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The U.S Department of Housing and Urban Development's (HUD) Office of Inspector General audited Cook County's (County) HOME Investment Partnerships Program (Program). The audit was part of the activities in our fiscal year 2008 annual audit plan. We selected the County based upon our analysis of risk factors relating to Program grantees in Region V's jurisdiction. Our audit objectives were to determine whether the County effectively administered its Program, appropriately provided match contributions (contributions) for its Program, disbursed Program funds and/or income for new construction multifamily housing projects (multifamily projects) and non-administrative activities, and followed HUD's requirements. This is the third of three audit reports on the County's Program.

The County did not adequately manage its Program. It inappropriately used Program funds and income and American Dream Downpayment Initiative (Initiative) funds, incorrectly reported Program contributions and the amounts of Program contributions it was required to provide in its consolidated annual performance and evaluation reports (consolidated reports) to HUD, and lacked documentation to support its use of Program and Initiative funds.

The County incorrectly reported Program contributions and the amounts of Program contributions it was required to provide in its consolidated reports to HUD. Therefore, it inappropriately reported nearly $5.6 million in Program contributions available for future fiscal years.

The County also inappropriately disbursed Program funds drawn down from its HOME trust fund treasury account (treasury account) and Program income from its HOME trust fund local account (local account) for multifamily projects and disbursed Program funds drawn down from its treasury account for non-administrative activities. As a result, HUD lost more than $59,000 in interest on nearly $7.2 million in Program funds that the County did not use for eligible Program costs within 15 days of being drawn down from its treasury account and the County lost more than $6,000 in interest on more than $1.4 million in Program income that it did not immediately use for eligible Program costs.

We informed the director of the County's Department of Planning and Development (Department) and the Director of HUD's Chicago Office of Community Planning and Development of minor deficiencies through a memorandum, dated February 12, 2009.

We recommend that the Director of HUD's Chicago Office of Community Planning and Development require the County to implement a detailed comprehensive written action plan to improve its procedures and controls to ensure that it operates its Program in accordance with HUD's and its own requirements, reimburse HUD more than $59,000 and its local account more than $6,000 from nonfederal funds, and implement adequate procedures and controls to address the findings cited in this audit report.