We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to provide documentation to support that laborers associated with the activity are compensated in compliance with Davis-Bacon wage rates. If documentation cannot be provided, $567,767 needs to be reimbursed to the County’s HOME line of credit from non-Federal sources.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to strengthen the County’s administrative controls to ensure compliance with environmental, procurement, and other program requirements.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to provide HOME program training to County staff to ensure compliance with HOME program requirements.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to reallocate the $573,689 awarded to the ineligible CHDO, thus ensure that the fund is put to better use.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to reimburse $242,269 to the County’s HOME program line of credit for CHDO reserve fund disbursed to the ineligible CHDO.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to provide documentation to support that at least one-third of the Homefirst board were representatives of a low-income community. If documentation cannot be provided, reimburse the $227,903 to the County’s HOME program line of credit from non-Federal sources.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to reimburse the $536,507 in program income to the County’s HOME program local bank account and record the income in IDIS.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to reconcile the County’s carryover balance of HOME match as of September 30, 2015, for the ineligible HOME match contributions and the understated HOME match contributions.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to disburse the $92,557 to pay eligible HOME costs before making additional drawdowns from LOCCS.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to strengthen the County’s financial controls over reconciling bank records to ensure that HOME funds in the local bank account are spent before drawdowns are made from LOCCS.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to provide documentation, such as pay stubs and leases, to support compliance with HOME program rent limit and income eligibility requirements for the six tenants who occupied HOME-assisted units.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to provide documents, such as pay stubs and bank statements, to support the eligibility of the two home buyers. If documentation cannot be provided, reimburse $260,736 from non-Federal sources to the County’s HOME program line of credit.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to strengthen the County’s administrative controls to ensure that County staff adequately monitors its subgrantee for compliance with HOME program requirements and provide HOME program training to the County subgrantee’s staff.

Acknowledge that $3,129,000 of the $5 million in the attached settlement agreement represents an amount due HUD.

Require public housing agencies to run the Enterprise Income Verification existing tenant search during the admission process and retain the results in the tenant file, which would avoid unnecessary costs to HUD’s subsidy programs, allowing an estimated $935,283 to be put to better use.

Require public housing agencies to report the program admission date to any multifamily property listed on the Enterprise Income Verification existing tenant search during the admission process.

Require public housing agencies to maintain support for any communication with a multifamily property listed on the Enterprise Income Verification existing tenant search.

Require HUD staff to review Enterprise Income Verification reports from the last 12-month period during onsite housing agency reviews to ensure that any multiple subsidies have been resolved.

Implement recommendations 1A through 1D to ensure that $2.24 million in housing assistance funds will be put to better use.

Obtain repayment of $322,314 from nonproject funds from the management agent for the ineligible bookkeeper and accounts payable clerk’s salary and benefits, incurred during 2014 and 2015.