oversight

Final Audit Report - HUD's Office of Block Grant Assistance Had Not Codified the Community Development Block Grant Disaster Recovery Program

Published by the Department of Housing and Urban Development, Office of Inspector General on 2018-07-23.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

       Office of Block Grant Assistance,
               Washington, DC
        Community Development Block Grant Disaster
                   Recovery Program




Office of Audit, Region 6     Audit Report Number: 2018-FW-0002
Fort Worth, TX                                      July 23, 2018
To:            Jessie Handforth Kome, Acting Director, Office of Block Grant Assistance, DGB

From:          Kilah S. White, Regional Inspector General for Audit, 6AGA
Subject:       HUD’s Office of Block Grant Assistance Had Not Codified the Community
               Development Block Grant Disaster Recovery Program


Attached is the U.S. Department of Housing and Urban Development (HUD), Office of Inspector
General’s (OIG) final results of our review of whether the Office of Block Grant Assistance
should codify the Community Development Block Grant Disaster Recovery program.
HUD Handbook 2000.06, REV-4, sets specific timeframes for management decisions on
recommended corrective actions. For each recommendation without a management decision,
please respond and provide status reports in accordance with the HUD Handbook. Please furnish
us copies of any correspondence or directives issued because of the audit.
The Inspector General Act, Title 5 United States Code, section 8M, requires that OIG post its
publicly available reports on the OIG website. Accordingly, this report will be posted at
http://www.hudoig.gov.
If you have any questions or comments about this report, please do not hesitate to call me at
(817) 978-9309.
                    Audit Report Number: 2018-FW-0002
                    Date: July 23, 2018

                    HUD’s Office of Block Grant Assistance Had Not Codified the
                    Community Development Block Grant Disaster Recovery Program




Highlights

What We Audited and Why
As part of our annual risk and internal planning process, we audited the U.S. Department of
Housing and Urban Development (HUD), Office of Block Grant Assistance’s (OBGA)
Community Development Block Grant (CDBG) Disaster Recovery program. Our analysis noted
that Congress had historically provided disaster funding through supplemental appropriations,
yet OBGA had not created a formal codified program. Instead, it had issued multiple
requirements and waivers for each Disaster Recovery supplemental appropriation in Federal
Register notices, many of which were repeated from disaster to disaster. Our objective was to
determine whether OBGA should codify the CDBG Disaster Recovery funding as a program in
the Code of Federal Regulations.

What We Found
Although OBGA had managed billions in Disaster Recovery funds since 2002, it had not
codified the CDBG Disaster Recovery program. It had not codified the program because it
believed it did not have the authority under the Robert T. Stafford Disaster Relief and
Emergency Assistance Act, and it had not determined whether it had the authority under the
Housing and Community Development Act of 1974 as amended. It also believed a Presidential
Executive Order presented a barrier to codification, as it required the Office of Community and
Planning Development (CPD) to identify two rules to eliminate in order to create a new codified
rule. We believe OBGA has the authority under the Housing Act of 1974 and it should codify
the program. OBGA’s use of multiple Federal Register notices to operate the Disaster Recovery
program presented challenges to the grantees. For example, 59 grantees with 112 active Disaster
Recovery grants, which totaled more than $47.4 billion as of September 2017, had to follow
requirements contained in 61 different Federal Register notices to manage the program. Further,
codifying the CDBG Disaster Recovery program would (1) ensure that a permanent framework
is in place for future disasters, (2) reduce the existing volume of Federal Register notices, (3)
standardize the rules for all grantees, and (4) ensure that grants are closed in a timely manner.

What We Recommend
We recommend that the Acting Director of OBGA work with its Office of General Counsel to
codify the CDBG Disaster Recovery program.
Table of Contents
Background and Objective......................................................................................3

Results of Audit ........................................................................................................6
         Finding: OBGA Had Not Codified Its CDBG Disaster Recovery Program............... 6

Scope and Methodology .........................................................................................14

Internal Controls ....................................................................................................16
         A. Auditee Comments and OIG’s Evaluation ............................................................. 17

         B. Disaster Recovery Funding by State and Territory - 2001 Through 2016 .......... 21

         C. Active Disaster Recovery Grants as of September 19, 2017 ................................. 22

         D. HUD Federal Register Notices for Disaster Recovery Funding ........................... 25

         E. Analysis of Federal Register Notices for Common Rules and Waivers ............... 27

         F. HUD OIG CDBG Disaster Recovery Reports ........................................................ 29




                                                            2
Background and Objective
The U.S. Department of Housing and Urban Development’s (HUD) mission is to create strong,
sustainable, inclusive communities and quality, affordable homes for all. HUD’s Office of
Community Planning and Development (CPD) seeks to accomplish this mission through a wide
variety of housing and community development grants and loan programs. CPD’s Office of
Block Grant Assistance (OBGA) has responsibility for administering Community Development
Block Grant (CDBG) Disaster Recovery funding. As shown in figure 1, its funding and, thus, its
role had significantly expanded over time.
Figure 1: Congressional funding for the CDBG Disaster Recovery program

                  CDBG Disaster Recovery appropriations
                                                             (in millions)

                                                                                                $15,181
   $16,000

   $14,000

                                            $11,414
   $12,000

   $10,000
                                                                                                                          $7,400
    $8,000                                                         $6,408
                                                      $5,244
    $6,000

             $1,848                                          $3,000
    $4,000                   $2,783
                                                                                                                    $2,306

    $2,000       $700                                                        $0   $10 $400 $0
                                      $0 $146                                                             $0 $299

       $0



                                                 Hurricanes      Hurricane                  Hurricane         Lousiana    Hurricanes
                   9/11                                           Ike and                                                  Harvey,
                                                Katrina, Rita,                              Sandy and          flooding
                 terrorist                                        midwest                                                 Irma, and
                                                 and Wilma                                    other           and other
                  attacks                                          floods                                                   Maria
                                                                                              events            events




From 2001 to 2016, Congress provided supplemental appropriations totaling $48 billion to HUD
to help communities recover from disasters. In general, Congress required that the funds be used
for necessary expenses for activities authorized under Title I of the Housing and Community
Development Act of 1974 as amended, related to disaster relief, long-term recovery, restoration
of infrastructure and housing, and economic revitalization in the most impacted and distressed
areas resulting from a major disaster declared under the Robert T. Stafford Disaster Relief and



                                                                    3
Emergency Assistance Act. Congress required HUD to publish in the Federal Register any
waiver of any statute or regulation of Title I of the Housing Act of 1974. In addition to Federal
Register notices guidance, OBGA used the CDBG program as a framework for disaster recovery
because it was flexible and allowed grants to address a wide range of challenges.
Between March 2001 and January 2017, 1 OBGA used the supplemental appropriations to address
131 Presidential disaster declarations in 36 States and a territory covering 240 events, which
included hurricanes, tropical storms, floods, tornados, windstorms, snowstorms, landslides,
mudslides, wildfires, and a terrorist attack. As shown in figure 2, eight States received grants
that totaled more than 93 percent of the total Disaster Recovery funding. 2
Figure 2: Disaster Recovery funding by States and a territory from March 2001 through January 2017
                     2001-2017 Disaster Recovery funding awarded by
                            State and a territory (in millions)
                                    Florida         28 States and 1 territory funded >$400
                           Indiana       $431        $3,486
                                 $440
                    Iowa
                      $988

                 Texas
                  $4,018                                                         Louisiana
                                                                                   $16,501

              New Jersey
                 $4,205




                 Mississippi
                      $5,495                                             New York
                                                                           $12,419


According to OBGA’s Disaster Recovery Grants Reporting (DRGR) system, 3 the grantees with
active grants budgeted and spent their funds on a wide variety of Disaster Recovery activities as
shown in table 1.




1
    Figure 2 did not include amounts awarded for Hurricanes Harvey, Irma, and Maria as OBGA had not awarded
    those funds as of January 2017.
2
    See appendix B for a listing of all 36 States and a territory that received Disaster Recovery funds.
3
    CPD’s DRGR system is primarily used by grantees to access grant funds and report performance
    accomplishments for grant-funded activities. OBGA staff used the DRGR system to review grant-funded
    activities, prepare reports to Congress and other interested parties, and monitor program compliance. The
    DRGR system included all Disaster Recovery funds awarded and spent since 2001.



                                                       4
        Table 1: Activities funded by CDBG Disaster Recovery grants as of September 19, 2017
                                                                               Percentage of
                                                                                   grant
             Activity category
                                          Budgeted           Disbursed          disbursed
        Compensation                    $12,367,754,021    $12,309,391,139            99.53%
        Miscellaneous                     1,088,998,239         946,589,323           86.92%
        Economic development              2,525,934,513       2,172,582,884           86.01%
        Buyout                              871,947,608         712,820,227           81.75%
        Acquisition and disposition         722,555,981         561,554,616           77.72%
        Housing - rental                  3,572,808,216       2,780,877,160           77.83%
        Infrastructure                    5,447,610,327       4,265,032,948           78.29%
        Administration                    1,545,275,605       1,107,106,079           71.64%
        Planning                            692,151,456         477,645,011           69.01%
        Public facilities                 4,671,705,828       3,165,991,386           67.77%
        Housing - other                  10,721,682,262       7,083,330,578           66.07%
        Clearance and demolition            433,812,630         251,561,084           57.99%
        National disaster resiliency         46,574,236                    0           0.00%
                    Total                44,708,810,922     35,834,482,435            80.15%

Our objective was to determine whether OBGA should codify the CDBG Disaster Recovery
funding as a program in the Code of Federal Regulations.




                                                  5
Results of Audit

Finding: OBGA Had Not Codified Its CDBG Disaster Recovery
Program
Although OBGA had managed billions in Disaster Recovery funds since 2002, it had not
codified the CDBG Disaster Recovery program. OBGA had not codified the program because it
believed it did not have authority under the Stafford Act. Further, it stated that it had not
determined whether it had authority under the Housing Act of 1974 to create a codified Disaster
Recovery program. It also believed an Executive Order presented barriers to codification. 4 We
believe it has the authority under the Housing Act of 1974 and should exercise its authority to
codify the program. OBGA’s use of multiple Federal Register notices to operate the Disaster
Recovery program presented challenges to grantees. For example, 59 grantees with 112 active
Disaster Recovery grants, which totaled more than $47.4 billion as of September 2017, had to
follow requirements contained in 61 different Federal Register notices. Further, codifying the
CDBG Disaster Recovery program would (1) ensure that a permanent framework is in place for
future disasters, (2) reduce the existing volume of Federal Register notices, (3) standardize the
rules for all grantees, and (4) ensure that grants are closed in a timely manner.

OBGA Managed Billions in Disaster Recovery Grant Funds but Had Not Codified the
Program
From 2001 through 2016, OBGA awarded 138 Disaster Recovery program grants totaling almost
$48 billion to various States, counties, parishes, cities, a territory, and a corporation. As of
September 2017, the grantees had 112 active grants 5 open, or 81 percent, which totaled more than
$47.4 billion. These grantees had not spent almost $11.6 billion, or almost 25 percent, of the
amount awarded, as shown in table 2. 6




4
    Presidential Executive Order on Reducing Regulation and Controlling Regulatory Costs, January 30, 2017
5
    See appendix C for active grants, which had unspent funds and were open in DRGR as of September 19, 2017.
6
    Table 1’s total budgeted was less than the total amount awarded in table 2 as grantees had not budgeted or
    disbursed funds for four grants as of September 19, 2017.



                                                       6
Table 2: Active CDBG Disaster Recovery grants as of September 19, 2017
                                  No. of
                                            Year(s)       No. of                               Unspent
                                  public
           Disaster event                   funded        grants    Grant amount               amount
                                  law(s)
 Terrorist attacks of September
 11, 2001                           4      2001-2002            3   $ 3,483,000,000          $ 364,710,339
 Hurricanes Katrina, Rita, and
 Wilma                              2      2005-2007            6    19,319,892,908             560,248,936
 Severe storms, tornados, and
 flooding                           1         2008              6       278,416,318              14,911,943
 Hurricanes Ike, Gustav, and
 Dolly. Severe storms and
 flooding                           1         2008             13     6,004,684,356             874,151,229
 Severe storms and flooding         1         2010              7        98,718,642              12,214,659
 Hurricane Irene, severe storms,
 tornados, and flooding             1         2011             17       400,000,000             180,124,560
 Hurricanes Irene, Isaac, and
 Sandy. Severe storms and
 flooding                           1      2011-2013           47    15,180,999,750           7,070,958,622
 Hurricanes Joaquin and Patricia.
 Severe storms, tornados, and
 flooding                           1         2015              6       248,304,000             227,938,695
 Hurricanes Hermine and
 Matthew. Severe storms,
 tornados, and flooding             3         2016              7     2,356,672,000           2,323,669,386
 Total                              15                       112     47,370,687,974          11,628,928,369

Although OBGA had not codified the program, it continued to play a major role in providing
Disaster Recovery assistance. On September 8, 2017, and February 9, 2018, Congress allocated
HUD an additional $35.4 billion to provide additional disaster relief. 7 Based on the number of
recent disasters, OBGA will be responsible for managing Disaster Recovery grants for years to
come. Establishing a permanent standardized set of rules could help improve program
effectiveness and assist in managing the grants by providing a permanent structure for the
Disaster Recovery program.

OBGA Had Not Fully Addressed Its Ability to Codify the Program
OBGA stated that it did not have statutory authority to codify a Disaster Recovery program as
each disaster supplemental appropriation was unique and the Stafford Act did not grant HUD the
authority to create regulations. Further, OBGA stated that it had not determined whether it had
authority under the Housing Act of 1974 to create a codified Disaster Recovery program. OBGA
also stated that it would have to follow an Executive Order 8 on reducing regulation and
controlling regulatory costs before it could issue new codified rules for a Disaster Recovery
program. According to OBGA, the Executive Order required it to identify two existing
regulations it would repeal before issuing a single new rule.



7
    Supplemental Appropriations for Disaster Relief Requirements Act, 2017, and the Bipartisan Budget Act of 2018
8
    See footnote 4.



                                                       7
Although the Stafford Act does not specifically grant HUD authority to issue regulations under
the Stafford Act, HUD does have the ability to establish policy and issue regulations relating to
the disaster programs that work in conjunction with the Stafford Act. In addition, the public laws
required that the disaster funds be used for activities under Title I of the Housing Act of 1974,
and HUD has statutory authority to issue regulations under the Housing Act of 1974. The public
laws also allowed HUD to issue waivers or alternative requirements to disaster grantees when it
believed the requirements were not consistent with the Housing Act of 1974. Thus, we believe
that OBGA has the regulatory authority to codify the Disaster Recovery program under the
Housing Act of 1974 and it should create specific Disaster Recovery regulations. In addition, if
OBGA codified the program, it could reduce the number of existing Federal Register notices it
uses to operate the program.
In addition, other agencies had codified their Disaster Recovery programs. Two agencies that
received Hurricane Sandy funding, 9 the Federal Emergency Management Agency (FEMA) and
the Small Business Administration (SBA), had codified their disaster recovery programs. Under
the Stafford Act, Congress specifically granted FEMA authority to issue regulations and
implement the Stafford Act. Although FEMA is authorized to issue regulations under the
Stafford Act, SBA used its own programmatic authority to codify its program.

OBGA’s Use of Federal Register Notices Presented Challenges to the Grantees
OBGA’s use of multiple Federal Register notices to administer the Disaster Recovery funding
presented challenges to the grantees. Grantees

     •   Had to refer to an increasing number of Federal Register notices to operate their
         programs.
     •   Had to refer to notices that contained repetitive or similar requirements.
     •   Had to navigate what could be confusing requirements, which varied depending on the
         type of grantee they were.
     •   Continued to have issues with common weaknesses, including procurement requirements.
     •   Could close their grants in a more timely manner.

OBGA Issued Many Federal Register Notices To Operate the Disaster Recovery Program
OBGA created and issued 63 Federal Register notices to address the funding Congress provided
in 16 public laws from 2001 to 2016. As shown in table 3, OBGA’s Federal Register notices
were voluminous and increased in number and size over time, and most remained in effect in
2017. In addition, OBGA’s Federal Register notices for disasters do not expire or close until all
associated grants are closed. As of September 2017, its 112 active grants had 61 open Federal
Register notices. 10 Further, OBGA issued an additional three Federal Register notices during our




9
     For a listing of agencies and Sandy funding, see Audit Report 2016-FW-1007, Disaster Relief Appropriations
     Act, 2013: Financial Status, Observations, and Concerns, issued September 12, 2016.
10
     Two Federal Register notices covering the 2003-2004 multiple disasters had closed because all grants issued
     from the appropriation (Public Law 108-324) were complete. See appendix C for a listing of all active grants.



                                                          8
audit, and it will continue to issue additional Federal Registers notices for funding provided in
the 2017 and 2018 Acts. 11

Table 3: Federal Register notices covering Disaster Recovery funding from January 2002 to February 2017
                                                                           No. of Federal
                                                                                              No. of
                                                                          Register notices
                                Disaster event(s)                                             pages
                                                                               issued
 Terrorist attacks of September 11, 2001                                             8          22
 Multiple disasters 2003-2004 12                                                     2          11
 Hurricanes Katrina, Rita, and Wilma                                                19         104
 Severe storms, tornados, and flooding                                               2          16
 Hurricanes Ike, Gustav, and Dolly; severe storms; and flooding                      3          26
 Severe storms and flooding                                                          2          20
 Hurricane Irene, severe storms, tornados, and flooding                              2          21
 Hurricanes Irene, Isaac, and Sandy; severe storms; and flooding                    21         125
 Hurricanes Joaquin and Patricia, severe storms, tornados, and flooding              1          24
 Hurricanes Hermine and Matthew, severe storms, tornados, and flooding               2          27
 All disasters - duplication of benefits (issued in 2011)                            1           7
                                     Total                                          63         403

OBGA’s Federal Register Notices Included 59 Core Requirements and Waivers That Could
Be Codified
OBGA’s 63 Federal Register notices contained more than 100 Disaster Recovery requirements
and waivers, and our analyses showed that OBGA included at least 59 duplicative or similar
items in most of the notices. 13 Codifying these 59 core requirements could reduce the number of
current Federal Register notices by eliminating repetitive rules and waivers that applied to all
disasters. For example, OBGA consistently repeated the following rules or waivers:

     •   allowing States to directly administer grants and carry out eligible activities,
     •   requiring grantees to submit an action plan,
     •   requiring grantees to review for duplication of benefits,
     •   allowing States to use subrecipients, and
     •   allowing the acquisition of real property and flood buyouts. 14

If OBGA codified the core requirements, grantees would have a permanent framework in place,
which would allow them to rapidly respond to a major disaster, including allowing them to create
their action plan. Codifying requirements for action plans may allow grantees to provide disaster
recovery assistance more quickly. For example, the State of Texas stated that it had drafted an
action plan for its pending Hurricane Harvey allocation based on previous Federal Register
notices. However, Texas was waiting to submit its action plan to OBGA for approval because



11
     See footnote 7.
12
     See footnote 10.
13
     See appendix E for our analyses of the rules in common among the 63 Federal Register notices.
14
     See appendix D, numbers 7, 11, 14, 20, and 48.



                                                         9
OBGA had not issued a Federal Register notice for the 2017 Act’s Disaster Recovery funds.
Texas stated that OBGA should standardize and codify the Disaster Recovery requirements.
OBGA’s Use of Many Federal Register Notices Could Be Confusing to Grantees
OBGA’s use of multiple Federal Register notices for a specific disaster could confuse grantees.
Generally, the Federal Register notices had to be taken in their entirety as early notices continued
to apply even after later notices were issued. As shown in the notice excerpt below, Hurricane
Sandy grantees had to refer to many prior Federal Register notices to administer their grants
when this notice was issued. 15
     This notice [82 FR 9753] modifies the waiver and alternative requirement initially
     published in the Federal Register notice on July 11, 2014 (79 FR 40133), and later
     modified in the Federal Register notice published on April 2, 2015 (80 FR 17772).
     All waivers and alternative requirements for Hurricane Sandy grantees in receipt of
     allocations under the Appropriations Act, are described within the Federal Register
     notices published by the Department on March 5, 2013 (78 FR 14329), April 19,
     2013 (78 FR 23578), August 2, 2013 (78 FR 46999), November 18, 2013 (78 FR
     69104), March 27, 2014 (79 FR 17173), July 11, 2014 (79 FR 40133), October 16,
     2014 (79 FR 62182), April 2, 2015 (80 FR 17772), and May 11, 2015 (80 FR 26942),
     August 25, 2015 (80 FR 51589), November 18, 2015 (80 FR 72102), February 12,
     2016 (81 FR 7567), and August 15, 2016 (81 FR 54114) (referred to collectively in
     this notice as the ‘‘prior notices’’). The requirements of the prior notices continue to
     apply, except as modified by this notice. 16
Also, OBGA could not provide a document showing which sections of the various Federal
Register notices it had revised or eliminated in later notices for Sandy grantees. Some Federal
Register notices had requirements that had been revised by one or more later notices, and in one
case, a revision was revised again by an even later notice. Thus, grantees had to refer to all
applicable Federal Register notices in their entirety and determine for themselves what rules
applied.
Further, grantees that received funding from multiple public laws for different disaster events
had to follow all Federal Register notices related to each disaster. For example, as of
February 2017,

     •   Louisiana had 7 open grants and had to follow 45 Federal Register notices to
         administer its grants, and
     •   Texas had 6 open grants and had to follow 48 Federal Register notices to administer
         its grants.



15
     Grantees for the Disaster Relief Appropriation Act, 2013, had to follow 21 Federal Register notices specific to
     the Act and 1 general Federal Register notice that addressed duplication of benefits.
16
     February 8, 2017, 82 FR 9753, Additional Clarifying Guidance, Waivers, and Alternative Requirements for
     Grantees in Receipt of Community Development Block Grant (CDBG) Disaster Recovery Grant Funds Under
     the Disaster Relief Appropriations Act, 2013



                                                           10
In another example of confusing requirements, OBGA issued a Federal Register notice related to
Hurricane Sandy funding; however, the notice also applied to a previous disaster funded under a
different public law (112-55), which had its own separate Federal Register notices. OBGA
posted this notice on its website as applying to Hurricane Sandy and did not post it as applying to
the multiple disasters in 2011. Thus, 2011 grantees affected by this notice may not have known
that it applied when searching HUD’s web pages for guidance.
Grantees also had to reference and follow different sections of the Federal Register notices
depending what type of grantee they were – State or entitlement. State CDBG grantees were
allowed to use maximum feasible deference, to create their own program definitions, and to
follow their own procurement rules. Entitlement grantees did not have maximum feasible
deference, had CDBG programmatic definitions, and were required to follow Federal
procurement rules. 17 Further, States did not normally directly administer their regular State
CDBG program funds but were allowed to directly administer the Disaster Recovery funds.
In addition, OBGA often issued the Disaster Recovery program Federal Register notices on an
expedited basis. The expedited basis limited the time for review and comments and occasionally
resulted in technical errors. If OBGA codified the Disaster Recovery program, it could improve
the effectiveness of the program by reducing the number and volume of Federal Register notices,
which would reduce the number of items that needed to go through the departmental clearance
process.
Office of Inspector General’s (OIG) Reports Identified Common Weaknesses in the Disaster
Recovery Program
Based on our many audits and evaluations of the Disaster Recovery program, we believe that
codification of the core program requirements and standardization of procurement rules could
improve the program’s operations and could potentially address common weaknesses, such as
procurement and monitoring. As of September 30, 2017, OIG had completed 111 audit and 7
evaluation reports relating to CDBG Disaster Recovery funding from 2002 to 2017. 18 Those
reports included 130 findings, which identified $1.4 billion in questioned costs and $5.5 billion
in funds to be put to better use. 19




17
     Entitlement grantees were previously required to follow the procurements rules at 24 CFR (Code of Federal
     Regulations) 85.36(b), which have now been incorporated into 2 CFR 200.318 to 200.326.
18
     See appendix F for a listing of OIG’s reports concerning OBGA’s CDBG Disaster Recovery funding.
19
     The total of funds to put to better use in appendix F represents future cost savings or the avoidance of
     unnecessary expenditures if the specific audit recommendations in those reports are implemented.



                                                         11
Table 4: Common findings and weaknesses identified in OIG’s Disaster Recovery reports
                                                                                                          Reported
                            Common grantee or subrecipient weaknesses                                     instances
     Incurred ineligible or unsupported costs. Costs identified as (1) overpayments, (2)
     underpayments, or (3) duplicate payments.                                                               40
     Did not follow procurement requirements.                                                                28
     Could not support the eligibility of applicant or grant awards.                                         23
     Program guidelines, procedures, policies, or internal controls (1) need improvement or (2) were
     not followed.                                                                                           20
     Monitoring or reviews (1) were not adequately documented, (2) were not performed, (3) needed
     improvement, or (4) lacked procedures.                                                                  19
     Duplication of benefits existed with (1) insurance proceeds, (2) SBA loans or grants, or (3) other
     funding sources.                                                                                        13
     Program files and documents lacked adequate support to ensure that (1) grant activities were
     eligible or completed or (2) program goals and outcomes were accomplished.                              13
     Program administration, accounting, or management information system controls were not
     followed or need improvement.                                                                           11
     Did not follow agency, State, local, or Federal Register requirements or subrecipient agreements
     and did not meet performance benchmarks.                                                                10
     Did not comply or was not familiar with Federal cost principles or administrative requirements.          9
     Action plan requirements and amendments were not followed, had missing provisions, or needed
     improvements.                                                                                           9

Our reports found that procurement issues presented significant challenges to Disaster
Recovery program grantees, as shown in table 5. 20 Problem areas occurred due to (1) different
procurement requirements applied depending on the type of grantee (State or entitlement
entity), (2) questions over whether a State’s procurement processes were equivalent to Federal
procurement requirements, and (3) a State’s inexperience in directly administering Disaster
Recovery program funds and procuring program administrators and contractors.

 Table 5: Common procurement issues in OIG’s reports
                                                                                                          Reported
                                          Procurement issue                                               instances
 No cost or price analysis was performed. Contract costs were not reasonable or best value was
 not obtained. A lack of competitive procedures existed or full and open competition was not
 performed. Evaluations process was not followed. Contract did not meet request for proposal
 requirements.                                                                                               20
 Federal and agency procurement requirements were not followed or implemented.                               15
 Unsupported payments were made, contract work was performed outside the scope or before
 the executed contract date, unbudgeted costs were paid, billing was not tied to deliverables,
 billings were missing deliverables, or excessive fees were paid.                                            13
 Grantees or subrecipients were unfamiliar with Federal requirements.                                         6
 Contracts included ineligible cost-plus-a-percentage-of-cost method or other ineligible payment
 types or provisions.                                                                                         4
 Services were procured without executed subrecipient agreements or contracts.                                3



20
       For detailed information on procurement issues, see Audit Report 2016-PH-0005, HUD Did Not Always
       Provide Accurate and Supported Certifications of State Disaster Grantee Procurement Processes, issued
       September 29, 2016.



                                                             12
A grantee stated that its greatest concern was that the potential subrecipients did not know or
were not familiar with procurement requirements. 21 It noted that procurement training was
needed before funds were awarded and procurements were made. We believe that OBGA
could improve the effectiveness of the program by consolidating and standardizing the
procurement requirements. It would help grantees and subrecipients become familiar with
requirements before contracts were awarded.
Codification Could Ensure That Grants Are Closed in a More Timely Manner
Since Congress did not set deadlines for the funding used for 65 of the 112 grants, OBGA did
not establish obligation and expenditure deadlines for these grants. Although OBGA stated that
Disaster Recovery grants should largely be completed within 6 years, 7 grants totaling more than
$12.2 million were more than 7 years old, and 28 of them totaling more than $1.8 billion were
more than 9 years old. 22 OBGA must continue to monitor these aging grants until they close, and
there is a risk that later activities may not meet the original intended goals of the program.
Since Congress established obligation and expenditure deadlines for the remaining 47 grants
funded by the Disaster Relief Appropriations Act, 2013, 23 OBGA included 2-year grantee
expenditure deadlines in these grants. However, some grantees received extensions, which have
allowed these grants to remain open until September 30, 2022. As of September 2017, 46
percent of the Hurricane Sandy funding had not been spent. However, all of the funds must be
spent by September 30, 2022, 9 years after Congress allocated the funds. If OBGA codified and
set obligation and expenditure deadlines, it could ensure that all Disaster Recovery activities
would be completed and closed out in a more timely manner, including those that do not have
statutory deadlines, and reduce the amount of open grants that OBGA would have to monitor.

Conclusion
OBGA could improve the Disaster Recovery program, with grants totaling $47.4 billion, by
issuing a codified rule. If it codified the requirements, OBGA would be able to (1) ensure that a
permanent framework is in place for future disasters; (2) reduce the number and volume of
existing and future Federal Register notices that grantees have to follow; (3) issue standardized
rules, including rules for procurement, for all grantees; and (4) set expenditure deadlines, which
would ensure that grants would be closed in a timely manner.
Recommendations
We recommend that the Acting Director of OBGA

         1A.      Work with HUD’s Office of General Counsel to create a codified Disaster
                  Recovery program.




21
     2 CFR Part 200.318 to 200.326
22
     See appendix C for a complete aging list of all active grants.
23
     Section 904(c) of the Act required grantees to spend the funds within 24 months of obligation unless there was a
     waiver.



                                                          13
Scope and Methodology
Our audit scope covered the period September 2001 through September 2017. We expanded the
scope to include background information on Disaster Recovery funding from 1993 to 2001. We
performed our audit from May through December 2017 at HUD OBGA’s offices in Washington,
DC, and our offices located in Fort Worth and San Antonio, TX.
To accomplish our objective, we obtained and reviewed
   •   The 16 public laws related to HUD’s disaster supplemental appropriations from 2001 to
       2016.
   •   The Robert T. Stafford Disaster Relief and Emergency Assistance Act and the Housing
       and Community Development Acts of 1974 as amended.
   •   HUD’s 63 Disaster Recovery Federal Register notices issued from January 2002 to
       January 2017, which awarded the funding to the grantees and provided applicable rules,
       waivers, and alternative requirements. We summarized the requirements and identified
       common rules among the disasters.
   •   The CDBG State and entitlement programs’ regulations.
   •   All presidentially declared disasters funded by HUD’s disaster supplemental
       appropriations. The Federal Register notices identified 131 FEMA disaster declarations.
       We obtained 131 FEMA disaster declarations from the FEMA website. We analyzed the
       disaster declarations and summarized the data by State and disaster event.
   •   HUD’s additional 29 separate grantee resources and 8 Disaster Recovery toolkits that
       provide grantees with guidance and information related to the CDBG Disaster Recovery
       program.
   •   HUD’s Disaster Recovery program website information to identify and verify the funding
       history of the disaster recovery program from 1993 to 2017.
   •   OIG’s 118 audit and evaluation reports issued from May 2002 to September 2017
       concerning the CDBG Disaster Recovery program. We summarized the funds reviewed,
       findings, and questioned costs. We also identified the common weaknesses related to the
       CDBG Disaster Recovery program.
In addition, we obtained access to HUD’s DRGR system. We downloaded financial reports for
138 Disaster Recovery grants awarded from 2001 to 2016. The downloaded data included all
funding transactions from when the first grant was awarded in 2001 to the date of report
generation, which was September 19, 2017. We summarized the data by grantee, State, grant
number, current grant status, grant amount, and funds spent for all active and inactive grants.
We analyzed the data to identify the unspent amounts and the age of the grants for all 112 active
grants. We conducted data validation and reliability testing of the DRGR system data by
matching all the 138 grant amounts to the Federal Register notices’ award amounts and to related
OIG reports. We concluded that the computer-processed data obtained from the DRGR system
were sufficiently reliable to meet our audit objective.




                                                14
We also interviewed various HUD employees, including staff from CPD, OBGA, the Office of
the Chief Financial Officer, and the Office of General Counsel. In addition, we obtained a legal
opinion from our Office of Legal Counsel regarding HUD’s authority to codify a disaster
program under the Stafford Act or the Housing and Community Development Act of 1974 as
amended.
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
objective(s). We believe that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objective.




                                                15
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 objective:

•   Public laws and Federal Register notices that contain the rules for grantees in carrying out the
    Disaster Recovery program.

•   Additional HUD policies and guidance for Disaster Recovery grantees.
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.
Significant Deficiency
Based on our review, we believe that the following item is a significant deficiency:
•    OBGA had not established permanent codified rules for the CDBG Disaster Recovery
    program. It used requirements contained in many Federal Register notices to operate the
    Disaster Recovery program, which presented challenges to the grantees.




                                                  16
Appendix A
             Auditee Comments and OIG’s Evaluation




Ref to OIG    Auditee Comments
Evaluation
                                             U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
                                                                  WASHINGTON, DC 20410-7000



              OFFICE OF COMMUNITY PLANNING
              AND DEVELOPMENT


               MEMORANDUM FOR:               Kilah S. White, Regional Inspector General for Audit, 6AGA
               FROM:


               SUBJECT:                      Comments on May 17, 2018, Draft Report regarding Codification
                                             of the Community Development Block Grant Disaster Recovery
                                             Requirements
                           Thank you for the opportunity to provide comments on the subject draft report. As the
                report notes, Congress has provided Community Development Block Grant disaster recovery
                (CDBG-DR) funding under supplemental appropriations since 1992, and the Department issues
                Federal Register Notices modifying the underlying CDBG program requirements (when
                determined necessary) by applying tailored regulatory and statutory waivers and alternative
                requirements. The Department has not amended the CDBG regulations to include requirements
                governing supplemental appropriations, and this is what your report recommends be done now.
                Further, the report states the Office of Inspector General (OIG) believes HUD has the authority
Comment 1       to issue regulations despite the lack of statutory authorization for CDBG-DR.
                           In making this recommendation, the report cites the intended purposes of ensuring a
                permanent framework is in place for future events, reducing the volume of Federal Register
                Notices, standardizing the rules for all grantees, and ensuring that grants are closed timely.
                HUD has two major concerns with the draft report.

Comment 1                  First, HUD issues regulations to guide programs. CDBG-DR is not a program; it is
                groups of grants made under a series of constantly changing appropriations statutes and
                explicitly supplements the CDBG program (which has regulations). If HUD has responded to
                this decade's barrage of supplemental funding by developing some waivers that are deployed
                with some consistency across two or more appropriations, this is because the waivers respond to
                issues or areas not adjusted by Congress in those statutes. HUD is allowed consistency to the
                extent that Congress creates consistency. Generally, such consistency is provided by Congress
                enacting authorizing legislation for a program, such as the Housing and Community
                Development Act of 1974 and through amendments to that law.
                        Second, HUD does not understand how this can be a Finding as defined in AMS
Comment 2       Handbook Appendix I:
                      Audit Finding. A written explanation of: errors, weaknesses in internal controls,
                      deficiencies, adverse conditions, noncompliance with contractual, statutory, regulatory, or
                      other legal requirements, or the need for improvements or changes which are disclosed by
                      the audit. An audit Finding usually includes a comparison of "what is" (criteria) with
                      "what should be" (criteria) and an answer to the question "what does this mean?" or "so
                      what?"
                                               www.hud.gov              espanol.hud.gov




                                             17
Ref to OIG    Auditee Comments
Evaluation
                                                                                                                2



                   (adverse effect). In addition, an audit finding usually identifies and explains the reasons
Comment 2          why (cause) there is a difference between "what is" and "what should be." The Finding will
                   be the basis for conclusions and recommendations for corrective action.
                         In this case, the audit appears to have examined whether HUD had issued regulations and
Comment 2    concluded that HUD should issue regulations. The criteria are not laid out, and specific adverse
             effects cited are administrative and not linked to material issues, compliance related or operational.
             In other words, this audit recommendation is solidly in the realm of HUD's management discretion.
             Most of the issues cited can be resolved with more technical assistance for grantees. At this time,
             during the largest CDBG-DR grants launch to date, HUD program officials have the management
             and policy discretion to determine where and on what to apply limited program expert and legal
             resource - to the launch of $35 billion in grants or to drafting regulations for future appropriations
             that may never occur.
                         After conferring with CDBG-DR program attorneys regarding this audit, a legal
Comment 1    impediment, long present, was further defined. Although HUD could choose to issue regulations to
             implement any one appropriation, because the appropriations statutes state that any HUD waivers
             and alternative requirements for that appropriation must be published for five days before becoming
             effective, no pre-existing regulation relying on such waivers and applying such requirements can
             exist. Another way of looking at this is that HUD may not publish regulations for effect that rely on
             statutory waiver and alternative requirements authority HUD has not been permanently granted.
                        Overall, HUD does appreciate the OIG's observation that the current process of constantly
Comment 3    changing appropriations requirements echoed by changing waivers and alternative requirements can
             be unwieldy. After decades of HUD, the OIG, and the grantee community learning how to
             administer and implement CDBG-DR recoveries, the time may now demand a more standard,
             regulation-governed program, but that decision is up to Congress, not HUD.




                                           18
                                OIG Evaluation of Auditee Comments

Comment 1        HUD stated that it lacked statutory authority to create a CDBG Disaster Recovery
                 program because the funds are provided under a series of constantly changing
                 appropriation statutes, and it cannot publish regulations for effect that rely on
                 statutory waivers and alternative requirements as it has not been permanently
                 granted authority to do so.

                 We believe HUD has the statutory authority to create a Disaster Recovery
                 program under Title I of the Housing and Community Development Act of 1974
                 as amended. Although HUD raised the issue of the potential lack of statutory
                 authority at our entrance conference, it noted at the exit conference that it had not
                 obtained a formal legal opinion concerning the issue from its Office of General
                 Counsel. Although it did not provide a legal opinion, HUD did state that it
                 conferred with CDBG-DR program attorneys its response.

                 Over the years, the various Disaster Recovery statutes have contained core
                 requirements which provided the funding for necessary expenses related to
                 disaster relief, long-term recovery, restoration of infrastructure and housing, and
                 economic revitalization in the most impacted and distressed areas resulting from a
                 major disaster declared pursuant to the Robert T. Stafford Disaster Relief and
                 Emergency Assistance Act. Although we agree that there will occasionally be
                 some unique requirements that will require waivers to be published in Federal
                 Register notices, HUD has issued repeated alternative requirements that could be
                 codified under its existing statutory authority, which would (1) ensure that a
                 permanent framework is in place for future disasters, (2) reduce the existing
                 volume of Federal Register notices, (3) standardize the rules for all grantees, and
                 (4) ensure that grants are closed in a timely manner.

Comment 2        HUD stated that it did not understand how this could be a finding as defined by
                 HUD’s Audit Management System (AMS) Handbook Appendix I. 24

                 We contend that the AMS Handbook describes the type of finding that we
                 developed in this report. The AMS Handbook definition of a finding refers to,
                 among other things, a written explanation of the need for improvements or
                 changes which are disclosed by the audit. As a result of the audit, we concluded
                 that HUD could improve its Disaster Recovery efforts by codifying basic
                 requirements.

Comment 3        HUD said it appreciated OIG’s observation that the current process can be
                 unwieldy. It further stated that time may now demand a more standard,


24
     HUD Office of the Chief Financial Officer’s Handbook 2000.06, Rev-4, issued October 2011. The Handbook
     contains an appendix 1, Glossary of Terms, and not an appendix I.



                                                      19
regulation-governed program, but it stated the decision is up to Congress and not
HUD.

We acknowledge HUD’s comments. We maintain that HUD has authority to
create codified regulations for the CDBG Disaster Recovery program. However,
we encourage it to work with Congress, if it believes it lacks statutory authority,
as it has an obligation to ensure the Disaster Recovery program is operated in an
effective and efficient manner.




                                  20
Appendix B
      Disaster Recovery Funding by State and Territory - 2001 Through 2016
               Count   State or territory        Disaster grant(s) amount
               1.      Louisiana                          $ 16,500,852,389
               2.      New York                             12,418,771,963
               3.      Mississippi                           5,495,224,462
               4.      New Jersey                            4,205,027,506
               5.      Texas                                 4,017,647,960
               6.      Iowa                                    987,756,643
               7.      Indiana                                 439,559,497
               8.      Florida                                 430,199,586
               9.      Illinois                                399,658,438
               10.     Colorado                                320,935,651
               11.     Tennessee                               292,734,885
               12.     Missouri                                287,743,696
               13.     Alabama                                 281,872,963
               14.     South Carolina                          221,969,000
               15.     Connecticut                             213,556,359
               16.     North Carolina                          203,114,996
               17.     North Dakota                            195,331,418
               18.     Oklahoma                                147,693,876
               19.     Wisconsin                               139,584,277
               20.     California                              135,375,287
               21.     Virginia                                125,786,572
               22.     West Virginia                           109,440,001
               23.     Pennsylvania                             99,122,991
               24.     Arkansas                                 94,855,600
               25.     Massachusetts                            46,162,880
               26.     Vermont                                  39,592,211
               27.     Puerto Rico                              37,847,867
               28.     Rhode Island                             32,911,001
               29.     Maryland                                 30,702,131
               30.     Kentucky                                 13,000,000
               31.     Nebraska                                  5,557,736
               32.     Georgia                                   5,210,779
               33.     Maine                                     2,187,114
               34.     South Dakota                              1,987,271
               35.     Ohio                                      1,392,319
               36.     Minnesota                                   925,926
               37.     Montana                                     666,666
                       Total funding                        47,981,959,917




                                            21
Appendix C
                   Active Disaster Recovery Grants as of September 19, 2017
                                                                       Grant
                                                                                   Grant         Unexpended
                 Grantee                 Grant no.                     age in
 No.                                                         Awarded              amount           amount
                                                                       years
       Empire State Development
1.     Corporation (New York State)   B-01-DW-36-0001         2001      16      $ 700,000,000    $     9,075,627
       Empire State Development       B-02-DW-36-0001
2.     Corporation (New York State)                           2002      15       2,000,000,000       174,640,611
       Empire State Development       B-02-DW-36-0002
3.     Corporation (New York State)                           2002      15         783,000,000       180,994,101
4.     Louisiana                      B-06-DG-22-0001         2006      11       6,210,000,000        96,343,301
5.     Louisiana                      B-06-DG-22-0002         2006      11       4,200,000,000       177,877,672
6.     Mississippi                    B-06-DG-28-0001         2006      11       5,058,185,000       215,169,028
7.     Mississippi                    B-06-DG-28-0002         2006      11         423,036,059         2,858,792
8.     Texas                          B-06-DG-48-0002         2006      11         428,671,849            36,573
9.     Illinois                       B-08-DF-17-0001         2008      9           17,341,434           798,089
10.    Indiana                        B-08-DF-18-0001         2008      9           67,012,966        11,153,531
11.    Iowa                           B-08-DF-19-0001         2008      9          156,690,815         2,887,383
12.    Mississippi                    B-08-DF-28-0001         2008      9            2,281,287            21,804
13.    Missouri                       B-08-DF-29-0001         2008      9           11,032,438                 -
14.    Wisconsin                      B-08-DF-55-0001         2008      9           24,057,378            51,136
15.    Louisiana                      B-08-DG-22-0003         2008      9        3,000,000,000        67,963,570
16.    Arkansas                       B-08-DI-05-0001         2008      9           90,475,898         7,945,927
17.    California                     B-08-DI-06-0001         2008      9           54,531,784        14,520,968
18.    Georgia                        B-08-DI-13-0001         2008      9            5,210,779           214,668
19.    Illinois                       B-08-DI-17-0001         2008      9          193,700,004        18,703,496
20.    Indiana                        B-08-DI-18-0001         2008      9          372,546,531        30,365,229
21.    Iowa                           B-08-DI-19-0001         2008      9          734,178,651        27,530,066
22.    Louisiana                      B-08-DI-22-0001         2008      9        1,093,212,571       200,476,907
23.    Mississippi                    B-08-DI-28-0001         2008      9           11,722,116         1,159,070
24.    Missouri                       B-08-DI-29-0001         2008      9           97,605,490        12,316,437
25.    Tennessee                      B-08-DI-47-0001         2008      9           92,517,890         2,139,817
26.    Texas                          B-08-DI-48-0001         2008      9        3,113,472,856       546,740,407
27.    Wisconsin                      B-08-DI-55-0001         2008      9          115,526,899         1,574,673
28.    Puerto Rico                    B-08-DI-72-0001         2008      9           29,982,887        10,463,564
29.    Kentucky                       B-10-DF-21-0001         2010      7           13,000,000                 -
30.    Rhode Island                   B-10-DF-44-0001         2010      7            8,935,237         1,530,495
31.    Tennessee                      B-10-DF-47-0001         2010      7           30,906,517         1,059,158
32.    Warwick, RI                    B-10-MF-44-0002         2010      7            2,787,697         1,765,860
33.    Memphis, TN                    B-10-MF-47-0001         2010      7            6,264,239         2,562,257
34.    Nashville-Davidson, TN         B-10-MF-47-0002         2010      7           33,089,813         5,296,889
35.    Shelby County, TN              B-10-UF-47-0001         2010      7            3,735,139                 -
36.    Alabama                        B-12-DT-01-0001         2012      5           24,697,966           828,783
37.    Missouri                       B-12-DT-29-0001         2012      5            8,719,059         1,331,277
38.    New Jersey                     B-12-DT-34-0001         2012      5           15,598,506         2,741,452
39.    New York                       B-12-DT-36-0001         2012      5           71,654,116        67,631,816
40.    North Dakota                   B-12-DT-38-0001         2012      5           11,782,684            60,707
41.    Pennsylvania                   B-12-DT-42-0001         2012      5           27,142,501        19,822,280
42.    Texas                          B-12-DT-48-0001         2012      5           31,319,686        12,439,217
43.    Vermont                        B-12-DT-50-0001         2012      5           21,660,211         1,861,080
44.    Birmingham, AL                 B-12-MT-01-0001         2012      5            6,386,326         2,748,827
45.    Tuscaloosa, AL                 B-12-MT-01-0002         2012      5           16,634,702         9,178,701
46.    Joplin, MO                     B-12-MT-29-0001         2012      5           45,266,709        21,646,887




                                                        22
                                                                Grant
                                                                           Grant         Unexpended
                Grantee           Grant no.                     age in
No.                                                   Awarded             amount           amount
                                                                years
47.   Town of Union, NY        B-12-MT-36-0001         2012       5         10,137,818       4,312,104
48.   Minot, ND                B-12-MT-38-0001         2012       5         67,575,964       8,947,917
49.   Jefferson County, AL     B-12-UT-01-0001         2012       5          7,847,084       6,059,288
50.   Orange County, NY        B-12-UT-36-0001         2012       5         11,422,029      11,390,705
51.   Dauphin County, PA       B-12-UT-42-0001         2012       5          6,415,833       2,103,268
52.   Luzerne County, PA       B-12-UT-42-0002         2012       5         15,738,806       7,020,251
53.   Alabama                  B-13-DS-01-0001         2013       4         49,157,000       7,433,735
54.   California               B-13-DS-06-0001         2013       4         70,359,459      70,026,919
55.   Colorado                 B-13-DS-08-0001         2013       4        320,346,000     176,020,036
56.   Connecticut              B-13-DS-09-0001         2013       4        159,279,000      66,547,407
57.   Connecticut              B-13-DS-09-0002         2013       4         54,277,359      54,005,844
58.   Illinois                 B-13-DS-17-0001         2013       4         10,400,000       2,960,085
59.   Iowa                     B-13-DS-19-0001         2013       4         96,887,177      92,337,674
60.   Louisiana                B-13-DS-22-0001         2013       4         64,379,084      31,644,963
61.   Louisiana                B-13-DS-22-0002         2013       4         92,629,249      90,901,434
62.   Maryland                 B-13-DS-24-0001         2013       4         28,640,000       8,356,371
63.   Massachusetts            B-13-DS-25-0001         2013       4          7,210,000       1,244,704
64.   Missouri                 B-13-DS-29-0001         2013       4         11,844,000       5,590,511
65.   New Jersey               B-13-DS-34-0001         2013       4      4,174,429,000   1,622,397,295
66.   New Jersey               B-13-DS-34-0002         2013       4         15,000,000      14,954,800
67.   New York                 B-13-DS-36-0001         2013       4      4,416,882,000   1,598,736,590
68.   New York                 B-13-DS-36-0002         2013       4         35,800,000      35,726,062
69.   North Dakota             B-13-DS-38-0001         2013       4          6,576,000         227,490
70.   Oklahoma                 B-13-DS-40-0001         2013       4         93,700,000      24,700,872
71.   Pennsylvania             B-13-DS-42-0001         2013       4         29,986,000      29,259,992
72.   Rhode Island             B-13-DS-44-0001         2013       4         19,911,000       7,682,685
73.   Tennessee                B-13-DS-47-0001         2013       4         13,810,000       6,900,023
74.   Tennessee                B-13-DS-47-0002         2013       4         44,502,374      44,113,715
75.   Texas                    B-13-DS-48-0001         2013       4          5,061,000          27,623
76.   Vermont                  B-13-DS-50-0001         2013       4         17,932,000       2,126,107
77.   Virginia                 B-13-DS-51-0001         2013       4        120,549,000     120,319,147
78.   Birmingham, AL           B-13-MS-01-0001         2013       4         17,497,000      10,521,824
79.   Tuscaloosa, AL           B-13-MS-01-0002         2013       4         43,932,000       9,089,212
80.   Chicago, IL              B-13-MS-17-0001         2013       4         63,075,000      19,166,773
81.   New Orleans, LA          B-13-MS-22-0001         2013       4         15,031,000       8,159,001
82.   New Orleans, LA          B-13-MS-22-0002         2013       4        141,260,569     140,905,377
83.   Springfield, MA          B-13-MS-25-0001         2013       4         21,896,000      11,627,580
84.   Springfield, MA          B-13-MS-25-0002         2013       4         17,056,880      16,664,945
85.   Joplin, MO               B-13-MS-29-0001         2013       4        113,276,000      63,501,400
86.   New York City, NY        B-13-MS-36-0001         2013       4      4,213,876,000   2,237,549,660
87.   New York City, NY        B-13-MS-36-0002         2013       4        176,000,000     174,750,030
88.   Minot, ND                B-13-MS-38-0001         2013       4         35,056,000       1,504,236
89.   Minot, ND                B-13-MS-38-0002         2013       4         74,340,770      69,907,327
90.   Moore, OK                B-13-MS-40-0001         2013       4         52,200,000      27,681,394
91.   Jefferson County, AL     B-13-US-01-0001         2013       4          9,142,000       4,500,416
92.   Cook County, IL          B-13-US-17-0001         2013       4         83,616,000      64,535,466
93.   DuPage County, IL        B-13-US-17-0002         2013       4         31,526,000      14,693,958
94.   Jefferson Parish, LA     B-13-US-22-0001         2013       4         16,453,000      13,522,291
95.   St. Tammany Parish, LA   B-13-US-22-0002         2013       4         10,914,916       6,909,176
96.   Dauphin County, PA       B-13-US-42-0001         2013       4          7,632,000       1,736,996
97.   Luzerne County, PA       B-13-US-42-0002         2013       4          9,763,000          15,437
98.   Shelby County, TN        B-13-US-47-0001         2013       4          7,463,750           (250)
99.   Shelby County, TN        B-13-US-47-0002         2013       4         60,445,163      59,774,289




                                                 23
                                                              Grant
                                                                          Grant         Unexpended
                 Grantee           Grant no.                  age in
No.                                                 Awarded              amount           amount
                                                              years
100.   South Carolina           B-16-DH-45-0001      2016       1          96,827,000       78,232,209
101.   Texas                    B-16-DH-48-0001      2016       1          50,696,000       50,573,874
102.   Florida                  B-16-DL-12-0001      2016       1          58,602,000       58,602,000
103.   Louisiana                B-16-DL-22-0001      2016       1       1,656,972,000    1,624,292,793
104.   North Carolina           B-16-DL-37-0001      2016       1         198,553,000      198,553,000
105.   South Carolina           B-16-DL-45-0001      2016       1          65,305,000       65,103,719
106.   Texas                    B-16-DL-48-0001      2016       1         222,264,000      222,264,000
107.   West Virginia            B-16-DL-54-0001      2016       1         104,280,000      104,280,000
108.   Columbia, SC             B-16-MH-45-0001      2016       1          19,989,000       19,902,765
109.   Houston, TX              B-16-MH-48-0001      2016       1          66,560,000       66,390,731
110.   San Marcos, TX           B-16-MH-48-0002      2016       1          25,080,000       24,238,764
111.   Lexington County, SC     B-16-UH-45-0001      2016       1          16,332,000       15,982,430
112.   Richland County, SC      B-16-UH-45-0002      2016       1          23,516,000       23,191,796
                              Total                                    47,370,687,974   11,628,928,369




                                               24
Appendix D
                    HUD Federal Register Notices for Disaster Recovery Funding
                              Disaster event(s)                            Federal Register            Date
                                                                            67 FR 4164             1/28/2002
                                                                            67 FR 5845             2/7/2002
                                                                            67 FR 12042            3/18/2002
                                                                            67 FR 36017            5/22/2002
 Terrorist attacks of September 11, 2001
                                                                            68 FR 26640            5/16/2003
                                                                            68 FR 19211            4/12/2004
                                                                            76 FR 52340            8/22/2011
                                                                            82 FR 4911             1/27/2017
                                                                            69 FR 72100            12/10/2004
 Multiple disasters 2003-2004 25
                                                                            70 FR 21437            4/26/2005
                                                                            71 FR 7666             2/13/2006
                                                                            71 FR 34451            6/14/2006
                                                                            71 FR 34457            6/14/2006
                                                                            71 FR 34448            6/14/2006
                                                                            71 FR 43622            8/1/2006
                                                                            71 FR 51678            8/30/2006
                                                                            71 FR 62372            8/24/2006
                                                                            71 FR 63337            10/30/2006
                                                                            72 FR 10020            3/6/2007
 Hurricanes Katrina, Rita, and Wilma                                        72 FR 10014            3/6/2007
                                                                            72 FR 48808            8/24/2007
                                                                            72 FR 48804            8/27/2007
                                                                            72 FR 61788            10/31/2007
                                                                            72 FR 70472            12/11/2007
                                                                            73 FR 46312            8/8/2008
                                                                            73 FR 58612            10/7/2008
                                                                            73 FR 61148            10/15/2008
                                                                            73 FR 75733            12/12/2008
                                                                            74 FR 56206            10/30/2009
                                                                            73 FR 52870            9/11/2008
 Severe storms, tornados, and flooding
                                                                            73 FR 77818            12/19/2008
                                                                            74 FR 7244             2/13/2009
 Hurricanes Ike, Gustav, and Dolly; severe storms; and flooding             74 FR 41146            8/14/2009
                                                                            75 FR 65368            10/22/2010
                                                                            75 FR 69087            11/10/2010
 Severe storms and flooding
                                                                            75 FR 20998            4/14/2011
                                                                            77 FR 22583            4/16/2012
 Hurricane Irene, severe storms, tornados, and flooding
                                                                            77 FR 60708            10/7/2012
                                                                            78 FR 14329            3/5/2013
                                                                            78 FR 23578            4/19/2013
                                                                            78 FR 32262            5/29/2013
 Hurricanes Irene, Isaac, and Sandy; severe storms; and flooding            78 FR 45551            7/29/2013
                                                                            78 FR 46999            8/2/2013
                                                                            78 FR 52560            8/23/2013
                                                                            78 FR 69104            11/18/2013



25
     All grants issued for the multiple disasters in 2003 and 2004 were complete and these two associated Federal
     Register notices were closed.



                                                               25
                              Disaster event(s)                          Federal Register       Date
                                                                         78 FR 76154        12/16/2013
                                                                         79 FR 17173        3/27/2014
                                                                         79 FR 31964        6/3/2014
                                                                         79 FR 40133        7/11/2014
                                                                         79 FR 60490        10/7/2014
                                                                         79 FR 62182        10/16/2014
                                                                         80 FR 1039         1/8/2015
                                                                         80 FR 17772        4/2/2015
                                                                         80 FR 26942        5/11/2015
                                                                         80 FR 51589        8/25/2015
                                                                         80 FR 72102        11/18/2015
                                                                         81 FR 7567         2/12/2016
                                                                         81 FR 54114        8/15/2016
                                                                         82 FR 9753         2/8/2017
Hurricanes Joaquin and Patricia, severe storms, tornados, and flooding   81 FR 39687        6/17/2016
                                                                         81 FR 83254        11/21/2016
Hurricanes Hermine and Matthew, severe storms, tornados, and flooding
                                                                         82 FR 5591         1/18/2017
All disasters - duplication of benefits                                  76-FR 71060        11/16/2011
                                     Total                                         63




                                                              26
     Appendix E
                    Analysis of Federal Register Notices for Common Rules and Waivers
                                                             Common rule in Federal Register notices by year(s) the disaster occurred
                                                                          2005-                                   2011-
No.             Common rule description
                                                           2001   2004    2007     2008   2008    2010    2011    2013     2015   2016   Total
      Title 1 of the Community Development Act of
1.    1974 and 24 CFR (Code of Federal
      Regulations) Part 570 applied                                X        X       X       X       X      X        X       X       X        9
2.    Applicability of State CDBG requirements              X      X                                X      X        X       X                6
3.    Necessary and reasonable cost principles              X      X        X       X       X       X      X        X       X       X       10
      Waiver of the requirement that 70 percent of
      the CDBG funds received by the State over a
4.
      1- to 3-year period be for activities that benefit
      persons of low and moderate income                    X      X        X       X       X       X      X        X       X       X       10
      Low- to moderate-income area benefit national
5.    objective waiver and alternative requirement
      (certain localities and targeted areas)                               X                              X        X                        3
      Use of the “upper quartile”’ or “exception
      criteria” for low- and moderate-income area
6.
      benefit activities - not applicable to all
      grantees                                                                                             X        X       X       X        4
      Direct grant administration and means to carry
7.
      out eligible activities (States)                             X        X       X       X       X      X        X       X       X        9
8.    Consolidated plan waiver                              X      X        X       X       X       X      X        X       X       X       10
9.    Citizen participation waiver and requirements         X      X        X       X       X       X      X        X       X       X       10
      Modify requirement for consultation with local
10.
      governments                                           X               X       X       X       X      X        X       X       X        9
      Action plan waiver of additional elements and
11.
      alternative requirements                              X      X        X       X       X       X      X        X       X       X       10
12.   Allow reimbursement for preagreement costs            X               X       X       X       X      X        X       X       X        9
      Environmental requirements and release of
13.
      funds                                                 X               X       X       X       X      X        X       X       X        9
14.   Duplication of benefits                               X      X        X       X       X       X      X        X       X       X       10
      Waiver and alternative requirement for
15.   distribution to CDBG metropolitan cities and
      urban counties                                        X      X        X       X       X       X      X        X       X       X       10
16.   Program income alternative requirement                X      X        X       X       X       X      X        X       X       X       10
      Note that use of grant funds must relate to the
17.   covered disaster(s) (eligible activities and use
      of funds)                                             X      X        X       X       X       X               X                        7
      Grant administration responsibilities; planning
18.
      and administration cost limitations and caps          X      X        X               X       X      X        X       X       X        9
      Waiver of grantee performance reports and
19.   grantee reporting requirements in the DRGR
      system                                                X      X        X       X       X       X      X        X       X       X       10
20.   Use of subrecipients (States)                         X               X       X       X       X      X        X       X                8
21.   Recordkeeping                                         X               X       X       X       X      X        X       X       X        9
22.   Change of use of real property                        X      X        X       X       X       X      X        X       X       X       10
      Responsibility for State review and handling
23.
      of noncompliance                                      X      X        X       X       X       X      X        X       X       X       10
24.   Information collection approval note                         X        X       X       X       X      X        X                        7
      Certifications waivers and alternative
25.
      requirement (States and Indian tribes)                       X        X       X       X       X      X        X       X       X        9
26.   Housing-related eligibility waivers                          X        X       X       X       X      X        X       X       X        9
      Waiver and modification of the antipirating
27.   clause to permit assistance to help a business
      return                                                X      X        X       X       X                                                5
      Waiver and modification of the job relocation
28.   clause to permit assistance to help a business
      return                                                                                X       X      X        X       X       X        6




                                                                          27
                                                         Common rule in Federal Register notices by year(s) the disaster occurred
                                                                      2005-                                   2011-
No.            Common rule description
                                                       2001   2004    2007     2008   2008    2010    2011    2013     2015   2016   Total
      General planning activities (planning only
29.
      activities for State grantees)                                    X               X       X      X        X       X       X        7
      National objective documentation for
30.   economic development and revitalization
      activities                                                        X               X       X      X        X       X       X        7
      Waiver and alternative requirements and
      documentation for public benefit for certain
31.
      economic development activities (bridge
      loans, etc.)                                      X               X               X       X      X        X       X       X        8
      Waiver to permit some activities in support of
32.
      the tourism industry (certain States)             X               X                                       X                        3
33.   Prohibiting assistance to private utilities                                                                       X       X        2
      Waiver of Section 414 of the Stafford Act
34.   (specific cities)                                                 X               X                       X                        3
      Buildings for the general conduct of
35.
      government                                                        X               X       X      X        X       X       X        7
36.   Use of CDBG as match                                                                                      X       X       X        3
      Clarifying note on Section 3 income
37.
      documentation requirements                                                                                X       X       X        3
      Compensation to an individual, nonprofit, or
38.   small business for economic losses related to
      disasters                                         X               X               X                                                3
39.   Prioritizing small businesses                                                                                     X       X        2
40.   Limitation on emergency grant payments                                            X       X      X        X       X                5
41.   Procurement                                                                               X      X        X       X       X        5
      Public website, including use of funds and
42.   contracts                                                                                                 X       X       X        3
      Waiver of timely distribution (expenditure) of
43.
      funds                                                             X                       X      X        X       X       X        6
44.   Duration of funding                                      X        X               X       X      X        X       X       X        8
      Review of continuing capacity to carry out
45.
      CDBG-funded activities in a timely manner                                                                 X       X       X        3
      Housing incentives (compensation) to
      encourage housing resettlement consistent
46.
      with local recovery plans (certain States and
      localities)                                                       X               X       X      X        X       X       X        7
      Uniform Relocation Act waiver of one-for-one
47.
      replacement of units damaged by disaster                 X        X       X       X       X      X        X       X       X        9
      Acquisition of real property, flood buyouts,
48.
      and flood insurance                                      X        X       X       X       X      X        X       X       X        9
49.   Flood insurance purchase requirements                                                                             X       X        2
      Alternative requirement for housing
50.
      rehabilitation, assistance for second homes                                                               X       X       X        3
51.   Corrective and remedial actions                                                                  X        X       X       X        4
      Reduction, withdrawal, or adjustment of a
52.
      grant or other appropriate action                                                                X        X       X       X        4
      Documentation of low- and moderate-income
53.   national objective for multiunit housing
      projects (certain cities and States)                              X                                       X                        2
54.   Calculating unmet public housing needs                                                                    X       X       X        3
55.   Calculating unmet infrastructure needs                                                                    X       X       X        3
      Calculating economic revitalization (small
56.
      business) needs                                                                                           X       X       X        3
57.   Elevation of nonresidential structures                                                                            X       X        2
      Urgent need national objective certification
58.
      requirements (certain States)                                                                             X       X       X        3
      Alternative requirement to permit extended
59.   time for the provision of interim mortgage
      assistance (certain States)                                                                               X       X       X        3




                                                                      28
Appendix F
                       HUD OIG CDBG Disaster Recovery Reports
                                                                                            Funds to
                         Issue                                             Questioned       be put to
Count    Report no.      date           Entity audited or evaluated          costs          better use
1.      2002-NY-1802   5/22/2002    Empire State Development Corporation               -                 -
2.      2003-NY-1003   3/25/2003    Empire State Development Corporation   $     354,691                 -
3.      2003-NY-1005   9/30/2003    Empire State Development Corporation         270,948                 -
                                    Lower Manhattan Development
4.      2003-NY-1006   9/30/2003    Corporation                                   82,342    $     93,214
5.      2004-NY-1001   3/25/2004    Empire State Development Corporation          49,000               -
                                    Lower Manhattan Development
6.      2004-NY-1002   3/25/2004    Corporation                                  102,900                 -
                                    Lower Manhattan Development
7.      2004-NY-1004   9/15/2004    Corporation                                   87,394                 -
                                    Lower Manhattan Development
8.      2005-NY-1003   3/23/2005    Corporation                                  141,347                 -
                                    Lower Manhattan Development
9.      2005-NY-1008   9/27/2005    Corporation                                 2,028,282       6,441,103
                                    Lower Manhattan Development
10.     2006-NY-1006   3/31/2006    Corporation                                  266,802                 -
11.     2006-AT-1014   7/26/2006    State of Florida                                   -                 -
12.     2006-AT-0001   8/29/2006    HUD’s Procurement Office                           -                 -
                                    Lower Manhattan Development
13.     2006-NY-1013   9/27/2006    Corporation                                    3,053         186,749
                                    Lower Manhattan Development
14.     2007-NY-0802   4/3/2007     Corporation                                         -                -
                                    Lower Manhattan Development
15.     2007-NY-1005   4/17/2007    Corporation                                    6,000               -
16.     2007-AO-1001   5/7/2007     State of Mississippi                               -         159,172
                                    Lower Manhattan Development
17.     2007-NY-1013   9/28/2007    Corporation                                         -                -
                                    Lower Manhattan Development
18.     2008-NY-0801   10/23/2007   Corporation                                         -                -
19.     2008-AO-1001   12/19/2007   State of Louisiana                                  -                -
20.     2008-AO-1002   1/30/2008    State of Louisiana                         15,528,378                -
21.     2008-AO-1801   3/6/2008     State of Mississippi                           20,571                -
                                    Lower Manhattan Development
22.     2008-NY-1004   3/31/2008    Corporation                                         -          6,782
23.     2008-AO-1003   4/25/2008    Mississippi Development Authority           3,907,378        243,210
24.     2008-AO-1005   8/7/2008     State of Louisiana                            263,959              -
                                    Lower Manhattan Development
25.     2009-NY-0801   11/9/2008    Corporation                                         -        868,000
                                    Lower Manhattan Development
26.     2009-NY-1003   12/4/2008    Corporation                                  468,649        3,031,351
                                    Texas Department of Housing and
27.     2009-FW-1004   1/14/2009    Community Affairs                                  -                 -
28.     2009-AO-1001   5/5/2009     State of Louisiana                           228,930                 -
29.     2009-AO-1002   5/5/2009     State of Louisiana                           735,087                 -
30.     2009-NY-1013   5/27/2009    Lower Manhattan Development
                                    Corporation                                   508,361         19,643
31.     2009-AO-1801   6/12/2009    State of Mississippi                        1,877,806              -
32.     2009-AO-1802   7/31/2009    State of Mississippi                                -              -




                                                   29
                                                                                            Funds to
                         Issue                                               Questioned     be put to
Count    Report no.      date           Entity audited or evaluated            costs        better use
                                    HUD’s Office of Community Planning and              -                -
33.     IED-08-005     9/1/2009     Development
34.     2009-AO-1003   9/23/2009    Louisiana Land Trust                                -                -
                                    Texas Department of Housing and
35.     2009-FW-1016   9/30/2009    Community Affairs                                   -    60,235,000
                                    Lower Manhattan Development
36.     2010-NY-1001   10/6/2009    Corporation                                         -                -
37.     2010-AO-1001   12/15/2009   Mississippi Development Authority                   -                -
38.     2010-AO-1002   1/4/2010     State of Louisiana                            147,681                -
39.     2010-KC-1001   3/10/2010    State of Iowa                              10,532,871                -
                                    Lower Manhattan Development
40.     2010-NY-1008   3/22/2010    Corporation                                        -                 -
41.     2010-AO-1003   4/30/2010    State of Louisiana                            82,752                 -
42.     2010-KC-1004   5/26/2010    State of Iowa                                      -                 -
43.     2010-AO-1004   6/22/2010    Mississippi Development Authority             21,964                 -
                                    Texas Department of Housing and
44.     2010-FW-1005   7/20/2010    Community Affairs                          18,763,330             -
45.     2010-AO-1005   8/4/2010     State of Louisiana                                  -    28,125,000
46.     IED-09-002     9/1/2010     State of Louisiana                          3,800,000             -
47.     2010-AO-1006   9/30/2010    State of Alabama                                    -             -
48.     2010-AO-1007   9/30/2010    State of Alabama                                    -             -
49.     2011-AO-1001   10/28/2010   State of Louisiana                                  -             -
50.     2011-AO-1002   10/29/2010   State of Louisiana                          2,817,530             -
                                    Texas Department of Housing and
51.     2011-FW-1006   1/26/2011    Community Affairs                             71,691                 -
                                    Lower Manhattan Development
52.     2011-NY-1005   2/7/2011     Corporation                                         -             -
53.     2011-AO-1005   4/18/2011    State of Mississippi                           90,000        75,000
54.     2012-FW-1005   3/7/2012     State of Texas                              9,061,794    75,009,910
55.     2012-FW-1011   7/19/2012    City of Houston, TX                                 -             -
                                    Lower Manhattan Development
56.     2012-NY-1010   7/27/2012    Corporation                                   159,261         2,258
57.     2013-KC-1001   10/23/2012   City of Cedar Rapids, IA                   12,210,247             -
58.     2013-NY-1801   1/11/2013    Deutsche Bank of New York                           -             -
59.     2013-FW-0001   3/28/2013    HUD’s Office of Block Grant Assistance              -             -
60.     2013-IE-0803   3/29/2013    State of Louisiana                        698,343,830             -
61.     2013-KC-1002   5/6/2013     State of Iowa                                       -             -
                                    Lower Manhattan Development
62.     2013-NY-1008   7/18/2013    Corporation                                         -             -
63.     2014-AT-1004   12/30/2013   State of Mississippi                        2,165,915             -
64.     2014-KC-1002   1/29/2014    City of Joplin, MO                                  -             -
65.     2014-FW-1004   7/15/2014    State of Texas                              1,609,580     8,624,700
66.     2014-PH-1008   8/29/2014    State of New Jersey                        22,986,481             -
67.     2014-PH-1009   9/5/2014     State of New Jersey                                 -             -
                                    Vermont Department of Housing and
68.     2014-BO-1004   9/29/2014    Community Development                               -    13,232,000
                                    Lower Manhattan Development
69.     2014-NY-1011   9/30/2014    Corporation                                         -                -
                                    City of New York, Office of Management
70.     2015-NY-1001   11/24/2014   and Budget                                183,000,000    40,000,000
71.     2015-KC-1002   3/13/2015    City of Minot, ND                          11,671,037             -
                                    City of New York, Office of Management
72.     2015-NY-1004   4/23/2015    and Budget                                          -                -




                                                  30
                                                                                             Funds to
                          Issue                                               Questioned     be put to
Count    Report no.       date           Entity audited or evaluated            costs        better use
73.     2015-PH-1003    6/4/2015     State of New Jersey                        38,512,267      9,061,780
                                     City of New York, Office of Management
74.     2015-NY-1007    6/12/2015    and Budget                                    241,000              -
75.     2015-FW-1002    6/26/2015    City of New Orleans, LA                     2,556,409      4,539,286
                                     Lower Manhattan Development
76.     2015-NY-1008    6/26/2015    Corporation                                         -                -
77.     2015-PH-1004    7/20/2015    State of New Jersey                                 -                -
78.     2015-AT-1006    7/27/2015    State of Florida                            2,324,058                -
79.     2015-FW-1003    8/7/2015     City of Moore, OK                                   -                -
                                     State of New York Governor’s Office of
80.     2015-NY-1010    9/17/2015    Storm Recovery                             18,289,388     18,763,894
                                     State of New York Governor’s Office of
81.     2015-NY-1011    9/17/2015    Storm Recovery                            185,221,340    274,035,899
82.     2015-PH-1005    9/25/2015    State of Maryland                           1,928,646        292,910
                                     Alabama Department of Economic and
83      2015-AT-1010    9/28/2015    Community Affairs                                   -              -
84.     2015-CH-1009    9/30/2015    State of Illinois                           1,461,842      4,346,358
                                     Lower Manhattan Development
85.     2016-NY-1004    2/19/2016    Corporation                                         -                -
86.     2016-KC-1001    2/22/2016    State of Missouri                           1,551,656                -
87.     2016-BO-1001    3/9/2016     State of Rhode Island                         127,750                -
88.     2016-NY-1005    3/11/2016    City of New York, Office of Management
                                     and Budget                                          -                -
                                     State of New York Governor’s Office of
89.     2016-NY-1006    3/29/2016    Storm Recovery                               425,162         300,000
90.     2016-PH-1004    6/18/2016    Luzerne County, PA                                 -               -
91.     2016-CH-1003    6/30/2016    State of Indiana                             372,783               -
                                     State of New York Governor’s Office of
92.     2016-NY-1009    8/12/2016    Storm Recovery                             21,958,549              -
93.     2016-FW-1006    8/31/2016    St. John the Baptist Parish, LA             1,572,079      5,365,327
94.     2016-FW-1007    9/12/2016    HUD’s Office of Block Grant Assistance              -              -
95.     2016-OE-0009S   9/23/2016    HUD’s Office of Community Planning and
                                     Development                                         -              -
96.     2016-DE-1003    9/28/2016    Boulder County, CO                                  -              -
97.     2016-KC-1006    9/28/2016    City of Joplin, MO                                  -      2,275,177
                                     HUD’s Office of Community Planning and
98.     2016-PH-0005    9/29/2016    Development                                         -   4,872,056,594
99.     2016-FW-1010    9/30/2016    State of Oklahoma                          11,717,288      81,982,712
100.    2016-PH-1009    9/30/2016    State of New Jersey                        43,080,932               -
101.    2017-BO-1001    10/12/2016   State of Connecticut                       16,053,062               -
102.    2017-BO-1002    10/17/2016   City of Springfield, MA                     1,448,663         472,246
                                     City of New York, Mayor’s Office of
103.    2017-NY-1001    11/2/2016    Housing Recovery Operations                 5,544,284      1,415,466
                                     City of New York Office of Management
104.    2017-NY-1004    12/21/2016   and Budget                                 18,274,054                -
105.    2017-AT-1001    1/18/2017    City of Tuscaloosa, AL                              -                -
106.    2017-AT-1002    1/18/2017    Shelby County, TN                                   -                -
                                     HUD’s Office of Community Planning and
107.    2016-OE-0004S   3/29/2017    Development                                         -                -
                                     HUD’s Office of Community Planning and
108.    2017-OE-0002S   4/10/2017    Development                                        -               -
109.    2017-FW-1004    4/16/2017    St. Tammany Parish, LA                       451,894       8,679,994




                                                   31
                                                                                             Funds to
                          Issue                                              Questioned      be put to
Count    Report no.       date          Entity audited or evaluated            costs         better use
                                    HUD’s Office of Community Planning and
110.    2016-OE-0011S   5/3/2017    Development                                          -                -
                                    HUD’s Office of Community Planning and
111     2017-KC-0004    6/2/2017    Development                                          -                -
                                    Lower Manhattan Development
112.    2017-NY-1009    6/13/2017   Corporation                                          -                -
                                    City of Birmingham, Department of
113.    2017-AT-1008    7/21/2017   Community Development                               -               -
114.    2017-PH-1005    8/14/2017   State of New Jersey                           987,500               -
115.    2017-NY-1010    9/15/2017   State of New York                          18,782,054       8,932,630
116.    2017-NY-1012    9/21/2017   City of New York, NY                                -               -
                                    HUD’s Office of Community Planning and
117.    2017-PH-0002    9/22/2017   Development                                          -               -
118.    2017-CH-1010    9/30/2017   DuPage County, IL                               98,507         569,391
        Totals                                                               1,397,449,009   5,529,442,756




                                                  32