We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide documentation to justify $8,564 in excessive property management fees charged by the COCC or reimburse its Operating Fund from non-Federal funds for any amount it cannot support.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to reimburse its Operating Fund from non-Federal funds $82,907 for 16 document management services contract payments that should have been paid with COCC funds.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to strengthen its controls to ensure that operating funds are requested, received, and used in accordance with HUD, Federal, and Authority requirements.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide training to employees involved in the funding and expenditure processes to ensure compliance with HUD, Federal, and Authority requirements

Evaluate the apparent conflict-of-interest situations in this report and pursue administrative sanctions if warranted.

Update and revise the CPD Notice to further improve the code enforcement guidance.

Provide mandatory training on the revised Notice to the local field offices and to grantees that use CDBG funds for the code enforcement program to ensure compliance with requirements.

Ensure that the updated and revised notice is issued with the appropriate clearance.

Transfer $78,786 ($22,601 $56,185) from its Family Self-Sufficiency account to its Housing Choice Voucher Program account for the overfunded and forfeited escrows.

Support or reimburse its Housing Choice Voucher Program $120,067 from non-Federal funds for unsupported graduation disbursements.

Reimburse its Housing Choice Voucher Program $12,460 from non-Federal funds for the ineligible disbursements.

Transfer $3,801 from its Housing Choice Voucher Program account to its Family Self-Sufficiency account for the underfunded escrows.

Reimburse one participant, $547 from its Family Self-Sufficiency program for the underpaid graduation payment.

Implement procedures and controls to ensure that documentation required by HUD and the Authority’s own action plan is correctly completed, documented, and updated.

Ensure that its staff is appropriately trained and familiar with HUD’s requirements and its program action plan regarding the administration of its program to ensure that (1) participants’ individual training and services plans are complete and contain appropriate goals to assist the family in achieving self-sufficiency, (2) participants are notified of their escrow account balances at least annually, and (3) contracts of participation are complete and accurate.

Ensure that its newly created policies and procedures include a process for ensuring that (1) escrow balances are correctly calculated and disbursed, (2) escrow accounts and disbursements are fully supported, and (3) forfeited escrow account funds are returned to the Housing Choice Voucher Program as required.

Determine the amount of the $445,122 in coordinator grant funds that were appropriately earned by the Authority for meeting requirements and paid to the coordinators while performing duties of the Family Self-Sufficiency program. The funds that are determined to be unearned should be reimbursed to HUD from non-Federal funds.

Reimburse its program $20,450 from non-Federal funds ($10,331 $10,119 in associated administrative fees) for the overpayment of housing assistance due to inappropriate calculations of housing assistance.

Reimburse the appropriate households $3,590 from program funds for the underpayment of housing assistance due to inappropriate calculations.

Support or reimburse its program $18,638 from non-Federal funds for the unsupported payments of housing assistance cited in this finding.