Issue Date
October 25, 2011
Audit Report Number
2012-NY-1003
TO: William O’Connell, Director, Community Planning and Development, Buffalo,
New York, 2CD
FROM: Edgar Moore, Regional Inspector General for Audit, NY/NJ, 2AGA
SUBJECT: The City of Syracuse, NY, Did Not Always Administer Its CDBG Program in
Accordance With HUD Requirements
HIGHLIGHTS
What We Audited and Why
We audited the operations of the City of Syracuse, NY, pertaining to its
Community Development Block Grant (CDBG) program. We selected the City
based on a risk analysis of upstate New York grantees, which identified Syracuse
as high risk. The objectives of the audit were to determine whether the City
administered its CDBG program effectively, efficiently, and economically in
accordance with applicable rules and regulations. Specifically, we wanted to
determine whether City officials had (1) established and implemented the
necessary controls to ensure that program activities were adequately documented
and administered in accordance with HUD regulations, and (2) expended CDBG
funds for eligible activities.
What We Found
The City did not always administer its CDBG program in accordance with HUD
regulations. Specifically, it had administrative weaknesses in its float loan
program. City officials could not demonstrate that $907,195 in float loan funds
used to finance 11 new housing construction activities (1) were provided to
qualified nonprofits; (2) were necessary, reasonable, and adequately supported;
and (3) met a national objective. As a result, $162,200 in ineligible costs and
$744,995 in unsupported costs were incurred, and City officials’ ability to ensure
that CDBG program objectives were met was diminished.
Review of four CDBG Special Housing Program activities revealed that City
officials did not ensure that national objectives were obtained; costs charged were
necessary, reasonable, and adequately supported; and performance goals were
achieved. As a result, ineligible costs of $53,990 and unsupported costs of
$415,927 were incurred.
In addition, 38 CDBG activities administered by both the City and various
subrecipients, budgeted for funding during program years 2004-2007, had been
either not completed or not started due to a lack of controls. As a result,
performance goals were not achieved for various activities for which $408,282 in
CDBG funds had not been drawn from the line of credit. We attribute these three
deficiencies to City officials’ not implementing adequate administrative control
procedures to ensure compliance with CDBG program requirements.
What We Recommend
We recommend that the Director of HUD’s Buffalo Office of Community
Planning and Development instruct City officials to (1) repay from non-Federal
funds the $162,200 in ineligible float loan activity costs; (2) submit
documentation to justify the unsupported float loan costs of $744,995 and
unsupported Special Housing Program costs of $415,927, so that HUD can make
an eligibility determination, and repay any amounts determined to be ineligible;
(3) reallocate for other viable activities the $408,282 in unused CDBG funding
authority related to the 38 activities from program years 2004-2007 that had been
either not completed or not started or return the unused funds to the U.S.
Treasury; and (4) establish controls to ensure that costs are eligible and necessary
before being charged to the program, program activities meet a national objective,
and performance goals are accomplished.
For each recommendation in the body of the report 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 discussed the results of the review during the audit, provided a copy of the
draft report to City officials, and requested their comments on September 14,,
2011. We held an exit conference on September 28, 2011, and City officials
provided their written comments on October 4, 2011, at which time they
disagreed with some of the issues in the findings. The complete text of the
auditee’s response, along with our evaluation of that response, can be found in
appendix B of this report.
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TABLE OF CONTENTS
Background and Objectives 4
Results of Audit
Finding 1: Administrative Weaknesses Existed in the City’s Float Loan Program 5
Finding 2: City Officials Did Not Always Comply With HUD Regulations 12
When Disbursing CDBG Funds
Finding 3: Performance Goals for Certain CDBG Activities Were Not Always
Achieved 18
Scope and Methodology 23
Internal Controls 25
Appendixes
A. Schedule of Questioned Costs and Funds To Be Put to Better Use 27
B. Auditee Comments and OIG’s Evaluation 28
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BACKGROUND AND OBJECTIVES
The Community Development Block Grant (CDBG) program was established by Title I of the
Housing and Community Development Act of 1974, Public Law 93-383 as amended, 42 U.S.C.
(United States Code) 5301. The program provides grants to State and local governments to aid
in the development of viable urban communities. Governments are to use grant funds to provide
decent housing and suitable living environments and to expand economic opportunities,
principally for persons of low and moderate income. To be eligible for funding, every CDBG-
funded activity must meet one of the program’s three national objectives. Specifically, every
activity, except for program administration and planning, must
Benefit low- and moderate-income persons,
Aid in preventing or eliminating slums or blight, or
Address a need with a particular urgency because existing conditions pose a serious and
immediate threat to the health or welfare of the community.
The City of Syracuse, NY, is a CDBG entitlement grantee. The U.S. Department of Housing and
Urban Development (HUD) awarded the City more than $6 million in CDBG funding in fiscal
year 2008, more than $6.1 million in 2009, and more than $6.6 million in 2010. In addition, the
City received more than $1.6 million in funds under the American Recovery and Reinvestment
Act of 2009. These funds are available to support a variety of activities directed at improving the
physical condition of neighborhoods by providing housing rehabilitation and public
improvements and facilities, fostering economic development by providing technical and
financial assistance to local businesses and creating employment, or improving services for low-
or moderate-income households. The City operates under a mayor-council form of government,
and its CDBG activities are administered both in-house and by outside nonprofit organizations.
The City is responsible for overseeing, monitoring, and managing CDBG activities. The files
and records related to the City’s CDBG program are maintained in City Hall, Syracuse, NY.
The objectives of the audit were to determine whether the City administered its CDBG program
effectively, efficiently, and economically in accordance with applicable rules and regulations.
Specifically, we wanted to determine whether City officials had (1) established and implemented
the necessary controls to ensure that program activities were adequately documented and
administered in accordance with HUD regulations, and (2) expended CDBG funds for eligible
activities.
4
RESULTS OF AUDIT
Finding 1: Administrative Weaknesses Existed in the City’s Float Loan
Program
The City had administrative weaknesses in its float loan program. City officials could not
demonstrate that $907,195 in float loan funds used to finance 11 new housing construction
activities (1) were provided to qualified nonprofits; (2) were necessary, reasonable, and
adequately supported; and (3) met a national objective. Moreover, City officials did not
administer the City’s float loan program in accordance with program regulations. We attribute
these deficiencies to City officials’ general unfamiliarity with the float loan program requirements
and the failure to establish administrative control procedures to ensure compliance with CDBG
program requirements, including ensuring that costs were eligible and necessary before being
charged to the program. As a result, $162,200 in ineligible costs and $744,995 in unsupported costs
were incurred, and City officials’ ability to ensure that CDBG program objectives were met was
diminished.
Background
Regulations at 24 CFR (Code of Federal Regulation) 570.301(b) permit a grantee to
use undisbursed funds in the line of credit within its CDBG program account, which
are budgeted in statements or action plans for one or more activities that do not need
the funds immediately for unfunded activities. Such funds are referred to as the
“float,” and an activity that uses such funds is called a float-funded activity. The
float-funded activity must meet all of the requirements that apply to CDBG activities
and generally must be expected to produce program income in an amount at least
equal to the amount of the floated funds used and be repaid in 2.5 years.
The primary purpose of the City’s new construction float loan program is to use
CDBG funds secured by a letter of credit to provide area nonprofit organizations
with zero percent construction financing for new single-family homes. These homes
are then sold to an income-qualified buyer. The City administered 11 new
construction float loan activities during the 2006 and 2007 program years reviewed.
The weaknesses are discussed in detail below.
Inadequate Documentation
Regarding the Qualifications of
the Nonprofits Provided
Funding
Section 570.207(b)(3) of the CDBG regulations states that CDBG funds may not be
used for the construction of new permanent residential structures or for any program
5
to subsidize or assist new construction except when carried out by an eligible entity
pursuant to section 570.204(a) of the CDBG regulations. More specifically, the
entity must qualify as a community-based development organization (CBDO).
To qualify as a CBDO, the entity must, among other things, maintain at least 51
percent of its governing body’s membership for low- and moderate-income
residents, owners or senior officers of private establishments and other institutions
located in and serving its geographic area of operation, or representatives of low-
and moderate-income neighborhood organizations located in and servicing its
geographic area of operation.
Contrary to this requirement, City officials did not maintain adequate documentation
demonstrating that any of the three nonprofits provided CDBG funding for new
housing construction qualified as a CBDO. While the program files did include
some information as to the makeup of the board of directors, none of the files
contained specific information to confirm that the board members met the
requirements cited above. Moreover, in the City’s 2007 summary of consolidated
plan projects report to HUD, the City acknowledged that two of the three nonprofits
that received new housing construction funding were not qualified CBDOs.
Consequently, the City’s new housing construction program did not comply with the
CDBG regulations. Therefore, costs incurred were not supported, as there was a
lack of documentation to demonstrate that the new housing construction activities
were carried out by qualified CBDOs.
A total of $907,195 in Federal Funds was disbursed for the 11 float loan new
construction activities as follows:
Federal
Program year Activity name funds Notes
disbursed
2007 Property A Tennyson Ave. $ 75,000 Ineligible
2007 Property B Sedgwick Street 90,000
2007 Property C Palmer Ave. 93,087
2007 Property D Palmer Ave. 78,087
2007 Property E Palmer Ave. 93,087
2007 Property F Palmer Ave. 93,087
2006 Property G Howard Street 50,000
2006 Property H Coolidge Ave. 84,247
2006 Property I Coolidge Ave. 87,200 Ineligible
2006 Property J Coolidge Ave. 81,200
2006 Property K Coolidge Ave. 82,200
Total $ 907,195
Contrary to program requirements, because City officials did not maintain adequate
documentation demonstrating that any of the three organizations provided CDBG
funding for new housing construction qualified as a CBDO or maintain documents
6
to support that the costs incurred were reasonable and supported by financial
records, these costs were questionable. Further in two cases, in addition to the lack
of documented CBDO qualifications, the homeowners did not meet the income
requirements (income was too high); therefore, these two cases were ineligible. In
summary, of the $907,195 in questioned costs incurred, two cases totaling $162,200
($75,000 + $87,200) were considered to be ineligible, and the remaining nine cases
totaling $744,995 were considered to be unsupported.
Costs Not Necessary,
Reasonable, and Supported
City officials did not adequately monitor their new housing float loan program to
ensure that construction costs were necessary, reasonable, and adequately supported.
Specifically, in those instances in which the nonprofit chose a contractor to perform
the work, no evidence was provided to show the method used to select the
contractor, that the contractor selection was effective in promoting free and open
competition, or that adequate controls were in place to monitor the costs charged for
construction work for reasonableness. Additionally, in cases in which the nonprofit
chose to be the general contractor on the new construction project, the proposed
project costs were based on budgeted amounts, rather than documentation such as
contracts and invoices as required. Moreover, for one of the new housing
construction projects, the City was unable to provide the project files in support of
the new housing construction costs; therefore, the total costs for the project could not
be determined.
Apart from the above, for the 10 new construction float loan activities for which the
City was able to provide the project files, City officials did not provide evidence that
they performed any type of onsite monitoring of the construction work.
Additionally, there was no evidence that City officials obtained property appraisals
on the newly constructed homes to justify the reasonableness of the costs incurred.
This issue is particularly important since the average purchase price was $184,186,
and during this same period, the National Association of Realtors reported that the
median price of a home in Syracuse, NY, was $105,950. Consequently, the City’s
control over the reasonableness and propriety of the costs incurred under its new
housing construction float loan program were questionable.
Regulations at 24 CFR 570.506(h) provide details regarding the financial records
that are to be maintained by the City to support how CDBG funds are expended.
Such documentation must include, to the extent applicable, invoices, schedules
containing comparisons of budgeted amounts and actual expenditures, construction
progress schedules signed by appropriate parties, and other documentation
appropriate to the nature of the activity.
7
Inadequate Documentation To
Demonstrate That a CDBG
National Objective Was Met
City officials were unable to provide documentation showing that new construction
float loans met one of the three national objectives of benefiting low- and moderate-
income persons, aiding in preventing or eliminating slums or blight, or addressing a
need with particular urgency because existing conditions posed a serious and
immediate threat to the health or welfare of the community. All of the float loans
were listed in HUD’s Integrated Disbursement and Information System as low-mod
housing benefit, community development financial institution, or neighborhood
revitalization strategy area activities that are carried out for the purpose of providing
or improving permanent residential structures by a community development
financial institution or pursuant to a HUD-approved neighborhood revitalization
strategy.
However, examination of the project files showed that there was no documentation
to show that the new construction activities undertaken by the nonprofits were part
of a planned neighborhood revitalization project of sufficient size and scope to have
an impact on the decline of a designated geographic location within the City’s
jurisdiction. Regulations at 24 CFR 570.204(a)(1) require that to qualify as an
eligible activity, the new construction must be part of a neighborhood revitalization
project of sufficient size and scope to have an impact on the decline of a designated
geographic location within the jurisdiction of the City. To the contrary, inspection
of the newly constructed properties showed that the neighborhoods as a whole
consisted of many vacant and rundown properties, with no evidence that a
neighborhood revitalization had occurred (see photographs for newly constructed
and existing properties on Palmer Avenue). Inspection of the neighborhood
identified many vacant and boarded-up houses in the area.
8
Palmer Ave.
Newly constructed
property provided HUD
and other grant funds
$118,087
Palmer Ave.
Existing abandoned and
boarded-up property –
Example 1
Palmer Ave.
Existing abandoned and
boarded-up property –
Example 2
9
Palmer Ave.
Existing abandoned and
boarded-up property –
Example 3
There was a lack of evidence to support that the City’s activities met a national
objective, since new construction activities had to be of a sufficient scope to have
made an impact on revitalizing a geographic area within the City and this did not
appear to be the case.
Float Loan Program Not in
Compliance With HUD
Requirements
Regulations at 24 CFR 570.301(b) provide that a float-funded activity must meet all
the requirements that apply to CDBG activities and generally must be expected to
produce program income in an amount at least equal to the amount of the floated
funds used. Contrary to this requirement, City officials did not administer their new
housing float loan program in a manner that would provide for a return of program
income in an amount at least equal to the amount of the floated funds used. As
previously noted, the City’s new construction float loan program used CDBG funds
secured by a letter of credit to provide nonprofits with zero percent construction
financing for new single-family homes. The homes were then to be sold to an
income-qualified buyer. Upon the sale of the home, part of the loan repayment was
provided by the City in the form of a HOME Investment Partnerships Program or
CDBG grant to the homeowner, thus the nonprofit was required to repay only a
portion of the original amount loaned.
Moreover, the CDBG eligibility of the new housing activities carried out with float
loans was not adequately supported since City officials were unable to document
that the nonprofits that participated in the program qualified as CBDOs or that the
activity met a national objective of the CDBG program.
Further, the project files lacked adequate detail on how potential homeowners
qualified for or were selected for the program. There was no documentation
showing whether this program, which provided for the purchase of a new home at a
substantial discount, was advertised to the public at large or that the potential
10
homeowners were selected from a waiting list. Accordingly, City officials did not
comply with applicable regulations for float-funded activities as required.
Conclusion
Review of the City’s administration of its new home construction float loan
activities, revealed that adequate controls to ensure compliance with applicable
regulations for float-funded activities had not been established. Specifically, there
was inadequate evidence that the nonprofit companies provided funding qualified as
CBDOs; costs were necessary, reasonable and supported; and a CDBG national
objective was met. As a result, $162,200 in ineligible costs and $744,995 in
unsupported costs were incurred. We attribute these deficiencies to City officials’
general unfamiliarity with HUD’s regulations pertaining to float-funded activities
and inadequate controls to ensure compliance with program requirements.
Recommendations
We recommend that the Director of HUD’s Buffalo Office of Community Planning
and Development instruct City officials to
1A. Reimburse from non-Federal funds the ineligible costs incurred of $162,200,
of which $87,200 was paid from HOME program funds and $75,000 was paid
from CDBG funds.
1B. Submit documentation to demonstrate that its new housing construction
activities were carried out by qualified CBDOs and support the reasonableness
of the $744,995 in costs incurred so that HUD can make an eligibility
determination. For any costs determined to be ineligible, HUD should require
the City to reimburse the HOME program from non-Federal funds.
1C. Develop administrative control procedures to ensure compliance with CDBG
program requirements, including ensuring that costs are eligible and necessary
before being charged to the program.
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Finding 2: City Officials Did Not Always Comply With HUD
Regulations When Disbursing CDBG Funds
City officials did not always disburse CDBG funds in compliance with HUD requirements.
Review of the four CDBG Special Housing Program activities, funded through the City’s CDBG
and Technical Assistance Grant programs, revealed that the City did not always adequately
monitor and administer grant- and subgrant-supported activities to ensure the effective and
efficient use of HUD resources. Specifically, City officials did not ensure that national
objectives were attained; costs charged were necessary, reasonable, and adequately supported;
and performance goals were achieved. These deficiencies were due to the lack of emphasis and
insistence by management that procedures be in place to ensure that grant and subgrant activities
were continuously and thoroughly monitored for compliance and progress, fully supported by
adequate cost documentation, and performed and administered efficiently. As a result, ineligible
costs of $53,990 and unsupported costs of $415,927 were incurred.
Background
Three of the four activities reviewed were administered by nonprofits, and the
fourth was administered directly by the City. City officials were responsible for
implementing controls and monitoring procedures to ensure compliance with all
program requirements. However, there was a lack of documented monitoring by
City officials for all the activities reviewed. The detailed results of the review and
conclusions reached relating to each of the activities reviewed are contained in the
following sections.
Activity 1 - Tully Street
City officials disbursed $90,973, consisting of $80,973 in CDBG funds and
$10,000 in Technical Assistance Grant funds, to subsidize and bring in line with
the market value the total development costs of a newly constructed home on
Tully Street, Syracuse, NY, without ensuring that a national objective of the
CDBG program had been accomplished or that the costs incurred were reasonable
and adequately supported. Regulations at 24 CFR 570.200(a)(2) require that each
recipient ensure and maintain evidence that each of its activities assisted with
CDBG funds meets one of the three national objectives as contained in its
certification. Moreover, Office of Management and Budget (OMB) Circular A-
87, Attachment A, Section C.1.a provides that to be allowable under Federal
awards, costs must be necessary and reasonable for proper and efficient
performance and administration of Federal awards and be adequately
documented.
For program year 2009, City officials identified the national objective for this
activity in HUD’s Integrated Disbursement and Information System as the
12
prevention or elimination of slums and blight. It appeared that City officials may
have tied this activity to the national objective of slums and blight, rather than
low-mod benefit, because the record showed that the owners of the newly
constructed home had incomes that exceeded the low-mod limits established by
HUD; therefore, the activity would not have met the low-mod benefit national
objective. However, while the activity was listed as meeting the objective of slum
and blight, it was not until October 2009 that the nonprofit’s officials requested
that City officials provide write-down funding for the newly constructed home,
stating that they had demolished the previous structure located at the Tully Street
address in February 2009. Consequently, since the former structure was
demolished in February 2009, any slum and blight conditions would have been
addressed at that time. Moreover, in March 2011, inspection of the Tully Street
neighborhood found that the houses in that area generally appeared to be in good
condition, further supporting that this area did not show signs of slum or blight
conditions.
City officials also were not able to provide documentation for the $90,973 in
CDBG and Technical Assistance Grant funds used for this activity to show that
the costs were necessary and reasonable and supported by proper source
documents. For example, while the files contained a property cost summary
report that referenced a construction contract for $235,714, a 5 percent
contingency fee of $11,785, an additional nondescriptive 15 percent fee totaling
$37,305, and many other soft cost items, the files contained no detailed
documentation in support of the costs identified on the property cost summary.
Thus, City officials had not implemented adequate controls to ensure that each of
its CDBG-assisted activities met one of the three national objectives as contained
in its certification, nor had they implemented adequate controls to ensure that
costs incurred were necessary and reasonable for proper and efficient performance
and administration of Federal awards or that costs were adequately documented.
Therefore, the $90,973 in funds used for this activity was considered unsupported
pending an eligibility determination by HUD.
Activity 2 - East Kennedy Street
City officials disbursed $227,765, consisting of $44,500 in CDBG and $183,265
in Technical Assistance Grant funds, in the form of loans to subsidize the sale of a
two-family rental property by a nonprofit corporation without ensuring that the
costs incurred were necessary, reasonable, and adequately supported or that a
national objective of the CDBG program had been accomplished.
Regulations at 24 CFR 85.20(b)(2) provide that grantees and subgrantees must
maintain records which adequately identify the source and application of funds
provided for financially assisted activities. These records must contain
information pertaining to grant or subgrant awards and authorizations,
13
obligations, unobligated balances, assets, liabilities, outlays or expenditures, and
income. Also, 24 CFR 85.20(b)(6) provides that accounting records must be
supported by such source documentation as cancelled checks, paid bills, payrolls,
time and attendance records, contract and subgrant award documents, etc.
OMB Circular A-87, Attachment A, Section C.1.a provides that to be allowable
under Federal awards, costs must be necessary and reasonable for proper and
efficient performance and administration of Federal awards and costs must be
adequately documented. Moreover, OMB Circular A-122, Attachment B, Section
16 provides that costs of fines and penalties resulting from violations of or failure
of the organization to comply with Federal, State, and local laws and regulations
are unallowable.
Review of the files for the East Kennedy Street property revealed that $44,500 in
costs paid with CDBG funds was not related to the sale of the property. These
costs included back taxes and water bills for other properties owned by the
borrower. The costs also included a worker’s compensation judgment that was
owed by the purchaser to the State of New York that was incorporated into the
closing for the East Kennedy Street property and paid from the CDBG loan
proceeds. Since these costs were not related to the East Kennedy Street property,
they would not represent necessary or reasonable costs of the activity, and,
therefore, the $44,500 was considered ineligible.
Additional HUD funds of $183,265, consisting of $42,792 from 2001 and
$140,473 from 2004 Technical Assistance Grants, provided as subsidy for the sale
of the East Kennedy Street property and paid to the seller of the property, were
considered unsupported pending a HUD eligibility determination since City
officials were unable to provide adequate supporting documentation for the costs
incurred. Specifically, there was no support for many of the line items shown on
the HUD-1 settlement statement. For example, documentation was not provided
to support funding sources, including the funding agency and applicable grant
number, or for lines 205 SNI (Syracuse Neighborhood Initiative) and 207
developer’s fee.
In addition, City officials did not provide documentation showing that the national
objective of benefiting low- and moderate-income persons was met as required by
regulations at 24 CFR 570.200(a)(2) because they were unable to provide a rental
history for the property and income verification data for the occupants of the
property to show that the property had been rented to low-income residents after
the sale of the property.
In summary, for the East Kennedy Street activity, the $44,500 in CDBG funds
expended for costs that were not related to the property sold was considered
ineligible. In addition, the $183,265 in Technical Assistance Grants expended for
this activity that lacked proper source documents for the costs incurred and
14
documentation to show that a national objective had been met, was considered
unsupported pending a HUD eligibility determination.
Activity 3 - Cherry Street
City officials disbursed $64,543 in CDBG funds to subsidize the sale of three
rental properties from a local nonprofit entity to a private third-party investor
without ensuring that a national objective of the CDBG program had been
accomplished, costs incurred were adequately supported, and performance goals
for the activity had been achieved.
Specifically, City officials did not provide property appraisals to support that the
sales prices for the properties were reasonable, documentation verifying that the
purchaser of the three properties qualified as a low-mod income individual, or
property rental information for tenants that may have occupied the properties after
the sale to ensure that the tenants were low-mod income qualified to support
meeting a national objective. Therefore, the City did not adequately monitor the
activity to ensure that performance goals were achieved.
Regulations at 24 CFR 570.501(b) provide that the recipient is responsible for
ensuring that CDBG funds are used in accordance with all program requirements.
The use of designated public agencies, subrecipients, or contractors does not
relieve the recipient of this responsibility. The recipient is also responsible for
determining the adequacy of performance under subrecipient agreements and
procurement contracts.
Since City officials were unable to provide documentation to show that $64,543
in CDBG funds expended for the Cherry Street properties was necessary,
reasonable, and adequately supported or met a national objective, the costs
incurred for this activity were considered unsupported pending an eligibility
determination by HUD.
Activity 4 – Hartson-Rowland
A total of $86,636 in CDBG funds was used to pay for costs related to the cleanup
of the properties, repairing or replacing water heaters and furnaces, and purchase
of new washers and dryers to replace those that were damaged as a result of a
water main break located on or near the area of Hartson and Rowland Streets
without ensuring that the funds expended were eligible, necessary, reasonable,
and adequately supported. In addition, City officials were unable to provide
documentation showing that these activities met the listed national objectives of
slum or blight spot benefits and low-mod housing benefits.
15
Regulations at 24 CFR 570.200(a)(2) require that each recipient ensure and
maintain evidence that each of its activities assisted with CDBG funds meets one
of the three national objectives as contained in its certification. City officials
indicated that they treated this activity as an emergency addressing an urgent need
due to the damage caused by a water main break. However, a review of the files
provided for this activity did not show that the recipient certified that the activity
was designed to alleviate existing conditions, which posed a serious and
immediate threat to the health or welfare of the community. The documents in
the files also did not show that the event was of recent origin or had recently
become urgent or that the recipient was unable to finance the activity on its own
and that other sources of funding were not available as required by regulations at
24 CFR 570.208(c). Consequently, there was no assurance that the use of CDBG
funds represented necessary or reasonable costs to the program or that a national
objective of the program was attained.
Review of the disbursement documentation for the $86,636 charged to CDBG
activities relating to the water main break revealed that the costs included $9,490
for the purchase of new washers and dryers. However, according to regulations at
CFR 570.207(b)(1)(iii), the purchase of equipment, fixtures, motor vehicles,
furnishings, or other personal property not an integral structural fixture is
generally ineligible.
In summary, for the Hartson-Rowland activity, $9,490 was determined to be
ineligible, and the remaining $77,146 was considered to be unsupported costs for
which HUD will need to make an eligibility determination.
Conclusion
Review of the four CDBG Special Housing Program activities, funded through
the City’s CDBG and Technical Assistance Grant programs, revealed that the City
did not adequately monitor and administer grant- and subgrant-supported
activities to ensure the effective and efficient use of HUD resources. Specifically,
City officials did not ensure that national objectives were attained; costs charged
were necessary, reasonable, and adequately supported; and performance goals
were achieved. These deficiencies were due to the lack of adequate controls over
grant- and subgrant-supported activities. As a result, ineligible costs of $53,990
and unsupported costs of $415,927 were incurred.
16
Recommendations
We recommend that the Director of HUD’s Buffalo Office of Community
Planning and Development instruct City officials to
2A. Repay from non-Federal funds the ineligible costs incurred of $53,990
(44,500 related to the East Kennedy property and $9,490 related to the
Hartson-Rowland property).
2B. Submit documentation to justify the unsupported costs incurred of
$415,927 ($90,973 related to the Tully Street property, $183,265 related to
the East Kennedy Street property, $64,543 related to the Cherry Street
properties, and $77,146 related to the Hartson-Rowland Street properties)
so that HUD can make an eligibility determination. For any costs
determined to be ineligible, HUD should require the City to reimburse the
CDBG program from non-Federal funds.
2C. Establish controls to ensure that grant- and subgrant-supported activities
are adequately monitored and administered to provide assurance that funds
have been used only for eligible activities that meet a national objective,
costs incurred are necessary and reasonable, and performance goals are
achieved.
17
Finding 3: Performance Goals for Certain CDBG Activities Were Not
Always Achieved
As of February 1, 2011, the City had 38 CDBG activities, administered by both the City and
various subrecipients, budgeted for funding during program years 2004-2007 that had been either
not completed or not started. This condition existed because the City had not implemented
controls to ensure that (1) CDBG activity performance goals were achieved, (2) Federal awards
were administered effectively and efficiently, and (3) each of its activities assisted with CDBG
funds met one of the three national objectives as contained in its certification. As a result,
performance goals were not achieved for various activities for which $408,282 in CDBG funds
had not been drawn from the line of credit; therefore, these funds should be reallocated for other
activities that are viable or returned to the U.S. Treasury.
CDBG Performance Goals Not
Always Achieved
Review of the City’s grantee performance report, as contained in the Integrated
Disbursement and Information System as of February 1, 2011, revealed that
performance goals were not always achieved for CDBG activities.
As indicated in the following chart, the City had 38 budgeted CDBG activities for
program years 2004-2007, which were administered by both the City and various
subrecipients, that had been either not completed or not started as of February 1,
2011. For the 38 activities identified, $408,282 in funds had not been drawn from
the line of credit as follows:
City of Syracuse, NY - CDBG program open activities in fiscal year 2007
and earlier
Drawn
Program Integrated Disbursement and Funded thru Balance
year Information System activity amount 2/1/11 available
2601 - Parks and Recreation - Youth
2004 Pgms $50,031 $0 $50,031
2602 - Parks and Recreation - On
2004 Summer Pgm 25,047 8,400 16,647
0026 – Tomorrow’s Neighborhoods
2004 Today (TNT) Sector Escrows 16,000 5,198 10,802
2005 2803 - TNT Sector Escrows 16,000 10,216 5,784
2807 - Fair Housing Enforcement
2005 Activities 50,000 49,772 228
2811 - Housing Referral and Advocacy
2005 Pgm 8,848 6,286 2,562
2005 2812 - Project Summer Hope 25,000 24,264 736
18
Drawn
Program Integrated Disbursement and Funded thru Balance
year Information System activity amount 2/1/11 available
2816 - Parks and Recreation - Youth
2005 Pgm 50,031 0 50,031
2005 2818 - Parks & Rec - Plays On 25,047 24,750 297
2006 3092 - Arise-Home Access Program 40,000 39,901 99
3104 - Home Headquarters - SHARP
2006 Pgm 70,000 60,505 9,495
3105 - Home Headquarters - SHARP
2006 Pgm-PS 30,000 28,748 1,252
3117 - ARISE - Housing Referral and
2006 Advocacy 8,848 1,242 7,606
3125 - Dunbar Association - After
2006 School Pgm 15,000 12,500 2,500
3137 - Spanish Action League - Career
2006 Services 15,000 14,805 195
3138 - Spanish Action League -
2006 Housing Pgm 10,400 9,773 627
3144 - Latinos Unidos - Southwest
2006 Community Ctr 3,000 2,422 578
3182 - Parks and Recreation - Summer
2006 Evening Rec 20,000 0 20,000
3183 - Parks and Recreation - Expanded
2006 Rec Prgm 25,000 20,000 5,000
3184 - TNT Tomorrow’s
2006 Neighborhoods Today-ESCR 16,000 10,157 5,843
3228 - Planning and Contractual
2006 Services 50,000 3,926 46,074
2006 3318 - 700 Oswego Street-LALIGA 27,000 26,453 547
3319 - Foreclosure Intervention
2006 Program 90,000 64,840 25,160
3413 - Home Headquarters - Distressed 186,76
2007 Property Program 203,500 2 16,738
3422 - Code Enforcement - Relocation
2007 Expenses 10,000 0 10,000
3432 - Parks and Recreation - Expanded
2007 Pgm 25,000 20,000 5,000
3434 - Parks and Recreation – “Plays
2007 On” Pgm 20,000 12,000 8,000
3438 - Greater Love in Christ - Rehab
2007 Pgm 10,000 0 10,000
3456 - Salud - Latinos United Against
2007 Disparities 24,148 0 24,148
329,49
2007 3458 - Southwest Community Center 348,000 8 18,502
2007 3460 - Westcott Kids Club 19,500 16,291 3,209
3462 - YMCA - Residential
2007 Advisement Pgm 7,000 0 7,000
19
Drawn
Program Integrated Disbursement and Funded thru Balance
year Information System activity amount 2/1/11 available
2007 3464 - SWCC - Latinos Unidos 10,000 3,000 7,000
2006 3601 - Salina Street South 5617 16,430 0 16,430
2007 3728 - Empire Avenue 219 6,490 0 6,490
2007 3746 - TNT Sector Escrows 16,000 11,641 4,359
2007 3945 - Wadsworth Street 317 3,989 0 3,989
2007 3953 - Kimber Avenue 130 5,323 0 5,323
Total $408,282
Regulations at 24 CFR 570.208 provide the basis for determining whether an
activity meets a national objective, and activities that are not completed do not
meet a national objective. Further, a 2003 HUD guide book, entitled “Ensuring
Subrecipient Timeliness,” under the part labeled “Select Subrecipients and
Activities That Will Meet Timeliness Standards” provides that communities that
receive entitlement funds from the CDBG program are required to use their funds
in a timely manner.
Since the above activities had not been started or completed, the City did not meet
its performance goals and did not meet the national objectives of the activities.
Therefore, the $408,282 is questioned and should be reallocated to other eligible
activities or returned to the U.S. Treasury.
Effective Program
Administration
Based on the above activities that had not been completed or started for periods
ranging from 2004 to 2007, City officials did not appear to have effectively and
efficiently administered their CDBG funds. Regulations at 24 CFR 85.40(a)
require that grantees be responsible for managing the day-to-day operations of
grant- and subgrant-supported activities. Grantees must monitor grant- and
subgrant-supported activities to ensure compliance with applicable Federal
requirements and that performance goals are achieved. Grantee monitoring must
cover each program, function, or activity.
OMB Circular A-87, Attachment A, Section A.2.a provides that governmental
units are responsible for the efficient and effective administration of Federal
awards through the application of sound management practices.
City officials’ lack of monitoring of subgrantees led to the condition described
above. If proper monitoring had occurred, City officials could have effectively
administered these activities, ensuring that funds were expended and activities
were completed in a timely manner.
Apart from the above, City officials should consider a 2003 HUD guidance,
entitled “Ensuring CDBG Subrecipient Timeliness,” which recommends that if a
20
proposed activity cannot be completed or nearly completed in 1 year, the project
should be phased. An example of a project being phased is funding the design
and engineering the first year and construction the next year. The guidance also
provides that if funds are recaptured from a subrecipient, one option would be to
reallocate the funds to existing, faster moving projects that can absorb the funds
within the grant year or to projects with a shortfall of funds. Another option
would be to reallocate funds to entities on a waiting list of potential subrecipients
identified in the consolidated plan or elsewhere that did not receive awards
because demand for CDBG funds exceeded the supply.
Meeting National Objectives
Regulations at 24 CFR 570.200 (a)(2) require that each recipient under the
entitlement program ensure and maintain evidence that each of its activities
assisted with CDBG funds meets one of the three national objectives as contained
in its certification. Criteria for determining whether an activity addresses one or
more of these objectives are found in the regulations at 24 CFR 570.208. The
national objectives include benefiting low- and moderate-income persons,
addressing slums or blight, and meeting a particularly urgent community
development need because existing conditions pose a serious and immediate
threat to the health or welfare of the community. Therefore, as mentioned above,
because little or no activity had taken place for the listed activities for an extended
period, the national objectives were not accomplished. Thus, the undrawn funds
should be either reprogrammed or used for activities that are viable and meet one
of the national objectives or returned to the U.S. Treasury.
Conclusion
Since funding for the 38 CDBG activities identified above was available but had
not been drawn during the last 3½ to 6½ years, the City did not ensure that
program activities were accomplished in a timely manner, performance goals
were achieved, or a national objective was met for the undrawn budgeted amounts
as required by regulations at 24 CFR 570.208. Therefore, these funds should be
reallocated to other activities that are viable or returned to the U.S. Treasury.
This condition can be attributed to City officials’ lack of monitoring of
subgrantees to ensure that all program regulations were complied with.
21
Recommendations
We recommend that the Director of HUD’s Buffalo Office of Community
Planning and Development instruct City officials to
3A. Reallocate for other viable activities the $408,282 in unused CDBG
funding authority related to the 38 activities from program years 2004-
2007 that have been either not completed or not started or return the
unused funds to the U.S. Treasury.
3B. Implement controls to ensure that CDBG activity performance goals are
achieved, Federal awards are administered effectively and efficiently, and
each of its activities assisted with CDBG funds meets one of the three
national objectives as contained in its certification.
22
SCOPE AND METHODOLOGY
The onsite audit work for this review was conducted at the City’s offices, located in Syracuse, NY,
between January and July 2011. Our audit scope covered the period January 1, 2008, through
December 31, 2010, and was expanded as necessary. To accomplish the objectives, we
Reviewed applicable HUD regulations, the Code of Federal Regulations, and other
requirements and directives that govern the CDBG program.
Reviewed the City’s applicable policies and procedures used to administer CDBG activities.
Reviewed the City’s action plans, grant agreements, and agreements between the City and
its subrecipients and contractors, including verifying whether national objectives were met.
Interviewed City personnel responsible for administration of the City’s CDBG program.
Obtained and reviewed documentation from the City pertaining to CDBG activities
reviewed.
Reviewed HUD’s monitoring reports and files for the City’s CDBG program, including
verifying any reported corrective actions.
Reviewed independent public accountant audits and financial reporting, including analysis
of noted findings and control weaknesses applicable to City operations including the CDBG
program.
Reviewed all costs charged to the CDBG program activities tested during the audit, along
with the applicable supporting documentation provided.
Reviewed information systems data from HUD’s Integrated Disbusement and Information
System (IDIS) for background and information purposes. We performed a minimum level
of testing and found the the computer processed data to be adequate for our purposes.
During the audit, we reviewed various CDBG activities including float loans and grant- and
subgrant-supported Special Housing Program activities. We also analyzed the City’s progress in
completing planned activities to determine whether performance goals were accomplished in a
timely manner.
Specifically, for review of float loan activities, we selected a nonstatistical sample of 11 new
construction float loans, consisting of all of the float loans made in program years 2006 and
2007. The City had not budgeted any float loan activities since program year 2007. Therefore,
we reviewed 100 percent of the Federal funding totaling $907,195 for the 11 activities.
To review the grant- and subgrant-supported Special Housing Program activities, we selected a
nonstatistical sample of four activities budgeted for CDBG funding from program years 2005
23
through 2009. The total amount of CDBG funds budgeted from 2005 through 2009 for the
City’s Special Housing Program activities was $796,480. Of that amount, the sample of four
activities included CDBG costs of $236,652, or about 32 percent of all CDBG Special Housing
Program budgeted amounts for those program years. Other HUD funding sources were used to
supplement additional costs associated with the sample of four Special Housing Program
activities reviewed. Specifically, 2001, 2004, and 2005 Technical Assistance Grant funding of
$193,271 and additional CDBG funds of $40,000 budgeted for the 2006 Home HeadQuarters
Distressed Property Program activity were also disbursed in support of the four Special Housing
Program activities reviewed. The total amount of Technical Assistance Grant funding awarded
to the City for the related 2001, 2004, and 2005 grants amounted to more than $20 million, while
the 2006 HeadQuarters Distressed Property Program activity was budgeted for a total of
$203,500.
To analyze the progress of the City in completing planned activities to determine whether
performance goals were accomplished in a timely manner, we reviewed the City’s grantee
performance report as contained in the Integrated Disbursement and Information System as of
February 1, 2011, to determine whether performance goals had been achieved for CDBG
activities. We reviewed all CDBG activities contained in the grantee performance report for
program years 2007 and earlier to determine whether any of the activities had budgeted amounts
that had not been drawn down from the line of credit as of February 1, 2011. The review showed
that the City had 38 CDBG activities budgeted for funding from program years 2004-2007 that
had been either not completed or not started. For the 38 activities identified, administered by
both the City and various subrecipients, $408,282 had yet to be drawn from the line of credit.
We conducted the audit in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings and conclusions based on our audit
objectives. We believe that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.
24
INTERNAL CONTROLS
Internal control is a process adopted by those charged with governance and management,
designed to provide reasonable assurance about the achievement of the organization’s mission,
goals, and objectives with regard to
Effectiveness and efficiency of operations,
Reliability of financial reporting, and
Compliance with applicable laws and regulations.
Internal controls comprise the plans, policies, methods, and procedures used to meet the
organization’s mission, goals, and objectives. Internal controls include the processes and
procedures for planning, organizing, directing, and controlling program operations as well as the
systems for measuring, reporting, and monitoring program performance.
Relevant Internal Controls
We determined that the following internal controls were relevant to our audit
objectives:
Effectiveness and efficiency of operations - Policies and procedures that
management has implemented to reasonably ensure that a program meets its
objectives.
Reliability of financial data and reporting - Policies and procedures that
management has implemented to reasonably ensure that valid and reliable data
are obtained, maintained, and fairly disclosed in reports.
Compliance with applicable laws and regulations - Policies and procedures
that management has implemented to reasonably ensure that resource use is
consistent with laws and regulations.
We assessed the relevant controls identified above.
A deficiency in internal control exists when the design or operation of a control does
not allow management or employees, in the normal course of performing their
assigned functions, the reasonable opportunity to prevent, detect, or correct (1)
impairments to effectiveness or efficiency of operations, (2) misstatements in
financial or performance information, or (3) violations of laws and regulations on a
timely basis.
25
Significant Deficiencies
Based on our review, we believe that the following items are significant deficiencies:
City officials did not have adequate controls over effectiveness and
efficiency of operations when they did not ensure that 38 CDBG activities
budgeted for funding during program years 2004-2007 had been started or
completed as of February 1, 2011, and did not always ensure that CDBG-
funded activities achieved a national objective of the program (see
findings 1, 2, and 3).
City officials did not have adequate controls over reliability of financial data
and reporting when they did not adequately monitor grant and subgrant
activities or maintain sufficient documentation in support of costs charged
to CDBG activities (see findings 1 and 2).
City officials did not have adequate controls over compliance with laws and
regulations as they did not always comply with HUD regulations while
disbursing CDBG funds (see findings 1 and 2).
26
APPENDIXES
Appendix A
SCHEDULE OF QUESTIONED COSTS
AND FUNDS TO BE PUT TO BETTER USE
Recommendation Ineligible 1/ Unsupported Funds to be put
number 2/ to better use 3/
1A $162,200
1B $744,995
2A 53,990
2B 415,927
3A $408,282
Total $216,190 $1,160,922 $408,282
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 the 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. These amounts include reductions in outlays, deobligation of funds,
withdrawal of interest, costs not incurred by implementing recommended improvements,
avoidance of unnecessary expenditures noted in preaward reviews, and any other savings
that are specifically identified. In this instance, if City officials implement our
recommendation and reallocate the more than $400,000 in unused funds, they can assure
HUD that these funds will be put to better use.
27
Appendix B
Auditee Comments and OIG’s Evaluation
Ref to OIG Evaluation Auditee Comments
Comment 1
Comment 2
Comment 3
Comment 4
Comment 5
28
Ref to OIG Evaluation Auditee Comments
Comment 6
Comment 7
Comment 8
Comment 9
Comment 10
29
Ref to OIG Evaluation Auditee Comments
Comment 11
Comment 12
Comment 13
Comment 14
30
Comment 1 City officials indicate they will provide documentation that they subsequently
qualified two of the three entities as eligible CBDO’s to HUD as part of the audit
resolution process. However, HUD officials will need to make a determination if
the three entities were eligible to receive funding when the activities took place.
Comment 2 HUD officials will need to make a determination as to the eligibility of the costs
based on the documentation to be provided by City officials.
Comment 3 City officials indicate that since January 2010, they have implemented a risk
based approach to monitoring and that they would provide a schedule of the
planned monitoring to HUD. We believe additional controls need to be
implemented to ensure compliance with procurement requirements and that
effectively promote full and open competition.
Comment 4 City officials indicate that the reimbursements for new construction were and are
reviewed by a City inspector, and that a new form, which more explicitly
documents the City’s approval of the work done, will be used in the voucher
process. Nevertheless, we believe additional controls and monitoring are needed
to ensure that construction costs are necessary, reasonable and adequately
supported.
Comment 5 City officials indicate that appraisals were obtained for private and non-private
financing of new construction. Although the costs of new construction are higher
than the median sales price it is worth it because the new construction has
increased the value of the surrounding properties. However, City officials were
not able to provide appraisals for the properties provided funding and there was a
lack of documentation to support the reasonableness of the costs incurred.
Comment 6 City officials acknowledge the lack of documentation in its files regarding
revitalization activities and have instituted new procedures, which require the
requesting entity to provide detail plans for every property on the block for which
funds are requested. The proposed action is responsive to the finding and HUD
will have to determine the adequacy of corrective action as part of the audit
resolution process.
Comment 7 City officials contend that all float loan funds were repaid to the program and
reported as program income. Float loans are supposed to be repaid from the
activity that benefited from the float loan. However, these float loans were repaid
in part using HOME and CDBG funds, which is not in compliance with the
requirements for repayment of float loans.
Comment 8 City officials indicate that there was proof of the eligibility of each prospective
home owner, but that there was a lack of documentation that the information had
been confirmed by City officials. City officials indicated that additional controls
will be implemented to document that prospective participants’ income eligibility
is verified. The audit determined that the tenant files did not always contain proof
31
of tenant income eligibility and as a result $162,200 disbursed for two over
income purchasers was questioned. Furthermore, there was a lack of
documentation of whether the program was advertised to the public at large or
that the homeowners were selected from a waiting list. Therefore, HUD will have
to determine the adequacy of the proposed corrective actions as part of the audit
resolution process to ensure compliance with program requirements.
Comment 9 City officials indicated that the acquisition, demolition and subsequent new
construction of this property was the entire scope of the project, which eliminated
a blighted condition; therefore, the national objective of elimination of slums and
blight was achieved. City officials stated that they cited this neighborhood as the
most distressed of the City and Region in their Consolidated Plan, and they are
awaiting HUD’s approval to designate this area as a Neighborhood Revitalization
Strategy Area (NRSA). Thus the neighboring good conditions were the result of
ongoing revitalization funded by CDBG and Technical Assistance grants. While
the activity was listed as meeting the objective of slum and blight, it was not until
October 2009 that the nonprofit’s officials requested that City officials provide
write-down funding for the newly constructed home, stating that they had
demolished the previous structure located at the Tully Street address in February
2009. Consequently, since the former structure was demolished in February
2009, any slum and blight conditions would have been addressed at that time.
Moreover, in March 2011, inspection of the Tully Street neighborhood found that
the houses in that area generally appeared to be in good condition, further
supporting that this area did not show signs of slum or blighted conditions.
Therefore, we do not accept the City’s position that it views the acquisition,
demolition and subsequent new construction of the house at 521 Tully Street as
the entire scope of the project. Thus, the elimination of an abandoned property is
not an automatic precursor to constructing a new home. Furthermore, records
showed that the owners of the newly constructed home had incomes that exceeded
the low-mod income limits established by HUD and therefore would not have met
the low-mod benefit national objective. Thus, by failing to meet the low-mod
income requirements and not being slum and blight, we consider the new home
construction costs for this activity to be unsupported pending a HUD eligibility
determination.
Comment 10 City officials indicated that they would provide HUD additional information on
the costs associated with this activity and that they viewed contingency fees such
as the 15 percent non-descriptive costs as a sound business practice and an
allowable planning fee under the Technical Assistance program. However,
City officials were not able to provide documentation for the $90,973 in CDBG
and Technical Assistance Grant funds used for this activity to show that the costs
were necessary, reasonable, and supported by proper source documents. In
addition, although City officials believe that the non-descriptive 15 percent fee is
a good business practice, allowable under the Technical Assistance program, it
should be noted that the non-descriptive fee totaled $37,305, while the Technical
Assistance funds invested in this activity only totaled 10,000. As such, HUD
32
officials will have to make a determination as to the eligibility of the costs for this
activity as part of the audit resolution process.
Comment 11 City officials indicated they would provide HUD information on the funds used
for this property and income data for the current occupants of the property. The
City officials’ proposed actions are responsive to the finding.
Comment 12 City officials indicated appraisals of the properties were not done to avoid further
soft costs related to this transaction. Rather, the City based the reasonableness of
the purchase price on the City’s assessed valuation of the property as well as its
familiarity with sales prices in the Near East Side neighborhood. In addition, they
will provide HUD with up-to-date tenant data forms documenting the income of
the current occupants of each of the properties. However, since City officials did
not provide documentation to support the reasonableness of the costs, and the
income levels of the occupants of the property, HUD will have to determine the
eligibility and reasonableness of the costs as part of the audit resolution process.
Comment 13 City officials indicate that although they were unable to locate documentation that
the prior Mayor had declared this situation to be an emergency, they believe that
this activity was eligible because the property is in a revitalization neighborhood.
City officials also agreed that the costs for new appliances were not eligible; as
such, they indicated that they would work with HUD to resolve this issue as part
of the audit resolution process. Thus the actions of the City officials’ are
responsive to the finding.
Comment 14 City officials agreed with finding 3 and will request a formal reallocation of these
funds either through a substantial amendment to its Consolidated Plan or with its
submission of the 2012 Action Plan. The City officials’ actions are responsive to
the finding.
33
The City of Syracuse, NY, Did Not Always Administer Its CDBG Program in Accordance With HUD Requirements
Published by the Department of Housing and Urban Development, Office of Inspector General on 2011-10-25.
Below is a raw (and likely hideous) rendition of the original report. (PDF)