U.S. Department of Housing and Urban Development
Office of Inspector General for Audit, Midwest
Ralph H. Metcalfe Federal Building
77 West Jackson Boulevard, Suite 2646
Chicago, Illinois 60604-3507
AUDIT MEMORANDUM
00-CH-249-1811
September 13, 2000
MEMORANDUM FOR: Robert Poffenberger, Director of Community Planning and
Development, Indiana State Office
FROM: Dale L. Chouteau, District Inspector General for Audit, Midwest
SUBJECT: City of South Bend
Broadway Street Mortgage Loan Subsidy Program
South Bend, Indiana
We completed a review of the Broadway Street Mortgage Loan Subsidy Program which is
funded by the City of South Bend’s Community Development Block Grant Program. The
review resulted from a citizen complaint to our Office. The complainant alleged that
Block Grant funds were misappropriated and that houses purchased under the Mortgage
Loan Subsidy Program were substandard. The objectives of our review were to determine
whether the complainant’s allegations were substantiated and whether HUD’s rules and
regulations were violated.
The City was organized under the laws of the State of Indiana. The City is governed by a
Mayor and a nine member City Council. The Mayor of the City is Stephen J. Luecke.
The Community and Economic Development Department administers the City’s
Community Development Block Grant Program. Jon R. Hunt is the Department’s
Executive Director. The City’s official records for the Broadway Street Mortgage Loan
Subsidy Program are at 227 West Jefferson Boulevard, South Bend, Indiana.
To determine whether the complainant’s allegations were substantiated and whether
HUD’s rules and regulations were violated, we reviewed the City’s: Community
Development Block Grant Agreements with HUD for the periods between October 1,
1997 and September 30, 2000; Mortgage Loan Subsidy Program Guidelines; Program
administration contracts for the period between April 15, 1997 and December 31, 1999;
and Program participants’ files. We also reviewed HUD’s files for the City, the Housing
and Community Development Act of 1974, and Title 24 of the Code of Federal
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Audit Memorandum
Regulations Part 5. We interviewed: HUD’s staff; City employees; the former Program
administrator’s employees; the complainant; and Program participants. In addition, our
inspector inspected seven of the 20 houses that received assistance through the Broadway
Street Mortgage Loan Subsidy Program to determine whether the houses met the City’s
Building Code. The seven houses were selected based either on the homeowners’
responses to our questionnaire that problems existed with their house or their availability
for an inspection.
The City’s Broadway Street Mortgage Loan Subsidy Program was generally administered
correctly. However, we found that the City did not follow the Housing and Community
Development Act of 1974 to ensure houses assisted through the Mortgage Loan Subsidy
Program met the City’s Building Code. The Housing Inspector for the Housing Assistance
Office, which the City contracted with to administer its Program, incorrectly certified that six of
the seven houses met the City’s Building Code when they did not. As a result, Block Grant
funds were misappropriated. HUD also lacks assurance that houses were in decent condition
when the Program participants purchased the houses.
We presented our draft finding to the Director of Financial and Program Management for the
City’s Community and Economic Development Department. We held an exit conference
with the Director on August 15, 2000. The City disagreed that some of the housing
construction work that was improperly performed or not provided was a violation of the
City’s Building Code. The City agreed to ensure the construction work was corrected.
We included an excerpt of the City’s comments with the finding. The complete text of the
comments are in Appendix B with the exception of one attachment that was not necessary
for understanding the City’s comments. A complete copy of the City’s comments with the
attachment was provided to HUD’s Indiana State Office Director of Community Planning
and Development. A copy of this memorandum was provided to the City’s Mayor and the
Executive Director of the City’s Community and Economic Development Department.
Within 60 days, please provide us, for each recommendation made in this memorandum, a
status report on: (1) the corrective action taken; (2) the proposed corrective action and the date
to be completed; or (3) why action is considered unnecessary. Also, please furnish us copies of
any correspondence or directives issued because of the review.
Should you or your staff have any questions, please contact me at (312) 353-7832.
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Finding
The City Did Not Ensure That Houses Met
Its Building Code Before Receiving
Assistance
The City of South Bend did not follow the Housing and Community Development Act of 1974
to ensure houses assisted through the Broadway Street Mortgage Loan Subsidy Program met
the City’s Building Code. The City assisted 20 participants in purchasing houses under the
Program. We inspected seven of the 20 houses and concluded each of the seven houses had
construction work not provided or improperly performed. The Housing Inspector for the
Housing Assistance Office, which the City contracted with to administer its Mortgage Loan
Subsidy Program, incorrectly certified that six of the seven houses met the City’s Building
Code when they did not. A requirement of the Housing and Community Development Act of
1974 is that when Community Development Block Grant funds are used to assist individuals in
purchasing a house, the house should be in decent condition. HUD defines decent housing as a
dwelling unit that meets the applicable State and local building codes. The City established the
Mortgage Loan Subsidy Program to meet the national objective of providing decent housing
for low and moderate income individuals. The problems with the Mortgage Loan Subsidy
Program occurred because the Housing Assistance Office did not have proper procedures and
controls over the Program to ensure houses met the City’s Building Code before the
participants received the assistance. The City also did not monitor the Housing Assistance
Office to ensure it administered the Program as required. As a result, Block Grant funds were
not efficiently and effectively used. HUD also lacks assurance that houses were in decent
condition when the Program participants purchased the houses.
Housing And Community Title I, Section 101(c), of the Housing and Community
Development Act Development Act of 1974 requires that when
Community Development Block Grant funds are used
to provide housing to low and moderate income
residents of urban communities, the housing unit
should be in decent condition. 24 CFR Part 5.703(g)
defines decent housing as a dwelling unit that meets the
applicable State and local building codes.
Sample Selection And We selected a sample of seven of the 20 houses that
Inspection Results received housing assistance through the City’s
Broadway Street Mortgage Loan Subsidy Program.
We selected the seven houses to determine whether
they met the City’s Building Code when the
Program participants purchased the houses. The
City or the Housing Assistance Office, which the City
contracted with to administer its Mortgage Loan
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Finding
Subsidy Program, executed seven housing assistance
contracts with the Program participants between
April 1998 and April 2000.
Six of the 20 homeowners indicated in their
responses to our questionnaire that problems existed
with their housing construction work. One
homeowner was selected based upon his availability
for an inspection. The seven houses were inspected
by our inspector during the week of June 5, 2000.
We provided the inspection results to HUD’s
Indiana State Office Director of Community
Planning and Development and the Director of
Finance and Program Management for the City’s
Community and Economic Development Department.
Block Grant Funds Were The City provided $115,000 of Community
Used To Assist Participants Development Block Grant funds to assist seven
With Purchasing Houses That participants in purchasing houses that did not meet the
Did Not Meet The City’s City’s Building Code. The houses contained housing
Building Code construction work that was improperly performed
($3,900) and was not provided ($4,450). The
improper work and work that was not provided
occurred at all seven houses inspected by our inspector.
The seven houses were assisted under the City’s
Broadway Street Mortgage Loan Subsidy Program.
The City recorded forgivable loan repayment
agreements against the seven houses for the assistance
provided.
The following table shows the amount of work that
was improperly performed or not provided for the
seven houses.
Work
Improperly Work Not
Address of House Performed Provided
125 Broadway Street $ 600 $500
301 Broadway Street 1,175 950
309 Broadway Street 750 350
617 Pennsylvania Avenue 300 400
629 Pennsylvania Avenue 400 750
634 Pennsylvania Avenue 425 850
610 Wenger Avenue 250 650
Totals $3,900 $4,450
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Finding
The City established its Broadway Street Mortgage
Loan Subsidy Program to provide housing assistance
to low and moderate income households interested in
purchasing a new house. The housing assistance was
intended to promote homeownership in the City’s
Southeast Neighborhood. The Housing Inspector for
the Housing Assistance Office, which the City
contracted with to administer its Mortgage Loan
Subsidy Program, was responsible for assuring that the
houses met the City’s Building Code.
Our inspector determined that the Housing Inspector
for the Housing Assistance Office did not assure that
the houses met the City’s Building Code when they
were purchased. The houses included construction
work that was not performed correctly and not
provided. The work incorrectly performed and not
provided related to such items as no drywall fire break
under basement stairwells, a sagging floor, stairwells
with inconsistent stair heights and no trim boards
installed, no attaching screws for basement support
posts, no privacy locks for bathrooms, and an
uncovered hole penetrating the exterior wall near the
entrance of the gas line to a house. None of the houses
were caulked where such items as electrical and gas
lines penetrated the exterior of the houses. The
following pictures show examples of construction work
that was improperly performed or not provided.
The house at 629 Pennsylvania
Avenue did not have the required
drywall fire break installed under
the basement stairwell.
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Finding
The house at 309 Broadway Street
had an undersized floor joist in the
laundry room causing the floor to
sag in the middle of the room. The
floor tiles are cracking as a result
of the floor sag.
An unused open hole was made
through the exterior wall of the
home located at 634 Pennsylvania
Avenue. This could allow rodent
and vermin infestation to the
house.
The Housing Assistance Office’s Housing Inspector
was responsible for performing the inspections of the
homes to determine whether they met the City’s
Building Code. He certified that six of the seven
houses met the City’s Building Code. The house at
617 Pennsylvania Avenue was certified as meeting the
Building Code by a former City Code Inspector. The
City’s Building Commissioner said the former Code
Inspector over looked the items that did not meet the
Building Code. The Housing Assistance Office’s
Inspector said it was an oversight that he failed to
identify that the houses did not meet the City’s Building
Code. The Executive Director for the Housing
Assistance Office said no one from her Office
monitored the Housing Inspector’s inspections of the
houses to ensure the quality of the Inspector’s work.
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Finding
The City did not monitor the Housing Assistance
Office to ensure it administered the City’s Broadway
Street Mortgage Loan Subsidy Program as required.
As a result, Community Development Block Grant
funds were not efficiently and effectively used. HUD
also lacks assurance that houses met the City’s
Building Code when the Program participants
purchased the houses.
Auditee Comments Excerpts paraphrased from the City’s comments on
our draft finding follow. Appendix B, pages 12 to
14, contains the complete text of the comments.
While we agree that the Building Code violations on
the houses must be completed correctly, we do not
agree that every item cited in your report is actually
required by the City’s Code. We do agree with the
spirit of this finding and fully intend to take steps to
ensure that the necessary repairs are completed.
We intend to work with the administering entity to
minimize any future problems.
OIG Evaluation Of We agree that not every item cited as housing
Auditee Comments construction that was improperly performed or not
provided was a violation of the City’s Building
Code. However, the seven houses cited in the
finding contained between five and eight Code
violations. In addition, the houses had construction
work that was not a violation of the City’s Building
Code, but the work did not meet the terms of the
sale agreements. The actions proposed by the City
to ensure the housing construction work is corrected
should ensure that the houses meet the City’s
Building Code and the sale agreements.
The City should establish procedures and controls to
monitor the applicable contractor, who administers
the City’s Broadway Street Mortgage Loan Subsidy
Program, to ensure the contractor follows the
Program’s requirements.
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Finding
Auditee Comments We disagree that Title I, Section 101(c), of the
Housing and Community Development Act of 1974
requires Community Development Block Grant
funds to provide decent housing to low and
moderate income residents of urban communities.
While providing decent housing is certainly one of
the objectives, it is not required that all or any Block
Grant funds be used to provide housing.
While 24 CFR Part 5.703(g) says a decent, safe, and
sanitary dwelling unit means a unit that meets the
applicable State and local building codes, the
implementing regulations for the Block Grant
Program are contained at 24 CFR Part 570.
Nothing requires home purchases assisted with
Block Grant funds to meet the requirements of 24
CFR Part 5.703(g).
The City used Community Development Block
OIG Evaluation Of
Grant funds to provide financial assistance to low
Auditee Comments and moderate income individuals interested in
purchasing a new home. The City met the objective
of serving income eligible individuals. However, the
City was also required to ensure that when Block
Grant funds were used to provide housing, the
housing unit should be in decent condition as
required by Title I, Section 101(c), of the Housing
and Community Development Act of 1974. HUD
defines decent housing as a dwelling unit that meets the
applicable State and local building codes.
24 CFR Part 5.703(g) is HUD’s definition of decent
housing.
Auditee Comments The Housing Assistance Office was not required
under contract to inspect the homes prior to
purchase. We believe the City’s Building
Department inspection should be satisfactory to
ensure the quality of the homes. The Housing
Assistance Office did inspect these houses.
OIG Evaluation Of The City contracted with the Housing Assistance
Auditee Comments Office to administer the Broadway Street Mortgage
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Finding
Loan Subsidy Program. The Office’s Housing
Inspector performed inspections of the houses to
ensure they met the City’s Building Code. The City
paid the Housing Assistance Office for the housing inspection
services. Therefore, the City should have ensured
that the Housing Inspector’s inspections were
performed correctly and that the houses met the
City’s Building Code.
Auditee Comments While the finding states $8,350 in housing
construction work needs attention and faults the
City and the Housing Assistance Office for failing to
ensure the construction work was corrected at the
time of purchase, several of these items were noted
as warranty or material defect. Thus, those items
only appeared after the house was purchased. We
agree the builder may have a responsibility to correct
such items as cracked tiles, broken driveway apron,
and cracks in the drywall, these are certainly not
items anyone expected. Citing these items in the
finding is unjustified. These items total $1,875,
leaving a balance of $6,475 as potential Code
violations.
OIG Evaluation Of As previously mentioned, we agreed that not every
Auditee Comments item cited as housing construction work improperly
performed or not provided was a violation of the
City’s Building Code. The construction work cited
as warranty or material defect are items not required
by the City’s Code; however, these are items that
the builder or his subcontractors did not perform
correctly. The City should ensure that these items
are corrected to met the intent of the Program to
provide decent, safe, and sanitary housing.
Auditee Comments The City’s Building Commissioner indicates the
Code numbers cited in the finding do not correspond
to the current Building Code adopted by the City.
The Commissioner provided a copy of the City’s
current Code to the auditors, but it appears a
different version of Code may have been used in
developing the finding.
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Finding
OIG Evaluation Of The Building Commissioner did not provide a copy
Auditee Comments of the City’s Building Code. While an older version
of the City’s Code was used in developing the
finding, the Building Commissioner did verify that
the Code citations mentioned in the inspection
reports did exist in the City’s current Building Code.
We provided the City’s Director of Finance and
Program Management for the Community and
Economic Development Department with a schedule
that showed the housing construction work that was
cited as Code violations were contained in the City’s
current Building Code.
Recommendations We recommend that the Director of Community
Planning and Development, Indiana State Office,
assures that the City of South Bend:
A. Ensures that the $8,350 of construction work
cited in this finding is correctly completed. If
the City is unable to ensure the construction
work is completed, then the City should
reimburse its Community Development Block
Grant Program from non-Federal funds the
total amount of housing assistance that was
provided to the applicable houses and release
the applicable loan repayment agreements.
B. Establishes procedures and controls to
ensure assisted houses meet the City’s
Building Code before the participants receive
the housing assistance as required by Title I,
Section 101(c), of the Housing and
Community Development Act of 1974.
C. Establishes procedures and controls to
monitor the applicable contractor, who
administers the City’s Broadway Street
Mortgage Loan Subsidy Program, to ensure
the contractor follows the Program’s
requirements.
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Appendix A
Schedule Of Ineligible Costs
Recommendation
Number Ineligible Costs 1/
B $8,350
Total $8,350
1/ Ineligible costs are costs charged to a HUD program or activity that the
auditor believes are not allowable by law, contract, or Federal, State, or
local policies or regulations.
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Appendix B
Auditee Comments
PHONE 219/ 235-9371
1200 COUNTY- CITY BUILDING FAX 219/ 235-9021
SOUTH BEND, INDIANA 46601-1830 TDD 219/ 235-5567
CITY OF SOUTH BEND STEPHEN J. LUECKE, MAYOR
COMMUNITY & ECONOMIC DEVELOPMENT
August 10, 2000
Heath Wolfe
Assistant District Inspector General for Audit
Department of Housing and Urban Development
Office of Inspector General
77 West Jackson Boulevard, Room 2646
Chicago, IL 60604
Dear Mr. Wolfe:
We have received your letter dated August 1, 2000 and the attached draft audit finding on
our Broadway Street (Southeast) Mortgage Subsidy program. The purpose of the
program is to assist low to moderate income clients purchase newly constructed homes
within the Southeast neighborhood. While we agree all outstanding code items on these
units must be completed correctly, we do not agree that every item cited in your report is
actually a code required item. We further believe your stated rationale in determining this
issue constitutes a finding, took literary license in interpreting the applicability of certain
laws and regulations. We will clarify our positions on these points later in this letter. That
said, as we told your auditors, we do agree with the spirit of parts of the finding and, as
recommended, fully intend to take steps to work with all involved to have all necessary
repairs completed for the benefit of our clients, the assisted home buyers. We further
intend to work with the subgrantee administering this program to minimize any future
problems.
First, we disagree with the assertion that “Title I, Section 101(c), of the Housing and
Community Development Act of 1974 requires Community Development Block Grant
funds to provide decent housing to low and moderate income residents of urban
communities”. While providing decent housing is certainly one of the objectives it is not
required that all, or any, CDBG funds must be used in that fashion. Further, while 24
CFR 5.703(g) may say “a decent, safe, and sanitary dwelling unit means a unit that meets
the applicable State and local building codes”, the implementing regulations of the CDBG
program under 24 CFR 570, specifically 24 CFR 570.201(n) (Homeownership assistance)
under which our Broadway Street Mortgage Subsidy program is eligible, neither
references nor requires home purchases assisted with CDBG to meet the requirements of
24 CFR 5.703(g).
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Appendix B
Second, our subgrantee, Housing Assistance Office (HAO) was not required under
contract to inspect the homes prior to purchase. Indeed, because of our understanding
outlined above, we believe the Building Department inspection should be satisfactory to
ensure the quality of the homes. However, Housing Assistance Office does provide an
inspection service on other, similar programs and, in an effort to provide better service for
the home buying clients did inspect these units.
Third, we must note that while your finding states $8,350 worth of items needing
attention, and faults the City and its subgrantee for failing to have all these items corrected
at the time the home was purchased, several of these items you noted as “warranty” or
“material defect” items, meaning those conditions only appeared during the passage of
time, as the house was occupied. We agree the builder may have the responsibility to
correct such items (cracked tiles, broken driveway apron, cracks in drywall), but they
certainly are not items anyone could have foreseen would develop in the future. Counting
those as part of our “finding” is unjustified. According to our calculations, these items
which are clearly in this category total $1,875, leaving a balance of $6,475 as potential
code items.
Fourth, our Building Commissioner indicates the code numbers cited in your report do not
correspond to the correct current code book adopted for South Bend, Indiana. The
Building Commissioner gave a copy of the correct current code to your auditor during a
personal meeting on the subject, but it appears some different version of code may have
been used in developing your report. We have attached our line by line response to each
cited area of concern listed in your report. In general, we assert $3,275 of the items listed
are definitely not code violations, leaving the cost of correcting potential code violations
to be $3,200. (Please note there are $1,075 in items which we cannot tell from the
picture/information provided whether an actual violation exists, if it is determined there is
no violation, the amount will decrease.) For seven units, averaging about $100,000 each
in appraised value, that’s about ½ of 1%.
We feel it is important to note that the amount of work needing to be corrected is very
minor and completely normal in new housing construction. We agree code violations
must be corrected, but are not sure the magnitude of the need, nor the regulatory
foundation are sufficient to warrant a “finding”.
Finally, we are disturbed that this draft does not speak al all to the overwhelming benefit
to both our client home buyers and our community revitalization efforts this program
provides to South Bend. Your auditors were visibly impressed with the overall quality of
these homes. They are beautiful! A real asset to our community. While the program is
not perfect, we are working hard to provide an exceptional opportunity for eligible home
buyers-both the chance to live in a large, beautiful new home, and the potential to
recognize a real increase in net worth-because they are willing to take a risk in a
neighborhood during its rebuilding.
In closing, we would like to thank you and your staff for your diligence and
professionalism in conducting this audit. We were also impressed with their genuine
concern for our clients and their welfare. As we discussed with them many times, we are
open to suggestions for improvement to our programs and sincerely wish to provide great
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Appendix B
CDBG programming for the citizens of the City of South Bend. We know we are not
experts in all areas and appreciate your assistance in further refining and improving our
efforts.
Sincerely,
Elizabeth Leonard
Director
Financial & Program Management
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Appendix C
Distribution
Secretary's Representative, Midwest (2)
Senior Community Builder/State Coordinator, Indiana State Office
Director of Community Planning and Development, Indiana State Office (2)
Deputy Secretary, SD (Room 10100)
Acting Chief of Staff, S (Room 10000)
Special Assistant to the Deputy Secretary for Project Management, SD (Room 10100)
Assistant Secretary for Administration, A (Room 10110)
Assistant Secretary for Congressional and Intergovernmental Relations, J (Room 10120)
Senior Advisor to the Secretary, Office of Public Affairs, W (Room 10132)
Director of Scheduling and Advance, AL (Room 10158)
Counselor to the Secretary, S (Room 10218
Deputy Chief of Staff, S (Room 10226)
Deputy Chief of Staff for Operations, S (Room 10226)
Deputy Chief of Staff for Programs, S (Room 10226)
Deputy Chief of Staff for Policy, S (Room 10226)
Acting Deputy Assistant Secretary for Public Affairs, W (Room 10222)
Special Assistant for Inter-Faith Community Outreach, S (Room 10222)
Executive Officer for Administrative Operations and Management, S (Room 10220)
Senior Advisor to the Secretary for Pine Ridge Project, W (Room 10216)
General Counsel, C (Room 10214)
Assistant General Counsel, Midwest
Director of Federal Housing Enterprise Oversight, O (9th Floor Mailroom)
Assistant Secretary for Housing-Federal Housing Commissioner, H (Room 9100)
Office of Policy Development and Research, R (Room 8100)
Assistant Secretary for Community Planning and Development, D (Room 7100)
General Deputy Assistant Secretary for Community Planning and Development, D (Room
7100)
Deputy Assistant Secretary for Grant Programs, DG (Room 7208)
Acting Director of Block Grant Assistance, DGB (Room 7286)
Director of Field Management, DCF (Room 7204)
Executive Vice President, Government National Mortgage Association, T (Room 6100)
Assistant Secretary for Fair Housing and Equal Opportunity, E (Room 5100)
Chief Procurement Officer, N (Room 5184)
Assistant Secretary for Public and Indian Housing, P (Room 4100)
Chief Information Officer, Q (Room 8206)
Director of Departmental Operations and Coordination, I (Room 2124)
Chief Financial Officer, F (Room 2202)
Deputy Chief Financial Officer for Finance, FF (Room 2202)
Acting Director of Enforcement Center, V (200 Portals Building)
Director of Real Estate Assessment Center, X (1280 Maryland Avenue, SW, Suite 800)
Director of Multifamily Assistance Restructuring, Y (4000 Portals Building)
Assistant Deputy Secretary for Field Policy and Management, SDF (Room 7108)
Director of Budget, FO (Room 3270)
Audit Liaison Officer, 3AFI (2)
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Appendix C
Special Advisor/Comptroller, D (Room 7228) (2)
Departmental Audit Liaison Officer, FM (Room 2206) (2)
Acquisitions Librarian, Library, AS (Room 8141)
Deputy Staff Director, Counsel, Subcommittee of Criminal Justice, Drug Policy & Human
Resources, B 373 Rayburn House Office Building, Washington DC 20515
The Honorable Fred Thompson, Chairman, Committee on Governmental Affairs, 340
Dirksen Senate Office Building, United States Senate, Washington DC 20510
The Honorable Joseph Lieberman, Ranking Member, Committee on Governmental Affairs,
706 Hart Senate Office Building, United States Senate, Washington DC 20510
Honorable Dan Burton, Chairman, Committee on Government Reform, 2185 Rayburn
Building, United States House of Representatives, Washington DC 20515
Henry A. Waxman, Ranking Member, Committee on Government Reform, 2204 Rayburn
Building, United States House of Representatives, Washington DC 20515
Ms. Cindy Sprunger, Subcommittee on Oversight and Investigations, Room 212, O'Neil
House Office Building, Washington DC 20515
Director, Housing and Community Development Issue Area, United States General
Accounting Office, 441 G Street N.W., Room 2474, Washington DC 20548 (Attention:
Judy England-Joseph)
Steve Redburn, Chief, Housing Branch, Office of Management and Budget, 725 17th Street,
N.W., Room 9226, New Executive Office Building, Washington DC 20503
Mayor, City of South Bend
Director of Community and Economic Development Department, City of South Bend (2)
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City of South Bend, Broadway Street Mortgage Loan Subsidy Program, South Bend, Indiana
Published by the Department of Housing and Urban Development, Office of Inspector General on 2000-09-13.
Below is a raw (and likely hideous) rendition of the original report. (PDF)