We recommend that the Director of HUD’s Buffalo Office of Community Planning and Development instruct City officials to provide documentation to support the reasonableness and eligibility of the administrative program delivery costs charged to the CDBG program, including $597,048 in program delivery costs that could have been allocated to the State program, and repay the CDBG program from non-Federal funds any amounts determined to be unreasonable or ineligible.

Provide all supporting documentation associated with the $10,838,880 (Footnote 13) Total disbursements of $10,876,095 were adjusted to consider $37,215 questioned in recommendation 1D. in State CDBG, Section 108, and program income proceeds disbursed for the development of the sports complex, if HUD determines the plan to be feasible (recommendation 1A). HUD must determine the eligibility, reasonableness, and allocability of the funds disbursed. OCMA must reimburse its State CDBG program from non-Federal funds any amount determined ineligible.

We recommend that the Director of HUD’s Buffalo Office of Community Planning and Development instruct City officials to Provide documentation to justify the $177,923 unsupported difference between the City’s CDBG program income balance in IDIS and its bank account balances as of June 30, 2013. Any portion of the unsupported difference determined to be ineligible should be reimbursed from non-Federal funds.

We recommend that the Director of HUD’s Buffalo Office of Community Planning and Development instruct City officials to expend or reprogram to other eligible program activities the $2,451,645 in CDBG program income maintained in the City’s community development bank accounts as of June 30, 2013, so the City can assure HUD that these funds have been put to better use.

Provide adequate supporting documentation for the $1,628,130 in unsupported salary and benefit costs or repay the CDBG program from non-Federal funds.

Reimburse its HOME program $1,595,113 from non-Federal funds for HOME funds that were inappropriately used on Section 8 housing assistance payments.

We recommend that the Director of HUD’s New York Office of Community Planning and Development instruct County officials to develop controls that will ensure that the County’s decentralized record-keeping system is centralized for ready access to HOME documents.

We recommend that the Director of HUD’s New York Office of Community Planning and Development instruct County officials to develop controls to ensure that the County’s recently established debarment verification procedures are implemented for all future procurement activity.

We recommend that the Director of HUD’s New York Office of Community Planning and Development instruct County officials to document their application review committee membership and provide evidence of the committee meetings and their evaluation and rating of subrecipients to fully support their funding recommendations.

We recommend that the Director of HUD’s New York Office of Community Planning and Development instruct County officials to provide documentation to justify the $1,264 in unsupported project delivery costs. Any unsupported costs determined to be ineligible should be reimbursed from non-Federal funds.