We recommend that the Director of HUD’s New York Office of Community Planning and Development instruct Palladia officials to provide documentation to justify that the $1,615,057 in unsupported costs is associated with eligible program activities. Any unsupported costs determined to be ineligible should be reimbursed from non-Federal funds.

We recommend that the Director of HUD’s New York Office of Community Planning and Development instruct Palladia officials to strengthen oversight controls over disbursements to ensure that adequate supporting documentation is maintained and complies with applicable regulations.

We recommend that the Director of HUD’s New York Office of Community Planning and Development instruct Palladia officials to follow its policies and procedures for record-keeping to maintain records that adequately identify the source and application of funds provided for financially assisted activities.

We recommend that the Director of HUD’s New York Office of Community Planning and Development instruct Palladia officials to provide records detailing the funding sources of the non-Federal cash match for the six grant activities reviewed.

We recommend that the Director of HUD’s New York Office of Community Planning and Development instruct Palladia officials to provide source documentation to substantiate that the $584,579 in required non-Federal cash matching funds for five of the six program projects reviewed were met.

We recommend that the Director of HUD’s New York Office of Community Planning and Development instruct Palladia officials to reconcile its accounting records to ensure that total revenues and expenditures in its general ledgers reconcile to the revenues and expenditures reported in its annual performance reports and LOCCS.

Update selection rules for CAIVRS to provide for complete reporting of all ineligible borrowers to put $9.5 million to better use.

Status

In 2020, HUD suspended reporting delinquencies and defaults to the Credit Alert Verification Reporting System (CAIVRS) because these debts are owed to the lender and are not delinquent federal debt.  A debt is not delinquent until payment is overdue to HUD for a deficiency judgment against the borrower in connection with an FHA claim.  Rather than add the missing borrowers to CAIVRS, the Office of Single Family Housing directed HUD’s National Servicing Center to cease including borrower creditworthiness information in CAIVRS and to solely use the system to report deficiency judgments until the delinquent debt is resolved.  HUD provided the Interface Control Document showing what data is sent to CAIVRS related to deficiency judgments.  As of July 2025, OIG is seeking clarification on HUD's implementation and closure of the recommendation because it is not clear whether all deficiency judgments are now being reported in CAIVRS until resolved.  HUD OIG disagrees with the closure of this recommendation until HUD provides evidence that the system updates have been implemented and that they provide complete reporting of all ineligible borrowers.
 

Analysis

To fully address this recommendation, HUD must provide evidence that all deficiency judgments are reported in CAIVRS until resolved.

Implementation of this recommendation should result in HUD putting $9.5 million to better use.

Revise HUD’s asset management fee policy to refederalize the Operating Fund program’s management and bookkeeping fees and the Capital Fund program’s management fees.

HUD should remove the provision that allows public housing authorities to charge asset management fees, which would ensure that at least $81.6 million in operating funds could be put to better use in meeting HUD program objectives.

Establish and implement procedures to reassess the management and bookkeeping fees periodically to ensure that they are reasonable. HUD should retain the documentation justifying the calculation of the rates.

Develop, document, and implement written procedures to ensure that fees charged to the asset management projects and Capital Fund program and expenses from the central office cost center are used to support HUD’s mission.

Discontinue using its low-rent public housing fund as a general fund to pay costs associated with its business activities until it has established appropriate controls.

We recommend that the Director of HUD’s Buffalo Office of Community Planning and Development instruct City officials to provide documentation to support the reasonableness and eligibility of the administrative program delivery costs charged to the CDBG program, including $597,048 in program delivery costs that could have been allocated to the State program, and repay the CDBG program from non-Federal funds any amounts determined to be unreasonable or ineligible.