We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to provide environmental review documentation, such as environmental assessment and a phase I environmental review, for the activity to support compliance with environmental review requirements.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to provide procurement documentation, such as proof of advertising, bids received, bid analysis reports, contracts, and other documents, for contracts associated with the three activities to support compliance with procurement requirements.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to impose deed restrictions or other mechanisms approved by HUD on the two properties that received HOME assistance of $597,519 to enforce affordability requirements during the affordability period.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to strengthen the County’s administrative controls to ensure compliance with environmental, procurement, and other program requirements.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to provide HOME program training to County staff to ensure compliance with HOME program requirements.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to reallocate the $573,689 awarded to the ineligible CHDO, thus ensure that the fund is put to better use.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to reconcile the County’s carryover balance of HOME match as of September 30, 2015, for the ineligible HOME match contributions and the understated HOME match contributions.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to disburse the $92,557 to pay eligible HOME costs before making additional drawdowns from LOCCS.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to strengthen the County’s financial controls over reconciling bank records to ensure that HOME funds in the local bank account are spent before drawdowns are made from LOCCS.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to provide documentation, such as pay stubs and leases, to support compliance with HOME program rent limit and income eligibility requirements for the six tenants who occupied HOME-assisted units.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to strengthen the County’s administrative controls to ensure that County staff adequately monitors its subgrantee for compliance with HOME program requirements and provide HOME program training to the County subgrantee’s staff.

Complete the implementation of the new accounting system and ensure it tracks program funds to a level that supports compliance with HUD requirements.

Determine the eligibility of the $537,773 disbursed for the Ciudad de Ensueño project and reevaluate the feasibility of the activity. (Footnote 9) Total disbursements of $538,973 were adjusted to consider $1,200 questioned in recommendation 1F. The Municipality must reimburse its HOME program from non-Federal funds if HUD determines the activity to have been terminated.