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.

Execute contractual agreements with each CDBG recipient department to ensure compliance with all Federal guidelines.

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.

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.

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.

Update its quality control plan to include the performance of physical inspections of the properties in its inventory.

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.

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.

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.

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.

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.

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.

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.

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-of-interest requirements and includes elected and appointed positions.

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.

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…

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.

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.

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.

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.