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.

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.

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…

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.

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…

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.

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.

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.

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.

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.

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.

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.

HUD OCIO should implement procedures to ensure that information in cybersecurity risk registers is obtained accurately, consistently, and in a reproducible format and is used to a. quantify and aggregate security risks, b. normalize cybersecurity risk information across organizational units, and c. prioritize operational risk response (derived from metric 5).

HUD OCIO should ensure that system owners and information system security officers consistently test their ISCPs and upload the test results to CSAM in accordance with HUD’s defined ISCP testing policy (derived from metric 63).

HUD OCIO and the Office of Administration should implement procedures to ensure proper validation of media sanitization in accordance with HUD Media Protection Procedures 2.0 (February 2022) and form HUD 1067A, Certification of Sanitization (derived from metric 36).

Require MidFirst to update its policies and procedures to comply with HUD requirements by placing foreclosure holds for loss mitigation requests made before the first legal filing.

HUD OCIO and the HUD Chief Risk Officer should coordinate to implement procedures to monitor the effectiveness of cybersecurity risk responses to ensure that risk tolerances are maintained at an appropriate level (derived from metric 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.

Establish and implement an effective system to maintain a complete and accurate contract register to ensure proper contract planning and administration.

Provide technical assistance to the Authority to ensure that responsible staff and board members receive necessary procurement training.