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.

Ensure that the Land Bank completes and clears all outstanding annual audits for fiscal years 2012 through 2016.

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.

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.

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.

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.

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.

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.

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.

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.

Repay the program $7,323 from non-Federal funds for ineligible code enforcement costs.

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.

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.

Support the reasonableness of the $110,000 Graffiti Removal program (activities 504 and 520) cost allocations or repay the program from non-Federal funds.

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.

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.

Implement additional policies and procedures to ensure that salaries and wages and cost allocations are charged in compliance with HUD requirements.

Implement additional procedures and controls to ensure that documentation is obtained to support that the limited clientele national objective was met.

Obtain training or technical assistance on CDBG program requirements.

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.