We conducted a capacity review of the operations of the City of Brockton’s (City) grantee, Building a Better Brockton, Inc. (recipient), which has responsibility for administering the City’s NSP. Our objective was to determine whether the City and/or its recipient had the capacity to effectively and efficiently administer its NSP under the provisions of the Housing and Economic Recovery Act of 2008 (HERA) and the American Recovery and Reinvestment Act of 2009 (Recovery Act).

Our review determined that the recipient did not have the capacity to effectively and efficiently administer its NSP. Specifically, the recipient lacked adequate internal controls over the areas of financial reporting and procurement and adequate staffing to administer the program effectively. In addition, we found potential conflict-of-interest issues among the recipient, its board members, and several of the subrecipients that would receive NSP funding. We are concerned about the recipient’s ability to administer potential NSP-2 funding until such time as it can satisfactorily address and demonstrate adequate controls over the areas of financial reporting, procurement, and staffing and the conflicts of interest.