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 reimburse $3,536,974 to the County’ HOME program line of credit for assistance spent on the four activities that were partially terminated or noncompliant with program requirements.

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 provide disbursement documentation to support the eligibility of the $435,094 made for the two activities or repay the County’s HOME program line of credit from non-Federal source.

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 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.