Issue Date
June 9, 2008
Audit Report Number
2008-AT-1009
TO: Mary D. Presley, Director, HUD Atlanta Office of Community Planning
and Development, 4AD
FROM: James D. McKay, Regional Inspector General for Audit, 4AGA
SUBJECT: The City of Augusta, Georgia, Controls Over Its HOME Program Were
Inadequate
HIGHLIGHTS
What We Audited and Why
We audited the City of Augusta’s (City) HOME Investment Partnerships (HOME)
program as part of the U.S. Department of Housing and Urban Development’s
(HUD) annual audit plan. We selected the City for review based on a HOME risk
assessment we conducted. Our audit objectives were to determine whether the
City complied with HOME program requirements for commitments, production
and completion of project activities, and eligibility and support of project costs.
What We Found
The City’s controls over its HOME program were inadequate. We identified
more than $1 million in HOME funds that involved questioned costs and funds
that were subject to recapture. Specifically, the City did not (a) properly commit
$755,284, (b) have proper documentation and analysis to support approvals and
effectively address project performance delays, (c) ensure proper support of more
than $196,657, (d) ensure the eligibility of $92,129 for affordable housing
compliance, and (e) properly maintain and manage program staff. The violations
occurred because City management and staff did not follow and enforce program
requirements.
What We Recommend
We recommend that the Director of HUD’s Atlanta Office of Community
Planning and Development require the City to properly support or repay more
than $566,697 in questioned costs and recapture more than $477,373 because of
program violations. We also recommend that the Director require the City to
establish and implement proper controls and procedures to ensure compliance
with program requirements.
For each recommendation without a management decision, please respond and
provide status reports in accordance with HUD Handbook 2000.06, REV-3.
Please furnish us copies of any correspondence or directives issued because of the
audit.
Auditee’s Response
We provided our discussion draft audit report to the City on April 21, 2008 and
held an exit conference on April 30, 2008. The City provided written comments
on May 14, 2008.
The City generally agreed with our finding and stated it has begun implementing
the recommendations. The complete text of the City’s written response, along
with our evaluation of that response, can be found in appendix B of this report.
The City also provided attachments with its response that are available for review
upon request.
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TABLE OF CONTENTS
Background and Objectives 4
Results of Audit
Finding 1: The City’s Controls Over Its HOME Program Were 5
Inadequate
Scope and Methodology 12
Internal Controls 14
Appendixes
A Schedule of Questioned Costs and Funds to Be Put to 15
Better Use
B Auditee Comments and OIG’s Evaluation 16
C Schedule of Funds Not Committed by the Required 24
Deadline
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BACKGROUND AND OBJECTIVES
The City of Augusta’s (City) government was created by legislative act in the state of Georgia
from the unification of two governments, the City of Augusta, Georgia, and Richmond County,
Georgia. On June 20, 1995, the citizens of the City of Augusta and Richmond County voted to
consolidate into one government named Augusta, Georgia. The officials for the new government
were elected and took office on January 1, 1996. The unified government combined all
functions and began financial operations on January 1, 1996.
The City is governed by a full-time mayor, with a term of four years, and a 10-member
commission, serving on a part-time basis and elected to staggered terms of four years. The
mayor and commission appoint an administrator who serves as a full-time administrative officer
and is responsible for the daily operations of the government. The City’s Housing and
Community Development department is responsible for administering several programs
including the Community Development Block Grant, HOME Investment Partnerships (HOME),
Emergency Shelter Grant, and the Economic Development Initiative. The mission of the
Augusta Housing and Community Development department is to create positive change by
promoting self-sufficiency through partnership in economic development, quality housing, and
neighborhood reinvestment.
Since 2003, the City has received more than $6.9 million in HOME and American Dream
Downpayment Initiative funding. HOME funding is allocated to eligible state and local
governments to strengthen public-private partnerships and to supply decent, safe, and sanitary
affordable housing to very low-income families. Participating jurisdictions may use HOME
funds to carry out multiyear housing strategies through acquisition, rehabilitation, new
construction, and tenant-based rental assistance.
The U.S. Department of Housing and Urban Development’s (HUD) Atlanta Office of
Community Planning and Development in Atlanta, Georgia, is responsible for overseeing the
City. HUD’s most recent monitoring report, dated August 10, 2007, indicated that the City’s
HOME program did not operate at a level that ensured compliance with HOME program
requirements.
The City’s independent public accountant report for fiscal year 2006 contained one current
finding and five prior findings. The independent public accountant findings included excessive
administrative costs allocation, lack of subreceipient monitoring, and noncompliance with
program income requirements.
Our audit objectives were to determine whether the City complied with HOME program
requirements for commitments, production and completion of project activities, and eligibility
and support of project costs.
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RESULTS OF AUDIT
Finding 1: The City’s Controls Over Its HOME Program Were
Inadequate
The City’s controls over the administration of its HOME program were inadequate. The
violations occurred because City management and staff did not follow and enforce program
requirements. As a result, the City incurred more than $1 million in HOME funds that involved
questioned costs and funds that were subject to recapture.
Specifically, the City did not
• Follow commitment requirements involving $755,284,
• Have proper documentation and analysis to support project approvals and effectively
address project delays,
• Ensure proper support of more than $196,657,
• Ensure the eligibility of $92,129 for affordable housing compliance, and
• Maintain and manage program staff.
Commitment Requirements
Not Followed
The City did not properly commit $755,284 in HOME funds that were subject to
recapture by HUD because it did not meet the commitment deadline (see
appendix C). For 7 of 18 activities examined, the City did not commit the funds
by the 24-month commitment deadline. The $755,284 includes $477,373 that the
City had not committed at the time of our review and $277,911 that was
committed after expiration of the 24-month commitment deadline. Regulations at
24 CFR [Code of Federal Regulations] 92.500(d) state that HUD will recapture or
reduce HOME funds not committed within 24 months after the last day of the
month in which HUD provides notice of its execution of the HOME agreement.
The City also did not accurately report commitment information to HUD. It
entered incorrect commitment dates into HUD’s Integrated Disbursement and
Information System for 17 of 18 sampled activities. The incorrect data included
$983,185 for nine activities, for which the City entered commitment dates that
were earlier than the actual commitment dates, and more than $1.5 million for
another eight activities, for which the City entered commitment dates that were
later than the actual commitment dates. HUD relies on the accuracy of the
commitment information entered by the grantee in the system. The incorrect
5
dates reduced the effectiveness of the report as a tool for HUD’s monitoring of the
program’s commitment requirements.
Delayed Projects Approved without
Required Documentation and
Supporting Analysis
The City did not maintain the required documentation and analysis to support its
approval of three project activities. Regulations at 24 CFR 92.504(a) provide that
recipients are responsible for managing the day-to-day operations of their HOME
program, ensuring that HOME funds are used in accordance with all program
requirements and written agreements, and taking appropriate action when
performance problems arise. Notice CPD (Community Planning and
Development) 98-1 states that as part of the application process, recipients should
have the applicant submit a statement of sources/uses of funds for the project.
Regulations at 24 CFR 92.508(a) require recipients to establish and maintain
sufficient records to enable HUD to determine compliance with requirements.
The City also did not effectively address delays that did or could affect the
eventual completion and sale of affordable housing. Regulations at 24 CFR 92.2
require construction to start within 12 months. The City contracts required
projects to be either obligated or completed within 13 months. The three project
activities consisted of projects 954, 1334, and 1599.
Project 954 - The City awarded a contract for $185,782 to a community housing
development organization (CHDO) on January 3, 2006, using fiscal year 2003
funding. The contract stated that the CHDO was to perform new construction
services for up to 10 single-family homes. These homes were to be sold or rented
to eligible low- and very low-income persons. The contract also required the
CHDO to maintain evidence of additional financing resources. However, the
City’s file did not contain evidence that the CHDO had obtained any financial
commitments. The file also did not contain the required source and application of
fund statements.
The contract also states that the project must be completed within 13 months from
the signing of the contract. However, the CHDO did not start construction within
the required timeframe. The HOME program manager stated that in the past, City
officials did not encourage staff to take appropriate actions against slow
performing CHDOs. Also, during the latter part of 2006 and early 2007, the
CHDO went through a transition in its administration when the CHDO’s director
left. After his departure, no housing activity took place. Due to the CHDO’s
inactivity, in July 2007, the City recaptured funds totaling $185,782 from the
CHDO and reprogrammed the funds for use by other CHDOs. Although the City
reprogrammed the funds, they should have been recaptured or reduced by HUD
because they were not committed within the 24-month period.
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Project 1334 - A contract was approved for the same CHDO as project 954. On
October 18, 2005, using fiscal year 2005 funding, the City awarded a contract for
$92,128 to the CHDO to construct up to 10 single-family homes. The contract
required the same number of units as project 954. These homes were also to be
sold or rented to HOME-eligible persons. The contract stated that the CHDO
would complete the project within 13 months from the signing of the contract. As
of March 31, 2008, there was no activity, and no funds had been drawn. The
project was past the required start date and was behind schedule with no homes
constructed. The CHDO’s ability to perform construction services and provide
affordable housing in a timely manner is questionable. City staff stated that they
were waiting for the CHDO to submit a revised plan which involved reducing the
number of homes to be built. According to City staff, the CHDO indicated that it
would not be able to complete the project for $92,128. The contract required the
CHDO to maintain evidence of additional financing resources. However, the
City’s file did not contain evidence that the CHDO had the financial commitments
needed to complete the project. The file also did not contain the required source
and application of fund statements.
Project 1599 – The contract between the City and a nonprofit organization was
awarded for $200,000 on December 12, 2006. The organization was required to
obligate the HOME funds within 13 months of the date of the contract execution.
However, as of March 31, 2008, no funds had been disbursed, and construction
had not begun. In addition, the City’s file did not contain evidence that the
organization had obtained additional finance resources as required by the contract.
The files also did not contain the required source and application of fund
statements.
The Augusta Housing and Community Development department director stated
that in the past, CHDOs were not required to obtain additional funding.
Therefore, they did not obtain additional financing. Thus, the practice of
providing the CHDOs all of the funds needed to complete projects did not comply
with the program requirements.
Costs Not Properly Supported
The City disbursed $196,657 for project activities that were not properly
supported as allowable HOME costs. The amount included costs for
homeownership downpayment assistance, lots purchased, CHDO staff salaries,
consultant services, and other miscellaneous expenses. Regulations at 24 CFR
92.508(a) require recipients to establish and maintain sufficient records to enable
HUD to determine compliance with program requirements. The $196,657
consists of
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• $105,036 the City disbursed for homeownership downpayment assistance
program project activities. The City did not obtain supporting
documentation to verify whether the homebuyer had previously owned a
home and if so, when. There was no supporting documentation indicating
whether the homebuyer met the criteria for eligibility to receive
downpayment assistance.
• $60,000 paid by the City for four lots purchased by a CHDO (which
includes project 963) without adequate documentation to support how
much was paid for the lots. For example, the file did not contain a
cancelled check or the closing statement.
• $17,701 for unsupported salary expenditures. The file did not evidence
that the City had obtained proper payroll documentation from the CHDOs.
The timesheets did not provide information regarding how the employees’
time was charged, and there were no photocopies of payroll
documentation in the file.
• $2,400 for unsupported consultant services. There were no written
agreements in the file to support payments made to consultants. Without
the agreements, the City could not determine whether the consultant
services were necessary, reasonable, and in compliance with HOME
program requirements.
• $11,520 in other miscellaneous expenses paid by the City without
sufficient supporting documentation. The City could not determine
whether the expenses were for HOME-eligible activities.
Ineligible Costs and Inadequate
Support for Affordable Housing
Units
The City did not meet the program’s affordable housing objective for two of four
completed project activities. Home sales in projects 963 and 1236 showed that
the City did not ensure that four of eight affordable housing units were only sold
to individuals who met the required income limits.
• For project 963, one of the four homebuyers had income that exceeded the
program’s limit. We were unable to obtain documentation for another
homebuyer. Regulations at 24 CFR 92.508(a) requires recipients to
maintain records demonstrating that each family is income-eligible.
• For project 1236, two of the four homebuyers had incomes that exceeded
the program’s limit. The City disbursed $92,129 for this project.
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Because of these conditions, the City did not meet the program’s affordable
housing objective. Thus, the $92,129 spent on the activity was not supported as
an eligible program cost.
Staff Capacity Issues
The City did not properly hire, train, manage, and supervise the staff needed to
administer the program. Regulations at 24 CFR 92.504(a) provide that the City is
ultimately responsible for managing the day-to-day operations of its HOME
program and taking appropriate action when performance problems arise.
Regulations at 24 CFR 92.508(a) require recipients to establish and maintain
sufficient records to enable HUD to determine compliance with program
requirements. The review showed that the City did not
• Maintain staff to administer the program. The City’s organizational charts
and employee listing showed that since 2003, there had been four different
directors of the City’s Housing and Community Development office. It also
showed that since 2003, there had been two different financial officers and
three different housing program managers in the City’s Housing and
Community Development office. At the end of December 2007, the financial
officer left, and as of March 31, 2008, the City had not hired a full-time
permanent financial officer. The City’s Housing and Community
Development director stated that he planned to hire a new financial officer and
an assistant director.
• Properly manage, hire, train, and supervise its staff on issues concerning
commitment requirements, supporting documentation for project approvals,
project activity delays, eligibility and support of project costs, and
documentation of compliance with affordable housing requirements. In
February 2007, the City reorganized its Housing and Community
Development office. However, the City’s Housing and Community
Development staff was reassigned duties and responsibilities in areas in which
they had no prior experience or training. The staff was not provided with
adequate guidance to properly administer the program.
Conclusion
The City needs to improve controls over its HOME program. City management
and staff did not follow and enforce program requirements concerning
commitment requirements, project activity delays, eligibility and support of
project costs, and documentation of compliance with affordable housing
requirements. The City also did not properly manage, supervise, and maintain the
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staff needed to administer the program. As a result, the City had more than $1
million in HOME funds that involved questioned costs and funds that were
subject to recapture.
Recommendations
We recommend that the Director of HUD’s Atlanta Office of Community
Planning and Development
1A. Require the City to reimburse its United States Treasury trust fund account
from nonfederal funds the $277,911 that it committed after expiration of
the commitment deadline.
1B. Recapture $477,373 on deposit in the United States Treasury trust fund
account, which the City had not committed although the commitment
deadline had expired.
1C. Require the City to develop and implement procedures and controls to
ensure that future program funds are committed by the required deadline
dates.
1D. Require the City to develop and implement procedures and controls to
ensure accurate entries into HUD’s Integrated Disbursement and
Information System.
1E. Require the City to take appropriate action to recover all HOME funds
invested in activities the City cannot complete in a timely manner.
1F. Require the City to develop and implement procedures and controls to
ensure proper documentation of its review and approval of activities
before disbursing future HOME funds for ownership and rental housing
carried out by community housing development organizations and other
developers.
1G. Require the City to reimburse its United States Treasury trust fund account
from nonfederal funds $196,657 in questioned costs that it cannot support
as having been incurred for costs that met program requirements.
1H. Require the City to reimburse its United States Treasury trust fund account
from nonfederal funds the $92,129 disbursed for project 1236, since the
project did not result in units being sold to individuals who met the
HOME program’s income limits.
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1I. Require the City to develop and implement procedures and controls to
ensure that affordable housing units are only sold or rented to individuals
who meet the program’s income limits.
1J. Require the City to hire and train sufficient staff to effectively administer
its HOME program.
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SCOPE AND METHODOLOGY
To accomplish our objectives, we
• Researched HUD handbooks, the Code of Federal Regulations, and other requirements
and directives that govern the City’s HOME program;
• Obtained and reviewed HUD’s Integrated Disbursement and Information System reports
from HUD;
• Reviewed HUD’s monitoring reports and files for the City’s HOME program;
• Reviewed the City’s consolidated annual performance and evaluation reports for its
HOME program;
• Reviewed the City’s procedures and controls used to administer its HOME program
activities;
• Interviewed officials of the Atlanta HUD Office of Community Planning and
Development, the City, and community housing development organizations;
• Obtained and reviewed the City’s accounting records, annual audited financial
statements, program and project files, policies, and procedures; and
• Conducted tests to determine the City’s compliance with HOME program requirements.
During the audit period, the City disbursed $7,277,669 for community housing
development organizations, housing rehabilitation, downpayment assistance, demolition
rebuild, and professional services, of which we examined $2,289,520 or 31 percent. We
selected the tested items, considering factors such as past HUD monitoring concerns,
transaction amount, and transaction type. We also conducted tests to determine whether
the City complied with HOME program requirements for commitments. We selected for
review 18 projects from a universe of 449 HOME program activities. Our sample
included projects from HOME grant program years 2003 through 2006. The results of
the audit only apply to the tested activities and cannot be projected to the universe or total
population.
We performed the review from October 2007 to March 2008 at the offices of the City’s Housing
and Community Development department, the residences of its HOME program recipients, and
the HUD Office of Community Planning and Development in Atlanta, Georgia.
We did not review and assess general and application controls over computer-processed data for
the City’s general ledger and HUD’s Integrated Disbursement and Information System. We
conducted other tests and procedures to assure the integrity of computer-processed data that were
relevant to the audit objectives. The tests included, but were not limited to, comparison of
12
computer-processed data to written agreements, contracts, invoices, and other supporting
documentation. We also inspected selected development sites and interviewed community
housing development organization officials. The tests disclosed that the City entered incorrect
commitment information into HUD’s Integrated Information and Disbursement System. The
incorrect data entries did not impact our report because we obtained correct information for the
activities reviewed.
The review generally covered the period January 1, 2003, through December 31, 2007. We
adjusted the review period when necessary.
We performed the review in accordance with generally accepted government auditing standards.
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INTERNAL CONTROLS
Internal control is an integral component of an organization’s management that provides
reasonable assurance that the following objectives are being achieved:
• Effectiveness and efficiency of operations,
• Reliability of financial reporting, and
• Compliance with applicable laws and regulations.
Internal controls relate to management’s plans, methods, and procedures used to meet its
mission, goals, and objectives. Internal controls include the processes and procedures for
planning, organizing, directing, and controlling program operations. They include the systems
for measuring, reporting, and monitoring program performance.
Relevant Internal Controls
We determined the following internal controls were relevant to our audit objectives:
• Policies and procedures that management has implemented to reasonably
ensure that resource uses are consistent with laws and regulations.
• Policies and procedures that management has implemented to reasonably
ensure that resources are safeguarded against waste, loss, and misuse.
We assessed the above controls.
A significant weakness exists if management controls do not provide reasonable
assurance that the process for planning, organizing, directing, and controlling
program operations will meet the organization’s objectives.
Significant Weaknesses
Based on our review, we believe the following item is a significant weakness:
• The City lacked adequate controls and procedures to ensure compliance
with HUD requirements (see finding 1).
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APPENDIXES
Appendix A
SCHEDULE OF QUESTIONED COSTS
AND FUNDS TO BE PUT TO BETTER USE
Recommendation Funds to be put
number Ineligible 1/ Unsupported 2/ to better use 3/
1A $277,911
1B $477,373
1G $196,657
1H $92,129 _______ _______
Total $370,040 $196,657 $477,373
1/ Ineligible costs are costs charged to a HUD-financed or HUD-insured program or activity
that the auditor believes are not allowable by law; contract; or federal, state, or local
policies or regulations.
2/ Unsupported costs are those costs charged to a HUD-financed or HUD-insured program
or activity when we cannot determine eligibility at the time of audit. Unsupported costs
require a decision by HUD program officials. This decision, in addition to obtaining
supporting documentation, might involve a legal interpretation or clarification of
departmental policies and procedures.
3/ Recommendations that funds be put to better use are estimates of amounts that could be
used more efficiently if an Office of Inspector General (OIG) recommendation is
implemented. This includes reductions in outlays, deobligation of funds, withdrawal of
interest subsidy costs not incurred by implementing recommended improvements,
avoidance of unnecessary expenditures noted in preaward reviews, and any other savings
which are specifically identified. In this instance, if our recommendations are
implemented, HUD will recapture the $477,373 not committed by the required deadline.
15
Appendix B
AUDITEE COMMENTS AND OIG’S EVALUATION
Ref to OIG Evaluation Auditee Comments
16
Comment 1
Comment 2
17
Comment 2
Comment 2
18
Comment 3
Comment 4
Comment 5
19
Comment 6
Comment 7
Comment 8
Comment 9
20
Comment 10
21
OIG Evaluation of Auditee Comments
Comment 1 The City acknowledges its non-compliance and agrees the funds are subject to
recapture. The City should reimburse $277,911 to the United States Treasury
trust fund account from nonfederal funds.
Comment 2 The City agreed that $477,373 in HOME funds were not committed within the
statutory requirement of 24-months. The City stated that of the $477,373 in
HOME funds, it obligated $43,778 to three projects under the year 2003 rental
rehabilitation program. However, the City obligated the $43,778 after the
expiration of the 24-month commitment deadline; therefore, HUD should
recapture the funds.
Comment 3 The City stated it has developed and implemented procedures to ensure that
HOME funds are committed in compliance with the required commitment
deadline dates. The City provided a copy of its HOME procedures for
committing HOME funds and HOME project tracking log. The procedures were
provided after we completed our site work. Thus, we did not verify the
information. The City should provide its new procedures for committing and
tracking HOME funds to HUD.
Comment 4 The City responded it has developed and is in the process of implementing the
procedures for entering HOME project data in Integrated Disbursement and
Information System. The City included its procedures for entering Integrated
Disbursement and Information System data and the applicable forms. The
procedures were provided after we completed our site work. Thus, we did not
verify the information. The City should provide its new procedures for entering
HOME project data in the Integrated Disbursement and Information System to
HUD.
Comment 5 The City commented that staff reviewed all open HOME projects and determined
the need to reprogram funds from completed projects and to undertake new
projects. The City provided a chart listing open HOME projects and projects that
are having their funds reprogrammed. Since the chart was provided after we
completed our site work, we did not verify the information. The City should
provide its chart listing all open HOME projects to HUD.
Comment 6 The City stated that staff has implemented procedures to assist in reviewing all
applications before awarding funds. The City provided an underwriting checklist,
a house plans form, and a compliance review checklist. The information was
provided after we completed our site work. Therefore, we did not verify the
information. The City should provide the information to HUD for review.
22
Comment 7 The City stated that it obtained adequate supporting documentation to substantiate
$305,235 of the $392,540 in questioned costs. The City concluded that $87,304 is
subject to repayment. Based on the supporting documentation provided, we
determined that $196,657 of the $392,540 remains unsupported. We revised the
report to reflect the revised unsupported costs.
Comment 8 The City reviewed the agency clients’ income documentation and agreed that the
units were not sold to individuals who met the HOME program’s income limits.
The City stated the $60,000 for project 963 is included under recommendation 1G
which is subject to repayment. The City accepts responsibility and the $92,129 is
also subject to repayment. We agree that projects 963and 1236 did not result in
units being sold to individuals who met the HOME program’s income limits. We
also agree with the City that the $60,000 for project 963 is included under
recommendation 1G. We revised the report to reflect that $92,129 for project
1236 should be reimbursed to the United States Treasury trust fund account from
nonfederal funds for this recommendation.
Comment 9 The City responded it has developed and implemented the HOME income
eligibility determination worksheet. The City also responded that the worksheet
was distributed to all the CHDOs. According to the City, staff performs quarterly
on-site monitoring of CHDOs to review project and client records, check on
progress of the projects, and provide technical assistance. The documentation
was provided after we completed our site work. Thus, we did not verify the
information. The City should provide its documentation to HUD.
Comment 10 The City has not hired and trained sufficient staff to effectively administer its
HOME program. We acknowledge that the City plans to hire an assistant director
in housing development. However, the City did not address the hiring of a full-
time permanent financial officer. The City also did not address the continuing
training needs of its staff.
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Appendix C
SCHEDULE OF FUNDS NOT
COMMITTED BY THE REQUIRED DEADLINE
Days
Actual past 24-
Project Program Required commitment month
number year commitment date date deadline Amount Notes
Funds still not committed as of January 28, 2008
1316 2004 Apr. 30, 2006 See note A 637 $67,350 B, C
1317 2004 Apr. 30, 2006 See note A 637 $74,218 B, C
1530 2005 May 31, 2007 See note A 241 $210,000 B, C
1536 2003 May 31, 2005 See note A 971 $77,383 B, C
1537 2004 Apr. 30, 2006 See note A 637 $48,422 B, C
Subtotal See note A $ 477,373
Funds committed after 24-month deadline
954 2003 May 31, 2005 Jan. 3, 2006 216 $185,782 B
1514 2005 May 31, 2007 July 10, 2007 39 $92,129 B
Subtotal $ 277,911
Total $ 755,284
Notes
A Funds still not committed as of January 28, 2008. The 24-month commitment period has expired.
B The costs associated with these projects are not allowed because the City did not commit the funds
by the 24-month commitment deadline. Regulations at 24 CFR 92.500(d)(1) state that HUD will
recapture or reduce HOME funds in the HOME trust fund by the amount of any funds in the U.S.
Treasury account that are not committed within 24 months after the last day of the month in which
HUD notifies the participating jurisdiction of HUD’s execution of the HOME agreement.
Regulations at 24 CFR 92.2 define commitment as an executed legally binding agreement to use a
specific amount of HOME funds to produce affordable housing, an executed written agreement
reserving a specific amount of funds to a community housing development organization, or having
met the requirements to commit to a specific local activity.
C The City had not drawn down these funds at the time of our review.
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The City of Augusta, Georgia, Controls Over Its HOME Program Were Inadequate
Published by the Department of Housing and Urban Development, Office of Inspector General on 2008-06-09.
Below is a raw (and likely hideous) rendition of the original report. (PDF)