We recommend that the Chief Financial Officer determine whether the summary expenditures totaling $160,360,714, which exceeded the grant round obligations for the two grantees, were ADA violations. If the transactions were violations, action should be taken as required by the ADA.

We recommend that the Chief Financial Officer determine whether the revised and completed detail transactions totaling to $435,263,268, which occurred before and after grant rounds obligation and expenditure dates, were ADA violations. If the transactions were violations, actions should be taken as required by the ADA.

We recommend that the Chief Financial Officer determine whether the revised and completed transactions totaling $496,913,235 and made more than a year after the original voucher entry were GAAP violations. If the transactions were violations, appropriate actions should be taken, including but not limited to adjusting the transactions in LOCCS and HUD’s financial statements.

We recommend that the Chief Financial Officer enter a 24-month expiration term into LOCCS for Disaster Recovery funding provided by the 2017 Act and monitor to ensure that expenses are not entered before or after the grant period.

We recommend that the Chief Financial Officer require CPD to enter into a separate grant agreement for each grantee’s round of disaster funding for funding provided by the 2017 and 2018 Acts.

We recommend that the Chief Financial Officer require CPD to monitor the detailed voucher transactions in the DRGR system to ensure that grantees appropriately record transactions.

We recommend that the Chief Financial Officer require CPD to prohibit grantees from revising completed vouchers in the DRGR system and require adjustments to be entered as new vouchers into the DRGR system, which will ensure that LOCCS records and tracks revisions.

We recommend that the Fort Worth Office of Community Planning and Development Director require the City to repay its HOME program from non-Federal funds $1,322,280, which it misspent reconstructing homes.

We recommend that the Fort Worth Office of Community Planning and Development Director require the City to ensure that staff responsible for environmental reviews understands and complies with environmental requirements.

We recommend that the Fort Worth Office of Community Planning and Development Director require the City to hire a qualified entity to determine and correct deficiencies related to 13 reconstructed homes, including the structural integrity of the homes.

We recommend that the Fort Worth Office of Community Planning and Development Director require the City to provide a detailed plan for covering the cost of any potential warranty work needed on these 13 properties for the entire statutory warranty period.

We recommend that the Fort Worth Office of Community Planning and Development Director require the City to support or reduce its match contributions by $2,967,568 and review its HOME match contributions for the past 5 years for compliance with HOME regulations and report the results to the Fort Worth Office of Community Planning and Development.

We recommend that the Fort Worth Office of Community Planning and Development Director require the City to develop and adopt policies and procedures to address HOME match contribution requirements.

We recommend that the Fort Worth Office of Community Planning and Development Director require the City to ensure that the loan agreements are signed and valid legal instruments.

We recommend that the Fort Worth Office of Community Planning and Development Director require the City to develop policies and procedures, to include the review of all subcontractors in SAM.

We recommend that the Fort Worth Office of Community Planning and Development Director require the City to ensure that its staff understands and complies its policies and procedures including HOME income requirements.

We recommend that HUD’s Acting Director for the Office of Block Grant Assistance require the Texas General Land Office to review and update its internal controls throughout the grant cycle to ensure that the procurement and expenditure policies and procedures are implemented and working as designed, including the Federal prohibition of cost plus percentage of cost contracts.

We recommend that HUD’s Acting Director for the Office of Block Grant Assistance require the Texas General Land Office to fill vacancies, ensuring that staffing levels remain adequate to administer Hurricane Harvey disaster grant funds.

We recommend that HUD’s Acting Director for the Office of Block Grant Assistance require the Texas General Land Office to negotiate with SBA to extend its data-sharing agreements for the term of the expenditure requirements set forth in public laws or the Federal Register.

We recommend that HUD’s Acting Director for the Office of Block Grant Assistance require the Texas General Land Office to initiate negotiations with the Texas Department of Insurance to establish data-sharing agreements for the Hurricane Harvey disaster, any open disaster recovery grants, and future disasters.