We recommend that Deputy Assistant Secretary for Grant Programs recapture $524,289 in grant funds, which the grantee had not reported spent by the grant round expenditure deadline, and return the funds to the U.S. Treasury as HUD can no longer reobligate the funds.

We recommend that Deputy Assistant Secretary for Grant Programs require four grantees to repay $334,441,871 for grant funds spent by the grantee after the grant round’s 24-month expenditure deadline had expired.

We recommend that Deputy Assistant Secretary for Grant Programs require five grantees to repay $24,409,255 for grant funds spent before the grantee had signed a grant round agreement obligating the funds.

We recommend that Deputy Assistant Secretary for Grant Programs require two grantees to repay $167,254,244 for grants funds spent in excess of the amount obligated for a round.

Provide technical assistance to the City to ensure that responsible staff receives necessary environmental, underwriting, and overall program administration training.

Develop and implement tools to improve record-keeping practices to support the eligibility, necessity, and reasonableness of the HOME activities.

Develop and implement adequate policies and procedures to ensure that fixed HOME units are identified and adequate documentation is maintained to support tenant eligibility and compliance with HOME rental limits for the entire affordability period.

Develop and implement adequate environmental policies and procedures to ensure that environmental reviews are properly documented and supported and that HUD and Federal environmental requirements have been followed before committing HOME funds to an activity.

Establish underwriting policies and procedures to ensure that HOME activities are consistent and meet Federal requirements.

Identify, review, and approve a CHDO to work with the City to ensure that $254,215 in CHDO funds will be properly committed to avoid being deobligated.