The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide documentation to show that the $594,012 disbursed due to the use of multipliers was for eligible, reasonable, necessary, and supported costs or reimburse its program from non-Federal funds.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide documentation to show that the $2,689 disbursed due to a higher than required overtime rate was supported by documentation from the trade unions or reimburse its program from non-Federal funds.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to reimburse its program $1,198 from non-Federal funds for overpaid wages due to billing and payroll errors.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to pay $544 in unpaid wages to the subcontractors of the affected employees and submit evidence that these employees have been paid.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide training to its staff to help ensure compliance with applicable cost principle, procurement, and Davis-Bacon requirements.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide documentation showing that payments made under the Rockaway Boardwalk construction management services contract complied with Davis-Bacon and Related Acts requirements and that restitution is made to affected workers for any underpayments identified.

Implement a change to regulations at 24 CFR Part 203 to require curtailment of preforeclosure interest and other costs that are caused by lender servicing delays, resulting in $413,513,975 in funds to be put to better use. This should include updating or seeking statutory authority to update HUD’s regulations as necessary and coordinating with HUD’s Office of Finance and Budget, well before any changes go through departmental clearance, to ensure that planned curtailment requirements can be consistently enforced through the claims process.

Status

This audit recommendations cannot be closed out without the publication of the Federal Housing Administration (FHA): Maximum Claim Rule. The proposed changes have been on HUD’s regulatory agenda since Spring 2020 but, as of June 2024, the Office of Single Family Housing does not have an estimated publication date.

Analysis

To fully address this recommendation, HUD must publish the FHA Maximum Claim Rule.

Implementation of this rule should result in HUD putting $413 million to better use.

Provide documentation to support $671,838 in code enforcement costs or repay the program from non-Federal funds for any amount that it cannot support.

Provide documentation to support $1 million in community policing salary costs or repay the program from non-Federal funds for any amount that it cannot support.

We recommend that the Director of HUD’s Newark Office of Public Housing require the Authority to provide documentation to show that the $252,000 paid to the Long Branch Housing Authority was for eligible, reasonable, necessary, and allocable costs or reimburse its Operating and Capital Fund programs from non-Federal funds for any amount that it cannot support or that is not considered reasonable.

We recommend that the Director of HUD’s Newark Office of Public Housing require the Authority to provide documentation to show that the $161,600 paid for legal, fee accounting, and auditing services was for prices that were reasonable and that the costs were properly allocated among the Authority’s programs or reimburse its Operating and Capital Fund programs from non-Federal funds for any amount that it cannot support or is not considered reasonable

We recommend that the Director of HUD’s Newark Office of Public Housing require the Authority to provide documentation to show that $172,538 paid for goods and services was reasonable or reimburse its Operating and Capital Fund programs from non-Federal funds for any amount that it cannot support or that is not considered reasonable.

Coordinate with the Deputy Assistant Secretary for Finance and Budget to board 350 manually paid partial claims that were not boarded into SMART, resulting in funds to be put to better use in the amount of $2,297,706.

Obtain the missing mortgage documents for 33 loans and the missing note documents for 40 loans, totaling $644,767 in partial claim notes, and require any unrecorded mortgage documents to be recorded at the appropriate county’s office to ensure that HUD’s interests are protected. For any missing documents that cannot be obtained, the Deputy Assistant Secretary should require the lender to reimburse HUD for the partial claim note.

Coordinate with the Deputy Assistant Secretary for Finance and Budget to record lender payments to update the balances for 139 loans in SMART, resulting in funds to be put to better use in the amount of $1,055,113.

Pursue the collection of the $5,690,000 in surplus proceeds that HUD was entitled to receive from 2017 loan terminations.

Implement a policy to require servicers to send surplus proceeds notifications to the HUD Secretary-held assets servicing contractor and establish procedures to improve HUD’s surplus proceeds collection efforts.

Redesign the partial claim program to eliminate its weaknesses and ensure that partial claims benefit from a stronger lien position to put $6,770,000 to better use.