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The U.S. Department of Housing and Urban Development (HUD) Office of Inspector General reviewed the City of St. Louis' use of HOME Investment Partnerships Program (HOME) funds. Our audit objective was to determine whether the City used HOME funds for reasonable and necessary development costs. We concluded that The City used HOME funds for costs that were not reasonable and necessary to produce housing for low-income families. Additionally, it did not establish adequate controls to ensure that it determined the proper amount of subsidy for HOME-funded development activities. We recommended that HUD require the City to design and implement a process to ensure that HOME-funded project costs are reasonable and necessary.