The U.S. Department of Housing and Urban Development’s (HUD) Office of Inspector General audited the City of Flint’s (City) HOME Investment Partnerships Program (Program). The audit was part of the activities in our fiscal year 2010 annual audit plan. We selected the City based upon our analysis of risk factors relating to Program grantees in Region V’s jurisdiction and a citizen complaint to our office. Our objectives were to determine whether the City complied with Federal requirements in its use of Program funds for community housing development organizations’ (organization) home-buyer projects and subrecipients’ activities and accurately reported Program accomplishments in HUD’s Integrated Disbursement and Information System (System). This is the second of three planned audit reports on the City’s Program.

The City did not comply with Federal requirements in its use of Program funds for organizations’ home-buyer projects. It (1) did not ensure that organizations entered into lease-purchase agreements or entered into appropriate lease-purchase agreements with households, (2) failed to ensure that an organization transferred homes to home buyers within 42 months of project completion and did not convert the home-buyer projects to rental projects, (3) did not reimburse its HOME trust fund treasury account (treasury account) for terminated projects, (4) inappropriately used Program funds for home-buyer project costs that were administrative expenses, (5) did not prevent an organization from entering into a land contract with a home buyer, (6) inappropriately used Program organization reserve funds for an owner-occupied single-family rehabilitation project, (7) used Program funds for unreasonable acquisition costs, and (8) did not decommit and reprogram Program funds for a terminated project. As a result, the City drew down and disbursed nearly $1.7 million in Program funds for organizations’ home-buyer projects that did not meet Federal requirements and inappropriately drew down and disbursed more than $143,000 in additional Program funds.

The City also did not comply with Federal requirements in its use of Program funds for subrecipients’ activities. It (1) inappropriately used Program funds for costs that were not associated with an eligible project, were administrative expenses, and were unrelated to the City’s Program activities; (2) lacked sufficient documentation to support Program funds used for projects; and (3) did not reprogram Program funds for a terminated project. As a result, the City inappropriately drew down and disbursed nearly $427,000 in Program funds and lacked sufficient documentation to support nearly $65,000 in Program funds.

Further, the City did not accurately report Program accomplishments in HUD’s System. It (1) inappropriately entered activity data into HUD’s System for 61 properties under 2 or more activity numbers for a total of 130 activities, (2) overreported Program units created by 79 units, (3) did not accurately report completion dates for 35 home-buyer activities, and (4) inappropriately reported the type of activity in HUD’s System for 2 activities.

We recommend that the Acting Director of HUD’s Detroit Office of Community Planning and Development require the City to (1) revise 12-month lease agreements and 60-month purchase option agreements with households to 36-month lease-purchase agreements, convert the home-buyer project to a rental project, or reimburse its Program more than $843,000 from non-Federal funds; (2) convert home-buyer projects to rental projects if it can support that the homes meet property standards or reimburse its Program more than $607,000 from non-Federal funds; (3) reimburse its treasury account nearly $164,000 from non-Federal funds; (4) reimburse its Program nearly $406,000; (5) reimburse its Program nearly $26,000 from non-Federal funds or reprogram the nearly $26,000 from Program organization reserve funds to Program entitlement or subrecipient funds; (6) decommit more than $94,000 in Program funds; (7) reimburse its Program nearly $112,000 from non-Federal funds or reprogram the nearly $112,000 from homeowner and/or acquisition-only activity costs to administrative costs; (8) provide supporting documentation or reimburse its treasury account nearly $65,000 from non-Federal funds; (9) reimburse its treasury account nearly $14,000 from non-Federal funds or reprogram nearly $14,000 to the appropriate project; (10) revise Program accomplishments in HUD’s System as appropriate; and (11) implement adequate procedures and controls to address the findings cited in this audit report.