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.

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.

Update selection rules for CAIVRS to provide for complete reporting of all ineligible borrowers to put $9.5 million to better use.

Status

In 2020, HUD suspended reporting delinquencies and defaults to the Credit Alert Verification Reporting System (CAIVRS) because these debts are owed to the lender and are not delinquent federal debt. A debt is not delinquent until payment is overdue to HUD for a deficiency judgment against the borrower in connection with an FHA claim. Rather than add the missing borrowers to CAIVRS, the Office of Single Family Housing directed HUD’s National Servicing Center to cease including borrower creditworthiness information in CAIVRS and to solely use the system to report deficiency judgments until the delinquent debt is resolved. HUD provided the Interface Control Document showing what data is sent to CAIVRS related to deficiency judgments.

As of July 2025, OIG is seeking clarification on HUD's implementation and closure of the recommendation because it is not clear whether all deficiency judgments are now being reported in CAIVRS until resolved. HUD OIG disagrees with the closure of this recommendation until HUD provides evidence that the system updates have been implemented and that they provide complete reporting of all ineligible borrowers.

Analysis

To fully address this recommendation, HUD must provide evidence that all deficiency judgments are reported in CAIVRS until resolved.

Implementation of this recommendation should result in HUD putting $9.5 million to better use.

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.

Provide all supporting documentation associated with the $10,838,880 (Footnote 13) Total disbursements of $10,876,095 were adjusted to consider $37,215 questioned in recommendation 1D. 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 (recommendation 1A). 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.

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.

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.

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.

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.

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.

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.

Provide adequate supporting documentation for the $1,628,130 in unsupported salary and benefit costs or repay the CDBG program from non-Federal funds.

Reimburse its HOME program $1,595,113 from non-Federal funds for HOME funds that were inappropriately used on Section 8 housing assistance payments.

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 non-Federal funds.

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.

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.

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.

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.

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.

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.