Reimburse the CDBG program from non-Federal funds the $106 paid for ineligible bank penalties.

Establish and implement adequate controls and procedures to permit proper accountability for all CDBG funds to ensure that they are used solely for authorized purposes and properly safeguarded.

Submit supporting documentation showing how $469,974 in CDBG funds disbursed for street improvements was properly used and in accordance with HUD requirements or reimburse the CDBG program from non-Federal funds.

Determine the amount spent for the resurfacing of the 16 private properties identified and reimburse the CDBG program from non-Federal funds.

Establish and implement adequate policies and procedures, including project inspection protocols, to ensure that CDBG funds are used for activities that meet a national objective, are used for eligible purposes, and are properly supported.

Repay from non-Federal funds the $665,920 in ineligible costs charged to the program

Support that 14 projects, with $494,517 in construction costs, met the environmental review requirements and repay from non-Federal funds any amounts attributed to projects that cannot be certified.

Provide additional guidance to their grantees and strengthen controls to ensure that tier two environmental reviews are performed and properly conducted and signed by the responsible entity before committing program funds.

Support $401,870 for contracts that were awarded without an independent cost estimate or repay from non-Federal funds any amount that cannot be supported.

Provide additional guidance to their grantees and strengthen controls over procurement to ensure that grantees follow applicable State and Federal procurement requirements, including obtaining independent cost estimates and ensuring full and open competition.

Define which expenses should be considered program delivery costs and strengthen controls over program costs to ensure that costs are properly charged.

Provide documentation to support housing assistance payments the projects received totaling $497,762 or reimburse HUD from nonproject funds for any amount that it cannot support.

Implement controls to ensure that it maintains adequate documentation in the tenant files to show that tenants were eligible for assistance and that the housing assistance payments were supported.

Provide support of eligibility or require lender repayment of $5,115,079 for the 822 identified claims with a reported partial claim or loan modification within the prior 24 months.

Further revise and implement Single Family Insurance System – Claims Subsystem controls to address deficiencies that allowed payment for a limited number of claims that were ineligible due to prior loan modification or FHA-HAMP option within 24 months.

Provide support of eligibility or require repayment of $333,178 for the 28 identified potential duplicate claims with reported matching partial claim note amounts and take appropriate action as necessary to ensure that related partial claim note amounts are correctly reflected within HUD’s Single Family Mortgage Asset Recovery Technology system for loan-servicing purposes.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to develop and implement a HUD-approved written plan and procedures and take actions that will correct and prevent the monitoring deficiencies in the finding, improve program administration effectiveness, and ensure compliance with HUD regulations and its own policies and procedures as required. This plan and written procedures should include controls to ensure that Northlake complies with HUD’s and its own requirements for monitoring recipients annually as well as documenting and maintaining the monitoring results. Implementing this recommendation should ensure that the $2,092,545 in HUD funds, allocated to Northlake’s four partners for program execution, is better used.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to support $81,013 or repay its program from non-Federal funds for disbursements made without adequate supporting documentation.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to develop and implement additional policies and controls and procedures, including but not limited to a disbursement file checklist, to ensure that adequate supporting documentation for disbursement is maintained in the files.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to support $47,679 or repay its program from non-Federal funds for payments made to contractors without written contracts and independent cost estimates.