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We completed a review of the City of New York, Mayor’s Office of Housing Recovery Operations’ administration of the Build it Back Single Family Program, funded with Community Development Block Grant Disaster Recovery (CDBG-DR) funds provided by the U.S. Department of Housing and Urban Development (HUD) to assist in the disaster recovery and rebuilding efforts resulting from Hurricane Sandy.  The objective of the audit was to determine whether City officials had adequate controls to ensure that the use of CDBG-DR funds was consistent with the Build it Back Single Family Program guidelines established under the HUD-approved action plan.

Our review determined that City officials implemented policies that did not always ensure that CDBG-DR funds were disbursed in accordance with the action plan and Federal requirements.  Specifically the policies implemented did not ensure that all eligible homeowners were reimbursed in accordance with the action plan and the Program and CDBG-DR-assisted homes complied with HUD’s Lead Safe Housing Rule requirements.  In addition, City officials did not maintain complete and accurate Program files and records.  These deficiencies resulted from City officials’ decision to provide additional CDBG-DR assistance to homeowners with Small Business Administration (SBA) loans and reduce operational costs.  Further, City officials believed that the Program would meet HUD’s Lead Safe Housing Rule requirements after reimbursement and wished to avoid recapturing grants from homeowners who did not allow the Program to complete the lead hazard work.  Additionally, City officials did not establish adequate monitoring controls to ensure that revised record-keeping procedures were consistently followed.  As a result, they could not assure HUD that the use of CDBG-DR funds benefited eligible homeowners in a fair and equitable manner, assisted homes were lead safe, and Program records were properly maintained.

We recommend that HUD instruct City officials to (1) submit an amended action plan for approval to ensure that it agrees with the City’s policies regarding the use of $4.5 million and planned use of $1.3 million in additional CDBG-DR assistance to homeowners with SBA loans and $32,107 in assistance above the Program’s 60 percent reimbursement rate, (2) reimburse $101,398 in additional grants owed to 11 homeowners, and (3) provide documentation to support that more than $1 million in CDBG-DR funds was disbursed for lead-safe homes.