Reallocate the $487,483 in unspent funds to ensure that they will be put to their intended use or, if the activities remain open, maintain support to show that the HOME funds disbursed were reasonable and Reallocate the $487,483 in unspent funds to ensure that they will be put to their intended use or, if the activities remain open, maintain support to show that the HOME funds disbursed were reasonable and supported in accordance with Federal requirements.

Support that the City properly administered the HOME program and earned $130,667 in HOME administrative fees or repay from non-Federal funds any amount that cannot be supported

Support that $3,136,798 in HOME funds disbursed was reasonable and supported in accordance with Federal requirements or repay from non-Federal funds any amount that cannot be supported.

Repay from non-Federal funds the $422,768 in ineligible funds related to the City’s failure to meet HOME CHDO commitment deadlines and complete activities in accordance with the HOME agreement and HOME regulations.

Develop and implement written policies and procedures for its administrative fee charges.

Submit an indirect cost rate schedule for its Continuum of Care grants to HUD for approval.

Provide support for the administrative fees or repay the Continuum of Care grants $663,070 from non-Federal funds. (See appendix D.)

Provide supporting documentation for the participant’s eligibility (tenant code t0019221) or repay its program $13,885 from non-Federal funds for the housing assistance payments and any subsequent payments made.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the State to provide documentation showing that the acquisition component of its program has ended or improve its controls over the program to ensure that properties purchased are eligible. This recommendation includes but is not limited to updating its policies and procedures and implementing verification processes to ensure that it verifies information provided by applicants and other entities.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the State to conduct a review of the universe of properties purchased through the acquisition component of its program to ensure that properties were eligible and reimburse from non-Federal funds the Disaster Recovery funds used in connection with any additional properties found to be ineligible.