We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct City officials to record the mortgages on the five CDBG-assisted properties that were demolished and acquired with CDBG assistance of $1,475,674, thus ensuring that these properties are administered in compliance with program requirements.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct City officials to provide documentation, such as proof of advertising, bids received, bid analysis reports, cost estimates, contracts, and other applicable records, to support compliance with Federal procurement regulations in the awarding of the five contracts.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct City officials to provide documentation to support compliance with Federal procurement regulations when contracts were awarded to the three single bidders.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct City officials to provide documentation to support the eligibility of the three tenants occupying low- to moderate-income housing units at a residential property assisted with CDBG funds.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct City officials to provide documentation to support that those laborers employed by the four contractors are compensated in accordance with Davis-Bacon wage rates. If documentation cannot be provided, the City’s line of credit should be reimbursed from non-Federal funds for disbursements made to the four contractors.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct City officials to provide documentation to support the income eligibility of the homeowner who received $30,600 in CDBG funds related to the rebate program. If documentation cannot be provided, the City’s CDBG program line of credit should be reimbursed $30,600 from non-Federal funds.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct City officials to reimburse $9,730 from non-Federal funds to the City’s CDBG program line of credit for the ineligible homeowner rehabilitation assistance provided that exceeded the subsidy limit.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct City officials to reimburse $83 from non-Federal funds to the City’s CDBG program line of credit for disbursements made for the two contracts exceeding 10 percent of the cost estimate.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct City officials to reimburse the City’s CDBG program line of credit for $100,982, which was used to pay costs that had been paid with CDBG program income, thus ensuring that these funds can be used for eligible activities.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct City officials to collect and test lead dust samples from the floors and window sills of the 27 homeowner units that received CDBG funds in program years 2012 and 2013 to ensure that the lead dust does not exceed the allowable lead dust standards. If the tests reveal the existence of excessive lead dust, City officials need to reduce the lead dust to the allowable limit, or reimburse the City’s CDBG line of credit from non-Federal funds for disbursements previously made to repair those 27 units.

We recommend that the Director of HUD’s Buffalo Office of Community Planning and Development instruct City officials to reimburse from non-Federal funds $153,279 spent on ineligible costs for duplicate and preaward costs of an economic development loan ($99,616), non-Federal City salary costs ($46,324), and duplicate subrecipient costs ($7,339).

We recommend that the Director of HUD’s Buffalo Office of Community Planning and Development instruct City officials to provide documentation to justify the $291,236 in unsupported costs related to disbursements made to the City’s public services subrecipient. Any costs determined to be inadequately supported 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 provide documentation in the loan file that HUD approved the withdrawal of funds after the required deadline, and provide an explanation and obtain approval for the untimely disbursement of the $6,724,820 after it had been drawn down. Any costs determined to be inadequately supported 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 strengthen controls to ensure compliance with Section 108 contract provisions and regulations requiring disbursement of funds in a timely manner after drawdown.

We recommend that the Director of HUD’s Buffalo Office of Community Planning and Development instruct City officials to reimburse the $1,500,000 in CDBG funds spent for the delinquent float loan that defaulted in 1998 through one of the options identified in HUD regulations so that it can be closed out as bad debt, thereby making the funds available for use on other eligible activities.

We recommend that the Director of HUD’s Buffalo Office of Community Planning and Development instruct City officials to implement procedures to ensure that any future CDBG float-funded activities are administered in accordance with HUD regulations requiring that the annual action plan identify the float-funded activity and a commitment to undertake one of the options listed in the regulations if the funds are unable to be repaid within the required timeframe.

We recommend that the Director of HUD’s Buffalo Office of Community Planning and Development instruct City officials to develop and implement procedures to ensure that the City’s liens related to HUD-funded loans are not released without repayment or evidence of due diligence to address delinquent, outstanding loans.

We recommend that the Director of HUD’s Buffalo Office of Community Planning and Development instruct City officials to provide documentation to support that the $1,166,000 public facilities and improvements procurement contract price was fair and reasonable and that the sole-source method used was justified. Any costs determined not to be fair and reasonable 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 implement procedures to ensure that all HUD-funded procurement is performed in accordance with regulations at 24 CFR 85.36, which require that sealed bid procurements be adequately advertised and involve at least two bids and that independent estimates be documented before bids or proposals are received.

We recommend that the Director of HUD’s Buffalo Office of Community Planning and Development instruct City officials to strengthen procedures over subrecipient monitoring to ensure that onsite visits are conducted for all CDBG subrecipients annually as specified in the agreements and that monitoring efforts are adequately tracked.