Projects and Did Not Comply With Some 

Match Requirements

08/23/2015 10/30/2015 Note 2

2015-NY-1010

New York State Did Not Always 

Administer Its Rising Home Enhanced 

Buyout Program in Accordance With 

Federal and State Regulations

09/17/2015 03/01/2016 Note 2

2015-NY-1011

Program Control Weaknesses Lessened 

Assurance That New York Rising Housing 

Recovery Program Funds Were Always 

Disbursed for Eligible Costs

09/17/2015 03/18/2016 Note 2

2015-CH-1008

The Housing Authority of the City of South 

Bend, IN, Did Not Always Comply with

HUD Requirements and Its Own Policies 

Regarding the Administration of Its Section 

8 Housing Choice Voucher Program

09/25/2015 01/22/2016 Note 2

2015-CH-1009

The State of Illinois' Administrator Lacked 

Adequate Controls Over the State's 

Community Development Block Grant 

Disaster Recovery Program-Funded 

Projects

09/30/2015 01/28/2016 01/30/2018

82 █

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SEMIANNUAL REPORT TO CONGRESS

REPORT NUMBER REPORT TITLE ISSUE DATE DECISION 

DATE FINAL ACTION

2015-CH-1010

The Cooperative and Management Agent 

Lacked Adequate Controls Over the 

Operation of Carmen-Marine Apartments, 

Chicago, IL

09/30/2015 01/28/2016 Note 2

2015-KC-1012

LoanCare Did Not Always File Claims for 

Foreclosed-Upon Properties Held on 

Behalf of Ginnie Mae and Convey Them to 

FHA in a Timely Manner

09/30/2015 01/04/2016 Note 2

2015-LA-1009

loanDepot’s FHA-Insured Loans With 

Downpayment Assistance Funds Did Not 

Always Meet HUD Requirements

09/30/2015 01/12/2016 Note 2

2015-LA-1010

loanDepot’s FHA-Insured Loans With 

Golden State Finance Authority 

Downpayment Assistance Gifts Did Not 

Always Meet HUD Requirements

09/30/2015 01/12/2016 Note 2

2015-LA-1803 

The City of Richmond, CA, Did Not 

Adequately Support Its Use of HUDFunded Expenses for Its Filbert Phase 1 

and Filbert Phase 2 Activities

09/30/2015 01/08/2016 12/31/2018

2016-FO-0001 Audit of Fiscal Years 2015 and 2014 

(Restated) Financial Statements 11/13/2015 03/24/2016 Note 3

2016-FO-0002 Fiscal Years 2015 and 2014 Financial 

Statements Audit 11/16/2015 03/16/2016 Note 2

2016-FO-0003

Additional Details To Supplement Our 

Fiscal Years 2015 and 2014 (Restated) U.S. 

Department of Housing and Urban 

Development Financial Statement Audit

11/18/2015 03/22/2016 Note 3

2016-DP-0801

Review of Information System Controls 

Over the Government National Mortgage 

Association

11/30/2015 03/30/2016 Note 2

2016-AT-1002

The Municipality of Toa Alta, PR, Did Not 

Properly Administer Its Section 108 Loan 

Guarantee Program

12/17/2015 04/12/2016 Note 2

2016-DP-0002 Single Family Insurance System and Single 

Family Insurance Claims Subsystem 12/21/2015 03/31/2016 Note 2

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SEMIANNUAL REPORT TO CONGRESS

REPORT NUMBER REPORT TITLE ISSUE DATE DECISION 

DATE FINAL ACTION

2016-NY-1003

The City of Rochester, NY Did Not 

Always Administer Its Community 

Development Block Grant Program in 

Accordance With HUD Requirements

02/05/2016 06/17/2016 Note 2

2016-CH-0001

HUD Lacked Adequate Oversight of Public 

Housing Agencies' Compliance With Its 

Declaration of Trust Requirements

02/26/2016 06/20/2016 10/01/2019

2016-SE-1001

Homewood Terrace, Auburn, WA, Did Not 

Always Conduct Timely Reexaminations, 

Properly Request Assistance Payments, or 

Verify Income Information

03/09/2016 07/06/2016 Note 2

2016-NY-1006

New York State Did Not Always Disburse 

Community Development Block Grant 

Disaster Recovery Funds in Accordance 

With Federal and State Regulations

03/29/2016 07/27/2016 Note 2

2016-FW-0001

HUD Did Not Effectively Negotiate, Execute, 

or Manage Its Agreements Under the 

Intergovernmental Personnel Act

03/30/2016 05/04/2017 Note 2

2016-NY-1007

The City of Jersey City, NJ's Community 

Development Block Grant Program Had 

Administrative and Financial Control 

Weaknesses

03/30/2016 06/08/2016 Note 2

2016-FO-0005 Compliance With the Improper Payments 

Elimination and Recovery Act 05/13/2016 10/04/2016 09/30/2018

2016-AT-0001

HUD Did Not Enforce and Sufficiently Revise 

Its Underwriting Requirements for 

Multifamily Accelerated Processing Loans

05/20/2016 09/16/2016 Note 2

2016-PH-1003

The City of Camden, NJ, Did Not Ensure That 

Activities Always Complied With National 

Objective, Procurement, and Environmental 

Review Requirements

05/24/2016 09/12/2016 Note 2

2016-LA-1006 The Richmond Housing Authority, Richmond, 

CA, Mismanaged Its Financial Operations

06/03/2016 09/21/2016 05/01/2018

2016-AT-1006 The City of Miami Beach Did Not Always 

Properly Administer Its HOME Program 06/17/2016 10/05/2016 10/04/2017

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REPORT NUMBER REPORT TITLE ISSUE DATE DECISION 

DATE FINAL ACTION

2016-BO-1003

The State of Connecticut Did Not Always 

Administer Its Neighborhood Stabilization 

Program in Compliance With HUD 

Regulations

06/28/2016 10/25/2016 10/25/2017

2016-PH-0001

HUD Did Not Always Provide Adequate 

Oversight of Property Acquisition and 

Disposition Activities

06/30/2016 02/16/2017 Note 3

2016-PH-0002

HUD Did Not Ensure That All Costs for 

Ginnie Mae’s Contract With BursonMarsteller Were Supported, Reasonable, and 

Necessary

07/23/2016 11/19/2016 11/30/2018

2016-PH-0003

HUD Did Not Ensure That Lenders Verified 

That FHA-Insured Properties in Flint, MI, 

Had Safe Water

07/29/2016 12/22/2016 12/20/2017

2016-AT-1009

The Members and Operator Did Not Comply 

With the Executed Regulatory Agreement and 

HUD’s Requirements for Saltillo Assisted 

Living, Saltillo, MS

08/02/2016 11/30/2016 11/28/2017

2016-CH-1005

The Jefferson Metropolitan Housing 

Authority, Steubenville, OH, Failed To 

Manage Its Procurements and Contracts in 

Accordance With HUD’s and Its Own 

Requirements

08/03/2016 11/17/2016 08/31/2019

2016-AT-1010

The Mobile Housing Board, Mobile, AL, Did 

Not Disclose an Apparent Conflict of Interest 

and Occupy One-Third of Its Public Housing 

Units

08/04/2016 11/18/2016 11/17/2017

2016-AT-1011

The Georgia Housing and Finance Authority, 

Atlanta, GA, Did Not Adequately Implement 

the Federal Housing Administration’s Home 

Affordable Modification Program in 

Accordance With HUD’s Requirements

08/05/2016 01/25/2017 10/27/2017

2016-NY-1009

The State of New York Had Weaknesses in Its 

Administration of the Tourism and Marketing 

Program

08/12/2016 12/09/2016 12/08/2017

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REPORT NUMBER REPORT TITLE ISSUE DATE DECISION 

DATE FINAL ACTION

2016-KC-0001

HUD Did Not Collect an Estimated 1,361 

Partial Claims Upon Termination of Their 

Related FHA-Insured Mortgages

08/17/2016 12/09/2016 12/08/2017

2016-PH-1005

The Richmond Redevelopment and Housing 

Authority, Richmond, VA, Did Not Always 

Charge Eligible and Reasonable Central

Office Cost Center Fees

08/17/2016 12/13/2016 12/13/2017

2016-CH-1006

The Housing Authority of the City of Muncie, 

Muncie, IN, Did Not Always Comply With 

HUD’s Requirements and Its Own Policies 

Regarding the Administration of Its Housing 

Choice Voucher Program

08/23/2016 12/21/2016 12/31/2017

2016-LA-1008

The Dolores Frances Affordable Housing 

Project, Los Angeles, CA, Was Not 

Administered in Accordance With Its 

Regulatory Agreement and HUD 

Requirements

08/26/2016 12/12/2016 12/08/2017

2016-LA-1009

The City and County of Honolulu, HI, Did 

Not Administer Its Community Development 

Block Grant in Accordance With 

Requirements

08/26/2016 12/12/2016 03/30/2018

2016-AT-1012

The Municipality of Bayamon, PR, Did Not 

Always Ensure Compliance With HUD 

Program Requirements

08/29/2016 12/15/2016 12/09/2017

2016-DP-0003 Additional Review of Information System 

Controls Over FHA Information Systems 08/31/2016 12/22/2016 12/21/2017

2016-FW-1006

The State of Louisiana’s Subrecipient Did Not 

Always Comply With Its Agreement and 

HUD Requirements When Administering Its 

Disaster Assistance Programs

08/31/2016 12/16/2016 12/16/2017

2016-LA-1011

Evergreen Home Loans, Las Vegas, NV, 

Branch Did Not Always Comply With HUD 

FHA Origination Regulations

09/12/2016 01/04/2017 01/03/2018

2016-NY-0001 Operating Fund Calculations Were Not 

Always Adequately Verified 09/12/2016 12/22/2016 01/01/2018

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REPORT NUMBER REPORT TITLE ISSUE DATE DECISION 

DATE FINAL ACTION

2016-AT-1013

The Sanford Housing Authority, Sanford, NC, 

Did Not Comply With HUD’s and Its Own 

Section 8 Housing Choice Voucher Program 

Requirements

09/13/2016 12/16/2016 12/12/2017

2016-DP-0004 HUD Rushed the Implementation of Phase 1 

Release 3 of the New Core Project 09/20/2016 01/10/2017 12/05/2017

2016-KC-0002

Ginnie Mae Improperly Allowed Uninsured 

Loans To Remain in Mortgage-Backed 

Securities Pools

09/21/2016 01/04/2017 12/16/2017

2016-PH-1007

The Housing Authority of the City of 

Annapolis, MD, Did Not Always Follow 

Applicable Procurement Requirements

09/27/2016 01/25/2017 01/31/2018

2016-KC-1006

The City of Joplin, MO, Did Not Always

Comply With the Requirements of Section 3 

of the Housing and Urban Development Act 

of 1968 for Its Disaster Recovery Program

09/28/2016 01/12/2017 01/20/2018

2016-CH-1008

P.K. Management Group, Inc., Doral, FL, Did 

Not Always Provide Property Preservation 

and Protection Services in Accordance With 

Its Contract With HUD and Its Own 

Requirements

09/29/2016 01/20/2017 12/01/2017

2016-FO-0006 HUD Needs To Improve Its Monitoring of the 

Travel and Purchase Card Programs 09/29/2016 03/29/2017 12/31/2017

2016-NY-1010

Folts, Inc., Herkimer, NY Did Not Administer 

the Folts Adult Home and Folts Home 

Projects In Accordance With Their Regulatory 

Agreements

09/29/2016 03/28/2017 12/31/2018

2016-PH-1008

The Housing Opportunities Commission of 

Montgomery County, Kensington, MD, Did 

Not Always Ensure That Its Program Units 

Met Housing Quality Standards

09/29/2016 01/12/2017 01/12/2018

2016-CH-1009

The Condominium Association and 

Management Agent Lacked Adequate 

Controls Over the Operation of West Park 

Place Condominium, Chicago, IL

09/30/2016 01/25/2017 01/20/2018

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SEMIANNUAL REPORT TO CONGRESS

REPORT NUMBER REPORT TITLE ISSUE DATE DECISION 

DATE FINAL ACTION

2016-FW-1010

The State of Oklahoma Did Not Obligate and 

Spend Its Community Development Block 

Grant Disaster Recovery Funds in Accordance 

With Requirements

09/30/2016 01/17/2017 11/29/2017

2016-PH-1009

The State of New Jersey Did Not Disburse 

Disaster Funds to Its Contractor in 

Accordance With HUD, Federal, and Other 

Applicable Requirements

09/30/2016 01/27/2017 12/30/2017

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SEMIANNUAL REPORT TO CONGRESS

SIGNIFICANT AUDIT REPORTS ISSUED WITHIN THE PAST 12 MONTHS THAT WERE 

DESCRIBED IN PREVIOUS SEMIANNUAL REPORTS FOR WHICH FINAL ACTION HAD NOT 

BEEN COMPLETED AS OF 09/30/2017

REPORT NUMBER REPORT TITLE ISSUE DATE DECISION DATE FINAL ACTION

2017-BO-1001

The State of Connecticut Did Not Always Comply 

With CDBG Disaster Recovery Assistance 

Requirements

10/12/2016 02/01/2017 10/17/2017

2017-KC-0001

FHA Paid Claims for an Estimated 239,000 

Properties That Servicers Did Not Foreclose Upon 

or Convey on Time

10/14/2016 02/28/2017 02/24/2019

2017-BO-1002

The City of Springfield, MA Needs To Improve Its 

Compliance with Federal Regulations for Its CDBG 

Disaster Recovery Assistance Grant

10/17/2016 01/04/2017 11/30/2017

2017-CH-0001

HUD Needs To Improve Its Oversight of Funds 

Covered Under the Low-Income Housing 

Preservation and Resident Homeownership Act of 

1990

10/25/2016 02/22/2017 02/22/2018

2017-NY-1001

The City of New York, NY, Implemented Policies 

That Did Not Always Ensure That CDBG Disaster 

Recovery Funds Were Disbursed in Accordance 

With Its Action Plan and Federal Requirements

11/02/2016 05/08/2017 12/29/2017

2017-FO-0001 Audit of Fiscal Years 2016 and 2015 (Restated) 

Financial Statements 11/14/2016 04/06/2017 Note 3

2017-FO-0002

Audit of the Federal Housing Administration’s 

Financial Statements for Fiscal Years 2016 and 

2015 (Restated)

11/14/2016 07/13/2017 12/28/2017

2017-FO-0003

Additional Details To Supplement Our Fiscal Years 

2016 and 2015 (Restated) U.S. Department of 

Housing and Urban Development Financial 

Statement Audit

11/15/2016 09/13/2017 Note 3

2017-NY-1003

The Town of Amherst, NY, Did Not Ensure That Its 

Housing Choice Voucher Program Units Met 

Housing Quality Standards

12/14/2016 03/01/2017 02/05/2018

2017-KC-1001

Majestic Management, LLC, a Multifamily Housing 

Management Agent in St. Louis, MO, Did Not 

Always Comply With HUD’s Requirements When 

Disbursing Project Funds

12/16/2016 04/14/2017 04/30/2018

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SEMIANNUAL REPORT TO CONGRESS

REPORT NUMBER REPORT TITLE ISSUE DATE DECISION DATE FINAL ACTION

2017-NY-1004

The City of New York, NY, Lacked Adequate 

Controls To Ensure That the Use of CDBG-DR 

Funds Was Always Consistent With the Action 

Plan and Applicable Federal and State 

Requirements

12/21/2016 04/17/2017 12/29/2017

2017-FW-1003

The Houston Housing Authority, Houston, TX, 

Needs To Improve Its Procurement and Financial 

Operations and Its Housing Choice Voucher 

Program Subsidy Determinations

12/27/2016 03/24/2017 03/24/2018

2017-PH-1801

Final Civil Action Borrower Settled Alleged 

Violations of Home Equity Conversion Mortgage 

Program

01/06/2017 01/06/2017 11/01/2017

2017-NY-1005

Union County, NJ'S HOME Investment 

Partnerships Program Was Not Always 

Administered in Compliance With Program 

Requirements

01/13/2017 05/11/2017 05/07/2019

2017-KC-0002

The U.S. Department of Housing and Urban 

Development Did Not Always Prevent Program 

Participants From Receiving Multiple Subsidies

01/20/2017 05/09/2017 12/31/2018

2017-CH-1001

The Port Huron Housing Commission, Port Huron, 

MI, Did Not Properly Implement Asset 

Management

01/24/2017 05/03/2017 04/02/2018

2017-LA-0002

HUD Failed To Follow Departmental Clearance 

Protocols for FHA Programs, Policies, and 

Operations

01/25/2017 09/22/2017 03/31/2018

2017-DP-0001 HUD's Transition to a Federal Shared Service 

Provider Failed to Meet Expectations 02/01/2017 05/25/2017 Note 3

2017-DP-0002

Review of Information Systems Controls Over 

FHA’s Single Family Premiums Collection 

Subsystem – Periodic and the Single Family 

Acquired Asset Management System

02/09/2017 06/12/2017 04/30/2018

2017-KC-1801

Final Action Memorandum: Purchaser of HUDInsured Single-Family Property Settled Allegations 

of Causing the Submission of a False Claim

02/23/2017 02/23/2017 06/15/2021

2017-FO-0005 HUD’s Fiscal Years 2016 and 2015 (Restated) 

Consolidated Financial Statements Audit (Reissued) 03/01/2017 07/03/2017 11/16/2017

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SEMIANNUAL REPORT TO CONGRESS

REPORT NUMBER REPORT TITLE ISSUE DATE DECISION DATE FINAL ACTION

2017-AT-1003

The Puerto Rico Department of Housing, San Juan, 

PR, Did Not Properly Administer Its Multifamily 

Special Escrow Funds

03/02/2017 06/27/2017 06/26/2018

2017-FO-0801

Independent Attestation Review: U.S. Department 

of Housing and Urban Development, DATA Act 

Implementation Efforts

03/02/2017 06/19/2017 Note 2

2017-LA-0003

HUD Failed To Adequately Oversee FHA-Insured 

Loans With Borrower-Financed Downpayment 

Assistance

03/03/2017 06/22/2017 06/15/2019

2017-NY-1008

The Irvington, NJ, Housing Authority Did Not 

Always Administer Its Public Housing Program in 

Accordance With Program Requirements

03/10/2017 07/07/2017 07/07/2018

2017-BO-0001

HUD's OCPO Did Not Always Comply With 

Acquisition Requirements When Planning and 

Monitoring Major Service Contracts

03/22/2017 06/28/2017 03/31/2018

2017-PH-1001

The City of Pittsburgh, PA, Did Not Always 

Administer Its CDBG Program in Accordance With 

HUD and Federal Requirements

03/22/2017 07/19/2017 07/19/2018

2017-CF-1803

United Shore Financial Services, LLC, Settled 

Allegations of Failing To Comply With HUD’s 

Federal Housing Administration Loan 

Requirements

03/29/2017 03/29/2017 03/27/2022

2017-CH-1801

Final Civil Action: Judgment Imposed on the 

Former President and Founder of MDR Mortgage 

Corporation Regarding Allegations of Failing To 

Comply With HUD’s Federal Housing 

Administration Requirements 

03/31/2017 08/31/2017 08/21/2018

Audits excluded: 

90 audits under repayment plans 

33 audits under debt claims collection processing, formal judicial review, investigation, or legislative solution

Notes: 

1 Management did not meet the target date. Target date is more than 1 year old. 

2 Management did not meet the target date. Target date is less than 1 year old. 

3 No management decision

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TABLE C

INSPECTOR GENERAL-ISSUED REPORTS WITH QUESTIONED AND UNSUPPORTED 

COSTS AT 9/30/2017 (THOUSANDS)

AUDIT REPORTS

NUMBER OF 

AUDIT 

REPORTS 

QUESTIONED 

COSTS

UNSUPPORTED 

COSTS

A1 For which no management decision had been made by 

the beginning of the reporting period 21 $217,600 $127,227

A2 For which litigation, legislation, or investigation was 

pending at the beginning of the reporting period 4 25,542 3,378

A3 For which additional costs were added to reports in 

beginning inventory - 1,663 38

A4 For which costs were added to noncost reports 0 0 0 

B1 Which were issued during the reporting period 62 189,218 86,506

B2 Which were reopened during the reporting period 0 0 0 

Subtotals (A+B) 87 434,023 217,149

C For which a management decision was made during the 

reporting period 3816 270,927 126,299

(1) Dollar value of disallowed costs:

 Due HUD 

 Due program participants 

1417

25

173,462

54,160

59,699

23,424

(2) Dollar value of costs not disallowed 318 43,305 43,176

D

For which a management decision had been made not to 

determine costs until completion of litigation, 

legislation, or investigation

3 25,110 2,946

E For which no management decision had been made by 

the end of the reporting period

46

<126>19 

137,986

<103,176> 19

87,904

<75,641>19 

16 Thirteen audit reports also contain recommendations with funds to be put to better use. 17 Two audit reports also contain recommendations with funds due program participants. 18 One audit report also contains recommendations with funds agreed to by management. 19 The figures in brackets represent data at the recommendation level as compared to the report level. See explanations of tables C and D 

located below table D.

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TABLE D

INSPECTOR GENERAL-ISSUED REPORTS WITH RECOMMENDATIONS THAT FUNDS BE 

PUT TO BETTER USE AT 9/30/2017 (THOUSANDS)

AUDIT REPORTS NUMBER OF AUDIT 

REPORTS DOLLAR VALUE

A1 For which no management decision had been made by the 

beginning of the reporting period 

15 $7,920,711

A2 For which litigation, legislation, or investigation was pending at the 

beginning of the reporting period 

1 1,694

A3 For which additional costs were added to reports in beginning 

inventory 

- 57

A4 For which costs were added to noncost reports 0 0 

B1 Which were issued during the reporting period 39 537,788

B2 Which were reopened during the reporting period 0 0 

Subtotals (A+B) 55 8,460,250

C For which a management decision was made during the reporting 

period 

1520 386,320

(1) Dollar value of recommendations that were agreed to by 

management:

 Due HUD

 Due program participants 

5 

10

289,940

96,380

(2) Dollar value of recommendations that were not agreed to by 

management 

0 0 

D For which a management decision had been made not to determine 

costs until completion of litigation, legislation, or investigation 

1 1,694

E 

For which no management decision had been made by the end of 

the reporting period 

39

<50>21

8,072,236

<5,734,288> 21

20 Thirteen audit reports also contain recommendations with questioned costs. 21 The figures in brackets represent data at the recommendation level as compared to the report level. See the explanations of tables C and 

D below.

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SEMIANNUAL REPORT TO CONGRESS

EXPLANATIONS OF TABLES C AND D

The Inspector General Act Amendments of 1988 require inspectors general and agency heads to report cost data on 

management decisions and final actions on audit reports. The current method of reporting at the “report” level 

rather than at the individual audit “recommendation” level results in misleading reporting of cost data. Under the 

Act, an audit “report” does not have a management decision or final action until all questioned cost items or other 

recommendations have a management decision or final action. Under these circumstances, the use of the “report” 

based rather than the “recommendation” based method of reporting distorts the actual agency efforts to resolve and 

complete action on audit recommendations. For example, certain cost items or recommendations could have a 

management decision and repayment (final action) in a short period of time. Other cost items or nonmonetary 

recommendation issues in the same audit report may be more complex, requiring a longer period of time for 

management’s decision or final action. Although management may have taken timely action on all but one of many 

recommendations in an audit report, the current “all or nothing” reporting format does not recognize their efforts. 

The closing inventory for items with no management decision in tables C and D (line E) reflects figures at the report 

level as well as the recommendation level.

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APPENDIX 4 – UNDISCLOSED REPORTS

The Inspector General Empowerment Act (IGEA), sections 5(a)(22)(A) and (B), requires reporting within the 

Semiannual Report a detailed description of particular circumstances of each (A) inspection, evaluation, and audit 

conducted by the office that is closed and was not disclosed to the public and (B) investigation conducted by the 

office involving a senior government employee that is closed and was not disclosed to the public. The following 

provides a summary of these items: 

AUDIT

AUDIT REPORTS THAT WERE CLOSED DURING THE PERIOD THAT WERE NOT 

DISCLOSED TO THE PUBLIC

2014-DP-0006, REVIEW OF INFORMATION SYSTEMS CONTROLS OVER THE PROGRAM 

ACCOUNTING SYSTEM (PAS), ISSUED SEPTEMBER 23, 2014, AND CLOSED MAY 17, 2017

This was a LIMITED DISTRIBUTION audit report. The U.S. Department of Housing and Urban Development, 

Office of Inspector General (HUD OIG), reviewed the general and application controls over HUD’s Program 

Accounting System (PAS) as part of the internal control assessments required for the fiscal year 2014 financial 

statement audit under the Chief Financial Officer’s Act of 1990. OIG’s objective was to focus on the effectiveness 

of general and application controls over PAS for compliance with HUD information technology (IT) policies and 

Federal information system security and financial management requirements. HUD did not ensure that general and 

application controls over PAS fully complied with Federal requirements and its own security policies. Specifically, 

PAS access controls needed updates. Some users’ permissions did not correlate with their user access forms, 

guidelines for obtaining access were not always followed, and some users were not assigned proper identification. 

A lack of proper controls increases the risk of inappropriate modification to the data used in financial processing 

and reporting. In addition, PAS transactions were modified to correct errors without a proper analysis. Improper 

error handling increases the risk of inaccurate financial processing. Also, internal controls were overridden without 

a documented process. The absence of a documented process for performing and monitoring transaction overrides 

presents the opportunity for fraudulent financial processing. Further, the PAS application documentation was 

outdated. Without proper documentation, users and technical support personnel may not be able to accurately 

perform their duties. Finally, documentation for supporting the segregation of duties was not maintained. Without 

documentation to support the segregation of duties, the Office of the Chief Financial Officer (OCFO) could not have 

properly evaluated whether the mission functions of its users were properly segregated to prevent the likelihood of 

errors and wrongful acts. OIG recommended that OCFO (1) ensure that PAS access controls are updated to fully 

protect the system from inappropriate exposure, (2) create and distribute procedures for PAS transaction error 

handling, (3) implement a documented process for transaction override processing, (4) update the PAS application 

documentation, and (5) develop and implement segregation of duties documentation and procedures. (Audit Report: 

2014-DP-0006) 

INVESTIGATION 

During the current reporting period, OIG has five investigation reports that were closed but not disclosed to the 

public. These cases were previously included under the Investigations of Senior Government Employees section of 

this report. 

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SEMIANNUAL REPORT TO CONGRESS

• It was alleged that a HUD regional administrator and a former senior advisor committed gross

mismanagement and created an announcement and rating factors to hire a spouse. It was also alleged

that the administrator and former advisor rewrote the elements for multifamily presidential 

management fellows to bring them into the agency at a grade higher than that of similar fellows in other 

divisions. The matter was investigated, but the allegations were not substantiated. However, during the

investigation, it was found that the regional administrator had given a Management Analyst improper

access to HUD’s Time and Attendance system. HUD OIG referred the case to the U.S. Attorney’s

Office (USAO) on November 9, 2016. The USAO declined criminal prosecution, citing a lack of

apparent criminal intent. The regional administrator departed HUD during the course of the

investigation and the management analyst was directed to take a Time and Attendance system training.

• A HUD administrative specialist reported that he was being harassed by a HUD senior advisor and that

the senior advisor sent sexually explicit text and voicemail messages on the administrative specialist’s

personal cellular telephone, as well as instant messages to the administrative specialist’s HUD account,

for approximately 18 months. The administrative specialist stated that he asked the senior advisor to

stop this activity and reported the harassment to several supervisors. The administrative specialist also

stated that the senior advisor implied that in exchange for sexual relations, the senior advisor could help

improve the administrative specialist’s professional career. HUD OIG referred the case to the USAO on 

January 16, 2017. On January 16, 2017, the USAO declined criminal prosecution due to available

administrative remedies. The senior advisor retired.

• It was alleged that a HUD director steered contracts and potentially violated the conflict-of-interest

statute. The matter was investigated, but the allegation was not substantiated.

• HUD OIG conducted a preliminary inquiry into potential violations of postemployment restrictions by a

former senior Federal Housing Administration official. The investigation did not substantiate

misconduct by the former official, nor did it identify evidence indicating that the former official

communicated with Department officials in violation of Federal law or regulation.

• HUD OIG received information alleging that a HUD administrative officer owned several apartment

buildings, which were rented to tenants in HUD’s Section 8 program. The investigation did not

substantiate misconduct by the administrative officer and determined that the subject did not violate any

program rules. 

EVALUATION

During the current reporting period, OIG has one evaluation report that was closed but not disclosed to the public. 

HUD WEB APPLICATION SECURITY EVALUATION

HUD OIG completed a targeted web application security evaluation of HUD in support of a Counsel of 

the Inspectors General on Integrity and Efficiency (CIGIE) Federal cross-cutting project, making nine 

recommendations for improvement to the Department. HUD OIG assessed HUD’s capability to identify 

and mitigate critical IT vulnerabilities in the Department’s publicly accessible web applications. OIG

identified key deficiencies in HUD’s practices that put HUD’s extensive collection of sensitive data, 

including personal information of private citizens, at increased risk of unauthorized access and 

compromise. Of particular concern was the discovery of multiple operating web applications unknown to 

the Office of the Chief Information Officer. (2016-OE-0002)

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APPENDIX 5 – OPEN RECOMMENDATIONS

OFFICE OF AUDIT

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

1995-NY-1001 1/24/1995 001-B 

We recommend that you make a determination on collectability 

of past due excess income liability and require the mortgagor to 

start correctly completing monthly excess income report.

$2,200,290

2000-AT-1003 3/6/2000 003-C Require that the PHA reimburse $2,568,000, less any restitution, 

for the fictitious training invoices. 1,114,897

2001-AT-1001 10/20/2000 001-A 

Obtain additional supporting documentation or recover from city 

$795,178 paid for police protection, recreation and code 

enforcement activities.

573,658

2001-FW-1003 12/18/2000 001-C 

Require the authority to repay the Low Rent Program $58,799 

from nonfederal funds for the ineligible transfers that have not 

been reimbursed by Section 8 Program.

58,799

2000-NY-1003 12/30/1999 004-C 

We recommend you instruct the Public Housing Authority to 

reimburse from nonfederal funds, the amount of unsupported 

costs determined to be ineligible.

31,443 

2001-FW-1003 12/18/2000 001-D 

Require the Authority to provide support for $13,082 in 

unsupported costs charged to Low Rent Program for audit period 

and any subsequent unsupported costs, etc.

13,082

2001-PH-1803 8/31/2001 001-A 

Take action to refinance mixed financing developments, recover 

inappropriately expended Annual Contributions Contract funds, 

sanctions for Annual Contributions Contract violations.

320,000

2002-AT-1002 7/3/2002 001-A Require the Authority to seek repayment of the $728,159 owed 

from the Tupelo Apartment Homes, L.P. 658,159

2002-AT-1002 7/3/2002 003-B Provide proper support for the $331,665 of expenditures for the 

fiscal year 2000 Annual Statement, or reimburse the CGP funds. 331,665

2002-AT-1002 7/3/2002 003-A Provide proper supporting documentation or reimburse the CGP 

$293,544 of unsupported expenditures. 293,544

2002-PH-1005 9/30/2002 001-C 

Support unsupported expenditures of $60,750 that were drawn 

down for the grant. For any unsupported expenditures require 

grantee reimburse HUD.

60,750

2002-PH-1005 9/30/2002 001-D Reimburse HUD for the $23,422 ineligible expenditures charged 

to the grant. 23,422

97 █

███ 97 ██97
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2002-AT-1002 7/3/2002 005-C Remove the refrigerators and ranges from the Ida Street 

development or require reimbursement from the partnership. 15,086

2002-NY-0001 2/25/2002 001-B If implementation continues we recommend that HUD complete 

and implement the regulations. 0 

2003-CH-1019 7/25/2003 001-B 

Establishes a formal repayment agreement with the Housing 

Authority that will allow the current debt owed to HUD of 

$533,432 to be repaid without disrupting the Section 8 Program. 

The following should be included in the agreement: prior HUD 

approval of the Housing Authority's proposed budgets; and a 

requirement that the Housing Authority revise its funding 

requisitions when leasing levels materially change so that future 

overpayments will be avoided.

507,290

2004-BO-1002 11/4/2003 001-A 

Recover from owner $2,687,822, the difference between 

$3,662,822 owed to HUD by owner and $975,000 proceeds of 

foreclosure sale.

333,581

2004-CH-1001 11/26/2003 003-B 

Provides documentation to support that it appropriately made 

$324,364 in Housing Assistance Payments. If adequate 

documentation cannot be provided, then the Authority should 

reimburse its Section 8 Housing Program from non-Federal 

funds for the appropriate amount.

300,327

2003-CH-1011 3/24/2003 001-A 

Ensures that the $287,224 of housing work cited in this finding 

is completed correctly using non-federal funds. If the Authority 

is unable to ensure the work is completed correctly, then the 

Authority should reimburse its Comprehensive Assistance 

Improvement Program (now the Capital Fund Program) from 

non-Federal funds the applicable amount of work not completed 

correctly or not provided.

287,224

2004-CH-1001 11/26/2003 002-B 

Reimburses its Section 8 Housing Program $150,851 from nonFederal funds for the Section 8 administrative fees collected by 

the Authority ($14,942) and the Housing Assistance Payments 

($135,909) improperly made for the Section 8 housing units that 

did not meet HUD's Housing Quality Standards.

170,051

2003-CH-1014 3/28/2003 002-A 

Provides documentation to support the $72,329 of unsupported 

salaries and wages cited in this finding. If documentation cannot 

be provided, the Authority should reimburse its Public Housing 

Program the appropriate amount from non-Federal funds.

72,329

2003-CH-1019 7/25/2003 002-D 

Provides documentation to support the $43,132 of unsupported 

payments cited in the Indiana State Board of Accounts audit 

report. If documentation cannot be provided, then the Authority 

should reimburse its Section 8 Voucher Program for the amount 

that cannot be supported from non-Federal funds.

43,132

98 █

███ 98 98 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2003-CH-1019 7/25/2003 002-A Reimburses its Section 8 Voucher Program $42,206 from nonFederal funds for the ineligible costs cited in this finding. 41,146

2003-CH-1019 7/25/2003 002-C 

Reimburses its Section 8 Voucher Program $40,708 from nonFederal funds for ineligible costs cited in the Indiana State Board 

of Accounts audit report.

40,708

2003-CH-1011 3/24/2003 001-B 

Reimburses its Comprehensive Assistance Improvement 

Program (now the Capital Fund Program) $36,408 from nonfederal funds for the inappropriate use.

36,408

2003-CH-1019 7/25/2003 003-A 

Reimburses its Voucher Program from non-Federal funds 

$60,399 for Section 8 subsidy at units it incorrectly certified met 

Housing Quality Standards.

28,248

2003-CH-1014 3/28/2003 005-A 

Provides documentation to support the $33,284 of unsupported 

payments cited in this finding. If documentation cannot be 

provided, then the Authority should reimburse its Public 

Housing Program the amount that cannot be supported from 

non-Federal funds.

27,097

2003-FW-1001 2/21/2003 002-A Repay its program $32,652 that it paid CDG for hiring it 

coordinator. 18,939

2004-CH-1001 11/26/2003 003-D 

Provides documentation to support the annual income used in 26 

reexaminations for $112,753 in Housing Assistance Payments. 

If adequate documentation cannot be provided, then the 

Authority should reimburse its Section 8 Housing Program from 

non-Federal funds for the appropriate amount.

11,859

2003-CH-1019 7/25/2003 002-B 

Provides documentation to support the $1,672 of unsupported 

payments cited in this finding. If documentation cannot be 

provided, then the Authority should reimburse its Section 8 

Voucher Program from non-Federal funds for the amount that 

cannot be supported.

1,672

2004-AT-1006 4/22/2004 001-B 

Require the PRPHA to submit all supporting documentation and 

determine the accuracy of the $4,230,646 owed by PBA and its 

public housing management agents. Any amounts determined 

ineligible must be reimbursed to the ACC projects, from nonFederal funds.

4,230,256

2005-AT-1004 11/19/2004 002-E 

Require the Authority to repay its programs $6,855,271 spent for 

ineligible procurements. Repayment should be from nonFederal funds and paid in the following amounts and to the 

following programs: Conventional Public Housing General 

Fund $2,818,331, Capital Fund $3,630,215, HOPE VI $259,289, 

Section 8 $115,128, Drug Elimination $12,048, Economic 

Development Support Services $13,831, and Turnkey III 

Program $6,429.

3,516,017

99 █

███ 99 ██99
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2004-CH-1006 6/23/2004 001-B 

Provides documentation to support that $768,517 of Housing 

Assistance Payment Savings funds benefited very low-income 

persons and families. If the Authority cannot provide the 

necessary documentation, then the Authority should reimburse a 

control account from non-Federal funds for the applicable 

amount.

768,517

2004-AT-1001 1/15/2004 001-A Require the Authority to collect the $327,326 due from SCHDC 

and discontinue advancing funds. 199,851

2004-PH-1011 9/8/2004 002-B Direct the Authority to provide adequate documentation to 

support $1,943,993 or reimburse HUD from nonfederal sources. 187,743

2005-CH-1003 11/29/2004 001-A 

We recommend that HUD’s Director of Public Housing Hub, 

Detroit Field Office, assure the Royal Oak Township Housing 

Commission: Reimburse its Public Housing Program $367,516 

from non-Federal funds for the improper use of HUD operating 

subsidy funds cited in this finding.

91,879

2005-CH-1003 11/29/2004 002-A 

We recommend that HUD’s Director of Public Housing Hub, 

Detroit Field Office, assure the Royal Oak Township Housing 

Commission: Reimburse its Public Housing Program $45,220 

from non-Federal funds for the operating subsidy that was not 

used in accordance with HUD's One Strike Policy.

45,220

2004-PH-1011 9/8/2004 001-B Require the Authority to reimburse HUD $882,916 from 

nonfederal sources. 29,051

2005-CH-1003 11/29/2004 002-C 

We recommend that HUD’s Director of Public Housing Hub, 

Detroit Field Office, assure the Royal Oak Township Housing 

Commission: Reimburse its Public Housing Program $3,340 

from non-Federal funds for thee ineligible travel costs.

3,340

2005-AT-1013 9/15/2005 002-A 

Require the Municipality to obtain and submit all supporting 

documentation and HUD determine the eligibility and propriety 

of $1,011,801 in administrative costs the Corporation charged to 

the Block Grant revolving fund. Any amounts determined 

ineligible must be reimbursed to the Block Grant program from 

nonfederal funds.

1,011,801

2005-CH-1020 9/29/2005 004-A 

We recommend that the director of HUD’s Public Housing Hub, 

Cleveland Field Office, require the Authority to provide support 

or reimburse its Section 8 program $812,967 ($738,708 in 

housing assistance payments plus $74,259 in related 

administrative fees) from nonfederal funds for unsupported 

housing assistance payments and unearned administrative fees 

related to the 65 tenants cited in this finding.

807,977

100 █

███ 100 100 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2005-CH-1020 9/29/2005 003-A 

We recommend that the director of HUD's Public Housing Hub, 

Cleveland Field Office, require the Authority to reimburse its 

Section 8 administrative fees $805,585 from nonfederal funds 

for inappropriately funding HOPE VI expenses.

751,881

2005-AT-1013 9/15/2005 003-A 

Require the Municipality to obtain and submit all supporting 

documentation and HUD determine the eligibility and 

compliance with national objectives of the $631,195 the 

Corporation disbursed for the four loans. Any amounts 

determined ineligible must be reimbursed to the Block Grant 

program from nonfederal funds.

471,578

2005-CH-1010 4/8/2005 001-A 

We recommend that HUD’s Director of Public Housing Hub, 

Chicago Regional Office, assure that the Authority reduces its 

Low-Rent Performance Funding Operating Subsidy by $119,376 

for the excessive operating subsidy cited in this finding.

105,186

2006-BO-0001 7/11/2006 001-C 

For the overpayments of phase-down funding identified in 

appendix C, recover $20.6 million in ineligible phase-down 

funding requests from the public housing agencies for fiscal 

years 2004 and 2005.

8,281,766

2006-NY-1003 2/14/2006 002-A 

We recommend that the Director of the HUD Office of Public 

Housing review the documentation provided by the Authority, 

determine if the evidence supports that services were provided 

that exceeded the services that were to be provided in 

accordance with the cooperation agreements and seek 

reimbursement of any amounts that are not supported.

3,758,034

2006-BO-1006 3/28/2006 001-C 

We recommend that the director of HUD’s Boston Multifamily 

Housing Hub, in conjunction with the HUD Office of Inspector 

General (OIG), pursue double damages remedies if the owner 

does not reimburse HUD for the inappropriate disposition of 

project assets.

1,421,859

2006-BO-1006 3/28/2006 001-B 

We recommend that the director of HUD’s Boston Multifamily 

Housing Hub assure the owner provides documentation to 

support the $992,979 in unsupported payments cited in this audit 

report. If adequate documentation cannot be provided, the 

owner should reimburse HUD for the appropriate amount.

992,979

2006-BO-1006 3/28/2006 001-A 

We recommend that the director of HUD’s Boston Multifamily 

Housing Hub assure the owner reimburses HUD $865,121 for 

the inappropriate disposition of project assets.

865,121

2006-CH-1018 9/28/2006 001-A 

We recommend that the director of HUD’s Detroit Office of 

Public Housing require the Commission to Reimburse its 

program $535,903 from nonfederal funds ($507,860 for the 

property purchase plus $28,043 for legal costs) for the improper 

use of program funds to pay for the property’s acquisition costs.

535,903

101 █

███ 101 101 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2006-NY-1012 9/22/2006 001-B 

We recommend that the director, New Jersey Office of Public 

Housing, instruct the Authority to recapture or reduce the 

Section 8 administrative fee reserve account by $590,042 to 

comply with the requirements of PIH [Public and Indian 

Housing] Notice 2005-30.

452,366

2006-NY-1012 9/22/2006 001-D 

We recommend that the director, New Jersey Office of Public 

Housing, instruct the Authority to reimburse the capital fund 

from the Section 8 program the $401,046 in excess/ineligible 

capital fund transfers.

334,205

2006-CH-1020 9/29/2006 001-A 

We recommend that the director of HUD’s Chicago Office of 

Public Housing require the Authority to provide supporting 

documentation or reimburse its program $582,926 ($547,238 in 

housing assistance and utility allowance payments and $35,688 

in associated administrative fees) from nonfederal funds for the 

unsupported payments and associated administrative fees related 

to the 73 household files cited in this finding.

293,425

2006-CH-1021 9/30/2006 002-C 

We recommend that the director of HUD’s Chicago Office of 

Public Housing require the Authority to review the remaining 

717 (779 minus 62) zero-income households as of September 

23, 2005, to determine whether they had unreported income. 

For households that received excessive housing assistance and 

utility allowance payments, the Authority should pursue 

collection and/or reimburse its program the applicable amount 

from nonfederal funds.

254,879

2006-BO-0001 7/11/2006 001-B 

Obtain and review support (as identified in recommendation 1D) 

for $15.1 million in unsupported phase-down funding in fiscal 

years 2004 and 2005, determine the correct amount of phasedown funding, and require the public housing agencies to 

reimburse HUD for any ineligible funding received.

250,282

2007-CH-1001 12/13/2006 001-A 

We recommend that the director of HUD’s Cleveland Office of 

Public Housing require the Authority to reimburse its public 

housing operating fund $181,513 from nonfederal funds for the 

inappropriate disbursements cited in this finding.

181,513

2006-CH-1021 9/30/2006 002-D 

We recommend that the director of HUD’s Chicago Office of 

Public Housing require the Authority to terminate the program 

housing assistance to the applicable households that certified 

they had no income when in fact they had income according to 

HUD’s system.

162,854

2006-PH-1013 9/18/2006 001-B 

Require the Commonwealth to provide documentation to 

substantiate the eligibility of $150,000 provided to Southampton 

or repay the HOME program from nonfederal funds.

125,000

102 █

███ 102 102 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2006-CH-1010 5/18/2006 001-A 

We recommend that the director of HUD’s Detroit Office of 

Public Housing require the Commission to provide 

documentation to support the $206,224 in unsupported program 

disbursements cited in this finding or reimburse its program 

from nonfederal funds for the applicable amount. 

115,149

2006-CH-1020 9/29/2006 001-B 

We recommend that the director of HUD’s Chicago Office of 

Public Housing require the Authority to reimburse its program 

$80,776 ($49,034 for the overpayment of housing assistance and 

utility allowance payments for 34 households and $31,742 in 

administrative fees associated with the overpayment and 

underpayment of housing assistance and utility allowance 

payments for 48 households) from nonfederal funds.

75,817

2006-CH-1021 9/30/2006 002-A 

We recommend that the director of HUD’s Chicago Office of 

Public Housing require the Authority to pursue collection from 

the applicable households or reimburse its program $62,365 

($51,244 in housing assistance and $11,121 in utility 

allowances) from nonfederal funds for the overpayment of 

housing assistance and utility allowance payments cited in this 

finding.

62,365

2006-NY-1008 6/30/2006 001-C 

We recommend that the director, Office of Public Housing, New 

York Hub seek repayment of the $49,483 in ineligible and 

erroneous housing assistance payments.

48,584

2006-CH-1021 9/30/2006 003-A 

We recommend that the director of HUD’s Chicago Office of 

Public Housing require the Authority to provide supporting 

documentation or reimburse its program $47,463 ($43,435 in 

housing assistance payments plus $4,028 in related 

administrative fees) from nonfederal funds for the unsupported 

housing assistance payments and related administrative fees for 

the five households cited in this finding.

47,463

2006-CH-1016 9/26/2006 001-A 

We recommend that the director of HUD’s Cleveland Office of 

Public Housing require the Authority to reimburse its program 

$236,157 ($31,802 in imputed interest, $28,802 in forgiven 

interest, $111,073 for the land purchase, $42,322 in cash, and 

$22,158 in improper expenses) from nonfederal funds for the 

inappropriate use of its sales proceeds for the Corporation.

27,726

2006-NY-1010 9/20/2006 002-B 

We recommend that the director, New Jersey Office of Public 

Housing, require the Authority to provide additional 

documentation for the $23,592 in unsupported costs related to 

managerial services and legal and auditing costs so that HUD 

can determine the eligibility of these items. Any amounts 

determined to be ineligible should be repaid.

23,592

103 █

███ 103 103 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2007-CH-1001 12/13/2006 002-A 

We recommend that the director of HUD’s Cleveland Office of 

Public Housing require the Authority to reimburse its 

Coordinators funds $18,757 from nonfederal funds for the 

inappropriate payment of salary and benefits cited in this 

finding.

18,757

2007-CH-1001 12/13/2006 002-B 

We recommend that the director of HUD’s Cleveland Office of 

Public Housing require the Authority to provide documentation 

to support the use of $25,033 in salary and benefits expenses for 

its former counselor was eligible or reimburse its Coordinators 

funds from nonfederal funds as appropriate.

4,963

2006-CH-1021 9/30/2006 001-A 

We recommend that the director of HUD’s Chicago Office of 

Public Housing require the Authority to reimburse its program 

$27,729 ($27,201 in housing assistance and $528 in utility 

allowances) from nonfederal funds for the overpayment of 

housing assistance and utility allowance payments cited in this 

finding.

219

2006-BO-1004 3/3/2006 001-A 

We recommend that the director, Rhode Island Multifamily 

Program Center pursue the recovery of double the amount of 

$533,954 in ineligible costs to identities-of-interest from the 

owner/management agent, as stipulated in 12 U.S.C. [United 

States Code] Sec. 1715z-4a.

0 

2006-BO-1004 3/3/2006 001-B 

We recommend that the director, Rhode Island Multifamily 

Program Center obtain adequate documentation from the 

owner/management agent for the cash disbursements for 

unsupported costs of $21,871 costs to identities-of-interest or 

pursue the recovery of double this amount as stipulated in 12 

U.S.C. [United States Code] Sec. 1715z-4a.

0 

2006-BO-1004 3/3/2006 001-C 

We recommend that the director, Rhode Island Multifamily 

Program Center pursue the recovery of double the amount of 

$426,375 in unnecessary costs to identities-of-interest and nonidentities-of-interest from the owner/management agent, as 

stipulated in 12 U.S.C. [United States Code] Sec. 1715z-4a.

0 

2006-BO-1004 3/3/2006 001-D 

We recommend that the director, Rhode Island Multifamily 

Program Center pursue the recovery of $397,895 in ineligible 

costs to non-identities-of-interest.

0 

2006-BO-1004 3/3/2006 001-E 

We recommend that the director, Rhode Island Multifamily 

Program Center obtain justification from the owner/management 

agent supporting the cash disbursements for unsupported costs 

of $266,574 to non-identities-of-interest or pursue recovery of 

this amount.

0 

104 █

███ 104 104 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2006-BO-1004 3/3/2006 001-F 

We recommend that the director, Rhode Island Multifamily 

Program Center take appropriate action to prevent payments of 

ineligible and unnecessary cash disbursements after our audit 

period, including the payment of questionable accrued payables 

to identities-of-interest of $95,800. If they have been paid, 

pursue the recovery of double this amount as stipulated in 12 

U.S.C. [United States Code] Sec. 1715z-4a.

0 

2006-BO-1004 3/3/2006 001-G 

We recommend that the director, Rhode Island Multifamily 

Program Center take appropriate action to prevent payments of 

ineligible accrued payables to non-identities-of-interest of 

$92,299. If they have been paid, pursue the recovery of this 

amount.

0 

2006-BO-1004 3/3/2006 001-H 

We recommend that the director, Rhode Island Multifamily 

Program Center obtain adequate documentation from the 

owner/management agent for the $4,388 in unsupported accrued 

payables or pursue recovery of this amount.

0 

2006-BO-1004 3/3/2006 002-A 

We recommend that the director, Rhode Island Multifamily 

Program Center obtain adequate documentation from the 

owner/management agent for cash disbursements of $1,053,550 

in unsupported partnership management fees paid to the owner 

or pursue the recovery of double this amount as stipulated in 12 

U.S.C. [United States Code] Sec. 1715z-4a.

0 

2006-BO-1004 3/3/2006 002-B 

We recommend that the director, Rhode Island Multifamily 

Program Center obtain adequate documentation from the 

owner/management agent for unsupported accrued payables of 

$108,600 payable to the owner or pursue the recovery of double 

this amount as stipulated in 12 U.S.C. [United States Code] Sec. 

1715z-4a.

0 

2006-BO-1004 3/3/2006 002-C 

We recommend that the director, Rhode Island Multifamily 

Program Center obtain justification from the owner/management 

agent supporting the cash disbursements for unsupported costs 

paid to the owner/management agent of $1,248,668 or pursue 

the recovery of double this amount as stipulated in 12 U.S.C. 

[United States Code] Sec. 1715z-4a.

0 

2006-BO-1004 3/3/2006 002-D 

We recommend that the director, Rhode Island Multifamily 

Program Center take appropriate action to prevent unnecessary 

cash disbursements after our audit period, including the payment 

of questionable accrued payables to the management agent of 

$40,077. If they have been paid, pursue the recovery of double 

this amount as stipulated in 12 U.S.C. [United States Code] Sec. 

1715z-4a.

0 

105 █

███ 105 105 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2006-BO-1004 3/3/2006 002-E 

We recommend that the director, Rhode Island Multifamily 

Program Center pursue recovery of double the amount of 

$112,254 in questionable salary payments paid to the assistant 

administrator as stipulated in 12 U.S.C. [United States Code] 

Sec. 1715z-4a.

0 

2007-CH-1011 7/23/2007 001-A 

We recommend that the director of HUD’s Cleveland Office of 

Public Housing require the Agency to reimburse its program 

administrative fee reserve $1,636,075 from the appropriate funds 

for the excessive administrative expenses cited in this finding.

1,636,075

2007-CH-1005 3/23/2007 001-A 

We recommend that the director of HUD’s Cleveland Office of 

Public Housing require the Authority to provide documentation 

to support that the $913,365 in refunding savings cited in this 

finding was used to provide affordable, decent, safe, and sanitary 

housing to very low-income households or reimburse from 

nonfederal funds its refunding savings account(s), as 

appropriate, to be able to trace its use of the savings.

913,365

2007-NY-1011 8/17/2007 001-A 

We recommend that the director of HUD’s Office of Public 

Housing instruct the Authority to reimburse the capital fund 

program $818,536 related to the administrative and management 

improvement costs that exceeded HUD limitations.

818,536

2007-NY-1011 8/17/2007 001-C 

We recommend that the director of HUD’s Office of Public 

Housing instruct the Authority to reduce the Authority’s future 

capital funds by $632,039 related to the fiscal years 2003 and 

2004 capital funds transferred to the low-rent public housing 

program.

505,631

2007-AT-1010 8/14/2007 001-B 

Reimburse from nonproject sources $656,536 for salary and 

benefits that represented Foundation costs. The repayments 

should be deposited to the residual receipt account for each 

affected project.

462,199

2007-NY-1006 5/24/2007 001-A 

We recommend that the director of HUD’s Office of Public 

Housing instruct the Authority to reimburse HUD for the 

excessive administrative fee charge of $692,990 in capital funds 

in accordance with the procedures described in 24 CFR 905.120. 

415,796

2007-PH-1013 9/27/2007 001-B 

Repay its low-rent public housing program $834,969 from 

nonfederal funds for the ineligible disbursements related to the 

credit union.

384,969

106 █

███ 106 106 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2008-CH-1001 11/19/2007 001-D 

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Authority to reimburse its Public 

Housing program $337,870 from nonfederal funds for the rental 

income received by its nonprofit from the Turnkey III properties.

292,820

2007-AT-1010 8/14/2007 001-C 

Reimburse from nonproject sources $458,101 that the 

Foundation paid itself for excessive janitorial costs. The 

repayments should be deposited to the residual receipt account 

for each affected project.

238,685

2007-CH-1010 7/20/2007 002-C 

We recommend that the director of HUD’s Chicago Office of 

Public Housing require the Authority to provide supporting 

documentation or reimburse its program $140,521 ($126,224 in 

housing assistance and utility allowance payments plus $14,297 

in related administrative fees) from nonfederal funds for the 

unsupported payments and associated administrative fees related 

to the 20 households cited in this finding.

140,521

2007-KC-1004 1/12/2007 002-A Repay from nonfederal sources, the $147,934 improperly spent 

for employee leave. 124,339

2007-AT-1010 8/14/2007 002-A 

Reimburse current tenants for any portion of the $93,677 they 

paid for prohibited parking fees. Parking fees collected from 

tenants who have moved and for whom it is not feasible to locate 

them to make the payments should be deposited to the projects’ 

residual receipt accounts.

93,677

2007-NY-1003 3/12/2007 001-F 

We also recommend that the director, Buffalo Office of 

Multifamily Housing, determine the disposition of the escrowed 

funds and bonds (consisting of $50,000 in cash, a $25,000 bond 

and $10,062 in accrued bond interest) set aside for the 

developer-related lawsuit. After determining the proper 

disposition of these funds HUD should determine whether to 

remove the funds from the project’s books and records. This 

would allow $85,062 in encumbered funds to be available for 

paying operating expenses.

85,062

2007-CH-1002 1/25/2007 002-A 

We recommend that the director of HUD’s Detroit Office of 

Public Housing require the Commission to provide supporting 

documentation or reimburse its program $166,782 from 

nonfederal funds for the unsupported operating subsidies related 

to the 51 household files cited in this finding.

80,637

107 █

███ 107 107 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2007-CH-1014 9/24/2007 001-B 

We recommend that the Director of HUD’s Chicago Office of 

Public Housing require the Authority to reimburse its program 

$54,024 from nonfederal funds ($47,295 for housing assistance 

payments and $6,729 in associated administrative fees) for the 

28 units that materially failed to meet HUD’s housing quality 

standards.

50,874

2007-CH-1010 7/20/2007 002-A 

We recommend that the director of HUD’s Chicago Office of 

Public Housing require the Authority to reimburse its program 

$39,428 in housing assistance from nonfederal funds for the 

overpayment of housing assistance and utility allowance 

payments cited in this finding.

39,428

2007-CH-1014 9/24/2007 001-F 

We recommend that the Director of HUD’s Chicago Office of 

Public Housing require the Authority to reimburse its program 

$52,421 from nonfederal funds in associated administrative fees 

for the 402 units that were more than 30 days late in receiving 

their annual inspections.

37,831

2007-AT-1010 8/14/2007 001-F 

Reimburse from nonproject sources any portion of $31,905 in 

parking fees that it cannot support as representing necessary and 

reasonable project costs. The repayments should be deposited to 

the residual receipt account for each affected project.

31,905

2007-AT-1010 8/14/2007 001-E 

Reimburse from nonproject sources $26,306 that the Foundation 

paid itself for excessive retirement plan costs. The repayments 

should be deposited to the residual receipt account for each 

affected project.

26,306

2007-NY-1003 3/12/2007 002-A 

We recommend that the director of the Buffalo Office of 

Multifamily Housing instruct the owner and agent to negotiate a 

management fee that is reasonable and commensurate with the 

services that are provided. The management fee should not 

exceed an amount ordinarily paid for such services, resulting in 

$25,974 in cost savings.

25,974

2007-CH-1016 9/28/2007 001-B 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to reimburse its 

program $38,537 from nonfederal funds ($35,918 for housing 

assistance payments and $2,619 in associated administrative 

fees) for the 38 units that materially failed to meet HUD’s 

housing quality standards.

7,068

108 █

███ 108 108 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2007-AT-1010 8/14/2007 001-G 

Reimburse from nonproject sources $6,352 representing 

Foundation expenses. The repayments should be deposited to 

the residual receipt account for each affected project. 

6,352

2007-CH-1010 7/20/2007 001-A 

We recommend that the director of HUD’s Chicago Office of 

Public Housing require the Authority to reimburse its program 

$30,360 from nonfederal funds ($27,944 for housing assistance 

payments and $2,416 in associated administrative fees) for the 

35 units that materially failed to meet HUD’s housing quality 

standards.

6,304

2007-KC-1004 1/12/2007 003C Repay $29,095 in unauthorized vehicle allowances. 5,501

2007-CH-1012 8/3/2007 001-B 

We recommend that the director of HUD’s Detroit Office of 

Public Housing require the Commission to reimburse the 

applicable program $27,578 ($9,644 for the overpayment of 

housing assistance and utility allowances and $17,934 in 

administrative fees associated with the overpayment and 

underpayment of housing assistance and utility allowances for 

the 48 households) from nonfederal funds.

5,160

2007-NY-1003 3/12/2007 002-B 

We also recommend that HUD review and approve the 

negotiated management fee to ensure that it is reasonable in 

relation to the services provided to the project.

0 

2007-CH-1010 7/20/2007 003-C 

We recommend that the director of HUD’s Chicago Office of 

Public Housing require the Authority to review the remaining 36 

(70 minus 34) zero-income households as of September 11, 

2006, to determine whether they had unreported income. For 

households that received excessive housing assistance and utility 

allowance payments, the Authority should pursue collection 

and/or reimburse its program the applicable amount from 

nonfederal funds.

0 

2009-LA-1005 12/30/2008 002-A 

Execute loan agreements between the City and its Agency 

indicating specific loan terms for repayment of the loans totaling 

$139,201,997 ($63,072,960 principal and $76,129,037 interest), 

which would result in an estimated additional recovery of 

$7,269,854 in CDBG program income over the first year.

64,039,600

2008-AO-1002 1/30/2008 001-C 

Review all of the remaining 392 grants coded ineligible or 

lacking an eligibility determination and either support or repay 

$14,697,812 disbursed for them.

4,615,112

109 █

███ 109 109 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2008-CH-1008 4/30/2008 001-D 

We recommend that the Director of HUD's Detroit Office of 

Public Housing require the Commission to reimburse its Public 

Housing program $745,436 from nonfederal funds for the 

improper use of funds cited in this finding.

700,454

2008-CH-1006 4/15/2008 002-D 

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Agency to provide supporting 

documentation or reimburse its program $587,022 from 

nonfederal funds for the unsupported payments related to the 59 

households cited in this finding.

587,022

2008-AO-1002 1/30/2008 001-A Repay $743,344 disbursed for the 17 ineligible grants to its 

Road Home program. 403,904

2008-AT-0803 9/30/2008 001-A Require the Authority to collect $274,914 from the Development 

Corporation and reimburse its operating fund. 274,914

2009-BO-1002 11/6/2008 001-E 

Request from responsible management agents supporting 

documentation for the $265,412 in unsupported costs charged to 

the project so that the eligibility of these costs can be 

determined. For any amounts determined to be ineligible, the 

project owner should repay or seek reimbursement from 

responsible management agent to pay the project from nonproject funds or remove payables from the project’s accounting.

265,412

2009-AT-1001 10/20/2008 001-C 

Provide support for $523,335 in payments made for various 

purchases or repay any unsupported costs to its public housing 

operating and capital improvement programs from nonfederal 

funds.

210,174

2008-CH-1006 4/15/2008 002-A 

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Agency to reimburse its program 

$192,854 ($113,973 for overpaid housing assistance, $17,257 

for overpaid utility allowances, and $61,624 in associated 

administrative fees) for the 63 households cited in this finding 

from nonfederal funds.

192,854

2008-CH-1007 4/18/2008 001-D 

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Authority to provide supporting 

documentation or reimburse its program $214,157 ($194,694 in 

housing assistance and utility allowances plus $19,463 in related 

administrative fees) from nonfederal funds for the unsupported 

payments and associated administrative fees related to the 30 

households cited in this finding.

190,363

2009-AT-1001 10/20/2008 001-A 

Repay $185,764 to it public housing operating and capital 

improvement programs for ineligible payments made to or on 

behalf of the former board chairman from nonfederal funds.

185,764

110 █

███ 110 110 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2009-AT-1001 10/20/2008 001-B 

Provide support for $182,369 in payments made to or on behalf 

of the former executive director and former lease enforcement 

officer or repay any unsupported costs to its public housing 

operating and capital improvement programs from nonfederal 

funds.

177,369

2008-CH-1003 2/15/2008 001-A 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to provide supporting 

documentation or reimburse its Public Housing program 

$153,223 ($22,092 for household eligibility and $131,131 for 

continued occupancy) from nonfederal funds for the 

unsupported operating subsidies related to the 36 household files 

cited in this finding.

153,223

2008-CH-1007 4/18/2008 003-G 

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Authority to provide documentation 

to support its allocation of time spent correctly administering its 

Family Self-Sufficiency Program or reimburse its program’s 

undesignated fund balance for administration account from 

nonfederal funds the appropriate portion of the $151,661 in 

Coordinator funds received for fiscal years 2004 and 2005 that 

were incorrectly administered.

151,661

2008-CH-1003 2/15/2008 002-B 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to provide support that 

the use of $82,774 ($27,286 to three family members, $23,418 

to two independent contractors, $22,150 to CLM Architects, and 

$9,920 to Harold Dunne, Attorney at Law) in Public Housing 

program funds for housing maintenance, cleaning, and 

professional services were reasonable or reimburse its program 

from nonfederal funds for the applicable amount.

82,774

2009-BO-1002 11/6/2008 001-B 

Reimburse or require the responsible management agent(s) to 

reimburse $64,601 to the project for ineligible project costs of 

$15,331 and for ineligible administrative, site supervisor, HUD 

202 and site management fees of $49,270.

64,601

2008-CH-1003 2/15/2008 002-A 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to provide supporting 

documentation for the use of $61,202 for work performed under 

its Public Housing Capital Fund program or reimburse its 

program from nonfederal funds for the applicable amount.

61,202

2008-CH-1016 9/29/2008 001-B 

Reimburse its program $55,047 from nonfederal funds ($50,356 

for housing assistance payments and $4,691 in associated 

administrative fees) for the 28 units that materially failed to meet 

HUD’s housing quality standards.

51,815

111 █

███ 111 111 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2008-CH-1005 4/10/2008 001-A

We recommend that the Director of HUD’s Chicago Office of 

Public Housing require the Authority to reimburse its program 

$52,737 from nonfederal funds for the overpayment of housing 

assistance and utility allowances cited in this finding.

49,471

2008-CH-1006 4/15/2008 003-A

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Agency to reimburse its program 

$47,543 ($36,748 for housing assistance payments and $10,795 

for utility allowance payments) from nonfederal funds for the 

inappropriate housing assistance payments related to the 17 

households cited in this finding.

47,543

2008-CH-1005 4/10/2008 003-A

We recommend that the Director of HUD’s Chicago Office of 

Public Housing require the Authority to pursue collection from 

the applicable households or reimburse its program $46,619 

from nonfederal funds for the overpayment of housing assistance 

and utility allowances cited in this finding.

46,619

2008-CH-1013 9/24/2008 001-A

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to reimburse its 

program $46,478 from nonfederal funds for the 34 units cited in 

this finding that were in material noncompliance.

46,478

2008-CH-1006 4/15/2008 001-A

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Agency to reimburse its program 

$41,094 from nonfederal funds ($37,280 for program housing 

assistance payments and utility allowances plus $3,814 in 

associated administrative fees) for the 38 units that materially 

failed to meet HUD’s housing quality standards and/or the 

Corporation’s housing standards.

41,094

2009-BO-1002 11/6/2008 001-D

Ensure that $23,499 for unreasonable late charges on fuel bills 

and sewer lien penalties and $6,779 for unreasonable payments 

to a lawn care company be reimbursed to the project from nonproject funds.

30,278

2008-CH-1003 2/15/2008 001-B

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to reimburse its Public 

Housing program $28,663 ($16,262 plus $12,401) from 

nonfederal funds for the lost total household payments for 23 

households cited in this finding.

28,663

2008-CH-1007 4/18/2008 002-A

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Authority to pursue collection from 

the applicable households or reimburse its program $28,267 

from nonfederal funds for the overpayment of housing assistance 

and utility allowances cited in this finding.

28,267

112 █

███ 112 112 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2008-CH-1013 9/24/2008 002-A

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to reimburse its 

program $29,148 from nonfederal funds for the seven long-term 

vacant units it inappropriately included in its program operating 

subsidy calculations.

26,538

2008-CH-1005 4/10/2008 002-E

We recommend that the Director of HUD’s Chicago Office of 

Public Housing require the Authority to provide documentation 

to support its allocation of time spent correctly administering the 

Family Self-Sufficiency Program or reimburse its Coordinator 

funds from nonfederal funds the appropriate portion of the 

$72,235 used when the Authority’s Family Self-Sufficiency 

Program was incorrectly administered.

21,965

2008-CH-1007 4/18/2008 002-C

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Authority to reimburse its program 

$21,411 from nonfederal funds for the overpayment of housing 

assistance and utility allowances due to not including household 

reported income.

21,411

2008-CH-1007 4/18/2008 003-C

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Authority to provide documentation 

to support its use of funds for the six Family Self-Sufficiency 

Program participants whose contracts were extended contrary to 

HUD’s requirements or reimburse its program $14,928 from 

nonfederal funds.

14,928

2008-CH-1005 4/10/2008 001-C

We recommend that the Director of HUD’s Chicago Office of 

Public Housing require the Authority to reimburse its program 

$14,603 from nonfederal funds for the inappropriate 

administrative fees related to the 32 households in this finding.

14,603

2008-CH-1005 4/10/2008 002-A

We recommend that the Director of HUD’s Chicago Office of 

Public Housing require the Authority to reimburse its program 

$14,576 from nonfederal funds for the escrow funds overpaid to 

the seven participants cited in this finding.

14,576

2008-CH-1003 2/15/2008 001-C

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to reimburse the 

appropriate households $13,070 for the underpayment of 

housing assistance and utility allowance payments cited in this 

finding.

13,070

2008-CH-1007 4/18/2008 002-B

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Authority to pursue collection from 

the applicable households or reimburse its program $12,505 

from nonfederal funds for the overpayment of housing assistance 

and utility allowances cited in this finding related to the 

underreporting of income.

12,505

113 █

███ 113 113 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2008-CH-1006 4/15/2008 002-C 

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Agency to reimburse its program 

$9,815 from nonfederal funds for the program administrative 

fees related to the underpaid housing assistance payments.

9,815

2008-CH-1003 2/15/2008 001-F 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to reimburse its Public 

Housing program $7,932 in operating subsidies from nonfederal 

funds for the two properties sold by the City.

4,532

2008-CH-1005 4/10/2008 003-B 

We recommend that the Director of HUD’s Chicago Office of 

Public Housing require the Authority to reimburse its program 

$11,225 from nonfederal funds for the inappropriate 

administrative fees related to the 47 households cited in this 

finding.

1,668

2008-CH-1006 4/15/2008 002-E 

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Agency to determine the appropriate 

administrative fees for the applicable households for which it is 

unable to provide supporting documentation cited in 

recommendation 2D and reimburse its program the applicable 

amount from nonfederal funds.

0 

2008-CH-1007 4/18/2008 003-D 

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Authority to review the files for the 

20 participants whose contracts of participation expired between 

July 1, 2005, and June 30, 2007, to support its use of program 

funds for the escrow accounts, or reimburse its program the 

applicable amount from nonfederal funds.

0 

2008-AT-0803 9/30/2008 001-B Apply appropriate sanctions if the Authority does not comply 

with its payback agreement. 0 

2009-AT-0001 9/28/2009 001-A 

Ensure that field offices require participating jurisdictions to 

close out in a timely manner $62,201,487 in activities reflected 

in its open activities report that are more than five years old and 

cancel the fund balances.

62,201,487

2009-AT-0001 9/28/2009 001-B 

Require participating jurisdictions to reimburse HUD from 

nonfederal sources any portion of the $11,634,558 for activities 

listed in appendix C that HUD determines had been terminated, 

voluntarily or involuntarily. When making this determination, 

HUD should consider the participating jurisdictions’ lack of 

timely physical completion and/or production of affordable 

housing occupied by HOME income-eligible individuals.

11,634,558

114 █

███ 114 114 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2009-CH-1002 1/23/2009 003-B 

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Agency to provide supporting 

documentation or reimburse its program $2,081,512 from 

nonfederal funds for the 11 Section 8 project-based projects 

cited in this finding.

2,081,512

2009-NY-1012 5/20/2009 001-B 

We recommend that the Director, Buffalo Office of Community 

Planning and Development, require the City of Rome to 

establish a schedule for documenting completion of the General 

Cable activity and the jobs retained and/or created at the site and 

reimburse HUD any portion of the $2,953,754 in CDBG funds 

expended on the activity for costs that do not qualify as meeting 

the job creation requirement.

1,100,000

2010-PH-1801 12/17/2009 002-B 

Provide documentation to support the source and use of 

$801,000 transferred into and withdrawn from its nonfederal 

account or reimburse HUD or the appropriate programs from 

nonfederal sources for any amounts that it cannot support.

447,810

2009-AO-1002 5/5/2009 001-B Either support or repay $441,027 disbursed for five unsupported 

grants. 441,027

2009-AO-1002 5/5/2009 001-A Repay $294,060 disbursed for three ineligible grants to its Road 

Home program. 294,060

2009-AT-1009 7/20/2009 002-A 

Require the Authority to propose a legal solution regarding the 

ownership structure of the nonprofit organization. If a legal 

solution is not possible, the Director should require the 

Authority to repay its public housing program $221,531 in 

nonfederal funds or the current amount owed that the Authority 

advanced to its nonprofit organization.

256,950

2009-BO-1009 8/4/2009 001-A 

Deposit $254,470 for the ineligible disbursements $236,439 + 

$12,559 + $5,472. Cited in this report into the project’s reserve 

for replacement or a restricted capital account that requires HUD 

approval for the release of the funds.

254,470

2010-PH-1801 12/17/2009 001-B 

Provide documentation to support the $282,000 expended to 

acquire and dispose of the vacant commercial building or 

reimburse the applicable program from nonfederal sources for 

any amounts that it cannot support.

242,520

2009-AO-1001 5/5/2009 001-A Repay $228,930 disbursed for five ineligible grants to its Road 

Home program. 228,930

2009-CH-1002 1/23/2009 003-A 

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Agency to reimburse its program 

$211,680 from nonfederal funds for the Section 8 administrative 

fees received related to its inappropriate program administration 

cited in this finding.

211,680

115 █

███ 115 115 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2009-CH-1007 4/28/2009 002-D 

We recommend that the Director of HUD’s Chicago Office of 

Public Housing require the Authority to review the remaining 

284 (333 minus 49) households claiming zero income as of 

October 2, 2008, to determine whether the households had 

unreported income. For households that received excessive 

housing assistance and utility allowance payments, the Authority 

should pursue collection and/or reimburse its program the 

applicable amount from nonfederal funds.

183,889

2010-PH-1801 12/17/2009 001-D 

Provide documentation to support payments totaling $180,000 

for insurance or reimburse HUD or the applicable program from 

nonfederal sources for any amounts that it cannot support.

180,000

2009-CH-1011 7/31/2009 003-A 

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Authority to reimburse its low-rent 

housing program $136,500 from nonfederal funds for the former 

executive director’s payments as the resident agent of the 

nonprofits in addition to his salary.

136,500

2009-KC-1005 3/2/2009 001-B Repay the voucher program fund from nonfederal sources 

$64,528 in improper housing assistance. 58,059

2009-LA-1008 3/18/2009 001-A 

Reimburse HUD’s Federal Housing Administration insurance 

fund $73,750 less amounts repaid after the completion of the 

audit ($15,000) for the ineligible disbursements cited in this 

report.

52,875

2009-NY-1011 5/15/2009 002-G 

We recommend that the Director, Office of Public Housing, 

New York, instruct Authority officials to seek repayment of 

$50,237 in ineligible housing assistance payments.

50,237

2009-CH-1007 4/28/2009 001-C 

We recommend that the Director of HUD’s Chicago Office of 

Public Housing require the Authority to pursue collection from 

the applicable households or reimburse its program $31,668 

from nonfederal funds for the overpayment of housing assistance 

due to unreported income.

26,044

2009-CH-1007 4/28/2009 001-A 

We recommend that the Director of HUD’s Chicago Office of 

Public Housing require the Authority to reimburse its program 

$25,074 from nonfederal funds for the overpayment of housing 

assistance cited in this finding.

25,074

116 █

███ 116 116 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2010-PH-1801 12/17/2009 001-C 

Provide documentation to support payments totaling $132,000 

for vehicle services or reimburse HUD or the applicable 

program from nonfederal sources for any amounts that it cannot 

support.

24,680

2009-CH-1007 4/28/2009 002-A 

We recommend that the Director of HUD’s Chicago Office of 

Public Housing require the Authority to pursue collection from 

the applicable households or reimburse its program $41,044 

($41,569 minus $525) from nonfederal funds for the 

overpayment of housing assistance cited in this finding.

19,583

2009-CH-1007 4/28/2009 001-H 

We recommend that the Director of HUD’s Chicago Office of 

Public Housing require the Authority to reimburse its program 

$19,071 from nonfederal funds for the improper administrative 

fees related to the households cited in this finding.

19,071

2009-PH-1011 7/30/2009 001-B 

Reimburse HUD’s program $66,934 from nonfederal funds 

($60,637 for housing assistance payments and $6,297 in 

associated administrative fees) for the 37 units that materially 

failed to meet HUD’s housing quality standards. 

18,759

2009-CH-1007 4/28/2009 001-D 

We recommend that the Director of HUD’s Chicago Office of 

Public Housing require the Authority to provide support or 

reimburse its program $16,487 from nonfederal funds for the 

unsupported overpayment of housing assistance and utility 

allowances for the nine households cited in this finding.

14,336

2009-BO-1009 8/4/2009 001-H 

Pursue double damages remedies against the responsible parties 

for the ineligible/inappropriate and applicable portion of the 

unsupported disbursements that were used in violation of the 

project’s regulatory agreement.

0 

2009-BO-1009 8/4/2009 001-I 

Pursue civil money penalties and administrative sanctions, as 

appropriate, against the owner, operator, and/or their 

principals/owners for their part in the regulatory violations cited 

in this report.

0 

2009-SE-0003 9/1/2009 001-A 

Revise the PBCA initiative guides (e.g., the monitoring and 

evaluation guide and the Section 8 guidebook) to clarify 

inconsistencies or unclear guidance for monitoring the PBCAs 

including clarification of PBCA performance that requires 

issuing incentive fees or assessment of disincentives.

0 

117 █

███ 117 117 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2009-SE-0003 9/1/2009 001-B 

Ensure that HUD staff follow the revised guidance when 

conducting the annual compliance reviews and monthly remote 

reviews to ensure that it receives quality work and the best value 

for funds spent on contract administration activities.

0 

2009-SE-0003 9/1/2009 001-C 

Reassess the resources allocated to overseeing the PBCAs to 

ensure that the resources are sufficient to monitor their 

performance.

0 

2009-AT-0001 9/28/2009 001-C Recapture any shortfalls generated by the closure and 

deobligation of fund balances associated with the open activities. 0 

2009-AT-0001 9/28/2009 002-A 

Establish and implement procedures to monitor the accuracy of 

commitments that participating jurisdictions enter into the 

information system. These procedures should include expanding 

HUD’s risk rating system to include risk factors for this review 

area and development of an appropriate monitoring checklist to 

ensure consistency and thoroughness of coverage among field 

offices.

0 

2010-PH-1003 11/25/2009 001-B 

Develop and implement adequate procedures and controls to 

ensure that disbursements made from its operating account are 

for expenses that are reasonable, necessary, and in accordance 

with program requirements, thereby ensuring that an estimated 

$81,257 will be used for eligible purposes annually.

0 

2010-PH-1003 11/25/2009 002-F 

Develop and implement procedures to ensure that housing 

assistance payments are correctly calculated and supported with 

the required documentation. The procedures, at a minimum, 

should include a statement from management certifying that the 

determined housing assistance payment amounts have been 

reviewed by management and prepared in accordance with HUD 

requirements.

0 

2011-FO-0003 11/15/2010 002-C 

Review the 510 obligations which were not distributed to the 

program offices during the open obligations review and 

deobligate amounts tied to closed or inactive projects, including 

the $27.5 million we identified during our review as expired or 

inactive.

27,500,000

118 █

███ 118 118 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2010-AT-1011 8/25/2010 001-B 

Determine the eligibility of the $9,027,082 disbursed for projects 

with signs of slow progress and reevaluate the feasibility of 

these activities. The Government of Puerto Rico must reimburse 

HUD from non-Federal funds for activities that HUD determines 

to have been terminated and reprogram and put to better use any 

unexpended funds associated with the terminated activities.

9,027,082

2010-AT-1009 8/13/2010 001-A 

Require the authority to provide support showing the eligibility 

and reasonableness of $9,784,157 (Footnote 2: Total 

disbursements of $13,371,572 were adjusted to consider 

$3,576,521 questioned in recommendation 1B and $10,894 

questioned in recommendation 1C.) disbursed for the 

surveillance system and multifunction printers or reimburse this 

amount to its operational fund account or HUD, as appropriate, 

from non-Federal funds.

4,892,078

2010-CH-1008 6/15/2010 001-A 

We recommend that the Director of HUD’s Chicago Office of 

Public Housing require the Authority to provide supporting 

documentation or reimburse its program $3,861,652 ($3,483,294 

in housing assistance payments plus $378,358 in associated 

program administrative fees) from non-Federal funds for the 

housing assistance payments and associated administrative fees 

for the unsupported program projects cited in this finding.

3,861,652

2010-AT-1006 6/11/2010 001-A 

Require the Department to reimburse its HOME treasury 

account from non-Federal funds $2,003,356 for disbursements 

associated with terminated activities that did not meet HOME 

objectives.

2,003,356

2010-AT-1010 8/23/2010 001-B 

Require the Authority to reimburse the net restricted assets fund 

account from non-Federal funds the $2,583,244 or the current 

amount owed.

1,969,809

2010-AT-1006 6/11/2010 003-A 

Require the Department to collect $1,269,032 associated with 

the 17 overdue loans and put the program income generated to 

better use in accordance with HUD requirements.

1,269,032

119 █

███ 119 119 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2010-NY-1806 9/22/2010 001-A 

We recommend that HUD’s Associate General Counsel for 

Program Enforcement determine legal sufficiency and if legally 

sufficient, pursue remedies under the Program Fraud Civil 

Remedies Act (31 U.S.C 3801-3812) and/or civil money 

penalties (24 CFR 30.35) against Security Atlantic and/or its 

principals for incorrectly certifying to the integrity of the data or 

that due diligence was exercised during the underwriting of six 

loans that resulted in actual losses of $452,217 on five loans and 

the potential loss of $101,513 on one loan, which could result in 

affirmative civil enforcement action of approximately 

$1,152,460. Double damages for actual loss amounts related to 

five loans ($452,217) and the potential loss ($101,513) related to 

one loan ($553,730 x 2 = $1,107,460) plus $45,000, which is a 

$7,500 fine for each of the six loans with material underwriting 

deficiencies.

553,730

2010-AT-1009 8/13/2010 001B

Require the authority to reimburse its operational fund account 

or HUD, as appropriate, from non-Federal funds $3,576,521 

paid for equipment that did not provide the intended benefits 

and/or was unaccounted for.

452,192

2010-AT-1003 4/28/2010 001-I 

Require the Authority to provide support that $446,918 in 

contracts were fairly and openly competed or reimburse its 

public housing and capital improvement program from 

nonfederal funds.

446,918

2010-CH-1008 6/15/2010 002-A 

We recommend that the Director of HUD’s Chicago Office of 

Public Housing require the Authority to reimburse its program 

$360,864 ($268,795 in housing assistance payments plus 

$92,069 in program-associated administrative fees) from nonFederal funds for the overpaid housing assistance and associated 

administrative fees cited in this finding.

360,864

2011-PH-1005 12/23/2010 003-B 

Deobligate $279,245 in available funds associated with the 

ineligible CHDO and reprogram the funds for other eligible 

HOME activities, thereby putting the funds to better use.

279,245

2010-AT-1003 4/28/2010 001-J 

Require the Authority to provide support for the $275,282 in 

capital fund drawdowns or reimburse its capital improvement 

program from nonfederal funds.

275,282

2010-AT-1003 4/28/2010 001-F 

Require the Authority to provide support for $264,229 in 

disbursements or repay any unsupported costs to its public 

housing operating and capital improvement program from 

nonfederal funds.

264,229

120 █

███ 120 120 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2010-CH-1808 7/22/2010 001-A 

We recommend that HUD’s Associate General Counsel for 

Program Enforcement determine legal sufficiency and if legally 

sufficient, pursue remedies under the Program Fraud Civil 

Remedies Act against Mac-Clair and/or its principals for 

incorrectly certifying to the integrity of the data or that due 

diligence was exercised during the underwriting of seven loans 

that resulted in losses to HUD totaling $562,551 which could 

result in affirmative civil enforcement action of approximately 

$1,177,602.

243,000

2010-PH-1008 5/11/2010 001-B 

Provide documentation to demonstrate that $1,945,050 was used 

for eligible activities that met the criteria of its HUD-approved 

budget line items or repay HUD from non-Federal funds.

227,772

2010-NY-1011 4/7/2010 001-A 

We recommend that the Director, Office of Public Housing, 

New York, instruct the Authority to reimburse from non-Federal 

funds the $219,715 expended for ineligible costs as follows; 

$215,402 to HUD, and $4,313 to the 2007 ROSS Family grant.

219,715

2010-CH-1008 6/15/2010 003-A 

We recommend that the Director of HUD’s Chicago Office of 

Public Housing require the Authority to reimburse its program 

$211,573 ($188,722 in housing assistance payments plus 

$22,851 in associated program administrative fees) from nonFederal funds for the housing assistance and associated 

administrative fees for the 14 households cited in this finding.

211,573

2010-AT-1003 4/28/2010 001-D 

Require the Authority to account for $134,889 in tenant rent 

receipts or repay any unsupported amounts to its public housing 

operating program from nonfederal funds.

134,889

2010-NY-1011 4/7/2010 001-B 

We recommend that the Director, Office of Public Housing, 

New York, instruct the Authority to provide documentation for 

the unsupported Family Self-Sufficiency and ROSS grant 

program costs of $100,637 so that HUD can make an eligibility

determination. If adequate documentation cannot be provided, 

these costs should be repaid from non-Federal funds.

100,637

2010-PH-1012 7/27/2010 001-A 

Provide documentation to support that payments for goods and 

services totaling $1,736,962 were fair and reasonable or 

reimburse the applicable programs from non-Federal funds for 

any amounts that it cannot support.

82,064

2010-CH-1008 6/15/2010 001-B 

We recommend that the Director of HUD’s Chicago Office of 

Public Housing require the Authority to reimburse its program 

$34,650 ($33,632 in housing assistance payments plus $1,018 in 

associated program administrative fees) from non-Federal funds 

for the inappropriate retroactive payments and associated 

administrative fees for the two projects cited in this finding.

34,650

121 █

███ 121 121 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2010-AT-1003 4/28/2010 001-H 

Require the Authority to support the $27,097 in unreasonable 

costs or reimburse its public housing and capital improvement 

program from nonfederal funds.

27,097

2010-NY-1010 4/7/2010 002-C 

We recommend that the Director, Office of Public Housing, 

New York, instruct the Authority to reimburse from non-Federal 

sources the low-rent program operating account for the ineligible 

expenditure of $38,355.

13,355

2010-NY-1010 4/7/2010 002-B 

We recommend that the Director, Office of Public Housing, 

New York, instruct the Authority to strengthen controls over 

payroll processing to ensure that employees properly account for 

time worked, employee time records are signed, and adequate 

segregation of duties is established in compliance with OMB 

Circular 87.

3,398

2010-AT-1003 4/28/2010 001-G Require the Authority to reimburse its public housing program 

$2,250 for ineligible costs using non-federal funds. 2,250

2010-BO-0001 2/18/2010 001-O Pursue all administrative and/or civil monetary penalties for the 

regulatory and contract violations disclosed in this finding. 0 

2010-AT-1006 6/11/2010 004-B 

Require the Department to review all grant agreements for each 

activity entered into HUD’s information system and correct any 

inaccurate information, including funding amount, activity 

status, and fund type classification.

0 

2010-AT-1011 8/25/2010 001-E 

Recapture any shortfalls generated by the closure and 

deobligation of funds associated with recommendations 1C and 

1D that do not meet statutory requirements for the timely 

commitment and expenditure of funds pursuant to the National 

Defense Authorization Act of 1991 and/or Title II of the 

Cranston-Gonzalez National Affordable Housing Act, as 

amended.

0 

2011-FO-0003 11/15/2010 001-A 

Cease the changes being made to IDIS for the HOME program 

related to the FIFO rules until the cumulative effect of using 

FIFO can be quantified on the financial statements.

0 

2011-FO-0003 11/15/2010 001-B 

Change IDIS so that the budget fiscal year source is identified 

and attached to each activity from the point of obligation to 

disbursement.

0 

2011-FO-0003 11/15/2010 001-C 

Cease the use of FIFO to allocate funds (fund activities) within 

IDIS and disburse grant payments. Match outlays for activity 

disbursements to the obligation and budget fiscal source year in 

which the obligation was incurred, and in addition, match the 

allocation of funds (activity funding) to the budget fiscal year 

source of the obligation.

0 

122 █

███ 122 122 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2011-FO-0003 11/15/2010 001-D 

Include as part of the annual CAPER, a reconciliation of HUD's 

grant management system, IDIS, to grantee financial accounting 

records on an individual annual grant basis, not cumulatively, 

for each annual grant awarded to the grantee.

0 

2011-PH-1005 12/23/2010 004-D 

Require its subrecipient, Greater Washington Urban League, to 

implement a system for maintaining time records that track 

employee time charges to the HOME program as required by 

OMB.

0 

2011-PH-1005 12/23/2010 004-E 

Implement an effective communication process with the 

appropriate OCFO staff to ensure compliance with recordkeeping requirements for the HOME program.

0 

2011-PH-1005 12/23/2010 004-F 

Identify at least annually its universe of HOME program 

recipients and applicable projects to be reviewed and monitor 

this universe including required onsite visits.

0 

2011-PH-1005 12/23/2010 004-G 

Establish a procedure, on an annual basis, on which to base 

future funds obligated for administrative costs on actual 

administrative expenses. This procedure will ensure that any 

amount in excess of actual expenditures is recommitted for use 

on eligible HOME projects.

0 

2012-PH-0001 10/31/2011 001-B 

Direct responsible grantees to justify the use of $66,849,658 that 

it disbursed for cancelled Block Grant program activities or 

repay HUD from non-Federal funds.

66,849,658

2011-NY-1010 4/15/2011 002-B 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct the City to 

provide documentation to justify the $20,143,219 ($4,902,754 + 

$15,240,465) in unsupported transactions recorded in the CDBG 

program income account. Any receipts determined to be 

unrecorded program income should be returned to the CDBG 

program, and any expenditures determined to be ineligible 

should be reimbursed from non-Federal funds.

5,290,982

2011-NY-1010 4/15/2011 002-A 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development require the City to 

suspend incurring costs and/or reimbursing itself for costs paid 

from the City’s municipal general expense account for economic 

development activities until HUD determines whether the City 

has the capacity to carry out its CDBG economic development 

activities in compliance with HUD regulations. If it is 

determined that the City lacks the capacity, the $4,739,829 in 

economic development projects funds remaining for fiscal years 

2008, 2009, and 2010 should be reprogrammed so the City can 

assure HUD that these funds will be put to better use.

4,739,829

123 █

███ 123 123 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2011-AT-1018 9/28/2011 002-D

Require the Municipality to put to better use $2,854,395 

associated with unexpended funds maintained in its local bank 

account.

2,854,395

2011-CH-1006 3/23/2011 003-A

We recommend that the Director of HUD’s Chicago Office of 

Public Housing require the Authority to reimburse its program 

$2,828,244 ($2,609,362 in housing assistance payments and 

$218,882 in associated administrative fees) from non-Federal 

funds for the housing assistance payments and associated 

administrative fees for the 146 households cited in this finding.

2,828,244

2011-NY-1012 8/16/2011 001-A

We recommend that HUD’s Acting Deputy Assistant Secretary 

for Single Family Housing require Ameritrust officials to 

indemnify HUD against any future losses on the 10 loans with 

material underwriting deficiencies. The projected loss is 

$2,742,810 based on HUD’s loss rate of 59 percent of the unpaid 

principal balance of $4,648,830. 

2,742,810

2011-AO-0001 6/22/2011 001-A

Support or repay from non-Federal funds any amounts that it 

cannot support, including $1,568,245 to its operating fund and 

$973,126 to its capital fund paid for (1) contracts that were 

improperly procured, (2) contract overpayments, or (3) contract 

payments made outside of the contract effective dates.

2,541,371

2011-AT-1018 9/28/2011 002-C Require the Municipality to reimburse the HOME program from 

non-Federal funds $2,263,799 paid for ineligible costs. 2,439,751

2011-AT-1018 9/28/2011 001-A

Determine the eligibility of the $2,399,428 disbursed for four 

projects with signs of slow progress and reevaluate the 

feasibility of the activities. Total disbursements of $3,483,086 

were adjusted to consider $713,008 questioned in 

recommendation 2C and $370,650 in recommendation 2A. The 

Municipality must reimburse its HOME program from nonFederal funds for activities that HUD determines to have been 

terminated.

2,399,428

2011-CH-1006 3/23/2011 002-A

We recommend that the Director of HUD’s Chicago Office of 

Public Housing require the Authority to reimburse its program 

$2,303,853 from non-Federal funds for the unallowable 

transactions cited in this finding.

2,303,853

2011-NY-1010 4/15/2011 001-C

We further recommend that the Director of HUD’s Buffalo 

Office of Community Planning and Development instruct the 

City to provide documentation to justify the $1,982,988 in 

unsupported costs associated with street improvement 

expenditures incurred between June 2007 and October 2009. 

Any unsupported costs determined to be ineligible should be 

reimbursed from non-Federal funds.

1,982,988

124 █

███ 124 124 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2011-CH-1012 8/9/2011 002-A 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to reimburse its Capital 

Fund $1,539,629 from non-Federal funds for the ineligible 

payments cited in this finding.

1,539,629

2011-AT-1006 4/8/2011 002-A 

Require the Municipality to submit all supporting documentation 

showing the eligibility and propriety of $1.5 million charged to 

the HOME program for the development of the Villas de Felisa 

housing project or reimburse the program from non-Federal 

funds.

798,000

2011-AT-1018 9/28/2011 001-C 

Require the Municipality to reimburse its HOME program from 

non-Federal funds $766,480 for disbursements associated with 

terminated activities that did not meet HOME objectives.

766,480

2011-NY-1010 4/15/2011 003-A 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development require the City to 

suspend incurring costs and/or reimbursing itself for costs paid 

from the City’s municipal general expense account for clean and 

seal activities until HUD determines whether the City has the 

capacity to carry out its CDBG clean and seal activities in 

compliance with HUD regulations. If it is determined that the 

City lacks the capacity, $744,479 in fiscal year 2010 clean and 

seal program funds should be reprogrammed so the City can 

assure HUD that these funds will be put to better use.

744,479

2011-NY-1010 4/15/2011 003-C 

We further recommend that the Director of HUD’s Buffalo 

Office of Community Planning and Development instruct the 

City to provide documentation to justify the $716,622 ($545,607 

+ $24,069 + $146,946) in unsupported clean and seal costs 

incurred so that HUD can make an eligibility determination. 

Any costs determined to be ineligible should be reimbursed from 

non-Federal funds.

716,622

2011-AT-1006 4/8/2011 001-C 

Require the Municipality to submit all supporting documentation 

showing the allowability and allocability of $1,062,991 

disbursed for participant families at the Villas de Felisa housing 

project or reimburse this amount to its HOME treasury account 

or HUD, as appropriate, from non-Federal funds. Footnote 6: 

Total disbursements of $2,836,000 were adjusted to consider 

$1,500,000 questioned in recommendation 2A and 

$273,009ineligible in recommendation 1D.

574,566

2011-AO-0001 6/22/2011 001-J 

As related to DHAP, support or repay from non-Federal funds 

any amounts that it cannot support for a total of $435,442 to its 

operating fund, which includes (1) $140,966 and $96,525 

disbursed to two DHAP case managers who were paid without 

an executed contract and for unsubstantiated, excessive salary 

increases; and (2) $197,951 disbursed to the three DHAP case 

managers for unsubstantiated, excessive salary increases.

435,442

125 █

███ 125 125 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2011-CH-1012 8/9/2011 002-B 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to return the $411,228 

in excess capital fund draws cited in this finding.

411,228

2011-CH-1012 8/9/2011 002-D 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to provide supporting 

documentation or reimburse its Capital Fund $394,683 from 

non-Federal funds for the unsupported costs cited in this finding.

394,683

2011-FW-0002 4/26/2011 001-E 

Review the $756,833 in unsupported costs at the two properties 

identified in this report, determine their validity, and take 

appropriate action.

386,562

2011-CH-1006 3/23/2011 002-B 

We recommend that the Director of HUD’s Chicago Office of 

Public Housing require the Authority to provide supporting 

documentation or reimburse its program $330,457 from nonFederal funds for the unsupported transactions cited in this 

finding.

330,457

2012-NY-1002 10/18/2011 001-B 

We recommend that the Director of HUD’s New York City 

Office of Community Planning and Development instruct City 

officials to provide documentation to justify the $329,937 in 

unsupported salary costs incurred between June and September 

2010. Any unsupported costs determined to be ineligible should 

be reimbursed from non-Federal funds. 

329,937

2011-NY-1010 4/15/2011 003-B 

We further recommend that the Director of HUD’s Buffalo 

Office of Community Planning and Development instruct the 

City to reimburse from non-Federal funds the $304,506 related 

to ineligible clean and seal code enforcement costs.

304,506

2011-AT-1006 4/8/2011 001-D 

Require the Municipality to reimburse its HOME treasury 

account or HUD, as appropriate, from non-Federal funds 

$273,009 paid for land acquired for the Villas de Felisa housing 

project that did not provide the intended benefits.

255,989

2011-AT-1006 4/8/2011 001-A 

Require the Municipality to reimburse its HOME treasury 

account or HUD, as appropriate, from non-Federal funds 

$4,433,035 for disbursements associated with two activities that 

did not meet HOME program objectives. Footnote 5: Total 

disbursements of $4,444,697 were adjusted to consider $11,662 

questioned in recommendation 2B.

199,037

2011-NY-1012 8/16/2011 001-B 

We recommend that HUD’s Acting Deputy Assistant Secretary 

for Single Family Housing require Ameritrust officials to 

reimburse HUD for the loss of $183,327 that resulted from the 

amount of the claim and associated fees paid on one loan with 

material underwriting deficiencies.

183,327

126 █

███ 126 126 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2011-CH-1012 8/9/2011 003-A 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to reimburse its 

appropriate programs $180,649 from non-Federal funds for the 

ineligible payments cited in this finding.

180,649

2011-CH-1012 8/9/2011 004-A 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to reimburse its Capital 

Fund $127,050 from non-Federal funds for the ineligible 

payments cited in this finding.

127,050

2011-NY-1010 4/15/2011 001-B 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development reimburse from nonFederal funds $162,923 ($134,711+$28,212) expended on 

ineligible costs pertaining to street improvement projects not 

done and a duplicate reimbursement.

120,199

2011-CH-1012 8/9/2011 004-B 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to reimburse its 

operating fund $107,692 from non-Federal funds for ineligible 

payments cited in this finding.

107,692

2011-CH-1006 3/23/2011 003-B 

We recommend that the Director of HUD’s Chicago Office of 

Public Housing require the Authority to provide supporting 

documentation or reimburse its program $69,793 from nonFederal funds for the O’Hare Modernization Program funds 

received for the seven households cited in this finding.

69,793

2011-CH-1018 9/30/2011 003-A 

We recommend that the Director of Public Housing, Detroit 

Office, require the Commission to reimburse wage restitution of 

$66,210 to its force account staff and provide proof that the 

payments were made to HUD’s Office of Labor Relations.

66,210

2011-CH-1018 9/30/2011 003-F 

We also recommend that the Director of Public Housing, Detroit 

Office, to recapture all funds that the Commission obligated for 

unit turnovers by its force account for transmission to the U.S. 

Treasury. This amount includes the work item for cycle painting 

and carpet removal work by its force account for $24,149 and 

$12,082 that was inappropriately obligated due to the 

Commission’s conflict-of-interest relationship that has not been 

spent.

36,231

2012-NY-1002 10/18/2011 001-A 

We recommend that the Director of HUD’s New York City 

Office of Community Planning and Development instruct City 

officials to reimburse from non-Federal funds $93,436 for 

ineligible costs charged to HPRP; specifically, $59,430 related 

to payments for rental arrears over the 6-month eligibility 

requirement and $34,006 for payments issued directly to 

participants.

34,006

127 █

███ 127 127 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2011-CH-1012 8/9/2011 003-B 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to provide supporting 

documentation or reimburse its appropriate programs $30,236 

from non-Federal funds for the unsupported costs cited in this 

finding.

29,112

2011-KC-1002 3/1/2011 001-B 

Return the $81,153 in ineligible draws to HUD subject to the 90 

percent limitation on the obligation period and repay the 

remaining amount to the project from non-Federal funds.

26,411

2011-CH-1018 9/30/2011 002-E 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to reimburse HUD 

$17,500 from non-Federal funds for contract work involving 

repairs to the Commission’s sidewalks and driveways and 

brickwork that were not completed for HUD to recapture and 

transmit to the U.S. Treasury.

17,500

2011-CH-1012 8/9/2011 002-F 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to reimburse its Capital 

Fund $13,085 from non-Federal funds for the inappropriately 

earned interest cited in this finding.

13,085

2011-AT-1006 4/8/2011 002-B 

Require the Municipality to submit all supporting documentation 

showing the eligibility and propriety of $23,862 drawn from 

HUD or reimburse the HOME program from non-Federal funds.

12,130

2011-CH-1018 9/30/2011 002-F 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to reimburse HUD 

$11,205 for the physical needs assessment paid with its 

Recovery Act funds for HUD to recapture and transmit to the 

U.S. Treasury. However, the Commission could pay for the 

activity with its 2010 capital funds.

11,205

2011-CH-1018 9/30/2011 003-C 

We recommend that the Director of Public Housing, Detroit 

Office, require the Commission to reimburse HUD $9,322 from 

non-Federal funds, due to the conflict-of-interest relationship, 

for transmission to the U.S. Treasury for the inappropriate use of 

grant funds.

9,322

2011-AT-1018 9/28/2011 002-B 

Require the Municipality to submit supporting documentation 

showing the allocability of $39,338 and any additional payroll 

costs charged to the HOME program between July 1, 2009, and 

June 30, 2011, associated with the three employees performing 

other functions not related to the program, or reimburse the 

program from non-Federal funds.

6,875

128 █

███ 128 128 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2011-KC-1002 3/1/2011 001-A 

Provide support for the $90,534 drawn for unsupported costs or 

return the funds to HUD subject to the 90 percent limitation on 

the obligation period and repay the remaining amount to the 

project from non-Federal funds. This support includes verifying 

that the Authority appropriately reimbursed the $80,716 via 

voucher 092-519938.

5,079

2011-CH-1018 9/30/2011 002-G 

We also recommend that the Director of Public Housing, Detroit 

Office to recapture the remaining $3,851 that the Commission 

obligated but had not expended for repairs to its sidewalk, 

driveway, and brickwork for transmission to the U.S Treasury.

3,851

2011-NY-1012 8/16/2011 001-C 

We recommend that HUD’s Acting Deputy Assistant Secretary 

for Single Family Housing require Ameritrust officials to ensure 

that borrowers have been reimbursed $3,843 for unallowable 

excessive loan discount and second appraisal fees.

3,843

2011-CH-1006 3/23/2011 001-A 

We recommend that the Director of HUD’s Chicago Office of 

Public Housing, in conjunction with the Director of HUD’s 

Departmental Enforcement Center take administrative action 

against the executive director and board of commissioners for 

failing to administer the Authority according to HUD’s and its 

own requirements.

0 

2011-NY-1010 4/15/2011 002-C 

We further recommend that the Director of HUD’s Buffalo 

Office of Community Planning and Development instruct the 

City to certify and provide support that the proper amount of 

CDBG assets was returned to the City from the subrecipient by 

performing an audit of the accounts that the Corporation 

maintained.

0 

2011-NY-1010 4/15/2011 002-D 

We further recommend that the Director of HUD’s Buffalo 

Office of Community Planning and Development instruct the 

City to establish and implement controls that will ensure 

adequate monitoring of subrecipient-administered activities, that 

CDBG funds are properly safeguarded, the achievement of 

performance goals in subrecipient supported activities, and that 

corrective actions are taken for nonperforming subrecipients.

0 

2011-NY-1010 4/15/2011 003-D 

We further recommend that the Director of HUD’s Buffalo 

Office of Community Planning and Development instruct the 

City to develop administrative control procedures that will 

ensure compliance with CDBG program requirements, including 

ensuring that costs are eligible and necessary before being 

charged to the program.

0 

129 █

███ 129 129 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2011-AT-1011 7/8/2011 001-A Require Prospect to reimburse HUD $344,326 for the actual loss 

sustained on five claim-terminated loans that HUD sold. 0 

2011-AT-1011 7/8/2011 001-B 

Require Prospect to reimburse HUD for potential losses on three 

claim-terminated loans that HUD has not resold. We estimate 

the losses to be $202,655 (Footnote 6): We calculated the 

potential loss for recommendations 1B and 1C using the 59 

percent average loss rate determined by HUD for the 2010 fiscal 

year for real estate owned properties that it sold. We applied the 

loss rate to the unpaid principal balances for loans listed in 

appendices C and D.

0 

2011-AT-1011 7/8/2011 001-C Require Prospect to indemnify HUD against $1,694,217 in 

potential losses on 17 defaulted loans. 0 

2011-AT-1011 7/8/2011 001-D 

Require Prospect to pay down the principal balance by $3,276 

for 4 over-insured loans. If HUD has paid a claim on any of 

these loans then it should remit the payment to HUD.

0 

2011-AT-1011 7/8/2011 001-H 

Determine legal sufficiency, and if legally sufficient, pursue 

civil action against Prospect and its underwriters for incorrectly 

certifying to the integrity of the data or that due diligence was 

exercised during the underwriting of 25 loans that placed the 

FHA insurance fund at risk for $550,257 in questioned costs and 

potential losses of $1,694,217. The penalty amount will be 

determined through a separate civil process.

0 

2011-AT-1011 7/8/2011 001-I 

Take appropriate administrative action against Prospect and 

underwriters A, B, C, F, G, and H for not complying with HUD 

requirements. The underwriters were responsible for the 

violations identified in appendices C and D.

0 

2011-NY-1012 8/16/2011 002-A 

We recommend that HUD’s Acting Deputy Assistant Secretary 

for Single Family Housing require Ameritrust officials to 

establish procedures to ensure that their quality control plan is 

implemented in accordance with HUD requirements, including 

but not limited to revising the plan to ensure that it includes all 

basic and specific requirements and ensuring that all required 

documentation supporting the performance of quality control 

reviews is retained in the quality control files.

0 

2011-NY-1012 8/16/2011 002-B 

We also recommend that HUD’s Associate Deputy Assistant 

Secretary for Single Family Housing verify the lender’s 

implementation of corrective actions taken with regard to its 

quality control plan.

0 

130 █

███ 130 130 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2011-NY-1012 8/16/2011 002-C 

We also recommend that HUD’s Associate Deputy Assistant 

Secretary for Single Family Housing due to the materiality of the 

quality control violations, several of which were previously cited 

during a HUD review, consider referring the lender to the 

Mortgagee Review Board for an assessment of civil money

penalties.

0 

2011-LA-1017 9/21/2011 001-A 

Refer the lender to the Mortgagee Review Board to take 

appropriate administrative action, such as imposing civil money 

penalties for the 15 loans due to the lender’s failure to 

underwrite loans in compliance with HUD regulations and the 

unallowable restrictive covenants.

0 

2011-AT-1018 9/28/2011 002-F 

Require the Municipality to update its accounting records and 

ensure that receipts and expenditures are properly accounted for, 

are reconciled with HUD’s information system, and comply with 

HUD requirements.

0 

2011-AT-1018 9/28/2011 002-G 

Require the Municipality to develop and implement a financial 

management system in accordance with HUD requirements, 

including that HOME funds can be traced to a level which 

ensures that such funds have not been used in violation of the 

restrictions and prohibitions of applicable statutes and that funds 

are disbursed in a timely manner.

0 

2011-CH-1018 9/30/2011 003-B 

We recommend that the Director of Public Housing, Detroit 

Office, require the Commission to identify the specific units 

assigned to each maintenance staff member for phase II unit 

turnover work and to the contractor for phase III unit turnover 

work and provide support to show when each unit was assigned, 

what work was to be done, who worked in the units, and when 

the work was performed, showing the days and hours spent in 

each unit until it was approved as completed. If the Commission 

cannot provide satisfactory records to support unit turnover costs 

and that duplicate unit turnover work was not performed, HUD 

should require that these costs be returned to HUD.

0 

2012-PH-0001 10/31/2011 001-A 

Implement policies and procedures requiring HUD to 

periodically use the data contained in its System to provide 

improved oversight of cancelled Block Grant program activities.

0 

131 █

███ 131 131 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2012-PH-0001 10/31/2011 001-C 

Implement policies and procedures requiring HUD to 

periodically use the data contained in its System to provide 

improved oversight of long-standing open Block Grant program 

activities.

0 

2012-PH-0001 10/31/2011 001-D 

Implement policies and procedures requiring HUD to 

periodically use the data contained in its System to provide 

improved oversight of revised Block Grant program activities.

0 

2012-PH-0001 10/31/2011 001-E 

Periodically evaluate the adequacy of actions grantees take 

regarding cancelled and long-standing open or revised activities 

shown in its System.

0 

2012-LA-0001 11/16/2011 001-A 

Establish and implement procedures to reassess the safe harbor 

percentage and rates periodically to ensure that they are 

reasonable. HUD should retain the documentation justifying the 

calculation of those percentages and rates. In addition, HUD 

should assess the feasibility of requiring the agencies to 

periodically justify and retain documentation showing the 

reasonableness of using the maximum rates, or lower them as 

appropriate.

0 

2013-PH-1001 10/31/2012 001-A 

Reimburse its business development loan program $5,999,894 

from non-Federal funds for the ineligible expenditures related to

the Hotel Sterling project.

5,999,894

2012-AT-1009 5/23/2012 001-A 

Require the Municipality to develop and implement a financial 

management system in accordance with HUD requirements and 

ensure that $3,213,572 in HOME funds drawn from HUD 

between July 1, 2009, and December 31, 2011, can be traced to a 

level which ensures that such funds have not been used in 

violation of the restrictions and prohibitions of applicable 

statutes or reimburse the HOME program from non-Federal 

funds (Footnote 2). Total disbursements of $3,523,723 were 

adjusted to consider $173,978 questioned in recommendation 

1B, $86,567 questioned in recommendation 1D, and $49,606 

questioned in recommendation 2B.

3,213,572

2012-CH-1013 9/27/2012 001-A 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to reimburse HUD 

$3,120,000 from non-Federal funds for transmission to the U.S. 

Treasury for its four Recovery Act grant funds for category 4, 

option 2 of HUD’s Notice of Funding Availability, dated June 3, 

2009, whose activities were not contracted using full and open 

competition.

3,120,000

132 █

███ 132 132 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2012-FW-1803 4/10/2012 001-E Support or repay $2,048,750 for the CDBG-purchased land sold 

or donated for the minor league baseball park. 2,048,750

2012-PH-1011 8/3/2012 001-F 

Provide adequate documentation to show that affordability 

requirements were met for three rental projects or repay the 

Program $1,272,325 from non-Federal funds.

1,272,325

2012-PH-1011 8/3/2012 001-C 

Repay the Program $1,235,940 from non-Federal funds for 

funds disbursed for a project that was acquired but not 

completed.

1,235,940

2012-PH-1011 8/3/2012 001-B 

Repay the Program the $1,025,654 it was previously asked to 

repay for funds disbursed to an ineligible development 

organization.

1,025,654

2012-PH-1011 8/3/2012 001-L 

Use its resources available of approximately $615,703 in 

administrative funds to strengthen its administration of the 

Program.

615,703

2012-AT-1009 5/23/2012 002-B 

Determine the eligibility of the $537,773 disbursed for the 

Ciudad de Ensueño project and reevaluate the feasibility of the 

activity. (Footnote 9) Total disbursements of $538,973 were 

adjusted to consider $1,200 questioned in recommendation 1F. 

The Municipality must reimburse its HOME program from nonFederal funds if HUD determines the activity to have been 

terminated.

537,773

2012-PH-1011 8/3/2012 001-D Reprogram $464,060 in committed set-aside funds for other 

eligible activities, thereby putting the funds to better use. 464,060

2012-NY-1011 8/15/2012 002-A 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City Officials 

to reimburse the City’s CDBG line of credit $475,339 from 

non-Federal funds for the unreported ($267,141) and unremitted 

($208,198) in program income from the sale of the theater and 

four properties; and record these reimbursements in HUD’s 

Integrated Disbursement and Information System as CDBG 

program income.

456,869

2012-AT-1012 6/1/2012 001-A Require the Authority to reimburse its public housing operating 

fund $522,125 using non-Federal funds. 443,807

2012-CH-1012 9/27/2012 001-K 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing determine the amount of the $573,170 of 

coordinator grant funds that were actually earned by the 

Commission for meeting the program’s requirements. The funds 

that are determined to be unearned should be reimbursed to 

HUD from non-Federal funds.

299,750

133 █

███ 133 133 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2012-BO-1002 3/14/2012 001-J 

We recommend that the Program Center Coordinator of the 

Hartford Office of Public Housing support that $2,506,434 in 

contract costs charged to Federal programs was reasonable and 

supportable, and repay any amounts it cannot support with nonFederal funds.

269,023

2012-NY-1011 8/15/2012 002-B 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City Officials 

to provide documentation to enable HUD to determine whether 

the City is entitled to additional program income of $263,938 

from the disposition of the Church property.

263,938

2012-LA-1005 3/13/2012 001-E 

Reimburse $897,821 from non-Federal funds for using 

Brownfields grant funds after the grant agreement expenditure 

deadline, plus any interest due, to HUD’s Brownfields account.

249,058

2012-KC-1002 3/2/2012 002-B 

Support that $304,780 in Recovery Act change orders was 

provided at a reasonable cost and repay any amount determined 

to be unreasonable from non-Federal funds to the U.S. Treasury.

216,529

2012-PH-1011 8/3/2012 001-A 

Repay the Program $150,000 from non-Federal funds for 

operating funds it disbursed to two ineligible development 

organizations.

150,000

2012-LA-1006 5/21/2012 002-B 

Require the project’s cooperative ownership to support $133,904 

in unsupported costs or repay the project from non-Federal 

funds.

133,904

2012-LA-1006 5/21/2012 003-A 

Establish and implement sufficient written procedures and 

controls for documenting shareholder interest and the funding 

and maintenance of the general operating reserve account, which 

would ensure that $127,303 in funds can be put to better use.

127,303

2012-AT-1009 5/23/2012 001-C 

Require the Municipality to submit supporting documentation 

showing the allocability and eligibility of $114,139 charged to 

the HOME program for project delivery costs or reimburse the 

program from non-Federal funds.

114,139

2012-NY-1011 8/15/2012 001-B 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City Officials 

to reimburse the City’s CDBG line of credit from non-Federal 

funds for the $150,000 ineligible loan.

93,500

2012-PH-1011 8/3/2012 001-G 

Provide adequate documentation for $86,575 in salaries and 

office expenses related to down payment assistance activities or 

repay the Program from non-Federal funds.

86,575

134 █

███ 134 134 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2012-LA-1006 5/21/2012 001-C 

Require Amar Plaza to seek indemnification of $75,038 in paid 

legal costs, $72,246 in outstanding costs, and future legal costs 

from the two shareholders who improperly executed the deed 

and note and named Rampart as the beneficiary and retain the 

two shareholders’ subscription price for liquidated damages 

incurred for the unauthorized encumbrance on the project.

73,964

2013-FO-0003 11/15/2012 006-B 

Review the 270 obligations with remaining balances totaling 

$432,147 and close out and deobligate amounts tied to 

obligations that are no longer valid or needed.

64,088

2012-LA-1005 3/13/2012 001-C 

Reimburse $625,000 from non-Federal funds for using 

Brownfields grant funds for an ineligible project after the grant 

agreement deadline, plus any interest due, to HUD’s 

Brownfields account.

58,922

2012-CH-1009 8/3/2012 003-A 

We recommend that the program center coordinator of HUD’s 

Office of Public and Indian Housing require the Authority to 

provide documentation to support HUD’s approval of its waiver 

requests or reimburse HUD $46,828 from non-Federal funds for 

transmission to the U.S. Treasury for the Recovery Act grant 

funds used to purchase materials manufactured outside the 

United States.

46,782

2012-LA-1005 3/13/2012 001-A 

Repay $3,817,000 from non-Federal funds for the use of Section 

108 loan funds for an ineligible project, plus any interest due, to 

HUD’s Section 108 loan account.

29,650

2012-CH-1009 8/3/2012 001-B 

We recommend that the program center coordinator of HUD’s 

Office of Public and Indian Housing require the Authority to 

provide documentation to show that the contract costs for the 

testing of asbestos were reasonable or reimburse HUD $26,875 

from non-Federal funds for transmission to the U.S. Treasury.

26,875

2012-PH-1011 8/3/2012 001-H 

Provide supporting documentation showing that income 

eligibility requirements were met for the rehabilitation assistance 

case, and to support the excess rehabilitation funds spent or 

reimburse the Program $26,645 in assistance funds provided 

from non-Federal funds.

26,645

2012-CH-1012 9/27/2012 001-A 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to reimburse its 

program $21,650 from non-Federal funds for the overpayment 

of escrow funds to the participants cited in this finding.

19,719

2012-KC-1002 3/2/2012 001-A 

Support that $1,570,038 in Recovery Act contracts awarded was 

granted at a reasonable cost and repay the U.S. Treasury from 

non-Federal funds any amount determined to be unreasonable.

19,575

135 █

███ 135 135 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2012-CH-1002 1/26/2012 003-B 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to reimburse $22,430 

($16,335 + $6,095) from non-Federal funds to HUD for 

transmission to the U.S. Treasury for the projects that had 

Section 3 funds included but not remitted to the Commission’s 

Section 3 training fund.

17,946

2012-CH-1012 9/27/2012 001-H 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to provide supporting 

documentation or reimburse its program $17,008 from nonFederal funds for the unsupported payments cited in this finding.

16,335

2012-CH-1002 1/26/2012 006-A 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to reimburse $11,289 

(the difference between the contract paid price of $33,638 and 

the lesser calculated cost of $ 22,349) from non-Federal funds to 

HUD for transmission to the U.S. Treasury for the cost savings 

cited in this finding.

10,573

2012-CH-1011 9/27/2012 001-A 

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Authority to obtain documentation to 

support that employees were paid in accordance with the DavisBacon Act, or reimburse the employees $6,820 from nonFederal funds for the unsupported wages cited in this report.

6,820

2012-LA-1006 5/21/2012 002-A 

Require the project’s cooperative ownership to repay the 

operating account the $4,921 in ineligible or unreasonable 

expenses from non-Federal funds.

4,921

2012-CH-1011 9/27/2012 002-A 

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Authority to reimburse $680 to HUD 

from non-Federal funds for transmission to the U.S. Treasury for 

the one range and one refrigerator that were improperly 

replaced.

680

2012-CH-1011 9/27/2012 001-B 

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Authority to pursue collections from 

the subcontractor and provide support for corrective payments 

made to its employee or reimburse the contractor’s employee 

$537 from non-Federal funds.

537

2012-FW-1803 4/10/2012 001-B 

Repay HUD the higher of the cost or market value of the 

properties purchased with CDBG funds that the Authority still 

owns (book value is $3,122,900). FN The $3,122,900 was 

included in the schedule of questioned costs in audit report 

2008-FW-1012.

0 

2012-FW-1803 4/10/2012 001-F 

Support or repay the higher of the cost or market value of the 

property identified as Block 78 (property north of Hartford 

building).

0 

136 █

███ 136 136 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2012-AT-1009 5/23/2012 003-C 

Require the Municipality to review all grant agreements for each 

activity entered into HUD’s information system and correct any 

inaccurate information, including the address of HOME-funded 

activities, project completion date, fund type classification, 

activity type and description, funding amount, and activity 

status.

0 

2012-AO-1002 7/30/2012 002-I 

Take appropriate administrative sanctions against the executive 

director, including but not limited to debarment from HUD 

programs, for the disbursement of Federal funds prohibited by 

HUD requirements.

0 

2012-AO-1002 7/30/2012 003-D 

Take appropriate administrative sanctions against the executive 

director and board members, up to and including debarment, for 

the disbursement of Federal funds prohibited by HUD 

requirements.

0 

2012-AO-1002 7/30/2012 004-D 

Take appropriate administrative sanctions against the executive 

director, up to and including debarment, for the disbursement of 

Federal funds prohibited by HUD requirements.

0 

2012-LA-0003 9/18/2012 001-G 

Ensure that HUD receives repayment for routine inspections that 

were not conducted by field service managers between June 

2011 and February 2012 and ensure that repayment is received 

for inspections that were not provided by asset managers 

between June 2011 and March 2012.

0 

2013-FO-0003 11/15/2012 003-C 

Develop and implement formal financial management policies 

and procedures to require an annual evaluation by OCFO and 

applicable program offices of all allowance for loss rates and 

other significant estimates currently in use to ensure 

appropriateness.

0 

2013-FO-0003 11/15/2012 004-B 

Develop internal controls to review field office compliance more 

frequent than every 4 years, especially when findings have been 

identified in the past, and to ensure that action plans operate 

effectively and have addressed the deficiencies noted so that 

noncompliance is not repeated during the next quality 

management review.

0 

2013-AT-1001 11/30/2012 001-A Develop and implement a financial management system in 

accordance with HUD requirements. 0 

2014-FO-0003 12/16/2013 002-A 

Transition the PHA NRA excess funds, which are as much as 

$643.6 million as of June 30, 2013, to HUD’s control as soon as 

possible to safeguard the program resources.

248,239,577

137 █

███ 137 137 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2013-LA-1008 8/20/2013 001-B 

Indemnify HUD against losses for the 725 FHA-insured loans 

with an unallowable gift in the amount of $97.3 million, thereby 

putting an estimated loss to HUD of $55.4 million to better use. 

See appendixes D and E.

55,439,896

2014-FO-0002 12/13/2013 001-C 

Review and de-obligate, as appropriate, the $43 million in 

expired property-related contracts once they have been closed 

out by the contracts office.

43,000,000

2013-CH-1011 9/30/2013 001-A 

We recommend that the Director of HUD’s Detroit Office of 

Multifamily Housing Programs require the Authority to ensure 

that $31,148,477 in residual receipts for the 15 projects as of 

May 31, 2013, is used to reduce or offset housing assistance 

payments in accordance with HUD’s requirements.

31,148,477

2014-FO-0003 12/16/2013 008-F Review and deobligate at least $26 million tied to 215 inactive 

and/or expired Section 8 obligations. 26,000,000

2014-FO-0003 12/16/2013 008-E Research and deobligate at least $9.3 million tied to the 115 

inactive and/or expired Section 202/811 funding lines. 9,300,000

2014-FO-0003 12/16/2013 008-O 

Deobligate $7,263,662 tied to 178 administrative obligations 

marked for deobligation during the department-wide 

unliquidated obligations review.

7,263,662

2013-DE-1005 9/30/2013 001-A 

Ensure that the Authority recovers from non-Federal sources 

$5,496,367 in disposition sales proceeds that was not received 

from the sale of its 65 low-income public housing units and use 

the recovered funds for their intended purposes or return those 

funds to HUD within a reasonable period.

5,496,367

2013-LA-1003 3/14/2013 001-A 

Repay the $5,178,293, transferred without proper HUD approval 

and used for ineligible expenses, to the trust fund from nonFederal funds.5,178,293

2014-PH-1001 12/17/2013 001-C Provide for HUD review documentation to support $5,014,403 

drawn for the additional 15 activities. 5,014,403

2014-PH-1001 12/17/2013 001-B 

Provide to HUD a remediation plan for the 10 delayed activities 

and demonstrate that national objectives have been met as 

required to support $4,078,941 in program funds drawn for the 

activities.

4,078,941

2013-CH-1003 7/15/2013 001-D 

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Authority to provide supporting 

documentation or reimburse its operating reserve fund 

$4,003,683 ($3,610,666 + $227,500 + $111,856 + $39,189 + 

$14,472) from non-Federal funds for the unsupported salary and 

benefit payments; operating contribution payments; and lawn 

maintenance, snow removal, utility, and training costs for the 

developments and program cited in this finding.

4,003,683

138 █

███ 138 138 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2013-CH-1003 7/15/2013 001-A 

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Authority to reimburse its capital 

fund $3,569,942 ($3,319,942 + $250,000) from non-Federal 

funds for the ineligible drawdowns and disbursements cited in 

this finding.

3,569,942

2014-FO-0003 12/16/2013 008-K 

Deobligate the $1,419 tied to three administrative obligations 

marked for deobligation during the department-wide 

unliquidated obligations review. Additionally, OCFO should 

review the 42 obligations with remaining balances totaling 

$3,115,954 and close out and deobligate amounts tied to 

obligations that are no longer valid, either based on the criteria 

defining the availability of appropriations at 31 U.S.C. 1301 or 

the criteria for recording obligations at 31 U.S.C. 1501. 

3,117,373

2013-FW-1006 6/19/2013 002-E 

Determine how much of the $7,010,079 in unreimbursed 

expenditures for damage assessment was paid with Federal 

funds and repay that amount to the appropriate program. If the 

Authority is unable to accurately determine the amount due todue from each program and support that funds charged to 

Federal programs were appropriate, the full $7,010,079 should 

be repaid to HUD.

2,971,168

2013-FW-1006 6/19/2013 002-C Repay from non-Federal funds the $3,811,279 it owes HUD for 

ineligible expenditures from DHAP-Ike funds. 2,888,889

2013-FW-1006 6/19/2013 002-D 

Determine how much of the $2,827,829 in unreimbursed 

expenditures for Cypresswood Estates was made with Federal 

funds and repay that amount to the appropriate program. If the 

Authority is unable to accurately determine the amount due todue from each program and support that funds charged to 

Federal programs were appropriate, the full $2,827,829 should 

be repaid to HUD.

2,827,829

2013-CH-1003 7/15/2013 001-B 

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Authority to reimburse its operating 

reserve fund $2,773,976 ($2,583,429 + $190,547) from nonFederal funds for the inappropriate transfers to its cost center 

and salary and benefit payments cited in this finding.

2,773,976

2014-PH-1001 12/17/2013 001-A 

Provide documentation to support the $2,455,162 in unsupported 

funds drawn for 12 activities or repay the amount to its program 

from non-Federal funds.

2,455,162

139 █

███ 139 139 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2013-NY-1010 9/26/2013 001-A 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct City officials to 

expend or reprogram to other eligible program activities the 

$2,451,645 in CDBG program income maintained in the City’s 

community development bank accounts as of June 30, 2013, so 

the City can assure HUD that these funds have been put to better 

use.

2,451,645

2013-AT-1003 3/22/2013 001-B 

Submit supporting documentation showing the eligibility, 

reasonableness, and allocability of $1,829,165 charged to the 

Block Grant program for payroll expenses that were not properly 

accounted for in the Municipality’s accounting records and for 

$422,393-Footnote 2: Amount includes $385,164 of rent 

charges between July 2009 and June 2012, and $37,228 charged 

to the Block Grant program, associated with administrative and 

other activity related expenses paid between July 2009 and 

August 2011, in administrative expenses and other activityrelated costs that were not properly supported or reimburse the 

program from non-federal funds.

2,251,558

2014-AT-1004 12/30/2013 001-B 

Require the State to provide supporting documentation for the 

$2,158,715 acquisition of property for projects W19, S21, and 

S20 or reimburse the program from non-Federal funds.

2,158,715

2013-LA-1010 9/20/2013 001-A 

Provide adequate supporting documentation for the $1,628,130 

in unsupported salary and benefit costs or repay the CDBG 

program from non-Federal funds.

1,628,130

2013-LA-1009 9/13/2013 001-A 

Reimburse its HOME program $1,595,113 from non-Federal 

funds for HOME funds that were inappropriately used on 

Section 8 housing assistance payments.

1,595,113

2013-AT-1008 9/30/2013 002-A 

Provide supporting documentation or reimburse its program 

$1,081,092 in unsupported expenditures related to activities 429, 

526, 637, and 672 from non-Federal funds.

1,081,092

2013-AT-1003 3/22/2013 002-B 

Require the Municipality to provide support showing the 

allocability and eligibility of $1,077,577 spent on salaries and 

fringe benefits for employees who performed local government 

duties and multiple federally funded activities without properly

allocating the costs directly related to carrying out each activity. 

Any amounts determined ineligible must be reimbursed to the 

Block Grant program from non-federal funds.

1,077,577

2013-LA-1003 3/14/2013 001-B 

Provide support showing the eligibility and reasonableness of 

the $1,056,252 in trust funds disbursed or repay the trust fund 

from non-Federal funds.

1,056,252

140 █

███ 140 140 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2013-DE-1005 9/30/2013 001-B 

Require the Authority to repay from non-Federal sources 

$975,146 in disposition sales proceeds used in violation of its 

disposition agreement and use the recovered funds for their 

intended purposes or return those funds to HUD within a 

reasonable period.

975,146

2013-CH-1009 9/27/2013 001-A 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to provide sufficient 

documentation to support the reasonableness of $960,904 in 

expenses or reimburse HUD $935,412. 

935,412

2013-PH-1804 7/22/2013 001-B 

Require the owner to provide documentation to support the 

$709,753 in unsupported disbursements identified by the audit 

or reimburse the project’s reserve for replacement account from 

non-Federal funds for any disbursements that it cannot support.

709,753

2013-FW-1006 6/19/2013 001-A 

Provide support showing that the $2,466,779 in unsupported 

expenses were paid from non-Federal funds or provide support 

showing the expenses were an eligible use of Federal funds. 

Any unsupported expenditures from Federal funds should be 

repaid to the Authority’s Housing Choice Voucher program or to 

HUD if the Authority is unable to determine the source of funds 

used to pay the expenses. Any repayments must be from nonFederal funds.

679,174

2013-CH-1011 9/30/2013 002-A 

We recommend that the Director of HUD’s Detroit Office of 

Multifamily Housing Programs require the Authority to 

reimburse the U.S. Treasury $608,337 ($77,856+ 436,759 + 

$93,722) for the three projects with terminated program 

contracts.

608,337

2013-CH-1011 9/30/2013 002-B 

We recommend that the Director of HUD’s Detroit Office of 

Multifamily Housing Programs require the Authority to obtain 

approval from HUD to apply the project’s replacement reserves 

to the defaulted mortgage for contract number MI28H150191 or 

reimburse the U.S. Treasury $604,949.

604,949

2013-FW-1006 6/19/2013 003-B 

Determine whether it received the services for which it paid 

$582,595 under two contracts that violated conflict-of-interest 

prohibitions and that those services cost the same or less than 

comparable services from a source without a conflict-of-interest 

relationship with the Authority. If it used Federal funds to pay 

for the services and it either did not receive the services or paid 

more for them than it would have paid from a source without a 

conflict-of-interest relationship, it should repay the funds to its 

appropriate program or HUD.

574,143

141 █

███ 141 141 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2013-AT-1003 3/22/2013 002-A 

Require the Municipality to reimburse from non-federal funds 

$552,658 in unallowable and unallocated costs associated with 

the disbursement of salaries and fringe benefits of employees 

who did not perform duties directly related to carrying out 

activities charged with the program delivery costs.

552,658

2013-CH-1004 8/1/2013 001-C 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to support or reimburse 

its program $425,193 ($19,924 + $384,755 in housing assistance 

payments + $46 in utility allowances + $20,468 in associated 

administrative fees) from non-Federal funds for the unsupported 

overpayment of housing assistance and utility allowances due to 

unsupported calculations, missing eligibility documentations, 

and discrepancies in the housing assistance payments register.

425,193

2013-LA-1008 8/20/2013 002-B 

Reimburse the FHA insurance fund for the $421,630 in actual 

losses resulting from the amount of claims and associated 

expenses paid on five loans with material underwriting 

deficiencies.

421,630

2013-KC-1003 8/8/2013 001-A Return the $401,705 in ineligible disbursements to the project 

operating account. 401,705

2014-AT-1003 12/30/2013 001-B 

Correct all deficiencies identified from non-Federal funds or 

reimburse $160,051 in CDBG funds and $221,804 in HOME 

funds, totaling $381,855, to program line of credit accounts from 

non-Federal funds.

381,855

2013-FW-1004 4/12/2013 001-A 

Repay $2,678,698 in 2009 Recovery Act funds to HUD, which 

will return the funds to the U. S. Treasury, or provide eligible 

costs that it obligated and expensed before the deadlines. HUD 

should take care to ensure that other expended funds are not 

improperly shifted to Recovery Act funds, as HUD’s policy 

stated that public housing agencies must use the funds provided 

in this grant to supplement expenditures, not to supplant 

expenditures from other Federal, State or local sources or funds 

independently generated.

337,564

2013-KC-1003 8/8/2013 001-B Support the $316,883 disbursed for unsupported costs or return 

the funds to the project operating account. 316,883

2014-AT-1001 12/3/2013 001-B 

Require the Municipality to submit all supporting documentation 

showing that 21 home-buyer activities met the principal 

residency requirement for the duration of the period of 

affordability or reimburse the HOME program from non-Federal 

funds the $307,537 disbursed.

307,537

142 █

███ 142 142 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2013-CH-1011 9/30/2013 003-A 

We recommend that the Director of HUD’s Detroit Office of 

Multifamily Housing Programs require the Authority to 

reimburse $290,437 to the appropriate project escrows from 

non-Federal funds for the inappropriate disbursement of 

replacement reserves.

290,437

2013-FW-1805 9/26/2013 001-A 

Repay $287,655 paid to the executive director’s and another 

Authority employee’s family members to its public housing 

program. However, if the Authority made any of the 

expenditures from its 2008 capital fund grant, or if the Authority 

is unable to determine the source of funds used to pay 

expenditures, the Authority should repay HUD. Any 

repayments must be from non-Federal funds.

287,655

2013-LA-1008 8/20/2013 001-C 

Reimburse the FHA insurance fund for the $284,412 in actual 

losses resulting from the amount of claims and associated 

expenses paid on seven loans that contained an unallowable gift. 

284,412

2013-AT-1008 9/30/2013 002-B Reimburse $225,235 in ineligible costs related to activities 476, 

524, 526, 546, 637, and 699 from non-Federal funds. 225,235

2013-AT-1007 9/13/2013 001-B 

Require the owner of Lighthouse Inn to provide documentation 

to support the $208,154 in unsupported disbursements cited in 

this report or reimburse HUD’s Federal Housing Administration 

insurance fund for the applicable portion.

208,154

2013-NY-1006 5/13/2013 001-A 

We recommend that the Director of HUD’s New York Office of 

Community Planning and Development instruct County officials 

to provide documentation to justify the $189,322 in unsupported 

administrative and planning costs that was disbursed for 

employee salaries and fringe benefits. Any unsupported costs 

determined to be ineligible should be reimbursed from nonFederal funds.

189,322

2013-FW-1802 6/21/2013 001-D 

Support or repay its public housing programs $180,379 for HUD 

funds inappropriately used for Sunnybrook. Repayment should 

be from non-Federal funds.

180,379

2013-NY-1010 9/26/2013 001-D 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct City officials to 

Provide documentation to justify the $177,923 unsupported 

difference between the City’s CDBG program income balance in 

IDIS and its bank account balances as of June 30, 2013. Any 

portion of the unsupported difference determined to be ineligible 

should be reimbursed from non-Federal funds.

177,923

143 █

███ 143 143 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2013-CH-1003 7/15/2013 001-E 

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Authority to provide supporting 

documentation or reimburse its capital fund $162,156 from nonFederal funds for the Centre’s operating expenses cited in this 

finding.

162,156

2013-AT-1008 9/30/2013 002-I 

Provide supporting documentation for activities 675, 697, 701, 

and 702 to show whether they were eligible HOME activities or 

reimburse its program $153,950 from non-Federal funds.

153,950

2013-AT-1007 9/13/2013 001-A 

Require the owner of Lighthouse Inn to reimburse HUD’s 

Federal Housing Administration insurance fund $146,983 for the 

ineligible disbursements cited in this report.

146,983

2013-PH-1804 7/22/2013 001-A 

Require the owner to deposit $138,862 from non-Federal funds 

into the project’s reserve for replacement account for the 

ineligible costs identified by the audit.

138,862

2013-FW-1805 9/26/2013 001-G 

Support or repay $135,995 for unsupported procurement 

expenditures. The funds should be repaid to the Authority’s 

public housing program. However, if the Authority made any of 

the expenditures from its 2008 capital fund grant, or if the 

Authority is unable to determine the source of funds used to pay 

expenditures, the Authority should repay HUD. Any 

repayments must be from non-Federal funds.

135,995

2014-AT-1002 12/5/2013 002-A 

Support $131,787 in unsupported contracts and procurement 

payments or repay the appropriate program from non-Federal 

funds.

131,787

2013-AT-1006 7/23/2013 001-C Remit to its treasury account and put to better use repayment 

funds totaling $130,915 in accordance with HUD requirements. 130,915

2013-DE-1003 9/10/2013 001-B 

Determine whether any portion of the $119,218 of improperly 

disbursed management agent fees are ineligible. For any portion 

determined to be ineligible, require the owner to repay the fees 

from non-project funds.

119,218

2013-CH-1012 9/30/2013 001-B 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to provide 

documentation for the three contracts to support that the costs 

paid for the contract modifications totaling $108,766 ($230,596 

less the ineligible use of funds from recommendation 1A) were 

reasonable. Any amounts that cannot be shown to be reasonable 

should be repaid to the U.S. Treasury from non-Federal funds.

108,766

144 █

███ 144 144 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2013-CH-1004 8/1/2013 001-A 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to reimburse its 

program $136,012 ($78,727 in housing assistance payments + 

$57,285 in associated administrative fees) from non-Federal 

funds for the overpayment of housing assistance due to 

inappropriate calculations of housing assistance payments.

95,017

2013-AT-1006 7/23/2013 001-D 

Submit all supporting documentation showing the eligibility and 

propriety of $89,331 in unaccounted for program income and 

recaptured funds or reimburse the HOME program from nonFederal funds.

89,331

2013-NY-1006 5/13/2013 001-B 

We recommend that the Director of HUD’s New York Office of 

Community Planning and Development instruct County officials 

to reimburse from non-Federal funds $78,530 for ineligible 

home-buyer rehabilitation and demolition costs charged to the 

HOME program.

78,530

2013-CH-1004 8/1/2013 001-H 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to reimburse the 

appropriate households $65,874 from non-Federal funds for the 

rent amounts paid in excess of 40 percent of their adjusted 

monthly income for units that were not affordable.

65,874

2013-FW-1805 9/26/2013 001-B 

Repay $65,360 paid from Recovery Act funds to the executive 

director’s and another Authority employee’s family members to 

HUD for its transmission to the U.S. Treasury. Repayment must 

be from non-Federal funds.

65,360

2013-CH-1003 7/15/2013 001-F 

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Authority to deobligate the $57,410 

in capital funds cited in this finding and ensure that the 

Authority uses the funds for eligible purposes.

57,410

2013-FW-1805 9/26/2013 001-D 

Support or repay $42,150 in unsupported additional 

compensation paid to Authority staff. The funds should be 

repaid to the Authority’s public housing program. However, if 

the Authority made any of the expenditures from its 2008 capital 

fund grant, or if the Authority is unable to determine the source 

of funds used to pay expenditures, the Authority should repay 

HUD. Any repayments must be from non-Federal funds.

42,150

2013-FW-1805 9/26/2013 001-C 

Support or repay $31,513 in unsupported equipment and 

supplies costs. The funds should be repaid to the Authority’s 

public housing program. However, if the Authority made any of 

the expenditures from its 2008 capital fund grant, or if the 

Authority is unable to determine the source of funds used to pay 

expenditures, the Authority should repay HUD. Any 

repayments must be from non-Federal funds.

31,513

145 █

███ 145 145 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2013-NY-1006 5/13/2013 001-C 

We recommend that the Director of HUD’s New York Office of 

Community Planning and Development instruct County officials 

to terminate the contract between the County and the Village of 

Freeport to rehabilitate and construct single-family public 

housing units to be sold to low-income residents. The remaining 

contract balance of $31,470 should be put to better use by 

reprogramming it for other eligible purposes.

31,470

2013-CH-1005 8/30/2013 001-B 

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Authority to reimburse its program 

$30,524 from non-Federal funds ($26,299 for program housing 

assistance plus $4,225 in associated administrative fees) for the 

25 units that materially failed to meet HUD’s housing quality 

standards.

30,524

2013-CH-1004 8/1/2013 001-E 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to pursue collection 

from the applicable households or reimburse its program 

$27,987 from non-Federal funds for the overpayment of housing 

assistance due to unreported income.

26,760

2014-FW-1801 11/8/2013 001-F 

Support or repay to HUD $437,710 in capital funds spent for 

any amounts that it cannot support for contracts that did not have 

procurement records, contracts, cost or price analyses, or 

independent cost estimates. Should the Authority provide 

sufficient procurement documentation, require the Authority to 

provide invoice documentation to support $21,686 paid to James 

Decker Builders, $1,049 paid to Pan American Engineers, and 

$49,695 paid to KDC Construction Company, or repay HUD 

any amounts that it cannot support. Any repayments must be 

from non-Federal funds.

21,400

2013-CH-1003 7/15/2013 001-C 

We recommend that the Director of HUD’s Cleveland Office of 

Public Housing require the Authority to reimburse its operating 

reserve fund $15,754 from non-Federal funds for the ineligible 

deposit of funds in a non-interest-bearing account.

15,754

2013-LA-1003 3/14/2013 001-C Repay $14,250 in ineligible expenses to the trust fund from nonFederal funds. 14,250

2014-FW-1801 11/8/2013 001-G 

Support or repay $124,009 to its operating funds any amounts 

that it cannot support for contracts that did not have procurement 

records, contracts, cost or price analyses, or independent cost 

estimates. Should the Authority provide sufficient procurement 

documentation, require the Authority to provide invoice 

documentation to support $225 paid to Van’s Plumbing Repairs 

& Construction and $30 paid to Mike Estes, PC, or repay to its 

operating fund any amount it cannot support, as questioned 

under recommendation 1A. Any repayments must be from nonFederal funds.

13,452

146 █

███ 146 146 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2013-CH-1011 9/30/2013 002-C 

We recommend that the Director of HUD’s Detroit Office of 

Multifamily Housing Programs require the Authority to 

reimburse the U.S. Treasury $12,830 from non-Federal funds for 

the lost interest.

12,830

2013-CH-1009 9/27/2013 002-A 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to provide 

documentation or reimburse HUD $12,165 for transmission to 

the U.S. Treasury for the materials and supplies for its force 

account labor unit renovations due to missing or inadequate 

purchase orders, invoices, receipts, or inventory records cited in 

this finding.

12,165

2013-AT-1007 9/13/2013 001-C 

Require the owner of Lighthouse Inn to reimburse the 22 tenants 

for ineligible fees collected totaling $10,950, from non-project 

funds.

10,950

2013-CH-1009 9/27/2013 002-B 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to provide 

documentation or reimburse HUD $8,554 from the appropriate 

fund for transmission to the U.S. Treasury for its force account 

labor employees due to missing labor logs or labor logs that 

indicated work on projects other than the Recovery Act formula 

grant work.

8,554

2014-FW-1801 11/8/2013 001-E 

Support that it properly used $7,796 in cash from salvaged 

appliances and equipment or repay the money from non-Federal 

sources to its low-rent program.

7,796

2014-AT-1004 12/30/2013 001-A 

Require the State to provide supporting documentation for the 

$7,200 in appraisal fees or reimburse the Program from nonFederal funds.7,200

2014-CH-1001 11/15/2013 001-E 

We also recommend that HUD’s Associate General Counsel for 

Program Enforcement pursue the appropriate administrative 

actions against the contractor’s vice president and architectural 

firm’s architect for inappropriately certifying that the contractor 

had completed its housing rehabilitation work on the project.

7,000

2013-AT-1008 9/30/2013 001-D Determine whether $11,728 drawn down for canceled activities 

was for supported and eligible expenditures. 6,688

2013-LA-1008 8/20/2013 001-D 

Support or repay the FHA insurance fund $5,450 for the loss 

mitigation claims paid as of April 30, 2013, on seven loans that 

contained an unallowable gift.

5,450

147 █

███ 147 147 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2013-CH-1004 8/1/2013 001-G 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to support, pursue 

collection from the applicable landlords, or reimburse its 

program $10,243 from non-Federal funds for the overpayment 

of housing assistance due to discrepancies in the housing 

assistance payments register.

3,156

2014-FW-1801 11/8/2013 001-A 

Support or repay $129,840, which includes $15,156 to its 

operating fund, $2,237 to HUD for its transmission to the U.S. 

Treasury, and $112,447 to its Capital Fund program, in 

unsupported disbursements. Repayment must be from nonFederal funds.

2,818

2014-FW-1801 11/8/2013 001-C 

Repay its operating fund $2,733 for funds paid to the previous 

executive director’s wife when she was not an employee. 

Repayment must be from non-Federal funds.

2,733

2014-FW-1801 11/8/2013 001-B 

Support or repay to its operating fund $33,081 in disbursements 

to employees for bonuses that were improperly awarded, 

duplicated pay periods, and unidentified purposes under the 

applicable years. Repayment must be from non-Federal funds.

2,175

2013-NY-1006 5/13/2013 001-D 

We recommend that the Director of HUD’s New York Office of 

Community Planning and Development instruct County officials 

to provide documentation to justify the $1,264 in unsupported 

project delivery costs. Any unsupported costs determined to be 

ineligible should be reimbursed from non-Federal funds.

1,264

2013-LA-1008 8/20/2013 002-C Pay down the principal balance by $1,101 for the one overinsured loan as a result of an excessive seller contribution. 1,101

2013-CH-1009 9/27/2013 002-E 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to provide sufficient 

documentation to support that the appliance was installed in a 

unit renovated under the Recovery Act formula grant or 

reimburse HUD $429 from its capital funds for transmission to 

the U.S. Treasury.

429

2013-BO-0001 2/12/2013 001-A 

Develop and implement comprehensive procedures to assess the 

effectiveness and completeness of monitoring efforts using 

metric or query data in the GMP database as detailed in this 

finding.

0 

2013-BO-0001 2/12/2013 001-B 

Develop and implement procedures to evaluate the field office 

testing of non-high-risk grantees to ensure the soundness of risk 

assessments and obtain early warning of potential deficiencies as 

provided for in HUD CPD Notice 12-02. 

0 

148 █

███ 148 148 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2013-BO-0001 2/12/2013 002-A 

Develop and implement a quality control system to validate 

HOME program data recorded in the Integrated Disbursement 

and Information System by using field office monitoring data in 

the GMP database or some other auditable method, such as 

statistical sampling and testing of key program data.

0 

2013-BO-0001 2/12/2013 002-B 

Develop and implement formal procedures to continually assess 

the effectiveness and completeness of field office data 

monitoring efforts using GMP monitoring data to include (1) 

verifying that HOME data are tested, (2) analyzing results to 

determine whether program data as a whole are reliable and to 

identify systemic data issues or issues that should be addressed, 

and (3) verifying that findings are corrected in a timely manner 

and monitoring is complete.

0 

2013-LA-1003 3/14/2013 001-D Replace GMP Development Group as Bay Vista’s management 

agent with a non-identity-of-interest agent. 0 

2013-LA-1003 3/14/2013 001-E 

Implement proper policies, procedures, and controls to restrict 

the use of trust funds to only allowable non-operating-type 

expenses and ensure that the trust funds are not commingled 

with Bay Vista’s and its properties’ operating funds.

0 

2013-HA-0001 4/16/2013 002-C 

Work with the Office of the Chief Information Officer to 

improve the deposit module’s reporting capabilities so that 

Labor Relations staff is able to report and analyze the deposit 

account transactions and taxes or replace the system.

0 

2013-NY-1006 5/13/2013 002-A 

We recommend that the Director of HUD’s New York Office of 

Community Planning and Development instruct County officials 

to document their application review committee membership 

and provide evidence of the committee meetings and their 

evaluation and rating of subrecipients to fully support their 

funding recommendations.

0 

2013-NY-1006 5/13/2013 002-D 

We recommend that the Director of HUD’s New York Office of 

Community Planning and Development instruct County officials 

to develop controls to ensure that the County’s recently 

established debarment verification procedures are implemented 

for all future procurement activity.

0 

2013-NY-1006 5/13/2013 003-C 

We recommend that the Director of HUD’s New York Office of 

Community Planning and Development instruct County officials 

to develop controls that will ensure that the County’s 

decentralized record-keeping system is centralized for ready 

access to HOME documents.

0 

2013-KC-0002 6/26/2013 001-D 

Resolve issues with the Office of Community Planning and 

Development and complete the process to publish final 

regulations for 24 CFR Part 135.

0 

149 █

███ 149 149 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2013-PH-1804 7/22/2013 001-C 

Require the owner to calculate and support the amount of funds 

required to be on deposit in the tenant security deposit account 

and deposit funds into the account, if needed, so that the balance 

in the account is equal to or exceeds the amount of funds 

required to be in the account.

0 

2013-PH-1804 7/22/2013 001-D 

Declare the project in default of its regulatory agreement and 

apply remedies available under the regulatory agreement up to 

and including foreclosure.

0 

2013-LA-1008 8/20/2013 001-A 

Determine legal sufficiency and if legally sufficient, pursue civil 

and administrative remedies (31 U.S.C. 3801-3812, 3729, or 

both), civil money penalties (24 CFR (Code of Federal 

Regulations) 30.35), or both against The Lending Company, its 

principals, or both for incorrectly certifying to the integrity of 

the data, the mortgage eligibility for FHA mortgage insurance, 

or that due diligence was exercised during the origination of 732 

loans that resulted in actual losses of $284,412 on 7 loans and 

potential losses of $55.4 million on 725 loans for a total loss of 

$55.7 million, which could result in affirmative civil 

enforcement action of approximately $116.9 million. Double 

damages for actual loss amounts related to 7 loans and potential 

losses to 725 loans ($284,412 + $55,439,896) plus a fine of 

$7,500 each for the 725 loans with unallowable gifts 

(($55,724,308 x 2) + ($7,500 x 732) = $116,938,616).

0 

2013-LA-1008 8/20/2013 002-A 

Determine legal sufficiency and if legally sufficient, pursue civil 

and administrative remedies (31 U.S.C. 3801-3812, 3729, or 

both), civil money penalties (24 CFR 30.35), or both against The 

Lending Company, its principals, or both for incorrectly 

certifying to the integrity of the data or that due diligence was 

exercised during the origination of five loans that resulted in 

actual losses of $421,630, which could result in affirmative civil 

enforcement action of approximately $880,760. Double damages 

for actual loss amounts related to five loans ($421,630) plus a 

fine of $7,500 each for the five loans with material underwriting 

deficiencies (($421,630 x 2) + ($7,500 x 5) = $880,760).

0 

2013-LA-1008 8/20/2013 003-A 

Fully implement its quality control plan and provide HUD with 

periodic reports for 12 months to ensure that its quality control 

reviews, to include early payment defaults, are conducted in 

accordance with HUD requirements.

0 

2013-LA-1008 8/20/2013 003-B Provide training to ensure that its quality control staff is aware 

of HUD’s quality control program requirements. 0 

150 █

███ 150 150 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2013-DE-1003 9/10/2013 001-A 

Require the owner to complete and submit a current version of 

the required certification to HUD for approval. If the owner 

does not submit the required certification for HUD approval, 

consider seeking administrative sanctions.

0 

2013-DE-1003 9/10/2013 002-A 

Require the owner to establish and implement comprehensive 

financial policies and procedures including the proper 

maintenance of the books of account.

0 

2013-DE-1003 9/10/2013 002-B Provide the necessary technical assistance and confirm that the 

procedures have been implemented. 0 

2013-KC-0003 9/10/2013 001-C Develop and implement additional system error checks to 

identify potential reporting issues. 0 

2013-LA-1009 9/13/2013 001-B Develop and implement written policies and procedures for its 

HOME program. 0 

2013-KC-0004 9/18/2013 001-B 

Enhance data collection to begin collecting information on 

whether each coborrower will occupy the subject property as 

well as the addresses and phone numbers of each coborrower.

0 

2013-LA-1010 9/20/2013 001-D 

Implement adequate written policies and procedures for its 

salary and administrative allocations to meet applicable HUD 

rules and requirements.

0 

2013-LA-1010 9/20/2013 001-E 

Provide adequate training to CDBG employees so that the 

employees have a better understanding and knowledge of 

administering the CDBG program in accordance with HUD rules 

and requirements.

0 

2013-NY-1010 9/26/2013 001-E 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct City officials to 

develop a comprehensive overall CDBG policies and procedures 

manual to ensure that City officials adequately administer the 

City’s CDBG program in accordance with HUD regulations. 

Specifically, the City should ensure that program income is 

accurately accounted for and reported to HUD in a timely 

manner.

0 

2013-NY-1010 9/26/2013 002-B 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct City officials to 

develop procedures to ensure that funded activities comply with 

program objectives and that the activities are sufficiently 

monitored.

0 

2013-DE-1005 9/30/2013 001-E 

Require the Authority to submit financial statements that show 

how its disposition funds were expended by item and dollar 

amount.

0 

151 █

███ 151 151 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-FO-0001 12/6/2013 001-A 

Obtain a corrective action plan from BAC with critical 

milestones to document how all information is to be provided, 

supported, and reconciled to the appropriate underlying 

information system.

0 

2014-FO-0001 12/6/2013 001-B 

Review the projected workload requirements with BAC, 

evaluate the remaining impact of ongoing delays in recording 

servicing activity, and document the anticipated effort on future 

financial reporting.

0 

2014-FO-0001 12/6/2013 001-C Continue efforts to confirm the insured status of loans not yet 

matched with data from the insuring agencies. 0 

2014-FO-0003 12/16/2013 001-A 

Develop and implement a detailed remediation action plan to 

ensure that grant management systems eliminate the FIFO 

methodology in its entirety. The plan should (1) explain how 

the budget fiscal year-TAFS for each accounting transaction 

(project and activity setup, commitment, disbursement, etc.) will 

be recorded, remain constant, and be maintained, (2) reference 

Federal system requirements and criteria, and (3) include 

resources, specific remedies, and intermediate target dates 

necessary to bring the financial management system into 

substantial compliance.

0 

2014-FO-0003 12/16/2013 001-B Establish controls within the system, which provide an audit trail 

of the use of the funds by the budget fiscal year-TAFS. 0 

2014-FO-0003 12/16/2013 001-C 

Provide oversight of CPD’s system implementation or 

modification to ensure that Federal financial management 

accounting standards are embedded into the system so that the 

information transferred from grant management systems to 

HUD’s core financial systems comply with these standards, are 

recorded in HUD’s consolidated financial statements in 

accordance with Federal GAAP, and ensure that compliant 

administrative control of funds for its formula grant programs is 

established.

0 

2014-FO-0003 12/16/2013 002-C 

Implement a cost-effective method for automating the cash 

management process to include an electronic interface of 

transactions to the standard general ledger.

0 

2014-FO-0003 12/16/2013 002-E 

Review the cash management process to identify all financial 

events to be recognized in accordance with GAAP. Establish 

procedures to account for the cash management activity in a 

timely manner in compliance with GAAP.

0 

2014-FO-0003 12/16/2013 002-G Ensure that PIH’s automation of its cash management process 

complies with Federal financial management requirements. 0 

152 █

███ 152 152 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-FO-0003 12/16/2013 003-A 

Design and Implement a loan guarantee system that complies 

with the Guaranteed Loan System Requirements. Ensure that the 

implemented loan guarantee system should be integrated with 

HUD’s financial management systems and be included in its 

financial management system plans.

0 

2014-FO-0003 12/16/2013 004-G 

Establish an appropriate accounting and financial reporting 

governance structure with OCFO with the appropriate level of 

accounting. 

0 

2014-FO-0003 12/16/2013 006-C 

Enforce already existing internal control procedures to ensure 

proper supervision over accounting for Section 8 FAF 

receivables.

0 

2014-FO-0003 12/16/2013 006-D 

Perform a thorough analysis of outstanding FAF receivables and 

fiscal year 2013 collections to ensure that the receivables 

accurately represent the amounts owed to HUD, including but 

not limited to positive confirmations of outstanding receivable 

balances with the trustees.

0 

2014-FO-0003 12/16/2013 008-B 

Complete the closeout of any remaining CDBG-R and HPRP 

grants and forward all grant closeout agreement certifications to 

OCFO for recapture.

0 

2014-FO-0003 12/16/2013 008-C 

Deobligate $14,425,629 tied to 238 program obligations marked 

for deobligation during the departmentwide unliquidated 

obligations review. Additionally, OCFO should review the 93 

obligations with remaining balances totaling $316,935 and close 

out and deobligate amounts tied to obligations that are no longer 

valid, either based on the criteria defining the availability of 

appropriations at 31 U.S.C. 1301 or the criteria for recording 

obligations at 31 U.S.C. 1501.

0 

2014-FO-0003 12/16/2013 008-M 

Design and implement a policy to ensure that reconciliations 

between the subsidiary ledgers (supporting records) and the 

obligation balances in the general ledger (controlling accounts) 

are periodically performed for all HUD appropriations. The 

policy should also address the follow-up and clearance of 

identified differences and the responsibilities for the preparers 

and reviewers.

0 

2014-FO-0003 12/16/2013 015-A 

Make changes to IDIS Online, which will require grantees to 

specifically identify the grant allocation year to which the 

commitment should be assigned and include the commitment 

dates. The system should also allow HUD to ensure that 

commitments made during overlapping allocations and periods 

are counted toward only 1 year’s compliance requirements.

0 

153 █

███ 153 153 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-FO-0003 12/16/2013 015-B 

Stop using the cumulative method and the deadline compliance 

report for determining compliance with the 24-month 

commitment requirement in the HOME Investment Partnership 

Act and use only the commitments made within the 24-month 

period to determine compliance.

0 

2014-FO-0003 12/16/2013 015-C 

In accordance, with the GAO legal decision and opinion, take 

steps to identify and recapture funds that remain uncommitted

after the statutory commitment deadline and reallocate such 

funds in accordance with the Act.

0 

2014-FO-0003 12/16/2013 015-D 

Recapture funds from allocations during the 24-month 

overlapping period only for grantees that do not comply with the 

24-month commitment requirement.

0 

2014-AT-1003 12/30/2013 001-C Adjust program participants’ lien amounts for items not 

completed or corrected in recommendations 1A and 1B. 0 

2014-AT-1003 12/30/2013 001-D 

Review the remaining 88 HARP contracts that were not part of 

our sample to ensure that the City paid contractors for contracted 

repairs according to HUD and City regulations. For any contract 

with ineligible or unsupported costs, the City should include the 

contract amounts in recommendation 1A or 1B for 

reimbursement.

0 

2014-AT-1003 12/30/2013 001-F 

Refrain from awarding any future HARP contracts until it has 

adequate personnel to monitor rehabilitation work and ensure 

that federal funds are properly expended.

0 

2014-AT-1003 12/30/2013 001-G Reinspect the homes to ensure that identified deficiencies have 

been properly corrected. 0 

2013-CH-1010 9/30/2013 001-C 

We recommend that the Director of HUD’s Columbus Office of 

Community Planning and Development require the City to 

review and provide the results to HUD for the remaining 98 

Recovery Act Block Grant-funded roof and other exterior repair 

project files that were not part of our sample to ensure that the 

households were income eligible and that it maintained adequate 

and sufficient documentation to support that households were 

income eligible. For any household determined to be ineligible 

or if the City’s files lack documentation to support a household’s 

eligibility, the related amount will be added to 1A or 1B as 

appropriate.

0 

154 █

███ 154 154 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2013-CH-1010 9/30/2013 002-E 

We recommend that the Director of HUD’s Columbus Office of 

Community Planning and Development require the City to 

review and provide the results to HUD for the remaining 98 

Recovery Act Block Grant-funded roof and other exterior repair 

project files that were not part of our sample to ensure that the 

City maintained adequate support to show whether the services 

were provided at a reasonable cost. For any project for which a 

price quote was not obtained from at least three contractors and 

the contract cost exceeded the City’s independent estimate, the 

project and the overage amount will be added to 

recommendation 2A.

0 

2015-FO-0001 11/14/2014 001-F 

Initiate the billing process for the claims paid, plus incentive, 

where the lender has not provided the original of the note and 

security instrument within the prescribed deadlines for the $1.5 

billion.

1,486,544,478

2015-NY-1001 11/24/2014 001-A 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs instruct City officials to provide documentation

to justify the $183 million in unsupported salary and fringe 

benefits and associated expenses charged to the CDBG-DR 

program. If documentation provided does not support the costs, 

this amount should be repaid from non-Federal funds.

183,000,000

2014-LA-0004 6/30/2014 001-B 

HUD should remove the provision that allows public housing 

authorities to charge asset management fees, which would 

ensure that at least $81.6 million in operating funds could be put 

to better use in meeting HUD program objectives.

81,613,671

2014-FW-0001 2/7/2014 001-A 

The Boston Housing Authority and the City of Boston to 

provide support that they complied with 24 CFR Part 58 

requirements for the Authority’s Recovery Act grant or require 

the housing agency to repay $33,329,733 to HUD for its 

transmission to the U.S. Treasury. Repayment must be from 

non-Federal funds.

33,329,733

2014-LA-0005 8/8/2014 001-A 

Initiate the billing process, including determining lender status, 

for the 237 loans that were part of the ACD program for which 

the lenders were not billed. HUD incurred losses of nearly $22.4 

million for these loans.

21,698,472

2014-FW-0001 2/7/2014 001-B 

The Boston Housing Authority and the City of Boston to 

provide support that they complied with 24 CFR Part 58 

requirements for the Authority’s 2011 Capital Fund grant or 

require the housing agency to repay $21,478,604 to HUD. 

Repayment must be from non-Federal funds.

21,478,604

155 █

███ 155 155 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-FW-0005 9/24/2014 001-E 

The Detroit Housing Commission and the City of Detroit to 

provide support that they complied with 24 CFR Part 58 

requirements for the Commission’s Recovery Act grant or 

require the Commission to repay $17,275,908 to HUD for its 

transmission to the U.S. Treasury. Repayment must be from 

non-Federal funds.

17,275,908

2014-FW-0001 2/7/2014 001-C 

The Boston Housing Authority and the City of Boston to 

provide support that they complied with 24 CFR Part 58 

requirements for the Authority’s 2012 Capital Fund grant or 

require the housing agency to reimburse $17,058,105 to the 

Authority’s 2012 Capital Fund grant from non-Federal funds.

17,058,105

2015-FO-0002 12/8/2014 006-J 

Deobligate all obligations marked for deobligation during the 

departmentwide open obligations review, including as much as 

$3,561,042 in 64 administrative obligations marked for 

deobligation as of September 29, 2014. Additionally, review the 

171 obligations with remaining balances totaling $19,730,791 

and close out and deobligate amounts tied to obligations that are 

no longer valid or needed.

13,188,250

2014-LA-0005 8/8/2014 001-C 

Initiate the billing process, including determining lender status, 

for the 217 loans that went into default before the 

indemnification agreement expired for which the lenders were 

not billed. HUD incurred losses of nearly $12.5 million for 

these loans.

0 

2014-AT-1801 3/20/2014 001-B 

Provide all supporting documentation associated with the 

$10,838,880 (Total disbursements of $10,876,095 were adjusted 

to consider $37,215 questioned in State CDBG, Section 108, and 

program income proceeds disbursed for the development of the 

sports complex, if HUD determines the plan to be feasible ). 

HUD must determine the eligibility, reasonableness, and 

allocability of the funds disbursed. OCMA must reimburse its 

State CDBG program from non-Federal funds any amount 

determined ineligible.

10,838,880

2014-KC-0002 7/2/2014 001-B 

Update selection rules for CAIVRS to provide for complete 

reporting of all ineligible borrowers to put $9.5 million to better 

use.

9,501,619

2014-FW-0005 9/24/2014 001-F 

The Detroit Housing Commission and the City of Detroit to 

provide support that they complied with 24 CFR Part 58 

requirements for the Commission’s 2011 Capital Fund grant or 

require the Commission to repay $7,756,710 to HUD from nonFederal funds.

7,756,710

156 █

███ 156 156 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-AT-1001 12/5/2014 001-B 

Submit a plan for how it will proceed with respect to the 

Municipality of Dorado hotel project, including a schedule that 

HUD can track to ensure its completion. HUD must reevaluate 

the feasibility of the activity and determine the eligibility of the 

$7,369,000 already invested. If HUD determines that the 

activity has been canceled or is not feasible, Municipal Affairs 

must mitigate activity losses by committing any unused loan 

proceeds for future loan repayments.

7,369,000

2014-FW-0005 9/24/2014 001-G 

The Detroit Housing Commission and the City of Detroit to 

provide support that they complied with 24 CFR Part 58 

requirements for the Commission’s 2012 Capital Fund grant or 

require the Commission to reimburse $7,275,028 to its 2012 

Capital Fund grant from non-Federal funds.

7,275,028

2014-AT-1007 8/8/2014 001-A 

Reevaluate the feasibility of the activities and determine the 

eligibility of the $7,136,298 disbursed for the three projects with 

signs of slow progress. The Municipality must reimburse its 

HOME program from non-Federal funds if HUD determines the 

activities to have been terminated and reprogram and put to 

better use any unexpended funds associated with the terminated 

activities.

7,136,298

2015-AT-1001 12/5/2014 001-A 

Submit a plan for how it will proceed with respect to the 

Municipality of San Lorenzo activity center project, including a 

schedule that HUD can track to ensure its completion. HUD 

must reevaluate the feasibility of the activity and determine the 

eligibility of the $7,010,276 already invested. If HUD 

determines that the activity has been canceled or is not feasible, 

Municipal Affairs must mitigate activity losses by committing 

any unused loan proceeds for future loan repayments.

7,010,276

2014-NY-0003 9/4/2014 001-A 

We recommend that the Director of the Public Housing 

Financial Management Division recapture the $6,206,924 in 

operating subsidies that was erroneously awarded to seven 

PHAs.

6,206,924

2015-AT-1001 12/5/2014 001-C 

Submit a plan for how it will proceed with respect to the 

Municipality of Camuy hotel project, including a schedule that 

HUD can track to ensure its completion. HUD must reevaluate 

the feasibility of the activity and determine the eligibility of the 

$5,474,376 already invested. If HUD determines that the 

activity has been canceled or is not feasible, Municipal Affairs 

must mitigate activity losses by committing any unused loan 

proceeds for future loan repayments.

5,474,376

2014-FW-0001 2/7/2014 001-G 

The New Bedford Housing Authority to repay $4,860,197 in 

Recovery Act grant funds to HUD for its transmission to the 

U.S. Treasury. Repayment must be from non-Federal funds.

4,860,197

157 █

███ 157 157 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-FW-0002 5/12/2014 001-E 

The Kansas City, MO, Housing Authority and the City of 

Kansas City, MO, to provide support that they complied with 24 

CFR Part 58 requirements for the Authority’s Recovery Act 

grant or require the housing agency to repay $4,517,915 to HUD 

for its transmission to the U.S. Treasury. Repayment must be 

from non-Federal funds.

4,517,915

2014-PH-1008 8/29/2014 001-C 

Determine whether the documentation the State provided is 

adequate to support $3,487,461 disbursed for wages and salaries 

charged to the program by the contractors’ employees and if not, 

direct the State to repay HUD from non-Federal funds for any 

amount that it cannot support.

3,487,461

2015-FO-0002 12/8/2014 006-F Deobligate the 76 expired or inactive Sections 202 and 811 and 

project-based Section 8 projects totaling $3,458,166. 3,458,166

2014-FW-0002 5/12/2014 001-B 

The Kansas City, KS, Housing Authority and the Unified 

Government of Wyandotte County-Kansas City, KS, to provide 

support that they complied with 24 CFR Part 58 requirements 

for the Authority’s Recovery Act grant or require the housing 

agency to repay $3,438,953 to HUD for its transmission to the 

U.S. Treasury. Repayment must be from non-Federal funds.

3,438,953

2014-FW-0001 2/7/2014 001-H 

The New Bedford Housing Authority and the City of New 

Bedford to provide support that they complied with 24 CFR Part 

58 requirements for the Authority’s 2011 Capital Fund grant or 

require the housing agency to repay $3,154,021 to HUD. 

Repayment must be from non-Federal funds.

3,154,021

2014-FW-0001 2/7/2014 001-J 

The New Bedford Housing Authority and the City of New 

Bedford to provide support that they complied with 24 CFR Part 

58 requirements for the Authority’s 2012 Capital Fund grant or 

require the housing agency to reimburse $2,966,280 to the 

Authority’s 2012 Capital Fund grant from non-Federal funds.

2,966,280

2014-FW-0002 5/12/2014 001-F 

The Kansas City, MO, Housing Authority and the City of 

Kansas City, MO, to provide support that they complied with 24 

CFR Part 58 requirements for the Authority’s 2011 Capital Fund 

grant or require the housing agency to repay $2,920,093 to HUD 

from non-Federal funds.

2,920,093

2014-FW-0002 5/12/2014 001-C 

The Kansas City, KS, Housing Authority and the Unified 

Government of Wyandotte County-Kansas City, KS, to provide 

support that they complied with 24 CFR Part 58 requirements 

for the Authority’s 2011 Capital Fund grant or require the 

housing agency to repay $2,827,316 to HUD from non-Federal 

funds.

2,827,316

158 █

███ 158 158 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-FW-0002 5/12/2014 001-G 

The Kansas City, MO, Housing Authority and the City of 

Kansas City, MO, to provide support that they complied with 24 

CFR Part 58 requirements for the Authority’s 2012 Capital Fund 

grant or require the housing agency to reimburse $2,710,079 to 

the Authority’s 2012 Capital Fund grant from non-Federal 

funds.

2,710,079

2014-AT-0001 3/14/2014 001-E 

Reassess the $2,621,624 unjustified write off for FAF 210 and 

reinstate and pursue collection of all or any portion of the 

amount determined to have been written off without proper 

justification.

2,621,624

2014-FW-0002 5/12/2014 001-D 

The Kansas City, KS, Housing Authority and the Unified 

Government of Wyandotte County-Kansas City, KS, to provide 

support that they complied with 24 CFR Part 58 requirements 

for the Authority’s 2012 Capital Fund grant or require the 

housing agency to reimburse $2,555,880 to the Authority’s 2012 

Capital Fund grant from non-Federal funds.

2,555,880

2014-LA-0005 8/8/2014 001-B 

Initiate the billing process, including determining lender status, 

for the 32 loans that were part of the CWCOT program for 

which the lenders were not billed. HUD incurred losses of 

approximately $2.2 million for these loans.

0 

2015-FW-1801 10/2/2014 001-C 

Require the Authority to take action to reclaim its properties 

valued at $2,032,266 to improve its financial position, decrease 

its reliance on HUD program funding, and address its 

comingling issues.

2,032,266

2015-FO-0002 12/8/2014 006-B 

Deobligate $174,168 in 5 administrative obligations and 

$9,920,926 in 308 program obligations marked for deobligation 

during the department-wide open obligations review. 

Additionally, review the 72 obligations with remaining balances 

totaling $313,419 and close out and deobligate amounts tied to 

obligations that are no longer valid or needed.

1,956,447

2014-NY-1008 7/25/2014 001-A 

We recommend that the Director of HUD’s New York Office of 

Community Planning and Development instruct Palladia 

officials to provide documentation to justify that the $1,615,057 

in unsupported costs is associated with eligible program 

activities. Any unsupported costs determined to be ineligible 

should be reimbursed from non-Federal funds.

1,615,057

2014-NY-0003 9/4/2014 001-B 

We recommend that the Director of the Public Housing 

Financial Management Division reimburse the 5 PHAs that were 

underfunded $1,516,882 in ARF funding.

1,516,882

159 █

███ 159 159 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-CH-0001 9/30/2014 001-B 

We recommend that HUD’s Deputy Assistant Secretary for 

Single Family Housing to require the lenders to indemnify HUD 

for any future losses on the 16 loans24 with an estimated loss of 

$1,487,921.25 based on the loss severity rate of 54 percent of the 

total unpaid principal balance of $2,755,409 as of June 1, 2014.

1,487,921

2014-AT-1010 9/11/2014 001-G 

Recalculate the commitment requirement as a result of the 

County’s improperly committing $1,478,250 The County 

improperly committed $1,478, 250, composed of activity 5109 

and project 61 with commitments of $500,000 and $978,250, 

respectively, in HOME funds for project 61 and activity 5109 

and determine the cumulative effect on the County’s 

commitment requirement.

1,478,250

2015-NY-1002 12/1/2014 002-C 

We recommend that the Director of HUD’s New York Office of 

Public and Indian Housing require Authority officials to provide 

supporting documents for the proper use of $1,250,417 in sale 

proceeds from the scattered-site properties. Any amounts not 

supported or found to be improperly used should be repaid to the 

homeownership program from non-Federal funds.

1,250,417

2014-AT-1005 5/29/2014 001-A 

Reimburse $1,183,642 in HOME and CHDO funds to the 

HOME Investment Trust Fund treasury account from nonFederal funds.

1,183,642

2014-FW-0001 2/7/2014 001-D 

The Nashua Housing Authority and the City of Nashua to 

provide support that they complied with 24 CFR Part 58 

requirements for the Authority’s Recovery Act grant or require 

the housing agency to repay $1,169,494 to HUD for its 

transmission to the U.S. Treasury. Repayment must be from 

non-Federal funds.

1,169,494

2014-NY-1001 1/15/2014 001-A 

We recommend that the Director of the HUD Newark Office of 

Public and Indian Housing instruct Authority officials to provide 

documentation to support that the 252 units for which the 

Authority’s records did not document that an annual inspection 

was performed during program year 2012 comply with housing 

quality standards. If such documentation cannot be provided,

the $3.89 million (consisting of $3,768,868 in housing assistance 

payments and $122,977 of the Authority’s administrative fee 

paid related to those units) should be reimbursed to the program 

from non-federal funds.

1,139,664

2015-AT-1001 12/5/2014 002-A 

Recover from the borrowers and reimburse $1,080,242 to the 

applicable loan guarantee account from non-Federal funds for 

ineligible disbursements that were not related to the approved 

projects and used to finance local government operations.

1,080,242

160 █

███ 160 160 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-NY-1009 9/18/2014 001-B 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to repay the $1,060,529 not expended within the required 

timeframe so that these funds can be recaptured in accordance 

with Federal regulations.

1,060,529

2014-FW-0002 5/12/2014 001-A 

The Kansas City, KS, Housing Authority to repay $1,039,797 in 

Recovery Act grant funds to HUD for its transmission to the 

U.S. Treasury for contract obligations that occurred before the 

environmental review was completed by the responsible entity. 

Repayment must be from non-Federal funds.

1,039,797

2014-AT-1005 5/29/2014 001-B Provide documentation to support the $1,031,000 in CDBG 

loans or reimburse the CDBG program from non-Federal funds. 1,031,000

2014-FW-0001 2/7/2014 001-E 

The Nashua Housing Authority and the City of Nashua to 

provide support that they complied with 24 CFR Part 58 

requirements for the Authority’s 2011 Capital Fund grant or 

require the housing agency to repay $874,261 to HUD. 

Repayment must be from non-Federal funds.

874,261

2014-CH-1003 4/30/2014 001-D 

We recommend that the Acting Director of HUD’s Detroit 

Office of Public Housing require the Commission to support the 

use of the sole-sourcing procurement method for its Recovery 

Act-funded competitive grant or reimburse HUD $785,159 from 

non-Federal funds for transmission to the U.S. Treasury.

785,159

2014-AT-1005 5/29/2014 002-A 

Reimburse $772,000 in HOME funds used to pay ineligible 

expenses to the HOME Investment Trust Fund treasury account 

from non-Federal funds.

772,000

2014-CH-0001 9/30/2014 001-A 

We recommend that HUD’s Deputy Assistant Secretary for 

Single Family Housing to require the lenders to support that the 

loans cited for post-endorsement technical reviews by HUD 

were eligible for FHA insurance or require the lenders to 

indemnify HUD for any future losses on the 12 loans22 with an 

estimated loss of $1, 047, 314.23 based on the loss severity rate 

of 54 percent of the total unpaid principal balance of $1,939,471 

as of June 1, 2014.

759,042

2014-NY-1005 6/10/2014 001-B 

We recommend that the Director of the Newark, NJ, Office of 

Community Planning and Development instruct County officials 

to provide documentation supporting that $745,606, drawn down

for activities without evidence of executed agreements, was 

committed in a timely manner as required. If supporting 

documentation cannot be provided, the amount should be 

recaptured in accordance with regulations at 24 CFR 

92.500(d)(1)(B).

745,606

161 █

███ 161 161 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-FW-0001 2/7/2014 001-F 

The Nashua Housing Authority and the City of Nashua to 

provide support that they complied with 24 CFR Part 58 

requirements for the Authority’s 2012 Capital Fund grant or 

require the housing agency to reimburse $728,596 to the 

Authority’s 2012 Capital Fund grant from non-Federal funds.

728,596

2014-AT-1007 8/8/2014 002-A 

Submit all supporting documentation showing the eligibility and 

propriety of $726,738 in unaccounted for drawdowns from its 

treasury account or reimburse the HOME program from nonFederal funds.

726,738

2014-AT-1007 8/8/2014 001-B 

Require the Municipality to submit all supporting documentation 

showing that the 35 home buyers met the principal residency 

requirement for the duration of the period of affordability or 

reimburse the HOME program from non-Federal funds the 

$675,194 in HOME assistance provided.

675,194

2014-CH-1006 8/14/2014 001-A 

We recommend that the program center coordinator of HUD’s 

Indianapolis Office of Public and Indian Housing require the 

Authority to establish and maintain a separate net restricted 

assets account and reimburse the net restricted assets fund from 

non-Federal funds $640,283 or the current amount owed and 

provide the results to HUD for verification.

640,283

2014-NY-1004 5/20/2014 001-G 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct City officials to 

provide documentation to support the reasonableness and 

eligibility of the administrative program delivery costs charged 

to the CDBG program, including $597,048 in program delivery 

costs that could have been allocated to the State program, and 

repay the CDBG program from non-Federal funds any amounts 

determined to be unreasonable or ineligible.

597,048

2014-NY-1008 7/25/2014 001-E 

We recommend that the Director of HUD’s New York Office of 

Community Planning and Development instruct Palladia 

officials to provide source documentation to substantiate that the 

$584,579 in required non-Federal cash matching funds for five 

of the six program projects reviewed were met.

584,579

2014-FW-1003 7/2/2014 001-C Support or reimburse its program $570,834 from non-Federal 

funds for payments that lacked supporting documentation. 570,834

2014-BO-1002 4/30/2014 002-A Reimburse the Authority’s programs from non-Federal funds for 

more than $697,471 in unreasonable salary expenditures. 512,516

2014-NY-1009 9/18/2014 001-A 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to repay the $464,663 not committed within the required 

timeframe so that these funds can be recaptured in accordance 

with Federal regulations.

464,663

162 █

███ 162 162 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-NY-1009 9/18/2014 002-C 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to provide documentation to support compliance with the 

maximum HOME subsidy limits, the environmental review 

process, and the use and application of program income for the 

unsupported housing activity or repay $459,991 from nonFederal funds to the City’s HOME program line of credit.

459,991

2014-FW-0005 9/24/2014 001-J 

The Pontiac Housing Commission to repay $457,861 in 2011 

capital funds to HUD for its statutory violation of the 

requirement that the responsible entity, not the Commission, 

sign as certifying officer on the request for release of funds and 

certification. Repayment must be from non-Federal funds.

457,861

2014-LA-1005 8/22/2014 001-B 

Require the City to repay HUD, using non-Federal funds, 

$449,598 paid to secondary lien holders, developers, and 

contractors for rehabilitation work not performed.

449,598

2014-BO-1001 1/23/2014 001-A 

Repay the Authority’s asset management projects from nonFederal funds $582,562 related to the ineligible cost deficiencies 

identified in this finding; specifically, charges of $240,321 for 

central maintenance employees; $281,611 for asset management, 

property management, and bookkeeping fees; $26,434 for 

insurance; $10,000 for auditing; $20,000 for consulting; and 

$4,196 for legal expenses.

413,493

2014-AT-1007 8/8/2014 003-A Deobligate, reprogram, and put to better use $387,449 in 

overstated commitments. 387,449

2014-CH-1006 8/14/2014 002-C 

We recommend that the program center coordinator of HUD’s 

Indianapolis Office of Public and Indian Housing require the 

Authority to implement adequate procedures and controls to 

ensure that all units meet HUD’s housing quality standards and 

its own requirements to prevent $373,661 in program funds from 

being spent on units that do not comply with HUD’s 

requirements over the next year. The procedures and controls 

should include but not be limited to providing feedback to the 

inspectors to correct recurring inspection deficiencies, inspectors 

are properly trained and familiar with HUD’s and its own

requirements, and inspectors consistently conduct accurate and 

complete inspections.

373,661

2014-LA-0005 8/8/2014 002-D 

Initiate the billing process for the five loans with losses to HUD 

that were streamline refinanced. HUD incurred losses of 

$373,228 for these loans.

0 

2015-AT-1001 12/5/2014 002-C 

Obtain and submit supporting documentation showing the 

eligibility and propriety of $367,840 in disbursements or 

reimburse the loan guarantee account from non-Federal funds.

367,840

163 █

███ 163 163 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-AT-1005 5/29/2014 002-B 

Seek recovery of the $323,720 in CDBG funds from the bank 

with interest from March 14, 2002, to the present. Reimburse 

$323,720 in CDBG funds to the CDBG program from nonfederal funds and reimburse the interest to the U.S. Treasury.

323,720

2014-FW-0005 9/24/2014 001-I 

The Pontiac Housing Commission and the City of Pontiac to 

provide support that they complied with 24 CFR Part 58 

requirements for the Commission’s Recovery Act grant or 

require the Commission to repay $315,831 to HUD for its 

transmission to the U.S. Treasury. Repayment must be from 

non-Federal funds.

315,831

2014-PH-1007 7/15/2014 001-A Reimburse the grantee’s program $312,077 from non-Federal 

funds for the ineligible disbursements. 312,077

2014-NY-1009 9/18/2014 004-D 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City Officials 

to record the receipt and use of $289,858 in program income in 

IDIS, thus ensuring that $289,858 in program income is properly 

accounted for and put to better use.

289,858

2014-AT-0001 3/14/2014 001-B 

Require contract administrators that did not apply the back-out 

requirements to recalculate all FAF projects with Section 8 rent 

increases that occurred from January 2004 to the present and 

adjust current and future rents to the amounts supported by the 

calculations. We estimate annual savings of $279,639 through 

the implementation of this recommendation for the projects 

reviewed.

279,639

2014-FW-0005 9/24/2014 001-H 

The Pontiac Housing Commission to repay $273,774 in 

Recovery Act grant funds to HUD for its transmission to the 

U.S. Treasury for contract obligations that occurred before the 

environmental review was completed by the responsible entity. 

Repayment must be from non-Federal funds.

273,774

2014-NY-1009 9/18/2014 002-A 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to reimburse the City’s HOME program line of credit $250,410 

from non-Federal funds for HOME assistance expended on 

housing units acquired by two ineligible home buyers.

250,410

2014-AT-1010 9/11/2014 001-B 

Provide supporting documentation for activity 5134 or 

reimburse its program $45,600 from non-Federal funds and put 

to better use $204,400 in HOME funds.

250,000

164 █

███ 164 164 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-FW-1801 10/2/2014 001-D 

Require the Authority to determine how much of the $243,442 

in salaries for individuals assigned to work at multiple properties 

was improperly paid with Federal funds and repay the amounts 

to the appropriate programs from non-Federal funds. If the 

Authority is unable to accurately determine the amount due to 

and due from each program or support that the funds charged to 

the Federal programs were appropriate, the full $243,422 should 

be repaid to HUD.

243,442

2014-CH-1003 4/30/2014 001-C 

We recommend that the Acting Director of HUD’s Detroit 

Office of Public Housing require the Commission to support the 

reasonableness or reimburse HUD $239,033 from non-Federal 

funds, for transmission to the U.S. Treasury, for the amount of 

the Commission’s Recovery Act-funded contract that exceeded 

the independent estimate.

239,033

2014-PH-1007 7/15/2014 001-B 

Provide documentation to support its use of $308,797 in 

program funds or reimburse the grantee’s program from nonFederal funds for any amount that it cannot support.

226,664

2014-LA-1005 8/22/2014 001-A 

Require the City to return to HUD, using non-Federal funds, the 

actual amount of administrative costs charged to the grant 

related to the three developers or $223,085 because the City 

mismanaged its NSP1.

223,085

2014-CH-1002 1/6/2014 001-C 

We recommend that the Director of HUD’s Detroit Office of 

Community Planning and Development require the City to use 

for eligible Program costs, before drawing down additional 

Program funds, $203,802 in (1) the remaining fire insurance 

funds for which it inappropriately drew down Program funds 

when it had fire insurance funds available (nearly $132,000) and 

(2) Program funds drawn down for duplicate demolition costs 

(nearly $72,000).

203,802

2014-NY-1004 5/20/2014 001-A 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct City officials to 

submit documentation to justify the unsupported costs of 

$200,000 incurred for an economic development loan so that 

HUD can make an eligibility determination. For any costs 

determined to be ineligible, HUD should require the City to 

reimburse the CDBG program from non-Federal funds.

200,000

2015-BO-1001 12/16/2014 001-B 

Provide documentation to support that the $200,000 transferred 

to the agent’s revolving fund account was expended for eligible 

project costs and if such support cannot be provided, repay the 

project this amount from non-Federal funds.

200,000

2014-FW-1002 5/27/2014 001-B 

Discontinue using its low-rent public housing fund as a general 

fund to pay costs associated with its business activities until it 

has established appropriate controls.

178,893

165 █

███ 165 165 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-AT-1011 9/22/2014 001-C 

Develop and implement procedures and controls to ensure 

compliance with requirements, to include but not be limited to 

procedures and controls to ensure that (1) housing assistance 

payments are eligible and supported, (2) appropriate 

documentation is obtained and maintained, and (3) property 

managers are adequately trained on the program requirements. 

By doing so, we estimate an annual savings of $174,995 in 

housing assistance payments.

174,995

2014-LA-0005 8/8/2014 001-D 

Determine the loss amounts for the three loans (412-4767940, 

442-2462614, and 561-8450712) that were part of the ACD 

program, which OIG was unable to determine the loss. 

147,467

2014-FW-1806 8/19/2014 001-E 

Support or repay from non-Federal funds $144,263 to its 

Operating Fund program for credit card purchases that did not 

have receipts or other support.

144,263

2015-FO-0002 12/8/2014 006-U 

Deobligate $5,210 in two administrative obligations and 

$109,500 in one program obligation marked for deobligation 

during the department-wide open obligations review. 

Additionally, review the 17 obligations with remaining balances 

totaling $26,711 and close out and deobligate amounts tied to 

obligations that are no longer valid or needed.

141,421

2014-LA-1005 8/22/2014 001-D Require the City to repay HUD, using non-Federal funds, 

$137,601 for the unreasonable costs identified in the report. 137,601

2014-CH-1009 9/12/2014 001-F 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to support the time 

spent correctly administering its Family Self-Sufficiency 

program or reimburse HUD from non-Federal funds the 

appropriate portion of the $137,347 in coordinator grant funds 

received for fiscal years 2012 and 2013 that was incorrectly 

paid.

137,347

2014-CH-1006 8/14/2014 001-C 

We recommend that the program center coordinator of HUD’s 

Indianapolis Office of Public and Indian Housing require the 

Authority to support that program funds were not used for the 

$132,974 ($68,369 in personal and inappropriate expenditures + 

$64,605 in unsupported expenditures) or reimburse its program 

from non-Federal funds for the unsupported credit card 

expenditures cited in this finding.

132,974

2014-NY-1009 9/18/2014 001-L 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to reconcile the $118,561 ($16,192 + 102,369) discrepancy 

between the City’s accounting records and financial information 

reported in IDIS to ensure that these funds have been put to their 

intended use.

118,561

166 █

███ 166 166 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-CH-1006 8/14/2014 003-F 

We recommend that the program center coordinator of HUD’s 

Indianapolis Office of Public and Indian Housing require the 

Authority to support or reimburse its program $118,079 

($112,571 in housing assistance payments + $5,508 in 

associated administrative fees) from non-Federal funds for the 

unsupported overpayment of housing assistance cited in this 

finding.

118,079

2014-FW-1802 3/31/2014 001-B 

Require the Authority to support or repay its various program 

accounts $109,861 from nonfederal funds for unsupported 

payroll, other compensation, bonuses, travel, supplies, contractor 

payments and petty cash disbursements.

103,420

2014-CH-1009 9/12/2014 001-A 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to reimburse its 

Housing Choice Voucher program $106,924 from non-Federal 

funds for the overpayment of its Family Self-Sufficiency 

program graduates’ escrow disbursements cited in this finding.

106,924

2014-LA-1005 8/22/2014 001-C Require the City to repay HUD, using non-Federal funds, 

$103,806 for all other ineligible costs identified in the report. 103,806

2014-AT-1005 5/29/2014 002-C Reimburse $100,000 in HOME funds to the HOME Investment 

Trust Fund Treasury account from non-Federal funds. 100,000

2014-CH-1004 7/14/2014 001-F 

We recommend that the Acting Director of HUD’s Chicago 

Office of Public Housing require the Authority to support or 

reimburse its program $220,704 ($70 + $197,906 in housing 

assistance payments + $26 in utility allowances + $22,702 in 

associated administrative fees) from non-Federal funds for the 

unsupported overpayment of housing assistance due to 

unsupported calculations, missing eligibility documentation, and 

discrepancies in the housing assistance payments register.

91,226

2014-FW-0005 9/24/2014 001-K 

The Pontiac Housing Commission to reimburse $82,470 to the 

Commissions’ 2012 Capital Fund grant for operation 

expenditures that occurred before the environmental review was 

completed by the responsible entity. Repayment must be from 

non-Federal funds.

82,470

2014-CH-1003 4/30/2014 001-A 

We recommend that the Acting Director of HUD’s Detroit 

Office of Public Housing require the Commission to reimburse 

HUD $79,975 from non-Federal funds, for transmission to the 

U.S. Treasury, for the work items that were not allocable to the 

Recovery Act competitive grant-funded contract.

79,975

2014-AT-0001 3/14/2014 001-F 

Reassess the $72,969 unsupported write-off for FAF 393 and 

reinstate and pursue collection of all or any portion of the 

amount determined to have been written off without proper 

justification.

72,969

167 █

███ 167 167 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-NY-1001 1/15/2014 002-C 

We recommend that the Director of the HUD Newark Office of 

Public and Indian Housing instruct Authority officials to provide 

adequate documentation of a valid Social Security number for 

the three tenants without valid Social Security numbers on 

whose behalf $116,761 in housing assistance payments was 

disbursed. Any amount not supported should be repaid from 

non-Federal funds, and the status of any tenant deemed 

ineligible should be determined in accordance with the 

Authority’s administrative plan.

70,111

2014-AT-1007 8/8/2014 002-B 

Submit all supporting documentation showing the eligibility and 

propriety of $68,322 charged to the HOME program for project 

and administrative costs or reimburse the program from nonFederal funds.

68,322

2014-AT-0001 3/14/2014 001-G 

Reassess the $67,000 unsupported write-off for FAF 184 and 

reinstate and pursue collection of all or any portion of the 

amount determined to have been written off without proper 

justification.

67,000

2014-FW-0005 9/24/2014 001-A 

The Dearborn Housing Commission to repay $63,255 in 

Recovery Act grant funds to HUD for its transmission to the 

U.S. Treasury for architect and engineering fees and contract 

obligations that occurred before the environmental review was 

completed by the responsible entity. Repayment must be from 

non-Federal funds.

63,255

2014-AT-1007 8/8/2014 002-C Reimburse from non-Federal funds $62,204 in ineligible project 

costs. 62,204

2015-BO-1001 12/16/2014 001-D 

Provide documentation to support that the expenditure of 

$57,110 in 2011 was for eligible project salaries and if such 

support cannot be provided, repay the amount to the project 

from non-Federal funds.

57,110

2014-AT-1007 8/8/2014 002-D Remit to its treasury account and put to better use the 

reimbursed HOME funds totaling $56,102. 56,102

2014-CH-1009 9/12/2014 001-B 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to reimburse its 

Housing Choice Voucher program $53,559 for the overfunding 

of its Family Self-Sufficiency program participants’ escrow 

accounts.

53,559

2014-CF-1805 8/11/2014 001-A 

Agree to allow HUD OIG to record the $57,500 settlement in 

HUD’s Audit Resolution and Corrective Actions Tracking 

System as an ineligible cost.

52,500

168 █

███ 168 168 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-FW-1801 10/2/2014 001-J 

Require the Authority to determine whether the Authority 

improperly used Federal funds totaling $50,000 which were used 

to pay unnecessary severance contract costs. If Federal funds 

were improperly used, the Authority should repay $50,000 to its 

Federal program accounts from non-Federal funds. If the 

Authority is unable to accurately determine the amount due to 

and due from each program or support that the funds charged to 

the Federal program were appropriate, the full $50,000 should 

be repaid to HUD.

50,000

2014-CH-1009 9/12/2014 002-A 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to

support its waiver request and the applicable approval from 

HUD to waive its conflict of interest requirements or reimburse 

HUD $47,353 for the housing assistance payments disbursed 

while the conflicts of interest existed.

47,353

2015-FW-1802 10/31/2014 001-D 

We recommend that the Director, Office of Public Housing, Fort 

Worth, TX, require the Authority to either support or repay to 

HUD for its transmission to the U.S. Treasury $43,300 in 

unsupported asbestos abatement expenses. Repayment must be 

from non-Federal funds.

43,300

2015-FW-1801 10/2/2014 001-F 

Require the Authority to determine whether the Authority 

improperly used Federal funds totaling $40,600 to make lease 

payments on the parking lot it already owned. If Federal funds 

were improperly used, the Authority should repay $40,600 from 

non-Federal funds to its Federal program accounts. If the 

Authority is unable to accurately determine the amount due to 

and due from each program or support that the funds charged to 

the Federal program were appropriate, the full $40,600 should 

be repaid to HUD.

40,600

2014-CH-1004 7/14/2014 001-A 

We recommend that the Acting Director of HUD’s Chicago 

Office of Public Housing require the Authority to reimburse its 

program $39,605 ($21,546 in housing assistance payments + 

$18,059 in associated administrative fees) from non-Federal 

funds for the overpayment of housing assistance due to 

inappropriate calculations of housing assistance payments.

39,605

2014-AT-1801 3/20/2014 001-D 

Submit supporting documentation showing the eligibility and 

propriety of $37,215 drawn from HUD or reimburse the State 

CDBG program from non-Federal funds.

37,215

2015-FW-1802 10/31/2014 001-B 

We recommend that the Director, Office of Public Housing, Fort 

Worth, TX, require the Authority to resolve its unpaid payroll 

taxes and retirement liabilities and ensure that the Authority only 

uses non-federal or non-HUD funds to pay the unpaid interest or 

penalties.

36,882

169 █

███ 169 169 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-CH-1006 8/14/2014 002-B 

We recommend that the program center coordinator of HUD’s 

Indianapolis Office of Public and Indian Housing require the 

Authority to reimburse its program $35,545 from non-Federal 

funds ($32,769 for program housing assistance + $2,776 in 

associated administrative fees) for the 19 units that materially 

failed to meet HUD’s housing quality standards and its own 

requirements.

35,545

2014-CH-1004 7/14/2014 002-A 

We recommend that the Acting Director of HUD’s Chicago 

Office of Public Housing require the Authority to reimburse its 

program $31,204 from non-Federal funds for the ineligible 

expenditures cited in this finding.

31,204

2014-CH-1006 8/14/2014 003-K 

We recommend that the program center coordinator of HUD’s 

Indianapolis Office of Public and Indian Housing require the 

Authority to implement procedures and controls to ensure that 

housing assistance is correctly calculated and repayment 

agreements are created to recover overpaid housing assistance 

when unreported income is discovered during the examination 

process to ensure that $30,764 ($27,211 in overpayments + 

$3,553 in underpayments) in program funds is appropriately

used for future payments.

30,764

2014-CH-1004 7/14/2014 001-G 

We recommend that the Acting Director of HUD’s Chicago 

Office of Public Housing require the Authority to reimburse the 

appropriate households $25,767 from non-Federal funds for the 

rent amounts paid in excess of 40 percent of their adjusted 

monthly income for units that were not affordable.

25,767

2015-FW-1801 10/2/2014 001-M 

Require the Authority to repay $23,546 to its Section 8 

Homeownership Voucher program from non-Federal funds for 

the $17,124 in ineligible owner housing assistance payments to 

the former Section 8 program manager and the $6,422 in 

ineligible owner housing assistance payments to the son of 

director 1.

23,546

2014-CH-1006 8/14/2014 001-E 

We recommend that the program center coordinator of HUD’s 

Indianapolis Office of Public and Indian Housing require the 

Authority to support that program funds used were not used to 

pay the $23,353 in employee loans or reimburse its program 

from non-Federal funds for the unsupported employee loans 

cited in this finding.

23,353

2014-FW-0001 2/7/2014 001-I 

The New Bedford Housing Authority to repay $22,786 from 

non-Federal funds to its 2012 Capital Fund grant for salaries and 

benefits that were released before the responsible entity 

documented that activities met exemption requirements.

22,786

170 █

███ 170 170 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-FW-1802 10/31/2014 001-C 

We recommend that the Director, Office of Public Housing, Fort 

Worth, TX, Require the Authority to support or repay $46,097 in 

unsupported expenditures. The funds should be repaid to the 

Authority’s public housing program. However, if the Authority 

made any of the expenditures from its 2010 or earlier capital 

fund grants, or if the Authority is unable to determine the source 

of funds used to pay expenditures, the Authority should repay 

HUD. Any repayments must be from non-Federal funds.

21,767

2014-CH-1003 4/30/2014 001-B 

We recommend that the Acting Director of HUD’s Detroit 

Office of Public Housing require the Commission to reimburse 

HUD $20,833 from non-Federal funds, for transmission to the 

U.S. Treasury, for the Recovery Act-funded work items that 

were not included in the Commission’s annual or 5-year plan.

20,833

2014-CH-1006 8/14/2014 003-A 

We recommend that the program center coordinator of HUD’s 

Indianapolis Office of Public and Indian Housing require the 

Authority to reimburse its program $20,001 ($12,221 in housing 

assistance payments + $7,780 in associated administrative fees) 

from non-Federal funds for the overpayment of housing 

assistance due to inappropriate calculations of housing 

assistance payments.

20,001

2014-NY-1001 1/15/2014 001-C 

We recommend that the Director of the HUD Newark Office of 

Public and Indian Housing instruct Authority officials to 

reimburse from non-federal funds the $62,789 in housing 

assistance disbursed for the nine units that materially failed 

housing quality standards inspection.

19,407

2014-NY-1004 5/20/2014 001-C 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct City officials to

repay from non-Federal funds the ineligible costs of $18,027 that 

were paid to a subrecipeint, which did not benefit the CDBG 

program.

18,027

2014-FW-1003 7/2/2014 002-B 

Reimburse its program $18,391 from non-Federal funds for the 

12 units that materially failed to meet HUD’s housing quality 

standards.

16,391

2014-FW-1003 7/2/2014 001-A 

Reimburse its program $16,350 from non-Federal funds for the 

overpayment of housing assistance and utility reimbursement 

payments.

16,350

171 █

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SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-CH-1002 1/6/2014 001-H 

We recommend that the Director of HUD’s Detroit Office of 

Community Planning and Development support that the more 

than $14,000 in refunded gas cut and cap fees that was 

inappropriately transferred into its Program account and used for 

Program costs was an eligible Program use under the Recovery 

Act or reimburse its Program under the Recovery Act $14,250 

from non-Federal funds and use the funds for eligible Program 

costs under the Recovery Act.

14,250

2014-CH-1006 8/14/2014 001-F 

We recommend that the program center coordinator of HUD’s 

Indianapolis Office of Public and Indian Housing require the 

Authority to reimburse its program $12,654 from non-Federal 

funds for the ineligible overdraft, nonsufficient fund checks, and 

service charges.

12,654

2015-FW-1801 10/2/2014 001-H 

Require the Authority to determine whether the Authority 

improperly used Federal funds totaling $11,833 which were used 

to cancel an existing phone system and purchase a new one. If 

Federal funds were improperly used, the Authority should repay 

$11,833 to its Federal program accounts from non-Federal 

funds. If the Authority is unable to accurately determine the 

amount due to and due from each program or support that the 

funds charged to the Federal program were appropriate, the full 

$11,833 should be repaid to HUD.

11,833

2014-AT-1011 9/22/2014 001-B 

Support or reimburse its project $218,676 from non-project 

funds for housing assistance payments that lacked supporting 

documentation.

11,175

2014-CH-1006 8/14/2014 003-C 

We recommend that the program center coordinator of HUD’s 

Indianapolis Office of Public and Indian Housing require the 

Authority to pursue collection from the applicable households or 

reimburse its program $10,369 from non-Federal funds for the 

overpayment of housing assistance due to unreported income.

10,369

2014-CH-1006 8/14/2014 003-E 

We recommend that the program center coordinator of HUD’s 

Indianapolis Office of Public and Indian Housing require the 

Authority to reimburse its program $9,420 from non-Federal 

funds for the overpayment of housing assistance due to allowing 

households a one-bedroom payment standard each for a sharedhousing unit.

9,420

2014-CH-1009 9/12/2014 001-E 

We recommend that the Director of HUD’s Detroit Office of 

Public Housing require the Commission to support the escrow 

account balances for its current program participants totaling 

$9,040 or reimburse its Housing Choice Voucher program for 

the unsupported escrow credits cited in this finding. The actual 

unsupported escrow balance was $39,178. However, $30,138 of 

that amount was included in recommendation 1B as an ineligible 

cost, thus reducing the amount in recommendation 1E to $9,040.

9,040

172 █

███ 172 172 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-FW-1804 8/1/2014 001-J Support or repay from non-Federal funds $8,721 in unsupported 

vacation payments. 8,721

2014-NY-1004 5/20/2014 001-D 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct City officials to 

provide documentation regarding the repayment of the $7,035 

that was paid an architecture firm related to a State grant to 

ensure that it was properly repaid to the CDBG program from 

non-Federal funds.

7,035

2014-CH-1004 7/14/2014 001-C 

We recommend that the Acting Director of HUD’s Chicago 

Office of Public Housing require the Authority to pursue 

collection from the applicable households or reimburse its 

program $5,599 from non-Federal funds for the overpayment of 

housing assistance due to unreported income.

5,599

2014-CH-1006 8/14/2014 003-B 

We recommend that the program center coordinator of HUD’s

Indianapolis Office of Public and Indian Housing require the 

Authority to reimburse the appropriate households $3,973 from 

program funds for the underpayment of housing assistance due 

to inappropriate calculations of housing assistance payments.

3,973

2014-FW-1806 8/19/2014 001-D 

Repay $3,840 from non-Federal funds to its Operating Fund 

program for amounts paid for ineligible credit card purchases 

and transactions.

3,840

2014-CH-1002 1/6/2014 001-F 

We recommend that the Director of HUD’s Detroit Office of 

Community Planning and Development require the City to 

support that the more than $7,000 in fire insurance funds 

transferred into its Block Grant program account in May 2012 

for an address was appropriate or reimburse its Program $3,833 

from non-Federal funds, as appropriate, for the nearly $4,000 in 

Program funds that it drew down for the address.

3,833

2014-LA-1006 9/25/2014 001-E 

Provide documentation to support the $3,242 in total 

development costs identified in this report or reimburse the 

homeowner. 

3,242

2014-CH-1006 8/14/2014 001-D 

We recommend that the program center coordinator of HUD’s 

Indianapolis Office of Public and Indian Housing require the 

Authority to reimburse its program $3,036 from non-Federal 

funds for the ineligible credit card late fees and finance charges.

3,036

2014-CH-1006 8/14/2014 003-G 

We recommend that the program center coordinator of HUD’s 

Indianapolis Office of Public and Indian Housing require the 

Authority to reimburse the appropriate household $3,006 from 

non-Federal funds for the rent amount paid in excess of 40 

percent of its adjusted monthly income for the unit that was not 

affordable.

3,006

173 █

███ 173 173 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-CH-1006 8/14/2014 003-D 

We recommend that the program center coordinator of HUD’s 

Indianapolis Office of Public and Indian Housing require the 

Authority to reimburse its program $2,558 from non-Federal 

funds for the overpayment of housing assistance due to not 

capturing income increases reported by the households.

2,558

2014-CH-1004 7/14/2014 001-D 

We recommend that the Acting Director of HUD’s Chicago 

Office of Public Housing require the Authority to pursue 

collection from the applicable landlords or reimburse its 

program $2,095 in housing assistance from non-Federal funds 

for the overpayment of housing assistance due to discrepancies 

in the housing assistance payments register.

2,095

2014-FW-1806 8/19/2014 001-F 

Support or repay from non-Federal funds $2,070 to its Capital or 

Operating Fund program as appropriate for the missing 

appliances.

2,070

2014-FW-1804 8/1/2014 001-M Repay from non-Federal funds $1,724 paid for unnecessary 

costs paid for mileage. 1,724

2014-FW-1804 8/1/2014 001-N Support or repay from non-Federal funds $1,682 paid to its 

executive director for unsupported costs. 1,682

2014-CH-1004 7/14/2014 001-B 

We recommend that the Acting Director of HUD’s Chicago 

Office of Public Housing require the Authority to reimburse the 

appropriate households $5,308 from program funds for the 

underpayment of housing assistance due to inappropriate 

calculations.

1,394

2014-CH-1004 7/14/2014 001-E 

We recommend that the Acting Director of HUD’s Chicago 

Office of Public Housing require the Authority to reimburse the 

appropriate landlords $1,143 in housing assistance from program 

funds for the underpayment of housing assistance due to 

discrepancies in the housing assistance payments register.

1,070

2015-FW-1801 10/2/2014 001-I 

Require the Authority to determine whether the Authority 

improperly used Federal funds totaling $657 which were used to 

purchase ineligible meals and other personal items. If Federal 

funds were improperly used, the Authority should repay $657 to 

its Federal program accounts from non-Federal funds. If the 

Authority is unable to accurately determine the amount due to 

and due from each program or support that the funds charged to 

the Federal program were appropriate, the full $657 should be 

repaid to HUD.

657

2014-FW-1804 8/1/2014 001-O Repay from non-Federal funds $620 paid to the executive 

director for ineligible costs. 620

174 █

███ 174 174 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-AT-0001 3/14/2014 001-A 

Develop and implement controls and procedures to monitor the 

application of required rent adjustments to Section 8 FAF 

projects which should include adding a section to Housing’s 

monitoring review checklist to address the backing out of trustee 

sweep payments.

0 

2014-AT-0001 3/14/2014 001-C 

Renew Housing Notices 97-49 and 3-28 and include appropriate 

example calculations to guide contract administrators and HUD 

staff on how to calculate annual adjustment factor rents for 

bond-refunded projects and for use in enforcing the 

requirements.

0 

2014-AT-0001 3/14/2014 001-D 

Develop and implement controls to ensure requests made by 

Housing for adjustments to bond receivables are properly 

assessed and supported in accordance with provisions in 

Housing Notice 3-28.

0 

2014-AT-0001 3/14/2014 001-H 

Develop and implement controls and procedures to monitor the 

remitting of trust fund balances to ensure that funds due to HUD 

upon prepayments or normal payoff of bonds are not released to 

other parties unless conditions established by headquarters are 

met and documented.

0 

2014-AT-1007 8/8/2014 001-C 

Recapture any shortfalls generated by the closure and 

deobligation of funds associated with recommendations 1A to 

1B that do not meet statutory requirements for the timely 

commitment and expenditure of funds pursuant to the National 

Defense Authorization Act of 1991 and/or Title II of the 

Cranston-Gonzalez National Affordable Housing Act, as 

amended.

0 

2014-AT-1007 8/8/2014 003-B 

Correct any inaccurate information in HUD’s information 

system, including but not limited to the receipt of $233,137 

associated with program income and recaptured funds not 

reported and inaccurate commitment amounts and dates.

0 

2014-AT-1010 9/11/2014 001-A 

Establish and implement policies and procedures to ensure that 

commitments are entered into IDIS after the County has a valid 

written agreement that has been signed and dated by all parties.

0 

2014-AT-1010 9/11/2014 001-D 

Provide the revised HOME agreement templates for the various 

types of awardees, which must include the HOME provisions 

and date line for signatures. The home buyer assistance 

agreements template should also include a signature and date 

line for the County.

0 

2014-AT-1010 9/11/2014 001-E Establish and implement policies and procedures to ensure that 

amendments are executed on a timely basis. 0 

2014-AT-1011 9/22/2014 001-A Reimburse its project $216,749 from non-project funds for the 

ineligible housing assistance payments. 0 

175 █

███ 175 175 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-AT-1011 9/22/2014 001-D Develop and implement policies to monitor its property 

managers to ensure adequate administration of the program. 0 

2014-AT-1015 9/30/2014 001-A 

Refer Prudential Huntoon Paige Associates, LTD to the 

Mortgagee Review Board for appropriate action for violations 

that caused a more than $20 million loss to HUD’s FHA 

insurance fund.

0 

2014-AT-1015 9/30/2014 001-B 

Take appropriate enforcement actions against the responsible 

parties and pursue civil remedies under the False Claims Act, if 

legally sufficient, against responsible parties for incorrectly 

certifying to the integrity of the data or that due diligence was 

exercised by the underwriting of the loan that resulted in a loss 

to HUD totaling $20,157,329.

0 

2014-AT-1015 9/30/2014 001-C 

Pursue administrative actions, as appropriate, against the 

responsible party for the material underwriting deficiencies cited 

in this report.

0 

2014-AT-1801 3/20/2014 001-C 

Ensure that the Municipality maintains adequate documentation 

related to the Vieques sports complex project in accordance with 

HUD requirements and that these demonstrate the allowability, 

necessity, and reasonableness of the costs incurred.

0 

2014-CH-1002 1/6/2014 001-B 

We recommend that the Director of HUD’s Detroit Office of 

Community Planning and Development determine whether the 

U.S. Treasury paid unnecessary interest on the Program funds 

associated with the more than $604,000 in fire insurance funds 

the City transferred into its Program account in July 2013. If the 

U.S. Treasury paid unnecessary interest, the City should 

reimburse HUD, for transmission to the U.S. Treasury, from 

non-Federal funds for the unnecessary interest the U.S. Treasury 

paid on the Program funds that the City inappropriately drew 

down for activities when it had fire insurance funds for the 

properties associated with the activities.

0 

2014-CH-1002 1/6/2014 001-G 

We recommend that the Director of HUD’s Detroit Office of 

Community Planning and Development require the City to 

determine for the remaining 177 addresses in its report whether 

fire insurance funds were available when it drew down Program 

funds for the demolition costs. If fire insurance funds were 

available, the City should (1) use the fire insurance funds for 

eligible Program costs before drawing down additional Program 

funds and (2) reimburse HUD, for transmission to the U.S. 

Treasury, from non-Federal funds any unnecessary interest the 

U.S. Treasury paid on the Program funds that it drew down for 

activities when it had fire insurance funds for the properties 

associated with the activities.

0 

176 █

███ 176 176 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-CH-1004 7/14/2014 001-I 

We recommend that the Acting Director of HUD’s Chicago 

Office of Public Housing require the Authority to for households 

currently residing in units that are not affordable, renegotiate the 

rents to owner or require the households to move to units that are 

affordable.

0 

2014-CH-1006 8/14/2014 001-B 

We recommend that the program center coordinator of HUD’s 

Indianapolis Office of Public and Indian Housing require the 

Authority to reconcile its books and accounting records to 

determine the sources and use of funds in its operating account.

0 

2014-CH-1006 8/14/2014 003-H 

We recommend that the program center coordinator of HUD’s 

Indianapolis Office of Public and Indian Housing require the 

Authority to review the remaining household files to ensure that 

additional households are not residing in units that are not 

affordable.

0 

2014-CH-1006 8/14/2014 003-L 

We recommend that the program center coordinator of HUD’s 

Indianapolis Office of Public and Indian Housing require the 

Authority to implement procedures and controls to ensure that 

required eligibility documentation is obtained and maintained to 

support households’ admission to and continued assistance on 

the program.

0 

2014-FO-0004 4/15/2014 001-G 

Report on Multifamily, Public Housing, and Section 8 program 

improper payment rates separately in the agency financial 

reports.

0 

2014-FO-0004 4/15/2014 001-L 

Coordinate with all appropriate program officials when 

responding to OCFO’s information requests to ensure that all 

statements are accurate for the current fiscal year, to include but 

not be limited to updates to corrective action plans, internal 

controls in place, and information on any barriers the agency is 

experiencing.

0 

2014-FO-0004 4/15/2014 001-M 

Develop and execute formal plans to hold accountable program 

officials and processing entities (owners or administrators) 

responsible for improper payments.

0 

2014-FO-0004 4/15/2014 002-A 

Reassess existing supplemental measures and corrective actions, 

and enhance or develop new supplemental measures and 

corrective actions to ensure that they target the root causes of 

error identified in the improper payment studies.

0 

2014-FO-0004 4/15/2014 002-D 

Reassess existing supplemental measures and corrective actions, 

and enhance or develop new supplemental measures and 

corrective actions to ensure that they target the root causes of 

error identified in the improper payment studies.

0 

177 █

███ 177 177 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-FO-0004 4/15/2014 002-E 

Periodically reevaluate the supplemental measures and 

corrective actions so that new and innovative ways to reduce 

improper payments are identified and implemented.

0 

2014-FO-0004 4/15/2014 002-F 

Work with REAC to develop management-level reports in EIV 

that will allow Multifamily Housing management to efficiently 

and effectively identify processing entities that are responsible 

for improper payments and develop policies and procedures to 

hold owners/administrators identified accountable.

0 

2014-FO-0004 4/15/2014 002-G 

Work with PIH and Multifamily Housing management to 

develop management-level reports in EIV that will allow PIH 

and Multifamily Housing management to efficiently and 

effectively identify processing entities that are responsible for 

improper payments.

0 

2014-FO-0004 4/15/2014 002-H 

Work with PIH and Multifamily Housing to determine annual 

improper payments HUD made to deceased tenants, and report 

this amount as an additional source of improper payments in its 

AFR.

0 

2014-FW-0001 2/7/2014 001-K 

The housing agencies to work with their respective responsible 

entities and local HUD environmental officer to show that no 

harm occurred from completion of all of the projects or mitigate 

any harm that occurred.

0 

2014-FW-0002 5/12/2014 001-H 

The housing agencies to work with their respective responsible 

entities and local HUD environmental officer to show that no 

harm occurred from completion of all the projects or mitigate 

any harm that did occur.

0 

2014-FW-0005 9/24/2014 001-L 

The housing commissions to work with their respective 

responsible entities and local HUD environmental officer to 

show that no harm occurred from completion of all of the 

projects or mitigate any harm that occurred.

0 

2014-FW-1804 8/1/2014 001-K Support or repay from non-Federal funds $6,895 in unsupported 

pay increases. 0 

2014-KC-0002 7/2/2014 001-A 

Document the selection rules used for feeding data to CAIVRS 

to explain in detail the flow of information from HUD’s 

systems.

0 

2014-KC-0002 7/2/2014 001-C Develop and implement system error checks to identify potential 

reporting issues. 0 

2014-KC-0002 7/2/2014 002-A 

Update CAIVRS’ selection rules to report delinquent Federal 

debt beyond the 3-year claim period or obtain an exemption 

from the Secretary of the Treasury to exempt FHA loans after 3 

years.

0 

178 █

███ 178 178 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-LA-0004 6/30/2014 001-A 

Revise HUD’s asset management fee policy to re-federalize the 

Operating Fund program’s management and bookkeeping fees 

and the Capital Fund program’s management fees.

0 

2014-LA-0004 6/30/2014 001-C 

Establish and implement procedures to reassess the management 

and bookkeeping fees periodically to ensure that they are 

reasonable. HUD should retain the documentation justifying the 

calculation of the rates.

0 

2014-LA-0004 6/30/2014 001-H 

Develop, document, and implement written procedures to ensure 

that fees charged to the asset management projects and Capital 

Fund program and expenses from the central office cost center 

are used to support HUD’s mission.

0 

2014-LA-0005 8/8/2014 001-E 

Develop and implement post indemnification and billing policies 

and procedures to ensure that lenders are billed for loans that are 

part of the ACD and CWCOT programs.

0 

2014-LA-0005 8/8/2014 001-F 

Develop and implement post indemnification and billing policies 

and procedures to ensure that lenders are billed for loans that 

went into default during indemnification agreement period.

0 

2014-LA-0005 8/8/2014 001-G 

Develop and implement policies and procedures to ensure that it 

notifies the Financial Operations Center of any program changes 

that could impact the billing of FHA single-family lenders for 

losses related to enforceable indemnification agreements.

0 

2014-LA-1007 9/29/2014 001-B 

Review the rest of its active CDBG-funded projects in its 

portfolio managed by its former redevelopment agency to ensure 

that all required executed agreements are in place with the 

relevant parties, guaranteeing the City’s vested interest within 

one year of this report or take appropriate action against the City 

for those that did not have the applicable required agreements.

0 

2014-LA-1007 9/29/2014 001-C 

Review the rest of its active CDBG-funded projects in its 

portfolio that were managed by its former redevelopment agency 

to ensure that all projects meet a national objective. For those 

that did not meet program national objectives, provide and 

implement a plan of action to meet the specific national 

objective within one year of this report or reimburse HUD from 

non-Federal funds.

0 

2014-NY-0001 2/19/2014 001-B 

We recommend that the Director, Office of Multifamily Asset 

Management, require that each Hub or field office review its 

refinanced Section 202/223(f) projects for debt service savings 

amounts, utilizing data provided from this audit for possible 

additional debt service savings. Where legally possible each 

Hub or field office should identify, account for by project, and 

use these amounts for current and future opportunities benefiting 

tenants or to fund reductions in housing assistance payments.

0 

179 █

███ 179 179 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-NY-0001 2/19/2014 001-C 

We recommend that the Director, Office of Multifamily Asset 

Management, implement procedures to ensure that all future 

Section 202 refinancings comply with the requirement to 

generate positive debt service savings or the limited exception to 

this requirement related to 6 percent or lower interest rates.

0 

2014-NY-0003 9/4/2014 001-C 

We recommend that the Director of the Public Housing 

Financial Management Division ensure that the 2014 ARF 

funding calculation for the 10 PHAs includes the corrections 

needed as a result of this finding, thus ensuring that the ARF 

funding provided will represent funds to be put to better use.

0 

2014-NY-1004 5/20/2014 001-B 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct City officials to 

require the subrecipient to request a waiver related to the 

apparent conflict of interest and implement standards of conduct 

procedures that prohibit participation in the selection, award, or 

administration of a contract involving Federal funds if there is a 

real or apparent conflict of interest.

0 

2014-NY-1004 5/20/2014 001-E 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct City officials to 

establish controls to ensure that grant- and subgrant-supported 

activities are adequately monitored and administered to provide 

assurance that funds have been used only for eligible activities, 

costs incurred are necessary and reasonable, and national 

objectives have been attained.

0 

2014-NY-1004 5/20/2014 001-F 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct City officials to 

establish controls to ensure that CDBG funds are not used to pay 

for costs related to other funding sources or programs.

0 

2014-NY-1004 5/20/2014 001-H 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct City officials to 

establish procedures to ensure that the costs of administering the 

State-funded rehabilitation program are no longer charged to the 

CDBG program.

0 

2014-NY-1004 5/20/2014 001-I 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct City officials to 

Establish controls to ensure that assets are adequately 

safeguarded and duties are adequately segregated.

0 

2014-NY-1008 7/25/2014 001-B 

We recommend that the Director of HUD’s New York Office of 

Community Planning and Development instruct Palladia 

officials to strengthen oversight controls over disbursements to 

ensure that adequate supporting documentation is maintained 

and complies with applicable regulations.

0 

180 █

███ 180 180 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2014-NY-1008 7/25/2014 001-C 

We recommend that the Director of HUD’s New York Office of 

Community Planning and Development instruct Palladia 

officials to follow its policies and procedures for record-keeping 

to maintain records that adequately identify the source and 

application of funds provided for financially assisted activities.

0 

2014-NY-1008 7/25/2014 001-D 

We recommend that the Director of HUD’s New York Office of 

Community Planning and Development instruct Palladia 

officials to provide records detailing the funding sources of the 

non-Federal cash match for the six grant activities reviewed.

0 

2014-NY-1008 7/25/2014 001-F 

We recommend that the Director of HUD’s New York Office of 

Community Planning and Development instruct Palladia 

officials to reconcile its accounting records to ensure that total 

revenues and expenditures in its general ledgers reconcile to the 

revenues and expenditures reported in its annual performance 

reports and LOCCS.

0 

2014-NY-1009 9/18/2014 002-N 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to provide documentation to support compliance with HOME 

program rent limit and income eligibility requirements for the 

three tenants who occupy HOME-assisted units.

0 

2014-PH-1007 7/15/2014 001-D 

Based on the outcome of the State’s investigation and criminal 

trial, make a referral to HUD recommending administrative 

sanctions, as appropriate, up to and including debarment of the 

Authority’s former rehabilitation specialist, the Planning District 

Commission’s former deputy director, and the involved 

contractors.

0 

2015-AT-1001 12/5/2014 001-D 

Conduct monitoring of the Section 108 activities with signs of 

slow progress to ensure that program objectives are met and 

provide the intended benefits.

0 

2015-AT-1001 12/5/2014 002-B 

Ensure that borrowers did not use Section 108 funds to finance 

local government operations and verify the return of any 

ineligible disbursement.

0 

2015-AT-1001 12/5/2014 002-D 

Ensure that the borrowers either transfer the unexpended Section 

108 loan proceeds to the repayment account or submit a request 

for extension to HUD.

0 

2015-AT-1001 12/5/2014 002-E Ensure that the borrowers provide HUD the additional security 

requirements according to the loan agreement. 0 

2015-AT-1001 12/5/2014 002-F 

Ensure that borrowers develop and implement a financial 

management system in accordance with HUD requirements to 

ensure that program funds can be traced to a level that ensures 

that such funds have not been used in violation of the restrictions 

and prohibitions of applicable statutes.

0 

181 █

███ 181 181 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-AT-1001 12/5/2014 002-G 

Ensure that all Section 108 loan proceeds deposited at 

commercial banks are properly collateralized with Government 

obligations.

0 

2015-AT-1001 12/5/2014 002-H 

Conduct monitoring reviews of all Section 108 projects and 

ensure that borrowers comply with all loan agreement provisions 

and HUD regulations.

0 

2015-AT-1001 12/5/2014 002-I 

Increase monitoring of Municipal Affairs’ performance in the 

administration of its Section 108 loan program. Consider 

imposing sanctions if Municipal Affairs does not demonstrate 

program progress.

0 

2015-DP-0004 12/9/2014 001-B Not released to public. 0 

2015-DP-0004 12/9/2014 001-D Not released to public. 0 

2015-DP-0004 12/9/2014 001-E Not released to public. 0 

2015-FO-0002 12/8/2014 001-A 

Continue to work with CPD’s information technology services 

contractor and OCFO to ensure that all three phases of the plan 

to bring IDIS into compliance with GAAP and applicable 

Federal system requirements are completed as scheduled. 

0 

2015-FO-0002 12/8/2014 003-F Validate grants payable estimates and any assumptions used to 

produce the estimates against subsequent grantee reporting. 0 

2015-FO-0002 12/8/2014 003-G 

Incorporate into their grants payable accrual estimation 

methodologies steps to appropriately validate grant accrual 

estimates and assumptions used to produce the estimates against 

subsequent grantee reporting.

0 

2015-FO-0002 12/8/2014 005-E 

Work with OCFO to revise the funds control plans for the 

Section 8 project-based programs to ensure that the obligation 

process in place is sufficient to support a legally binding point of 

obligation and is reviewed and authorized by designated 

officials.

0 

2015-FO-0002 12/8/2014 007-D Periodically reconcile balances with OCIO subsidiary records 

and research and resolve any identified differences. 0 

2015-FO-0002 12/8/2014 007-F 

Increase efforts to quickly complete outstanding front-end risk 

assessments and coordinate with OCFO to finalize the review 

and approval process even in the absence of policies and 

procedures with specific deadlines in this area.

0 

2015-FO-0002 12/8/2014 007-I 

Develop a subsidiary system to accumulate the capitalized cost 

and related depreciation expense for each software project under 

development or placed into production.

0 

182 █

███ 182 182 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-FO-0003 11/18/2015 013-A 

Complete any outstanding validation reviews and transition back 

as much as $466.5 million in Housing Choice Voucher program 

funding from MTW PHAs and $41 million from non-MTW 

PHAs.

507,500,000

2016-FO-0002 11/16/2015 001-C 

Start the billing process for the claims paid, plus incentive, in 

which the lender has not provided the original note and security 

instrument within the prescribed deadlines for the $291 million.

291,489,605

2015-NY-1011 9/17/2015 003-A 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs direct State officials to provide documentation 

showing that the $127.2 million budgeted for inspection-related 

construction management and environmental review services is 

fair and reasonable in accordance with a cost or price analysis as 

required by regulations at 24 CFR 85.36.

127,200,000

2016-FO-0003 11/18/2015 008-A 

Close out and deobligate the remaining balances on 2,308 

expired homeless assistance contracts of $104,347,996. HUD 

should also deobligate $3,602,342 in 102 program obligations 

marked for deobligation during the departmentwide open 

obligations review. Lastly, HUD should review the 57 

obligations with remaining balances of $188,176 and close out 

and deobligate amounts tied to obligations that are no longer 

valid or needed.

108,138,514

2016-FO-0003 11/18/2015 008-F 

Review and if necessary deobligate the 228, 477, and 29 expired 

or inactive project-based Section 8, Section 235-236, and 

Section 202-811 projects totaling $52.5 million, $36.2 million, 

and $1.3 million, respectively.

90,000,000

2015-LA-0002 7/6/2015 001-A 

Develop and implement written policies and procedures with an 

emphasis on increased controls toward the monitoring, tracking, 

underwriting, and evaluating of the Section 184 program. 

Implementing these controls would reduce the current high level 

of risk in the program and result in potentially $76,967,618 in 

funds to be put to better use (see appendix A).

76,967,618

2015-NY-1011 9/17/2015 001-F 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs direct State officials to provide adequate 

documentation for the reasonableness of the cost figure used to 

disburse $55,672,982 for reconstruction costs. Any amount not 

adequately supported should be repaid to the State’s line of 

credit.

55,672,982

2015-NY-1011 9/17/2015 001-G 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs direct State officials to provide adequate 

documentation for the reasonableness of the cost figure used for 

reconstruction costs, thus ensuring that the undisbursed award 

balance of $31,831,316 is put to its intended use.

31,831,316

183 █

███ 183 183 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-FO-0003 11/18/2015 008-E 

Deobligate all obligations marked for deobligation during the 

department-wide open obligations review, including as much as 

$19,634,263 in 209 administrative obligations and $2,224,807 in 

24 program obligations marked for deobligation as of September 

30, 2015. Additionally, HUD should review the 225 obligations 

with remaining balances of $285,024 and close out and 

deobligate amounts tied to obligations that are no longer valid or 

needed.

22,144,094

2015-KC-1005 8/4/2015 001-A 

Refer Berkadia to the Mortgagee Review Board for appropriate 

action for violations that caused a more than $11 million loss to 

HUD’s FHA insurance fund.

11,312,956

2015-AT-1003 6/30/2015 001-A 

Refer Prudential to the Mortgagee Review Board to take 

appropriate action for violations that caused $10,159,961 in 

unnecessary or unreasonable cost to HUD’s FHA insurance fund 

or other administrative action as appropriate.

10,159,961

2016-AT-1002 12/17/2015 001-A 

Submit a plan for how it will proceed with respect to the 

multipurpose facility project, including a schedule that HUD can 

track to ensure its completion. HUD must reevaluate the 

feasibility of the activity and determine the eligibility of the 

$8,111,304 already invested. (Footnote 4: Total investments of 

$8,232,388 were adjusted to account for $109,084 questioned in 

recommendation 2A and $12,000 in recommendation 2B.) If 

HUD determines that the activity has been canceled or is not 

feasible, the Municipality must commit any unused loan 

proceeds for future loan repayments.

8,111,304

2015-BO-1003 3/4/2015 001-B 

Provide documentation to support that $4,235,773 in NSP funds 

was spent for eligible costs by obtaining documentation showing 

that the projects met a national objective, purchase price 

discounts were met, rehabilitation costs were reasonable and 

necessary, resale prices were in accordance with NSP 

requirements, rental amounts were affordable, and developers 

assumed risk by investing some of their own money in the 

project as applicable and if such support cannot be provided, 

repay the amount.

1 

2015-AT-0001 3/31/2015 001-B 

Provide support showing that it took proper remedial action 

regarding five NSP3 grantees that missed the expenditure 

deadline, thereby putting $3,379,269 to better use.

3,345,967

2015-LA-1004 5/29/2015 001-A Repay HUD $3,119,448 from non-Federal funds for program 

funds spent on ineligible participants. 3,119,448

2015-NY-1005 4/30/2015 002-A 

We recommend that the HUD Director of Community Planning 

and Development instruct City officials to reduce the City’s 

CHDO reserve balance reported in IDIS as of June 30, 2014, for 

the ineligible CHDO reserve of $2,229,445.

2,229,445

184 █

███ 184 184 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-NY-1011 9/17/2015 001-A 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs direct State officials to reimburse the line of 

credit for $2,229,234, which was disbursed to program 

recipients for ineligible costs. 

2,229,234

2016-FO-0003 11/18/2015 008-H 

Deobligate all obligations marked for deobligation during the 

department-wide open obligations review, including as much as 

$430,942 in 44 administrative obligations and $135,957 in 2 

program obligations marked for deobligation as of September 

30, 2015. Additionally, HUD should review the 17 obligations 

with remaining balances of $1,486,191 and close out and 

deobligate amounts tied to obligations that are no longer valid or 

needed.

2,053,090

2015-NY-1010 9/17/2015 002-C 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs instruct State officials to review the five 

properties with indications that they may be second homes and if 

they are, reimburse the State’s line of credit from non-Federal 

funds for the $1,664,658 disbursed for these purchases.

1,664,658

2015-FW-1002 6/26/2015 001-A 

We recommend that the Director of HUD’s New Orleans Office 

of Community Planning and Development require the City to 

support the cost reasonableness of the drainage cleaning contract 

and provide adequate support for payment of the contractor’s 

invoices or repay its grant any of the $1,611,143 that it cannot 

support. Repayment should be from non-Federal funds.

1,611,143

2016-FO-0003 11/18/2015 008-J 

Review the 216 obligations with remaining balances totaling 

$1,506,233 and close out and deobligate amounts tied to 

obligations that are no longer valid or needed.

1,506,233

2016-AT-1002 12/17/2015 001-B 

Submit a plan for how it will proceed with respect to the 

municipal cemetery project, including a schedule that HUD can 

track to ensure its completion. HUD must reevaluate the 

feasibility of the activity and determine the eligibility of the 

$1,454,801 already invested. If HUD determines that the 

activity has been canceled or is not feasible, the Municipality 

must commit any unused loan proceeds for future loan 

repayments.

1,454,801

2015-NY-1005 4/30/2015 002-B 

We recommend that the HUD Director of Community Planning 

and Development instruct City officials to provide 

documentation to support the additional CHDO reserve of 

$1,163,598 or reimburse the City’s HOME program line of 

credit from non-Federal funds.

1,163,598

185 █

███ 185 185 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-NY-1010 9/17/2015 003-E 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs instruct State officials to provide documentation 

that the selection of the appraiser in Staten Island was consistent 

with the other State agency’s contract provisions. If such 

documentation cannot be provided, the $1,093,290 budgeted 

should be deobligated, thus ensuring that the funds will be put to 

better use.

1,093,290

2015-NY-1011 9/17/2015 001-B 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs direct State officials to deobligate the 

undisbursed amount of $911,662 to ensure that the funds will be 

put to their intended use.

911,662

2015-LA-1004 5/29/2015 001-C 

Develop and implement written policies and procedures to 

ensure that participants are eligible for the program and comply 

with HUD rules and requirements. Also, the Authority should 

ensure that these policies and procedures include the monitoring 

of third-party organizations involved with the program so that 

$873,428 in program funds can be put to better use.

873,428

2015-NY-1005 4/30/2015 002-K 

We recommend that the HUD Director of Community Planning 

and Development instruct City officials to revise deed 

restrictions to correct effective affordability periods for the four 

properties that had not been completed or repay more than 

$850,008 from non-Federal funds to the City’s HOME program 

line of credit.

850,008

2015-NY-1005 4/30/2015 001-A 

We recommend that the HUD Director of Community Planning 

and Development instruct City officials to repay the $844,640 in 

HOME funds committed contrary to program regulations so that 

these funds can be recaptured in accordance with Federal 

regulations.

844,640

2015-NY-1006 5/22/2015 001-A 

We recommend that the Deputy Assistant Secretary for Single 

Family Housing instruct First Niagara Bank to provide HUD 

evidence that the lender's servicing practices for loans identified 

in Appendix D were acceptable for mortgages insured by HUD. 

In the event that HUD determines servicing practices were 

inadequate, First Niagara Bank should indemnify HUD for 

$825,133 in estimated losses for 10 loans. The estimated loss is 

based on the loss severity rate of 50 percent of the total unpaid 

principal balance of $1,650,266 as of December 31, 2014.

825,133

2015-CH-1008 9/25/2015 001-C 

Implement procedures and controls to ensure that (1) housing 

assistance payments are correctly calculated and paid and (2) 

required eligibility documentation is obtained and maintained to 

ensure that $820,881 ($753,728 in overpayments + $67,153 in 

underpayments) in program funds is appropriately used for 

future payments.

820,881

186 █

███ 186 186 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-PH-0003 7/29/2015 001-A 

Require the three agencies to justify $814,382 in unnecessary 

assistance payments made for the overhoused cases or either 

reduce future HUD funding or reduce the contract or budget 

authority for any funding increment by the applicable amounts 

that the agencies could not justify.

214,917

2015-CH-0001 7/31/2015 001-A 

We recommend that HUD’s Deputy Assistant Secretary for 

Single Family Housing require the lenders to support that the 

repairs to the properties associated with the 32 loans without 

evidence of permits complied with local code or reimburse HUD 

$792,837 for the escrow repair funds.

792,837

2016-CH-1001 11/24/2015 001-A 

Support or reimburse its program from non-Federal funds for the 

$686,701 in program funds drawn down for which it did not 

provide sufficient documentation to support that the funds were 

used for eligible project expenses.

686,701

2015-LA-1803 9/30/2015 001-B 

Repay $1,089,613 in ineligible costs for funds that were 

misrepresented in IDIS, funds that were drawn before a legally 

binding agreement was in place between the City and the 

developer, and did not produce a project (Filbert Phase 2).

632,063

2015-FW-1002 6/26/2015 001-B 

We recommend that the Director of HUD’s New Orleans Office 

of Community Planning and Development require the City to 

support the reasonableness of the cost increases for the 

demolition contract or repay $616,529 to its grant from nonFederal funds.

616,529

2016-FO-0003 11/18/2015 008-O 

Deobligate the $587,198 in eight administrative obligations 

marked for deobligation during the departmentwide open 

obligations review.

587,198

2015-AT-1004 7/2/2015 001-A 

Submit all supporting documentation showing the eligibility and 

propriety of $538,485 drawn from its treasury account or 

reimburse the HOPWA program line of credit from non-Federal 

funds.

538,485

2015-NY-1005 4/30/2015 002-J 

We recommend that the HUD Director of Community Planning 

and Development instruct City officials to impose deed 

restrictions or other mechanisms approved by HUD on the four 

properties assisted with HOME funds to enforce affordability 

requirements or repay $527,116 from non-Federal funds to the 

City’s HOME program line of credit.

527,116

2015-PH-1001 1/30/2015 001-C 

Provide documentation to support its use of $519,284 in 

program funds for activities 1760 and 1816 or reimburse its 

program from non-Federal funds for any amount that it cannot 

support.

519,284

187 █

███ 187 187 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-PH-1805 4/20/2015 001-A 

Provide documentation to support the $503,744 in unsupported 

payments identified by the review or reimburse the applicable 

programs from non-Federal funds for any costs that it cannot 

support.

503,744

2015-CH-1009 9/30/2015 001-A 

Support or reimburse its program from non-Federal funds 

$1,211,842 (more than $652,000 disbursed to Chicago 

Neighborhood Initiatives, Inc. + $1 million disbursed to the City 

of Belleville + nearly $60,000 for the Association’s two 

contracts - $500,000) for the program funds used for the three 

projects without sufficient documentation to support that the use 

of the funds met Federal requirements.

500,000

2015-DE-1802 9/30/2015 001-A 

Ensure that HUD records the $500,000 settlement due in its 

accounting records, including the $11,000 paid at the time of 

settlement, to recognize funds due as a return of an ineligible 

cost.

479,000

2015-PH-1003 6/4/2015 001-D 

Determine whether the documentation the State provided is 

adequate to support the $467,659 disbursed for wages and 

salaries charged to the program by contractors’ employees and if 

not, direct the State to repay HUD from non-Federal funds any 

amount that it cannot support.

467,659

2015-LA-1002 4/16/2015 001-B Support or repay the payroll allocation, estimated at $457,357, to 

its SHP grants for 2013. 457,357

2015-AT-1005 7/9/2015 001-C 

Provide adequate support or reimburse the U.S. Treasury from 

non-Federal funds for procurement activities from the 2008 

grant totaling $457,327 (Footnote 4). The actual amount 

unsupported was $460,397. To avoid double counting, the 

amount was reduced by $3,070, which is accounted for in the 

eligibility section.

457,327

2015-AT-1005 7/9/2015 001-D 

Provide adequate support or repay the program from nonFederal funds for procurement activities from the 2011 grant 

totaling $416,914.

416,914

2015-CF-1807 9/28/2015 001-A 

Ensure that HUD records the $465,981 settlement due and the 

$50,000 payment received at settlement to recognize funds due 

as return of an ineligible cost.

415,981

2015-CH-1004 9/9/2015 001-C 

We recommend that the Director of HUD’s Cleveland Office of 

Public and Indian Housing require the Authority to support or 

reimburse its program $414,781 ($375,336 + $7,273 in housing 

assistance payments + $32,172 in associated administrative fees) 

from non-Federal funds for the unsupported payments of 

housing assistance cited in this finding.

414,781

188 █

███ 188 188 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-CH-1008 9/25/2015 001-I 

1Support or reimburse its program $411,382 from non-Federal 

funds ($395,299 + $2,418 in housing assistance payments + 

$13,665 in associated administrative fees for the missing 

eligibility documentation) for the missing eligibility 

documentation and unsupported housing assistance payments.

411,382

2015-LA-1005 7/9/2015 001-E 

Reimburse FHA borrowers $376,102 for the unallowable, 

misrepresented discount fees and $7,110 for fees that were not 

customary or reasonable.

383,212

2015-NY-1005 4/30/2015 002-E 

We recommend that the HUD Director of Community Planning 

and Development instruct City officials to provide 

documentation to support the income eligibility of the five home 

buyers assisted with HOME funds and if documentation cannot 

be provided, reimburse the City’s HOME program line of credit 

$379,494 from non-Federal funds.

379,494

2015-NY-1005 4/30/2015 002-C 

We recommend that the HUD Director of Community Planning 

and Development instruct City officials to reimburse the City’s 

HOME program line of credit $344,776 from non-Federal funds 

for HOME assistance spent on housing units acquired by five 

ineligible home buyers.

344,776

2015-NY-1005 4/30/2015 001-C 

We recommend that the HUD Director of Community Planning 

and Development instruct City officials to reimburse the City’s 

HOME program line of credit $344,341 from non-Federal funds 

for assistance provided in excess of HOME subsidy limits.

344,341

2015-LA-1802 9/24/2015 001-C Support or repay the program for grant funds of $340,581 that 

were drawn without being reviewed by HUD. 340,581

2015-FW-1002 6/26/2015 001-C 

We recommend that the Director of HUD’s New Orleans Office 

of Community Planning and Development require the City to 

support the reasonableness of the cost increases for the grant 

management contract or repay $328,737 to its grant from nonFederal funds.

328,737

2015-CH-0001 7/31/2015 001-B 

We recommend that HUD’s Deputy Assistant Secretary for 

Single Family Housing require the lenders to support that the 

repairs to the properties associated with the six loans were not 

structural repairs or indemnify HUD for the four active loans 

with a total estimated loss of $222,073 and reimburse HUD for 

the actual loss of $83,322 incurred on the sale of two properties 

associated with FHA case numbers 052-4308836 and 034-

8239100.

305,395

2015-BO-1003 3/4/2015 001-E 

Provide documentation to support $265,572 in unsupported 

administrative expenses. Any expenses determined not to be 

properly supported should be considered ineligible and 

reimbursed. .

265,572

189 █

███ 189 189 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-FO-0003 11/18/2015 008-K 

Deobligate $140,165 in 41 administrative and $125,166 in 3 

program obligations marked for deobligation during the 

department-wide open obligations review.

265,331

2015-FW-1806 6/11/2015 001-B 

We recommend that the Director of the San Antonio Office of 

Public Housing require the Authority to support payroll costs 

totaling $372,832 or repay its Housing Choice Voucher program 

fund $321,684 and public housing program fund $51,148 from 

non-Federal funds.

256,204

2015-CH-1009 9/30/2015 001-C 

Reimburse its program from non-Federal funds $250,000 for the 

program funds that the City of Belleville inappropriately forgave 

the Wagner Motor Car Company from repaying.

250,000

2015-CH-1006 9/11/2015 001-C 

Indemnify HUD $191,074 for two loans that were still active 

and did not receive proper loss mitigation (FHA case numbers 

151-6263199 and 151-9226347) and one loan (FHA case 

number 156-0374114) in which the borrower’s revised payment 

was incorrect (50 percent loss severity rate applied to the unpaid 

balance of $382,147). 

191,074

2015-LA-1001 1/30/2015 001-B 

Provide adequate supporting documentation for the $183,642 in 

unsupported operating expenses and lease costs or repay the 

HOPWA program from non-Federal funds.

183,642

2015-NY-1005 4/30/2015 002-D 

We recommend that the HUD Director of Community Planning 

and Development instruct City officials to reimburse City’s 

HOME program line of credit $163,516 from non-Federal funds 

for the two ineligible homeowners who owned other real 

properties.

163,516

2015-AT-1005 7/9/2015 001-A 

Reimburse the U.S. Treasury from non-Federal funds $151,699 

from the 2008 grant for ineligible procurement activities using 

the expired environmental contract.

151,699

2015-AT-1004 7/2/2015 001-B 

Submit all supporting documentation showing the eligibility and 

propriety of $143,320 in HOPWA expenditures or reimburse the 

HOPWA program line of credit from non-Federal funds.

143,320

2016-AT-1002 12/17/2015 002-A 

Reimburse $139,767 to its loan guarantee account from nonFederal funds for ineligible disbursements that were not related 

to the approved projects.

139,767

2015-LA-1004 5/29/2015 001-B 

Provide supporting documentation for $136,346 in program 

funds used for participants for whom eligibility could not be 

determined or repay HUD from non-Federal funds (see appendix 

D).

136,346

190 █

███ 190 190 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-FW-1806 6/11/2015 001-C

We recommend that the Director of the San Antonio Office of 

Public Housing require the Authority to support purchases 

totaling $195,080 or repay its Housing Choice Voucher program 

fund $123,791 and public housing program fund $71,289 from 

non-Federal funds.

135,839

2015-NY-1005 4/30/2015 001-G

We recommend that the HUD Director of Community Planning 

and Development instruct City officials to provide 

documentation to support that $125,810 in costs charged to the 

three unsupported HOME activities was for eligible costs, and if 

such documentation cannot be provided, reimburse the City’s 

HOME program line of credit from non-Federal funds.

125,810

2015-NY-1011 9/17/2015 001-D

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs direct State officials to provide adequate 

documentation to support $119,124 in CDBG-DR funds that was 

disbursed to three recipients. If any amount cannot be 

adequately supported, it should be repaid to the State’s line of 

credit.

119,124

2016-FW-1801 10/2/2015 001-C

We recommend that the Director, Office of Public Housing, San 

Antonio, TX, require the Authority to repay from non-Federal 

funds unreasonable contractor costs of $119,000 to its HUD 

low-rent program account.

119,000

2015-NY-1005 4/30/2015 001-E

We recommend that the HUD Director of Community Planning 

and Development instruct City officials to reimburse the City’s 

HOME line of credit for $113,849 that was drawn down in 

excess of need so that these funds can be put to better use.

113,849

2015-AT-1011 9/30/2015 001-C

Reimburse its program from non-Federal funds for the 

overpayment of any housing assistance for approval of rent 

increases on program units contrary to its requirements.

100,340

2015-BO-1003 3/4/2015 001-D Repay $100,250 in NSP funds that were spent for ineligible 

administrative expenses. 100,250

2015-CH-0001 7/31/2015 001-E

Support that the required repairs to the property associated with 

FHA case numbers 241-9513470 and 277-1438986 were 

sufficiently addressed and complied with local codes or 

indemnify HUD for the estimated loss of $97,355, based on the 

loss severity rate of 50 percent of the unpaid balance of 

$194,709 as of January 29, 2015.

97,355

2015-NY-1005 4/30/2015 002-H

We recommend that the HUD Director of Community Planning 

and Development instruct City officials to reimburse the City’s 

HOME program line of credit $95,781 from non-Federal funds 

for funds spent on the development of two housing properties 

that were later terminated from the program.

95,781

191 █

███ 191 191 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-CH-1001 11/24/2015 001-B Reimburse HUD from non-Federal funds for the $87,651 in 

program funds used for improper operating expenses. 87,651

2015-NY-1010 9/17/2015 002-E 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs instruct State officials to provide documentation 

to support that the $85,309 disbursed for four applicants was 

calculated correctly. If adequate support cannot be provided, the 

amount should be repaid to the State’s line of credit from nonFederal funds.

85,309

2015-CH-0001 7/31/2015 001-C 

We recommend that HUD’s Deputy Assistant Secretary for 

Single Family Housing require the lenders to support that the 

borrower for FHA case number 451-1165810 was not 

reimbursed for the cost of labor or indemnify the loan with an 

estimated loss amount of $83,715, based on the loss severity rate 

of 50 percent of the unpaid principal balance of $167,429 as of 

January 29, 2015.

83,715

2015-LA-1001 1/30/2015 001-A 

Provide adequate supporting documentation for the $82,563 in 

unsupported salary costs or repay the HOPWA program from 

non-Federal funds.

82,563

2015-CH-1008 9/25/2015 001-A 

Reimburse its program $79,884 from non-Federal funds 

($45,093 in housing assistance overpayments + $15,816 due to 

inappropriate voucher size + $605 in overpaid utility allowances 

+ $18,370 in associated administrative fees) for the 

inappropriate payments cited in this finding.

79,884

2015-FW-1807 8/14/2015 001-B 

We recommend that the Director, Office of Public Housing, 

Little Rock, require the Authority to support or repay its public 

housing program $611,338 from non-Federal funds for 

improperly procured contracts. However, if the Authority made 

any of the expenditures from its capital fund grants that have not 

been validated within 2 years, or if the Authority is unable to 

determine the source of funds used to pay expenditures, the 

Authority should repay HUD.

78,293

2016-FO-0003 11/18/2015 008-L 

Review the 20 obligations with remaining balances of $77,807 

and close out and deobligate amounts tied to obligations that are 

no longer valid or needed.

77,807

2015-LA-1003 4/24/2015 001-C 

Provide supporting documentation for the $77,200 in 

unsupported administrative and management costs or repay its 

project from non-project funds for any costs that remain 

unsupported.

77,200

2015-PH-1804 2/19/2015 001-A 

Allow the HUD Office of Inspector General to post the civil 

penalty of $75,000 in HUD’s Audit Resolution and Corrective 

Action Tracking System as funds put to better use.

75,000

192 █

███ 192 192 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-LA-1002 4/16/2015 001-A Support or repay $73,451 in unsupported costs to the program 

from non-Federal funds. 73,451

2015-LA-1009 9/30/2015 001-E 

Reimburse FHA borrowers $25,700 for fees that were not 

customary or reasonable and $46,510 in discount fees that did 

not represent their intended purpose.

72,210

2015-CH-1006 9/11/2015 001-B 

Support or reimburse HUD $71,827 for the loss incurred or 

incentive claim paid on two loans (FHA case numbers 151-

8081634 and 151-9161593) that lacked support of appropriate 

loss mitigation decisions.

71,827

2015-KC-1001 3/5/2015 002-A 

Require Breakthrough Living to repay the $69,577 that it 

collected from its Section 8 tenants. For any tenant who left the 

Section 8 program and cannot be located, HUD should require 

Breakthrough Living to send his or her refund to the Kansas 

State treasurer so the treasurer can get the refund to the tenant or 

a family member.

69,577

2015-CH-1006 9/11/2015 001-D 

Support or indemnify HUD $67,660 for the two active loans 

(FHA case numbers151-9161593 and 263-4317828) that lacked 

evidence that loss mitigation was properly implemented (50 

percent loss severity rate applied to the unpaid principal balance 

of $135,318).

67,660

2015-NY-1005 4/30/2015 002-F 

We recommend that the HUD Director of Community Planning 

and Development instruct City officials to provide 

documentation to support the income eligibility of the two 

homeowners who received home-ownership assistance and if 

documentation cannot be provided, reimburse the City’s HOME 

program line of credit $55,941 from non-Federal funds.

55,941

2015-LA-1802 9/24/2015 001-A Support or repay $49,307 in unsupported costs to the program 

from non-Federal funds. 49,307

2015-KC-1001 3/5/2015 001-A 

Require Breakthrough Living to repay from non-Federal sources 

the unpaid balance of $47,690 that it transferred from its reserve 

for replacement account to its operating account and 

management agent.

47,690

2015-AT-1005 7/9/2015 001-B 

Repay the program $45,740 from non-Federal funds from the 

2011 grant for ineligible procurement activities using the expired 

environmental contract.

45,740

2015-CH-0001 7/31/2015 001-D 

Support that the repair conditions and comments indicated in the 

direct endorsement underwriter form, form HUD-54114, were 

satisfied for FHA case number 501-8198149. If the repair 

conditions and comments were not properly addressed, the 

lenders should indemnify the loan with an estimated loss amount 

of $39,367, based on the loss severity rate of 50 percent of the 

unpaid principal balance of $78,733 as of January 29, 2015.

39,367

193 █

███ 193 193 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-LA-1003 4/24/2015 001-H 

Provide supporting documentation showing the payment of the 

unremitted rents from its sponsor for deposit into the project’s 

bank account totaling $37,138 or repay its project from 

nonproject funds.

37,138

2015-LA-1008 9/22/2015 001-A 

Provide supporting documentation for the $36,000 in 

unsupported accounting journal entries and correct inaccurate 

information related to these entries in its general ledger.

36,000

2015-AT-1011 9/30/2015 001-A 

Support or reimburse its program $34,414 from non-Federal 

funds for the unsupported payment of housing assistance due to 

missing eligibility documentation (Footnote: $25,590 + $6,223 

in housing assistance payments + $2,275 + $326 in associated 

administrative fees). 

34,414

2015-KC-1007 8/20/2015 001-A 

Reprocure its executive director services using the appropriate 

policies and procedures to ensure properly procured services 

going forward and use the quotes from that procurement to 

justify the $34,226 spent for executive director services from 

August 2011 through December 2014. For any amount the 

Authority cannot support, HUD should reduce future annual 

operating funds.

34,226

2015-AT-1012 9/30/2015 001-B 

Provide support that $33,473 paid for procurements was 

reasonable or reimburse the appropriate projects for the balance 

from non-project funds.

33,473

2015-LA-1003 4/24/2015 001-D 

Provide supporting documentation for the $31,637 in 

unsupported income deposit entries and correct any inaccurate 

information related to the income deposits in its general ledger.

31,637

2015-AT-1012 9/30/2015 001-A 

Provide documentation to support $27,646 was spent on eligible 

purposes or reimburse the appropriate projects for the balance 

from non-project funds.

27,646

2015-LA-1003 4/24/2015 001-F Require its sponsor to immediately repay the ineligible loans 

totaling $25,300 from nonproject funds. 25,300

2015-KC-1008 9/1/2015 001-A 

Reprocure its executive director services using the appropriate 

policies and procedures to ensure properly procured services 

going forward and use the quotes from that procurement to 

justify the $24,600 spent for executive director services from 

August 2011 through December 2014. For any amount the 

Authority cannot support, HUD should reduce future annual 

operating funds.

24,600

2015-CH-1008 9/25/2015 002-A Reimburse HUD $24,088 from non-Federal funds for the Family 

Self-Sufficiency grant funds inappropriately received. 24,088

194 █

███ 194 194 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-FW-1807 8/14/2015 001-F 

We recommend that the Director, Office of Public Housing, 

Little Rock, require the Authority to support or repay its 

programs, as appropriate, $23,621 from non-Federal funds for 

unsupported leave balance payments to the former executive 

director. However, if the Authority made any of the 

expenditures from its capital fund grants that have not been 

validated within 2 years, or if the Authority is unable to 

determine the source of funds used to pay expenditures, the 

Authority should repay HUD.

23,621

2015-FW-1004 8/17/2015 001-C 

We recommend that HUD require the Authority to provide 

support for or reimburse the $21,426 in unsupported payments 

to its program. Payment must be from non-Federal funds.

21,426

2015-KC-1006 8/20/2015 001-C 

Reprocure its fee accounting services using the appropriate 

policies and procedures to ensure properly procured services 

going forward and to use the quotes from that procurement to 

justify the $12,873 spent from the Public Housing Operating 

Fund program and the $8,375 spent from the Housing Choice 

Voucher program funds for fee accounting services from 

October 2011 through December 2014. The Authority should 

repay any unsupported portion to the appropriate program fund 

from non-Federal funds.

21,248

2016-FW-1801 10/2/2015 001-B 

We recommend that the Director, Office of Public Housing, San 

Antonio, TX, require the Authority to repay from non-Federal 

funds ineligible contractor costs of $19,880 to its HUD low-rent 

($18,900) and Housing Choice Voucher ($980) program 

accounts.

19,880

2015-LA-1008 9/22/2015 001-D 

Obtain written approval from HUD for the $17,674 in 

unsupported rental credits or repay its project from nonproject 

funds for rental credits that remain unsupported.

17,674

2015-KC-1008 9/1/2015 001-D 

Justify the three awards given to contractors when only one bid 

was received totaling $17,626. For any amount the Authority 

cannot support, HUD should reduce future annual capital funds.

17,626

2015-CH-1008 9/25/2015 001-E 

Pursue collection from the applicable households or reimburse 

its program $16,648 from non-Federal funds for the 

overpayment of housing assistance due to unreported income.

16,648

2015-LA-1002 4/16/2015 003-A Repay the applicable clients the overcharged program fees, 

which combined totaled $15,435 (see appendix E). 15,435

2015-AT-1011 9/30/2015 001-B 

Reimburse its program $15,151 from non-Federal funds for the 

deficiencies cited in the finding (Footnote: $672 + $10,228 + 

$537 + $2,152 in housing assistance payments + $574 + $503 + 

$140 + $345 in associated administrative fees). 

15,151

195 █

███ 195 195 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-LA-1010 9/30/2015 001-E Reimburse $13,726 to FHA borrowers for the fees that were not 

customary or reasonable. 13,726

2015-LA-1003 4/24/2015 001-E

Provide supporting documentation for the $13,418 in 

unsupported general costs or repay its project from nonproject 

funds for any costs that remain unsupported.

13,418

2015-CF-1804 3/27/2015 001-A

Agree to allow HUD OIG to record the $15,000 settlement in 

HUD’s Audit Resolution and Corrective Actions Tracking 

System as an ineligible cost.

13,000

2015-CH-0001 7/31/2015 002-A

Reimburse or apply $10,552 in credit to borrowers’ future 

premiums for the 54 active loans with overpaid premiums and 

refund $2,024 to the borrowers of the 7 terminated loans.

12,576

2015-AT-1004 7/2/2015 001-C

Reimburse $12,447 to the HOPWA program line of credit from 

non-Federal funds for ineligible disbursements that were not 

related to the program.

12,447

2015-FW-1805 4/10/2015 001-C

We recommend that the Director, Office of Public Housing, Fort 

Worth, TX, require the Authority to support or repay $11,875 in 

unsupported salary costs.

11,775

2015-FW-1805 4/10/2015 001-D

We recommend that the Director, Office of Public Housing, Fort 

Worth, TX, require the Authority to repay its low-rent public 

housing program $11,256 from non-Federal funds for ineligible 

contract labor payments.

11,256

2015-LA-1802 9/24/2015 001-D

Support or repay the June 2015 drawdown of $11,198, which 

Veterans First was advised to use for its Susan Street past-due 

rent.

11,198

2015-KC-1006 8/20/2015 002-C

Provide adequate support for the $9,632 not reviewed to show 

that funds were spent for eligible items or repay the affected 

program from non-Federal funds.

9,632

2015-KC-1006 8/20/2015 002-D

Repay the Housing Choice Voucher program for the $9,214 

spent for Housing Quality Standards voucher inspections from 

non-Federal funds.

9,214

2015-FW-1805 4/10/2015 001-E

We recommend that the Director, Office of Public Housing, Fort 

Worth, TX, require the Authority to repay its low-rent public 

housing program $9,072 for ineligible USDA program 

administrative expenses.

9,072

196 █

███ 196 196 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-FW-1807 8/14/2015 001-E 

We recommend that the Director, Office of Public Housing, 

Little Rock, require the Authority to repay its public housing 

program $11,651 from non-Federal funds for ineligible 

expenditures. However, if the Authority made any of the 

expenditures from its capital fund grants that have not been 

validated within 2 years, or if the Authority is unable to 

determine the source of funds used to pay expenditures, the 

Authority should repay HUD.

8,803

2015-LA-1802 9/24/2015 001-B Repay $8,083 in ineligible costs to the program from nonFederal funds. 8,083

2015-KC-1001 3/5/2015 001-B 

Require Breakthrough Living to repay from non-Federal sources 

the $5,642 that it used to pay for its management agent’s 

overhead expenses.

5,642

2015-KC-1007 8/20/2015 001-B 

Reprocure its fee accounting services using the appropriate 

policies and procedures to ensure properly procured services 

going forward and use the quotes from that procurement to 

justify the $4,507 spent for fee accounting services from August 

2011 through December 2014. For any amount the Authority 

cannot support, HUD should reduce future annual operating 

funds.

4,507

2015-LA-1008 9/22/2015 001-C 

Provide supporting documentation for the $4,000 unsupported 

loan deposit entry and correct inaccurate information related to 

the deposit in its general ledger.

4,000

2015-KC-1008 9/1/2015 001-B 

Reprocure its fee accounting services using the appropriate 

policies and procedures to ensure properly procured services 

going forward and use the quotes from that procurement to 

justify the $3,991 spent for fee accounting services from August 

2011 through December 2014. For any amount the Authority 

cannot support, HUD should reduce future annual operating 

funds.

3,991

2015-LA-1002 4/16/2015 001-C Repay $3,245 in ineligible costs to the program from nonFederal funds. 3,245

2015-CH-1008 9/25/2015 001-B 

Reimburse the appropriate households $6,330 ($4,292 in 

housing assistance underpayments + $1,488 due to inappropriate 

voucher size + $550 in utility allowance underpayments from 

program funds for the inappropriate underpayments cited in this 

finding.

3,173

2015-KC-1007 8/20/2015 002-A 

Collect from its executive director services provider and repay 

its Capital Fund program the $3,000 that it improperly paid the 

provider from its capital funds.

3,000

197 █

███ 197 197 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-CH-1008 9/25/2015 001-H 

Pursue collection from the applicable landlords or reimburse its 

program $2,900 from non-Federal funds for the overpayment of 

housing assistance due to discrepancies in the housing assistance 

payment register.

2,900

2015-KC-1007 8/20/2015 001-C 

Justify the $2,400 spent for the 2012 annual agency plan and 

2014 5-year and annual agency plan. For any amount the 

Authority cannot support, HUD should reduce future annual 

operating funds.

2,400

2015-KC-1006 8/20/2015 002-A 

Repay the affected programs the $2,148 spent for meals, social 

activities, donations, gifts, and floral arrangements from nonFederal funds.

2,148

2015-FW-1004 8/17/2015 001-A 

We recommend that HUD require the Authority to repay its 

Housing Choice Voucher program $2,139 in incorrect housing 

assistance. Payment must be from non-Federal funds.

2,139

2015-LA-1008 9/22/2015 001-B 

Provide supporting documentation for the $14,873 in 

unsupported disbursements that included a $200 loan to an 

employee, or repay its project from nonproject funds for costs 

that remain unsupported.

1,985

2015-KC-1008 9/1/2015 001-C 

Justify the $1,200 spent for the 2014 5-year and annual agency 

plan. For any amount the Authority cannot support, HUD 

should reduce future annual operating funds.

1,200

2015-LA-1003 4/24/2015 001-G Repay to its project $889 from nonproject funds for incurred 

ineligible expenses. 889

2015-KC-1010 9/30/2015 002-B 

Require the Authority to provide adequate support that it spent 

$47,057 on allowable expense. Any amount determined to be 

ineligible should be repaid from non-Federal funds to its 

program or to HUD as the field office deems appropriate based 

on the funding source.

736

2015-KC-1009 9/30/2015 002-B 

Require the Authority to provide adequate support that it spent 

$31,147 on allowable expenses. Any amount determined to be 

ineligible should be repaid from non-Federal funds to its 

program or to HUD as the field office deems appropriate based 

on the funding source.

519

2015-LA-1003 4/24/2015 001-I 

Provide supporting documentation for the $450 balance in its 

general ledger account related to security deposits, ensure that 

the required security deposit bank account is established and 

funded to the required amount in accordance with HUD rules 

and requirements, and correct any inaccurate information related 

to security deposits in its general ledger.

450

198 █

███ 198 198 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-KC-1011 9/30/2015 002-B 

Require the Authority to provide adequate support that it spent 

$27,600 on allowable expense. Any amount determined to be 

ineligible should be repaid from non-Federal funds to its 

program or to HUD as the field office deems appropriate based 

on the funding source.

435

2015-FW-1004 8/17/2015 001-D 

We recommend that HUD require the Authority to provide 

support or repay its program $53 for the unexplained payments. 

Payment must be from non-Federal funds.

53

2015-KC-1006 8/20/2015 002-B Provide adequate support for the $53 spent at the grocery store 

or repay the affected program from non-Federal funds. 53

2015-FW-1004 8/17/2015 001-B 

We recommend that HUD require the Authority to reimburse 

$22 to the family that was overcharged. Reimbursement should 

be from the Authority’s reserves.

22

2015-AT-1008 8/23/2015 001-B 

Develop, implement, and enforce procedures to comply with 

rent reasonableness requirements to prevent an estimated 

$195,975 in excess rents from being charged to the program.

0 

2015-CH-0801 6/25/2015 001-A 

We recommend that the Director of HUD's Office of Affordable 

Housing Programs implement adequate procedures and controls 

to ensure that leases between rental housing projects' owners and 

households for Program-funded units do not include language 

prohibited by HUD's regulations.

0 

2015-CH-1001 2/24/2015 001-B 

We recommend that the Deputy Assistant Secretary for Public 

Housing Investments require the Authority to conduct special 

recertifications for the households with payment standards above 

the percentage determined to be reasonable and cost effective so 

that their payment standards can be reduced within one year.

0 

2015-CH-1001 2/24/2015 001-C 

We recommend that the Deputy Assistant Secretary for Public 

Housing Investments require the Authority to reimburse its 

program from non-Federal funds for the excess housing 

assistance paid for the households based on the results of the 

analysis.

0 

2015-DE-1001 5/26/2015 003-C 

Implement a procedure for checking all contractors in the 

System for Award Management before awarding any contract 

and all subcontractors before distributing Federal funds, such as 

requiring subrecipients to submit a copy of the System for 

Award Management results for each contractor and 

subcontractor seeking payment with each draw request to ensure 

that they are verified before receiving Federal funds.

0 

199 █

███ 199 199 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-FO-0003 2/27/2015 001-A 

Establish and implement policies and procedures to demonstrate 

how Ginnie Mae provides appropriate accounting and financial 

reporting oversight of the master-subservicers to ensure that the 

master-subservicers are capable of producing accurate and 

reliable accounting records and reports.

0 

2015-FO-0003 2/27/2015 001-B 

Establish and implement policies and procedures to properly 

account for and track at a loan level all of the accounting 

transactions and events in the life cycle of the loans. This 

measure is intended to compensate for the servicing system’s 

inability to perform loan level transaction accounting.

0 

2015-FO-0003 2/27/2015 002-A 

Establish and implement policies and procedures to ensure that 

reimbursable costs are tracked and accounted for at the loan 

level.

0 

2015-FO-0003 2/27/2015 002-B 

Determine the amount of reimbursable costs incurred by Ginnie 

Mae per loan, report the reimbursable costs incurred as 

receivables rather than expensing them, and adjust them out of 

the mortgage-backed securities loss liability account as 

appropriate.

0 

2015-FO-0003 2/27/2015 002-C 

Restate fiscal year 2013 financial statements to correct the 

impact of the accounting errors determined in recommendation 

2B.

0 

2015-FO-0003 2/27/2015 002-D 

Review and recalculate the appropriate amount of interest 

accrued on the loans and adjust the accrued interest receivable 

balances reported as appropriate.

0 

2015-FO-0003 2/27/2015 002-E 

Report the escrow fund balances on the face of the financial 

statements, including additional disclosure information in the 

notes, in accordance with generally accepted accounting 

principles.

0 

2015-FO-0003 2/27/2015 002-F Restate fiscal year 2013 financial statements to show escrow 

fund balances omitted on the face of the financial statements. 0 

2015-FO-0003 2/27/2015 003-A 

Establish and implement policies and procedures for the 

documentation and validation of Ginnie Mae management 

assumptions, including foreclosure costs and redefault rates, 

used in the loss reserve model going forward.

0 

2015-FO-0003 2/27/2015 004-B 

Work with HUD’s Chief Financial Officer to design and 

implement a compliant financial management governance 

structure.

0 

2015-FO-0003 2/27/2015 004-D Overseeing a comprehensive risk assessment of Ginnie Mae’s 

financial management governance. 0 

200 █

███ 200 200 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-FO-0003 2/27/2015 004-E 

Preparing and implementing a plan, based on the results of the 

risk assessment in recommendation 4D, that 

i) Demonstrates HUD OCFO oversight of Ginnie Mae’s, as a 

HUD component, financial management activities; 

ii) Ensures that Ginnie Mae updates its financial management 

policies to reflect conclusions reached in the financial 

management risk assessment; iii) Provides complete, reliable, 

consistent and timely information for defaulted issuers’ pooled 

and non-pooled loans, prepared on a uniform basis for 

preparation of Ginnie Mae financial statements, management 

reporting, and cost reporting; and iv) Ensures all of Ginnie 

Mae’s financial management systems, both owned and 

outsourced, provide the financial information necessary to 

prepare and support financial statements that comply with 

generally accepted accounting principles.

0 

2015-FO-0005 5/15/2015 003-C 

Reassess the susceptibility of significant improper payments for 

the CPD entitlement, non-entitlement, HOME Investment 

Partnerships Program, and other formula grant programs based 

on the results of audit report 2014-FO-0003 as well as the 

community service and self-sufficiency requirement in public 

housing subsidiaries identified in OIG audit report 2015-KC0001.

0 

2015-FO-0005 5/15/2015 004-A 

For HUD’s high priority programs, high priority programs are 

those identified by OMB as the programs with the most 

egregious cases of improper payments. HUD’s RHAP was 

identified as high-priority by OMB. HUD should reevaluate the 

types of errors previously identified to determine whether new 

causes of errors exist that would lead to significant improper 

payments and require reporting in accordance with the improper 

payments categories outlined in OMB Circular A-123, appendix 

C, for fiscal years 2015 and beyond.

0 

2015-FW-0001 6/16/2015 001-A 

We recommend that the Deputy Secretary of the U.S. 

Department of Housing and Urban Development ensure that 

HUD follows and complies with 24 CFR Part 50, Protection and 

Enhancement of Environmental Quality, and provides adequate 

oversight to ensure compliance with 24 CFR Part 58, 

Environmental Review Procedures for Entities Assuming HUD 

Environmental Responsibilities.

0 

2015-FW-0001 6/16/2015 001-C 

We recommend that the Deputy Secretary of the U.S. 

Department of Housing and Urban Development clarify the 

delegation of authority issued in the Federal Register related to 

environmental responsibility and the implementation of 

requirements.

0 

201 █

███ 201 201 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-FW-0001 6/16/2015 001-D 

If an independent program office is not established, the Deputy 

Secretary should ensure that the Assistant Secretaries for 

Housing, Public and Indian Housing, and Community Planning 

and Development establish an agreement that clearly outlines 

each program office’s responsibilities for oversight of 

environmental requirements and resource supplements.

0 

2015-FW-0001 6/16/2015 001-E 

If an independent program office is not established, the Deputy 

Secretary should ensure that the Assistant Secretaries for 

Housing, Public and Indian Housing, and Community Planning 

and Development adopt a quality control monitoring program 

that includes a review of all program area field offices as 

required by Executive Order 11514.

0 

2015-FW-0001 6/16/2015 001-F 

If an independent program office is not established, the Deputy 

Secretary should ensure that the Assistant Secretaries for 

Housing, Public and Indian Housing, and Community Planning 

and Development develop and implement a monitoring program 

that all program area field offices can use to monitor grantees 

and responsible entities under 24 CFR Part 58.

0 

2015-FW-0001 6/16/2015 001-G 

If an independent program office is not established, the Deputy 

Secretary should ensure that the Assistant Secretaries for 

Housing, Public and Indian Housing, and Community Planning 

and Development develop training programs that meet the needs 

of all program areas, including 24 CFR Parts 50 and 58.

0 

2015-FW-0001 6/16/2015 001-H 

If an independent program office is not established, the Deputy 

Secretary should ensure that the Assistant Secretaries for 

Housing, Public and Indian Housing, and Community Planning 

and Development develop and implement reporting 

requirements, which ensure that written records are maintained 

and the appropriate headquarters personnel are notified of 

environmental concerns.

0 

2015-FW-0001 6/16/2015 001-I 

If an independent program office is not established, the Deputy 

Secretary should ensure that the Assistant Secretaries for 

Housing, Public and Indian Housing, and Community Planning 

and Development ensure that each program area has a dedicated 

program environmental clearance officer with an official job 

description that outlines his or her roles and responsibilities as 

required by 24 CFR Part 50.

0 

2015-FW-1806 6/11/2015 001-F 

We recommend that the Director of the San Antonio Office of 

Public Housing require the Authority to determine the amount of 

Federal and State taxes it owes for payments made to its 

contractors and pay those tax liabilities.

0 

202 █

███ 202 202 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-FW-1806 6/11/2015 001-G

We recommend that the Director of the San Antonio Office of 

Public Housing require the Authority to review its contracts with 

the contractors and their outside employment and take necessary 

action to either properly treat them as contractors or reclassify 

them as employees.

0 

2015-LA-1003 4/24/2015 001-L Ensure that the membership of its board of directors complies 

with its by-laws by consisting of seven members. 0 

2015-LA-1003 4/24/2015 001-M

Obtain HUD training and technical assistance for its project 

administrator, management company, and board of directors to 

ensure compliance with HUD rules and requirements that pertain 

to the management and operation of its project.

0 

2015-NY-1005 4/30/2015 002-M

We recommend that the HUD Director of Community Planning 

and Development instruct City officials to correct the reported 

completion status and home-buyer information recorded in IDIS 

for the three HOME activities for which incorrect information 

was recorded.

0 

2015-PH-1001 1/30/2015 001-F

Evaluate the apparent conflict-of-interest situation identified in 

this report, determine whether a conflict of interest existed, and 

pursue administrative sanctions if warranted.

0 

2015-AT-0002 8/21/2015 001-A

Comply with its Management Agent Handbook requirements 

that stipulate HUD must perform management reviews of the 

management agent’s central office activities as well as regular 

onsite reviews of functions carried out at the projects. These 

central office reviews should be performed at least once every 

18 months.

0 

2015-AT-1008 8/23/2015 001-D

Develop, implement, and enforce detailed procedures for County 

staff to detect double billing and prevent duplicate payments of 

grant funds.

0 

2015-AT-1008 8/23/2015 002-B

Develop, implement, and enforce detailed procedures for staff 

and project sponsors to ensure that they comply with HUD’s 

match requirements. Procedures and accompanying guidance 

should include (1) tracking the cash or in-kind match amounts 

monthly or consistently to ensure that the match amount 

reported in its APR to HUD is accurate and supported by the 

documentation provided by the project sponsors, (2) providing 

to project sponsors a list of the types of documentation that may 

be sufficient to ensure the eligibility of the use and source of the 

match funds, and (3) reviewing the documentation from project 

sponsors to ensure that the sources of the funds used to match 

the grant funds are eligible and sufficiently supported to comply 

with 24 CFR 578.73.

0 

203 █

███ 203 203 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-AT-1009 9/3/2015 001-F

Pursue administrative actions, as appropriate, against the 

responsible parties for the regulatory agreement violations cited 

in this report.

0 

2015-AT-1009 9/3/2015 001-G

Determine legal sufficiency and if legally sufficient, pursue 

remedies under the Program Fraud Civil Remedies Act against 

the hospital’s former chief financial officer for incorrectly 

certifying to the accuracy of the financial information submitted 

to obtain the Section 242 program mortgage increase.

0 

2015-AT-1011 9/30/2015 001-C

Reimburse its program from non-Federal funds for the 

overpayment of any housing assistance for approval of rent 

increases on program units contrary to its requirements.

100,340

2015-CH-0001 7/31/2015 002-B

Determine the overpaid mortgage insurance premium for the 69 

active loans after September 2014 for the life of the loans, and 

reimburse or apply the overpayments as credits to borrowers’ 

future premium payments.

0 

2015-CH-0001 7/31/2015 002-C

Determine the number of 203(k) loans impacted by the incorrect 

loan-to-value ratio for mortgage insurance premium calculations 

and when applicable, reimburse borrowers or apply the overpaid 

premiums as credits toward borrowers’ future premium 

payments.

0 

2015-CH-0802 8/26/2015 001-A

Implement adequate policies and procedures to ensure that the 

activities included in Authority’s plans are (1) allowable under 

the Moving to Work statutory purposes, (2) described in 

sufficient detail to convey anticipated impacts (including 

financial impact), and (3) in accordance with the terms and 

authorizations set forth in the Moving to Work agreements.

0 

2015-CH-1008 9/25/2015 001-G

Renegotiate the rents to the owners or require the households to 

move to units that are affordable, for the households residing in 

units that are not affordable.

0 

2015-CH-1008 9/25/2015 001-J

Develop and implement adequate quality control procedures to 

ensure that it (1) correctly calculates and pays housing assistance 

and (2) obtains and maintains the required eligibility 

documentation.

0 

2015-CH-1008 9/25/2015 002-B

Implement adequate procedures and controls to ensure that (1) 

program participants are connected to needed supportive 

services, (2) services included in the participants’ contracts of 

participation are provided, (3) and participants’ escrow accounts 

are properly maintained.

0 

2015-CH-1009 9/30/2015 001-D

Implement adequate controls to ensure that the Department 

administers the program in accordance with Federal 

requirements.

0 

204 █

███ 204 204 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-CH-1010 9/30/2015 001-B

Provide sufficient documentation to support that HUD had 

received 50 percent of the proceeds from initial membership 

sales as of June 2015. If the Cooperative cannot do this, it 

should pay HUD half of the principal on the Cooperative notes 

for all memberships less the amount the Cooperative paid HUD 

for initial membership sales.

0 

2015-FW-0802 9/16/2015 001-C

We recommend that the Deputy Assistant Secretary, Office of 

Public Housing and Voucher Programs, Require that housing 

agencies provide HUD with a signed acknowledgement by 

executive directors and board chairpersons when they are hired 

or appointed. The acknowledgement should detail their 

awareness and understanding of their responsibilities, and their 

acceptance that failure to comply with requirements could result 

in administrative or other actions.

0 

2015-FW-1808 9/10/2015 001-L

We recommend that the Director of the Departmental 

Enforcement Center Consider administrative sanctions against 

the former executive director and board for the gross 

mismanagement and poor physical condition of the Authority’s 

property.

0 

2015-KC-0002 8/11/2015 001-A Issue guidance to help participating jurisdictions accurately 

report the amount of match contributed and consumed. 0 

2015-KC-0002 8/11/2015 001-B

Include monitoring of HOME match during its performance 

reviews to ensure that match contributions exist, are eligible, and 

are supported.

0 

2015-KC-0002 8/11/2015 001-C

Require the 10 jurisdictions that overstated their excess match 

balances to remove the overstated amounts from their reported 

HOME match carry-forward balances.

0 

2015-KC-1009 9/30/2015 001-C

Monitor the Authority’s expenditures after training to ensure that 

the executive director understands and correctly applies 

procurement requirements.

0 

2015-KC-1009 9/30/2015 002-C

Require the Authority to obtain appropriate training on eligible 

uses of program funds, including items that can be charged to 

tenant services, travel expenses, and hiring practices.

0 

2015-KC-1009 9/30/2015 003-J

Monitor the Authority after the recommended training and 

tenant file reviews are complete to ensure the executive director 

understands and properly implements public housing occupancy 

requirements.

0 

2015-KC-1009 9/30/2015 005-B

Require the Authority’s executive director to obtain appropriate 

training regarding inventory and record keeping requirements to 

supplement the training recommended in the other findings.

0 

205 █

███ 205 205 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-KC-1009 9/30/2015 005-C Monitor the Authority to ensure that it implements appropriate 

records management systems. 0 

2015-KC-1009 9/30/2015 005-D

Determine whether Authority management is able to properly 

implement HUD requirements and consider remedies that may 

be required to address any noncompliance with the annual 

contributions contract.

0 

2015-KC-1010 9/30/2015 001-C

Monitor the Authority’s expenditures after training to ensure that 

the executive director understands and correctly applies 

procurement requirements.

0 

2015-KC-1010 9/30/2015 002-C

Require the Authority to obtain appropriate training on eligible 

uses of program funds, including items that can be charged to 

tenant services, travel expenses, and hiring practices.

0 

2015-KC-1010 9/30/2015 003-J

Monitor the Authority after the recommended training and 

tenant file reviews are complete to ensure the executive director 

understands and properly implements public housing occupancy 

requirements.

0 

2015-KC-1010 9/30/2015 005-B

Require the Authority’s executive director to obtain appropriate 

training regarding inventory and record-keeping requirements to 

supplement the training recommended in the other findings.

0 

2015-KC-1010 9/30/2015 005-C Monitor the Authority to ensure that it implements appropriate 

records management systems. 0 

2015-KC-1010 9/30/2015 005-D

Determine whether Authority management is able to properly 

implement HUD requirements and consider remedies that may 

be required to address any noncompliance with the annual 

contributions contract.

0 

2015-KC-1011 9/30/2015 001-C

Monitor the Authority’s expenditures after training to ensure that 

the executive director understands and correctly applies 

procurement requirements.

0 

2015-KC-1011 9/30/2015 002-C

Require the Authority to obtain appropriate training on eligible 

uses of program funds, including items that can be charged to 

tenant services, travel expenses, and hiring practices.

0 

2015-KC-1011 9/30/2015 003-I

Monitor the Authority after the recommended training and 

tenant file reviews are complete to ensure the executive director 

understands and properly implements public housing occupancy 

requirements.

0 

2015-KC-1011 9/30/2015 005-B

Require the Authority’s executive director to obtain appropriate 

training regarding inventory and record-keeping requirements to 

supplement the training recommended in the other findings.

0 

2015-KC-1011 9/30/2015 005-C Monitor the Authority to ensure that it implements appropriate 

records management systems. 0 

206 █

███ 206 206 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-KC-1011 9/30/2015 005-D

Determine whether Authority management is able to properly 

implement HUD requirements and consider remedies that may 

be required to address any noncompliance with the annual 

contributions contract.

0 

2015-KC-1012 9/30/2015 001-A Require LoanCare to repay any additional costs associated with 

the violations noted. 0 

2015-LA-1008 9/22/2015 001-E

Develop and implement written policies and procedures to 

ensure that project funds are used solely for reasonable operating 

expenses or necessary repairs unless it receives prior written 

approval from HUD and uses surplus cash.

0 

2015-LA-1008 9/22/2015 001-F

Obtain written approval from HUD for its management agent 

and execute a management agreement that defines the 

management agent’s roles and responsibilities as required by 

HUD rules and requirements.

0 

2015-LA-1008 9/22/2015 001-G Develop and implement written policies and procedures to 

address the financial operations of the project. 0 

2015-LA-1008 9/22/2015 001-H Submit to HUD all outstanding financial statements. 0 

2015-LA-1008 9/22/2015 001-I

Obtain HUD training and technical assistance for itself and its 

identity-of-interest management agent to ensure compliance with 

HUD rules and requirements that pertain to the management and 

operation of its project.

0 

2015-LA-1802 9/24/2015 001-F

Pursue civil remedies or administrative sanctions against 

Veterans First and responsible parties for the misuse of HUD 

funds.

0 

2015-NY-1010 9/17/2015 002-F

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs instruct State officials to strengthen controls to 

ensure that buyout awards are calculated in accordance with 

Federal regulations.

0 

2015-NY-1011 9/17/2015 001-C

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs direct State officials to strengthen controls over 

determining the eligibility of award recipients and substantiate 

award calculations to ensure that costs charged to the CDBG-DR 

program are eligible.

0 

2015-NY-1011 9/17/2015 001-E

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs direct State officials to strengthen controls over 

the maintenance of documentation to provide greater assurance 

that disbursed funds are adequately supported.

0 

207 █

███ 207 207 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2015-NY-1011 9/17/2015 001-H 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs direct State officials to document the amount 

paid for the flawed studies used to support the $160-per-squarefoot cost figure and take action to recoup the amount paid, thus 

ensuring that this amount will be available for other eligible 

costs.

0 

2015-NY-1011 9/17/2015 002-C 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs direct the State to properly document the lowand moderate-income status of the two homeowners whose 

status was improperly reported.

0 

2015-NY-1011 9/17/2015 002-G 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs direct the State to strengthen controls to ensure 

that all required contracts and amounts are accurately reported 

on its Web site.

0 

2015-NY-1012 9/30/2015 001-A 

We recommend that the Director of HUD’s Office of Residential 

Care Facilities instruct Morris Park officials to establish and 

implement procedures to ensure that distributions are made to 

the owner only if the project complies with all requirements in 

the regulatory agreement, to include compliance with notices of 

physical inspection deficiencies.

0 

2015-NY-1012 9/30/2015 001-B 

We recommend that the Director of HUD’s Office of Residential 

Care Facilities instruct Morris Park officials to establish and 

implement written accounting procedures to ensure that books 

and records are maintained in accordance with HUD 

requirements.

0 

2015-NY-1012 9/30/2015 001-C 

We recommend that the Director of HUD’s Office of Residential 

Care Facilities instruct Morris Park officials to ensure that 

accounting records are reconciled monthly.

0 

2015-NY-1012 9/30/2015 001-D 

We recommend that the Director of HUD’s Office of Residential 

Care Facilities instruct Morris Park officials to implement 

procedures to ensure that audited financial statements are 

prepared and submitted to HUD in a timely manner in 

accordance with the regulatory agreement.

0 

2016-AT-1002 12/17/2015 002-C 

Provide supporting documentation showing that it complied with 

all environmental requirements. If the Municipality does not 

provide evidence that it complied with all environmental 

requirements, HUD must initiate appropriate sanctions under 24 

CFR 58.77(d)(1)(v) for noncompliance.

0 

2016-AT-1002 12/17/2015 002-D Either transfer the unexpended Section 108 loan proceeds to the 

repayment account or submit a request for extension to HUD. 0 

2016-AT-1002 12/17/2015 002-E Provide HUD the additional security requirements according to 

the loan agreement. 0 

208 █

███ 208 208 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-AT-1002 12/17/2015 002-F 

Develop and implement a financial management system in 

accordance with HUD requirements to ensure that program 

funds can be traced to a level, which ensures that such funds 

have not been used in violation of the restrictions and 

prohibitions of applicable statutes. 

0 

2016-AT-1002 12/17/2015 002-G 

Ensure that all Section 108 loan proceeds deposited at 

commercial banks are properly collateralized with Government 

obligations.

0 

2016-AT-1002 12/17/2015 002-H 

Provide training, technical assistance, and increase monitoring 

of the Municipality’s performance in the administration of its 

Section 108 loan program.

0 

2016-AT-1801 12/16/2015 001-A 

Enforce HUD’s requirements for the owners and operator to 

immediately obtain and maintain liability and property insurance 

on the project.

0 

2016-DP-0002 12/21/2015 001-B Not released to public. 0 

2016-DP-0002 12/21/2015 001-C Not released to public. 0 

2016-DP-0801 11/30/2015 001-A Not released to public. 0 

2016-DP-0801 11/30/2015 001-B Not released to public. 0 

2016-DP-0801 11/30/2015 001-C Not released to public. 0 

2016-DP-0801 11/30/2015 001-D Not released to public. 0 

2016-DP-0801 11/30/2015 001-E Not released to public. 0 

2016-DP-0801 11/30/2015 001-F Not released to public. 0 

2016-DP-0801 11/30/2015 001-G Not released to public. 0 

2016-FO-0001 11/13/2015 002-A 

Prepare an analysis of all outstanding REMIC deals to determine 

the cumulative effect of misstatements and make the appropriate 

adjustments to the financial statements.

0 

2016-FO-0001 11/13/2015 002-B 

Update the accounting policies and procedures related to 

revenue recognition to reasonably ensure compliance with 

GAAP.

0 

2016-FO-0001 11/13/2015 002-C 

Establish and implement policies and procedures to ensure that 

asset balances in Ginnie Mae’s books are appropriately adjusted 

to account for the timing differences in the collection and 

remittance of cash from its master sub-servicers

0 

209 █

███ 209 209 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-FO-0001 11/13/2015 004-A 

Ensure that the systems and processes for servicing and financial 

reporting on Ginnie Mae’s defaulted issuers’ portfolio are ready 

and capable of handling loan level accounting.

0 

2016-FO-0001 11/13/2015 004-B 

Establish and implement entity wide policies and procedures for 

an effective model risk management. At a minimum, it should 

include the following elements: Controls over model 

development, implementation and use;

Controls over model validation; Controls over model 

documentation;Controls over evaluation for fitness, selection 

and validation of third-party models; andEstablish adequate 

structure of responsibilities for model oversight, including 

evaluation of model data inputs, assumptions and methodology

0 

2016-FO-0001 11/13/2015 005-A 

Segregate duties between individuals collecting, recording, 

depositing, and reconciling cash, and periodically review the 

controls over the cash process to ensure proper implementation 

of compatible functions in its cash operations department.

0 

2016-FO-0001 11/13/2015 005-C 

Automate the approval process to include restricting the ability 

to make unauthorized changes unless evidence of approval is 

present or increase the scope of the “Admin Adjustments 

Report” to include all exceptions and adjustments. Additionally, 

the contractor should review the report for changes, verify that 

the changes identified in the report coincide with evidence of 

proper authorization, and ensure changes that are not properly 

supported are investigated and resolved accordingly.

0 

2016-FO-0001 11/13/2015 006-A 

Request a legal opinion from the implementing agency, the U.S. 

Treasury, for a determination of whether Ginnie Mae is required 

to comply with DCIA.

0 

2016-FO-0003 11/18/2015 002-D 

Establish a process to track the amount HUD owes to PHAs to 

cover prepayment shortages and provide the information to 

OCFO so that it can be properly recognized as accounts payable.

0 

2016-FO-0003 11/18/2015 004-B Promptly complete all reconciliation processes to determine the 

root causes of incorrect balances. 0 

2016-FO-0003 11/18/2015 004-C 

Based on root causes identified, make necessary adjustments to 

the system configurations in GFAS to ensure proper and 

accurate budgetary resource reporting that complies with 

FFMIA and OMB A-11.

0 

2016-FO-0003 11/18/2015 004-D Review user roles in GFAS and assign additional staff to ensure 

that proper segregation of duties is maintained. 0 

2016-FO-0003 11/18/2015 006-A 

Evaluate the weaknesses identified by NAPA, as well as 

OCFO’s disagreement with those weaknesses and 

recommendations, and identify what corrective actions will be 

taken and when those actions will be taken.

0 

210 █

███ 210 210 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-FO-0003 11/18/2015 006-B 

Develop a process to ensure that issues and recommendations 

from all evaluations and audits, including those performed by 

third parties like NAPA, are adequately documented and tracked 

and properly evaluated by senior management to ensure that 

HUD’s FMFIA structure remains compliant. HUD should also 

ensure that corrective actions are agreed upon and responsibility 

for implementing corrective actions is appropriately delegated.

0 

2016-FO-0003 11/18/2015 006-C 

Develop procedures to provide oversight of OCPO procurement 

activities to ensure that those with financial accounting and 

reporting impact are properly captured and reflected in HUD’s 

financial statements.

0 

2016-FO-0003 11/18/2015 006-D 

Review projects and acquisitions to determine whether the 

proper accounting treatment was applied and determine whether 

corrections to HUD’s financial statements are needed.

0 

2016-FO-0003 11/18/2015 006-E 

Contact all other HUD program offices to determine whether 

any other programs authorize or are aware of grantees holding 

funds in advance of their immediate disbursement needs and 

determine financial statement impact on and compliance with 

Treasury cash management requirements of any found.

0 

2016-FO-0003 11/18/2015 006-F 

Distribute the workload among available accountants when staff 

is unavailable to ensure that all cash reconciliations are 

performed in a timely manner.

0 

2016-FO-0003 11/18/2015 006-G 

Ensure that standard operating procedures for IGT activity are 

updated, to include reconciling IGT balances for all transactions 

required by the Federal Intragovernmental Transactions 

Accounting Policies Guide included in the Treasury Financial 

Manual 2-4700. HUD should also include procedures to 

promptly reconcile, research, and resolve differences identified 

in the Treasury quarterly scorecard.

0 

2016-FO-0003 11/18/2015 006-H 

Provide training on IGT reporting to ensure that responsible staff 

is sufficiently trained to allow reconciliations to be promptly 

performed and differences identified to be identified, researched, 

and resolved in a timely manner.

0 

2016-FO-0003 11/18/2015 006-I 

Ensure that the agency’s key IGT point of contact is responsible 

for overseeing and coordinating efforts with component entities 

to ensure that Treasury quarterly scorecard differences are 

promptly researched and resolved.

0 

2016-FO-0003 11/18/2015 006-J 

Revise policies and procedures to ensure that MCRs are 

routinely monitored and completed for all program areas and 

establish a timeframe for completion of the MCR reports. 

Further, HUD should ensure that an escalation process is 

included to address untimely completion of the MCR process.

0 

211 █

███ 211 211 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-FO-0003 11/18/2015 007-A 

Develop policies and procedures to ensure that any data changes 

and accounting adjustments processed by OCFO Systems staff 

that impact the general ledger are sufficiently documented, 

identifying a description of the event, the preparers of the 

adjustment, the approving officials of the adjustment, and dates 

when adjustments occurred.

0 

2016-FO-0003 11/18/2015 008-C 

Develop and implement a monitoring plan to review outstanding 

disaster grant activity to ensure that the expenditure rates are 

consistently tracked and evaluated and that there are specific 

criteria to identify slow-moving projects. The procedures should 

include a process to follow up and recommend corrective actions 

for the slow-moving projects identified, to include recapturing 

funds if necessary.

0 

2016-FO-0003 11/18/2015 008-D 

Design and implement a policy to ensure that reconciliations of 

expenditure activity between HUD’s financial management 

systems and DRGR are periodically performed for all active 

disaster grant balances to ensure that expenditure activity is 

accurate in DRGR. The policy should also include procedures 

for follow-up and resolution of identified differences.

0 

2016-PH-0005 9/29/2016 001-A 

Perform a detailed review of the procurement procedures for 

each of the State grantees that received funds under the Disaster 

Relief Act. If the State did not demonstrate that its procedures 

incorporated the specific procurement standards included in 24 

CFR 85.36(b) through (i) or that its procedures were equivalent 

to each individual procurement provision of 24 CFR 85.36(b) 

through (i), HUD should (1) require the grantee to update its 

procedures and provide an updated certification and (2) review 

the updated grantee certification to confirm that the State meets 

requirements and has a proficient procurement process in place, 

thereby putting up to $4,872,056,594 to better use. In cases in 

which HUD has not yet awarded all of the allocated funds to the 

State, HUD should complete these steps before it executes any 

additional grant agreements with the State.

4,872,056,594

2017-KC-0001 10/14/2016 001-A 

Issue a change to regulations at 24 CFR Part 203, which would 

avoid unnecessary costs to the FHA insurance fund, allowing an 

estimated $2.23 billion to be put to better use. These changes 

include (1) a maximum period for filing insurance claims and (2) 

disallowance of expenses incurred beyond established 

timeframes.

2,238,721,464

212 █

███ 212 212 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-CH-0001 2/26/2016 001-D 

Implement adequate procedures and controls to ensure that 

public housing agencies maintain valid declarations of trust that 

are recorded in public records to prevent more than $509 million 

in annual operating subsidy funds from being provided to 

projects in which HUD’s interests and investments are not 

protected. Such procedures and controls should include but not 

be limited to (1) issuing additional guidance regarding 

declarations of trust to assist HUD’s field office staff, public 

housing agencies, and independent auditors in clarifying HUD’s 

requirements and appropriately evaluating the declarations of 

trust and (2) amending the A-133 Compliance Supplement to

require auditors to review an entire project at a time and include 

steps for determining whether all property of the project is 

included on declarations of trust and whether the declarations of 

trust were properly recorded in public records.

509,000,000

2017-FO-0002 11/14/2016 002-D Ensure that the $276.5 million identified as invalid obligations 

in fiscal years 2015 and 2016 are deobligated as appropriate. 276,567,940

2017-FO-0001 11/14/2016 002-F 

Reverse the accounting write-off of the advances accounts. In 

conjunction with the subledger data solution, conduct a proper 

analysis to determine whether any of the $248 million balances 

in the advances accounts are collectible.

248,016,624

2017-FO-0003 11/15/2016 008-A 

Close out and deobligate the remaining balances on 3,121 

expired homeless assistance contracts of $151,719,152. Further, 

deobligate $10,996,784 in 234 program obligations marked for 

deobligation during the departmentwide open obligations 

review.

162,715,936

2017-FO-0003 11/15/2016 012-A 

Complete any outstanding validation reviews and transition back 

as much as $168.3 million in Housing Choice Voucher program 

funding from PHAs.

150,100,000

2017-FO-0003 11/15/2016 008-Q 

Record the deobligations provided by OCPO totaling as much as 

$86.4 million for the contracts identified during our review. 

Additionally, Ginnie Mae should deobligate the $587,505 in 

three administrative obligations marked for deobligation during 

the departmentwide open obligations review.

86,987,505

2016-FW-1010 9/30/2016 001-A 

We recommend that the Acting Deputy Assistant Secretary for 

Grant Programs require the State to develop and implement 

policies and procedures to document and perform detailed 

review and testing to establish eligibility, existence, disaster 

event qualifications, reasonableness of cost estimates, 

prioritization, and fund allocation, both retroactively and 

prospectively, which would put $81,982,712 to better use.

81,982,712

2016-CF-1801 9/8/2016 001-A Acknowledge that the attached settlement agreement for $70 

million represents an amount due HUD. 59,000,000

213 █

███ 213 213 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-FO-0002 11/14/2016 003-C 

Request payment in the amount of the claims paid, plus 

incentive, from mortgagees that have not provided the original 

note within the prescribed deadline for the $55.3 million.

55,350,830

2016-CF-1806 9/19/2016 001-A Acknowledge that $76 million of the $113 million in the 

attached settlement agreement represents an amount due HUD. 50,000,000

2016-KC-0002 9/21/2016 001-B 

Establish a process for requiring removal of pooled loans that 

remain uninsured at the maximum time to put $49.3 million to 

better use.

49,300,000

2017-FO-0003 11/15/2016 008-G 

Review and if necessary deobligate the 785 expired or inactive 

Section 235-236, Section 202-811, and Project Based Section 8 

projects totaling $22,075,052, $12,261,389, and $384,125, 

respectively.

34,720,566

2016-NY-1009 8/12/2016 001-A 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs direct State officials to provide documentation 

showing that the approximately $22 million disbursed for the 

identified procurements complied with the applicable 

procurement requirement at 24 CFR 85.36(f) and repay any 

amounts determined to be unsupported from non-Federal funds.

21,958,549

2017-FO-0003 11/15/2016 008-F 

Deobligate all obligations marked for deobligation during the 

departmentwide open obligations review, including as much as 

$18,290,686 in 307 administrative obligations and $3,420,032 in 

202 program obligations marked for deobligation as of 

September 30, 2016.

21,710,718

2016-KC-0001 8/17/2016 001-A 

Require the contractor to complete the necessary debt collection 

efforts for $21,526,130 in uncollected partial claims associated 

with FHA mortgages terminated during fiscal year 2015.

21,526,130

2017-NY-1004 12/21/2016 001-A 

We recommend that HUD’s Acting Deputy Assistant Secretary 

for Grant Programs instruct City officials to reimburse the 

Program from non-Federal funds $18,274,054 in exempt State 

sales tax on repairs and maintenance services.

18,274,054

2017-FO-0003 11/15/2016 008-B 

Review the status of the remaining balances on 1,356 expired 

ESG contracts totaling $17,986,109 and determine whether these 

balances should be recaptured.

17,986,109

214 █

███ 214 214 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-CH-1009 9/30/2016 001-V 

Make a preliminary determination as to whether the 

Condominium Association is in default of the grant agreement. 

If it is preliminarily determined that the Condominium 

Association is in default, HUD should provide the 

Condominium Association notice of the determination and 

propose corrective or remedial actions to address the default and 

prevent the Condominium Association from the possible 

repayment of the remaining $13,878,088 in program funds, 

which HUD disbursed for the project ($14,156,600 in program 

funds disbursed for the project – $278,512 in proceeds from 

initial unit sales the Condominium Association remitted to 

HUD).

13,878,088

2017-BO-1001 10/12/2016 001-A 

Support that the $13,333,151 awarded for the architect, engineer, 

and construction management services contracts was fair and 

reasonable in accordance Federal procurement requirements or 

repay to HUD from non-Federal funds any amounts not 

supported.

13,333,151

2016-FW-1010 9/30/2016 001-B 

We recommend that the Acting Deputy Assistant Secretary for 

Grant Programs require the State to support or properly obligate 

$11,717,288 in unsupported obligations.

11,717,288

2016-NY-1007 3/30/2016 001-A 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to reimburse the City’s CDBG local bank account for the 

$11,532,769 in uncollected program income generated from the 

disposition of real property previously assisted with CDBG 

funds, thus ensuring that these funds can be used for eligible 

activities.

11,532,769

2016-LA-1009 8/26/2016 001-A 

Support that the Hibiscus Hill Apartments acquisition was 

necessary and served the purpose intended and support that the 

premium paid for the acquisition over the market value was 

reasonable and that HUD received an adequate value, or repay 

its CDBG program line of credit $10,000,000 from non-Federal 

funds.

10,000,000

2016-NY-0001 9/12/2016 001-D 

We recommend that the Director of the Public Housing 

Financial Management Division obtain adequate supporting 

documentation of the utility expense level amounts and verify 

the computation of $8,993,484 in operating funds is accurate or 

recapture ineligible amounts.

8,993,484

2016-PH-1008 9/29/2016 001-E 

Develop and implement procedures and controls to ensure that 

program units meet housing quality standards, thereby ensuring 

that an estimated $7,576,867 in program funds is spent for units 

that are decent, safe, and sanitary.

7,576,867

215 █

███ 215 215 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-PH-0003 7/29/2016 001-C 

Direct the applicable lenders to provide evidence that the 

properties for the 99 FHA-insured loans, which closed after 

October 1, 2015, but were not included in our sample, had a safe 

and potable water source at the time the loans closed and were 

endorsed, or, if the lenders cannot provide this evidence, direct 

them to perform water testing and any necessary remediation to 

ensure that the properties have a safe and potable water source, 

or indemnify HUD against any future loss, thereby putting up to 

$7,514,800 to better use.

7,514,800

2017-FO-0003 11/15/2016 008-E 

Research grants with no drawdown activity and if a bonafide 

need no longer exists, close out and deobligate remaining 

balances on the 16 grants with no drawdown activity totaling 

$6,966,585.

6,966,585

2016-NY-1003 2/5/2016 001-E 

We recommend that the Director of HUD’s Buffalo Office of

Community Planning and Development instruct City officials to 

provide documentation in the loan file that HUD approved the 

withdrawal of funds after the required deadline, and provide an 

explanation and obtain approval for the untimely disbursement 

of the $6,724,820 after it had been drawn down. Any costs 

determined to be inadequately supported should be reimbursed 

from non-Federal funds.

6,724,820

2016-LA-1008 8/26/2016 001-D 

Provide adequate documentation to support HUD approval for 

the $6,340,504 loan between Dolores Frances and Pico Union 

and how the funds were used or remove the loan and any 

associated encumbrance from the project.

6,340,504

2016-CH-1005 8/3/2016 001-C 

Work with HUD to develop a plan to ensure that energy savings 

are realized to prevent a potential default on the $5,869,770 

energy conservation loan used to purchase energy conservation 

equipment attached to the Authority’s public housing properties.

5,869,770

2016-BO-1002 6/27/2016 001-E 

Provide adequate support that $5,573,214 ($866,235 in Capital 

Fund program and $4,706,979 in American Recovery and 

Reinvestment Act funds) was spent for eligible costs. Any 

amounts that cannot be supported should be repaid to the 

program from non-Federal funds.

5,573,214

216 █

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SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-FW-1006 8/31/2016 001-A 

We recommend that the Director of HUD’s Office of Block 

Grant Assistance require the State to develop and implement 

written procedures and actions that would correct and prevent 

the deficiencies outlined in the finding to ensure that the Parish 

adequately supports program participant eligibility. The written 

procedures and actions should include but not be limited to (1) 

reviewing and amending the Parish’s program policies, 

documentation checklist, and income calculation worksheet to 

ensure the consistency of file documentation and eligibility 

determinations; (2) providing training and assistance to the 

Parish and its contractors regarding program participant 

eligibility determinations and documentation requirements; and 

(3) conducting a final file review before disbursing funds on 

behalf of program participants to ensure that files have complete 

documentation, appropriate follow-ups are conducted, and the 

participant remains eligible for disaster assistance. 

Implementing this recommendation should better ensure that the 

Parish spends at least $5,365,327 in CDBG disaster assistance 

funds obligated for its disaster assistance programs in 

accordance with requirements.

5,365,327

2016-PH-0001 6/30/2016 001-A 

Direct the New Orleans, LA, field office to enforce its 

monitoring findings and require the grantee to provide 

documentation to support costs totaling $4,959,911 or the 

grantee must reimburse its program from non-Federal funds for 

any costs that it cannot support.

4,959,911

2016-PH-1005 8/17/2016 001-B 

Provide documentation to show that fees it charged for 

maintenance services totaling $4,927,176 were reasonable or 

reimburse its public housing projects from non-Federal funds for 

any amount that it cannot support.

4,927,176

2016-LA-1008 8/26/2016 001-E 

Provide adequate documentation to support that the $4,586,471 

loan between Dolores Frances and Alliant Tax Credit Fund, 

LTD, was approved by HUD or remove the loan and any 

associated encumbrance from the project.

4,586,471

2016-PH-0001 6/30/2016 001-D 

Direct the Minneapolis, MN, field office to require the grantee to 

provide documentation to support the $4,299,963 in unsupported 

payments identified or the grantee must reimburse its program 

from non-Federal funds for any costs that it cannot support.

4,299,963

2016-LA-1006 6/3/2016 001-C 

Repay the U.S. Treasury $2,096,528 ($1,637,704 in public 

housing funds and $458,823 in Housing Choice Voucher 

program funds) for its ineligible use of Federal funds for 

payment of debt to the City.

4,193,056

217 █

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SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-NY-0001 9/12/2016 001-A 

We recommend that the Director of the Public Housing 

Financial Management Division determine whether any of the 

overpayment of $3,630,286 was ineligible and take appropriate 

actions to recoup the ineligible payments.

3,630,286

2016-PH-1007 9/27/2016 001-A 

Provide documentation to show that prices paid for services and 

products totaling $3,028,666 were fair and reasonable or 

reimburse the applicable program from non-Federal funds for 

any amount that it cannot support.

3,028,666

2017-FW-1003 12/27/2016 001-D 

We recommend that the Director of the Houston Office of Public 

Housing require the Authority to support or repay $3,014,541 to 

its public housing and voucher programs from non-Federal 

funds for the contractor payments listed in appendix C.

3,014,541

2016-CH-1008 9/29/2016 001-D 

Improve its quality control procedures to ensure that all 

properties in its active inventory comply with its contract with 

HUD and its own requirements to prevent $2,532,000 in 

monthly ongoing property management fees from being spent 

for properties that are not adequately maintained over the next 

year.

2,532,000

2016-PH-0003 7/29/2016 001-D 

Direct the applicable lenders to provide evidence that the 

properties for the 28 FHA-insured loans, which closed before 

October 1, 2015, and were endorsed after October 1, 2015, but 

were not included in our sample, had a safe and potable water 

source at the time the loans closed and were endorsed, or, if the 

lenders cannot provide this evidence, direct them to perform 

water testing and any necessary remediation to ensure that the 

properties have a safe and potable water source, or indemnify 

HUD against any future loss, thereby putting up to $2,512,464 to 

better use.

2,512,464

2017-BO-1001 10/12/2016 002-C 

Repay to HUD from non-Federal funds the $2,138,469 in 

ineligible CDBG-DR funds committed and spent without 

publishing the required notice of intent and request for release of 

funds.

2,138,469

2016-NY-1010 9/29/2016 001-C 

We recommend that the Director of HUD’s Office of Residential 

Care Facilities instruct project officials to provide 

documentation to justify $2,047,444 in unsupported costs. Any 

costs determined to be ineligible and paid from project funds 

should be reimbursed by the responsible party to the proper 

project account from nonproject funds. Any costs determined to 

be ineligible that were charged but not paid should be removed 

from the projects’ books and accounts.

2,047,444

218 █

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SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-NY-1010 9/29/2016 001-B 

We recommend that the Director of HUD’s Office of Residential 

Care Facilities instruct project officials to reimburse the proper 

project account from nonproject funds for any of the $1,812,777 

($252,823 + $1,559,954) in ineligible expenses paid with project 

funds. Those ineligible expenses that were charged but not paid 

should be removed from the projects’ books and accounts.

1,812,777

2016-BO-1003 6/28/2016 001-C 

Provide documentation to support that $1,807,359 in NSP funds 

was spent for reasonable, necessary, and supported costs. Any 

amount for which adequate support cannot be provided should 

be repaid to the Treasury from non-Federal funds.

1,807,359

2016-PH-0001 6/30/2016 001-E 

Direct the Washington, DC, field office to require the grantee to 

provide documentation to support the $1,766,778 in unsupported 

payments identified or the grantee must reimburse its program 

from non-Federal funds for any costs that it cannot support.

1,766,778

2016-AT-1013 9/13/2016 001-C 

Fully implement its procedures to ensure that all program units 

meet HUD’s housing quality standards to prevent $1,709,556 in 

program funds from being spent on units that do not comply 

with HUD’s requirements over the next year. The procedures 

should include but not be limited to ensuring that inspectors 

consistently conduct accurate and complete inspections.

1,709,556

2016-NY-1007 3/30/2016 001-F 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to provide documentation to support the $1,652,223 in CDBG 

funds used for developing the 22 affordable townhouses. Any 

amount determined to be ineligible should be reimbursed to the 

City’s CDBG program line of credit from non-Federal funds.

1,652,223

2016-AT-1013 9/13/2016 002-D 

Fully implement its policies and procedures to ensure that its 

staff complies with HUD regulations and its administrative plan 

when administering its program to prevent disbursing $ 

1,607,706 in program funds for improper housing assistance 

payments over the next year.

1,607,706

2016-FW-1006 8/31/2016 001-D 

We recommend that the Director of HUD’s Office of Block 

Grant Assistance require the State to ensure that the Parish 

supports the cost reasonableness of the grant management 

contract or repay $1,534,629 to its CDBG disaster assistance 

program from non-Federal funds. 

1,534,629

2016-NY-1003 2/5/2016 001-G 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct City officials to 

reimburse the $1,500,000 in CDBG funds spent for the 

delinquent float loan that defaulted in 1998 through one of the 

options identified in HUD regulations so that it can be closed out 

as bad debt, thereby making the funds available for use on other 

eligible activities. 

1,500,000

219 █

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SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-NY-1007 3/30/2016 001-I 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to record the mortgages on the five CDBG-assisted properties 

that were demolished and acquired with CDBG assistance of 

$1,475,674, thus ensuring that these properties are administered 

in compliance with program requirements.

1,475,674

2017-BO-1002 10/17/2016 001-A 

Provide adequate documentation to support that $1,448,663 in 

CDBG-DR funds was spent for supported, necessary and 

reasonable costs. Any amount for which adequate support 

cannot be provided should be repaid from non-Federal funds.

1,448,663

2016-AT-1010 8/4/2016 001-A 

Require the Housing Board to provide support showing that a 

conflict of interest did not exist between the Mobile 

Development Enterprises and Superior Masonry or reimburse 

HUD $1,241,958 from non-Federal funds.

1,241,958

2016-NY-0001 9/12/2016 001-B 

We recommend that the Director of the Public Housing 

Financial Management Division validate the $1,191,767 in 

underpayments and determine if any corrections should be 

made.

1,191,767

2016-NY-1003 2/5/2016 001-J 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct City officials to 

provide documentation to support that the $1,166,000 public 

facilities and improvements procurement contract price was fair 

and reasonable and that the sole-source method used was 

justified. Any costs determined not to be fair and reasonable 

should be reimbursed from non-Federal funds.

1,166,000

2016-NY-1007 3/30/2016 001-C 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to strengthen administrative controls to ensure that future 

Section 108 income of $1,162,801 will be recorded in IDIS, thus 

ensuring that these funds can be used for eligible activities.

1,162,801

2016-PH-0001 6/30/2016 001-B 

Enforce the Miami, FL, field office’s monitoring findings and 

require the grantee to provide documentation to support costs 

totaling $1,161,616 or the grantee must reimburse its program 

from non-Federal funds for any costs that it cannot support.

1,161,616

220 █

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SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-AT-1012 8/29/2016 001-B 

Provide support that $944,687 (Footnote 2: Emergency funds of 

more than $1.1 million drawn between July 1, 2011, and 

December 31, 2015, were adjusted to consider $158,800 

questioned in recommendation 1C and $38,164 questioned in 

recommendation 1D.) in Emergency funds drawn from HUD is 

reconciled with the accounting records and that such funds have 

not been used in violation of the restrictions and prohibitions of 

applicable statutes or reimburse the Emergency programs from 

non-Federal funds.

944,687

2016-DE-1005 9/28/2016 001-B 

Require the Authority to provide support to HUD showing that it 

received the best value in all instances when it incorrectly 

awarded a contract based on a faxed bid. For any portion the 

$918,766 the Authority cannot support, HUD should require the 

Authority to repay its HOME and NSP programs from nonFederal funds.

918,766

2016-AT-1009 8/2/2016 001-B 

Require the members to provide support or reimburse HUD’s 

FHA insurance fund $865,142 for unsupported project 

disbursements.

865,142

2017-NY-1001 11/2/2016 002-C 

We recommend that HUD’s Acting Deputy Assistant Secretary 

for Grant Programs coordinate with the Office of Healthy 

Homes and Lead Hazard Control to provide technical assistance 

and instruct City officials to provide supporting documentation 

that lead-based paint testing was performed, identified hazards 

were removed, and clearance was achieved for the 41 properties 

for which homeowners received $833,199 in CDBG-DR 

assistance. If supporting documentation is not provided, City 

officials should repay the $833,199 from non-Federal funds.

833,199

2016-CH-1004 7/28/2016 001-A 

Reimburse its program $707,091 from non-Federal funds 

($645,509 in housing assistance payments and $61,582 in 

associated administrative fees) for the inappropriate payments 

cited in this finding.

707,091

2016-LA-1006 6/3/2016 001-L Provide support showing that the $684,020 charged by the City 

for general liability coverage was reasonable. 684,020

2016-BO-1003 6/28/2016 001-A 

Repay to the Treasury from non-Federal funds the $666,668 in 

NSP funds spent for ineligible activity costs and funds that had 

already been paid by another Federal program.

666,668

2016-BO-1002 6/27/2016 001-F 

Provide support for the proper allocation of the $650,990 in 

information technology costs charged to the Capital Fund 

program. Any amounts that cannot be supported should be 

repaid from non-Federal funds.

650,990

221 █

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SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-FO-0003 11/15/2016 008-K 

Deobligate all obligations marked for deobligation during the 

departmentwide open obligations review, including as much as 

$384,703 in 27 administrative obligations and $234,619 in 6 

program obligations marked for deobligation as of September 

30, 2016.

619,322

2016-LA-1013 9/30/2016 001-A 

Support the eligibility of $605,614 used for unsupported 

allocated overhead costs charged for the fiscal year ending 

September 30, 2015, and its current fiscal year through June 30, 

2016, or reimburse its administrative fee reserve account using 

non-Federal funds.

605,614

2016-PH-0003 7/29/2016 001-B 

Direct the applicable lenders to provide evidence that the 

properties for the seven additional FHA-insured loans reviewed, 

for which the files did not contain evidence of water testing, had 

a safe and potable water source at the time the loans closed and 

were endorsed, or, if the lenders cannot provide this evidence, 

direct them to perform water testing and any necessary 

remediation to ensure that the properties have a safe and potable 

water source, or indemnify HUD against any future loss, thereby 

putting up to $570,827 to better use.

570,827

2016-CF-1813 9/30/2016 001-A Acknowledge that the attached settlement agreement for 

$510,000 represents an amount due HUD. 510,000

2016-PH-1005 8/17/2016 001-A 

Reimburse its public housing projects $507,800 from nonFederal funds related to the ineligible duplication of the 

information technology fee.

507,800

2016-CH-1007 9/28/2016 001-A 

Reimburse its program $497,668 ($453,995 in housing 

assistance payments + $43,673 in associated administrative fees) 

from non-Federal funds for the inappropriate payments cited in 

this finding.

497,668

2016-CH-1006 8/23/2016 001-A 

Support or reimburse its program $496,585 from non-Federal 

funds ($467,426 + $444 in housing assistance payments + 

$28,715 in administrative fees) for the missing eligibility 

documentation and unsupported housing assistance payments.

496,585

2016-BO-1002 6/27/2016 001-K 

Provide support showing that the contracts for which $488,150 

($216,142 and $272,008 for legal services and public relations 

services, respectively) was paid were procured at the most 

competitive and best price and the costs paid were necessary and 

reasonable. Any unnecessary or unreasonable costs should be 

repaid from non-Federal funds to the program(s) that paid the 

costs.

488,150

222 █

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SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-NY-1002 11/22/2016 001-A 

We recommend that the Director of HUD’s Office of Public 

Housing instruct Authority officials to provide documentation 

showing that the $474,571 in identified procurements was 

reasonable or repay any amounts not supported from nonFederal funds.

474,571

2017-BO-1002 10/17/2016 001-B 

Obtain adequate support to document the reasonableness and 

necessity of $472,246 or reprogram the funds to other allowable 

activities, thus ensuring that the funds will be put to their 

intended use.

472,246

2016-CH-1005 8/3/2016 001-A 

Support or reimburse its program $964,365 ($619,750 + 

$344,615) from non-Federal funds for the unsupported 

procurement and contracting cited in this finding.

463,885

2017-KC-1001 12/16/2016 002-B 

Require Majestic Management to provide support that $462,281 

paid for procurements was reasonable or reimburse the 

appropriate projects for the balance.

462,281

2017-KC-1001 12/16/2016 001-B 

Provide documentation to support that it paid itself $447,345 for 

eligible purposes or reimburse the appropriate projects for the 

balance.

447,345

2016-NY-1007 3/30/2016 001-H 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to record the mortgage on the CDBG-assisted rental property 

that was rehabilitated or reimburse the $426,296 from nonFederal funds to the City’s CDBG program line of credit, thus 

ensuring that the funds are put to their intended use.

426,296

2016-SE-1801 9/12/2016 001-A Acknowledge that the attached settlement agreement for 

$425,000 represents an amount due HUD. 416,145

2016-NY-1007 3/30/2016 002-C 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to record the receipt and expense of $397,031 in the City’s 

accounting records and correctly classify the amount in IDIS to 

show the use of the City’s CDBG funds for repayment of a 

guaranteed Section 108 loan, thus ensuring that the funds were 

put to their intended use.

397,031

2016-FW-1001 3/21/2016 001-C 

We recommend that the Director of HUD’s New Orleans Office 

of Community Planning and Development require the City to 

support that project 3, to build a bike path along the Mississippi 

River, met a national objective or repay $396,836 to its CDBG 

program from non-Federal funds.

396,836

223 █

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SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-AT-1006 6/17/2016 001-A Reimburse HUD for $379,547 in ineligible costs related to 

activities 831and 843 from non-Federal funds. 379,547

2016-AT-1006 6/17/2016 001-B 

Provide supporting documentation or reimburse its program for 

$362,723 in unsupported expenditures related to activities 831, 

747, and 800 from non-Federal funds.

362,723

2016-AT-1008 7/19/2016 001-A 

Support the cost reasonableness of the nine contracts or 

reimburse $408,958 to the appropriate Operating Fund, Capital 

Fund, and Housing Choice Voucher programs from non-Federal 

funds.

352,228

2016-FW-1001 3/21/2016 001-A 

We recommend that the Director of HUD’s New Orleans Office 

of Community Planning and Development require the City to 

support that project 1, to recruit and train low-income persons 

for construction jobs in the Baton Rouge area, met a national 

objective or repay $338,176 to its CDBG program from nonFederal funds.

338,176

2016-FW-1001 3/21/2016 002-A 

We recommend that the Director of HUD’s New Orleans Office 

of Community Planning and Development require the City to 

Support the cost reasonableness of the 64 housing rehabilitation 

contracts or repay $677,948 to its CDBG program from nonFederal funds.

320,911

2017-BO-1001 10/12/2016 001-B 

Repay to HUD from non-Federal funds the $316,850 in 

payments made for services outside the scope of the seven 

contracts.

316,850

2016-DE-1005 9/28/2016 001-A 

Require the Authority to provide support to HUD showing the 

necessity of drug testing every house and that the Authority 

received the best value for amounts spent on testing and 

remediation. For any portion the $315,166 the Authority cannot 

support, HUD should require the Authority to repay its HOME 

and NSP programs from non-Federal funds.

315,166

224 █

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SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-FW-1004 7/27/2016 001-A 

We recommend that the Acting Director of the HUD Southwest 

Region Office of Multifamily Housing Programs require the 

Corporation to develop and implement a HUD-approved written 

plan and checklists that will correct the project’s physical 

condition and other deficiencies outlined in the finding and 

prevent a recurrence of such issues to ensure compliance with 

HUD requirements. The written plan should include actions to 

(1) obtain a fully functioning board and operate in compliance 

with the Corporation’s bylaws and any HUD requirements, (2) 

correct all hazardous and unsafe physical deficiencies, including 

those cited in the February 2016 REAC inspection; (3) revise its 

operating budget to ensure the most economical use of funds and 

that the project income covers operating expenses; (4) establish 

written board-approved policies and procedures; and (5) obtain 

HUD-approved training for management and the Corporation’s 

board regarding their roles and responsibilities. The checklists 

should include systems and procedures to ensure that the 

Corporation meets all requirements, including but not limited to 

fully funding its reserve fund for replacements, spending funds 

for eligible costs, and submitting all required forms and 

documents. Implementing this recommendation should better 

ensure that the Corporation spends and better manages at least 

$314,184 in housing subsidies that it is set to receive in the next 

12 months in accordance with requirements.

314,184

2016-LA-1011 9/12/2016 001-B 

Indemnify HUD against potential losses of $304,871 for the 

three loans that did not comply with FHA underwriting 

requirements (appendix E).

304,871

2016-PH-1009 9/30/2016 001-C 

Provide documentation to show that $2,377,970 disbursed for 

other direct costs was supported and was for prices that were fair 

and reasonable or repay HUD from non-Federal funds any 

amount that it cannot support (excluding any amount repaid as a 

result of recommendation 1B).

303,004

2016-AT-1006 6/17/2016 001-C Recapture the remaining balance of $300,278 allocated to the 

stalled Barclay Apartment activity 843. 300,278

2016-NY-1006 3/29/2016 002-C 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs instruct State officials to immediately recapture 

more than $300,000 in CDBG-DR funds disbursed to 35 

businesses that was subject to full or partial recapture, thus 

ensuring that these funds will be put to their intended use.

300,000

2016-LA-1008 8/26/2016 001-A 

Stop the practice of disbursing the monthly social service fee to 

the general partner and reimburse the project for $300,000 in 

ineligible social service fees from non-Project funds.

300,000

225 █

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SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-DE-1802 9/12/2016 001-A Acknowledge that the attached settlement agreement for 

$1,032,715 represents an amount due HUD. 300,000

2016-PH-1006 8/31/2016 001-A 

Provide documentation to support program accomplishment data 

related to disbursements totaling $292,611 or repay HUD from 

non-Federal funds for any amount that it cannot support.

292,611

2016-NY-1003 2/5/2016 001-C 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct City officials to 

provide documentation to justify the $291,236 in unsupported 

costs related to disbursements made to the City’s public services 

subrecipient. Any costs determined to be inadequately 

supported should be reimbursed from non-Federal funds.

291,236

2016-LA-1007 8/17/2016 001-A 

Obtain written agreements and support the eligibility of 

$284,649 in unsupported costs or repay the program using nonFederal funds.

284,649

2016-NY-1006 3/29/2016 001-A 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs direct State officials to reimburse the line of 

credit for $272,459 in CDBG-DR funds disbursed to four 

businesses for ineligible costs from non-Federal funds.

272,459

2016-PH-0002 7/23/2016 001-B 

Require Ginnie Mae to improve its procurement and contract 

administration processes to ensure that it follows all applicable 

requirements, thereby putting up to $259,008 to better use.

259,008

2016-BO-1003 6/28/2016 001-G 

Provide a plan for the completion within acceptable timeframes 

of the five unfinished properties or cancel the activities and 

deobligate and reprogram the $254,183 in funds to other 

allowable activities, thus ensuring that the funds will be put to 

their intended use.

254,183

2016-CH-1006 8/23/2016 001-H 

Implement procedures and controls to ensure that housing 

assistance is correctly calculated and paid and that repayment 

agreements are created to recover overpaid housing assistance 

when unreported income is discovered during the examination 

process to ensure that $250,500 in overpayment of program 

funds is appropriately used for future payments.

250,500

2016-PH-1009 9/30/2016 001-D 

Provide documentation to support $516,560 disbursed for wages 

and salaries charged to its programs by its contractor’s 

employees or repay HUD from non-Federal funds any amount 

that it cannot support.

244,612

2017-KC-1001 12/16/2016 002-A 

Require Majestic Management to reimburse the appropriate 

projects their portion of $231,091 for work not completed or 

overbilled.

231,091

226 █

███ 226 226 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-AT-1007 6/22/2016 001-A Provide supporting documentation or reimburse its program for 

$227,587 in unsupported expenditures from non-Federal funds. 227,587

2016-NY-1002 1/7/2016 001-A 

We recommend that the Director of the HUD's Buffalo Office of 

Community Planning and Development instruct City officials to 

provide documentation to adequately support that $70,538 

disbursed and $150,000 obligated were for eligible costs. Any 

costs determined to be ineligible should be reimbursed from 

non-Federal funds.

220,538

2017-CH-0001 10/25/2016 001-A 

Deobligate the $1,247,153 in proceeds from initial sales 

associated with program grants and undisbursed program and 

capital funds, and coordinate with HUD’s Office of the Chief 

Financial Officer to ensure that the proceeds are remitted to the 

U.S. Treasury.

219,372

2016-SE-1002 6/23/2016 002-A 

Provide cost justifications for the six service contracts by 

obtaining written cost estimates from at least three contractors 

for each contract and reimburse the property’s operating account 

from non-project funds up to $219,309 for any amounts that are 

unreasonable.

219,309

2016-PH-0003 7/29/2016 001-A 

Direct the applicable lenders to provide evidence that the 

properties for the four FHA-insured loans reviewed, which had 

lead and copper levels above the EPA action level, had a safe 

and potable water source at the time the loans closed and were 

endorsed, or, if the lenders cannot provide this evidence, direct 

them to perform water testing and any necessary remediation to 

ensure that the properties have a safe and potable water source, 

or indemnify HUD against any future loss, thereby putting up to 

$215,571 to better use.

215,571

2016-BO-1003 6/28/2016 001-L 

Provide support showing that $212,496 in program funds was 

remitted to the State and reallocated to eligible NSP activities 

and that any additional program income owed by the developer 

has been remitted.

212,496

2016-AT-1012 8/29/2016 001-C Reimburse $189,227 to the Emergency programs from nonFederal funds for ineligible charges made to the programs. 189,227

2017-NY-1001 11/2/2016 002-B 

We recommend that HUD’s Acting Deputy Assistant Secretary 

for Grant Programs coordinate with the Office of Healthy 

Homes and Lead Hazard Control to provide technical assistance 

and instruct City officials to document the negative lead test 

results in CMS for one home and the removal of identified lead 

hazards and lead clearance reports for four homes, thus ensuring 

that $182,660 in CDBG-DR assistance was disbursed for leadsafe homes. If the negative test results are not documented, City 

officials should repay the $182,660 from non-Federal funds.

182,660

227 █

███ 227 227 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-CH-1012 9/30/2016 001-A 

Support the reasonableness of $181,290 ($97,290 + $84,000) 

paid for the two contracts (contract numbers 1697 and 1707) that 

did not have adequate cost estimates or reimburse its Capital 

Fund program from non-Federal funds.

181,290

2016-AT-1009 8/2/2016 001-A Require the members to reimburse HUD’s FHA insurance fund 

$181,020 for the ineligible distributions to the members. 181,020

2016-LA-1006 6/3/2016 001-I 

Provide documentation to support that $180,000 spent on office 

rent was reasonable or repay its public housing program from 

non-Federal funds.

180,000

2016-CH-1012 9/30/2016 001-D 

Support that contract modifications totaling $179,949 for two 

contracts (contract numbers 1702 and 1724) were reasonable. 

The amount that cannot be shown to be reasonable should be 

reimbursed to its Capital Fund program from non-Federal funds.

179,949

2016-AT-1013 9/13/2016 003-A 

Reimburse its program $153,593 from non-Federal funds for the 

$129,558 in housing assistance payments made and $24,035 in 

administrative fees received for the payments made to Brick 

Capital Community Development Corporation on the expired 

contract.

153,593

2016-NY-1006 3/29/2016 001-B 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs direct State officials to provide adequate 

documentation to justify $152,703 in CDBG-DR funds 

disbursed to six businesses. If any amount cannot be adequately 

supported, it should be reimbursed from non-Federal funds to 

the State’s line of credit.

152,703

2017-FO-0003 11/15/2016 008-J 

Deobligate the $152,211 in 108 administrative obligations 

marked for deobligation during the departmentwide open 

obligations review.

152,211

2016-NY-1007 3/30/2016 001-E 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to provide documentation to support whether $148,000 in 

CDBG program income was generated from the disposition of 

real properties acquired with CDBG funds so that HUD can 

determine eligibility. Any recognized program income should 

be reimbursed to the City’s local bank account and recorded in 

IDIS, thus ensuring that these funds can be put to better use.

148,000

2016-SE-1004 9/12/2016 001-A 

Provide support for the $132,759 in assistance that was based on 

the missing tenant files and reimburse HUD for the amount that 

remains unsupported.

132,759

228 █

███ 228 228 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-CH-1007 9/28/2016 002-A 

Determine the amount of the $128,228 in coordinator grant 

funds that was earned by the Authority for meeting program 

requirements. The funds that are determined to be unearned 

should be reimbursed to HUD from non-Federal funds.

128,228

2016-NY-0001 9/12/2016 001-H 

We recommend that the Director of the Public Housing 

Financial Management Division obtain accurate data from the 

PHAs and recalculate the calendar year 2014 operating subsidy 

for the project, which was mistakenly awarded based on other 

projects’ utility expense level data. If the eligible amount is less 

than $124,788, the difference should be recaptured.

124,788

2016-BO-1003 6/28/2016 001-D 

Provide documentation that $123,108 in NSP funds paid to two 

developers for administrative expenses was supported and that 

work performed was completed in accordance with their

contracts. Any amount for which adequate support cannot be 

provided should be repaid to the Treasury from non-Federal 

funds.

123,108

2016-NY-0001 9/12/2016 001-F 

We recommend that the Director of the Public Housing 

Financial Management Division recapture the overpayment of 

$116,218 disbursed for the units, which exceeded the PHAs’ 

Faircloth limit.

116,218

2016-LA-1008 8/26/2016 001-C Reimburse the project from non-Project funds for $114,068 in 

ineligible legal fees. 114,068

2016-NY-1002 1/7/2016 001-D 

We recommend that the Director of the HUD's Buffalo Office of 

Community Planning and Development instruct City officials to 

spend program income of $113,733 on eligible CDBG activities 

before drawing down additional CDBG entitlement funds, thus 

ensuring that these funds are put to better use.

113,733

2016-SE-1002 6/23/2016 003-A 

Provide supporting documents for the $112,064 in unsupported 

disbursements and repay the project operating account from nonproject funds for any amounts that remain unsupported.112,064

2016-PH-1006 8/31/2016 001-B 

Provide documentation to support salary and fringe benefit costs 

totaling $109,248 or repay HUD from non-Federal funds for any 

amount that it cannot support.

109,248

2016-AT-1007 6/22/2016 001-B Reimburse its line of credit for $108,563 in ineligible costs from 

non-Federal funds. 108,563

2016-AT-1005 5/10/2016 001-A 

Reimburse the program $108,390 from non-Federal funds for 

housing assistance payments ($100,214) and administrative fees 

received ($8,176) for the 40 units that materially failed to meet 

HUD’s and its own housing quality standards.

108,390

229 █

███ 229 229 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-SE-1001 3/9/2016 001-C 

Perform all past-due reexaminations and determine the correct 

amount of housing assistance due to Homewood Terrace since 

April 1, 2015, for the 22 members who did not receive timely 

reexaminations and adjust the next request for assistance to 

account for these corrections. By implementing this 

recommendation, $105,324 in housing assistance payments will 

be better used in the next year by providing the correct amount 

of assistance to families.

105,324

2016-DE-1005 9/28/2016 002-A 

Require the Authority to provide support justifying the 

reasonableness and necessity of all travel to conferences and 

trainings over the 31-month period reviewed. For any portion of 

the $102,563 in travel costs that HUD determines to be 

unreasonable, HUD should require the Authority to repay its 

HOME and NSP programs with non-Federal funds.

102,563

2017-NY-1001 11/2/2016 001-D 

We recommend that HUD’s Acting Deputy Assistant Secretary 

for Grant Programs instruct City officials to reimburse 

$101,398 in additional grants owed to the 11 homeowners 

whose grant amounts should have been materially increased as a 

result of recalculated duplication of benefits.

101,398

2016-SE-1002 6/23/2016 001-A 

Reimburse the project $101,282 from non-project funds ($4,706 

for unauthorized distributions and $96,576 for unauthorized 

repayments of loan advances) and if necessary, make priorperiod adjustments to the financial statements to disclose the 

information in accordance with generally accepted accounting 

principles.

101,282

2016-NY-1007 3/30/2016 002-B 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to reimburse the City’s CDBG program line of credit for 

$100,982, which was used to pay costs that had been paid with 

CDBG program income, thus ensuring that these funds can be 

used for eligible activities.

100,982

2016-LA-1010 8/29/2016 001-B 

Indemnify HUD against potential losses of $97,937 for one loan 

that did not comply with HUD underwriting requirements (048-

7976048).

97,937

2016-BO-1002 6/27/2016 001-C 

Repay the programs from non-Federal funds the $97,330 spent 

for the unallowable costs of scanning and storing records, 

accounting and financial software licenses, and iPads.

97,330

2016-LA-1008 8/26/2016 001-B 

Reimburse the project $92,962 from non-Project funds for 

ineligible consulting fees ($74,784) and supervising fees 

($18,178).

92,962

2016-CF-1810 9/29/2016 001-A Acknowledge that the attached settlement agreement for $91,377 

represents an amount due HUD. 91,377

230 █

███ 230 230 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-FO-0003 11/15/2016 008-L 

Deobligate the $85,782 in 5 administrative obligations marked 

for deobligation during the departmentwide open obligations 

review.

85,782

2017-FO-0003 11/15/2016 008-H 

Deobligate the $83,501 in 124 administrative obligations 

marked for deobligation during the departmentwide open 

obligations review.

83,501

2016-CH-1006 8/23/2016 002-A 

Take the appropriate actions to resolve the income discrepancies 

and pursue collection from the applicable households or 

reimburse its program $75,619 ($66,236 in housing assistance 

payments + $9,383 in administrative fees) from non-Federal 

funds for the overpayment of housing assistance cited in this 

finding.

75,619

2016-AT-1013 9/13/2016 001-A 

Reimburse its program $74,210 from non-Federal funds for the 

$65,430 in housing assistance payments and $8,780 in 

administrative fees received for the 37 units that failed to meet 

HUD’s housing quality standards.

74,210

2016-AT-1011 8/5/2016 001-F 

Support or indemnify HUD for one active modified loan 

agreement with unpaid balance of $138,790 (Footnote 9: Fifty 

percent loss severity rate is applied to the unpaid principal 

balance of $138,790 for funds to be put to better use. See 

appendix A.) for which the Authority did not have adequate 

support for the borrower’s verifiable loss of income or increase 

in living expenses.

69,395

2016-CH-1006 8/23/2016 001-F 

Reimburse its program $63,542 from non-Federal funds 

($51,536 in housing assistance overpayments + $9,236 + $2,770 

in associated administrative fees) for the inappropriate 

payments.

63,542

2016-BO-1002 6/27/2016 001-J 

Provide documentation for the $61,804 in unaccounted for 

inventory. If the items cannot be accounted for, repayment 

should be made to the Authority’s low-rent program from nonFederal funds.

61,804

2016-LA-1006 6/3/2016 001-E 

Repay its public housing program from non-Federal funds 

$60,000 plus any additional payments made to the City for the 

management and performance audit initiated by the City.

60,000

2016-LA-1006 6/3/2016 001-J Renegotiate its $60,000 per year office space rent to ensure that 

the Authority obtains a fair market price for the reduced space. 60,000

2016-CH-1012 9/30/2016 001-E 

Support that the contract modification totaling $59,620 for 

contract number 1724 was reasonable. The amount that cannot 

be shown to be reasonable should be deobligated under its 

Capital Fund program.

59,620

231 █

███ 231 231 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-CH-1006 8/23/2016 003-D Transfer $55,297 in forfeitures from its program account to its 

Housing Choice Voucher program account. 55,297

2016-AT-1009 8/2/2016 001-C Require the members to reimburse HUD’s FHA insurance fund 

$53,885 for the ineligible project disbursements. 53,885

2016-LA-1006 6/3/2016 001-D 

Reverse the debt of $53,347 for duplicate charges to the 

Authority’s public housing programs included in the indirect 

cost allocation plan that were included in the rent allocation and 

review the indirect cost allocation for additional duplicate 

charges.

53,347

2016-AT-1011 8/5/2016 001-C 

Indemnify HUD for two active modified loan agreements with 

total unpaid balance of $102,241 (Footnote 8: Fifty percent loss 

severity rate is applied to the unpaid principal balance of 

$102,241 for funds to be put to better use. See appendix A.) that 

were not eligible for FHA-HAMP due to a failure to successfully 

complete the trial payment plans.

51,121

2017-KC-1001 12/16/2016 003-B 

Provide documentation to support that $48,891 was spent for 

eligible purposes or reimburse the appropriate projects for the 

balance.

48,891

2016-LA-1007 8/17/2016 002-A Repay the program for $48,611 in ineligible costs using nonFederal funds. 48,611

2016-PH-1008 9/29/2016 001-B 

Reimburse its program $44,887 from non-Federal funds 

($44,584 for housing assistance payments and $303 in 

associated administrative fees) for the 15 units that materially 

failed to meet HUD’s housing quality standards.

44,887

2016-CH-1012 9/30/2016 001-B 

Support the reasonableness of $44,452 ($246,112 - $201,660) 

paid in excess of the independent cost estimate for contract 

number 1698 or reimburse its Capital Fund Financing program 

from non-Federal funds.

44,452

2016-LA-1007 8/17/2016 001-B 

Revise or reclassify the national objective for the $38,165 in 

questioned costs used for the solar panel project or repay the 

program using non-Federal funds.

38,165

2016-AT-1012 8/29/2016 001-D 

Submit supporting documentation showing the eligibility, 

reasonableness, and allocability of $38,164 charged to the 

Emergency programs for unsupported drawdowns and 

equipment cost allocations or reimburse the programs from nonFederal funds.

38,164

2016-FW-1006 8/31/2016 001-G 

We recommend that the Director of HUD’s Office of Block 

Grant Assistance require the State to ensure that the Parish 

provides documentation detailing the number of hours worked 

for each disaster assistance program or repay $37,450 to its 

CDBG disaster assistance program from non-Federal funds.

37,450

232 █

███ 232 232 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-CH-1006 8/23/2016 003-G 

Support or reimburse its program bank account $36,038 from its 

Housing Choice Voucher program bank account for the 

withdrawal to force balance the program bank account.

36,038

2016-SE-1004 9/12/2016 001-C 

Provide support for the $35,890 in assistance that was based on 

the unperformed or missing annual recertifications and 

reimburse HUD for the amount that remains unsupported.

35,890

2016-CH-1012 9/30/2016 001-C 

Support that $34,928 ($229,123 - $194,195) paid in excess of 

the independent cost estimate for contract number 1702 was 

reasonable or deobligate the funds.

34,928

2017-BO-1001 10/12/2016 002-F Support or repay to HUD from non-Federal funds $32,398 in 

duplicative assistance provided to program applicants. 32,398

2017-NY-1001 11/2/2016 001-C 

We recommend that HUD’s Acting Deputy Assistant Secretary 

for Grant Programs instruct City officials to repay the Program 

from non-Federal funds $32,107 in overpaid grants to 

homeowners whose grant amounts (1) were not revised to show 

recalculated duplication of benefits and (2) exceeded the 

Program’s 60 percent reimbursement rate.

32,107

2016-FW-0001 3/30/2016 002-F 

We recommend that the Deputy Secretary require the Chief 

Financial Officer to support or require employers to repay 

$49,989 in overpayments on IPA agreements.

31,066

2016-NY-1007 3/30/2016 001-P 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to provide documentation to support the income eligibility of the 

homeowner who received $30,600 in CDBG funds related to the 

rebate program. If documentation cannot be provided, the City’s 

CDBG program line of credit should be reimbursed $30,600 

from non-Federal funds.

30,600

2016-BO-1003 6/28/2016 001-B 

Justify the reasonableness of or repay to the Treasury from nonFederal funds the $29,106 in NSP funds spent for unreasonable 

activity costs.

29,106

2017-NY-1001 11/2/2016 002-E 

We recommend that HUD’s Acting Deputy Assistant Secretary 

for Grant Programs coordinate with the Office of Healthy 

Homes and Lead Hazard Control to provide technical assistance 

and instruct City officials to reconcile the discrepancy in the lead 

test results. If it is determined that the home tested positive for a 

lead-based paint hazard, City officials should provide supporting 

documentation showing that the hazard has been removed and 

the home has achieved clearance, thus ensuring that $29,019 in 

CDBG-DR assistance was disbursed for a lead-safe home. If the 

lead test results are not reconciled and the lead safety of the 

home is not documented, City officials should repay the $29,019 

from non-Federal funds.

29,019

233 █

███ 233 233 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-AT-1014 9/30/2016 001-A 

Reimburse its program $28,199 ($19,771 + $7,793 + $635) from 

non-Federal funds for the overpayment of housing assistance 

and ineligible administrative fees it received for the deficiencies 

cited in this report.

28,199

2017-FW-1001 12/12/2016 001-B 

We recommend that the Director, Office of Public Housing, Fort 

Worth, TX, require the Authority to support or repay its Capital 

Fund program from non-Federal funds $28,000 for work 

completed without a valid contract.

28,000

2016-PH-1803 9/9/2016 001-A Acknowledge that the attached judgment and repayment 

agreement for $24,500 represents an amount due HUD. 24,000

2016-AT-1013 9/13/2016 002-A 

Reimburse its program $22,967 from non-Federal funds for the 

$20,111 in housing assistance payments and $2,856 in 

administrative fees received for the 51 ineligible housing 

assistance payments missing housing assistance payments 

contracts.

22,967

2016-NY-1007 3/30/2016 001-Q 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to provide a registered mortgage for the homeowner property 

assisted with $21,195 in CDBG funds. If a registered mortgage 

cannot be provided, the City’s CDBG program line of credit 

should be reimbursed $21,195 from non-Federal funds.

21,195

2016-CH-1008 9/29/2016 001-B 

Reimburse HUD $19,425 in ineligible monthly ongoing 

property management fees for the 105 properties that contained 

property preservation and protection deficiencies.

19,425

2016-CH-1006 8/23/2016 001-I 

Pursue collection from the applicable households or reimburse 

its program $18,718 from non-Federal funds for the 

overpayment of housing assistance due to unreported or 

underreported income.

18,718

2017-KC-1001 12/16/2016 001-A 

Provide support showing that $17,414 in management fees 

charged to the projects using a budgeted amount represented 

actual amounts or repay the difference to each affected project.

17,414

2016-PH-1003 5/24/2016 001-C 

Require the City to provide documentation for two activities, 

with draws totaling $14,900, to show that it conducted an 

environmental review or repay its program from non-Federal 

funds any amount that it cannot support. 

14,900

2016-LA-1007 8/17/2016 001-C Support the eligibility of $11,960 in unsupported costs or repay 

the program using non-Federal funds. 11,960

2016-AT-1009 8/2/2016 001-D 

Require the members to reimburse HUD’s FHA insurance fund 

$11,587 for the unreasonable nonsufficient funds and overdraft 

charges.

11,587

234 █

███ 234 234 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-KC-1001 12/16/2016 003-A Reimburse the appropriate projects their portion of $11,184 that 

it charged for ineligible items. 11,184

2016-NY-1007 3/30/2016 001-R 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to reimburse $9,730 from non-Federal funds to the City’s CDBG 

program line of credit for the ineligible homeowner 

rehabilitation assistance provided that exceeded the subsidy 

limit.

9,730

2016-CH-1007 9/28/2016 002-D Reimburse its program $9,506 from non-Federal funds for the 

incorrect escrow account disbursements. 9,506

2016-CH-1004 7/28/2016 002-A 

Support or reimburse its program $9,382 from non-Federal 

funds ($8,216 + $276 in unsupported housing assistance 

payments + $614 + $276 in associated unsupported 

administrative fees + $185 in unsupported expenditures) for the 

missing eligibility documentation, unsupported payments of 

housing assistance, and unsupported program expenditures cited 

in this finding.

9,382

2017-FW-1001 12/12/2016 001-E 

We recommend that the Director, Office of Public Housing, Fort 

Worth, TX, require the Authority to reimburse its Capital Fund 

program with the $9,117 of insurance proceeds for the roof 

repairs.

9,117

2016-CH-1006 8/23/2016 003-C Support or reimburse its Housing Choice Voucher program 

$8,223 for the unsupported escrow balances cited in this finding. 8,223

2016-AT-1008 7/19/2016 001-B 

Reimburse $7,851 spent on ineligible expenses to the 

appropriate Operating Fund and Housing Choice Voucher 

programs from non-Federal funds.

7,851

2016-SE-1002 6/23/2016 003-C 

Provide support showing that the project was entitled to the 

$7,378 from the security deposit account or reimburse the 

security deposit account from the operating account for any 

amounts to which the project was not entitled.

7,378

2016-PH-1006 8/31/2016 001-C Repay HUD $6,850 from non-Federal funds for the ineligible 

training costs that were not approved in advance. 6,850

2016-SE-1003 9/12/2016 001-A 

Provide support for the $6,804 in housing assistance that was 

based on the unverified income and reimburse HUD any amount 

that remains unsupported.

6,804

2016-SE-1002 6/23/2016 004-A Reimburse HUD $6,118 for ineligible housing assistance 

payments. 6,118

2016-SE-1001 3/9/2016 001-B 

Repay HUD from non-Federal funds the $5,928 in ineligible 

housing assistance received after April 1, 2015, that was based 

on past-due annual reexaminations.

5,928

235 █

███ 235 235 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-CH-1006 8/23/2016 001-K 

Pursue collection from the applicable landlords or reimburse its 

program $7,354 (of which $5,891 had not been collected or 

reimbursed) from non-Federal funds for the duplicate housing 

assistance payments.

5,891

2016-DE-1005 9/28/2016 002-B 

Require the Authority to provide support for the unreasonable 

amount of hotel costs above the local per diem rate. For any 

portion of the $22,083 in unreasonable costs ($16,386 of which 

is included in costs identified in recommendation 2A) that the 

Authority cannot support, HUD should require the Authority to 

repay its HOME and NSP programs with non-Federal funds.

5,697

2017-BO-1001 10/12/2016 002-E Repay HUD from non-Federal funds $5,056 in ineligible 

duplicative assistance provided to program applicants. 5,056

2016-SE-1002 6/23/2016 003-B 

Repay the project $4,587 from non-project funds for the costs 

that were not necessary for the operation or maintenance of the 

project.

4,587

2016-PH-0001 6/30/2016 001-F 

Direct the Washington, DC, field office to require the grantee to 

repay its program $4,214 from non-Federal funds for the 

ineligible costs associated with activity 1515.

4,214

2016-BO-1003 6/28/2016 001-J Repay to the Treasury from non-Federal funds the $4,110 

disbursed for properties in excess of the required discount. 4,110

2016-PH-1802 9/9/2016 001-A Acknowledge that the attached settlement agreement for $7,000 

represents an amount due HUD. 4,000

2016-AT-1008 7/19/2016 001-C 

Provide adequate support for disbursements or reimburse $3,588 

to the appropriate Operating Fund and Housing Choice Voucher 

programs from non-Federal funds.

3,588

2016-PH-1006 8/31/2016 001-D Repay HUD $3,400 from non-Federal funds for the ineligible 

payments made to the public housing resident. 3,400

2017-NY-1003 12/14/2016 002-B 

We recommend that the Director of HUD’s Buffalo Office of 

Public Housing instruct Town officials to continue collection 

efforts from the tenant on the repayment agreement for $3,393 in 

ineligible costs for the overpayment of the rental subsidy.

3,393

2016-AT-1013 9/13/2016 002-B 

Support or reimburse its program $3,092 from non-Federal 

funds for the $2,756 in housing assistance payments and $336 in 

administrative fees received for the six unsupported housing 

assistance payments missing deeds, utility allowance 

determinations, and inspection reports.

3,092

236 █

███ 236 236 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-SE-1001 3/9/2016 001-D 

For the member whose October 1, 2015, reexamination relied on 

unverified income information, determine the appropriate 

housing assistance payment amount for that reexamination date 

by verifying and supporting the member’s income at that time, 

reimburse HUD up to $3,087 for any amount that remains 

unsupported, and adjust the next request for assistance to 

account for the appropriate amount.

3,087

2016-NY-1002 1/7/2016 001-C 

We recommend that the Director of the HUD's Buffalo Office of 

Community Planning and Development instruct City officials to 

reprogram unexpended funds of $2,516 on a subgrantee 

agreement that expired June 30, 2015, for use by other eligible 

CDBG activities so that these funds are put to better use.

2,516

2016-PH-1006 8/31/2016 001-F 

Develop and implement controls to ensure that it complies with 

applicable program requirements, thereby putting $2,444 in 

unspent training funds from one grant to better use.

2,444

2016-CH-1004 7/28/2016 002-C Reimburse its program $2,360 from non-Federal funds for the 

ineligible expenditures. 2,360

2016-CH-1008 9/29/2016 001-C Reimburse HUD $2,314 for the ineligible monthly ongoing 

property management fees received for services not performed. 2,314

2016-CH-1004 7/28/2016 002-E 

Reimburse the appropriate landlords and households $2,252 

($1,650 + $565+$37) from program funds for inappropriate 

charges of administrative service fees.

2,252

2016-DE-1005 9/28/2016 002-C 

Require the Authority to provide support justifying the necessity 

of the weekend travel that occurred. For any portion of the 

$2,134 in weekend travel costs that HUD determines to be 

unsupported, HUD should require the Authority to repay its 

HOME and NSP programs with non-Federal funds.

2,134

2016-CH-1007 9/28/2016 002-B 

Transfer $30,842 (of which $2,098 remains to be transferred) 

from its Family Self-Sufficiency program account to its Housing 

Choice Voucher program account for the overfunded escrows 

cited in this finding.

2,098

2016-CH-1012 9/30/2016 001-F 

Reimburse the U. S. Treasury from its capital fund account 

$1,945 charged to the incorrect budget line item in HUD’s 

system.

1,945

2016-PH-1009 9/30/2016 001-E 

Provide documentation to support $11,268 disbursed for travel 

or repay HUD from non-Federal funds any amount that it cannot 

support.

1,838

2016-CH-1007 9/28/2016 002-E Support or reimburse its program $1,812 from non-Federal 

funds for the unsupported escrow account disbursements. 1,812

237 █

███ 237 237 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-CH-1004 7/28/2016 002-B 

Pursue collection from the applicable household or reimburse its 

program $1,112 from non-Federal funds for the overpayment of 

housing assistance due to unreported income.

1,112

2016-AT-1014 9/30/2016 001-B Reimburse the three households $1,010 from program funds for

housing assistance underpayments. 1,010

2016-CH-1006 8/23/2016 003-H 

Support or reimburse its Housing Choice Voucher program bank 

account for the $1,000 deposit to the program escrow bank 

account cited in this finding.

1,000

2016-CH-1006 8/23/2016 001-C 

Reimburse the appropriate household $936 from non-Federal 

funds for the rent amount paid in excess of 40 percent of the 

adjusted monthly income for the unit that was not affordable.

936

2016-SE-1002 6/23/2016 004-B Reimburse the overcharged tenant $792. 792

2016-CH-1006 8/23/2016 001-M Reimburse the appropriate households $748 from program funds 

for inspection fees cited in this finding. 748

2016-SE-1003 9/12/2016 001-C 

Reimburse the three tenants who overpaid rent by $714. If HUD 

agrees to reimburse Solace for the $714 in underpaid assistance, 

Solace could use these funds to reimburse the tenants.

714

2016-CH-1006 8/23/2016 001-G Reimburse the appropriate households $623 from program funds 

for the underpayment of housing assistance. 623

2016-SE-1003 9/12/2016 002-A Require Solace to reimburse HUD the $584 it paid in postmove-out assistance for four tenants. 584

2016-SE-1003 9/12/2016 001-B Reimburse HUD the $320 in overcharged housing assistance. 320

2016-SE-1004 9/12/2016 001-B 

Provide support for the $248 in assistance that was based on the 

unsupported hardship exemptions and reimburse HUD for the 

amount that remains unsupported.

248

2016-SE-1002 6/23/2016 005-C Reimburse its operating account $161 from non-project funds 

for ineligible insufficient funds fees. 161

2016-NY-1007 3/30/2016 001-S 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to reimburse $83 from non-Federal funds to the City’s CDBG 

program line of credit for disbursements made for the two 

contracts exceeding 10 percent of the cost estimate.

83

2016-CH-1007 9/28/2016 002-C 

Transfer $261 (of which $11 remains to be transferred) from its 

Housing Choice Voucher program account to its Family SelfSufficiency program account for the underfunded escrows cited 

in this finding.

11

238 █

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SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-NY-1002 1/7/2016 001-B 

We recommend that the Director of the HUD's Buffalo Office of 

Community Planning and Development instruct City officials to 

strengthen monitoring procedures for CDBG-funded subgrantees 

to ensure compliance with program requirements.

0 

2016-NY-1002 1/7/2016 001-E 

We recommend that the Director of the HUD's Buffalo Office of 

Community Planning and Development instruct City officials to 

implement procedures to ensure that program income received 

by subgrantees is properly reported in HUD's integrated 

Disbursement and Information System and spent before funds 

are drawn down from the U.S. Treasury.

0 

2016-NY-1002 1/7/2016 001-F 

We recommend that the Director of the HUD's Buffalo Office of 

Community Planning and Development instruct City officials to 

strengthen subgrant procedures to ensure that all required 

documents are received, explanations are obtained when prior 

performance does not meet goals, and subgrants are executed in 

a timely manner.

0 

2016-NY-1003 2/5/2016 001-B 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct City officials to 

strengthen disbursement controls to ensure that CDBG funds are 

drawn down to reimburse only eligible costs.

0 

2016-NY-1003 2/5/2016 001-D 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct City officials to 

strengthen procedures to ensure that all costs claimed for CDBG 

reimbursement are adequately supported by documentation 

before funds are disbursed.

0 

2016-NY-1003 2/5/2016 001-F 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct City officials to 

strengthen controls to ensure compliance with Section 108 

contract provisions and regulations requiring disbursement of 

funds in a timely manner after drawdown.

0 

2016-NY-1003 2/5/2016 001-H 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct City officials to 

implement procedures to ensure that any future CDBG floatfunded activities are administered in accordance with HUD 

regulations requiring that the annual action plan identify the 

float-funded activity and a commitment to undertake one of the 

options listed in the regulations if the funds are unable to be 

repaid within the required timeframe.

0 

239 █

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SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-NY-1003 2/5/2016 001-I 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct City officials to 

develop and implement procedures to ensure that the City’s liens 

related to HUD-funded loans are not released without repayment 

or evidence of due diligence to address delinquent, outstanding 

loans.

0 

2016-NY-1003 2/5/2016 001-K 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct City officials to 

implement procedures to ensure that all HUD-funded 

procurement is performed in accordance with regulations at 24 

CFR 85.36, which require that sealed bid procurements be 

adequately advertised and involve at least two bids and that 

independent estimates be documented before bids or proposals 

are received.

0 

2016-NY-1003 2/5/2016 001-L 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct City officials to 

strengthen procedures over subrecipient monitoring to ensure 

that onsite visits are conducted for all CDBG subrecipients 

annually as specified in the agreements and that monitoring 

efforts are adequately tracked.

0 

2016-NY-1003 2/5/2016 001-M 

We recommend that the Director of HUD’s Buffalo Office of 

Community Planning and Development instruct City officials to 

request CDBG program training from the HUD Office of 

Community Planning and Development field office relating to 

Section 108 and float loan administration, drawdown and 

disbursement of funds in a timely manner, and federal 

procurement regulations.

0 

2016-NY-1801 2/11/2016 001-B 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to collect and test lead dust samples from the floors and window 

sills of the 27 homeowner units that received CDBG funds in 

program years 2012 and 2013 to ensure that the lead dust does 

not exceed the allowable lead dust standards. If the tests reveal 

the existence of excessive lead dust, City officials need to reduce 

the lead dust to the allowable limit, or reimburse the City’s 

CDBG line of credit from non-Federal funds for disbursements 

previously made to repair those 27 units.

0 

2016-NY-1801 2/11/2016 001-C 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to strengthen the City’s administrative controls to ensure that the 

lead risk assessment conducted after the completion of 

rehabilitation work is adequately documented.

0 

240 █

███ 240 240 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-NY-1801 2/11/2016 001-D 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to strengthen the City’s administrative controls to ensure that 

adequate documentation is maintained to support compliance 

with the Federal and State lead requirements.

0 

2016-NY-1801 2/11/2016 001-F 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to provide lead hazard training to the City’s lead risk assessor to 

ensure compliance with Federal and State requirements.

0 

2016-CH-0001 2/26/2016 001-A 

Record new declarations of trust for the 22 projects to ensure 

that HUD’s interests are protected for the period in which the 

public housing agencies are required to operate the projects as 

public housing.

0 

2016-CH-0001 2/26/2016 001-B 

Support that the 47 projects have sufficient declarations of trust 

that cover all HUD-assisted properties to protect HUD’s interest 

and prevent encumbrances. If the public housing agencies 

cannot support that valid declarations of trust were recorded for 

all HUD-assisted properties, HUD should require the agencies to 

record declarations of trust or apply appropriate sanctions 

against the agencies that do not comply with HUD regulations.

0 

2016-CH-0001 2/26/2016 001-C 

Amend the declaration of trust forms and instructions to (1) 

include a second identifier for each property, such as physical 

addresses, so that HUD may verify the effectiveness of the 

declaration of trust with the information maintained in its 

systems; (2) allow for the declaration of trust to terminate only 

upon release from HUD; and (3) reflect the actual preparation 

process used.

0 

2016-SE-1001 3/9/2016 001-A Hire, train and maintain sufficient staff to adequately perform its 

housing assistance payment functions. 0 

2016-NY-1006 3/29/2016 001-C 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs direct State officials to strengthen controls over 

program operations to provide greater assurance that costs 

charged to the CDBG-DR program are for eligible activities and 

supported by all required documentation, specifically by 

requiring recipients to provide receipts or other documentation 

to support the completed replacement or repair costs.

0 

2016-NY-1006 3/29/2016 002-A 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs instruct State officials to strengthen 

administrative controls to ensure that any ineligibility 

determination is immediately followed by the next level of 

management for further action and the current status in the 

IntelliGrants system is accurate.

0 

241 █

███ 241 241 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-NY-1006 3/29/2016 002-B 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs instruct State officials to incorporate and 

implement recapture policies and procedures to ensure that funds 

disbursed for ineligible businesses and costs are promptly 

recovered.

0 

2016-NY-1007 3/30/2016 001-G 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to strengthen administrative controls over record keeping to 

ensure that documentation is maintained to support the 

eligibility of costs paid with CDBG funds.

0 

2016-NY-1007 3/30/2016 001-J 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to provide documentation, such as proof of advertising, bids 

received, bid analysis reports, cost estimates, contracts, and 

other applicable records, to support compliance with Federal 

procurement regulations in the awarding of the five contracts.

0 

2016-NY-1007 3/30/2016 001-K 

We recommend that the Director of HUD’s Newark, NJ, Office

of Community Planning and Development instruct City officials 

to provide documentation to support compliance with Federal 

procurement regulations when contracts were awarded to the 

three single bidders.

0 

2016-NY-1007 3/30/2016 001-L 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to provide documentation to support the eligibility of the three 

tenants occupying low- to moderate-income housing units at a 

residential property assisted with CDBG funds.

0 

2016-NY-1007 3/30/2016 001-M 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to provide documentation to support the review of the remaining 

30 tenants’ eligibility to occupy low- and moderate-income 

housing units.

0 

2016-NY-1007 3/30/2016 001-N 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to provide documentation to support that those laborers 

employed by the four contractors are compensated in accordance 

with Davis-Bacon wage rates. If documentation cannot be 

provided, the City’s line of credit should be reimbursed from 

non-Federal funds for disbursements made to the four 

contractors.

0 

242 █

███ 242 242 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-NY-1007 3/30/2016 001-O 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to strengthen administrative controls over the City’s CDBG 

program to ensure compliance with program income and 

procurement requirements.

0 

2016-NY-1007 3/30/2016 001-T 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to provide documentation to support compliance with Federal 

procurement regulations when a winning bidder was allowed to 

submit two bids with different prices for a single contract. If 

documentation cannot be provided, the City’s line of credit 

should be reimbursed from non-Federal funds for disbursements 

made to the contractor.

0 

2016-NY-1007 3/30/2016 001-U 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to provide documentation, such as a New Jersey State business 

registration, liability insurance, licenses, and other 

documentation, to support the eligibility of the three contractors 

awarded HORP contracts in program years 2012 and 2013.

0 

2016-NY-1007 3/30/2016 001-V 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to strengthen administrative controls over HORP to ensure 

compliance with program requirements.

0 

2016-NY-1007 3/30/2016 001-W 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to provide training to City staff responsible for administering the 

City’s CDBG program to strengthen the staff’s awareness of 

CDBG program requirements.

0 

2016-NY-1007 3/30/2016 002-A 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to strengthen financial controls over cash flow to ensure that the 

time between making and spending LOCCS drawdowns is 

minimized.

0 

2016-NY-1007 3/30/2016 002-F 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to provide training to City staff responsible for reporting in IDIS 

and making drawdowns from LOCCS, thus ensuring compliance 

with CDBG program requirements.

0 

2016-NY-1007 3/30/2016 002-G 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct City officials 

to strengthen financial controls to ensure that LOCCS 

drawdowns are charged to the correct IDIS activities and 

traceable to the City’s accounting records.

0 

243 █

███ 243 243 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-LA-1004 4/28/2016 001-E 

Submit annually to HUD for the next 3 years, a list of all 

procurement contracts over $10,000 (whether ongoing or 

recently procured contracts) listing the vendor name, contract 

service description or items purchased, and contract amount. 

HUD will perform a review and evaluation of selected contracts.

0 

2016-LA-1004 4/28/2016 001-F Submit to HUD, on an annual basis, for the next 3 years, the 

Authority’s last 12-month vendor payment history. 0 

2016-AT-1005 5/10/2016 001-B 

Ensure that the housing quality standards violations have been 

corrected for the 69 units cited in this finding and certify that the 

units meet the standards.

0 

2016-FO-0005 5/13/2016 001-A 

Revise its risk assessment process to ensure that all HUD 

programs, including Ginnie Mae programs, are (1) initially riskassessed for improper payments or request a waiver from OMB, 

and if programs are determined to be low risk, reassess them on 

a 3-year cycle; and (2) risk assessed against all of the required 

risk factors.

0 

2016-FO-0005 5/13/2016 001-B 

Establish policies and procedures to ensure that adequate 

documentation of the risk assessment process is maintained to 

facilitate an independent third-party’s review of OCFO’s 

compliance with the requirements of OMB Circular A-123, 

appendix C, for risk assessments.

0 

2016-FO-0005 5/13/2016 001-C 

Consider stratifying the population of RHAP tenant cases 

between income-based and non-income based rents going 

forward in determining the population of cases for the QC study 

and determine whether it is appropriate to include only the 

income-based tenants in the population.

0 

2016-FO-0005 5/13/2016 002-A 

Develop, document, and implement formal policies and 

procedures to ensure that (1) all programs or activities that 

expend $1 million or more annually for each program office 

identified are included in either the program office’s payment 

recapture audit plan or provide a justification and analysis 

showing why a payment recapture audit would not be cost 

effective for that program or activity and (2) justifications and 

analyses showing why a payment recapture audit would not be 

cost effective are maintained and adequately described in the 

AFR, in accordance with OMB Circular A-123, appendix C.

0 

2016-FO-0005 5/13/2016 003-A 

Develop and document a methodology for adjusting the billing 

error for factors that may change the billing error previously 

reported if a billing study is not performed annually.

0 

244 █

███ 244 244 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-FO-0005 5/13/2016 004-A 

Amend the checklist to ensure that the description of corrective 

actions in the AFR include an explanation of how the corrective 

actions address the root causes reported in table 2 and all 

required timelines.

0 

2016-FO-0005 5/13/2016 004-B 

Establish and implement procedures to ensure that the required 

information specified in the checklist is adequately and 

specifically addressed and is included in the published AFR.

0 

2016-FO-0005 5/13/2016 004-C 

Establish and implement a process to identify high-dollar 

overpayments and report them quarterly to OMB and us or 

submit a written request to OMB for an alternative reporting 

structure.

0 

2016-FO-0005 5/13/2016 002-C 

Resubmit the justifications for why a payment recapture audit 

would not be cost-effective for each program that expended over 

$1 million or more to OMB and OIG for programs that were not 

already identified under a separate recovery audit plan.

0 

2016-FO-0005 5/13/2016 001-E 

Revise its risk assessment process to (1) ensure that all FHA 

programs are assessed for significant improper payments or 

request a waiver from OMB; (2) establish a 3-year cycle to 

reassess all low-risk programs; and (3) ensure that consideration 

of all of the required risk factors is clearly documented.

0 

2016-FO-0005 5/13/2016 002-B 

Revisit the existing recovery audit plan and update it as needed 

to ensure that all programs and activities that expended more 

than $1 million annually were included in the recovery audit 

plan or excluded from the recovery audit plan and maintain the 

corresponding cost-benefit analyses supporting their exclusion.

0 

2016-AT-0001 5/20/2016 001-A 

Revise its memorandum of understanding with the Office of 

Risk Management and Assessment to ensure that loans approved 

by the Office of Multifamily Production are reviewed for 

compliance with MAP underwriting requirements.

0 

2016-AT-0001 5/20/2016 001-B 

Coordinate with the Office of Risk Management and Assessment 

to conduct compliance reviews of loans approved by the Office 

of Multifamily Production that have not been completed since 

October 2014.

0 

2016-AT-0001 5/20/2016 002-A 

Update the valuation appendixes to reflect the requirements 

provided in paragraph 7.18.E of the 2016 MAP Guide. The 

updated requirements should be included in the MAP Guide

when it is formally revised.

0 

245 █

███ 245 245 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-AT-0001 5/20/2016 002-B 

Update the requirements provided in paragraph 7.18.D of the 

MAP Guide by issuing alternate guidance to require 

management to provide adequate support documentation to 

justify loan approval in instances in which technical staff and 

underwriters recommend or conclude that a loan should not be 

approved. The updated requirements should be included in the 

MAP Guide when it is formally revised.

0 

2016-AT-0001 5/20/2016 002-C 

Update the requirements provided in paragraph 7.1.D of the 

2016 MAP Guide by issuing alternate guidance to ensure 

USPAP compliance when the reviewer is not an appraiser. The 

updated requirements should be included in the MAP Guide 

when it is formally revised.

0 

2016-AT-0001 5/20/2016 002-D 

Update the requirements provided in paragraph 4.4.A of the 

2016 MAP Guide by issuing alternate guidance, which clearly 

outlines who will determine whether a technical specialist will 

be used for each part of a loan under the Single Underwriter

model and how that determination will be made. The updated 

requirements should be included in the MAP Guide when it is 

formally revised.

0 

2016-AT-0001 5/20/2016 002-E 

Formalize a detailed training program process to ensure that new 

employees hired after the multifamily transformation is 

complete are familiar with the Single Underwriter model.

0 

2016-PH-1003 5/24/2016 001-E Require the City to develop and implement controls to ensure 

that it properly monitors subrecipient activities. 0 

2016-PH-1003 5/24/2016 001-F 

Require the City to develop and implement controls to ensure 

that subrecipient activities comply with all requirements before 

making disbursements.

0 

2016-PH-1003 5/24/2016 001-H 

Require the City to develop and implement controls to ensure 

that it complies with HUD procurement and environmental 

review requirements.

0 

2016-LA-1006 6/3/2016 001-A 

Determine legal sufficiency and if legally sufficient, pursue 

remedies under the Program Fraud Civil Remedies Act for 

submitting misleading documentation to HUD associated with 

HUD OIG audit report 2009-LA-1020 and its original PHARS 

agreement.

0 

2016-LA-1006 6/3/2016 001-F 

Work with HUD on a disposition plan for the Authority’s former 

maintenance building including but not limited to selling the 

property for a fair and reasonable amount or entering into a fair 

market lease agreement that provides the Authority with income 

from the property and ensure the City follows all lease 

requirements including that the City pays for all associated 

alarm and utility costs.

0 

246 █

███ 246 246 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-LA-1006 6/3/2016 001-K Obtain HUD approval for its self-insured general liability policy 

and its participation in a risk pool not approved by HUD. 0 

2016-LA-1006 6/3/2016 001-N 

Work with HUD headquarters on corrective actions to improve

the Authority’s control and accountability regarding its finances 

and operations including but not limited to HUD receivership 

and/or separating the Authority’s finances from those of the 

City.

0 

2016-AT-1006 6/17/2016 001-D 

Continue to monitor the City to ensure it is effectively 

implementing its revised controls and processes throughout its 

HOME program.

0 

2016-AT-1007 6/22/2016 001-C Confirm that the City has implemented its revised written 

policies and procedures throughout its CDBG program. 0 

2016-SE-1002 6/23/2016 001-B 

Develop and implement written policies and procedures to 

ensure that distributions are made only from surplus cash and 

that it obtains approval from HUD before making repayment of 

advances when the project is in a non-surplus-cash position.

0 

2016-SE-1002 6/23/2016 002-B Obtain training to ensure that it properly implements HUD rules 

and regulations regarding procurement. 0 

2016-SE-1002 6/23/2016 002-C Develop and implement policies and procedures for procuring 

contractors which it will pay more than $10,000 in a year. 0 

2016-SE-1002 6/23/2016 003-D Obtain training to ensure that it properly implements HUD rules 

and regulations regarding disbursements from project funds. 0 

2016-SE-1002 6/23/2016 003-E Develop and implement controls to ensure that it follows HUD 

rules and its own policies and procedures for paying invoices. 0 

2016-SE-1002 6/23/2016 004-C Obtain training on HUD rules and regulations regarding Section 

8 housing assistance payments. 0 

2016-SE-1002 6/23/2016 004-D 

Develop and implement policies and procedures for monitoring 

its housing assistance payment claims and processing moveouts.0 

2016-SE-1002 6/23/2016 005-A Establish and implement written policies and procedures to 

record the date and time of tenant selection from its waiting list. 0 

2016-SE-1002 6/23/2016 005-B 

Establish and implement written policies and procedures to 

ensure check numbers, amounts, and payees are accurately 

recorded in its accounting system.

0 

2016-SE-1002 6/23/2016 005-D Establish and implement written policies and procedures to 

ensure that bank reconciliations are accurately performed. 0 

247 █

███ 247 247 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-SE-1002 6/23/2016 005-E 

Reperform its operating account bank reconciliations, beginning 

with the October 2012 statements, to reflect the accurate balance 

in its accounting system.

0 

2016-CH-1003 6/30/2016 001-B Reduce program income in HUD’s system by more than 

$293,000. 0 

2016-PH-0001 6/30/2016 001-C 

Develop and implement controls to ensure that it expeditiously 

takes action to enforce grantee compliance with monitoring 

findings or pursue one of the established remedies for 

noncompliance.

0 

2016-PH-0001 6/30/2016 001-G 

Direct field offices to include property acquisition and 

disposition activities as an area of special emphasis when 

assessing grantee risk and establishing their monitoring plans 

and grantee monitoring strategies.

0 

2016-FW-1004 7/27/2016 001-F 

We recommend that the Acting Director of the HUD Southwest 

Region Office of Multifamily Housing Programs require the 

Corporation to Repay the remaining balance of the judgment 

totaling $74,590 from nonproject funds.

0 

2016-CH-1004 7/28/2016 001-D 

Implement adequate procedures and controls to ensure that the 

Authority complies with HUD’s requirements for program 

conflicts of interest.

0 

2016-CH-1004 7/28/2016 001-E 

Work with the Authority to ensure that (1) additional funds are 

not inappropriately paid for program units, (2) rent 

reasonableness determinations are appropriate, and (3) the 

program units met HUD’s housing quality standards for the units 

cited in this finding.

0 

2016-CH-1004 7/28/2016 002-F 

Implement adequate procedures and controls to ensure that (1) 

required eligibility documentation is obtained and maintained; 

(2) housing assistance payments contracts are executed in a 

timely manner; and (3) housing assistance payments are 

appropriately calculated, supported, and paid.

0 

2016-CH-1004 7/28/2016 002-G 

Implement adequate procedures and controls to ensure that (1) 

program funds are used for eligible expenditures and (2) 

documentation to support its expenditures is maintained.

0 

2016-CH-1004 7/28/2016 002-H 

Implement adequate procedures and controls to ensure that 

utility reimbursements are appropriately refunded to program 

households when the utility reimbursement payments to utility 

companies exceed the actual utility costs.

0 

248 █

███ 248 248 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-CH-1004 7/28/2016 002-I 

Implement adequate procedures and controls to ensure that 

administrative service charges for functions related to the 

Housing Choice Voucher program are not passed to the 

landlords and household for the normal costs of doing Authority 

business.

0 

2016-CH-1004 7/28/2016 002-J 

Ensure staff is trained and familiar with HUD’s regulations and 

the Authority’s own requirements including, but not limited to 

appropriately (1) managing its program waiting list, (2) applying 

local preferences, and (3) ensuring 24-hour exigent health-and 

safety-related violations are corrected within 24 hours, or 

appropriate extensions are documented.

0 

2016-CH-1004 7/28/2016 002-K 

Work with the Authority to determine whether program 

households are admitted in accordance with HUD’s program 

requirements and if not, consider a referral to HUD’s Office of 

Fair Housing and Equal Opportunity.

0 

2016-CH-1004 7/28/2016 002-L 

Work with the Authority to determine whether it is appropriate 

to require households to obtain and pay for criminal background 

checks. If it is determined to not be appropriate, the Director 

should ensure that the Authority (1) provides background checks 

for all future applicants, (2) determines the number of 

households affected, and (3) reimburses the affected households 

as appropriate from program funds.

0 

2016-PH-0003 7/29/2016 001-E 

Take appropriate administrative action against the lenders and 

appraisers for any cases (identified through recommendations 

1A through 1D) where it finds that they did not take appropriate 

steps to ensure that properties had a safe and potable water 

source.

0 

2016-PH-0003 7/29/2016 001-F 

Improve its controls to ensure that it does not insure additional 

loans in Flint for properties that do not have a safe and potable 

water source. These controls could include updating its 

endorsement or monitoring processes until the water 

contamination issue has been resolved in Flint.

0 

2016-AT-1009 8/2/2016 001-E 

Pursue double damages remedies against the responsible parties 

for the ineligible, unreasonable, and the applicable portion of the 

unsupported disbursements that was used in violation of the 

project’s regulatory agreement.

0 

2016-AT-1009 8/2/2016 001-F 

Pursue civil money penalties and administrative sanctions 

against the responsible parties for mismanagement of project 

funds and noncompliance with the regulatory agreement and 

HUD’s requirements.

0 

249 █

███ 249 249 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-CH-1005 8/3/2016 001-B 

Update its expected energy savings – the total contract amount 

to include change orders – and provide supporting 

documentation to HUD for approval to ensure that the remaining 

contract amount is appropriately approved.

0 

2016-AT-1010 8/4/2016 001-B 

Require the Housing Board to update its books, records, and 

policies and procedures to identify its nonprofit; Mobile 

Development Enterprises as an instrumentality per applicable 

HUD regulations, to prevent a future, actual or apparent conflict 

of interest between the Housing Board, its nonprofit, and other 

contractors.

0 

2016-AT-1010 8/4/2016 001-C 

Require the Housing Board to work with HUD to ensure that it 

meets the conditions of its RAD approval to ensure that the 

Housing Board’s units are made available for eligible families.

0 

2016-AT-1010 8/4/2016 001-D 

Take appropriate enforcement action against the Housing 

Board’s management staff for failing to disclose the 

instrumentality relationship between the Housing Board and the 

Mobile Development Enterprises, if a conflict of interest exists.

0 

2016-NY-1009 8/12/2016 001-B 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs direct State officials to obtain independent cost 

estimates before receiving bids or proposals for contract 

procurement.

0 

2016-NY-1009 8/12/2016 001-C 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs direct State officials to include complete 

budgets in written subrecipient agreements to ensure that 

CDBG-DR funds are used for their intended purpose.

0 

2016-LA-1007 8/17/2016 001-D 

Establish and implement program-specific written policies and 

procedures to ensure that all program expenses and projects 

comply with program rules and requirements.

0 

2016-LA-1007 8/17/2016 001-E Provide training to program staff on program rules and 

requirements. 0 

2016-LA-1007 8/17/2016 002-B Terminate the contract with the subrecipient and stop all 

remaining payments for the project. 0 

2016-LA-1007 8/17/2016 002-C 

Establish and implement written policies and procedures and 

monitor its subrecipients to minimize any future instances of 

potential conflicts of interest that violate program rules and 

requirements, agreements, and the City’s own procurement 

policies and procedures.

0 

2016-CH-1006 8/23/2016 001-B 

Complete background checks for program household members 

that are 18 years of age or older and ensure that all households 

receive a criminal background and sex offender registry check 

before admission to the program.

0 

250 █

███ 250 250 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-CH-1006 8/23/2016 001-D 

For the household residing in a unit that was not affordable, 

renegotiate the rent to the owner or require the household to 

move into a unit that is affordable.

0 

2016-CH-1006 8/23/2016 001-E 

Implement adequate procedures and controls to ensure that (1) 

required eligibility documentation is obtained and maintained 

and (2) program households reside in units that are affordable.

0 

2016-CH-1006 8/23/2016 001-J 

Review the remaining 35 (38-3) zero-income households to 

determine whether additional households had income and if so, 

take appropriate actions to recover any overpaid housing 

assistance and utility allowance payments.

0 

2016-CH-1006 8/23/2016 001-L 

Implement adequate procedures and controls to ensure that 

duplicate payments of housing assistance are not made to 

program landlords.

0 

2016-CH-1006 8/23/2016 001-N 

Implement adequate procedures and controls to ensure that fees 

for missed housing quality standards inspections are not charged 

to the program households.

0 

2016-CH-1006 8/23/2016 002-C 

Implement adequate procedures and controls to ensure that the 

Authority reviews HUD’s system report during the 

reexamination process and that appropriate actions are taken 

when income discrepancies exceeding HUD’s threshold are 

discovered during the examination process or during its review 

of the individual income reports.

0 

2016-CH-1006 8/23/2016 002-D 

Review the remaining 46 (58-12) households on HUD’s system 

income discrepancy report to determine whether additional 

households have valid income discrepancies and if so, take 

appropriate actions to recover any overpaid housing assistance 

and utility allowance payments.

0 

2016-CH-1006 8/23/2016 003-A Establish a program coordinating committee. 0 

2016-CH-1006 8/23/2016 003-B 

Determine the actual number of active, graduated, and 

terminated participants on its program and provide the 

documentation to HUD for review.

0 

2016-CH-1006 8/23/2016 003-E 

Complete program applications and family needs assessments 

and execute appropriate (1) contracts of participation and (2) 

individual training and services plans for all active program 

participants.

0 

2016-CH-1006 8/23/2016 003-F 

Implement adequate procedures and controls to ensure that all 

required documentation is complete, accurate, and maintained in 

the participants’ files to support program eligibility.

0 

251 █

███ 251 251 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-CH-1006 8/23/2016 003-J 

Implement adequate procedures and controls and a corrective 

action plan for its program to ensure that the program is 

appropriately administered, including but not limited to ensuring 

that (1) escrow accounts are appropriately established, (2) 

monthly escrows are appropriately calculated and entered into 

the Authority’s subsidiary ledgers, (3) forfeited escrow balances 

are returned to the Housing Choice Voucher program bank 

account timely, and (4) its program bank account is 

appropriately maintained.

0 

2016-CH-1006 8/23/2016 003-K 

Review the Authority’s Section 8 Management Assessment 

Program results and consider revising its designation and if 

warranted, conduct a confirmatory review of its scoring process.

0 

2016-FO-0802 8/26/2016 001-A 

Identify the universe of all program obligations and 

disbursements, including the appropriations account level of 

obligations and outlays by program activity and by object class 

for compliant USASpending.gov reporting.

0 

2016-FO-0802 8/26/2016 001-B 

Prepare and execute a plan to resolve errors already identified in 

programmatic expenditure information transferred to 

USASpending.gov before full implementation and ensure that 

similar types of errors are timely identified and promptly 

resolved prior to implementation.

0 

2016-FO-0802 8/26/2016 001-D Complete the project plan documentation for the FHA and 

Ginnie Mae components. 0 

2016-LA-1008 8/26/2016 001-F 

Implement additional written controls to ensure that 

management and ownership follow the project’s policies and 

procedures, the regulatory agreement, and HUD program 

requirements.

0 

2016-LA-1008 8/26/2016 001-G 

Pursue civil and administrative remedies, as appropriate, against 

the owners of Dolores Frances for making ineligible payments 

using project funds and securing loans that encumbered the 

properties of Dolores Frances without HUD approval.

0 

2016-LA-1009 8/26/2016 001-E 

Review all current CDBG-funded projects, open CDBG 

projects, and projects subject to CDBG use restrictions for 

unreported program income. If the City and HUD determine 

that there was unreported program income for the audit period or 

CDBG use restriction period, the City should report the program 

income to HUD and record receipt of the CDBG program 

income in the Integrated Disbursement and Information System.

0 

2016-LA-1009 8/26/2016 001-G 

Develop citywide written policies and procedures that govern 

the CDBG program and ensure compliance with CDBG 

requirements.

0 

252 █

███ 252 252 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-LA-1009 8/26/2016 001-H 

Implement adequate controls to ensure compliance with 

applicable regulations related to cost eligibility, procurement, 

and program income for any further activities involving the use 

of CDBG funding.

0 

2016-LA-1009 8/26/2016 001-I 

Implement adequate controls to ensure compliance with the 

City’s own process for awarding HUD funding and to ensure 

that potential conflicts of interest are mitigated to protect 

procurement integrity.

0 

2016-AT-1012 8/29/2016 001-A 

Complete the implementation of the new accounting system and 

ensure it tracks program funds to a level that supports 

compliance with HUD requirements.

0 

2016-DP-0003 8/31/2016 001-D Not released to public. 0 

2016-DP-0003 8/31/2016 002-B Not released to public. 0 

2016-DP-0003 8/31/2016 002-C Not released to public. 0 

2016-DP-0003 8/31/2016 003-A Not released to public. 0 

2016-DP-0003 8/31/2016 003-B Not released to public. 0 

2016-DP-0003 8/31/2016 003-C Not released to public. 0 

2016-DP-0003 8/31/2016 003-D Not released to public. 0 

2016-DP-0003 8/31/2016 003-E Not released to public. 0 

2016-DP-0003 8/31/2016 003-F Not released to public. 0 

2016-DP-0003 8/31/2016 003-G Not released to public. 0 

2016-DP-0003 8/31/2016 003-H Not released to public. 0 

2016-DP-0003 8/31/2016 003-I Not released to public. 0 

2016-DP-0003 8/31/2016 003-J Not released to public. 0 

2016-DP-0003 8/31/2016 003-K Not released to public. 0 

2016-DP-0003 8/31/2016 003-L Not released to public. 0 

2016-DP-0003 8/31/2016 003-N Not released to public. 0 

2016-DP-0003 8/31/2016 003-O Not released to public. 0 

2016-DP-0003 8/31/2016 003-P Not released to public. 0 

2016-DP-0003 8/31/2016 003-Q Not released to public. 0 

2016-DP-0003 8/31/2016 003-R Not released to public. 0 

253 █

███ 253 253 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-DP-0003 8/31/2016 004-B Not released to public. 0 

2016-DP-0003 8/31/2016 004-D Not released to public. 0 

2016-DP-0003 8/31/2016 004-E Not released to public. 0 

2016-FW-1006 8/31/2016 001-B 

We recommend that the Director of HUD’s Office of Block 

Grant Assistance require the State to ensure that the Parish 

obtains additional documentation to support eligibility for the 28 

program participant files that did not have adequate 

documentation to support program eligibility or amend the 

eligibility determination.

0 

2016-FW-1006 8/31/2016 001-C 

We recommend that the Director of HUD’s Office of Block 

Grant Assistance require the State to ensure that the Parish 

reviews the remaining 293 program participant files for its 

homeowner rehabilitation, housing elevation, home-buyer 

assistance, and small rental rehabilitation programs to ensure 

that documentation complies with HUD and program 

requirements and to support the eligibility determinations.

0 

2016-FW-1006 8/31/2016 001-E 

We recommend that the Director of HUD’s Office of Block 

Grant Assistance require the State to provide assistance to the 

Parish regarding procurement requirements to ensure 

compliance with requirements for future procurement activities 

related to CDBG disaster assistance contracts.

0 

2016-FW-1006 8/31/2016 001-F 

We recommend that the Director of HUD’s Office of Block 

Grant Assistance require the State to review and evaluate the 

Parish’s procurement policy to ensure compliance with 24 CFR 

85.36 requirements and that the Parish amends its procurement 

policy to include clear language requiring that its staff perform 

independent cost estimates before receiving bids or proposals for 

every procurement.

0 

2016-FW-1006 8/31/2016 001-H 

We recommend that the Director of HUD’s Office of Block 

Grant Assistance require the State to review the Parish’s written 

financial management policy for compliance with HUD and 

program requirements and ensure that the Parish amends its 

policy to incorporate requirements to comply with State policy 

when applicable.

0 

2016-PH-1006 8/31/2016 001-E Provide documentation to show that it verified the value of the 

matching in-kind contributions identified in the audit report. 0 

2016-PH-1006 8/31/2016 001-G Develop and implement controls to ensure that in-kind 

contribution amounts are verified. 0 

2016-PH-1006 8/31/2016 001-H 

Provide technical assistance to the Authority to ensure that its 

administration of its ROSS grants complies with applicable 

requirements.

0 

254 █

███ 254 254 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-LA-1011 9/12/2016 001-A 

Work with HUD to nullify the restrictions on conveyance that 

violate HUD policy or indemnify HUD. This action will protect 

HUD against future losses of $867,134 for the 14 loans 

(appendix F).

0 

2016-LA-1011 9/12/2016 001-C 

Develop and implement procedures to ensure that it reviews all 

closing documents, including closing documents for second 

mortgages associated with downpayment assistance, before 

closing the loan.

0 

2016-LA-1011 9/12/2016 001-D 

Ensure that it has adequately trained its employees regarding 

HUD underwriting requirements, including calculating 

commission and overtime income, identifying irregularities and 

red flags, and unallowable restrictions on conveyance.

0 

2016-LA-1011 9/12/2016 001-E 

Determine legal sufficiency and if legally sufficient, pursue civil 

and administrative remedies, civil money penalties, or both 

against Evergreen, its principals, or both for incorrectly 

certifying to the integrity of the data, the eligibility for FHA 

mortgage insurance, or that due diligence was exercised during 

the origination of FHA loans.

0 

2016-NY-0001 9/12/2016 001-C 

We recommend that the Director of the Public Housing 

Financial Management Division continue to implement the 

reconciliation software application to provide greater assurance 

that Operating Fund calculations are based on correct data.

0 

2016-NY-0001 9/12/2016 001-E 

We recommend that the Director of the Public Housing 

Financial Management Division strengthen controls to ensure 

that files maintained at Headquarters are complete.

0 

2016-NY-0001 9/12/2016 001-G 

We recommend that the Director of the Public Housing 

Financial Management Division strengthen controls to ensure 

that the units funded under the Operating Fund program do not 

exceed the PHA’s Faircloth limit.

0 

2016-NY-0001 9/12/2016 001-I 

We recommend that HUD’s Deputy Assistant Secretary of the 

Office of Field Operations develop and implement procedures to 

conduct a more detailed review of the PHA self-certified unit 

months and utility costs data and strengthen controls to ensure 

that field office staff follow the established verification 

procedures Operating Fund calculations.

0 

2016-SE-1003 9/12/2016 001-D 

Recalculate the housing assistance charged for the 35 units not 

sampled during our audit, reimburse HUD for any overcharged 

assistance amounts, provide support for any unsupported 

amounts, and reimburse tenants for any overcharged rents.

0 

255 █

███ 255 255 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-SE-1003 9/12/2016 001-E 

Conduct periodic reviews of tenant files to ensure that its 

manager correctly calculates the housing assistance payments 

and adequately documents completion of the required annual 

recertifications.

0 

2016-SE-1003 9/12/2016 002-B 

Provide technical assistance to ensure that Solace’s manager 

understands the requirements in the Monthly Activity 

Transmission Guide, paragraph 7-12(E), and review Solace’s 

tenant files 1 year later to determine whether this requirement is 

understood and being followed.

0 

2016-SE-1003 9/12/2016 002-C 

Require Solace to review the 49 tenant files not sampled during 

our audit, determine whether HUD paid additional housing 

assistance for tenants after they had moved out, and have Solace 

reimburse HUD for any additional post-move-out assistance it 

paid.

0 

2016-SE-1003 9/12/2016 002-D 

Require Solace to conduct periodic reviews of tenant files to 

ensure that its manager does not request assistance from HUD 

for tenants after they have moved out.

0 

2016-SE-1004 9/12/2016 001-D 

Conduct periodic reviews of tenant files to ensure that its 

manager or management agent maintains the tenant files, 

completes the required annual recertifications, and adequately 

supports hardship exemptions in accordance with HUD 

requirements.

0 

2016-AT-1013 9/13/2016 001-B 

Ensure that housing quality standards violations identified for 

the 56 units were corrected and certify that the units meet 

HUD’s housing quality standards.

0 

2016-AT-1013 9/13/2016 001-D 

Fully implement its quality control inspection procedures to 

ensure that supervisory inspections are used to determine 

whether individual performance or training issues need to be 

addressed and ensure consistency among the Authority’s 

inspectors when applying HUD’s housing quality standards.

0 

2016-AT-1013 9/13/2016 002-C 

Develop and implement quality control procedures to ensure that 

its staff complies with HUD regulations and its administrative 

plan.

0 

2016-AT-1013 9/13/2016 002-E 

Continue providing training to ensure that its staff administers 

its Housing Choice Voucher program in compliance with HUD 

regulations and its administrative plan.

0 

2016-DP-0004 9/20/2016 001-A Not released to public. 0 

2016-DP-0004 9/20/2016 001-B Not released to public. 0 

2016-DP-0004 9/20/2016 001-E Not released to public. 0 

256 █

███ 256 256 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-DP-0004 9/20/2016 001-F Not released to public. 0 

2016-KC-0002 9/21/2016 001-A Establish a maximum time that loans may remain pooled 

without insurance. 0 

2016-PH-1007 9/27/2016 001-B Develop and implement controls to ensure that it complies with 

all applicable procurement requirements. 0 

2016-PH-1007 9/27/2016 001-C Provide training to all employees involved in the procurement 

process.

0 

2016-PH-1007 9/27/2016 001-D Provide technical assistance to the Authority to ensure that it 

properly conducts its procurement activities. 0 

2016-CH-1007 9/28/2016 001-B 

Ensure that the independent third parties complete the remaining 

housing quality standards inspections and rent reasonableness 

determinations and continue to perform housing quality 

standards inspections and rent reasonableness determinations for 

the units owned by entities that the Authority substantially 

controls.

0 

2016-CH-1007 9/28/2016 002-F 

Implement the procedures and controls it developed to ensure 

that (1) documentation required by HUD is correctly completed 

and maintained, (2) escrow account balances are correctly 

calculated and recorded, and (3) escrow account disbursements 

are fully supported.

0 

2016-DE-1005 9/28/2016 001-C 

Require the Authority to develop and implement detailed 

policies and procedures for the procurement process regarding 

inspections, competitive bidding, and sealed bids. HUD should 

ensure that these procedures include adequate separation of 

duties.

0 

2016-DE-1005 9/28/2016 001-D 

Require the Authority to develop and implement an official drug 

testing and remediation policy. This policy should include 

procurement of any goods and services related to the testing and 

mitigation and a determination of when drug testing is needed.

0 

2016-DE-1005 9/28/2016 002-D 

Require the Authority to develop and implement a travel policy 

that reflects Federal travel regulations and guidelines when using 

Federal funds for travel purposes.

0 

2016-DE-1005 9/28/2016 002-E 

Require the Authority to develop and implement a policy that 

requires more oversight of the approval of travel authorizations 

and travel vouchers.

0 

2016-KC-1005 9/28/2016 001-C Implement a detailed tracking system to ensure that it properly 

tracks activities. 0 

2016-KC-1005 9/28/2016 001-D Receive training on salary distribution methods and 

documentation requirements for Federal grants. 0 

257 █

███ 257 257 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-KC-1005 9/28/2016 001-E Receive monitoring by the appropriate grantee to ensure that it 

establishes and implements a new activity tracking system. 0 

2016-KC-1005 9/28/2016 002-B Receive conflict-of-interest training that addresses Federal 

regulations. 0 

2016-KC-1005 9/28/2016 002-C 

Receive monitoring by the appropriate grantee to ensure that it 

establishes and implements detailed NSP policies and 

procedures, checklists, and applications that require City 

employees or applicants to disclose potential conflict-of-interest 

relationships.

0 

2016-KC-1005 9/28/2016 003-D 

Receive monitoring by the appropriate grantee to ensure that it 

develops a system to receive NSP policy alerts and other related 

guidance.

0 

2016-KC-1005 9/28/2016 004-B 

Receive monitoring by the appropriate grantee to ensure that its 

waiting list policies and procedures are implemented and the 

NSP waiting list is accurate and updated.

0 

2016-KC-1006 9/28/2016 001-B Provide Section 3 technical assistance to the City and monitor 

the City’s compliance with Section 3 requirements. 0 

2016-CF-1812 9/29/2016 001-A Acknowledge that the attached settlement agreement for $5,000 

represents an amount due HUD from the real estate agent. 0 

2016-CF-1812 9/29/2016 001-C Acknowledge that the attached settlement agreement for $1,000 

represents an amount due HUD from the second borrower. 0 

2016-CH-1008 9/29/2016 001-A 

Certify and provide supporting documentation showing that the 

applicable property preservation and protection deficiencies 

have been corrected for the 105 properties cited in this finding.

0 

2016-CH-1008 9/29/2016 001-E 

Implement the improved quality control procedures to ensure 

that property preservation and protection services are performed 

in accordance with its contract with HUD and its own 

requirements, including but not limited to ensuring that (1) it 

provides proper supervision and oversight of its subcontractors 

and (2) supervisory quality control inspections are completed 

and feedback is provided to the subcontractors to correct 

recurring deficiencies.

0 

2016-CH-1008 9/29/2016 001-F 

Implement procedures and controls to ensure that it manually 

removes properties from its monthly field service manager batch 

billing transmittals to HUD, when HUD asks that services not be 

provided for a particular property that is in PKMG’s active 

inventory.

0 

2016-NY-1010 9/29/2016 001-A 

We recommend that the Director of HUD’s Office of Residential 

Care Facilities instruct project officials to develop an adequate 

liquidation plan related to the two mortgages assigned to HUD.

0 

258 █

███ 258 258 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-NY-1010 9/29/2016 001-D 

We recommend that the Director of HUD’s Office of Residential 

Care Facilities instruct project officials to submit an acceptable 

change in operator to protect HUD’s interest in the properties.

0 

2016-NY-1010 9/29/2016 001-E 

We recommend that the Director of HUD’s Office of Residential 

Care Facilities instruct project officials to seek HUD’s approval 

before repaying loan advances to affiliated companies.

0 

2016-NY-1010 9/29/2016 001-F 

We recommend that the Director of HUD’s Office of Residential 

Care Facilities instruct project officials to strengthen controls to 

provide greater assurance that disbursements for project 

expenses comply with the regulatory agreements.

0 

2016-NY-1010 9/29/2016 001-G 

We also recommend that the Director of HUD’s Departmental 

Enforcement Center, in coordination with the Director of HUD’s 

Office of Residential Care Facilities pursue double damages 

remedies against the responsible parties for the disbursements 

made in violation of the projects’ regulatory agreements.

0 

2016-NY-1010 9/29/2016 001-H 

We further recommend that the Director of HUD’s Departmental 

Enforcement Center pursue civil money penalties and 

administrative sanctions, as appropriate, up to and including 

debarment, against responsible parties for their part in the 

regulatory violations cited in this report.

0 

2016-PH-0005 9/29/2016 001-B 

For each State grantee that did not meet the stated requirements 

to demonstrate that its procurement process was proficient, 

review procurement files for contracts that were paid with funds 

provided under the Disaster Relief Act and if the procurement 

did not comply with Federal procurement requirements, require 

the grantees to repay HUD from non-Federal funds for any 

amounts that (1) they cannot support or (2) were not fair and 

reasonable.

0 

2016-PH-0005 9/29/2016 001-C 

Continue to improve the guidance that it provides to grantees to 

ensure that future grantee certifications are accurate and 

supported.

0 

2016-PH-0005 9/29/2016 001-D 

Continue to improve its controls to ensure that its staff 

adequately understands and reviews future grantee certifications 

to ensure that they are accurate and supported before certifying 

that grantees have a proficient procurement process.

0 

2016-PH-0005 9/29/2016 001-E Increase monitoring of State grantees that selected the 

equivalency option. 0 

2016-PH-1008 9/29/2016 001-A 

Certify, along with the owners of the 56 units cited in the 

finding, that the applicable housing quality standards violations 

have been corrected.

0 

259 █

███ 259 259 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-PH-1008 9/29/2016 001-C 

Submit a request for approval of an independent entity to 

perform housing quality standards inspections of units that it 

owns.

0 

2016-PH-1008 9/29/2016 001-D 

Develop and implement procedures to ensure that the required 

number of quality control inspections are conducted and that the 

results of those inspections are used to improve the effectiveness 

of its housing quality standards inspections.

0 

2016-PH-1008 9/29/2016 001-F 

Evaluate its inspection contract to ensure that it provides 

sufficient resources to the inspectors that will result in thorough 

unit inspections.

0 

2016-AT-1014 9/30/2016 001-C 

Ensure that its staff is trained and familiar with HUD’s and the 

Authority’s requirements for proper calculation of housing 

assistance payments.

0 

2016-AT-1014 9/30/2016 001-D 

Develop and implement written controls consistent with HUD’s 

regulations that require the Authority to monitor and resolve 

EIV income discrepancies.

0 

2016-AT-1014 9/30/2016 001-E 

Review, verify, and resolve the substantial underreporting of 

tenant annual income identified on the April 20, 2016, EIV 

income discrepancy report. Any overpayments should be 

reimbursed to its program from non-Federal funds.

0 

2016-AT-1014 9/30/2016 001-F 

Ensure that its staff is trained and familiar with HUD’s 

requirements regarding the mandatory use of HUD’s EIV 

system.

0 

2016-AT-1014 9/30/2016 001-G 

Develop and implement controls to ensure that EIV income 

reports are retained for at least 3 years from the effective date of 

action and the Authority’s records management is consistent 

with other HUD privacy and data security requirements, such as 

the HUD EIV security procedures.

0 

2016-CH-1009 9/30/2016 001-A 

Obtain ownership of the 8 units owned by the Preservation 

Association and assume the promissory notes secured by 

mortgages payable to the Preservation Association for the 60 

units that were to be owned by Condominium Association 

members.

0 

2016-CH-1009 9/30/2016 001-B 

Implement adequate procedures and controls to ensure that when 

applicable, the Condominium Association, rather than the 

Preservation Association, (1) purchases units from the owners, 

(2) takes title to the units, (3) assumes the promissory notes 

secured by mortgages payable to HUD, and (4) enters into 

promissory notes secured by mortgages payable to the 

Condominium Association with the purchasers of the units.

0 

260 █

███ 260 260 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-CH-1009 9/30/2016 001-C Have a representative of HUD at the closing for unit sales to 

sign the HUD notes. 0 

2016-CH-1009 9/30/2016 001-G 

Provide sufficient documentation to support that HUD had 

received 50 percent of the proceeds from initial unit sales as of 

June 2016. If the Condominium Association cannot do this, it 

should pay HUD half of the principal on the promissory notes 

payable to the Condominium Association for all unit sales less 

the amount the Condominium Association can support that it 

paid HUD for initial unit sales.

0 

2016-CH-1009 9/30/2016 001-I 

Establish and maintain a reserve account for its share of the 

proceeds from initial unit sales to be used as required by the 

grant agreement.

0 

2016-CH-1009 9/30/2016 001-M 

Determine who has the right to ownership of the unit where the 

sole owner passed away, transfer ownership of the unit to that 

person, and require him or her to move into or sell the unit.

0 

2016-CH-1009 9/30/2016 001-O 

Require the two owners that did not maintain their unit at the 

project as their principal residence to move back into or sell their 

unit.

0 

2016-CH-1009 9/30/2016 001-Q 

Ensure that the unit that it is using as an office and meeting 

space is in a decent, safe, and sanitary condition and then rent 

the unit to a very low-, low-, or moderate-income household 

selected from a waiting list for rental units that meets the 

requirements of the resident home-ownership plan.

0 

2016-CH-1009 9/30/2016 001-T 

Ensure that appraisals are conducted of the seven units sold 

since May 2012 to determine the fair market value of the units at 

the time of sale. If any of the units sold for more than the fair 

market value, HUD should require the Condominium 

Association to (1) reduce the purchase price of the units to the 

fair market value by reducing the promissory notes payable to 

the Preservation Association and reimbursing the owners for 

overpayments on the downpayments and notes as appropriate 

and (2) release the promissory notes payable to HUD. If any of 

the units sold for less than the fair market value and the 

promissory notes payable to HUD do not reflect the difference 

between the fair market value of the units and the purchase 

price, HUD should require the Condominium Association to 

amend the promissory notes payable to HUD as appropriate. 

Further, for the three subsequent unit sales, HUD should require 

the Condominium Association to remit to the City any net 

proceeds that it should have paid to the City’s HOME 

investment trust fund.

0 

261 █

███ 261 261 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2016-CH-1012 9/30/2016 001-G 

Implement adequate procedures and controls to ensure that the 

proper documentation is maintained and contracts are procured 

and administered in accordance with HUD’s and the Authority’s 

procurement requirements. Such procedures and controls should 

include but not be limited to providing training to its contract 

officer(s) on HUD’s and the Authority’s procurement 

requirements.

0 

2016-FW-1010 9/30/2016 001-C 

We recommend that the Acting Deputy Assistant Secretary for 

Grant Programs require the State to review and document State 

determination of compliance with procurement, contract, and 

environmental requirements for its subrecipients.

0 

2016-FW-1010 9/30/2016 001-D 

We recommend that the Acting Deputy Assistant Secretary for 

Grant Programs require the State to collect, review, and verify 

supporting source documents for all requests for funds to ensure 

it supports the expenditure as appropriate for the activity in 

question.

0 

2016-FW-1010 9/30/2016 001-E 

We recommend that the Acting Deputy Assistant Secretary for 

Grant Programs require the State to document all State 

procedures performed to verify the appropriateness and accuracy 

of all subrecipient documentation submitted for payment of 

program expenditures.

0 

2016-FW-1010 9/30/2016 001-F 

We recommend that the Acting Deputy Assistant Secretary for 

Grant Programs require the State to support or repay $4,394,552 

in unsupported expenditures.

0 

2016-PH-1009 9/30/2016 001-F 

Provide documentation showing that the amount it paid under 

the contract was reasonable and necessary or repay HUD from 

non-Federal funds any amount that it cannot support.

0 

2016-PH-1009 9/30/2016 001-G 

Provide documentation to show that it has complete and up-todate inventory and equipment records for all items purchased 

under the contract in accordance with its property management 

and disposition policy.

0 

2016-PH-1009 9/30/2016 001-H 

Implement policies and procedures to ensure that it adequately 

administers current and future contracts related to disaster funds 

and disburses funds for costs that are eligible, supported, 

reasonable, and necessary.

0 

2016-PH-1009 9/30/2016 001-I 

Implement policies and procedures to ensure that it monitors 

contract performance related to disaster funds and takes 

appropriate action when contractors fail to meet performance 

goals contained in the contract terms.

0 

262 █

███ 262 262 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-KC-0001 10/14/2016 001-B 

Develop a strategic information technology plan to make 

significant operational changes to HUD’s monitoring of singlefamily conveyance claims to ensure that servicers comply with 

foreclosure and conveyance timeframes.

0 

2017-KC-0001 10/14/2016 001-C Develop and implement controls to identify noncompliance with 

current regulations at 24 CFR 203.402. 0 

2017-CH-0001 10/25/2016 001-C Deposit the $367,645 in capital funds into the reserve for 

replacements accounts for the six projects. 0 

2017-CH-0001 10/25/2016 001-D 

Review the remaining eight projects with $79,735 in the 

projects’ grant accounts (17 projects with more than $1.6 million 

in the projects’ grant accounts – nine projects reviewed with 

more than $1.5 million in the projects’ grant accounts) and 

determine whether it is appropriate for the funds to be in the 

projects’ grant accounts. If the funds should not be in the 

projects’ grant accounts, HUD should take the proper corrective 

actions.

0 

2017-NY-1001 11/2/2016 001-B 

We recommend that HUD’s Acting Deputy Assistant Secretary 

for Grant Programs instruct City officials to execute new grant 

agreements to show material changes in grant amounts resulting 

from duplication of benefits recalculations.

0 

2017-NY-1001 11/2/2016 002-A 

We recommend that HUD’s Acting Deputy Assistant Secretary 

for Grant Programs coordinate with the Office of Healthy 

Homes and Lead Hazard Control to provide technical assistance 

and instruct City officials to ensure that Program files clearly 

identify whether a home required lead-based paint testing. 

When such testing is performed, City officials should ensure that 

the testing results are documented, identified lead-based paint 

hazards are removed, and clearance is achieved.

0 

2017-NY-1001 11/2/2016 002-D 

We recommend that HUD’s Acting Deputy Assistant Secretary 

for Grant Programs coordinate with the Office of Healthy 

Homes and Lead Hazard Control to provide technical assistance 

and instruct City officials to advise homeowners of their 

obligation under the terms of the reimbursement grant agreement 

to allow the Program to perform lead-based paint testing or 

hazard removal. Homeowners who refuse to allow the Program 

to complete lead hazard work or provide evidence that the 

property achieved clearance must repay the grant.

0 

263 █

███ 263 263 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-NY-1001 11/2/2016 003-A 

We recommend that HUD’s Acting Deputy Assistant Secretary 

for Grant Programs instruct City officials to complete the 

planned document and data cleanup process in CMS before file 

closeout to ensure that duplicative documents are archived, the 

most recent documents are identified and filed in the appropriate 

subfolders, and all files are auditable and comply with the 

requirements and the City’s record-keeping procedures.

0 

2017-NY-1001 11/2/2016 003-B 

We recommend that HUD’s Acting Deputy Assistant Secretary 

for Grant Programs instruct City officials to ensure that all 

financial reports are accurate and agree with supporting 

documentation in the Program files.

0 

2017-NY-1001 11/2/2016 003-C 

We recommend that HUD’s Acting Deputy Assistant Secretary 

for Grant Programs instruct City officials to update the 

Coordination of Benefits Standard Operating Procedures to 

include definitions of SBA cancellation codes.

0 

2017-FO-0001 11/14/2016 002-A 

Update Ginnie Mae’s cash and cash equivalents accounting 

policies and procedures to ensure that its cash-in-transit balance 

is properly accounted for.

0 

2017-FO-0001 11/14/2016 002-B Review the cash and cash equivalents account and determine the 

appropriate adjustments needed to correct the misstatement. 0 

2017-FO-0001 11/14/2016 002-C 

Revisit the REMIC accounting adjustments made in fiscal year 

2015 based on the points cited in this finding to determine 

appropriate accounting adjustments. At a minimum, Ginnie Mae 

should: Conduct a review of invoice documents for each 

REMIC deal to determine the appropriate amount of upfront 

costs that should be included in the incurred cost ratio 

calculation, Review source data to ensure the accuracy of the 

weighted average maturity data used in its analysis, Determine 

the appropriate incurred cost ratio for REMIC deals from the 

1994 to 2013 cohort years based on reasonable and acceptable 

methodology, and Review source data for deals issued between 

1994 and 2013 to ensure the accuracy of the guarantee fees data 

used in its analysis.

0 

2017-FO-0001 11/14/2016 002-D 

Establish and implement policies and procedures to ensure that 

proper accrual accounting entries are made to record the 

accounting event related to closed REMIC deals at the end of 

each month.

0 

2017-FO-0001 11/14/2016 002-E 

Review the revenue account balances based on points cited 

related to the improper accruals of REMIC deals and determine 

the appropriate adjustments needed to correct the misstatement.

0 

264 █

███ 264 264 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-FO-0001 11/14/2016 002-G 

Establish and implement policies and procedures to ensure that a 

subledger is maintained to accurately account for the advances 

balances at a loan level.

0 

2017-FO-0001 11/14/2016 002-H 

Enhance existing policies and procedures for its fixed assets, to 

include systems, processes, and controls, to ensure (1) proper 

review of invoices to determine whether costs are capitalized or 

expensed in accordance with GAAP, (2) development costs are 

capitalized when incurred, and (3) book value is consistent 

across all documents.

0 

2017-FO-0001 11/14/2016 002-I 

Establish and implement controls to ensure that escrow and 

outstanding MBS commitment balances reported in the financial 

statements are accurate and complete.

0 

2017-FO-0001 11/14/2016 002-J 

Establish and implement procedures and controls to ensure that 

indemnification or repurchase agreements (guarantees) are 

properly accounted for and disclosed in the financial statements 

in accordance with GAAP.

0 

2017-FO-0001 11/14/2016 002-K 

Establish and implement adequate procedures and controls to 

ensure that information related to mortgages held for investment 

and the associated allowance for loan losses are adequately 

disclosed in the notes to the financial statements in accordance 

with GAAP.

0 

2017-FO-0001 11/14/2016 003-A Adjust the reimbursable costs out of the allowance accounts as 

appropriate. 0 

2017-FO-0001 11/14/2016 003-B 

Exclude the loan impairment allowance on other indebtedness 

appropriately instead of reporting it as part of loan impairment 

allowance on MHI account.

0 

2017-FO-0001 11/14/2016 003-C 

Document Ginnie Mae’s analysis and support for the 

categorization of its loans for loan impairment purposes and 

update accounting policies and procedures based on this 

analysis.

0 

2017-FO-0001 11/14/2016 003-D 

Modify, as appropriate, the TDR allowance model to ensure 

production of reasonable and appropriate loss estimates, 

including allowance estimates on FHA-insured loans.

0 

2017-FO-0001 11/14/2016 004-A 

Develop and document an issuer default governance framework 

that includes the identification, monitoring, analysis, evaluation, 

and response to potential issuer defaults. This process includes 

an assessment to maximize defaulted issuer assets and minimize 

losses to Ginnie Mae.

0 

265 █

███ 265 265 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-FO-0001 11/14/2016 005-A 

Develop an audit tracking tool in IPMS that automatically tracks 

and logs (1) the type of override used, (2) who performed the 

override, and (3) the reason for the override. In addition, Ginnie 

Mae should establish policies and procedures to govern and 

monitor the use of overrides, which include the timely 

submission of override reports to Ginnie Mae for review and 

verification.

0 

2017-FO-0001 11/14/2016 005-B 

Establish policies and procedures for monitoring changes to 

master data, to include creating and reviewing a change report 

and establishing controls within IPMS to inform managers of 

changes to master data. In addition, Ginnie Mae should 

automate the reconciliation process between IPMS and other 

interfacing applications or systems to ensure that all pool-level 

details are compared and that changes are captured and reported 

in a timely manner.

0 

2017-FO-0001 11/14/2016 005-C 

Develop written policies and procedures for master data and 

ensure that those policies and procedures are available to all 

staff. In addition, Ginnie Mae should revise policies and 

procedures, as needed, to reflect the changes in business 

processes to ensure that policies and procedures are accurate, 

complete, and current at all times. This should include when 

new systems are developed and implemented or other 

organizational changes occur. Ginnie Mae should also ensure 

that significant changes to the policies and procedures are 

properly communicated to all individuals responsible for 

handling Ginnie Mae’s data.

0 

2017-FO-0002 11/14/2016 002-C 

Establish and implement policies and procedures to ensure that 

accurate data are used to report the undelivered order balances 

for management and marketing contracts.

0 

2017-FO-0002 11/14/2016 003-B 

Revise FHA’s internal control procedures to realign with its 

regulatory requirements so that the first reimbursement letter is 

sent immediately after 60 days instead of after 6 months and 

establish a timeframe for collection once partial claims are 

referred to the Mortgagee Review Board.

0 

2017-FO-0003 11/15/2016 001-C Review Ginnie Mae’s accounting policies to ensure that they 

comply with the USSGL. 0 

2017-FO-0003 11/15/2016 001-D 

Develop and implement policies and procedures that clearly 

outline the role and responsibilities of both HUD and ARC in 

the financial statement preparation and review process, including 

a timeline that will ensure compliance with OMB financial 

reporting deadlines and allow sufficient time to be audited.

0 

266 █

███ 266 266 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-FO-0003 11/15/2016 001-E 

Determine which notes cannot be completed in Oracle and 

develop and implement a plan to ensure that these notes can be 

produced in Oracle.

0 

2017-FO-0003 11/15/2016 001-F 

Perform user acceptance testing in Oracle to ensure that it can 

produce all HUD proper financial information needed for note 

preparation within the timeframe required. If it is determined 

that HFM will be used for some portions of the notes, perform 

user acceptance testing to ensure that HFM is reading and 

crosswalking the Oracle data correctly.

0 

2017-FO-0003 11/15/2016 001-G 

Based on the user acceptance testing, implement any further 

modifications needed in Oracle or HFM to ensure that the notes 

are populated correctly.

0 

2017-FO-0003 11/15/2016 001-H 

Prepare first and second quarter financial statements and note 

disclosures for fiscal year 2017 and beyond to ensure the early 

identification of errors or problems in the financial reporting 

process.

0 

2017-FO-0003 11/15/2016 001-J 

Implement controls to ensure that apportionments, allotments, 

and commitments (accounts 4510, 4610, and 4700) are closed to 

unapportioned authority (account 4450) as part of the yearend 

closing process and not before issuing any of its future financial 

statements.

0 

2017-FO-0003 11/15/2016 002-A 

Continue working with ARC and complete the reconciliation 

and cleanup efforts for balances related to HUD’s loan guarantee 

programs.

0 

2017-FO-0003 11/15/2016 002-C 

Work with the Office of the Chief Administration Officer to 

establish control activities (that is, procedures) to completely 

and accurately record internal use software, leasehold 

improvement, and property acquisition transactions and enable 

compliant financial reporting.

0 

2017-FO-0003 11/15/2016 002-D 

Evaluate whether using existing Oracle accounting modules and 

ARC business processes to account for fixed assets and internal 

use software will be more cost effective and beneficial for HUD 

operations.

0 

2017-FO-0003 11/15/2016 002-E 

Work with the OCFO to establish controls that ensure the timely 

communication of internal use and commercial-off-the-shelf 

software license acquisition activity and data.

0 

2017-FO-0003 11/15/2016 002-F 

Work with OCFO to develop control activities that address risks 

related leasehold improvement and property acquisition data 

completeness and accuracy.

0 

267 █

███ 267 267 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-FO-0003 11/15/2016 003-A 

Develop and implement standard operating procedures, 

including descriptions of roles and responsibilities, for fund 

balance with Treasury reconciliations.

0 

2017-FO-0003 11/15/2016 003-B 

Continue the subledger reconciliation project and complete it in 

a timely manner, communicate results to top key stakeholders, 

and complete necessary adjustments or restatements (if 

applicable).

0 

2017-FO-0003 11/15/2016 003-C 

Perform a root cause analysis to identify potential control gaps 

and ineffective controls in the review of subledger balances to 

the general ledger.

0 

2017-FO-0003 11/15/2016 003-D 

Communicate the impact of system limitations that contributed 

to unreconciled balances to relevant management and design and 

implement effective controls that address relevant risks.

0 

2017-FO-0003 11/15/2016 006-A 

Establish a framework for financial policy development and 

review of policy and procedures that defines roles and 

responsibilities and provides reasonable assurance regarding the 

effectiveness of related controls.

0 

2017-FO-0003 11/15/2016 008-C 

Work with the Office of Policy Development and Coordination 

to issue and implement procedures to address undisbursed 

obligations on contracts after the 24-month expenditure period 

for the ESG program.

0 

2017-FO-0003 11/15/2016 008-O Implement a formal process to periodically review obligations 

and when necessary, contact OCPO to execute deobligations. 0 

2017-FO-0003 11/15/2016 008-P 

Review the contracts totaling $72.8 million to determine validity 

and if no longer needed, forward to HUD’s procurement office 

for closure and deobligation.

0 

2017-FO-0003 11/15/2016 009-A Remove access granted to developer contractor personnel to the 

production database. 0 

2017-FO-0003 11/15/2016 009-B Prohibit developer user ID sharing and create an additional user 

ID for system administration within the developer environment. 0 

2017-FO-0003 11/15/2016 009-C 

Establish audit logs that track user activity for the security 

administration functions and once established, ensure that they 

are monitored in accordance with policy.

0 

2017-FO-0003 11/15/2016 009-D 

Establish audit logs that track user activity for privileged users 

within the production environment and once these logs are 

established, ensure that they are monitored in accordance with 

policy.

0 

268 █

███ 268 268 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-NY-1002 11/22/2016 001-B 

We recommend that the Director of HUD’s Office of Public 

Housing instruct Authority officials to adopt a HUD-approved 

procurement plan.

0 

2017-NY-1002 11/22/2016 001-C 

We recommend that the Director of HUD’s Office of Public 

Housing instruct Authority officials to develop a HUD-approved 

statement of policies and procedures and attach the statement to 

the annual report submitted to HUD.

0 

2017-NY-1002 11/22/2016 001-D 

We recommend that the Director of HUD’s Office of Public 

Housing instruct Authority officials to follow up to ensure 

inspections are completed before occupancy.

0 

2017-NY-1002 11/22/2016 001-E 

We recommend that the Director of HUD’s Office of Public 

Housing instruct Authority officials to obtain HUD’s approval 

for all public housing units occupied by Authority employees.

0 

2017-NY-1002 11/22/2016 001-F 

We recommend that the Director of HUD’s Office of Public 

Housing instruct Authority officials to accurately report 

employees who are required to live in public housing as a 

condition of their employment on form HUD-51234.

0 

2017-NY-1002 11/22/2016 001-G 

We recommend that the Director of HUD’s Office of Public 

Housing instruct Authority officials to develop and implement a 

flat rent policy that requires documentation to be maintained to 

support how flat rents were determined.

0 

2017-FW-1001 12/12/2016 001-F 

We recommend that the Director, Office of Public Housing, Fort 

Worth, TX, require the Authority to enforce its lease 

requirements related to tenant damage to the property and to 

establish procedures to collect tenant accounts receivable before 

writing off the account.

0 

2017-NY-1003 12/14/2016 001-C 

We recommend that the Director of HUD’s Buffalo Office of

Public Housing instruct Town officials to develop and 

implement procedures and controls to ensure that program units 

meet housing quality standards, thereby ensuring that an 

estimated $9,351,175 in future program funds is spent for units 

that are decent, safe, and sanitary. These procedures should 

include but not be limited to regular, updated training for the 

contractor’s housing inspectors to ensure that they are familiar 

with all relevant regulations and rotating its contractor’s housing 

inspectors to prevent units from always being inspected by the 

same official.

0 

269 █

███ 269 269 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-NY-1003 12/14/2016 001-D 

We recommend that the Director of HUD’s Buffalo Office of 

Public Housing instruct Town officials to implement procedures 

to ensure that housing quality standards quality control 

inspections are adequately performed by its contractor. 

Specifically, they should ensure that a sufficient number of 

inspections are performed by a qualified official and results are 

followed up on appropriately.

0 

2017-NY-1003 12/14/2016 001-E 

We recommend that the Director of HUD’s Buffalo Office of 

Public Housing instruct Town officials to develop and 

implement procedures to ensure adequate and timely resolution 

and sufficient documentation of all Housing Choice Voucher 

tenant complaints related to the condition of program units.

0 

2017-KC-1001 12/16/2016 001-C 

Implement adequate policies, procedures, and controls to help 

ensure that fees charged to its projects are in accordance with 

HUD’s requirements.

0 

2017-KC-1001 12/16/2016 001-D Verify all management fees charged to the projects from 2013 

through 2015 were appropriate. 0 

2017-KC-1001 12/16/2016 002-C 

Require Majestic Management to implement adequate policies, 

procedures, and controls to help ensure that goods and services 

are properly procured in accordance with HUD’s requirements.

0 

2017-KC-1001 12/16/2016 002-D 

Monitor Majestic Management’s expenditures to ensure that the 

employees understand and correctly apply procurement 

requirements.

0 

2017-KC-1001 12/16/2016 002-E 

Require Majestic Management to update its management 

agreements to properly disclose its identity-of-interest and 

employee-owned companies to HUD and property owners.

0 

2017-KC-1001 12/16/2016 002-F 

Consider administrative sanctions against Majestic Management 

and its employees for their failure to adequately manage the 

multifamily projects.

0 

2017-KC-1001 12/16/2016 003-C 

Implement adequate policies, procedures, and controls to help 

ensure that payments are adequately supported and for eligible 

purposes.

0 

2017-NY-1004 12/21/2016 001-B 

We recommend that HUD’s Acting Deputy Assistant Secretary 

for Grant Programs instruct City officials to strengthen controls 

over disbursements to ensure that all costs charged to the 

Program are allowable, reasonable, and necessary in compliance 

with the HUD-approved action plan and Federal and State 

regulations.

0 

2016-FO-0006 9/29/2016 002-B 

Establish a periodic review of the master file-official cardholder 

records (for example, cardholder, spending authority, approving

official reviews).

0 

270 █

███ 270 270 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-PH-0003 9/29/2017 001-D 

Develop and implement policies and procedures to ensure that 

appraisers comply with guidance implemented to resolve 

recommendation 1C, including penalties for failure to comply, 

thereby ensuring that at least $238,090,214 million is put to 

better use.

238,090,214

2017-LA-0004 9/14/2017 001-A 

Revise servicing review and monitoring policies and procedures 

to emphasize increased controls on reviewing claim loans 

showing that no loss mitigation evaluation occurred. Revising 

the policies and procedures would reduce the risk to HUD and 

result in a projected $120,902,564 in funds to be put to better 

use (appendix A).

120,902,564

2017-NY-0001 5/18/2017 001-A 

We recommend that HUD’s Deputy Assistant Secretary for 

Public Housing Investments direct staff to determine whether the 

nine PHAs that were classified as troubled or physically 

substandard have public housing developments that are subject 

to the required conversion requirements to support whether 

potentially distressed projects should be converted to tenantbased rental assistance. If conversion is required, ensure that it 

is accomplished timely, thereby ensuring that up to $75,540,916 

is used effectively for other projects that are cost effective and 

have long term viability and ensuring that residents receive other 

rental assistance. The $75 million cited as funds to be put to 

better use is based on an analysis of available data. We 

recognize that the 131 PHAs cited in this report, including the 9 

PHAs that comprise the $75 million figure, may not have 

projects with at least 250 units on one or more contiguous sites 

that have vacancy rates of 12 percent or more. However, the 

data did not allow us to calculate vacancy rates for each group of 

contiguous units, and HUD could not provide a reasonable, 

supported method to identify projects subject to required 

conversion. To address this recommendation, HUD will need to 

determine whether these PHAs have projects that are subject to 

required conversion.

75,540,916

2017-CF-1806 9/28/2017 001-A 

Acknowledge that $42,600,000 of the $65,000,000 in the 

attached settlement agreement represents an amount due HUD, 

less DOJ’s civil debt collection fees.

42,600,000

2017-CF-1803 3/29/2017 001-A 

Acknowledge that $45 million in the attached settlement 

agreement represents an amount due HUD, less the Department 

of Justice’s civil debt collection fees.

38,000,000

2017-BO-0001 3/22/2017 001-A Provide adequate documentation to support the $21,373,462 in 

unreasonable and unnecessary obligated funds. 21,373,462

271 █

███ 271 271 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-AT-1010 8/4/2017 001-D

Develop and implement adequate procedures and controls to 

ensure that its quality control inspection program functions 

properly to include adequately monitoring the inspection 

contractor to prevent $20,566,345 in program funds from being 

spent over the next year on units that do not materially comply 

with requirements.

20,566,345

2017-NY-1010 9/15/2017 001-A

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs direct the State to provide documentation to 

show that the $18,782,054 used for four activities was for 

eligible and supported costs and did not duplicate other benefits 

or repay from non-Federal funds any amount that it cannot 

support.

18,782,054

2017-CH-1006 9/5/2017 001-V

Make a preliminary determination as to whether the Cooperative 

is in default of the grant agreement. If it is preliminarily 

determined that the Cooperative is in default, HUD should 

provide the Cooperative notice of the determination and propose 

corrective or remedial actions to address the default and prevent 

the Cooperative from repaying the remaining $18,149,023, 

which HUD disbursed for the project ($18,607,467 in funds 

disbursed for the project – $458,444 in proceeds from initial 

membership sales the Cooperative remitted to HUD).

18,149,023

2017-AT-0001 4/27/2017 001-A

Reevaluate the feasibility of the two Section 108 activities that 

failed to meet a national objective and determine the eligibility 

of the $15,814,000 already invested. Any amount determined 

ineligible must be reimbursed to the program from non-Federal 

funds.

15,814,000

2017-BO-0001 3/22/2017 001-B

Strengthen and implement acquisition controls to ensure that 

proper cost and price documentation is obtained, adequate 

monitoring is conducted, adequate market research is conducted 

and that contractors are evaluated to assess their capability to 

perform work, and required contract documentation is 

maintained in the file to ensure that $9,645,864 that is yet to be 

used will not be spent for unreasonable and unnecessary costs.

9,645,864

272 █

███ 272 272 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-FW-1012 9/6/2017 001-A 

We recommend that the Director of HUD’s New Orleans Office 

of Community Planning and Development require the City to 

develop and implement a HUD-approved written plan and 

procedures and take actions that will correct and prevent the 

deficiencies noted in the finding, improve program 

administration effectiveness, strengthen the control environment, 

ensure compliance with HUD regulations and its own policies 

and procedures, and ensure that it has the continuing capacity to 

carry out its HOME program activities as required. 

Implementing this recommendation should ensure that the 

$9,339,983 in HOME funding available to the City is better 

used.

9,339,983

2017-NY-1010 9/15/2017 001-B 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs direct the State to Implement procedures to 

ensure that remaining program costs reimbursed with disaster 

recovery funds are adequately reviewed for eligibility and 

support, thereby putting up to $8,932,630 to better use.

8,932,630

2017-AT-0001 4/27/2017 001-B 

Require the borrowers to submit a plan for how they will 

proceed and use the $8,694,000 million in unused commitments 

to provide the intended benefits and meet program objectives.

8,694,000

2017-FW-1004 4/6/2017 001-A 

We recommend that the Director of HUD’s New Orleans Office 

of Community Planning and Development require the Parish to 

develop and implement a HUD approved written plan and 

checklists; and take actions that will correct and prevent the 

deficiencies outlined in the finding, improve program 

administration effectiveness, ensure compliance with HUD 

regulations and the policies and procedures it submitted and 

certified to HUD, and ensure it has the continuing capacity to 

carry out its activities, as required. Implementing this 

recommendation should ensure that the remaining $8,679,994 

allocated in disaster funding is better used.

8,679,994

2017-AT-1003 3/2/2017 001-A 

Submit a plan showing how it will use the $7,984,429 in unspent 

escrow funds to meet program objectives and increase the 

supply of low- and moderate-income housing for the residents of 

Puerto Rico, including a schedule HUD can track to ensure the 

expenditure.

7,984,429

2017-LA-1006 8/9/2017 001-A 

Support the eligibility of $6,529,500 in code enforcement costs, 

including meeting code enforcement requirements, preparing 

time distribution reports, and supporting vehicle costs, or repay 

the program from non-Federal funds (appendix D).

6,529,500

2017-KC-0007 9/12/2017 001-A 

Finalize and implement monitoring procedures to ensure that 

$6,324,625 in flat rents are appropriately charged to tenants over 

the next year.

6,324,625

273 █

███ 273 273 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-FW-1012 9/6/2017 001-D 

We recommend that the Director of HUD’s New Orleans Office 

of Community Planning and Development require the City to 

support that all HOME-assisted units at the Greater Treme 

Consortium, Inc.-Robertson Street, Greater Treme Consortium, 

Inc.-Dumaine Street, Iberville Project Phase II-Bienville Basin, 

OIC1-N. Dorgenois Street, OIC2-Painters Street, OIC5-Pauger 

Street, Treme Cottages, Robert Wolfe Construction-HOME 

Rental Project, and Rosa Keller projects meet HUD housing 

property standards or repay its program from non-Federal funds 

$5,718,095 disbursed in contract costs.

5,718,095

2017-LA-0006 9/21/2017 001-A 

Support the eligibility of more than $4,187,560 in unsupported 

costs or require the grantees to repay the U.S. Treasury from 

non-Federal funds.

4,187,560

2017-NY-1005 1/13/2017 001-A 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct County 

officials to reimburse $3,536,974 to the County’ HOME 

program line of credit for assistance spent on the four activities 

that were partially terminated or noncompliant with program 

requirements.

3,536,974

2017-CH-1801 3/31/2017 001-A 

Acknowledge that the judgment awarded $10,373,998 against 

the former president and founder of MDR Mortgage to the U.S. 

Government, of which HUD’s loss totaled $3,452,499.

3,452,499

2017-LA-0005 9/21/2017 001-B 

Conduct a complete analysis of existing procedures to strengthen 

controls over debt collection, including HUD’s Treasury Reports 

of Receivables reporting, resulting in funds to be put to better 

use of $3,247,078. Controls should include additional 

procedures for ensuring that DOJ approval is obtained when 

required, that all appropriate means of collection have been 

pursued (including referral to Treasury when required), and that 

all closed debts are tracked and were properly authorized for 

collection termination or forgiveness. The analysis should also 

include a review of HUD’s Treasury Reports on Receivables, 

and any other available records to verify that all closed debts 

were properly approved for collection termination or forgiveness 

when required. For any identified debts that were not properly 

approved, the Departmental Claims Collection Officer should 

coordinate with applicable program offices to obtain appropriate 

documentation to approve collection termination or reinstate the 

debt and resume collections.

3,247,078

2017-KC-0003 5/22/2017 001-A 

Investigate the 14 loans with unpaid mortgage amounts totaling 

$3,035,819, and require the lenders to obtain the borrowers 

consent, reinstate the insurance coverage, or take other action as 

appropriate given the facts of each particular loan.

3,035,819

274 █

███ 274 274 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-PH-1007 9/28/2017 001-C 

Develop and implement procedures and controls to monitor the 

inspection process to ensure that program units meet housing 

quality standards, thereby ensuring that an estimated $2,668,680 

in program funds is spent for units that are decent, safe, and 

sanitary.

2,668,680

2017-LA-1803 9/28/2017 001-A 

Work with HUD to nullify the restrictions on conveyance that 

violate HUD policy or indemnify HUD. This action will protect 

HUD against future losses of $2,434,204 for the 49 loans.

2,434,204

2017-AT-1003 3/2/2017 001-B 

Submit supporting documentation so HUD can reevaluate the 

feasibility of the three activities and determine the eligibility of 

the $2,432,271 in escrow funds already disbursed. If HUD 

determines that an activity has been canceled or is not feasible, 

the Department must reimburse the escrow account from nonFederal funds.

2,432,271

2017-PH-1001 3/22/2017 001-D 

Provide documentation to show that seven activities with costs 

totaling $2,266,543 were exempt or categorically excluded from 

environmental reviews or repay its program from non-Federal 

funds for any amount that it cannot support (excluding any 

amount repaid as a result of recommendations 1A, 1B, and 1C).

2,266,543

2017-KC-0002 1/20/2017 001-E 

Implement recommendations 1A through 1D to ensure that 

$2.24 million in housing assistance funds will be put to better 

use.

2,244,680

2017-AT-1003 3/2/2017 001-D 

Submit supporting documentation showing the reasonableness 

and allowability of $2,176,733 disbursed or reimburse its escrow 

account from non-Federal funds.

2,176,733

2017-AT-1011 8/21/2017 001-H 

Provide adequate supporting documentation for the $2,075,314 

paid for housing assistance payments for tenant rents for 2015 

and 2016 and the associated administrative fees earned or repay 

the project-based voucher program from non-Federal funds.

2,075,314

2017-BO-1006 8/18/2017 001-A 

Provide documentation to support that $2,063,351 was spent for 

reasonable and necessary costs. Any amount that cannot be 

supported should be repaid to the Housing Choice Voucher or 

public housing programs from non-Federal funds.

2,063,351

2017-PH-1006 9/25/2017 001-A 

Provide documentation to show that payroll costs totaling 

$2,019,496 and any payroll costs incurred outside our audit 

period, including fiscal year 2017, were reasonable and 

necessary expenses for the operation of the project or repay the 

project from nonproject funds for any amount that it cannot 

support.

2,019,496

2017-LA-1001 4/13/2017 002-A Identify the national objective met for the park project or repay 

the program $2,000,000 from non-Federal funds. 2,000,000

275 █

███ 275 275 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-FW-1012 9/6/2017 001-B 

We recommend that the Director of HUD’s New Orleans Office 

of Community Planning and Development require the City to 

repay its program from non-Federal funds $1,829,837 for the 

four projects that were sold and failed to meet the affordability 

requirements.

1,829,837

2017-CH-1008 9/28/2017 001-A 

Support that it met its $526,170 matching contribution 

requirement associated with the more than $2.1 million in 

program funds it drew down for supportive services and 

administrative expenses. If Travelers Aid cannot provide 

sufficient support, it should reimburse HUD $1,776,381 from 

non-Federal funds.

1,776,381

2017-LA-1007 8/24/2017 001-B 

Require the Authority to provide source documentation to 

determine the accuracy of the tribal enrollment numbers reported 

in 2015 and 2016. Based on those supported numbers, HUD 

should recapture or offset the unsupported amounts from the 

awarded $1,746,658 in program funds that resulted from under 

or overstated tribal enrollment numbers.

1,746,658

2017-LA-0004 9/14/2017 001-D 

Require indemnification for the 26 loans that had significant 

servicing deficiencies. In these cases, the loss to HUD was 

$1,673,117 (appendixes A and D).

1,673,117

2017-CF-1807 9/28/2017 001-A 

Acknowledge that $1,670,000 in the attached settlement 

represents an amount due HUD less DOJ’s civil debt collection 

fees.

1,670,000

2017-LA-1001 4/13/2017 001-A 

Support the reasonableness of the amount paid for the food 

facility consolidation and expansion project or repay the 

program $1,663,758 from non-Federal funds.

1,663,758

2017-CH-1009 9/30/2017 001-J 

Implement adequate procedures and controls to ensure that it (1) 

uses project funds for reasonable operating expenses or 

necessary repairs of the project, (2) obtains HUD approval 

before disposing of the project’s assets, (3) receives market 

value for the sale of licensed beds, (4) obtains HUD approval for 

the entities selected to manage the project before entering into 

management agent agreements with the entities, (5) properly 

completes Medicaid applications, and (6) makes timely 

mortgage payments to prevent a $1,591,849 claim to HUD on 

the mortgage.

1,591,849

2017-CH-1001 1/24/2017 001-A 

Support that $1,432,222 in central office cost center expenses 

allocated to the public housing program projects were eligible, 

necessary, and reasonable costs of the program. Costs that 

cannot be supported, or were unnecessary, unreasonable, or for 

ineligible program costs should be reimbursed to the program 

from non-Federal funds.

1,432,222

276 █

███ 276 276 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-PH-1001 3/22/2017 001-A 

Provide documentation to show that prices paid for products and 

services totaling $1,423,262 for three activities were fair and 

reasonable or repay its program from non-Federal funds for any 

amount that it cannot support.

1,423,262

2017-LA-0005 9/21/2017 001-A 

Take appropriate steps to establish eligibility for collection 

termination or compromise for 10 debts totaling $1,210,278, 

including three debts that were closed without required DOJ 

approval. For debts that have a remaining appropriate means of 

collection, such as demand letters, administrative offset, or 

referral to Treasury, HUD should reinstate the debt and resume 

collections.

1,210,278

2017-LA-1006 8/9/2017 001-F 

Support the eligibility of the $1,107,000 in after school program 

costs, including meeting the limited clientele national objective, 

or repay the program from non-Federal funds.

1,107,000

2017-AT-1802 9/15/2017 001-A 

Reevaluate the feasibility of the project to determine the 

eligibility of the $1,014,211 in State Block Grant funds 

disbursed. If HUD determines that the project has been canceled 

or is not feasible, the Government of Puerto Rico or its designee 

must reimburse all project costs to its State Block Grant program 

from non-Federal funds.

1,014,211

2017-PH-1005 8/14/2017 001-A 

Repay HUD from non-Federal funds for the $987,500 disbursed 

to 21 home buyers who did not meet all of the program 

eligibility requirements.

987,500

2017-PH-1003 5/22/2017 001-A 

Provide documentation to show that prices paid for purchases of 

products and services totaling $970,381 were fair and reasonable 

or reimburse the project from nonproject funds for any amounts 

that were not fair and reasonable.

970,381

2017-PH-1001 3/22/2017 001-B 

Provide documentation to show that costs totaling $942,636 for 

activity 7099 were for employees’ actual time spent benefiting 

the activity or repay its program from non-Federal funds for any 

amount that it cannot support.

942,636

2017-KC-0002 1/20/2017 001-A 

Require public housing agencies to run the Enterprise Income 

Verification existing tenant search during the admission process 

and retain the results in the tenant file, which would avoid 

unnecessary costs to HUD’s subsidy programs, allowing an 

estimated $935,283 to be put to better use.

935,283

277 █

███ 277 277 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-FW-1011 8/29/2017 001-D 

We recommend that the Associate Deputy Assistant Secretary 

for Single Family Housing require BLM to implement an 

effective quality control system, including specifying how many 

quality control field inspections it will perform, how it will 

select properties for review and inspection, reviewing exception 

reports by case number, completing the routine inspection form 

during field inspections, documenting quality control findings 

and how it resolved them, and retaining records that allow it to 

identify and correct patterns of deficiencies and poor 

performance. This would put an estimated $891,000 to better 

use in the next 12 months.

891,000

2017-AT-1801 8/21/2017 001-A 

Acknowledge that $2.93 million in the attached settlement 

agreement represents an amount due HUD, less DOJ’s civil debt 

collection fees (Footnote 2 - DOJ’s 1994 Appropriation Act 

(Public Law 103-121) authorized DOJ to retain up to 3 percent 

of all amounts collected as the result of its civil debt collection 

litigation activities). 

851,500

2017-NY-1013 9/28/2017 001-A 

We recommend that the Director of HUD’s Newark Office of 

Public Housing to require the Authority to provide 

documentation to show that the $800,439 paid for supplies and 

services purchased under the intergovernmental agreement for 

capital improvement projects was reasonable or reimburse its 

Capital Fund from non-Federal funds for any amount that it 

cannot support or that is not considered reasonable.

800,439

2017-KC-1002 3/3/2017 001-B 

Require New Horizons to provide support for the $726,399 in 

housing assistance payments based on missing or incomplete 

tenant files or repay the assistance from project funds if 

available (otherwise, from nonproject funds) to HUD.

726,399

2017-PH-1003 5/22/2017 001-B 

Provide documentation to show that payments for work totaling 

$716,693 complied with applicable building codes or reimburse 

the project from nonproject funds for payments that did not 

comply with the codes and take action to bring the work up to 

code.

716,693

2017-NY-1008 3/10/2017 001-P 

We recommend that the Acting Director of HUD’s Newark 

Office of Public Housing instruct Authority officials to provide 

documentation to show that the $710,721 paid for services 

procured was for costs that were reasonable or repay from nonFederal funds approximately $500,000 to the Operating Fund 

and approximately $200,000 to the Capital Fund (Regulations at 

24 CFR 905.306(f) require that all capital funds be spent within 

48 months after the date on which they become available. Funds 

that have not been properly spent within 48 months have to be 

recaptured and returned to the U.S. Treasury). 

710,721

278 █

███ 278 278 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-AT-1011 8/21/2017 001-J 

Provide adequate supporting documentation for $669,938 in 

monthly RAD rehabilitation assistance it received for vacant 

units during the period of construction or repay the project-based 

voucher program from non-Federal funds.

669,938

2017-LA-1004 6/13/2017 001-L Pay the project $620,937 in uncollected rent from non-project 

funds. 620,937

2017-NY-1005 1/13/2017 001-F 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct County 

officials to impose deed restrictions or other mechanisms 

approved by HUD on the two properties that received HOME 

assistance of $597,519 to enforce affordability requirements 

during the affordability period.

597,519

2017-LA-1001 4/13/2017 001-B 

Correct any citations from the Southern Nevada Health District 

at the Pettiti public pool before May 2017 using non-Federal 

funds or repay the entire project cost of $596,126 from nonFederal funds and support the reasonableness of the change 

orders for the Pettiti pool project or repay the program from nonFederal funds.

596,126

2017-CH-1011 9/30/2017 001-D 

Improve its quality control procedures to accurately track and 

conduct reviews in a manner that ensures all properties in its 

active inventory comply with HUD’s and its own requirements 

to prevent $594,000 in monthly routine inspection fees from 

being spent over the next year for properties that are not 

adequately maintained. The quality control procedures should 

include but not limited to continued training of BLM’s staff and 

subcontractors on properly identifying and addressing property 

deficiencies; maintaining sufficient documentation of its 

monthly quality control reviews and corrective actions; verifying 

that the date stamped photographs were for the corresponding 

inspection dates; and regularly updating its tracking mechanism 

for desktop reviews of inspections to ensure that it conducts 

desktop reviews for properties that are still in its inventory.

594,000

2017-LA-1005 6/16/2017 001-B 

Support the $576,997 in code enforcement costs (activities 499, 

512, and 531), including meeting code enforcement and cost 

allocation requirements, or repay the program from non-Federal 

funds.

576,997

2017-FW-1010 8/16/2017 001-B 

We recommend that the Director of HUD’s Albuquerque Office 

of Community Planning and Development require the City of 

Albuquerque’s Department of Family and Community Services 

to reimburse its CDBG line of credit for $572,929 in ineligible 

costs for its violation of Federal requirements and procurement 

procedures when it acquired a property with CDBG funding. 

Reimbursement must be from non-Federal funds.

576,929

279 █

███ 279 279 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-NY-0002 9/29/2017 001-E 

We recommend that the Deputy Assistant Secretary for Grant 

Programs instruct the Philadelphia, PA, field office to require 

Luzerne County to provide documentation to support the fair 

value of the property at the time of disposition. If 

documentation cannot be provided, the grantee should be 

required to reimburse $575,263 to its CDBG line of credit from 

non-Federal funds. If documentation can be provided, the 

grantee should be required to determine and reimburse its local 

bank account from non-Federal funds the additional program 

income not already reported and properly report the additional 

program income in IDIS under the activity ID that generated the 

income.

575,263

2017-FW-1009 6/29/2017 001-A 

We recommend that the Southwest Region Director of 

Multifamily Housing require Beverly Place’s owner to repay 

HUD $574,930 for subsidized units that were not occupied by 

qualified tenants. Repayment must be from non-Federal funds.

574,930

2017-NY-1005 1/13/2017 001-J 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct County 

officials to reallocate the $573,689 awarded to the ineligible 

CHDO, thus ensure that the fund is put to better use.

573,689

2017-LA-1001 4/13/2017 003-B 

Determine the allocable amount of CDBG payroll costs for the 

employees who worked on CDBG and non-CDBG activities and 

adjust the funding amount as necessary or repay the program 

$573,064 from non-Federal funds.

573,064

2017-FW-1010 8/16/2017 001-A 

We recommend that the Director of HUD’s Albuquerque Office 

of Community Planning and Development require the City of 

Albuquerque’s Department of Family and Community Services 

to reimburse its CDBG line of credit for $568,629 in ineligible 

costs for its violation of procurement requirements. 

Reimbursement must be from non-Federal funds.

568,629

2017-KC-1003 9/26/2017 001-C 

Require the Authority and Majestic Management to support 

$568,023 spent on payroll allocated to the projects or repay the 

projects from non-Federal funds.

568,023

2017-KC-0009 9/26/2017 001-C 

Review the identified 3,160 transactions totaling $555,337 to 

determine whether they were for official government travel. If 

they were not for official travel, OCFO should determine 

whether the cardholders paid the credit bill for the improper 

charges, request reimbursement when applicable, and take all 

other appropriate actions.

555,337

2017-CH-1009 9/30/2017 001-A 

Reimburse the project from nonproject funds for the $542,443 in 

disbursements from the project’s general operating fund account 

that was not used for reasonable operating expenses or necessary 

repairs of the project.

542,443

280 █

███ 280 280 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-AT-1006 6/9/2017 002-A 

Deobligate $542,289 in fiscal year 2015 capital funds in HUD’s 

system until binding agreements are executed for eligible and 

reasonable purposes, or coordinate with HUD for terminating its 

funding.

542,289

2017-NY-1005 1/13/2017 001-M 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct County 

officials to reimburse the $536,507 in program income to the 

County’s HOME program local bank account and record the 

income in IDIS.

536,507

2017-FW-1010 8/16/2017 003-A 

We recommend that the Director of HUD’s Albuquerque Office 

of Community Planning and Development require the City of 

Albuquerque’s Department of Family and Community Services 

to reimburse its CDBG line of credit for $507,218 in ineligible 

costs for its violation of its home rehabilitation policy and 

procedure when it exceeded the allowed maximum assistance 

per home with no cost justifications. Reimbursement must be 

from non-Federal funds.

507,218

2017-NY-0002 9/29/2017 001-D 

We recommend that the Deputy Assistant Secretary for Grant 

Programs instruct the Newark, NJ, field office to require Jersey 

City to provide documentation to support the fair market value 

of the property at the time of disposition. If documentation 

cannot be provided, the grantee should be required to reimburse 

$503,550 to its CDBG line of credit from non-Federal funds. If 

documentation can be provided, the grantee should be required 

to determine and reimburse its local bank account from nonFederal funds any additional program income not already 

reported and properly report the additional program income in 

IDIS under the activity ID that generated the income.

503,550

2017-FW-1011 8/29/2017 001-C 

We recommend that the Associate Deputy Assistant Secretary 

for Single Family Housing require BLM to support or repay 

$488,883 in unearned property management and inspection fees 

for 1,028 properties with three or more consecutive unresolved 

discrepancies in its routine exceptions reports.

488,883

2017-LA-1008 9/13/2017 001-A 

Modify the recapture provisions of the 35 home-buyer assistance 

agreements totaling $488,519 to meet HUD recapture 

requirements relating to the sales price, closing costs, and net 

proceeds.

488,519

2017-KC-1003 9/26/2017 002-B 

Require the Authority and Majestic Management to support that 

the $487,422 spent on goods and services for the projects was a 

reasonable cost and the goods and services were procured from 

eligible vendors or repay the projects from non-Federal funds.

487,422

281 █

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SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-CH-1010 9/30/2017 001-A 

The County does not reimburse itself with program funds for the 

$452,444 in County bond proceeds originally budgeted for the 

Armstrong Park project and used to pay for flood protection 

improvements in the Graue Mill subdivision in Hinsdale.

452,444

2017-NY-1005 1/13/2017 001-E 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct County 

officials to provide disbursement documentation to support the 

eligibility of the $435,094 made for the two activities or repay 

the County’s HOME program line of credit from non-Federal 

source.

435,094

2017-LA-1006 8/9/2017 001-I 

Develop and implement written code enforcement policies and 

procedures to meet CDBG requirements or amend the funding 

for another CDBG-eligible project. Improving code enforcement 

controls will result in $428,373 in funds to be put to better use.

428,373

2017-LA-1801 9/20/2017 001-A 

Work with HUD to nullify the restrictions on conveyance that 

violate HUD policy or indemnify HUD. This action will protect 

HUD against future losses of $418,277 for the eight loans.

418,277

2017-PH-1006 9/25/2017 002-B 

Request retroactive approval of the fees paid to the identity-ofinterest entity totaling $402,975 and any fees incurred outside 

our audit period, including fiscal year 2017, when submitting the 

project owner’s or management agent’s certification for identityof-interest agents in response to recommendation 2A. If the 

request is not approved retroactively, the owner should repay the 

project from nonproject funds for the amount that was not 

approved.

402,975

2017-AT-1006 6/9/2017 002-B 

Reclassify $398,022 in fiscal year 2016 capital funds as 

authorized in HUD’s system to an eligible and reasonable 

activity, or coordinate with HUD for terminating its funding.

398,022

2017-CH-1009 9/30/2017 001-H Pay the project from nonproject funds for the $390,583 in 

uncollected rental revenue. 390,583

2017-CH-1002 7/7/2017 001-L 

Determine the amount of the $387,507 in coordinator grant 

funds that was appropriately earned by the Authority for meeting 

requirements. The funds that are determined to be unearned 

should be reimbursed to HUD from non-Federal funds.

387,507

2017-CH-1009 9/30/2017 001-B Reimburse the State from nonproject funds for the additional 

$384,772 in Medicaid overpayments. 384,772

2017-LA-1802 9/22/2017 001-A 

Work with HUD to nullify the restrictions on conveyance that 

violate HUD policy or indemnify HUD. This action will protect 

HUD against future losses of $381,823 for the seven loans.

381,823

282 █

███ 282 282 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-CH-1007 9/28/2017 001-A 

Reimburse its program $373,860 ($302,638 in ineligible housing 

assistance payments + $63,643 in associated administrative fees 

+ $7,579 in program funds paid to the contractor) from nonFederal funds for the inappropriate payments cited in this 

finding.

373,860

2017-CH-1007 9/28/2017 001-B 

Seek retroactive approval or reimburse its program $358,237 

($339,908 in housing assistance payments + $18,329 in program 

funds paid to the contractor) for the housing quality standards 

inspections of units owned by entities substantially controlled by 

the Authority, completed by contractors that were not approved 

by HUD.

358,237

2017-NY-1005 1/13/2017 001-G 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct County 

officials to provide documentation to support that laborers 

associated with the activity are compensated in compliance with 

Davis-Bacon wage rates. If documentation cannot be provided, 

$567,767 needs to be reimbursed to the County’s HOME line of 

credit from non-Federal sources.

354,750

2017-BO-1003 1/24/2017 001-C 

Support or decrease the payables to its management agent for the 

amounts related to ineligible employee services charges before 

January 1, 2014, which we estimated to be $353,420.

353,420

2017-LA-0006 9/21/2017 001-B 

Require one grantee to repay the U.S. Treasury $343,000 from 

non-Federal funds for ineligible program costs incurred for the 

project identified in this report.

343,000

2017-LA-1005 6/16/2017 001-C 

Implement revised code enforcement program policies and 

procedures to meet CDBG requirements. This will help ensure 

that the remaining $328,918 budgeted for code enforcement 

activity 531 is put to better use.

328,918

2017-CH-1002 7/7/2017 002-E 

Implement adequate procedures and controls to ensure that (1) 

housing assistance payments are appropriately calculated and 

supported, (2) repayment agreements are created to recover 

overpaid housing assistance when unreported income is 

discovered during the examination process, and (3) annual 

reexaminations are completed in a timely manner to ensure that 

$322,550 in program funds is appropriately used for future 

payments.

322,550

2017-BO-1003 1/24/2017 001-A 

Obtain repayment of $322,314 from nonproject funds from the 

management agent for the ineligible bookkeeper and accounts 

payable clerk’s salary and benefits, incurred during 2014 and 

2015.

322,314

283 █

███ 283 283 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-CH-1008 9/28/2017 001-B 

Support or reimburse HUD from non-Federal funds for the 

$305,936 in program administrative funds for which it did not 

provide sufficient documentation to support that the funds were 

used for eligible administrative expenses associated with the 

project for which the funds were drawn.

305,936

2017-FW-1010 8/16/2017 004-C 

We recommend that the Director of HUD’s Albuquerque Office 

of Community Planning and Development require the City of 

Albuquerque’s Department of Family and Community Services 

to support that subrecipient 3 met a national objective, 

environmental requirements, and client eligibility or repay 

$304,975 to its CDBG line of credit from non-Federal funds.

304,975

2017-PH-1003 5/22/2017 002-A Reimburse the project $296,787 from nonproject funds for the 

ineligible legal expenses. 296,787

2017-KC-0003 5/22/2017 002-A 

Update Handbook 4000.1 to require the voluntary termination of 

insurance consent form to include an explanation that voluntary 

termination differs from mortgage insurance premium 

cancellation and the disclosure of any outstanding partial claims

to put $285,215 to better use.

285,215

2017-LA-1004 6/13/2017 001-D 

Remove $283,307 in ineligible accrued salary fees payable from 

its financial statements and records and ensure that these 

expenses are not accrued or paid for with project funds.

283,307

2017-PH-1002 3/24/2017 001-A Pay the project $282,578 from non-project funds for the fair 

value of the commercial rent not collected from the lessees. 282,578

2017-LA-1004 6/13/2017 001-C Repay the project from non-project funds $263,289 for ineligible 

salary expenses. 263,289

2017-NY-1005 1/13/2017 001-R 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct County 

officials to provide documents, such as pay stubs and bank 

statements, to support the eligibility of the two home buyers. If 

documentation cannot be provided, reimburse $260,736 from 

non-Federal sources to the County’s HOME program line of 

credit.

260,736

2017-FW-1010 8/16/2017 002-B 

We recommend that the Director of HUD’s Albuquerque Office 

of Community Planning and Development require the City of 

Albuquerque’s Department of Family and Community Services 

to support that environmental requirements were met for the roof 

replacement of a food bank or repay $260,000 to its CDBG line 

of credit from non-Federal funds.

260,000

2017-AT-1007 7/17/2017 001-E 

Reprogram the remaining NSP1 funds of $219,851 and NSP3 

funds of $28,745 to another subrecipient or developer or return 

the funds to the U.S. Treasury.

248,596

284 █

███ 284 284 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-LA-1007 8/24/2017 001-A 

Recapture the $248,222 in excess program funds from the 

Authority and allocate in the pool for other tribes to use in 

meeting program objectives.

248,222

2017-NY-1005 1/13/2017 001-K 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct County 

officials to reimburse $242,269 to the County’s HOME program 

line of credit for CHDO reserve fund disbursed to the ineligible 

CHDO.

242,269

2017-FW-1013 9/14/2017 001-A 

We recommend that the Director of HUD’s Houston Office of 

Community Planning and Development require the Department 

to support the $240,010 in unsupported procurement payments 

or repay its CDBG program from non-Federal funds.

240,010

2017-NY-1005 1/13/2017 001-L 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct County 

officials to provide documentation to support that at least onethird of the Homefirst board were representatives of a lowincome community. If documentation cannot be provided, 

reimburse the $227,903 to the County’s HOME program line of 

credit from non-Federal sources.

227,903

2017-PH-0001 9/5/2017 001-A 

Direct responsible field offices to require the grantees identified 

by the audit to either provide documentation to support 

$227,260 in unsupported payments or reimburse their programs 

from non-Federal funds for costs they cannot support.

227,260

2017-AT-1004 5/8/2017 001-B 

Provide documentation to support that the $224,868 in NSP2 

funds drawn down from the four vouchers was eligible or repay 

the program from non-Federal funds.

224,868

2017-LA-1006 8/9/2017 001-G Support the eligibility of the $218,028 in antigraffiti costs or 

repay the program from non-Federal funds. 218,028

2017-AT-1006 6/9/2017 002-C 

Coordinate with HUD for terminating the allocation of the 

remaining $217,553 funds given the Authority’s current 

intentions to not build or purchase public housing units.

217,553

2017-NY-1013 9/28/2017 001-B 

We recommend that the Director of HUD’s Newark Office of 

Public Housing to require the Authority to provide 

documentation to show that the $217,403 paid for legal, fee 

accounting, management consulting, and auditing services was 

reasonable or reimburse its Capital Fund or Operating Fund 

from non-Federal funds for any amount that it cannot support or 

that is not considered reasonable.

217,403

285 █

███ 285 285 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-CH-1009 9/30/2017 001-C 

Support or reimburse the project from nonproject funds for the 

$189,524, as appropriate, in disbursements from the project’s 

general operating fund account without sufficient documentation 

showing that the disbursements were for reasonable operating 

expenses of the project.

189,524

2017-NY-1013 9/28/2017 001-D 

We recommend that the Director of HUD’s Newark Office of 

Public Housing to require the Authority to provide 

documentation to show that $187,492 in 2013 and 2014 capital 

fund obligations or reimburse HUD from non-Federal funds for 

any amount that it cannot support.

187,492

2017-FW-1010 8/16/2017 002-C 

We recommend that the Director of HUD’s Albuquerque Office

of Community Planning and Development require the City of 

Albuquerque’s Department of Family and Community Services 

to support that environmental requirements were met for 

homeowner rehabilitation or repay $181,053 to its CDBG line of 

credit from non-Federal funds.

181,053

2017-CH-1008 9/28/2017 001-C 

Support or reimburse HUD from non-Federal funds for the 

$170,995 in program income for which it did not provide 

sufficient documentation to support that the funds were used for 

the project that generated the income ($147,534) and for eligible 

activities ($23,461).

170,995

2017-PH-1003 5/22/2017 001-C 

Provide documentation to support payments totaling $163,885 

or reimburse the project from nonproject funds for payments that 

it cannot support.

163,885

2017-CH-1007 9/28/2017 002-A 

Reimburse its program $163,316 from non-Federal funds 

($29,074 in housing assistance due to calculation errors + 74,957 

due to inappropriate voucher sizes, payment standards, and 

utility allowances + $18,141 + $41,144 in administrative fees) 

for the inappropriate payments cited in this finding.

163,316

2017-LA-1004 6/13/2017 001-M 

Pay the project from non-project funds $162,462 in lease 

agreement charges not deposited into Cypress Meadows’ bank 

account.

162,462

2017-BO-0001 3/22/2017 001-C 

Seek reimbursement for $161,718 in ineligible funds disbursed 

for equipment and support services not specified in a scanning 

services contract.

161,718

2017-FW-1009 6/29/2017 001-B 

We recommend that the Southwest Region Director of 

Multifamily Housing require Beverly Place’s owner to provide 

support to show that the subsidies for 11 tenants with falsified 

income were accurate or repay HUD $150,082 for those 

subsidies. Repayment must be from non-Federal funds.

150,082

286 █

███ 286 286 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-KC-1002 3/3/2017 001-A 

Require New Horizons to repay HUD from project funds if 

available (otherwise, from nonproject funds) $144,556 in 

housing assistance payments for tenants who were not eligible 

for assistance or not living in units.

144,556

2017-LA-1003 6/2/2017 001-C Support $142,181 spent on payroll allocated to HUD grants or 

repay the program from non-Federal funds. 142,181

2017-NY-1013 9/28/2017 001-E 

We recommend that the Director of HUD’s Newark Office of 

Public Housing to require the Authority to reimburse HUD 

$139,423 in replacement housing factor funds not disbursed by 

the expenditure deadline from its replacement housing factor 

funds or reduce its future capital funds.

139,423

2017-LA-1006 8/9/2017 001-D Repay the program $139,071 from non-Federal funds for 

ineligible tire team code enforcement program costs. 139,071

2017-BO-1003 1/24/2017 001-B 

Decrease the payable to the management agent by $139,027 for 

ineligible employee services billed during 2014 and 2015, 

thereby reducing future expenditures because project funds will 

not be used for these ineligible expenses when funds become 

available.

139,027

2017-LA-1004 6/13/2017 001-F 

Remove $129,416 in ineligible accrued offsite accounting fees 

payable from its financial statements and records and ensure that 

these expenses are not accrued or paid for with project funds.

129,416

2017-CH-1002 7/7/2017 001-K 

Develop and implement procedures and controls to ensure that 

(1) documentation required by HUD and its own action plan is 

correctly completed, documented, and updated; (2) escrow 

account balances are correctly calculated and disbursed; and (3) 

escrow accounts and disbursements are fully supported to ensure 

that $127,544 in coordinator grant funds is appropriately used 

over the next year.

127,544

2017-FW-1010 8/16/2017 004-A 

We recommend that the Director of HUD’s Albuquerque Office 

of Community Planning and Development require the City of 

Albuquerque’s Department of Family and Community Services 

to support that subrecipient 1 met a national objective, 

environmental requirements, and client eligibility or repay 

$123,831 to its CDBG line of credit from non-Federal funds.

123,831

2017-LA-1004 6/13/2017 001-E Repay the project from non-project funds $110,710 for ineligible 

offsite accounting expenses. 110,710

287 █

███ 287 287 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-FW-1010 8/16/2017 003-B 

We recommend that the Director of HUD’s Albuquerque Office 

of Community Planning and Development require the City of 

Albuquerque’s Department of Family and Community Services 

to reimburse its CDBG line of credit for $110,647 in ineligible

costs for the rehabilitation costs that exceeded the allowed 

HOME value limits. Reimbursement must be from non-Federal 

funds.

110,647

2017-LA-1005 6/16/2017 001-D 

Support the reasonableness of the $110,000 Graffiti Removal 

program (activities 504 and 520) cost allocations or repay the 

program from non-Federal funds.

110,000

2017-KC-1003 9/26/2017 001-D 

Require the Authority and Majestic Management to reimburse 

from non-Federal funds the $109,665 in ineligible expenses that 

Majestic Management charged to the projects.

109,665

2017-CH-1010 9/30/2017 001-C 

Deobligate the $109,270 in program funds obligated for 

ineligible activities in its construction contracts for the West 

Branch DuPage River Flood Control and Springbrook Culvert 

projects.

109,270

2017-CH-1007 9/28/2017 002-G 

Implement adequate procedures and controls to ensure that (1) 

housing assistance payments are appropriately calculated and 

supported, (2) households reside in units that are affordable, and 

(3) repayment agreements are created to recover overpaid 

housing assistance when unreported income is discovered during 

the examination process to ensure that $108,214 ($103,841 in 

potential overpayments + $4,373 in potential underpayments of 

housing assistance) in program funds is appropriately used for 

future payments.

108,214

2017-NY-1008 3/10/2017 001-K 

We recommend that the Acting Director of HUD’s Newark 

Office of Public Housing instruct Authority officials to provide 

documentation to justify the $106,971 in unsupported rent that 

was written off for 52 tenants. Any amount determined to be 

ineligible should be repaid from non-Federal funds to the 

Operating Fund.

106,971

2017-PH-1001 3/22/2017 001-C 

Provide documentation to show that costs totaling $100,000 for 

activity 6865 benefited the activity or repay its program from 

non-Federal funds for any amount that it cannot support.

100,000

2017-LA-1004 6/13/2017 001-G Repay the project from non-project funds $99,160 for ineligible 

personal health insurance expenses of the owner. 99,160

2017-CH-1010 9/30/2017 001-D 

Support or reimburse its program from non-Federal funds 

$98,507 for the program funds used for project management 

services without sufficient documentation to support that the use 

of the funds was reasonable.

98,507

288 █

███ 288 288 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-LA-1005 6/16/2017 001-F 

Support the reasonableness of the $95,736 in cost allocations 

charged as CDBG administrative (activity 522) costs or repay 

the costs from non-Federal funds.

95,736

2017-NY-1005 1/13/2017 001-O 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct County 

officials to disburse the $92,557 to pay eligible HOME costs 

before making additional drawdowns from LOCCS.

92,557

2017-NY-1008 3/10/2017 001-H 

We recommend that the Acting Director of HUD’s Newark 

Office of Public Housing instruct Authority officials to obtain 

retroactive approval from HUD for the $90,000 lawsuit 

settlement related to a former employee. If approval is not 

obtained, the Authority should reimburse $90,000 to the 

Operating Fund from non-Federal funds.

90,000

2017-NY-1008 3/10/2017 001-A 

We recommend that the Acting Director of HUD’s Newark 

Office of Public Housing instruct Authority officials to provide 

supporting documentation to justify the $88,534 in unsupported 

travel and training costs related to out-of-State trainings, 

meetings, and conferences. Any amount determined to be 

ineligible should be repaid from non-Federal funds to the 

Operating Fund.

88,534

2017-NY-1013 9/28/2017 001-G 

We recommend that the Director of HUD’s Newark Office of 

Public Housing to require the Authority to reimburse its project 

from non-Federal funds for $87,116 in excessive management 

fees charged for units undergoing demolition.

87,116

2017-FW-1012 9/6/2017 001-C 

We recommend that the Director of HUD’s New Orleans Office 

of Community Planning and Development require the City to 

support that rents were within the rent guidelines or repay 

tenants and/or HUD from non-Federal funds for rent 

overpayments of $82,800 at Rosa Keller.

82,800

2017-AT-1005 5/24/2017 001-A 

Provide supporting documentation or reimburse its Program 

$81,654 from non-Federal funds for unsupported on-the-job 

training costs incurred under project FL0220L4D001407.

81,654

2017-FW-1009 6/29/2017 001-C 

We recommend that the Southwest Region Director of 

Multifamily Housing require Beverly Place’s owner to provide 

support to show that the subsidies for 18 tenants without files or 

without adequate income documentation in their files were 

accurate or repay HUD $77,621 for those subsidies. Repayment 

must be from non-Federal funds.

77,621

289 █

███ 289 289 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-CH-1005 8/25/2017 001-E 

Implement adequate quality control procedures to ensure that 

housing assistance payments are appropriately calculated and 

supported. These procedures and controls should ensure that 

$76,107 in program funds are appropriately used for future 

payments.

76,107

2017-FW-1010 8/16/2017 002-D 

We recommend that the Director of HUD’s Albuquerque Office 

of Community Planning and Development require the City of 

Albuquerque’s Department of Family and Community Services 

to reimburse its CDBG line of credit for $73,186 in ineligible 

costs for its statutory violation of environmental requirements 

when it rehabilitated a home without completing the 

environmental review. Reimbursement must be from nonFederal funds.

73,186

2017-LA-1001 4/13/2017 003-C 

Repay $71,397 to the program from non-Federal funds for the 

use of CDBG funds for code enforcement costs related to 

general government expenses.

71,397

2017-AT-1010 8/4/2017 001-A 

Reimburse the program $70,992 ($63,312 + $7,680) from nonFederal funds for housing assistance payments made and 

administrative fees received for the units that materially failed to 

meet HUD’s housing quality standards.

70,992

2017-FW-1010 8/16/2017 003-E 

We recommend that the Director of HUD’s Albuquerque Office 

of Community Planning and Development require the City of 

Albuquerque’s Department of Family and Community Services 

to support payroll wages charged to the CDBG grant or repay 

$69,254 to its CDBG line of credit from non-Federal funds.

69,254

2017-FW-1010 8/16/2017 004-B 

We recommend that the Director of HUD’s Albuquerque Office 

of Community Planning and Development require the City of 

Albuquerque’s Department of Family and Community Services 

to support that subrecipient 2 met a national objective, 

environmental requirements, and client eligibility or repay 

$69,000 to its CDBG line of credit from non-Federal funds.

69,000

2017-LA-1004 6/13/2017 001-K 

Provide documentation to support that $65,232 in disbursements

was used on reasonable and necessary operating expenses or 

repay the project from non-project funds.

65,232

2017-NY-1008 3/10/2017 001-E 

We recommend that the Acting Director of HUD’s Newark 

Office of Public Housing instruct Authority officials to 

reimburse the Operating Fund from non-Federal funds for 

$61,145 in ineligible expenditures for personal expenses, such as 

meals, grocery items, gift cards, flowers, golf, an award dinner, 

Costco and AAA memberships, and a church deduction.

61,145

290 █

███ 290 290 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-FW-1010 8/16/2017 002-A 

We recommend that the Director of HUD’s Albuquerque Office 

of Community Planning and Development require the City of 

Albuquerque’s Department of Family and Community Services 

to support that environmental requirements and client eligibility 

were met for dental services or repay $59,604 to its CDBG line 

of credit from non-Federal funds.

59,604

2017-AT-1004 5/8/2017 001-A Reimburse NSP2 from non-Federal funds for the $59,523 in 

ineligible disbursements on the five vouchers. 59,523

2017-FW-1004 4/6/2017 001-D 

We recommend that the Director of HUD’s New Orleans Office 

of Community Planning and Development require the Parish to 

support the cost reasonableness or repay its program from nonFederal funds $58,873 paid to its surveyor contractor for the 

sole-sourced contract without an adequate cost analysis.

58,873

2017-CH-1002 7/7/2017 001-A 

Reconcile the $58,457 difference among its system report and 

subsidiary ledger and the information reported in HUD’s system 

($1,944 in monthly escrow deposits + $521 difference in 

monthly escrow deposits between HUD’s system and the 

amount reported in the Voucher Management system + the 

average difference of $55,992 in total escrow account balances) 

to ensure that the monthly escrow deposits and total escrow 

balances are appropriately reported in HUD’s system and 

provide the supporting documentation to HUD.

58,457

2017-PH-1006 9/25/2017 001-B 

Provide documentation to show that other direct costs totaling 

$56,021 and any direct costs incurred outside our audit period, 

including fiscal year 2017, were reasonable and necessary 

expenses for the operation of the project or repay the project 

from nonproject funds for any amount that it cannot support.

56,021

2017-LA-1006 8/9/2017 001-H Support the eligibility of the $55,000 subrecipient drawdown or 

repay the program from non-Federal funds. 55,000

2017-CH-1008 9/28/2017 001-D 

Support or reimburse HUD from non-Federal funds for the 

$54,770 in program funds for which it did not provide sufficient 

documentation to support that the funds were used for eligible 

project expenses for supportive services ($26,036) and leasing 

($28,734).

54,770

2017-CH-1005 8/25/2017 001-A 

Reimburse HUD $52,932 from non-project funds for the 

overpayment of housing assistance and utility allowances due to 

incorrect calculations.

52,932

291 █

███ 291 291 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-CH-1009 9/30/2017 001-E 

Support or reimburse the project from nonproject funds for the 

$51,261, as appropriated, in credit card purchases without 

sufficient documentation showing that the purchases were for 

reasonable operating expenses or necessary repairs of the 

project.

51,261

2017-AT-1007 7/17/2017 001-B 

Provide adequate support for expenses totaling $48,985. Any 

expenses that are not supported should be repaid to the 

appropriate NSP grant from non-Federal funds.

48,985

2017-LA-1001 4/13/2017 003-A Repay $48,323 to the program from non-Federal funds for nonprogram-related payroll costs. 48,323

2017-PH-1007 9/28/2017 001-B 

Reimburse its program $46,605 from non-Federal funds 

($44,214 for housing assistance payments and $2,391 in 

associated administrative fees) for the 22 units that materially 

failed to meet HUD’s housing quality standards.

46,605

2017-FW-1006 4/26/2017 001-H 

Provide support for the reasonableness of the unit repairs costs 

totaling $44,994 and repay from nonfederal funds any 

unsupported or unreasonable amount.

44,994

2017-PH-1002 3/24/2017 001-D 

Provide documentation to show that the $39,920 paid to replace 

an air conditioning system was fair and reasonable or repay the 

project from nonproject funds any amount determined not to be 

fair and reasonable (excluding any amount repaid as a result of 

recommendation 1C).

39,920

2017-NY-1008 3/10/2017 001-N 

We recommend that the Acting Director of HUD’s Newark 

Office of Public Housing instruct Authority officials to provide 

documentation to justify $37,671 that did not have receipts or 

other support showing how these transactions were used for lowincome housing and benefited the residents or repay the program 

income account from non-Federal funds for any amount not 

supported.

37,671

2017-PH-1002 3/24/2017 001-B 

Request approval from HUD to lease the commercial space. If 

HUD approves the request, then execute a lease at fair market 

rent thereby increasing the project’s rent revenue by at least 

$36,858 per year.

36,858

2017-CH-1002 7/7/2017 002-A 

Reimburse its program $34,666 from non-Federal funds 

($21,990 + $12,676 in administrative fees) for the overpayment 

of housing assistance due to inappropriate calculations of 

housing assistance.

34,666

2017-LA-1001 4/13/2017 003-D 

Revise its code enforcement program to meet CDBG 

requirements for the remaining $33,603 budgeted or amend the 

use of the funding to another CDBG-eligible activity.

33,603

292 █

███ 292 292 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-CH-1005 8/25/2017 001-C 

Reimburse HUD $32,334 for the overpayment of housing 

assistance due to unreported, and underreported income, or 

income reported late. This reimbursement is either from nonproject funds or collections from applicable households.

32,334

2017-PH-1002 3/24/2017 001-C 

Request approval from HUD for the $31,769 in project operating 

funds spent on building improvements or repay the project from 

nonproject funds for any amount not approved.

31,769

2017-LA-1005 6/16/2017 001-E 

Support the $31,186 After School program (activity 501) costs, 

including the reasonableness of the contract costs and meeting 

the limited clientele national objective, or repay the program 

from non-Federal funds.

31,186

2017-AT-1009 7/21/2017 001-A Adequately support or reimburse its HOPWA program $31,157 

from non-Federal funds for the inappropriate disbursements. 31,157

2017-FW-1004 4/6/2017 001-C 

We recommend that the Director of HUD’s New Orleans Office 

of Community Planning and Development require the Parish to 

support the cost reasonableness or repay its program from nonFederal funds $30,702 paid to its construction contractor for cost 

increases without adequate cost analyses.

30,702

2017-FW-1007 5/17/2017 001-B 

We recommend that the Program Center Coordinator, Office of 

Public Housing, Oklahoma City, OK, require the Authority to 

support or repay $28,574 from non-Federal funds to its Section 8 

program for unsupported payments based on questionable 

income calculations.

28,574

2017-FW-1006 4/26/2017 001-A 

Repay from nonfederal funds $27,818 to its Capital Funds 

program from non-Federal funds for the ineligible purchase of 

the truck and expenditure of 2013 funds before they were 

available.

27,818

2017-NY-1008 3/10/2017 001-B 

We recommend that the Acting Director of HUD’s Newark 

Office of Public Housing instruct Authority officials to provide 

supporting documentation to justify the $27,599 in unsupported 

training travel and per diem expenses related to quarterly 

meetings and trainings offered by HAI. Any amount determined 

to be ineligible should be repaid from non-Federal funds to the 

Operating Fund.

27,599

2017-NY-1008 3/10/2017 001-C 

We recommend that the Acting Director of HUD’s Newark 

Office of Public Housing instruct Authority officials to provide 

supporting documentation to justify the $27,487 reimbursed to 

Authority officials for various costs, such as health coverage 

waiver incentives, supplies, food, and decorations. Any amount 

determined to be ineligible should be repaid from non-Federal 

funds to the Operating Fund.

27,487

293 █

███ 293 293 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-LA-1802 9/22/2017 001-B Repay HUD $26,472 for partial claims paid on one FHA loan 

that contained prohibited restrictive covenants. 26,472

2017-LA-1803 9/28/2017 001-B Repay HUD $26,242 for partial claims paid on two FHA loans 

that contained prohibited restrictive covenants. 26,242

2017-CH-1003 7/14/2017 001-A 

Reimburse its program $25,133 ($17,174 in housing assistance 

payments + $7,959 in associated administrative fees) from nonFederal funds for the overpayment of housing assistance and 

utility allowances due to inappropriate calculations.

25,133

2017-PH-1002 3/24/2017 001-E Remove the $25,000 lien on the project property. 25,000

2017-CH-1002 7/7/2017 001-G 

Reimburse its Housing Choice Voucher program $23,475 from 

non-Federal funds for the two ineligible interim and three 

ineligible graduation disbursements cited in this finding.

23,475

2017-FW-1005 4/25/2017 001-C Support that it properly used the funds collected or repay its 

program $23,463 from non-Federal funds. 23,463

2017-FW-1013 9/14/2017 001-B 

We recommend that the Director of HUD’s Houston Office of 

Community Planning and Development require the Department 

to report $22,872 in program income to HUD and properly use 

program income.

22,872

2017-NY-1008 3/10/2017 001-M 

We recommend that the Acting Director of HUD’s Newark 

Office of Public Housing instruct Authority officials to 

reimburse the program income account from non-Federal funds 

for $21,857 in ineligible expenditures for golf outings, banquets, 

or dinner shows.

21,857

2017-CH-1009 9/30/2017 001-D 

Support or reimburse the project from nonproject funds for the 

$20,000 value of the project’s van, which was transferred 

without sufficient documentation showing that the transfer was 

for reasonable operating expenses.

20,000

2017-LA-1006 8/9/2017 001-E Repay the program $19,919 from non-Federal funds for 

ineligible antigraffiti program salary costs. 19,919

2017-CH-1011 9/30/2017 001-B 

Reimburse HUD $19,280 in ineligible management fees for 20 

properties for which initial services were improperly performed 

before promotion to ready-to-show status.

19,280

2017-NY-1007 2/17/2017 001-A 

We recommend that the Acting Deputy Assistant Secretary for 

Single Family Housing instruct Seneca Mortgage to repay the 

$19,136 in ineligible holding costs to the FHA insurance fund.

19,136

294 █

███ 294 294 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-BO-1006 8/18/2017 003-A 

Provide documentation to support that $18,501 in credit card 

charges was spent for reasonable and necessary costs. Any 

amount that cannot be supported should be repaid from nonFederal funds and returned to the Housing Choice Voucher and 

public housing programs.

18,501

2017-CH-1002 7/7/2017 001-D 

Support or transfer $17,266 from its program account to its 

Housing Choice Voucher program for the 11 unsupported 

escrow calculations cited in this finding.

17,266

2017-KC-1002 3/3/2017 001-C 

Require New Horizons to support that $16,687 in tenant rents 

was collected and deposited as required or repay the project 

from nonproject funds.

16,687

2017-AT-1005 5/24/2017 001-E 

Provide supporting documentation to show that participant 

87487 from FL0431L4D001403 was chronically homeless or 

reimburse its Program $15,756.

15,756

2017-NY-1006 1/31/2017 001-A 

We recommend that the Director of HUD’s New York Office of 

Public Housing require Authority officials to reimburse the 

public housing program from non-Federal funds for $15,020 in 

ineligible expenditures for executive staff travel, food, 

beverages, and musical entertainment.

15,020

2017-DE-1003 9/21/2017 001-C Repay its project’s operating account for the ineligible $15,000 

disbursement from non-project funds. 15,000

2017-AT-1009 7/21/2017 001-B Reimburse its HOPWA program $14,017 from non-Federal 

funds for the inappropriate disbursements. 14,017

2017-PH-1002 3/24/2017 001-I 

Recalculate the project’s annual surplus cash balances for 2013, 

2014, and 2015 after resolution of recommendations 1A, 1C, 

1D, and 1F to determine whether the project should make 

additional payment to HUD from surplus cash toward its 

mortgage beyond the $13,740 that it paid during the audit.

13,740

2017-NY-1008 3/10/2017 001-J 

We recommend that the Acting Director of HUD’s Newark 

Office of Public Housing instruct Authority officials to provide 

documentation to support that $13,340 in rent collected in March 

2016 was deposited into an appropriate bank account or repay 

the Operating Fund from non-Federal funds for any amount not 

properly deposited.

13,340

2017-NY-1006 1/31/2017 001-B 

We recommend that the Director of HUD’s New York Office of 

Public Housing require Authority officials to provide supporting 

documentation to justify the $13,329 in unsupported 

expenditures charged to the public housing program. Any 

amount determined to be ineligible should be repaid from nonFederal funds to the public housing program’s operating 

account.

13,329

295 █

███ 295 295 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-AT-1013 9/28/2017 001-B Support or reimburse HUD $13,058 from non-Federal funds for 

the drawdowns after program grant expiration. 13,058

2017-FW-1007 5/17/2017 001-A 

We recommend that the Program Center Coordinator, Office of 

Public Housing, Oklahoma City, OK, require the Authority to 

repay $12,739 from non-Federal funds to its Section 8 program 

for ineligible payments based on incorrect housing assistance 

payment calculations, incorrect payment standards and utility 

allowances, and unreported income.

12,739

2017-LA-1008 9/13/2017 002-A 

Revise and implement written policies and procedures for 

managing and accurately tracking all NSP3 activity to ensure 

that the $12,275 in identified closing cost refunds and any 

additional refunds identified in recommendation 2B are not 

overpaid by recipients.

12,275

2017-PH-1004 6/9/2017 001-B 

Reimburse its program $9,715 from non-Federal funds ($9,660 

for housing assistance payments and $55 in associated 

administrative fees) for the unit that materially failed to meet 

HUD’s housing quality standards.

9,715

2017-CH-1002 7/7/2017 002-C 

Pursue collection from the applicable households or reimburse 

its program $9,644 from non-Federal funds for the overpayment 

of housing assistance due to unreported or underreported 

income.

9,644

2017-FW-1010 8/16/2017 003-D 

We recommend that the Director of HUD’s Albuquerque Office 

of Community Planning and Development require the City of 

Albuquerque’s Department of Family and Community Services 

to reclassify the $9,476 to program administration and 

recalculate its cap to determine whether it exceeded the allowed 

20 percent. Any amount that is over the allowed cap would be 

ineligible, and repayment of the overage amount to its CDBG 

line of credit would be required. Reimbursement must be from 

non-Federal funds. 

9,476

2017-CH-1007 9/28/2017 002-B 

Reimburse the appropriate households $9,280 ($2,588 in 

housing assistance underpayments due to calculation errors + 

$6,692 due to inappropriate voucher sizes, payment standards, 

and utility allowances) from program funds for the inappropriate 

underpayments cited in this finding.

9,280

2017-PH-1002 3/24/2017 001-F 

Repay the project $8,597 from nonproject funds for the 

ineligible expenses it incurred for management fee and gas 

utility expenses that were identified by the audit and any 

additional management fee and gas utility expenses improperly 

paid outside of our review period.

8,597

296 █

███ 296 296 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-NY-1008 3/10/2017 001-F 

We recommend that the Acting Director of HUD’s Newark 

Office of Public Housing instruct Authority officials to 

reimburse the Operating Fund from non-Federal funds for 

$8,190 in ineligible salary advance.

8,190

2017-FW-1011 8/29/2017 001-B 

We recommend that the Associate Deputy Assistant Secretary 

for Single Family Housing require BLM to repay $8,034 in 

ineligible monthly management and inspection fees for 57 

sample properties with health and safety hazards or significant 

not-ready-to-show conditions.

8,034

2017-PH-1802 6/28/2017 001-A 

Acknowledge that the attached settlement agreement for $10,000 

represents an amount due HUD. As of April 18, 2017, a 

settlement agreement for $10,000, plus interest, had been 

reached, and it represents an amount due HUD. In the settlement 

agreement, the borrower agreed to make an initial payment of 

$2,000 and 47 timely monthly payments of $200, with final 

payment expected by February 28, 2021. In accordance with 

HUD Handbook 2000.06, REV-4, the final action target date 

will be set at March 31, 2021. At issuance of this memorandum, 

we will enter a management decision into HUD’s Audit 

Resolution and Corrective Action Tracking System, along with 

any supporting payment information received to date.

8,000

2017-CH-1010 9/30/2017 001-B 

The $7,677 ($460,121 - $452,444) in remaining County bond 

proceeds originally budgeted for the Armstrong Park project are 

used for eligible program activities.

7,677

2017-CH-1002 7/7/2017 001-E 

Transfer $7,574 from its program account to its Housing Choice 

Voucher program account for the five participants with 

overfunded escrows.

7,574

2017-FW-1006 4/26/2017 001-B 

Repay from nonfederal funds its HUD programs $7,446 for the 

executive director’s personal use of the Authority’s equipment, 

and amend the executive director’s prior Internal Revenue 

Forms W-2 to include the annual personal use of $5,888 as 

income.

7,446

2017-LA-1005 6/16/2017 001-A Repay the program $7,323 from non-Federal funds for ineligible 

code enforcement costs. 7,323

2017-NY-1008 3/10/2017 001-L 

We recommend that the Acting Director of HUD’s Newark 

Office of Public Housing instruct Authority officials to collect 

$7,164 in outstanding rent from the resident commissioner and if 

past-due rent is not paid, take appropriate legal action.

7,164

2017-CH-1002 7/7/2017 001-H 

Reimburse two participants $7,076 from its Housing Choice 

Voucher program account for the underfunded graduation 

payments cited in this finding.

7,076

297 █

███ 297 297 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-CH-1002 7/7/2017 001-F 

Support or reimburse its Housing Choice Voucher program 

$6,839 from non-Federal funds for the one unsupported interim 

disbursement and five unsupported graduation disbursements 

cited in this finding.

6,839

2017-CH-1011 9/30/2017 001-C 

Reimburse HUD $6,525 in ineligible routine inspection fees for 

93 properties that contained property preservation and protection 

deficiencies.

6,525

2017-CH-1005 8/25/2017 001-D 

Support or reimburse HUD $6,444 from non-project funds for 

the unsupported payments of housing assistance cited in the 

finding.

6,444

2017-BO-1006 8/18/2017 001-C 

Deobligate $6,100 from the asbestos abatement procurement and 

redistribute the funds to the public housing programs for eligible 

purposes.

6,100

2017-AT-1011 8/21/2017 001-F 

Enter into a repayment agreement with Community 

Management Corporation for the improper housing assistance 

payments of $5,912 to be repaid to the project-based voucher 

program or repay the project-based voucher program from nonFederal funds.

5,912

2017-LA-1801 9/20/2017 001-B Repay HUD $5,482 for partial claims paid on two FHA loans 

that contained prohibited restrictive covenants. 5,482

2017-CH-1009 9/30/2017 001-G 

Reimburse the project from nonproject funds for the $5,302 in 

petty cash expenditures that was not used for reasonable 

operating expenses of the project.

5,302

2017-KC-1801 2/23/2017 001-A Acknowledge that the settlement agreement for $5,000 

represents an amount due HUD. 5,000

2017-LA-1001 4/13/2017 001-D Provide supporting documentation for $4,955 in unsupported 

costs or repay the program from non-Federal funds. 4,955

2017-FW-1006 4/26/2017 001-C 

Repay from nonfederal funds its HUD programs $4,739 paid to 

its fee accountant, which had a conflict of interest with the 

executive director.

4,739

2017-CH-1002 7/7/2017 001-C 

Transfer $4,684 from its Housing Choice Voucher program 

account to its program account for the 12 participants with 

underfunded escrows.

4,684

2017-LA-1006 8/9/2017 001-C Repay the program $4,565 from non-Federal funds for ineligible 

code enforcement program costs. 4,565

298 █

███ 298 298 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-BO-1006 8/18/2017 003-B 

Provide documentation to support that $4,530 in petty cash 

funds was spent for reasonable and necessary costs. Any 

amount that cannot be supported should be repaid from nonFederal funds and returned to the Housing Choice Voucher and 

public housing programs.

4,530

2017-LA-1004 6/13/2017 001-H Repay the project from non-project funds $4,179 for excessive 

bank fees. 4,179

2017-NY-1008 3/10/2017 001-G 

We recommend that the Acting Director of HUD’s Newark 

Office of Public Housing instruct Authority officials to 

reimburse the Operating Fund from non-Federal funds for the 

$4,048 in ineligible civil service fines.

4,048

2017-FW-1006 4/26/2017 001-G Repay from nonfederal funds its HUD programs $4,000 paid for 

an ineligible 2011 training conference. 4,000

2017-PH-1003 5/22/2017 002-B Reimburse HUD $3,892 from nonproject funds for the 

overpayment of housing assistance. 3,892

2017-FW-1013 9/14/2017 001-C 

We recommend that the Director of HUD’s Houston Office of 

Community Planning and Development require the Department 

to correct its HOME matching liability report to include the 

recalculated amount for 2014 and pay the matching liability of 

$3,301.

3,301

2017-CH-1007 9/28/2017 002-E 

Reimburse the appropriate households $3,178 from non-Federal 

funds for the rent amount paid in excess of 40 percent of the 

adjusted monthly income for the units that were not affordable.

3,178

2017-AT-1004 5/8/2017 001-C 

Provide documentation to support that the differences resulting 

from the payroll costs for the three vouchers, which netted 

$3,169, were offset in later drawdown vouchers or repay the 

program from non-Federal funds.

3,169

2017-LA-1001 4/13/2017 001-C 

Support the cost reasonableness of $2,809 in change orders for 

the ADA pool improvement project or repay the program from 

non-Federal funds.

2,809

2017-BO-1006 8/18/2017 001-B 

Reimburse the Housing Choice Voucher and public housing 

programs $2,752 from non-Federal sources for improper 

conflict-of-interest purchases.

2,752

2017-CH-1003 7/14/2017 002-D 

Support its general ledger and bank account balances or transfer 

$2,547 ($2,334 for the overfunded general ledger account + 

$213 for the overfunded program bank account) from its Family 

Self-Sufficiency program account to its Housing Choice 

Voucher program account for the overfunded accounts cited in 

the finding.

2,547

299 █

███ 299 299 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-CH-1007 9/28/2017 002-C 

Support or reimburse its program $2,533 from non-Federal 

funds for the unsupported payments of housing assistance cited 

in this finding.

2,533

2017-AT-1010 8/4/2017 002-A 

Reimburse the program $2,492 ($2,286 in housing assistance 

payments and $206 in administrative fees received) from nonFederal funds for rental subsidies not abated on four units.

2,492

2017-CH-1009 9/30/2017 001-F 

Reimburse the project from nonproject funds for the $2,020 in 

credit card purchases that was not used for reasonable operating 

expenses of the project.

2,020

2017-CH-1002 7/7/2017 002-D 

Support or reimburse its program $1,666 from non-Federal 

funds for the unsupported payments of housing assistance cited 

in this finding.

1,666

2017-LA-1008 9/13/2017 002-D 

Repay the program $1,495 for closing cost expenses not incurred 

from non-Federal funds and remove the expenses from program 

records if the City incorrectly recorded the refunds as program 

income.

1,495

2017-FW-1010 8/16/2017 004-E 

We recommend that the Director of HUD’s Albuquerque Office 

of Community Planning and Development require the City of 

Albuquerque’s Department of Family and Community Services 

to reimburse its CDBG line of credit for $1,400 in ineligible 

costs for its failure to provide subrecipient oversight, which 

should have identified the ineligibility of clients whose income 

exceed the threshold as reported. Reimbursement must be from 

non-Federal funds.

1,400

2017-LA-1004 6/13/2017 001-I Repay the project from non-project funds $1,352 for expenses 

related to the identity-of-interest hair salon. 1,352

2017-FW-1006 4/26/2017 001-D 

Repay from nonfederal funds its HUD programs $1,273 lost on 

the conflict of interest sale of the Authority’s vehicle to the 

executive director’s daughter.

1,273

2017-CH-1002 7/7/2017 002-B 

Reimburse the appropriate households $1,265 from program 

funds for the underpayment of housing assistance due to 

inappropriate calculations.

1,265

2017-PH-1801 1/6/2017 001-A Acknowledge that the attached settlement agreement for $1,500 

represents an amount due HUD. 1,200

2017-CH-1008 9/28/2017 001-E Reimburse HUD from non-Federal funds for the $1,165 in 

program funds used for improper supportive service expenses. 1,165

2017-FW-1006 4/26/2017 001-E Repay from nonfederal funds its HUD programs $1,034 for 

ineligible charges on the Authority’s credit cards. 1,034

300 █

███ 300 300 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-AT-1005 5/24/2017 001-B 

Provide supporting documentation or reimburse its Program 

$1,023 from non-Federal funds for unsupported personal cell 

phone costs incurred under project FL0220L4D001407.

1,023

2017-AT-1013 9/28/2017 001-A Support or reimburse its ESG program participants $705 from 

non-Federal funds for the inadequately supported pay request. 705

2017-FW-1006 4/26/2017 001-F Support or repay from nonfederal funds its HUD programs $652 

for unsupported charges on the Authority’s credit card. 652

2017-CH-1005 8/25/2017 001-B 

Reimburse the appropriate households $566 from non-project 

funds for the underpayment of housing assistance due to 

incorrect calculations.

566

2017-FW-1010 8/16/2017 004-D 

We recommend that the Director of HUD’s Albuquerque Office 

of Community Planning and Development require the City of 

Albuquerque’s Department of Family and Community Services 

to reimburse its CDBG line of credit for $565 in ineligible costs 

for its failure to provide subrecipient oversight, which should 

have identified that the subrecipient had incorrectly applied 

eligibility requirements for homeless clients served. 

Reimbursement must be from non-Federal funds.

565

2017-LA-1007 8/24/2017 002-A Support the eligibility of the reported $548 in unsupported 

program costs or repay its program using non-Federal funds. 548

2017-FW-1010 8/16/2017 003-C 

We recommend that the Director of HUD’s Albuquerque Office 

of Community Planning and Development require the City of 

Albuquerque’s Department of Family and Community Services 

to reimburse its CDBG line of credit for $474 in ineligible costs 

for violation of Federal travel regulations. Reimbursement must 

be from non-Federal funds.

474

2017-CH-1007 9/28/2017 002-D 

Pursue collection from the applicable households or reimburse 

its program $470 from non-Federal funds for the overpayment of 

housing assistance due to unreported or underreported income.

470

2017-CH-1003 7/14/2017 002-C Reimburse the appropriate households $375 from program funds 

for the underpaid escrow disbursements. 375

2017-LA-1001 4/13/2017 003-E 

Determine the CDBG proportional benefit of the $329 charged 

for indirect automotive costs and repay the program any 

unsupported charges using non-Federal funds.

329

2017-LA-1008 9/13/2017 002-C Repay $95 from non-Federal funds to the two recipients who 

paid more than the assistance provided (appendix E). 95

301 █

███ 301 301 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-NY-0002 9/29/2017 001-G 

We recommend that the Deputy Assistant Secretary for Grant 

Programs instruct the Los Angeles, CA, field office to require 

the County of Los Angeles to reclassify program income to the 

activity ID in IDIS that generated the income, ensuring that the 

$300,330 in program income is properly accounted for.

0 

2017-NY-0002 9/29/2017 001-H 

We recommend that the Deputy Assistant Secretary for Grant 

Programs instruct the Milwaukee, WI, field office to document 

that no portion of the four State of Wisconsin’s activities 

reviewed is currently subject to the change of use requirements 

or remind the State of Wisconsin that the portions of the 

activities related to the voluntary grant reductions are still 

subject to the change of use requirements.

0 

2017-NY-0002 9/29/2017 001-C 

We recommend that the Deputy Assistant Secretary for Grant 

Programs instruct the Newark, NJ, field office to require Jersey 

City to provide documentation to show that a notice was 

provided to affected citizens as required or take action to advise 

affected citizens that they disposed of the property.

0 

2017-NY-0002 9/29/2017 001-F 

We recommend that the Deputy Assistant Secretary for Grant 

Programs instruct the Philadelphia, PA, field office to require 

Luzerne County to reclassify program income already reported 

to the activity ID in IDIS that generated the income, ensuring 

that the $798,273 in program income is properly accounted for.

0 

2017-NY-0002 9/29/2017 001-A 

We recommend that the Deputy Assistant Secretary for Grant 

Programs issue guidance reminding grantees of the requirement 

to properly report the addresses of assisted properties in IDIS 

and properly calculate and report program income from the 

disposition of these properties.

0 

2017-NY-0002 9/29/2017 001-I 

We recommend that the Deputy Assistant Secretary for Grant 

Programs issue guidance to HUD staff and grantees to clarify the 

applicability of change of use requirements in cases where there 

is both a repayment from non-Federal funds and a voluntary 

grant reduction.

0 

2017-CH-1011 9/30/2017 001-E 

Assess BLM’s performance under the area 4P contract at least 

quarterly to determine whether it has improved its performance. 

If its performance does not improve, HUD in coordination with 

the Office of the Chief Procurement Officer should determine 

whether BLM has defaulted on its contract and take the 

appropriate actions.

0 

2017-CH-1011 9/30/2017 001-A 

Certify and provide supporting documentation showing that the 

identified deficiencies have been corrected for the 8 of 109 

properties cited in this audit report.

0 

302 █

███ 302 302 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-CH-1009 9/30/2017 001-I 

Determine the market value of the operating rights for the 10 

licensed beds sold in April 2015. If the licensed beds were sold 

for less than market value, the owner should reimburse the 

project from nonproject funds for the difference between the 

market value and the $150,000 sales price of the operating rights 

for the 10 licensed beds.

0 

2017-CH-1010 9/30/2017 001-E 

Improve its procedures and controls to ensure that the County 

administers the program in accordance with Federal 

requirements.

0 

2017-CH-1007 9/28/2017 002-I 

Ensure that its staff is properly trained and familiar with HUD’s 

and its own requirements regarding program housing assistance 

calculations, applying appropriate voucher sizes, and when to 

apply changes to households’ payment standards and utility 

allowances.

0 

2017-CH-1007 9/28/2017 002-H 

Evaluate its quality control process to ensure that calculation, 

voucher size, payment standard, and utility allowance errors are 

identified and appropriately corrected.

0 

2017-CH-1007 9/28/2017 002-F 

For the five household’s residing in units that were not 

affordable, renegotiate the rent to the owners or require the 

households to move into units that are affordable.

0 

2017-AT-1013 9/28/2017 001-E 

Implement adequate policies and procedures for conducting 

complete and consistent monitoring of subrecipients’ matching 

requirements, including confirming eligibility and existence of 

matching funds to ensure compliance with HUD’s requirements.

0 

2017-AT-1013 9/28/2017 001-C 

Implement adequate policies and procedures to ensure that 

payments to subrecipients are issued in accordance with HUD’s 

requirements.

0 

2017-CH-1008 9/28/2017 001-F 

Implement adequate procedures and controls to ensure that it 

maintains sufficient documentation to support that matching 

contributions, program funds, and program income are 

accounted for and used in accordance with Federal regulations 

and it uses program funds for the projects in accordance with 

Federal regulations.

0 

303 █

███ 303 303 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-CH-1007 9/28/2017 001-C 

Implement adequate procedures and controls to ensure that the 

Authority complies with HUD’s requirements for program 

conflicts of interest, including but not limited to ensuring that (1) 

its staff does not complete inspections for units owned by 

entities substantially controlled by the Authority, (2) its staff is 

appropriately trained and familiar with HUD’s requirements for 

units owned by entities it substantially controls, and (3) future 

contracts to perform housing quality standards inspections for 

program units owned by entities substantially controlled by the 

Authority are with a HUD-approved independent third party.

0 

2017-DP-0003 9/28/2017 001-D Not released to public. 0 

2017-DP-0003 9/28/2017 001-E Not released to public. 0 

2017-DP-0003 9/28/2017 001-F Not released to public. 0 

2017-AT-1013 9/28/2017 001-D 

Provide adequate training to staff associated with the 

administration of the ESG program to ensure compliance with 

HUD’s requirements, including timely drawdowns.

0 

2017-CH-1008 9/28/2017 001-G 

Provide technical assistance to Travelers Aid to ensure that its 

staff is adequately trained on how to account for and use 

matching contributions, program funds, and program income in 

accordance with Federal regulations.

0 

2017-LA-1803 9/28/2017 001-D Provide training to its employees regarding HUD’s requirements 

related to prohibited restrictions on conveyance. 0 

2017-DP-0003 9/28/2017 001-C Not released to public. 0 

2017-CH-1007 9/28/2017 002-K 

Restrict the Authority from administering other HUD-funded 

programs until it substantially improves its program 

administration to ensure compliance with applicable 

requirements based on the findings cited in this audit report, 

absent sufficient documentation provided by the Authority.

0 

2017-CH-1007 9/28/2017 002-J 

Review all of the remaining program household files to 

determine whether appropriate voucher sizes were provided and 

payment standards and utility allowances were applied and 

updated appropriately. The Authority should conduct special 

recertifications for the households with vouchers that do not 

comply with HUD’s requirements and the Authority’s 

administrative plan, issue the appropriate voucher sizes, and 

apply updated payment standards and utility allowances as 

appropriate.

0 

2017-DP-0003 9/28/2017 001-A Not released to public. 0 

304 █

███ 304 304 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-NY-1013 9/28/2017 001-J 

We also recommend that the Director of HUD’s Newark Office 

of Public Housing consider reducing future capital funds as a 

penalty for the Authority’s obligating its 2009, 2010, and 2011 

replacement housing factor funds after the deadline.

0 

2017-NY-1013 9/28/2017 001-F 

We recommend that the Director of HUD’s Newark Office of 

Public Housing to require the Authority to improve its policies 

and procedures to ensure that capital funds, including 

replacement housing factor funds, are obligated and spent for 

eligible activities in a timely manner.

0 

2017-NY-1013 9/28/2017 001-I 

We recommend that the Director of HUD’s Newark Office of 

Public Housing to require the Authority to improve its policies 

and procedures to ensure that its budget, financial reports, and 

accounting data are accurate and up to date.

0 

2017-NY-1013 9/28/2017 001-C 

We recommend that the Director of HUD’s Newark Office of 

Public Housing to require the Authority to provide training to its 

staff related to HUD and Federal procurement requirements, 

including the requirements for using intergovernmental 

agreements and preparing independent cost estimates and cost 

analyses.

0 

2017-NY-1013 9/28/2017 001-H 

We recommend that the Director of HUD’s Newark Office of 

Public Housing to require the Authority to submit a request to 

the HUD field office to revise its budget so that it reflects actual 

expenditures for 2014 capital funds.

0 

2017-SE-1002 9/29/2017 001-B Assist the Authority in obtaining any training needs identified by 

the review in recommendation 1A. 0 

2017-PH-0003 9/29/2017 001-E Consider requiring water testing for all FHA-insured properties. 0 

2017-PH-0003 9/29/2017 001-C 

Develop and implement additional guidance to advise lenders 

and appraisers when water testing is required for properties 

serviced by a public water system which has issued a public 

notice of water contamination.

0 

2017-PH-0003 9/29/2017 001-A 

Direct the applicable lenders to provide evidence that the 

properties for the 1,383 FHA-insured loans not included in our 

sample had a safe and potable water source, or that the 

appraisers had not notified the lender of the water quality issue 

on their appraisals. If the lenders cannot provide this evidence, 

HUD should direct them to perform water testing and any 

necessary remediation to ensure that the properties have a safe 

and potable water source, or indemnify HUD against future loss.

0 

305 █

███ 305 305 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-AT-1014 9/29/2017 001-A 

Recalculate the commitment requirement as a result of the City 

improperly committing HOME funds for activities 5455, 5456, 

5058, 5059, 5173, 5174, and 4652 and determine the cumulative 

effect on the City’s overall commitment requirement. Any 

overpayments should be recaptured or reduced in the HOME 

Investment Trust Fund account.

0 

2017-SE-1002 9/29/2017 001-C 

Require the Authority to submit evidence and its board of 

directors to certify to the Director of the Seattle Office of Public 

Housing that it has complied with regulatory requirements for 

each step of the project-based voucher process for each new 

project-based voucher project until such time as the Director of 

the Seattle Office of Public Housing believes the Authority 

understands and is consistently complying with the 

requirements.

0 

2017-AT-1014 9/29/2017 001-B 

Require the City to establish and implement controls and 

procedures to ensure compliance with requirements for 

commitments entered into HUD’s information system. This 

includes but is not limited to controls and procedures to ensure 

that valid commitment entries and all HOME contracts and 

agreements are properly executed.

0 

2017-SE-1002 9/29/2017 001-A 

Review the Authority’s non-Sound Families Initiative projectbased voucher projects to determine whether it executed the 

agreement with the owners of new construction projects.

0 

2017-PH-0003 9/29/2017 001-B 

Take appropriate administrative action against the lenders or 

appraisers for any cases in which it finds that they did not take 

appropriate steps to ensure that properties had a safe and potable 

water source.

0 

2017-KC-0010 9/29/2017 001-A 

Update the terms in the purchase agreement to ensure that the 

agreements define “extenuating circumstance” in reference to 

foreclosure avoidance, establish how long stabilization outcomes 

can continue to be reported as planned, and establish financial or 

other penalties to hold purchasers accountable in instances of 

nonreporting and noncompliance.

0 

306 █

███ 306 306 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-NY-0002 9/29/2017 001-B 

We recommend that the Deputy Assistant Secretary for Grant 

Programs develop a process to ensure that grantees properly 

report the addresses of assisted properties in IDIS and properly 

calculate and report program income from the disposition of 

these properties regularly. This process could include but is not 

limited to developing a process to extract data reported in IDIS 

on activities with the matrix codes related to real property, and 

training and instructing the Office of Community Planning and 

Development’s field office staff to extract this data and 

manually check for address and program income data on 

grantees’ activities, particularly activities that are completed but 

have properties that could still be subject to program income 

requirements.

0 

2017-FW-1008 6/28/2017 001-E 

We recommend that the Director of the San Antonio Office of 

Public Housing require the Authority to provide training to 

commissioners and employees on travel requirements and their 

responsibilities and duties.

0 

2017-FW-1009 6/29/2017 001-E 

We further recommend that the Southwest Region Director of 

Multifamily Housing ensure that the project-based contract

administrator’s review process includes steps to obtain 

reasonable assurance that tenants being reported as subsidized at 

Beverly Place live in the subsidized units.

0 

2017-CH-1004 8/11/2017 001-A 

Implement adequate procedures and controls to ensure that it 

properly monitors the listing brokers to ensure compliance with 

its contract. The procedures and controls should include but not 

limited to performing quality control reviews and supervisory 

review of its brokers, and maintaining documentation of its 

quality control reviews and corrective actions.

0 

2017-CH-1004 8/11/2017 001-B Update its quality control plan to include the performance of 

physical inspections of the properties in its inventory. 0 

2017-FW-1010 8/16/2017 004-G 

We recommend that the Director of HUD’s Albuquerque Office 

of Community Planning and Development continue to classify 

the City of Albuquerque as a high risk grantee until such time as 

HUD has determined the City has implemented an effective 

program in compliance with all requirements.

0 

2017-FW-1010 8/16/2017 001-G 

We recommend that the Director of HUD’s Albuquerque Office 

of Community Planning and Development require the City of 

Albuquerque’s Department of Family and Community Services 

to amend and implement its conflict-of-interest policy and 

procedures to ensure that it complies with Federal conflict-ofinterest requirements and includes elected and appointed 

positions.

0 

307 █

███ 307 307 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-FW-1010 8/16/2017 004-F 

We recommend that the Director of HUD’s Albuquerque Office 

of Community Planning and Development require the City of 

Albuquerque’s Department of Family and Community Services 

to develop and implement written CDBG policies and 

procedures, which detail the requirements, including but not 

limited to (1) meeting Federal procurement requirements, (2) 

executing written agreements for all subrecipients and 

contractors that meet minimum requirements, (3) documenting 

all conflicts of interest, (4) complying with HUD environmental 

review requirements, (5) maintaining documentation to support 

that its CDBG-funded projects met one or more national 

objectives, (6) properly and accurately monitoring subrecipients 

for compliance with all requirements, and (7) consistently and 

accurately reporting activities in IDIS.

0 

2017-FW-1010 8/16/2017 001-F 

We recommend that the Director of HUD’s Albuquerque Office 

of Community Planning and Development require the City of 

Albuquerque’s Department of Family and Community Services 

to develop contracts to include all Federal requirements and to 

be signed by both the City and the contractors awarded bids with 

CDBG funding.

0 

2017-FW-1010 8/16/2017 003-F 

We recommend that the Director of HUD’s Albuquerque Office 

of Community Planning and Development require the City of 

Albuquerque’s Department of Family and Community Services 

to implement recommendations made from its internal and 

external auditors that will ensure compliance with applicable 

regulations related to cost reasonableness and eligibility and that 

costs are adequately supported.

0 

2017-FW-1010 8/16/2017 001-C 

We recommend that the Director of HUD’s Albuquerque Office 

of Community Planning and Development require the City of 

Albuquerque’s Department of Family and Community Services 

to implement technical assistance and guidance received from 

HUD to ensure compliance with requirements.

0 

2017-FW-1010 8/16/2017 001-D 

We recommend that the Director of HUD’s Albuquerque Office 

of Community Planning and Development require the City of 

Albuquerque’s Department of Family and Community Services 

to obtain technical assistance from HUD related to 

differentiating between subrecipients and contractors and 

ensuring that the correct procurement requirements are followed 

when obtaining a subrecipient or contractor.

0 

308 █

███ 308 308 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-FW-1010 8/16/2017 002-E 

We recommend that the Director of HUD’s Albuquerque Office 

of Community Planning and Development require the City of 

Albuquerque’s Department of Family and Community Services 

to provide training for staff members to ensure that they know 

their roles and responsibilities with respect to CDBG program 

oversight and that documentation and other requirements are 

met.

0 

2017-FW-1010 8/16/2017 001-E 

We recommend that the Director of HUD’s Albuquerque Office 

of Community Planning and Development require the City of 

Albuquerque’s Department of Family and Community Services 

to update its CDBG written agreements to include the specific 

language required.

0 

2017-BO-1006 8/18/2017 002-A 

Develop and implement written policies and procedures to 

ensure that each Housing Choice Voucher program tenant file 

has an appropriately documented rent reasonableness 

determination.

0 

2017-BO-1006 8/18/2017 002-C Determine whether tenants were underpaid for utility allowances 

and if so, reimburse the tenants from non-Federal funds. 0 

2017-BO-1006 8/18/2017 001-F Develop and enforce written conflict-of-interest requirements in 

compliance with Federal rules and regulations. 0 

2017-BO-1006 8/18/2017 001-E Develop and implement controls to ensure that contracts are in 

place when applicable. 0 

2017-BO-1006 8/18/2017 001-D Develop and implement procurement policies and procedures 

that comply with Federal, State, and local laws. 0 

2017-BO-1006 8/18/2017 002-B 

Develop and implement written policies and procedures to 

ensure that each public housing unit has an annual inspection, 

which is appropriately documented in the tenant file.

0 

2017-BO-1006 8/18/2017 001-G Develop and maintain a contract management system, including 

a contract register for all procurements. 0 

2017-BO-1006 8/18/2017 003-C Develop and maintain property records and conduct an inventory 

in accordance with Federal regulations. 0 

2017-BO-1006 8/18/2017 002-D Evaluate the training of West Warwick employees and 

determine what additional training is necessary. 0 

2017-BO-1006 8/18/2017 001-H 

Evaluate the training of West Warwick’s board of 

commissioners and determine whether additional training is 

required or other changes are appropriate.

0 

309 █

███ 309 309 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-CF-0801 8/21/2017 001-A 

Clarify whether assistance provided under its community 

development programs, such as HOPWA, are considered 

“Federal public benefits” and are, therefore, subject to 

PRWORA’s noncitizen eligibility restrictions.

0 

2017-CF-0801 8/21/2017 001-B 

Consult with the Office of the Attorney General to establish 

whether HOPWA and other homeless assistance programs are a 

Federal public benefit that meets the definition of “providing 

assistance for the protection of life or safety” and are, therefore, 

exempt from PRWORA noncitizen eligibility restrictions.

0 

2017-AT-1011 8/21/2017 001-L 

Determine whether the households residing in the Authority’s 

project-based voucher units, that bypassed others on the wait 

lists, received housing in accordance with the program’s 

requirements and if not, consider a referral to HUD’s Office of 

Fair Housing and Equal Opportunity.

0 

2017-LA-0004 9/14/2017 001-C 

Update and revise policies and procedures, including 

reinforcement of guidance (for example, mortgagee letters, 

notifications to servicers, or training) to ensure that servicers 

accurately report the status of delinquent loans to HUD.

0 

2017-FW-1013 9/14/2017 001-D 

We recommend that the Director of HUD’s Houston Office of 

Community Planning and Development require the Department 

to confirm that it has developed and implemented written 

procurement procedures to ensure that future contracts and 

subrecipient agreements address the procurement and required 

provision issues identified in the report.

0 

2017-LA-1801 9/20/2017 001-D Provide training to its employees regarding HUD’s requirements 

related to prohibited restrictions on conveyance. 0 

2017-KC-0009 9/26/2017 002-A 

Strengthen current purchase card controls to ensure that 

purchases are supported by all required approvals before the 

purchase is made.

0 

2017-PH-1007 9/28/2017 001-A 

Certify, along with the owners of the 61 units cited in the 

finding, that the applicable housing quality standards violations 

have been corrected.

0 

2017-LA-1803 9/28/2017 001-E 

Determine legal sufficiency and if legally sufficient, pursue civil 

and administrative remedies, civil money penalties, or both 

against RMS, its principals, or both for incorrectly certifying to 

the eligibility for FHA mortgage insurance or that due diligence 

was exercised during the origination of FHA loans.

0 

2017-LA-1803 9/28/2017 001-C 

Develop and implement policies and procedures to identify 

prohibited restrictions on conveyance to ensure that it does not 

originate FHA loans with prohibited restrictive covenants.

0 

310 █

███ 310 310 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-AT-1011 8/21/2017 001-K 

Develop and implement procedures for following project-based

voucher requirements for tenant recertifications as project-based 

voucher tenants at Terrace Lane and Southside Village, and 

ensure they comply with the Housing Choice Voucher 

regulations.

0 

2017-PH-0001 9/5/2017 001-C Develop and implement guidance to communicate appropriate 

ways for grantees to calculate household income. 0 

2017-CH-1006 9/5/2017 001-C 

Develop and maintain a waiting list for rental units that meets 

the requirements of the resident home-ownership plan and 

considers the tenant profile.

0 

2017-CH-1006 9/5/2017 001-T 

Ensure that the Cooperative’s board members and responsible 

staff of the Cooperative’s management agent are provided 

training on HUD’s requirements and the grant agreement.

0 

2017-CH-1006 9/5/2017 001-E 

For the two units for which the Cooperative acquired the 

memberships associated with the units from members and which 

had been vacant for more than 6 months, rent the units to 

households that meet the tenant income profile.

0 

2017-CH-1006 9/5/2017 001-B Have a representative of HUD at the closing for membership 

sales to sign the HUD notes. 0 

2017-CH-1006 9/5/2017 001-D 

Implement adequate procedures and controls to ensure that any 

rental units vacated by current households or units associated 

with memberships which were repurchased by the Cooperative 

and then remained vacant more than 6 months, are rented to very 

low-, low-, or moderate-income households selected from a 

waiting list for rental units that meets the requirements of the 

resident homeownership plan and considers the tenant profile.

0 

2017-CH-1006 9/5/2017 001-G 

Implement adequate procedures and controls to ensure that HUD 

receives its full share of the proceeds from future initial 

membership sales.

0 

2017-LA-0004 9/14/2017 001-E 

Reinforce existing guidance (such as mortgagee letters, 

notifications to servicers, and training) to servicers to ensure that 

they engage in required loss mitigation.

0 

2017-LA-0004 9/14/2017 001-F 

Require that the servicers with significant and other deficiencies 

revise and update their policies and procedures, as necessary, to 

ensure that they comply with HUD requirements and guidance 

on loss mitigation evaluation.

0 

2017-FW-1013 9/14/2017 001-E 

We recommend that the Director of HUD’s Houston Office of 

Community Planning and Development require the Department 

to ensure that all program files include required documentation 

and support.

0 

311 █

███ 311 311 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-FW-1013 9/14/2017 001-F 

We recommend that the Director of HUD’s Houston Office of 

Community Planning and Development require the Department 

to monitor subrecipients annually as stated in its monitoring 

policy.

0 

2017-FW-1013 9/14/2017 001-G 

We recommend that the Director of HUD’s Houston Office of 

Community Planning and Development require the Department 

to train its staff regarding HUD requirements and regulations or 

seek technical assistance.

0 

2017-AT-1802 9/15/2017 001-B 

Instruct the Office for the Socioeconomic and Community 

Development to submit a plan for how it will proceed with the 

fine arts center project. The plan should include a schedule that 

HUD can track to ensure the project’s completion without 

proposing the use of additional HUD funds.

0 

2017-NY-1010 9/15/2017 001-C 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs direct the State to provide training to its staff on 

applicable HUD and Federal requirements for eligibility, 

documentation of costs, and duplication of benefits reviews.

0 

2017-LA-1801 9/20/2017 001-E 

Determine legal sufficiency and if legally sufficient, pursue civil 

and administrative remedies, civil money penalties, or both 

against Venta, its principals, or both for incorrectly certifying to 

the eligibility for FHA mortgage insurance or that due diligence 

was exercised during the origination of FHA loans.

0 

2017-LA-1801 9/20/2017 001-C 

Develop and implement policies and procedures to identify 

prohibited restrictions on conveyance to ensure that it does not 

originate FHA loans with prohibited restrictive covenants.

0 

2017-NY-1011 9/20/2017 001-B 

We recommend that the Deputy Assistant Secretary for Single 

Family Housing require MB Financial to provide training to its 

underwriters on HUD’s underwriting requirements for approving 

and rejecting loans.

0 

2017-NY-1011 9/20/2017 001-C 

We recommend that the Deputy Assistant Secretary for Single 

Family Housing require MB Financial to update its policies and 

procedures to ensure that its staff understands underwriting 

requirements and the requirement that loans be manually 

underwritten when a refer decision is received from automated 

underwriting systems or when a loan is downgraded to a manual 

underwrite.

0 

2017-NY-1011 9/20/2017 002-A 

We recommend that the Deputy Assistant Secretary for Single 

Family Housing require MB Financial to update its quality 

control plan to include the specific procedures to be used when 

reviewing rejected loan applications.

0 

2017-DE-1003 9/21/2017 001-B Complete HUD-approved training regarding owner 

contributions and distributions. 0 

312 █

███ 312 312 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-KC-1003 9/26/2017 001-A 

Require the Authority to require Majestic Management to 

develop and implement a process to ensure that it makes any 

needed adjustments to employee payroll and transfers accurate 

amounts from the project accounts for payroll.

0 

2017-KC-1003 9/26/2017 002-C 

Require the Authority to review all other payments to the 

sampled vendors to confirm that the costs were reasonable and 

the goods and services were procured from eligible vendors or 

repay the projects from non-Federal funds.

0 

2017-KC-0009 9/26/2017 002-B 

Review the four cardholders with incomplete approvals and 

determine whether the purchases were allowable and proper. If 

they were not for official government use, OCPO should 

determine whether the cardholders paid the credit bill for the 

improper charges, request reimbursement when applicable, and 

ensure that appropriate administrative sanctions are taken.

0 

2017-KC-0801 9/26/2017 001-A 

Review the two cardholders with incomplete approvals and 

determine whether the purchases were allowable and proper. If 

they were not for official government use, OCPO should 

determine whether the cardholders paid the credit bill for the 

improper charges, request reimbursement when applicable, and 

ensure that appropriate administrative sanctions are taken.

0 

2017-DE-1003 9/21/2017 001-A 

Develop and implement controls over owner contributions and 

owner distributions to ensure compliance with its regulatory 

agreement and HUD regulations.

0 

2017-KC-0008 9/21/2017 001-C 

Develop and implement controls to continually assess skills 

required to meet organizational goals to include a plan to 

prioritize resources to accommodate changing organizational 

needs.

0 

2017-KC-0008 9/21/2017 001-A 

Develop and implement controls to ensure that policies and 

procedures for account executives are continually reviewed and 

updated to reflect changes in Ginnie Mae’s operations.

0 

2017-KC-0008 9/21/2017 001-B 

Develop and implement controls to review issuers to determine 

the total impact of a large or multiple-issuer default, the 

maximize-size default Ginnie Mae can adequately execute, and 

an issuer’s ability to adapt to changing market conditions.

0 

2017-KC-0008 9/21/2017 001-D 

Develop and implement training programs to ensure that 

employee skill levels are developed to meet changing 

organizational needs to include secondary market training.

0 

2017-BO-1007 9/21/2017 001-G Establish and implement an effective system to ensure that 

payments do not exceed approved contract values. 0 

313 █

███ 313 313 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-BO-1007 9/21/2017 001-H 

Establish and implement an effective system to maintain a 

complete and accurate contract register to ensure proper contract 

planning and administration.

0 

2017-DE-1003 9/21/2017 002-B 

Implement controls to ensure existing procedures are followed to 

maintain the project’s security deposit funds separately from all 

other accounts by depositing and disbursing all security deposit 

funds directly into and from the security deposit account.

0 

2017-DE-1003 9/21/2017 002-A Perform an analysis of all security deposits and ensure that the 

security deposit account is fully funded. 0 

2017-BO-1007 9/21/2017 001-I 

Provide technical assistance to the Authority to ensure that 

responsible staff and board members receive necessary 

procurement training.

0 

2017-BO-1007 9/21/2017 001-E 

Reprocure any service contracts necessary and ensure that the 

contracts are properly awarded in accordance with HUD 

requirements.

0 

2017-BO-1007 9/21/2017 001-F 

Strengthen and implement controls and procedures over 

procurement, including monitoring consultants, to ensure that 

procurement activities meet HUD requirements.

0 

2017-NY-1012 9/21/2017 001-B 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs require the City to provide documentation 

showing that it has strengthened its invoice review process to 

ensure that costs are eligible and supported before disbursing 

disaster funds to its subrecipient under the program.

0 

2017-NY-1012 9/21/2017 001-A 

We recommend that HUD’s Deputy Assistant Secretary for 

Grant Programs require the City to provide documentation 

showing that it obtained adequate support for contractor invoices 

related to disaster funds it disbursed to its subrecipient under the 

program.

0 

2017-PH-0002 9/22/2017 001-C 

Clarify and improve its guidance for State grantees to explain 

what it means to have a procurement process that fully aligns 

with, or meets the intent of, each of the Federal procurement 

standards at 2 CFR 200.318 through 200.326.

0 

2017-PH-0002 9/22/2017 001-A 

Clarify that if a State receives a disaster recovery grant and 

chooses to certify that its procurement process is equivalent to 

Federal procurement standards, “equivalent” means that its 

procurement process fully aligns with, or meets the intent of, 

each of the Federal procurement standards at 2 CFR 200.318 

through 200.326.

0 

314 █

███ 314 314 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-LA-1802 9/22/2017 001-E 

Determine legal sufficiency and if legally sufficient, pursue civil 

and administrative remedies, civil money penalties, or both 

against SecurityNational, its principals, or both for incorrectly 

certifying to the eligibility for FHA mortgage insurance or that 

due diligence was exercised during the origination of FHA 

loans.

0 

2017-LA-1802 9/22/2017 001-C 

Develop and implement policies and procedures to identify 

prohibited restrictions on conveyance to ensure that it does not 

originate FHA loans with prohibited restrictive covenants.

0 

2017-PH-0002 9/22/2017 001-B 

Improve its controls to ensure that appropriate staff adequately 

evaluates the proficiency of State grantee procurement processes 

for States that select the equivalency option. This includes 

ensuring that staff that specializes in procurement review the 

documentation to ensure that State processes fully align with, or 

meet the intent of, each of the Federal procurement standards at 

2 CFR 200.318 through 200.326.

0 

2017-PH-0002 9/22/2017 001-D 

Provide procurement training and technical assistance to State 

grantees to ensure that they understand the intent of each of the 

Federal procurement standards at 2 CFR 200.318 through 

200.326.

0 

2017-LA-1802 9/22/2017 001-D Provide training to its employees regarding HUD’s requirements 

related to prohibited restrictions on conveyance. 0 

2017-PH-1006 9/25/2017 001-C 

Develop and implement controls to ensure that the project 

complies with the regulatory agreement and applicable HUD 

requirements.

0 

2017-PH-1006 9/25/2017 002-C 

Evaluate the owner’s capability to effectively manage the project 

and consider whether independent professional management 

services are needed.

0 

2017-PH-1006 9/25/2017 001-D 

Provide training and technical assistance to the owner and its 

management agent to ensure compliance with the terms of its 

regulatory agreement and applicable HUD requirements.

0 

2017-PH-1006 9/25/2017 002-D 

Pursue civil money penalties and administrative sanctions, as 

appropriate, against the owner and its parent company and their 

principals for their part in the violations cited in this report.

0 

2017-PH-1006 9/25/2017 002-A 

Submit a project owner’s or management agent’s certification 

for identity-of-interest agents, a management entity profile, a 

management plan, and other required documentation for review 

and approval.

0 

315 █

███ 315 315 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-KC-0009 9/26/2017 001-A 

Develop and implement adequate written policies to ensure that 

cardholders obtain appropriate authorizations to support charges 

to their government travel cards and establish a process for 

submitting a written request to OCFO for a merchant code 

unblock.

0 

2017-KC-0009 9/26/2017 001-B 

Develop and implement written policies to ensure that program 

offices adequately follow up on identified questionable charges 

and inform OCFO of significant travel card violations when they 

are identified.

0 

2017-KC-1003 9/26/2017 001-E 

Require the Authority and Majestic Management to repay any 

excessive annual leave that Majestic Management paid to its 

employees from project funds when its contract terminated in 

2017.

0 

2017-KC-1003 9/26/2017 003-A 

Require the Authority to monitor Majestic Management to 

ensure that the recent training was effective and the new 

checklist is in use and effective.

0 

2017-KC-1003 9/26/2017 002-A 

Require the Authority to provide training on procurement 

requirements in public housing to all Majestic Management 

employees working at the projects.

0 

2017-KC-1003 9/26/2017 003-B 

Require the Authority to recompute the rents for the households 

noted above and as necessary for errors made by Majestic 

Management, reimburse tenants for overcharged rent from 

operating funds or rent credit, and enter into repayment 

agreements with tenants if they were undercharged based on 

nondisclosure of income.

0 

2017-KC-1003 9/26/2017 001-B 

Require the Authority to require Majestic Management to design 

and implement a process to ensure that actual staff hours are 

accurately tracked and only dedicated employees are paid from 

project funds.

0 

2017-CH-1006 9/5/2017 001-L 

Implement adequate procedures and controls to ensure that it 

sells memberships to the same proportion of very low-, low-, 

and moderate-income households as stated in the resident 

income profile in paragraph 4.a. and required by paragraph 10.b. 

of the use agreement.

0 

2017-CH-1006 9/5/2017 001-S 

Implement adequate procedures and controls to ensure that it 

submits the required reports to HUD to show continued 

compliance with the program.

0 

2017-CH-1006 9/5/2017 001-I 

Implement adequate procedures and controls to ensure that its 

share of the proceeds from initial membership sales is used in 

accordance with the grant agreement.

0 

316 █

███ 316 316 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-CH-1006 9/5/2017 001-P 

Implement adequate procedures and controls to ensure that 

members maintain their units at the project as their principal 

residence or sell their memberships.

0 

2017-CH-1006 9/5/2017 001-A 

Implement adequate procedures and controls to ensure that 

memberships are sold at or below the fair market value and 

HUD’s secured interest in the memberships is appropriately 

valued.

0 

2017-CH-1006 9/5/2017 001-J 

Implement adequate procedures and controls to ensure that the 

Cooperative receives HUD approval before using the $148,872 

in proceeds from initial membership sales offset by undisbursed 

funds which was in the Cooperative’s reserve for replacements 

account for the project.

0 

2017-CH-1006 9/5/2017 001-R 

Implement adequate procedures and controls to ensure that the 

project’s units are used for rental or cooperative housing unless 

otherwise approved by HUD.

0 

2017-PH-0001 9/5/2017 001-B 

Provide guidance to field office staff to clarify the statutory 

requirements in 42 U.S.C. 5305(a)(24) regarding a principal 

reduction and a downpayment for direct home-ownership 

assistance activities.

0 

2017-CH-1006 9/5/2017 001-F 

Provide sufficient documentation to support that HUD had 

received 50 percent of the proceeds from initial membership 

sales as of May 2017. If the Cooperative cannot do this, it 

should pay HUD half of the principal on the promissory notes 

payable to the Cooperative for all of the membership sales less 

the amount the Cooperative can support that it paid HUD for 

initial membership sales.

0 

2017-CH-1006 9/5/2017 001-H 

Provide sufficient documentation to support that the Cooperative 

used its share of the proceeds from initial membership sales in 

accordance with the grant agreement. If the Cooperative cannot 

do this, it should transfer funds from its operating account, in an 

amount equal to half of the principal on the mortgages to the 

Cooperative for all membership sales less the amount the 

Cooperative can support that it used for eligible purposes, to a 

reserve account to be used in accordance with the grant 

agreement.

0 

2017-CH-1006 9/5/2017 001-O 

Provide sufficient documentation to support that the single 

occupant of a unit was a member of the Cooperative. If the 

Cooperative cannot do this, it should determine who has the 

right to membership associated with the unit, transfer the 

membership to that person if appropriate, and require him or her 

to move into or sell the unit.

0 

317 █

███ 317 317 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-PH-0001 9/5/2017 001-D 

Reemphasize to field offices the importance of using the correct 

monitoring guide to monitor direct home-ownership assistance 

activities.

0 

2017-CH-1006 9/5/2017 001-Q 

Rent the unit that was used to provide rent-free housing to 

former employees of the management agent to a very low-, low-, 

or moderate-income household selected from a waiting list for 

rental units that meets the requirements of the resident homeownership plan and considers the tenant profile.

0 

2017-CH-1006 9/5/2017 001-M 

Require the member for whom it tried to transfer the 

membership associated with a unit in which the remaining 

member passed away, to move into the unit or continue to 

pursue the release of the member’s membership rights to the 

Cooperative.

0 

2017-CH-1006 9/5/2017 001-N 

Require the members who did not maintain their unit at the 

project as their principal residence to move into the unit or 

continue to pursue the sale of their membership in the 

Cooperative.

0 

2017-CH-1006 9/5/2017 001-K 

Sign the amendment to the use agreement which would require 

the Cooperative to ensure that monthly housing expenses did not 

exceed 35 percent of the members’ monthly adjusted gross 

income only at the time of sale. If the Cooperative does not sign 

the amendment, it should verify the current household income 

for all members to determine whether the members are paying 

more than 35 percent of their households’ monthly adjusted 

gross income for monthly housing expenses. For any members 

that are paying more than 35 percent of their households’ 

monthly adjusted gross income for monthly housing expenses, it 

should determine the amount the household overpaid and 

reimburse the household that amount. It should also implement 

adequate procedures and controls to ensure that members do not 

pay more than 35 percent of their households’ monthly adjusted 

gross income for monthly housing expenses.

0 

2017-FW-1012 9/6/2017 001-H 

We recommend that the Director of HUD’s New Orleans Office 

of Community Planning and Development require the City to 

develop and implement adequate written procedures and 

management controls to ensure that it conducts property 

inspections and onsite monitoring as required, including but not 

limited to establishing protocols for collecting and maintaining 

adequate documentation.

0 

318 █

███ 318 318 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-FW-1012 9/6/2017 001-K 

We recommend that the Director of HUD’s New Orleans Office 

of Community Planning and Development require the City to 

develop tools to improve record-keeping practices and maintain 

appropriate databases to track data related to property 

inspections, onsite monitoring, unit vacancies, HOME program 

participants, available units, tenant-based rental assistance units, 

and rents.

0 

2017-FW-1012 9/6/2017 001-G 

We recommend that the Director of HUD’s New Orleans Office 

of Community Planning and Development require the City to 

establish and implement procedures for ensuring that it performs 

initial income eligibility determinations, has supervisory review 

of determinations, and maintains adequate supporting 

documentation.

0 

2017-FW-1012 9/6/2017 001-E 

We recommend that the Director of HUD’s New Orleans Office 

of Community Planning and Development require the City to 

establish and implement procedures for identifying and 

resolving property ownership transfers by the HOME 

organizations and projects and to ensure ongoing compliance 

with program requirements by project owners.

0 

2017-FW-1012 9/6/2017 001-F 

We recommend that the Director of HUD’s New Orleans Office 

of Community Planning and Development require the City to 

establish and implement procedures to ensure that project 

owners submit required project compliance reports and rents are 

provided annually to the project owners and that it maintains 

documentation showing compliance.

0 

2017-FW-1012 9/6/2017 001-J 

We recommend that the Director of HUD’s New Orleans Office 

of Community Planning and Development require the City to 

implement adequate procedures and controls to ensure the timely 

reporting of program income and that it appropriately spends 

program income.

0 

2017-FW-1012 9/6/2017 001-I 

We recommend that the Director of HUD’s New Orleans Office 

of Community Planning and Development require the City to 

update the IDIS PR-47 HOME Vacant Units Report to include 

accurate and current data and continue this practice periodically.

0 

2017-KC-0007 9/12/2017 001-C 

Clarify guidance to better enhance housing authority 

understanding of the requirement, including explaining that 

housing authorities must code ceiling rent tenants as flat rents 

and explaining what housing authorities should do when 

maximum rents for low-income housing tax credit properties are 

lower than the minimum flat rent amounts required by HUD.

0 

2017-KC-0007 9/12/2017 001-B 

Follow up with the housing authorities in our sample, identified 

as noncompliant with flat rent requirements, to ensure that their 

rents are properly adjusted.

0 

319 █

███ 319 319 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-LA-1008 9/13/2017 002-F 

Consolidate and reconcile all NSP3 home-buyer assistance 

tracking spreadsheets and the general ledger with HUD’s DRGR 

to ensure that all information is accurate and up to date.

0 

2017-LA-1008 9/13/2017 002-G 

Develop and implement written policies and procedures to 

periodically reconcile all NSP3 tracking spreadsheets to ensure 

that data remain accurate and up to date.

0 

2017-LA-1008 9/13/2017 002-B 

Identify any additional closing cost refunds for NSP3 properties 

using the general ledger, DRGR supporting documentation, and 

the property file and either repay the recipients from non-Federal 

funds or update its tracking spreadsheet.

0 

2017-LA-1008 9/13/2017 002-H 

Provide training to all employees responsible for NSP3 to ensure 

that the City adequately determines repayment amounts and 

tracks and records NSP3 activities.

0 

2017-LA-1008 9/13/2017 002-E 

Reclassify home-buyer assistance expenses and refunds from the 

City’s NSP3 ARR program to its NSP3 Homebuyer Assistance 

Program in DRGR and the general ledger.

0 

2017-LA-1008 9/13/2017 001-C Train its staff to ensure that recapture amounts do not exceed net 

sales proceeds. 0 

2017-LA-1008 9/13/2017 001-B 

Update its procedures to ensure that any additional home-buyer 

assistance agreements contain recapture provisions that meet 

HUD recapture requirements relating to the sales price, closing 

costs, and net proceeds.

0 

2017-LA-0004 9/14/2017 001-B 

Develop and implement policies and procedures to ensure that 

the Office of Single Family Asset Management and Office of 

Lender Activities and Program Compliance communicate the 

results of their servicing reviews to each other.

0 

2017-AT-1011 8/21/2017 001-D 

Develop and implement procedures to ensure that it maintains 

books and records that provide the source and uses of all Federal 

funds.

0 

2017-AT-1011 8/21/2017 001-E Ensure that the Authority completes all outstanding annual 

audits. 0 

2017-AT-1011 8/21/2017 001-G Establish, maintain, and follow a waiting list for each project 

individually. 0 

2017-AT-1011 8/21/2017 001-I 

Properly certify all tenants and reimburse any overages paid and 

associated administrative fees for tenants housed after January 1, 

2017, to the project-based voucher program from non-Federal 

funds.

0 

320 █

███ 320 320 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-AT-1011 8/21/2017 001-A 

Provide adequate supporting documentation for the amount of 

Public Housing Capital Fund loan to verify the loan source. If 

another source of Federal funds is determined, repay the amount 

to the appropriate program from non-Federal funds.

0 

2017-AT-1011 8/21/2017 001-B 

Provide support showing the amount of predevelopment fees 

paid. If it is over the allowable amount, that portion should be 

repaid to the project-based voucher program from non-Federal 

funds.

0 

2017-AT-1011 8/21/2017 001-C 

Provide support showing the source and use of funds paid to the 

Terrace Lane, LP, and Southside Village, LP, after the RAD 

conversion or repay the project-based voucher program from 

non-Federal funds.

0 

2017-LA-1007 8/24/2017 002-B 

Implement controls to ensure that all future check request forms 

are complete for proper tracking in its accounting records and 

authorized approver verifies source documentation is attached 

prior to check issuance for future program expenses as required 

by its own policies and procedures.

0 

2017-LA-1007 8/24/2017 001-C 

Require the Authority to establish and implement controls and 

formal written policies and procedures to ensure that accurate 

tribal enrollment numbers are reported to the Formula Service 

Center and HUD for future grant years.

0 

2017-CH-1005 8/25/2017 001-I 

Develop and implement adequate procedures and controls to 

ensure that the project complies with HUD’s requirements and 

its own policies regarding the management of its waiting list.

0 

2017-CH-1005 8/25/2017 001-F Document the implementation of the quality control plan and the 

completed reviews of the tenant certification process. 0 

2017-CH-1005 8/25/2017 001-H 

Review and update the project’s internal transfer waiting list to 

include the applicants’ move-in dates, and the project’s external 

waiting list to include notations showing the reasons why 

applicants were not admitted into the project’s program and why 

applicants were bypassed.

0 

2017-CH-1005 8/25/2017 001-G Revise its occupancy standards to include policies and 

procedures to prevent underuse of the project’s units. 0 

2017-FW-1011 8/29/2017 001-H 

We recommend that HUD’s Associate Deputy Assistant 

Secretary for Single Family Housing assess BLM’s performance 

under the area 1D contract at least quarterly to determine 

whether it has improved its performance. If its performance 

does not improve, coordinate with the Office of the Chief 

Procurement Officer to determine whether BLM was in default 

of its contract and take appropriate action.

0 

321 █

███ 321 321 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-FW-1011 8/29/2017 001-A 

We recommend that the Associate Deputy Assistant Secretary 

for Single Family Housing require BLM to certify and provide 

supporting documentation that the identified deficiencies have 

been corrected for the 57 properties cited in this audit report.

0 

2017-FW-1011 8/29/2017 001-E 

We recommend that the Associate Deputy Assistant Secretary 

for Single Family Housing require BLM to evaluate the structure 

of its exception reports to ensure that they do not omit existing 

hazards and other issues reported by inspectors.

0 

2017-FW-1011 8/29/2017 001-F 

We recommend that the Associate Deputy Assistant Secretary 

for Single Family Housing require BLM to perform required 

background investigations before allowing individuals and 

vendors to work under the contract, and prevent those who have 

not had background checks from performing further work under 

the contract until it determines that they are suitable for the 

duties assigned.

0 

2017-FW-1011 8/29/2017 001-G 

We recommend that the Associate Deputy Assistant Secretary 

for Single Family Housing require BLM to sign its contracts 

with vendors.

0 

2017-CH-1006 9/5/2017 001-U Consider removing from the Cooperative’s board the member 

who did not maintain their unit as their principal residence. 0 

2017-AT-1005 5/24/2017 001-D Report Program income of $31,724 for FL0199L4D001407 to 

HUD. 0 

2017-LA-1003 6/2/2017 001-A 

Develop and implement a written methodology for employees’ 

time allocations for its HUD grant programs in accordance with 

program requirements.

0 

2017-KC-0004 6/2/2017 001-B 

Develop guidance that helps the public understand its options for 

assistance between CDBG-DR and SBA and how to comply 

with Federal requirements.

0 

2017-KC-0004 6/2/2017 001-C 

Develop improved procedures and provide training to 

appropriate staff regarding the departmental clearance process 

requirements, including determining which guidance is 

considered to be a directive, including public communications, 

and ensuring that HUD program participants have clear, 

instructive, and helpful information to comply with the 

applicable requirements and procedures for HUD programs.

0 

2017-LA-1003 6/2/2017 001-B Provide training on compensation for personal services grant 

program requirements to employees working on HUD grants. 0 

2017-KC-0004 6/2/2017 001-A 

Pursue departmental clearance for the July 25, 2013, guidance 

that did not go through required departmental clearance. For 

any items that cannot be appropriately cleared, HUD should take 

appropriate action to recall the document or policy.

0 

322 █

███ 322 322 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-PH-1004 6/9/2017 001-A 

Certify, along with the owners of the 11 units cited in this 

finding, that the applicable housing quality standards violations 

have been corrected.

0 

2017-AT-1006 6/9/2017 002-F 

Confirm the replacement of program units was appropriate for 

the number of units demolished at Johnson Ferry East, and 

submit a development proposal to construct new public housing 

units, transfer public housing assistance to another public 

housing agency, or terminate its annual contributions contract 

and return all unobligated and unexpended capital funds to 

HUD.

0 

2017-PH-1004 6/9/2017 001-C Provide training to its inspectors on conducting housing quality 

standards inspections. 0 

2017-LA-1004 6/13/2017 001-A 

Determine legal sufficiency and if legally sufficient, pursue civil 

and administrative remedies against Cypress Meadows, LLC; 

Skyline Crest Enterprises, LLC; the project’s owner; or all three 

for inappropriately disbursing funds in violation of the project’s 

regulatory agreement, operating lease agreement, and HUD 

requirements.

0 

2017-LA-1004 6/13/2017 001-O 

Develop and implement written policies and procedures for the 

management of the project, including but not limited to financial 

policies for cash disbursements, cash receipts, and 

documentation requirements.

0 

2017-LA-1004 6/13/2017 001-J Obtain approval from HUD for a lease agreement with the hair 

salon. 0 

2017-LA-1004 6/13/2017 001-B 

Pursue appropriate civil money penalties and administrative 

actions, up to and including debarment, against Cypress 

Meadows LLC; Skyline Crest Enterprises LLC; the project’s 

owner; or all three for violating the project’s regulatory 

agreement, operating lease agreement, and HUD requirements.

0 

2017-LA-1004 6/13/2017 001-N Remove Skyline Crest Enterprises, LLC, as the operator and 

replace it with a HUD-approved independent operator. 0 

2017-LA-1005 6/16/2017 001-G 

Implement additional policies and procedures to ensure that 

salaries and wages and cost allocations are charged in 

compliance with HUD requirements.

0 

2017-LA-1005 6/16/2017 001-H 

Implement additional procedures and controls to ensure that 

documentation is obtained to support that the limited clientele 

national objective was met.

0 

2017-LA-1005 6/16/2017 001-I Obtain training or technical assistance on CDBG program 

requirements. 0 

323 █

███ 323 323 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-FW-1008 6/28/2017 001-F 

Take appropriate administrative sanctions, including suspension, 

limited denial of participation, or debarment, against the 

commissioners.

0 

2017-FW-1008 6/28/2017 001-D 

We recommend that the Director of the San Antonio Office of 

Public Housing require the Authority to adopt policies and 

procedures that contain current Federal and State guidance.

0 

2017-FW-1009 6/29/2017 001-D 

We further recommend that the Southwest Region Director of 

Multifamily Housing require its contract administrator for 

Beverly Place to verify that the owner’s recently implemented 

quality control program is working as designed.

0 

2017-CH-1002 7/7/2017 001-I 

Ensure that it obtains a separate interest-bearing depository 

account for its program participants’ escrow funds in accordance 

with HUD’s requirements.

0 

2017-CH-1002 7/7/2017 001-J 

Ensure that its staff is appropriately trained and familiar with 

HUD’s requirements and its program action plan regarding the 

administration of its program to ensure that (1) participants’ 

contracts of participation and individual training and services 

plans are properly updated and contain the necessary signatures; 

(2) changes in participants’ files are properly identified and 

notated; and (3) participants are notified of changes in their 

monthly escrow deposits, total escrow balances, or both.

0 

2017-CH-1002 7/7/2017 001-O 

Provide technical assistance and guidance to the Authority to 

ensure that it properly administers its Family Self-Sufficiency 

program.

0 

2017-CH-1002 7/7/2017 001-B 

Reconcile the current program participants and related 

information in its internal systems with the current participants 

listed in HUD’s systems.

0 

2017-CH-1002 7/7/2017 001-M Review the Authority’s graduate documentation and adjust the 

Authority’s minimum program size as necessary. 0 

2017-CH-1002 7/7/2017 001-N 

Review the Authority’s Section Eight Management Assessment 

Program scores for the Family Self-Sufficiency program and 

adjust as necessary.

0 

2017-FW-0001 7/10/2017 001-A 

We recommend that the General Deputy Assistant Secretary for 

Community Planning and Development develop and implement 

a quality review process at the headquarters level to ensure 

consistent compliance with its policy for risk analysis, to include 

but not be limited to reviewing supporting documentation for 

conclusions drawn.

0 

324 █

███ 324 324 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-FW-0001 7/10/2017 001-B 

We recommend that the General Deputy Assistant Secretary for 

Community Planning and Development, develop and implement 

a policy requiring field offices to rate grantees of at least 

medium risk that have not been monitored in their respective 

program area within the last 3 years on factors that require 

assessments of capacity, program complexity, and monitoring 

findings resulting in repayment or grant reductions.

0 

2017-FW-0001 7/10/2017 001-D 

We recommend that the General Deputy Assistant Secretary for 

Community Planning and Development, develop and implement 

a quality control review process at the headquarters level to 

ensure compliance with monitoring requirements for reports and 

exhibits, to include but not be limited to explaining procedures 

performed and adequately explaining and providing supporting 

documentation for conclusions drawn.

0 

2017-FW-0001 7/10/2017 001-C 

We recommend that the General Deputy Assistant Secretary for 

Community Planning and Development, develop and implement 

guidance for field offices to maintain supporting documentation 

in their official files with an adequate explanation of procedures 

performed to verify risk scores assigned, which could include 

upgrading CPD’s systems to allow for the attachment of 

supporting documentation for risk analyses.

0 

2017-FW-0001 7/10/2017 001-E 

We recommend that the General Deputy Assistant Secretary for 

Community Planning and Development, require field offices to 

upload referenced supporting documentation into CPD’s system 

for findings and concerns developed during the monitoring 

review.

0 

2017-FW-0001 7/10/2017 001-F 

We recommend that the General Deputy Assistant Secretary for 

Community Planning and Development, update exhibits to 

require staff to document procedures performed, provide 

sufficient explanation to verify procedures performed and 

conclusions drawn, and reference appropriate supporting 

documentation.

0 

2017-KC-0006 7/14/2017 001-A Complete the rulemaking process for HUD’s single-family note 

sales program. 0 

2017-CH-1003 7/14/2017 002-E 

Deposit the Family Self-Sufficiency program escrow funds into 

an interest-bearing account in accordance with HUD’s 

requirements.

0 

2017-KC-0006 7/14/2017 001-B Develop and implement formal procedures and guidance for the 

note sales program. 0 

2017-CH-1003 7/14/2017 002-F Ensure that the program coordinator is trained on and familiar 

with HUD’s regulations. 0 

325 █

███ 325 325 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-CH-1003 7/14/2017 001-C 

Evaluate its administration of the program and take the 

appropriate actions to ensure that the program is managed 

effectively.

0 

2017-CH-1003 7/14/2017 002-H 

Evaluate its administration of the program to ensure it has the 

necessary capacity and resources to effectively manage the 

program.

0 

2017-CH-1003 7/14/2017 002-G 

Implement quality control procedures to ensure that (1) 

documentation required by HUD is correctly completed and 

maintained, (2) escrow account disbursements are appropriate 

and fully supported, (3) escrow account deposits are correctly 

calculated and recorded, and (4) the contracts of participation 

contain information that reflects participants’ current income 

and family rent amounts. The controls should include 

procedures for the review and approval of contract extensions 

and escrow account disbursements.

0 

2017-AT-1007 7/17/2017 001-C Ensure that the Land Bank completes and clears all outstanding 

annual audits for fiscal years 2012 through 2016. 0 

2017-AT-1007 7/17/2017 001-D 

Ensure that the Land Bank develops and implements adequate 

financial and file management policies and procedures to ensure 

that files are auditable and financial records adequately identify 

the source and application of federally sponsored activities in 

accordance with Federal regulations.

0 

2017-AT-1007 7/17/2017 001-A 

Provide adequate monitoring to the Land Bank to ensure that the 

subrecipient follows Federal regulations as required, including 

policies and procedures to help verify subrecipient compliance 

or address any deficiencies in need of correcting, such as annual 

audits, financial management systems, and file management.

0 

2017-AT-1008 7/21/2017 001-A 

Develop and implement HUD-approved policies and procedures 

to ensure that the process for conducting an internal audit 

complies with HUD regulations and the policies and procedures 

are submitted and certified to HUD.

0 

2017-AT-1008 7/21/2017 001-B Immediately conduct an internal audit of the CDBG-DR grant 

funds. 0 

2017-AT-1009 7/21/2017 001-D Implement adequate procedures for sufficiently monitoring its 

project sponsors’ cash management. 0 

2017-AT-1009 7/21/2017 001-C 

Provide adequate training to staff responsible for reviewing and 

approving the expenditures to ensure compliance with HUD’s 

and Louisville Metro’s requirements for the administration of 

the HOPWA program, including processing program 

disbursements and monitoring project sponsors’ cash 

management.

0 

326 █

███ 326 326 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-AT-1008 7/21/2017 001-C Update, finalize, and implement its procurement policies to 

comply with 2 CFR 200.317-326. 0 

2017-AT-1010 8/4/2017 001-B 

Certify, along with the owners of the 103 units cited in the 

finding, that the applicable housing quality standards violations 

have been corrected.

0 

2017-AT-1010 8/4/2017 002-D 

Complete a rent reasonableness determination for all current 

units for which a determination was required but not completed. 

The Authority should reimburse the program from non-Federal 

funds for any overpaid rental subsidy.

0 

2017-AT-1010 8/4/2017 002-B 

Complete a review of rental subsidy abatements for all current 

units for which a retroactive abatement was not conducted. The 

Authority should reimburse the program from non-Federal funds 

for any overpaid rental subsidy.

0 

2017-AT-1010 8/4/2017 002-F 

Complete a review that owners of current assisted units are not 

debarred, suspended, or subject to a limited denial of 

participation.

0 

2017-AT-1010 8/4/2017 001-C 

Develop and implement adequate policies and procedures for 

conducting quality control inspections in accordance with 

HUD’s requirements.

0 

2017-AT-1010 8/4/2017 002-C Develop and implement written procedures and a process for 

retroactively abating housing assistance payments. 0 

2017-AT-1010 8/4/2017 002-G Develop and implement written procedures for conducting a 

complete owner eligibility determination. 0 

2017-AT-1010 8/4/2017 002-E 

Develop and implement written procedures to ensure that a rent 

reasonableness determination is performed before rent increases 

are approved.

0 

2017-AT-1010 8/4/2017 002-H Provide adequate training to its staff to ensure compliance with 

HUD’s requirements for program units. 0 

2017-LA-1006 8/9/2017 001-L 

Develop and implement a monitoring program within the City’s 

Development and Resource Management Department to ensure 

that it periodically monitors and provides guidance to its 

subrecipient(s) and City departments on how to administer 

CDBG funds.

0 

2017-LA-1006 8/9/2017 001-K 

Develop and implement written policies and procedures for 

specific departments, update and implement CDBG-specific 

written policies and procedures, and provide formal training and 

technical assistance to the Development and Resource 

Management Department employees to ensure that they 

understand and follow CDBG requirements.

0 

327 █

███ 327 327 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-LA-1006 8/9/2017 001-J Execute contractual agreements with each CDBG recipient 

department to ensure compliance with all Federal guidelines. 0 

2017-LA-1006 8/9/2017 001-B 

Suspend funding to its code enforcement program until it can 

show that it has implemented controls, addressed its capacity 

issues, and understands and abides by HUD requirements.

0 

2017-FW-1004 4/6/2017 001-F 

We recommend that the Director of HUD’s New Orleans Office 

of Community Planning and Development require the Parish to 

implement an internal audit function that satisfies program 

requirements.

0 

2017-FW-1004 4/6/2017 001-I 

We recommend that the Director of HUD’s New Orleans Office 

of Community Planning and Development require the Parish to 

obtain technical assistance concerning the disaster recovery 

program requirements, including related Federal Register 

requirements. Specifically, the technical assistance should 

include guidance on how to satisfy the requirement regarding 

maintaining an internal audit function and Web site 

maintenance.

0 

2017-FW-1004 4/6/2017 001-G 

We recommend that the Director of HUD’s New Orleans Office 

of Community Planning and Development require the Parish to 

revise its monitoring policy to include the role of the internal 

auditor once implemented, and finalize and fully implement or 

revise its fraud, waste, and abuse detection policy to reflect 

current procedures.

0 

2017-LA-1001 4/13/2017 001-G Develop and implement policies and procedures that ensure 

labor wage interviews are completed and documented. 0 

2017-LA-1001 4/13/2017 001-F 

Develop and implement procurement policies and procedures for 

monitoring subrecipients to ensure that the scope of work 

developed by its subrecipients is sufficiently detailed to allow 

contractors to submit informed bids, reducing the number of 

change orders after the contract, and that its subrecipients do an 

independent cost analysis before all procurement transactions, 

including change orders, to ensure that it receives a reasonable 

price and allows for full and open competition.

0 

2017-LA-1001 4/13/2017 002-B 

Develop monitoring practices to ensure that all projects that use 

limited clientele criteria exclusively serve the specific 

population claimed.

0 

2017-LA-1001 4/13/2017 003-F 

Obtain training or technical assistance from HUD concerning 

CDBG code enforcement, allocation of payroll, and indirect 

administrative costs.

0 

2017-LA-1001 4/13/2017 001-E 

Provide support showing that the ADA pool improvement 

project allows equal and independent access for people with

disabilities through a third party or correct the access issue.

0 

328 █

███ 328 328 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-LA-1001 4/13/2017 001-H 

Provide training to its staff on CDBG program rules and 

requirements to ensure that its staff adequately implements 

policies and procedures.

0 

2017-BO-1005 4/21/2017 001-B 

Amend and resubmit the management agreements and the 

management certifications for HUD approval and ensure that the 

agreements do not conflict with the management certifications.

0 

2017-BO-1005 4/21/2017 001-A Develop and implement adequate controls over payments for 

services that are part of the management fee. 0 

2017-BO-1005 4/21/2017 001-C Identify all unallowable fees and reimburse from non-project 

funds. 0 

2017-FW-1005 4/25/2017 001-H 

Compare current participant and financial data to the EIV and 

PIC system data to ensure that all participant data were 

accurately submitted and reported.

0 

2017-FW-1005 4/25/2017 001-D 

Develop and implement controls to identify errors and ensure 

that housing assistance payments are correctly calculated and 

paid, leases run concurrently with the housing assistance 

payments contract, required eligibility documentation is 

maintained, rent reasonableness is completed before executing 

the housing assistance payments contract and lease, the correct 

utility allowance rate is used, and documentation to support 

completed background checks is maintained.

0 

2017-FW-1005 4/25/2017 001-G 

Develop written policies and procedures, to include HUD’s 

requirements to (1) properly report participant data in the PIC 

system, (2) report repayments and debts owed in the EIV 

system, and (3) monitor EIV reports.

0 

2017-FW-1005 4/25/2017 001-F Ensure that it executes form HUD-52675 with all program 

participants and adult household members. 0 

2017-FW-1005 4/25/2017 001-J Provide training to its staff to ensure that it is familiar with all 

HUD documentation and reporting requirements. 0 

2017-FW-1005 4/25/2017 001-I 

Revise its administrative plan to ensure that it accurately reflects 

current HUD requirements and the Authority’s current policies 

and procedures.

0 

2017-FW-1005 4/25/2017 001-E 

Revise its written policies and procedures to ensure that it 

administers its participant repayment agreements in compliance 

with requirements.

0 

2017-FW-1006 4/26/2017 002-B Monitor the Authority to ensure it is holding its board meetings, 

as required by its bylaws. 0 

2017-FW-1006 4/26/2017 002-A Provide technical assistance to the Mayor and the board 

concerning their responsibilities regarding the Authority. 0 

329 █

███ 329 329 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-FW-1006 4/26/2017 001-I Provide training for the Authority’s commissioners on their 

responsibilities and duties. 0 

2017-FW-1006 4/26/2017 001-J Require the Authority to update its policies and procedures so 

that they contain current Federal guidance. 0 

2017-FW-1006 4/26/2017 001-M 

We recommend that the Associate General Counsel for Program 

Enforcement determine legal sufficiency and, if legally 

sufficient, pursue remedies under the Program Fraud Civil 

Remedies Act against the executive director.

0 

2017-FW-1006 4/26/2017 001-K 

We recommend that the Director, Departmental Enforcement 

Center take appropriate administrative sanctions, including 

suspension, limited denial of participation, or debarment against 

the executive director.

0 

2017-AT-0001 4/27/2017 001-G Develop and implement a tracking system for monitoring 

reviews of Section 108 loans. 0 

2017-AT-0001 4/27/2017 001-D 

Develop procedures directing field offices to include the review 

of Section 108-funded activities when performing the annual 

reviews of Block Grant recipients.

0 

2017-AT-0001 4/27/2017 001-E 

Develop procedures to ensure that the information necessary to 

monitor program performance and compliance with program 

requirements is promptly provided to the field offices.

0 

2017-AT-0001 4/27/2017 001-F 

Implement procedures to ensure that borrowers comply with all 

loan contract provisions and that required documents are 

submitted, including bank agreements, monthly statements, and 

security documents. If a borrower does not provide evidence that 

it has complied with all program requirements, HUD must 

initiate appropriate remedial actions under paragraph 12 of the 

contract.

0 

2017-AT-1004 5/8/2017 001-D 

Review all administration drawdown vouchers and provide 

documentation to support that the drawdowns for estimated 

payroll costs are reconciled with the actual payroll costs for the 

pay periods. Any calculated overpayment by NSP should be 

returned to the program to meet program purposes.

0 

2017-FO-0006 5/11/2017 004-B 

Develop and implement steps to ensure that adequate disclosures 

are made when future-year reduction targets for improper 

payments reported in the AFR are higher than the current-year 

improper payment estimates.

0 

330 █

███ 330 330 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-FO-0006 5/11/2017 004-A 

Develop and implement steps to ensure that the description of 

corrective actions highlights current efforts and key milestones 

for ongoing efforts and explain in the AFR how it specifically 

tailored its corrective actions to better reflect the unique 

processes, procedures, and risks involved with RHAP as 

required by OMB.

0 

2017-FO-0006 5/11/2017 004-C 

Disclose in the AFR the results of HUD’s review concerning its 

current performance against program-specific improper payment 

reduction targets to promote transparency.

0 

2017-FO-0006 5/11/2017 001-A Ensure that all payments to Federal employees are included in 

HUD’s periodic risk assessment cycle. 0 

2017-FO-0006 5/11/2017 001-B 

Establish and implement procedures and controls, in 

coordination with FHA, to ensure that FHA information reported 

in the AFR is accurate and consistent with supporting 

documents.

0 

2017-FW-1007 5/17/2017 001-D 

We recommend that the Program Center Coordinator, Office of 

Public Housing, Oklahoma City, OK, require the Authority to 

implement policies and procedures to monitor the EIV income 

discrepancy reports each quarter to minimize subsidy payment 

errors.

0 

2017-FW-1007 5/17/2017 001-C 

We recommend that the Program Center Coordinator, Office of 

Public Housing, Oklahoma City, OK, require the Authority to 

strengthen its compliance with requirements by implementing a 

quality control system that would require management to review 

a sample number of income calculations, ensure staff follow-up 

on income discrepancies and document their analysis.

0 

2017-NY-0001 5/18/2017 001-B 

We recommend that HUD’s Deputy Assistant Secretary for 

Public Housing Investments direct staff to develop and 

implement policies and procedures with the Office of Field 

Operations regarding identification of potentially distressed 

projects and monitoring and enforcement of the required 

conversion program.

0 

2017-PH-1003 5/22/2017 002-C Correct the errors in the tenant files identified during the audit. 0 

2017-PH-1003 5/22/2017 001-D 

Develop and implement written procedures to ensure that it 

obtains written cost estimates as required and maintains 

complete documentation to support expenditures and that 

contractors performing or managing construction, removal, 

repair, or improvement work are properly licensed as required.

0 

2017-KC-0003 5/22/2017 001-C Improve its procedures for detecting and sanctioning improper 

voluntary terminations. 0 

331 █

███ 331 331 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-KC-0003 5/22/2017 001-B 

Remind lenders that voluntary termination is not the correct 

termination type to record third-party sales and that borrower 

consent is required to terminate insurance, even if the loans are 

indemnified.

0 

2017-PH-1003 5/22/2017 002-D 

Review the issues identified in this audit report and if 

appropriate, pursue administrative sanctions against the board of 

directors for the violations cited in this report.

0 

2017-AT-1005 5/24/2017 001-F 

Perform onsite monitoring of the subrecipient that administered 

project FL0431L4D001403 to ensure that participants are 

eligible and annual income re-certifications are performed.

0 

2017-AT-1005 5/24/2017 001-C 

Provide guidance to subrecipients to ensure that (1) on-the-job 

training hours are supported by source documents, such as 

signed attendance or time sheets, and (2) personal goods and 

services are supported by documents that show the allocation 

between business and personal use.

0 

2017-NY-1005 1/13/2017 001-B 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct County 

officials to strengthen the County’s administrative controls to 

ensure that its HOME program is reimbursed for assistance 

spent on terminated or noncompliant activities.

0 

2017-NY-1005 1/13/2017 001-C 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct County 

officials to provide environmental review documentation, such 

as environmental assessment and a phase I environmental 

review, for the activity to support compliance with 

environmental review requirements.

0 

2017-NY-1005 1/13/2017 001-D 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct County 

officials to provide procurement documentation, such as proof of 

advertising, bids received, bid analysis reports, contracts, and 

other documents, for contracts associated with the three 

activities to support compliance with procurement requirements.

0 

2017-NY-1005 1/13/2017 001-H 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct County 

officials to strengthen the County’s administrative controls to 

ensure compliance with environmental, procurement, and other 

program requirements.

0 

2017-NY-1005 1/13/2017 001-I 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct County 

officials to provide HOME program training to County staff to 

ensure compliance with HOME program requirements.

0 

332 █

███ 332 332 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-NY-1005 1/13/2017 001-N 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct County 

officials to reconcile the County’s carryover balance of HOME 

match as of September 30, 2015, for the ineligible HOME match 

contributions and the understated HOME match contributions.

0 

2017-NY-1005 1/13/2017 001-P 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct County 

officials to strengthen the County’s financial controls over 

reconciling bank records to ensure that HOME funds in the local 

bank account are spent before drawdowns are made from 

LOCCS.

0 

2017-NY-1005 1/13/2017 001-Q 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct County 

officials to provide documentation, such as pay stubs and leases, 

to support compliance with HOME program rent limit and 

income eligibility requirements for the six tenants who occupied 

HOME-assisted units.

0 

2017-NY-1005 1/13/2017 001-S 

We recommend that the Director of HUD’s Newark, NJ, Office 

of Community Planning and Development instruct County 

officials to strengthen the County’s administrative controls to

ensure that County staff adequately monitors its subgrantee for 

compliance with HOME program requirements and provide 

HOME program training to the County subgrantee’s staff.

0 

2017-KC-0002 1/20/2017 001-B 

Require public housing agencies to report the program 

admission date to any multifamily property listed on the 

Enterprise Income Verification existing tenant search during the 

admission process.

0 

2017-KC-0002 1/20/2017 001-C 

Require public housing agencies to maintain support for any 

communication with a multifamily property listed on the 

Enterprise Income Verification existing tenant search.

0 

2017-KC-0002 1/20/2017 001-D 

Require HUD staff to review Enterprise Income Verification 

reports from the last 12-month period during onsite housing 

agency reviews to ensure that any multiple subsidies have been 

resolved.

0 

2017-CH-1001 1/24/2017 001-B 

Implement adequate procedures and controls, including but not 

limited to developing a plan to manage its central office cost 

center expenses and determining an appropriate fee structure 

with HUD’s approval that would allow it to operate its program 

within HUD’s requirements.

0 

333 █

███ 333 333 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-CH-1001 1/24/2017 001-C 

Implement adequate procedures and controls, including but not 

limited to providing training to its staff to ensure that the 

Commission fully implements asset management and operates 

its program in accordance with HUD’s requirements.

0 

2017-BO-1003 1/24/2017 001-D 

Develop and implement controls over payments to include; 

ensuring that its management agreement clearly identifies 

services that are be provided by the management agent and paid 

for as part of the management fee, and the project is not charged 

for services that are part of the management fee.

0 

2017-LA-0002 1/25/2017 001-A 

Pursue departmental clearance for the 13 documents and policies 

identified that did not go through required departmental 

clearance. For any items that cannot be appropriately cleared, 

HUD should take appropriate action to recall the document or 

policy.

0 

2017-LA-0002 1/25/2017 001-C 

Review the Clearance Calendar and ensure that appropriate form 

HUD-22 concurrence forms were obtained and documented for 

directives issued by other HUD offices.

0 

2017-LA-0002 1/25/2017 001-D 

Implement controls to ensure that future directives are reviewed 

and documented in the Clearance Calendar tracking system as 

required.

0 

2017-LA-0002 1/25/2017 001-E 

Update policies and procedures for the directives process, 

including responsibilities for process oversight and clear 

guidance defining when clearance is required.

0 

2017-LA-0002 1/25/2017 001-F 

Develop and provide training to appropriate staff and required 

reviewing offices regarding the departmental clearance process 

requirements.

0 

2017-NY-1006 1/31/2017 001-C 

We recommend that the Director of HUD’s New York Office of 

Public Housing require Authority officials to establish and 

implement procedures and effective financial controls to ensure 

that costs charged to the public housing program are properly 

incurred and comply with applicable regulations.

0 

2017-DP-0001 2/1/2017 001-A Not released to public. 0 

2017-DP-0001 2/1/2017 001-B Not released to public. 0 

2017-DP-0001 2/1/2017 001-C Not released to public. 0 

2017-DP-0001 2/1/2017 001-D Not released to public. 0 

2017-DP-0001 2/1/2017 001-E Not released to public. 0 

2017-DP-0001 2/1/2017 001-H Not released to public. 0 

2017-DP-0001 2/1/2017 001-I Not released to public. 0 

334 █

███ 334 334 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-DP-0001 2/1/2017 001-J Not released to public. 0 

2017-DP-0001 2/1/2017 001-K Not released to public. 0 

2017-DP-0001 2/1/2017 001-L Not released to public. 0 

2017-DP-0002 2/9/2017 001-A Not released to public. 0 

2017-DP-0002 2/9/2017 001-B Not released to public. 0 

2017-DP-0002 2/9/2017 001-C Not released to public. 0 

2017-DP-0002 2/9/2017 002-A Not released to public. 0 

2017-DP-0002 2/9/2017 002-B Not released to public. 0 

2017-DP-0002 2/9/2017 002-C Not released to public. 0 

2017-DP-0002 2/9/2017 003-C Not released to public. 0 

2017-DP-0002 2/9/2017 004-A Not released to public. 0 

2017-DP-0002 2/9/2017 004-B Not released to public. 0 

2017-DP-0002 2/9/2017 004-D Not released to public. 0 

2017-DP-0002 2/9/2017 005-B Not released to public. 0 

2017-DP-0002 2/9/2017 005-C Not released to public. 0 

2017-DP-0002 2/9/2017 006-A Not released to public. 0 

2017-DP-0002 2/9/2017 006-B Not released to public. 0 

2017-DP-0002 2/9/2017 006-C Not released to public. 0 

2017-DP-0002 2/9/2017 006-D Not released to public. 0 

2017-DP-0002 2/9/2017 006-E Not released to public. 0 

2017-DP-0002 2/9/2017 006-F Not released to public. 0 

2017-DP-0002 2/9/2017 006-G Not released to public. 0 

2017-DP-0002 2/9/2017 007-D Not released to public. 0 

2017-DP-0002 2/9/2017 008-A Not released to public. 0 

2017-NY-1007 2/17/2017 001-B

We recommend that the Acting Deputy Assistant Secretary for

Single Family Housing instruct Seneca Mortgage to ensure that 

reimbursement is not requested for holding costs incurred 

beyond the conveyance deadline related to FHA loan number 

281-3493258.

0 

335 █

███ 335 335 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-NY-1007 2/17/2017 001-C

We recommend that the Acting Deputy Assistant Secretary for 

Single Family Housing instruct Seneca Mortgage to instruct the 

investors or holders for FHA loan numbers 501-7067695, 501-

6877136, 061-0982338, and 501-5885504 to transfer these loans 

to FHA-approved servicers.

0 

2017-NY-1007 2/17/2017 001-D

We recommend that the Acting Deputy Assistant Secretary for 

Single Family Housing instruct Seneca Mortgage to implement 

procedures to ensure that FHA loans are transferred only to 

FHA-approved servicers regardless of investor input.

0 

2017-NY-1007 2/17/2017 001-E

We recommend that the Acting Deputy Assistant Secretary for 

Single Family Housing instruct Seneca Mortgage to strengthen 

conveyance procedures to ensure that properties are transferred 

to HUD within 30 days of securing the property, thereby 

ensuring that ineligible costs are not paid by HUD on future 

loans submitted for claim.

0 

2017-NY-1007 2/17/2017 001-F

We recommend that the Acting Deputy Assistant Secretary for 

Single Family Housing instruct Seneca Mortgage to strengthen 

program controls and procedures to ensure that servicing efforts 

are accurately reported in HUD systems, thereby complying 

with HUD’s loss mitigation requirements.

0 

2017-NY-1007 2/17/2017 001-G

We recommend that the Acting Deputy Assistant Secretary for 

Single Family Housing review the part B claim paid for FHA 

loan number 501-7612832, determine the amount of holding 

costs paid after the conveyance deadline, and require the 

relevant servicer to repay the ineligible holding costs to the FHA 

insurance fund.

0 

2017-NY-1007 2/17/2017 002-A

We recommend that the Acting Deputy Assistant Secretary for 

Single Family Housing instruct Seneca Mortgage officials to 

develop and implement program controls and procedures for 

FHA-insured loans being subserviced by another lender, 

including procedures for conducting quality control reviews of 

the subservicer’s actions.

0 

2017-FO-0005 3/1/2017 001-A

Evaluate the current content of HUD’s financial statement note 

disclosures to identify outdated or irrelevant information that 

may not be needed, while maintaining compliance with OMB 

Circular A-136 and presenting the reader with the information 

necessary to understand HUD’s financial statements.

0 

2017-FO-0005 3/1/2017 001-B

Work with FHA and Ginnie Mae to reevaluate the note 

consolidation process to determine changes that can be made to 

the process to ensure compliance with financial reporting 

requirements.

0 

336 █

███ 336 336 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-FO-0005 3/1/2017 001-C 

Reassess HUD’s current consolidated financial statement and 

notes review process to ensure that (1) all reviewers have 

sufficient financial reporting experience; (2) it includes steps to 

verify that the notes match HUD’s financial statements, are 

sufficiently supported, and accurately include FHA and Ginnie 

Mae information; and the review can be completed within the 

required timeframe needed to allow for audit.

0 

2017-FO-0005 3/1/2017 001-D 

Develop a plan to ensure that restatements to HUD’s 

consolidated financial statements are properly reflected in all 

notes impacted by the restatement.

0 

2017-FO-0801 3/2/2017 001-A 

Request sufficient monetary resources to upgrade HUD’s many 

legacy and financial systems so its technologies and data 

elements no longer differ and can perform the necessary data 

inventory and mapping to report HUD’s information in 

USASpending.gov accurately and in a timely manner.

0 

2017-FO-0801 3/2/2017 001-B 

Ensure that HUD program officials continue taking appropriate 

steps to fully resolve its errors and data quality issues that the 

agency identified during implementation, including those related 

to assigning a unique identifier consistent with the established 

DATA Act schema, such as the Federal Award Identification 

Number.

0 

2017-AT-1003 3/2/2017 001-C 

Submit a plan showing how it will proceed regarding the 

Yabucoa, Juncos, and Barceloneta housing projects, including a 

schedule that HUD can track to ensure their completion.

0 

2017-FO-0801 3/2/2017 001-C 

Designate official DATA Act points of contact for FHA and 

Ginnie Mae and oversee the progress of the two HUD 

components’ individual implementation plans, ensuring timely 

and successful completion of their steps.

0 

2017-FO-0801 3/2/2017 001-D 

Finalize required mapping of HUD’s, including FHA’s and 

Ginnie Mae’s, financial, budgetary and programmatic data, as 

required by the DATA Act and OMB guidance.

0 

2017-AT-1003 3/2/2017 001-E 

Develop and implement written policies detailing procedures 

and responsibilities related to program administration and 

monitoring of the escrow program.

0 

2017-AT-1003 3/2/2017 002-A 

Transfer all escrow funds to a financial institution that is 

supervised by the Federal Deposit Insurance Corporation or the 

National Credit Union Administration and ensure that all 

deposits are secured by the Federal Government. Any amount 

not recovered from the Development Bank must be reimbursed 

to the escrow account from non-Federal funds.

0 

337 █

███ 337 337 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-AT-1003 3/2/2017 002-B 

Submit required certifications and supporting documentation 

showing that residents of escrow-funded activities met the 

established income limit requirements. Any amounts 

determined ineligible must be reimbursed to the escrow account 

from non-Federal funds.

0 

2017-LA-0003 3/3/2017 001-A 

Reconsider HUD’s position on questioned borrower-financed 

downpayment assistance programs, including an analysis of the 

financial impact to FHA borrowers, risk to the FHA program, 

and whether current statute prohibits borrower-financed 

downpayment assistance programs as they are currently 

structured.

0 

2017-LA-0003 3/3/2017 001-B 

Develop and implement policies and procedures to strengthen 

HUD’s comprehensive loan-level, postendorsement, and lender 

reviews by evaluating loans containing downpayment assistance 

(for example, interest rates, fees, borrower certifications, lender 

reviews, impact to borrower, related agreements, etc.). Policies 

and procedures should include evaluating the structure of 

downpayment assistance programs, including whether the 

programs’ structure and funding mechanisms comply with all 

HUD requirements and guidelines.

0 

2017-LA-0003 3/3/2017 001-C 

Develop specific requirements and guidance for lenders to 

review HFA downpayment assistance programs (for example, 

interest rates, fees, borrower certifications, lender reviews, 

impact to borrower, related agreements, etc.). Requirements and 

guidance should include evaluating the structure of 

downpayment assistance programs, including whether the 

programs’ structure and funding mechanisms comply with all 

HUD requirements and guidelines.

0 

2017-KC-1002 3/3/2017 001-D Require New Horizons to obtain independent management. 0 

2017-LA-0003 3/3/2017 001-D 

Require lenders to obtain a borrower certification that details 

their participation in an HFA downpayment assistance program, 

including relevant details of the specific program (for example, 

impact on interest rate, mortgage payments, fees, equity, 

acknowledgement of other less costly loan products, etc.).

0 

2017-KC-1002 3/3/2017 001-E Require New Horizons to conduct a review to determine who 

currently lives in the units and verify their eligibility. 0 

2017-LA-0003 3/3/2017 001-E 

Ensure that lenders enter accurate and missing downpayment 

assistance gift data into FHA Connection when identified by 

HUD.

0 

338 █

███ 338 338 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-KC-1002 3/3/2017 001-F

Monitor New Horizons to ensure that it properly maintains 

tenant files, completes required annual recertifications, and 

supports disability exemptions in accordance with HUD 

requirements.

0 

2017-LA-0003 3/3/2017 001-F

Implement new data fields where lenders would be required to 

enter specific downpayment assistance information (for 

example, name of the source, name of assistance program, name 

of government entity or HFA, etc.) to allow for auditability and 

for HUD to generate reports and perform risk assessments.

0 

2017-LA-0003 3/3/2017 001-G

Review fees identified in this report that were charged as part of 

borrower-financed downpayment assistance programs and 

determine whether they are reasonable or necessary. HUD 

should immediately notify lenders to discontinue charging any 

fees that are determined to be unreasonable and unnecessary.

0 

2017-LA-0003 3/3/2017 001-H

Require any participating lender to reimburse borrowers that 

received an FHA loan with borrower-financed downpayment 

assistance for any fees that were determined to be unreasonable 

and unnecessary.

0 

2017-NY-1008 3/10/2017 001-D

We recommend that the Acting Director of HUD’s Newark 

Office of Public Housing instruct Authority officials to 

implement policies and procedures to ensure accountability for 

travel and training costs and require the Authority to maintain 

adequate supporting documents for travel, training, health 

coverage waiver incentives, supplies, food, decorations, and any 

other costs charged to the Capital Fund and Operating Fund to 

ensure that costs were actually incurred, necessary, reasonable 

and allowable.

0 

2017-NY-1008 3/10/2017 001-I

We recommend that the Acting Director of HUD’s Newark 

Office of Public Housing instruct Authority officials to obtain 

retroactive approval from HUD for the pending litigation related 

to issues with the elevators. If approval is not obtained, the 

Authority should withdraw the lawsuit.

0 

2017-NY-1008 3/10/2017 001-O

We recommend that the Acting Director of HUD’s Newark 

Office of Public Housing instruct Authority officials to develop 

and implement an appropriate policy for program income, 

including the proper use, accounting, and reporting of program 

income in accordance with the Federal definition and treatment 

of program income.

0 

2017-NY-1008 3/10/2017 001-Q

We recommend that the Director of HUD’s Departmental 

Enforcement Center pursue administrative sanctions against any 

current or former Authority officials found to have spent public 

housing program funds for personal or unallowable use.

0 

339 █

███ 339 339 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-PH-1001 3/22/2017 001-E

Revise its policies and procedures to address compliance with 

applicable procurement regulations requiring independent cost 

estimates before receiving bids or proposals.

0 

2017-PH-1001 3/22/2017 001-F Train its staff on requirements for documenting costs funded by 

multiple funding sources. 0 

2017-PH-1001 3/22/2017 001-G

Develop and implement controls to ensure that subrecipients 

comply with requirements for documenting costs funded by 

multiple funding sources.

0 

2017-PH-1001 3/22/2017 001-H

Determine whether it has complied with environmental review 

requirements for all activities since October 2010 and provide a 

copy of its determination to HUD. If it did not comply, either 

provide the necessary support for the activities or repay its 

program from non-Federal funds for any activity costs it cannot 

support.

0 

2017-PH-1001 3/22/2017 001-I Develop and implement controls to ensure that it complies with 

environmental review requirements. 0 

2017-PH-1001 3/22/2017 001-J

Review accomplishment data that it reported in IDIS for open 

and completed activities to ensure that accomplishments were 

reported accurately.

0 

2017-PH-1001 3/22/2017 001-K

Train its staff on reporting accomplishments in IDIS and 

develop and implement policies and procedures for supervisory 

review to ensure accuracy.

0 

2017-PH-1001 3/22/2017 001-L

Include compliance with environmental review requirements in 

its project-specific reviews in its next periodic monitoring of the 

City’s Block Grant program.

0 

2017-PH-1002 3/24/2017 001-G

Develop and implement controls to ensure that financial 

statements are submitted to HUD in a timely manner, including 

paying the correct amount of annual payments according to the 

terms of the mortgage.

0 

2017-PH-1002 3/24/2017 001-H Develop and implement controls to ensure that the project 

complies with applicable HUD requirements. 0 

2017-PH-1002 3/24/2017 001-J

Provide training and technical assistance to the owner and its 

management agent to ensure compliance with the terms of its 

mortgage and other applicable HUD requirements.

0 

2017-FW-1004 4/6/2017 001-B

We recommend that the Director of HUD’s New Orleans Office 

of Community Planning and Development require the Parish to 

support the cost reasonableness or repay its program from nonFederal funds $362,319 paid to its consultant contractor without 

an independent cost estimate.

0 

340 █

███ 340 340 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-AT-1006 6/9/2017 002-D

Develop and implement adequate procedures and controls to 

ensure that the reporting of allocated capital funds in HUD’s 

system is accurate.

0 

2017-AT-1006 6/9/2017 002-E

Provide adequate training to staff responsible for making entries 

into HUD’s system to ensure accurate reporting on allocated 

funds. The training should include but not be limited to 

ensuring that its staff understands all of HUD’s reporting 

requirements for obligations and authorizations.

0 

2017-KC-0005 6/12/2017 001-A

Create and implement policies and procedures or change 

program regulations to prevent multifamily housing properties 

from charging more for Section 8 units than for comparable nonSection 8 units. For the 25 properties reviewed, this measure 

would prevent as much as $3,144,894 of Section 8 funds from 

subsidizing non-Section 8 units in the next year.

0 

2017-FW-1008 6/28/2017 001-A

We recommend that the Director of the San Antonio Office of 

Public Housing require the Authority to repay from non-Federal 

funds $11,172 paid for ineligible travel costs of which $6,904 

was Housing Choice Voucher and $4,268 was operating subsidy 

funds.

0 

2017-FW-1008 6/28/2017 001-B

We recommend that the Director of the San Antonio Office of 

Public Housing require the Authority to repay from non-Federal 

funds $2,946 paid for excessive lodging rates, extra trip days, 

and car rental costs of which $1,214 was Housing Choice 

Voucher and $1,732 was operating subsidy funds.

0 

2017-FW-1008 6/28/2017 001-C

We recommend that the Director of the San Antonio Office of 

Public Housing require the Authority to Support or repay its 

HUD programs from non-Federal funds $9,020 for unsupported 

meals, incidental expenses, lodging costs, and travel for training 

of which $2,978 was Housing Choice Voucher and $6,041 was 

operating subsidy funds.

0 

2017-CH-1003 7/14/2017 001-D

Implement adequate quality control procedures to ensure that it 

correctly calculates housing assistance payments to ensure that 

$32,960 in program funds is appropriately used for future 

payments.

0 

2017-CH-1003 7/14/2017 002-A

Reimburse its program $25,231 ($15,061 in inappropriate 

graduation payments + $10,170 in inappropriate interim 

disbursements) from non-Federal funds for the incorrect escrow 

account disbursements.

0 

2017-CH-1003 7/14/2017 001-B

Reimburse the appropriate households $2,213 from program 

administrative fee reserves for the underpayment of housing 

assistance due to inappropriate calculations.

0 

341 █

███ 341 341 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT

ESTIMATED 

COST 

SAVINGS 

2017-CH-1003 7/14/2017 002-B Support or reimburse its program $296 from non-Federal funds 

for the unsupported escrow account disbursements. 0 

2017-BO-1007 9/21/2017 001-C

Determine the appropriateness of the remaining balance of 

$1,242,154 on unsupported contracts to ensure costs were 

reasonable, reprocure the subject contracts, or reallocate the 

funds to the appropriate program.

0 

2017-BO-1007 9/21/2017 001-B

Repay the appropriate programs from non-Federal funds the 

$1,524,604 in ineligible funds paid when costs exceeded 

contract terms.

0 

2017-BO-1007 9/21/2017 001-D Strengthen controls to ensure that services are provided in 

accordance with contract scopes of work. 0 

2017-BO-1007 9/21/2017 001-A

Support that $2,533,377 in costs were reasonable and allowable 

program expenses in accordance with requirements or repay 

from non-Federal funds the appropriate programs any amounts 

they cannot support.

0 

2017-CH-1009 9/30/2017 001-K

Work with the project’s owner and Greystone for the owner to 

develop an action plan to bring the owner current on the 

project’s mortgage, reserve for replacements, and taxes and 

insurance to prevent a claim to HUD on the mortgage.

0 

342 █

███ 342 342 ██
SEMIANNUAL REPORT TO CONGRESS

OFFICE OF EVALUATION

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT BALANCE DUE

2013-OE-0001 11/15/2013 5 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2013-OE-0001 11/15/2013 9 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2013-OE-0001 11/15/2013 11

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2013-OE-0001 11/15/2013 21

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2013-OE-0001 11/15/2013 32

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2013-OE-0001 11/15/2013 36

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2013-OE-0001 11/15/2013 39

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2013-OE-0001 11/15/2013 40

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2013-OE-0001 11/15/2013 42

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2013-OE-0001 11/15/2013 44

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2013-OE-0001 11/15/2013 46

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

343 █

███ 343 343 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT BALANCE DUE

2013-OE-0001 11/15/2013 50

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2013-OE-0001 11/15/2013 51

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2013-OE-0001 11/15/2013 53

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2013-OE-0001 11/15/2013 55

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A 

2013-OE-0001 11/15/2013 56

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2014-ITED-0001 4/30/2014 2 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2014-ITED-0001 4/30/2014 4 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2014-ITED-0001 4/30/2014 7 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2014-ITED-0001 4/30/2014 8 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2014-ITED-0001 4/30/2014 10

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2014-ITED-0001 4/30/2014 11

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

344 █

███ 344 344 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT BALANCE DUE

2014-ITED-0001 4/30/2014 16

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2014-ITED-0001 4/30/2014 17

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2014-ITED-0001 4/30/2014 18

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2014-ITED-0001 4/30/2014 19

The OIG has determined that the contents of this 

recommendations would not be appropriate for public disclosure 

and has therefore limited its distribution to selected officials.

N/A

2014-ITED-0001 4/30/2014 21

The OIG has determined that the contents of this 

recommendations would not be appropriate for public disclosure 

and has therefore limited its distribution to selected officials.

N/A

2014-ITED-0001 4/30/2014 32

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2014-ITED-0001 4/30/2014 33

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2014-ITED-0001 4/30/2014 34

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2014-OE-0002 2/12/2016 1 

To strengthen HUD-wide enforcement that supports HUD’s 

broader risk management efforts, we recommend that the Deputy 

Secretary implement an enterprise-wide approach to enforcement 

using risk management concepts similar to those shown in the 

multifamily enforcement model.

$0

345 █

███ 345 345 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT BALANCE DUE

2014-OE-0002 2/12/2016 2 

To strengthen HUD-wide enforcement that supports HUD’s 

broader risk management efforts, we recommend that the Deputy 

Secretary strengthen DEC’s authority to enforce program 

requirements. Program offices should be directed to incorporate 

risk management procedures, to include risk-based, data-driven 

referrals to DEC, and implement a process that allows DEC to 

recommend enforcement actions independently. The Deputy 

Secretary or designee should be the final arbiter when 

disagreements arise.

$0

2014-OE-0002 2/12/2016 3 

To strengthen HUD-wide enforcement that supports HUD’s 

broader risk management efforts, we recommend that the Deputy 

Secretary provide DEC with the authority and resources necessary 

to implement a HUD-wide enforcement program.

0 

2014-OE-0002 2/12/2016 4 

To strengthen HUD-wide enforcement that supports HUD’s 

broader risk management efforts, we recommend that the Deputy 

Secretary Direct program offices and REAC to collaborate with 

DEC to research the types of data that would provide clear 

indications of financial and physical performance failures 

appropriate for use in data-driven referrals to DEC from each 

program office.

0 

2014-OE-0002 2/12/2016 5 

To address operational challenges that impede DEC’s capacity to 

support HUD programs, we recommend that the General Counsel 

provide resources and support to DEC to strengthen enforcement 

across HUD programs.

0 

2014-OE-0002 2/12/2016 6 

To address operational challenges that impede DEC’s capacity to 

support HUD programs, we recommend that the General Counsel 

develop a strategy for addressing additional enforcement 

workload.

0 

2014-OE-0002 2/12/2016 7 

We recommend that the Deputy Assistant Secretary evaluate the 

impact of Multifamily’s reorganization on enforcement, including 

(1) monitoring the impact of changes to the risk assessment

process, (2) making changes to MOUs, (3) documenting

procedural changes and how those changes affect DEC and REAC

collaboration, (4) improving data tracking and data sharing with

DEC and REAC on improvement and enforcement actions taken

and associated results, and (5) ensuring that Multifamily has the

capacity to maintain the improvements it has achieved in recent

years.

0 

346 █

███ 346 346 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT BALANCE DUE

2014-OE-0002 2/12/2016 8 

To support potential expanded data gathering for program offices, 

we recommend that the Principal Deputy Assistant Secretary 

direct REAC to work with DEC and program offices to identify 

and develop strategies for collecting data needed to support its 

National Risk Assessment Tool and ERM to include major 

program participant risks.

$0

2014-OE-0003 11/15/2014 4 

The OIG has determined that the contents of this 

recommendations would not be appropriate for public disclosure 

and has therefore limited its distribution to selected officials.

N/A

2014-OE-0003 11/15/2014 8 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2014-OE-0003 11/15/2014 13

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2014-OE-0003 11/15/2014 14

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2014-OE-0003 11/15/2014 16

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2014-OE-0003 11/15/2014 17

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2014-OE-0003 11/15/2014 18

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2014-OE-0003 11/15/2014 19

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2014-OE-0003 11/15/2014 20

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2014-OE-0003 11/15/2014 21

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

347 █

███ 347 347 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT BALANCE DUE

2014-OE-0003 11/15/2014 22

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2015-OE-0001 11/15/2015 1 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2015-OE-0001 11/15/2015 3 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore

limited its distribution to selected officials.

N/A

2015-OE-0001 11/15/2015 4 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2015-OE-0001 11/15/2015 5 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2015-OE-0001 11/15/2015 6 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2015-OE-0001 11/15/2015 7 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2015-OE-0001 11/15/2015 12

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2015-OE-0001 11/15/2015 13

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2015-OE-0001 11/15/2015 14

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2015-OE-0001 11/15/2015 15

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

348 █

███ 348 348 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT BALANCE DUE

2015-OE-0001 11/15/2015 16

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2015-OE-0001 11/15/2015 17

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2015-OE-0001 11/15/2015 18

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2015-OE-0001 11/15/2015 19

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2015-OE-0001 11/15/2015 20

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2015-OE-0002 9/29/2015 1 Develop a coordinated mission-critical system development life 

cycle replacement program for mission-critical systems. 

N/A

2015-OE-0002 9/29/2015 3 

Finalize, apply, and strategically communicate all standard IT 

policy across OCIO and the program offices to ensure that there is 

a common understanding of the modernization, EA, and CPIC 

policies. 

N/A

2015-OE-0002 9/29/2015 4 Approve at appropriate levels, implement, and disseminate policy 

and processes as intended. 

N/A

2015-OE-0002 9/29/2015 5 Formalize and fully implement segment governance. N/A

2015-OE-0002 9/29/2015 7 Implement project health assessments to measure the 

effectiveness of IT project planning and execution. 

N/A

2015-OE-0002 9/29/2015 8 Validate the accuracy of IT investment lists by segment and the 

associated projects and ensure alignment with EA strategy. 

N/A

2015-OE-0002 9/29/2015 9 Define and assess measurements in a yearly EA value 

measurement report in accordance with OMB EA framework 

guidance. 

N/A

2015-OE-0002 9/29/2015 10 Fully develop, approve at appropriate levels, and disseminate 

current CPIC process policies and procedures. 

N/A

349 █

███ 349 349 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT BALANCE DUE

2015-OE-0002 9/29/2015 11

Ensure that the Executive Investment Board meets in accordance 

with IT governance policy (related to recommendation from 

GAO-15-56). 

N/A

2015-OE-0002 9/29/2015 13 Implement HUDPlus to automate, track, and analyze the IT 

investment submissions and requirements. 

N/A

2015-OE-0004 2/2/2016 3A Systematically determine which types, sizes, or categories of 

contracts may be most efficiently and effectively accomplished by 

OCPO and which should use a shared services approach.

N/A

2015-OE-0004 2/2/2016 3B Develop decision criteria, protocols, and assistance for program 

offices to implement either OCPO or shared services acquisitions 

that are the most efficient and economical.

N/A

2015-OE-0004 2/2/2016 3D Work closely with each program office to reach agreement on the 

staffing model and resources needed to implement the COR 

professionalization initiative.

N/A

2015-OE-0007S 11/20/2015 1 Require field offices to review PHA-provided flood insurance 

documents to verify that PHAs have flood insurance policies for 

those buildings in flood zones.

N/A

2015-OE-0007S 11/20/2015 3 Require the Crisfield, MD, PHA to procure full flood insurance 

coverage to protect itself and HUD’s investments from financial 

loss.

N/A

2015-OE-0008 3/30/2016 1B

The Personnel Security Division director should development a 

comprehensive policy and clear guidance for all HUD personnel 

with roles and responsibilities related to contractor employee 

security.

NA

2015-OE-0008 3/30/2016 4A

The Chief Human Capital Officer should take immediate steps to 

eliminate the suitability adjudication backlog and meet the Office 

of Personnel Management timeliness standards, including the 

following: 

- Devoting adequate and appropriately trained staff to perform

suitability adjudications and

- Prioritizing, obtaining, and implementing an automated case

management system.

N/A

350 █

███ 350 350 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT BALANCE DUE

2016-OE-0001 9/23/2016 1 

Develop internal written procedures for records management that: 

a. Identify materials OHF collects or generates, which meet the 

regulatory definition of a record;

b. Comply with Federal and departmental records management 

policies, to include appropriate records disposition schedules; and

c. Inform all personnel of their records management 

responsibilities.

N/A

2016-OE-0001 9/23/2016 2 Ensure that personnel preparing records for archiving are trained 

to perform this function and aware of all relevant records 

disposition schedules and policies.

N/A

2016-OE-0001 9/23/2016 3 

Offer records management training that incorporates

a. Federal and departmental records management policies, to 

include HUD’s safeguards against the removal or loss of records 

and the penalties provided by law for the unlawful removal or 

destruction of records, and

b. Employee records management responsibilities, to include 

identification and maintenance of Federal records in all formats 

and media.

N/A

2016-OE-0002 6/7/2017 1 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2016-OE-0002 6/7/2017 2 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2016-OE-0002 6/7/2017 3 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2016-OE-0002 6/7/2017 4 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2016-OE-0002 6/7/2017 5 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2016-OE-0002 6/7/2017 6 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

351 █

███ 351 351 ██
SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT BALANCE DUE

2016-OE-0002 6/7/2017 7 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2016-OE-0002 6/7/2017 8 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2016-OE-0002 6/7/2017 9 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2016-OE-0004S 3/29/2017 1 

Director for the Office of Field Management ensure that the 

CDBG-DR risk analysis worksheet includes risk factors that show 

the measurement of performance outputs to determine completed 

activities.

N/A

2016-OE-0004S 3/29/2017 2 

Director for the Office of Field Management update the risk 

analysis guidance for CDBG-DR grants to include the assessment 

of the likelihood of risk occurrence to help inform management 

which critical risks to address during monitoring.

N/A

2016-OE-0004S 3/29/2017 3 

Director for the DRSI Division ensure that monitoring strategies 

correlate to the high-risk areas identified during the risk analysis 

and are in compliance with the central risk factor categories 

identified in HUD’s Monitoring Desk Guide.

N/A

2016-OE-0006 11/25/2016 2 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2016-OE-0006 11/25/2016 3 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2016-OE-0006 11/25/2016 4 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2016-OE-0006 11/25/2016 5 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

352 █

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SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT BALANCE DUE

2016-OE-0006 11/25/2016 7 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2016-OE-0006 11/25/2016 9 

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2016-OE-0006 11/25/2016 11

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2016-OE-0006 11/25/2016 12

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2016-OE-0006 11/25/2016 13

The OIG has determined that the contents of this recommendation 

would not be appropriate for public disclosure and has therefore 

limited its distribution to selected officials.

N/A

2016-OE-0010 4/19/2017 1 The Director of OFPM should complete all steps necessary for an 

effective evaluation effort. N/A

2016-OE-0010 4/19/2017 2 

The Director of OFPM should: 

• Work with grant program offices to overcome reporting 

challenges.

• Ensure that grant program offices report OMB-requested data.

• Learn from and leverage results of participating grant programs.

N/A

2016-OE-0010 4/19/2017 3 

The Director of OFPM should: 

• Work with the PD&R on an evaluation approach and design for 

the Promise Zone initiative.

• Ensure that OFPM has the appropriate resources for its new 

Communications and Data Analysis Division. 

N/A

2016-OE-0011S 5/3/2017 1 

Provide clearer guidance and instruction to PL 113-2 disaster 

grantees to assist them in establishing an effective internal audit 

activity.

N/A

2016-OE-0011S 5/3/2017 2 

Establish a recurring training and discussion forum among the PL 

113-2 grantees and CPD that enables grantees to share ideas and 

receive guidance and information about CPD’s expectations 

regarding the internal audit requirement.

N/A

353 █

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SEMIANNUAL REPORT TO CONGRESS

REPORT 

NUMBER 

REPORT 

DATE REC # RECOMMENDATION TEXT BALANCE DUE

2017-OE-0011 9/15/2017 1 

We recommend that ORCF identify and implement a method to 

ensure that eligible RCFs in its portfolio receive database 

adjustments when appropriate under local code, either by working 

directly with REAC or by instructing RCFs to apply for 

adjustments themselves.

N/A

2017-OE-0011 9/15/2017 2 

We recommend that REAC identify and implement a method to 

ensure that HUD does not instruct facilities to negate safety 

features.

N/A

2017-OE-0011 9/15/2017 3 

We recommend that ORCF identify and implement a method that 

ensures the expeditious followup inspection of RCFs that have not 

been inspected timely after receiving their last below-60 REAC 

score.

N/A

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OIG TELEPHONE DIRECTORY

OFFICE OF AUDIT

HEADQUARTERS OFFICE Washington, DC 202-402-0364

OFFICE OF AUDIT

REGION 1 Boston, MA 617-994-8380

 Hartford, CT 860-240-4837

REGION 2 New York, NY 212-264-4174

 Buffalo, NY 716-551-5755

 Newark, NJ 973-776-7339

REGION 3 Philadelphia, PA 215-656-0500

 Baltimore, MD 410-962-2520

 Pittsburgh, PA 412-644-6372

 Richmond, VA 804-771-2100

REGION 4 Atlanta, GA 404-331-3369

 Greensboro, NC 336-547-4001

 Miami, FL 305-536-5387

 San Juan, PR 787-766-5540

REGION 5 Chicago, IL 312-353-7832

 Columbus, OH 614-280-6138

 Detroit, MI 313-226-6280

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REGION 6 Fort Worth, TX 817-978-9309

Baton Rouge, LA 225-448-3976

Houston, TX 713-718-3199

New Orleans, LA 504-671-3715

Albuquerque, NM 505-346-7270

Oklahoma City, OK 405-609-8606

San Antonio, TX 210-475-6800

REGION 7-8-10 Kansas City, KS 913-551-5870

St. Louis, MO 314-539-6339

Denver, CO 303-672-5452

Seattle, WA 206-220-5360

REGION 9 Los Angeles, CA 213-894-8016

Las Vegas, NV 702-366-2100

Phoenix, AZ 602-379-7250

San Francisco, CA 415-489-6400

OFFICE OF INVESTIGATION

HEADQUARTERS Washington, DC 202-708-5998

OFFICE OF INVESTIGATION

REGION 1-2 New York, NY 212-264-8062

Boston, MA 617-994-8450

Hartford, CT 860-240-4800

Manchester, NH 603-666-7988

Newark, NJ 973-776-7355

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REGION 3 Philadelphia, PA 215-430-6758

 Baltimore, MD 410-209-6533

 Pittsburgh, PA 412-644-6598

 Richmond, VA 804-822-4890

REGION 4 Atlanta, GA 404-331-5001

 Birmingham, AL 205-745-4314

 Columbia, SC 803-451-4318

 Greensboro, NC 336-547-4000

 Memphis, TN 901-554-3148

 Miami, FL 305-536-3087

 San Juan, PR 787-766-5868

 Tampa, FL 813-228-2026

 Jackson, MS 601-329-6924

REGION 5 Chicago, IL 312-353-4196

 Cleveland, OH 216-357-7800

 Columbus, OH 614-469-6677

 Detroit, MI 313-226-6280

 Grand Rapids, MI 313-226-6280

 Indianapolis, IN 317-957-7377

 Minneapolis-St. Paul, MN 612-370-3130

357 █

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REGION 6 Fort Worth, TX 817-978-5440

Baton Rouge, LA 225-448-3941

Houston, TX 713-718-3227

Little Rock, AR 501-324-5931

New Orleans, LA 504-671-3700

Oklahoma City, OK 405-609-8601

San Antonio, TX 210-475-6822

REGION 7-8-10 Denver, CO 303-672-5350

Billings, MT 406-247-4080

Kansas City, KS 913-551-5566

Salt Lake City, UT 801-524-6090

St. Louis, MO 314-539-6559

Seattle, WA 206-220-5380

REGION 9 Los Angeles, CA 213-894-0219

Las Vegas, NV 702-366-2144

Phoenix, AZ 602-379-7252

Sacramento, CA 916-930-5691

San Francisco, CA 415-489-6683

JOINT CIVIL FRAUD DIVISION

Audit Kansas City, KS 913-551-5566

Investigation Kansas City, KS 913-551-5566

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ACRONYMS AND ABBREVIATIONS LIST

ACD......................................................................Accelerated Claims Disposition program

ADA......................................................................Americans with Disabilities Act

AFR....................................................................... agency financial report

ASC......................................................................Accounting Standards Codification

CAIVRS ................................................................Credit Alert Verification Reporting System

CDBG...................................................................Community Development Block Grant

CDBG-DR ............................................................Community Development Block Grant Disaster Recovery

CFR ......................................................................Code of Federal Regulations

CIGIE ...................................................................Counsel of the Inspectors General on Integrity and Efficiency

CPD......................................................................Office of Community Planning and Development

CMP .....................................................................civil monetary penalty

CNA......................................................................Capital Needs Assessment

CWCOT ...............................................................Claims Without Conveyance of Title program

DATA Act .............................................................Digital Accountability and Transparency Act of 2014

DOJ......................................................................U.S. Department of Justice

FEMA.................................................................... Federal Emergency Management Agency

FFMIA................................................................... Federal Financial Management Improvement Act of 1996

FHA ...................................................................... Federal Housing Administration

FHFA .................................................................... Federal Housing Finance Agency

FIFO .....................................................................first-in, first-out

FISMA .................................................................. Federal Information Security Modernization Act

FMR......................................................................fair market rent

FOIA..................................................................... Freedom of Information Act

FSSP..................................................................... Federal shared service provider

GAAP....................................................................generally accepted accounting principles

GAO .....................................................................U.S. Government Accountability Office

Ginnie Mae..........................................................Government National Mortgage Association

HECM...................................................................home equity conversion mortgage

359 █

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ACRONYMS AND ABBREVIATIONS LIST (CONTINUED)

HUD .....................................................................U.S. Department of Housing and Urban Development

ICP .......................................................................Integrity and Compliance Program

IDIS ......................................................................Integrated Disbursement and Information System

IG .........................................................................Inspector General

IGEA.....................................................................Inspector General Empowerment Act

IHBG ....................................................................Indian Housing Block Grant

IPERA...................................................................Improper Payments Elimination and Recovery Act of 2010

IRS CI...................................................................Internal Revenue Service Criminal Investigation

IT.......................................................................... information technology

MHI......................................................................mortgage held for investment

MSS......................................................................master subservicer

NAHASDA............................................................Native American Housing Assistance and Self Determination Act

NCIS.....................................................................New Core Interface Solution

OCFO...................................................................Office of the Chief Financial Officer

OCIO....................................................................Office of the Chief Information Officer

OCMA ..................................................................Office of the Commissioner for Municipal Affairs

OE ........................................................................Office of Evaluation

OFPM...................................................................Office of Field Policy and Management

OI .........................................................................Office of Investigation

OIG.......................................................................Office of Inspector General

OMB.....................................................................Office of Management and Budget

ORCF ...................................................................Office of Residential Care Facilities

OSPM...................................................................Office of Strategic Planning and Management

PHA......................................................................public housing agency

PHHHL.................................................................PHH Home Loans, LLC

PHHMC................................................................PHH Mortgage Corporation

PIH .......................................................................Office of Public and Indian Housing

RAD......................................................................Rental Assistance Demonstration program

360 █

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RCF ......................................................................residential care facility

REAC....................................................................Real Estate Assessment Center

SAR.......................................................................Semiannual Report to Congress

SIGTARP..............................................................Special Inspector General for the Troubled Asset Relief Program

URLA....................................................................Uniform Residential Loan Application

USAO ...................................................................U.S. Attorney’s Office

USSGL..................................................................United States Standard General Ledger

ACRONYMS AND ABBREVIATIONS LIST (CONTINUED)

361 █

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REPORTING REQUIREMENTS

The specific reporting requirements as prescribed by the Inspector General Act of 1978, as amended by the 

Inspector General Act of 1988, are listed below:

SOURCE-REQUIREMENT PAGES

Section 4(a)(2)-review of existing and proposed legislation and regulations. 34

Section 5(a)(1)-description of significant problems, abuses, and deficiencies relating to the 

administration of programs and operations of the Department.

1-36,

59-60

Section 5(a)(2)-description of recommendations for corrective action with respect to significant 

problems, abuses, and deficiencies.

41-58

Section 5(a)(3)24-identification of each significant recommendation described in previous 

Semiannual Report on which corrective action has not been completed.

Appendix 3, 

Table B, 73

Section 5(a)(4)-summary of matters referred to prosecutive authorities and the prosecutions and 

convictions that have resulted.

1-36

Section 5(a)(5)-summary of reports made on instances where information or assistance was 

unreasonably refused or not provided, as required by Section 6(b)(2) of the Act.

No Instances

Section 5(a)(6)-listing of each audit report completed during the reporting period, and for each 

report, where applicable, the total dollar value of questioned and unsupported costs and the dollar 

value of recommendations that funds be put to better use.

Appendix 2, 

62

Section 5(a)(7)-summary of each particularly significant report. 1-36

Section 5(a)(8)-statistical tables showing the total number of audit reports and the total dollar value 

of questioned and unsupported costs.

Appendix 3, 

Table C, 92

Section 5(a)(9)-statistical tables showing the total number of audit reports and the dollar value of 

recommendations that funds be put to better use by management.

Appendix 3, 

Table D, 93

Section 5(a)(10)-summary of each audit report issued before the commencement of the reporting period 

for which no management decision had been made by the end of the period.

Appendix 3, 

Table A, 71

Section 5(a)(10) - summary of each audit report, inspection, reports, and evaluation reports for 

which there are any outstanding unimplemented recommendations, including the aggregate 

potential cost savings of those recommendations.

Appendix 5, 

97

Section 5(a)(11)-a description and explanation of the reasons for any significant revised management 

decisions made during the reporting period.

51

Section 5(a)(12)-information concerning any significant management decision with which the 

Inspector General is in disagreement.

53

Section 5(a)(13)-the information described under section 05(b) of the Federal Financial Management 

Improvement Act of 1996.

57

Unsupported costs are a subset of questioned costs that the IG Act requires be identified separately from the cumulative questioned costs identified. 22

362 █

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FRAUD ALERT

Every day, loan modification and foreclosure rescue scams rob vulnerable homeowners of their money and their 

homes. The U.S. Department of Housing and Urban Development (HUD), Office of Inspector General, is the 

Department’s law enforcement arm and is responsible for investigating complaints and allegations of mortgage 

fraud. Following are some of the more common scams:

COMMON LOAN MODIFICATION SCAMS

Phony counseling scams: The scam artist says that he or she can negotiate a deal with the lender to modify 

the mortgage — for an upfront fee. 

Phony foreclosure rescue scams: Some scammers advise homeowners to make their mortgage payments 

directly to the scammer while he or she negotiates with the lender. Once the homeowner has made a few 

mortgage payments, the scammer disappears with the homeowner’s money.

Fake “government” modification programs: Some scammers claim to be affiliated with or approved by the 

government. The scammer’s company name and Web site may appear to be a real government agency, but 

the Web site address will end with .com or .net instead of .gov. 

Forensic loan audit: Because advance fees for loan counseling services are prohibited, scammers may sell 

their services as “forensic mortgage audits.” The scammer will say that the audit report can be used to avoid 

foreclosure, force a mortgage modification, or even cancel a loan. The fraudster typically will request an 

upfront fee for this service.

Mass joinder lawsuit: The scam artist, usually a lawyer, law firm, or marketing partner, will promise that he 

or she can force lenders to modify loans. The scammers will try to “sell” participation in a lawsuit against the 

mortgage lender, claiming that the homeowner cannot participate in the lawsuit until he or she pays some 

type of upfront fee. 

Rent-to-own or leaseback scheme: The homeowner surrenders the title or deed as part of a deal that will let 

the homeowner stay in the home as a renter and then buy it back in a few years. However, the scammer has 

no intention of selling the home back to the homeowner and, instead, takes the monthly “rent” payments and 

allows the home to go into foreclosure.

Remember, only work with a HUD-approved housing counselor to understand your options for assistance. 

HUD-approved housing counseling agencies are available to provide information and assistance. Call 

888-995-HOPE to speak with an expert about your situation. HUD-approved counseling is free of charge.

If you suspect fraud, call the U.S. Department of Housing and Urban Development, Office of Inspector General. 
Diversity and Equal Opportunity

The promotion of high standards and equal employment opportunity for

employees and job applicants at all levels. HUD OIG reaffirms its commitment

to nondiscrimination in the workplace and the recruitment of qualified employees

without prejudice regarding their gender, race, religion, color, national origin,

sexual orientation, disability, or other classification protected by law. HUD OIG

is committed and proactive in the prevention of discrimination and ensuring

freedom from retaliation for participating in the equal employment opportunity

process in accordance with departmental policies and procedures.

364 █
Faxing the OIG hotline: 202-708-4829

Emailing the OIG hotline: hotline@hudoig.gov

Sending written information to

Department of Housing and Urban Development

Inspector General Hotline (GFI)

451 7th Street SW

Washington, DC 20410

Internet

http://www.hudoig.gov/hotline/index.php

ALL INFORMATION IS CONFIDENTIAL, AND 

YOU MAY REMAIN ANONYMOUS.

Report fraud, waste, and mismanagement

in HUD programs and operations by

█
U.S. DEPARTMENT 

OF HOUSING 

AND URBAN 

DEVELOPMENT

Report Number 78

www.hudoig.gov

█