Support the eligibility of the $218,028 in antigraffiti costs or repay the program from non-Federal funds.

Support the eligibility of the $55,000 subrecipient drawdown or repay the program from non-Federal funds.

Develop and implement written code enforcement policies and procedures to meet CDBG requirements or amend the funding for another CDBG-eligible project. Improving code enforcement controls will result in $428,373 in funds to be put to better use.

Execute contractual agreements with each CDBG recipient department to ensure compliance with all Federal guidelines.

Develop and implement written policies and procedures for specific departments, update and implement CDBG-specific written policies and procedures, and provide formal training and technical assistance to the Development and Resource Management Department employees to ensure that they understand and follow CDBG requirements.

Develop and implement a monitoring program within the City’s Development and Resource Management Department to ensure that it periodically monitors and provides guidance to its subrecipient(s) and City departments on how to administer CDBG funds.

Develop and implement HUD-approved policies and procedures to ensure that the process for conducting an internal audit complies with HUD regulations and the policies and procedures are submitted and certified to HUD.

Immediately conduct an internal audit of the CDBG-DR grant funds.

Update, finalize, and implement its procurement policies to comply with 2 CFR 200.317-326.

Adequately support or reimburse its HOPWA program $31,157 from non-Federal funds for the inappropriate disbursements.

Reimburse its HOPWA program $14,017 from non-Federal funds for the inappropriate disbursements.

Provide adequate training to staff responsible for reviewing and approving the expenditures to ensure compliance with HUD’s and Louisville Metro’s requirements for the administration of the HOPWA program, including processing program disbursements and monitoring project sponsors’ cash management.

Implement adequate procedures for sufficiently monitoring its project sponsors’ cash management.

Provide adequate monitoring to the Land Bank to ensure that the subrecipient follows Federal regulations as required, including policies and procedures to help verify subrecipient compliance or address any deficiencies in need of correcting, such as annual audits, financial management systems, and file management.

Provide adequate support for expenses totaling $48,985. Any expenses that are not supported should be repaid to the appropriate NSP grant from non-Federal funds.

Ensure that the Land Bank completes and clears all outstanding annual audits for fiscal years 2012 through 2016.

Ensure that the Land Bank develops and implements adequate financial and file management policies and procedures to ensure that files are auditable and financial records adequately identify the source and application of federally sponsored activities in accordance with Federal regulations.

Reprogram the remaining NSP1 funds of $219,851 and NSP3 funds of $28,745 to another subrecipient or developer or return the funds to the U.S. Treasury.

We recommend that the General Deputy Assistant Secretary for Community Planning and Development develop and implement a quality review process at the headquarters level to ensure consistent compliance with its policy for risk analysis, to include but not be limited to reviewing supporting documentation for conclusions drawn.

We recommend that the General Deputy Assistant Secretary for Community Planning and Development, develop and implement a policy requiring field offices to rate grantees of at least medium risk that have not been monitored in their respective program area within the last 3 years on factors that require assessments of capacity, program complexity, and monitoring findings resulting in repayment or grant reductions.