Develop and implement controls over payments to include; ensuring that its management agreement clearly identifies services that are be provided by the management agent and paid for as part of the management fee, and the project is not charged for services that are part of the management fee.

Support that $1,432,222 in central office cost center expenses allocated to the public housing program projects were eligible, necessary, and reasonable costs of the program. Costs that cannot be supported, or were unnecessary, unreasonable, or for ineligible program costs should be reimbursed to the program from non-Federal funds.

Implement adequate procedures and controls, including but not limited to developing a plan to manage its central office cost center expenses and determining an appropriate fee structure with HUD’s approval that would allow it to operate its program within HUD’s requirements.

Implement adequate procedures and controls, including but not limited to providing training to its staff to ensure that the Commission fully implements asset management and operates its program in accordance with HUD’s requirements.

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.

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

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 its HOME program is reimbursed for assistance spent on terminated or noncompliant activities.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to provide environmental review documentation, such as environmental assessment and a phase I environmental review, for the activity to support compliance with environmental review requirements.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to provide procurement documentation, such as proof of advertising, bids received, bid analysis reports, contracts, and other documents, for contracts associated with the three activities to support compliance with procurement requirements.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to impose deed restrictions or other mechanisms approved by HUD on the two properties that received HOME assistance of $597,519 to enforce affordability requirements during the affordability period.

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 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.