Issue Date
September 6, 1996
Audit Case Number
96-NY-241-1005
TO: Frank Sagarese, Director
Community Planning and Development Division
New Jersey State Office
FROM: A. Paul Kane, District Inspector General for Audit
New York/New Jersey
SUBJECT: City of Camden
Community Development Programs
Camden, New Jersey
Henry G. Cisneros, Secretary of the U. S. Department of Housing and Urban Development
(HUD), asked that we examine the operations of the City of Camden, New Jersey (Grantee)
pertaining to its Community Development Block Grant (CDBG), HOME, HOPE 3, and
Empowerment Zone programs. In addition we reviewed the collection of miscellaneous revenue
due from completed Urban Development Action Grants (UDAG) and repayments made on a loan
guaranteed under the Section 108 Loan Guarantee program. However, we did not review the
Empowerment Zone program because program activities had not been initiated (See the General
Comment section of this report). Also, we did not review an approved Emergency Shelter Grant
(ESG) because there were no expenditures during the period reviewed. The purpose of our
examination was to determine whether the Grantee carried out activities as shown in its
applications in an economical, efficient, and effective manner; complied with requirements, laws
and regulations of HUD; and charged costs to the programs which were eligible and reasonable.
The period reviewed was from January 1, 1995 through December 31, 1995, and where
appropriate, was extended to include other periods. The on-site work was performed between
March 25, 1996 and May 3, 1996.
The report contains six findings that show a need to improve the Grantee's organizational
structure and correct significant weaknesses in financial and administrative controls. The
Grantee’s financial and program records are not complete, accurate, or current. Our report
identifies unallowable costs of $801,364 and unsupported costs of $1,381,045. We have also
identified a cost efficiency of $251,400.
Within 60 days, please furnish this office, for each recommendation cited in the report, a status
report on: (1) the corrective action taken, (2) the proposed corrective action and the date to be
completed, or (3) why action is not considered necessary. Also, please furnish us copies of any
correspondence or directives issued related to the audit.
Management Memorandum
Should your staff have any questions, please contact Alexander C. Malloy, Assistant District
Inspector General for Audit, at 212-264-8000, Extension 3976.
96-NY-241-1005 Page ii
Executive Summary
We reviewed the operations of the City of Camden (Grantee) pertaining to its CDBG, Home and
HOPE 3 programs. In addition, we reviewed the collection of miscellaneous revenue from
completed UDAGs and repayments made on a loan guaranteed under the Section 108 Loan
Guarantee program. However, we did not review the Empowerment Zone program because
program activities had not been initiated, (See the General Comment section of this report). Also,
we did not review an approved ESG because there were no expenditures during the period
reviewed. The purpose of our examination was to determine whether the Grantee carried out
activities as shown in its applications in an economical, efficient, and effective manner; complied
with requirements, laws and regulations of the U.S. Department of Housing and Urban
Development (HUD); and charged costs to the program that were eligible and reasonable.
Our review showed significant weaknesses in the Grantee's organizational structure and financial
management system. As a result, the Grantee's financial and program records are not complete,
accurate, or current. Since the Grantee's official accounting records were not readily auditable,
we had to rely on other records maintained by the Department of Development and
Redevelopment, other Grantee departments and subrecipients. Under these circumstances,
unrecorded or other inappropriate transactions may have occurred and remained undetected
during our audit tests of the Grantee's operations.
The administration of HUD programs is fragmented among
Deficiencies found
several City departments and subrecipients. Lines of
authority and communication are muddled and the absence
of accurate, complete, and timely financial records seriously
affects the Grantee's ability to administer the programs.
The Grantee did not comply with program regulations prior
to using $1,835,052 in CDBG funds to make payments on
a loan, which is owed the City, under the Section 108 Loan
Guarantee program. More significantly, $916,808 of the
amount was not authorized to be drawn down because the
funds had not been included in the CDBG budget or
charged to any approved activity or program year.
Additionally, we were unable to determine the propriety
and reasonableness of the remaining $918,244, charged to
various economic development and public facility activities.
This has jeopardized the Grantee's ability to complete its
approved activities, adversely affected HUD's ability to
evaluate program progress, and diminished the rights of
citizens to participate in program matters.
Page iii 96-NY-241-1005
Executive Summary
Subrecipients have not been adequately monitored by the
Grantee to assure compliance with Federal requirements.
The monitoring weaknesses extend to both the
administrative review of reimbursements and on-site
monitoring. The finding identifies $163,560 in expenditures
that were not adequately supported.
Finally, effective administrative practices necessary to
ensure that costs paid from grant funds are allowable and
reasonable have not been implemented. Consequently, the
program has been charged for costs that are not adequately
supported, not necessary or reasonable. Accordingly, we
consider payments totaling $38,874 to be unallowable and
another $299,241 to be unsupported.
We are recommending actions that will strengthen the
Recommendations to
Grantee's future administration of HUD programs. We are
mitigate problems
also recommending that you require the Grantee to repay
the ineligible costs of $801,364, and either repay or
document the unsupported costs of $1,381,045.
The results of the audit were discussed with Grantee
Exit conference
officials during the audit and at an exit conference held on
August 8, 1996, attended by:
City of Camden
Arnold W. Webster, Ph.D., Mayor
Patrick J. Keating, Business Administrator
Deborah Polk, Commissioner, Department of Development
& Redevelopment
State of New Jersey
Robert Law, State of New Jersey, Department of
Community Affairs, Division of Local
Government Services, City of Camden/Fiscal Monitor
Office of Inspector General
Alexander C. Malloy, Assistant District
Inspector General for Audit
Lawrence W. Magiera, Senior Auditor
96-NY-241-1005 Page iv
Executive Summary
Garry D. Clugston, Senior Auditor
John A. Cameron, III, Auditor
The Grantee's response to the draft findings, which is dated
August 8, 1996, provides that Grantee officials concur with
the findings and are in the process of implementing all
necessary and appropriate corrective actions. Specifically,
the Mayor states:
"We have reviewed the six findings developed during
the Office of Inspector General audit of our HUD
programs. The findings, concerns and recommenda-
tions in the draft of the audit report will be used as a
tool for the development of an overall organizational
structure to effectively administer these programs. We
concur with the findings and are in the process of
implementing corrective actions with respect to each
finding contained in your review. We look forward to
working with the HUD Field Office in Newark in
regard to these corrective actions."
The Grantee's response is included in this report as
Appendix B.
Page v 96-NY-241-1005
Executive Summary
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96-NY-241-1005 Page vi
Table of Contents
Management Memorandum i
Executive Summary iii
Introduction 1
Findings
1 An Effective Organizational Structure
is Needed 3
2 Weaknesses in Financial Management
System and Related Accounting Controls 9
3 Monitoring of Subrecipient Performance
Needs to be Improved 13
4 Section 108 Loan Repayments Made Without
Complying With CDBG Regulations 19
5 Inadequate Administrative Practices
Resulted in Uneconomical and Unsupported
Use of CDBG Funds 23
6 Improvements Needed in the Administration
of Housing Rehabilitation Programs 29
Internal Controls 33
Follow Up On Prior Audits 35
Page vii 96-NY-241-1005
Table of Contents
General Comment 37
Appendices
A Schedule of Ineligible and Unsupported
Costs, and Cost Efficiencies 39
B Auditee Comments 41
C Distribution 45
Acronyms
CBAC Cooperative Business Assistance Corporation
CDBG Community Development Block Grant
CEDC Camden Economic Development Corporation
CFR
Code of Federal Regulations
CRA Camden Redevelopment Agency
DDR Department of Development and Redevelopment
ESG Emergency Shelter Grant
EZ Empowerment Zone
HUD Department of Housing and Urban Development
IPA Independent Public Accountant
JCHD Jersey Counselling & Housing Development
OIG Office of Inspector General
OMB Office of Management and Budget
UDAG Urban Development Action Grant
96-NY-241-1005 Page viii
Introduction
Title I of the Housing and Community Development Act of 1974, established the CDBG
program. The CDBG program provides grants to States and units of local governments to aid in
the development of viable urban communities. The HOME program allows participating
jurisdictions to use the funds for a variety of housing activities, according to local housing needs.
The HOPE 3 program provides homeownership opportunities for eligible families to purchase
local government-owned single family properties. The Section 108 Loan Guarantee program
allows communities entitled to CDBG grants a means to finance up-front, certain large scale
projects beyond the scope that can be financed by annual grants.
The above described programs are administered by the Grantee and subrecipients. The Grantee
is governed by a Mayor and City Council. The Grantee's office is located at City Hall, Camden,
New Jersey. The Commissioner of the Department of Development and Redevelopment is
Deborah Polk and the Comptroller is Richard Cinaglia.
During the audit period, the Grantee administered the following grants:
• CDBG Entitlement Grants for Program Years 1994 and 1995 totaling $8,126,000.
• HOME Grant for $1,231,000.
• HOPE 3 Grant for $1,495,051.
The audit objectives were to determine whether the
Audit Objectives, Scope
Grantee: (1) carried out its activities as shown in its
and Methodology
applications and agreements in an economical, efficient,
and effective manner; (2) complied with HUD program
requirements, laws and regulations; and (3) charged costs to
its HUD programs that were reasonable and eligible.
The audit covered the period from January 1, 1995 through
December 31, 1995. However, we reviewed activity prior
and subsequent to the audit period as necessary. Based
upon our survey results the audit focused primarily on the
Grantee's organizational structure and related administrative
and financial controls. The audit site work was conducted
from March 25, 1996 through May 3, 1996.
To accomplish the audit objectives the following audit
procedures were performed:
Page 1 96-NY-241-1005
Introduction
• Examined records and files of the Grantee and
interviewed staff.
• Reviewed internal controls relevant to the audit
objectives.
• Tested selected transactions.
• Evaluated monitoring activities and determined whether
selected subrecipients were carrying out program
activities defined in their agreements with the Grantee.
• Performed site inspections of selected rehabilitation
units to determine whether all work was completed.
The audit was conducted in accordance with generally
accepted government audit standards.
A copy of this report was provided to the Grantee.
96-NY-241-1005 Page 2
Finding 1
An Effective Organizational Structure is
Needed
In 1994, the Grantee reorganized the City government in an attempt to provide a more effective
and efficient operation through establishing stronger lines of accountability and responsibility.
Unfortunately, the anticipated efficiencies have not been realized in the administration of HUD
programs. The administration of the CDBG, ESG, HOME, and HOPE 3 programs has been
fragmented among several City departments and subrecipients. No single department or agency
exercises complete authority or oversight of the programs. Lines of authority and communication
are muddled and the absence of accurate, complete, and timely financial records seriously
impacts the Grantee's ability to properly administer the programs. The specific effects of the poor
organizational structure are discussed in the other audit findings contained in this report.
Section 570.610 of the CDBG Regulations require grantees
Criteria
to comply with the policies guidelines and requirements of
24 CFR, Part 85, OMB Circulars A-87, A-110, A-122, and
A-133 as applicable. Part 85 is also applicable to the
HOME and HOPE 3 programs. Moreover, the grantees
responsibility to establish an effective organizational
structure is defined in the policy guide section of OMB
Circular A-87. The circular provides that "Each
governmental unit, in recognition of its own unique
combination of staff, facilities, and experience, will have
the primary responsibility for employing whatever form of
organization and management techniques may be necessary
to assure proper and efficient administration of Federal
awards."
Section 570.501(b) provides that grantees are responsible
for ensuring that CDBG funds are used in accordance with
all program requirements. It further provides that the use of
designated public agencies, subrecipients or contractors
does not relieve the grantee of this responsibility and that
the grantee is also responsible for determining the adequacy
of performance under subrecipient and procurement
contracts.
Page 3 96-NY-204-1005
Finding 1
The Department of Development and Redevelopment
Background
(DDR) is identified as the lead City department
administering HUD programs. Our review found that the
DDR is not operating in that capacity because it has not
been given the authority to accomplish this task. In fact,
under the current organizational structure, the DDR has
very little formal involvement in any of the structured
processes of the City. For example, DDR is not in the line
of authority over contracting, purchasing, receipts and
disbursements as they pertain to the HUD programs. DDR
does not have the authority to review procurement actions,
contracts, or purchase orders to determine if the items are
allowable and eligible. While DDR has acted as a program
monitor, its reports carry little weight and authority.
To DDR's credit, it has managed to construct a reasonable
system of unofficial records from copies of purchase orders
and contracts obtained from the Comptroller and other
departments. While DDR's records were found to be much
more accurate than the Comptrollers, they are not the
official records and cannot be used for that purpose.
Authority to administer the various grant activities is
Current Administrative
fragmented among City departments including the
Structure
Department of Community Affairs, Housing and
Community Development, Environmental Affairs, Planning
and Health and Human Services. The Departments are
further broken down by divisions and bureaus. In addition,
the Grantee employs the Camden Redevelopment Agency
(CRA), a public agency, to act as the administrator for
several CDBG and HOME activities, as well as performing
monitoring of several other subrecipients. In addition, CRA
also acts as a subrecipient. To further complicate CRA's
administrative role, the City has five of its planning
department employees working under the direction of CRA.
Each of the City Departments and CRA implement
activities, projects, and procure materials and services. They
also submit contracts to the City Council for approval and
authorize grant payments. Further, the City Departments
and/or CRA also contract with at least forty subrecipients to
carry out grant related activities. Program monitoring
responsibilities vary between activities and often overlap
between entities, resulting in poor program oversight.
96-NY-241-1005 Page 4
Finding 1
Our review which included interviews with Grantee, CRA,
Results of Review
and subrecipient personnel showed that the administration
of HUD programs have been impeded by the current
organizational structure. Particular weaknesses are
described below.
Planning Process
The Grantee does not have a centralized and focused
planning process to ensure that HUD programs, private
funding, and City resources are used in an effective and
coordinated fashion. The Grantee's planning function is
fragmented with little emphasis on project management.
Currently, planning personnel are spread between different
offices in City Hall and also assigned to CRA. In addition,
it appears that other subrecipients perform certain planning
functions with little oversight from the Grantee.
Examples of the decentralization of the planning function
are as follows:
• Planning for neighborhoods and housing is fragmented
between CRA, certain subrecipients, and the Division of
Housing Services.
• Planning for parks and recreational activities flows
through the Department of Community Affairs.
• Planning for economic development is split between
CRA, Department of Development and Redevelopment
and the Cooperative Business Assistance Corporation
(CBAC), a subrecipient.
• Planning for land use and site plans are performed by
the Division of Planning. While this Division is within
the Department of Administration and Finance, the
planning staff is supervised by the CRA.
Budget Process
Serious internal control weaknesses (discussed in Finding
2) and the lack of a formal written budget process for HUD
funds has adversely affected the Grantee's ability to
Page 5 96-NY-204-1005
Finding 1
administer its programs. There is little assurance that HUD
grants and activities will not be over obligated.
Monitoring Process
The Grantee's monitoring of HUD funded activities is in
disarray. Specific deficiencies are discussed in Finding 3 of
this report, but it is suffice to say that adequate monitoring
is not being performed under any of the HUD programs.
Financial and Internal Controls
There is no discernable system of financial controls or
organizational lines of authority and communication to
ensure that HUD program activities are effectively
administered. Policies and procedures necessary to achieve
HUD program objectives have not been implemented.
Finding 2 of this report identifies significant deficiencies in
the financial records and lack of rudimentary internal
controls.
Programmatic Communications
The current organizational structure inhibits free and open
communication between the various departments and
subrecipients. The failure to develop effective lines of
authority and the lack of a centralized lead department to
administer grants has resulted in a breakdown in
communications and caused an aura of rivalry between
various entities administering activities.
The absence of an effective organizational structure has
been the underlying cause for the significant deficiencies
included in the findings in this report. Unless effective
corrective actions are taken to resolve the organizational
problems, it is unlikely that the Grantee will have the
capacity to adequately administer its grants in the future.
Recommendations We recommend that you require the Grantee to:
96-NY-241-1005 Page 6
Finding 1
1A. Submit an organizational plan for your review that
meets the requirements of the various program
regulations and OMB Circulars.
The new organizational structure should establish
clear lines of authority and establish a lead
department to administer HUD programs.
Since the organizational deficiencies extend into the
City's operations, it is unlikely that significant
improvements can be made unless the City
participates in the organizational changes.
Also, we recommend that you:
1B. Review the submitted plan and direct its
implementation.
1C. Advise the Grantee that unless the plan is effectively
implemented in a timely manner, that corrective
actions identified in Title 24 CFR Sections 570.910,
911, and 913 will be instituted.
Page 7 96-NY-204-1005
Finding 1
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96-NY-241-1005 Page 8
Finding 2
Weaknesses in Financial Management System
and Related Accounting Controls
Our review disclosed significant weaknesses in the Grantee's financial management system. The
weaknesses have adversely impacted the Grantee's assurance that HUD funds are properly
safeguarded and that adequate financial records are maintained in accordance with HUD
requirements. As a result, the Grantee's financial records are not complete, accurate, or current.
The weaknesses can be attributed to the lack of effective management oversight caused by a poor
organizational structure.
The requirements mandating grantees to have effective
Criteria
financial management systems are contained in Title 24,
Part 85.20 of the Code of Federal Regulations. The
standards require financial systems to provide:
• Accurate, current and complete disclosure of financial
transactions.
• Records that adequately identify the source and
application of funds.
• Effective control and accountability for all grant cash,
property and other assets.
• Accounting records that are supported by source
documentation.
Moreover, the Office of Management and Budget (OMB)
Circular A-87, Cost Principles for State and Local
Governments provides that costs must be necessary and
reasonable for the proper and efficient administration of the
program and that the cost be accorded consistent treatment
through the application of generally accepted accounting
principles.
The Grantee's official accounting records are maintained by
Background and Scope
the City's Comptroller's Office. The Comptroller is
Page 9 96-NY-241-1005
Finding 2
responsible for maintaining general ledgers, journals, cash receipts and disbursement records
for the CDBG, HOME, HOPE 3 and ESG programs.
We reviewed the Grantee's financial management system
including internal controls, accounting procedures, and
purchasing policies to determine whether the Grantee was
in compliance with the aforementioned criteria. We tested
the accuracy of the financial records by comparing them
with program records maintained by other Grantee
departments, subrecipients, HUD Field Office, and the audit
performed by the Independent Public Accountant (IPA).
Material errors and deficiencies were found in the financial
Results of review
records maintained by the Grantee's Comptroller. The errors
and deficiencies have seriously affected the accuracy of
program reports, the City's annual audit, and the assurance
that HUD funds are properly being used and safeguarded as
evidenced by the Findings in this report.
We relied on the unofficial records maintained by the
Department of Development and Redevelopment for much
of our audit work, because the Grantee's official accounting
records were not readily auditable.
Some of the more significant deficiencies and errors are
Deficient accounting
discussed in detail below.
records
1. Grantee's General Ledger does not account for
program receipts and expenditures by grant activity
or grant program year.
2. Receipts and expenditures for the CDBG, ESG, and
Section 108 programs are commingled in one cash
account. This account is not being reconciled.
3. Grantee accounting records do not accurately record
the amount due from HUD programs. The
outstanding CDBG grant balance is significantly
understated on the General Ledger. Additionally, the
HOME, HOPE 3, and ESG programs are not even
included as General Ledger accounts.
4. CDBG ledger accounts are not posted in a timely
manner and therefore are not current. Many
96-NY-241-1005 Page 10
Finding 2
accounts are posted annually using IPA adjusting
journal entries.
5. Budgetary controls over the HUD programs are not
employed by the Comptroller's Office. There is no
assurance that expenditures are compared with
budget amounts or that funds are available for the
items being charged.
6. Payments are processed without adequate review of
source documentation. Payments have been made
without executed contracts and/or properly prepared
vouchers and advices.
7. HOME and HOPE 3 programs were not included in
the IPA annual audit. ESG funds were not identified
in the audits, but were erroneously included with
CDBG.
The Grantee has not established an efficient organizational
Cause
structure to administer its programs. We attribute the
deficiencies to the lack of centralized management control
over the programs as well as poor communication between
the various autonomous departments. Further, there appears
to have been little effort on the part of the Grantee to ensure
that its system meets HUD and generally accepted
accounting principles. Where controls and practices have
been established, they are not always followed.
The Grantee has not complied with the HUD requirements
Summary
to establish an effective financial management system. As
a result, HUD and the Grantee have little assurance that
program costs are proper, funds are being used in an
economical and effective manner, or that program
objectives are being met.
Recommendations We recommend that you require the Grantee to:
2A. Implement effective accounting controls necessary
to comply with HUD requirements. The corrective
actions should complement the organizational
Page 11 96-NY-241-1005
Finding 2
structure improvements instituted through Finding
1.
2B. Conduct a review of its financial records and
prepare correcting entries where applicable. The end
product should result in books of account that can
be reconciled with program records.
2C. Ensure that subsequent annual audits include all
HUD grant activities. The IPA should be instructed
to expand the audit period to include prior years
activities that were not audited.
96-NY-241-1005 Page 12
Finding 3
Monitoring of Subrecipient Performance
Needs to be Improved
The Grantee's monitoring of its subrecipients has not identified internal control weaknesses at the
subrecipients and has not detected or corrected untimely or poor performance. Consequently, the
Grantee does not have assurance that program funds were used for eligible costs and that
activities administered by subrecipients meet program objectives. We believe that adequate
monitoring has not been performed because of communication and coordination problems
between the various Grantee departments and subrecipients administering the programs.
Title 24 CFR, Part 85 contains the requirements that
Criteria
grantees are to follow regarding program monitoring
including the activities administered by subrecipients. In
addition, Part 85 provides financial management standards
that must be met by the grantee and subrecipients. Finally,
24 CFR Section 570.501 provides that the grantee is
responsible for determining the adequacy of performance
under subrecipient agreements and for taking appropriate
action when performance problems arise.
We examined the program files for 9 of the 41 subrecipients
Scope of Review
identified by the Grantee as participating in the HUD
programs during the audit period. We conducted site-visits
to 4 of the subrecipients. The nine subrecipients were
selected because our survey work either identified areas of
potential weaknesses that required further review, or
because the subrecipients received the largest allocation of
grant funding.
The purpose of our review was to evaluate the Grantee's
procedures for monitoring its subrecipients. Further, to
determine whether the subrecipients had implemented
financial monitoring systems that would meet the
requirements, and whether the subrecipients program
activities were achieving the applicable program objectives.
Page 13 96-NY-241-1005
Finding 3
As a result of our file reviews and site-visits we concluded
Review results
that the Grantee has not implemented effective procedures
necessary to monitor subrecipient performance and
compliance with program requirements. We found that
Grantee files did not always contain all the required
documentation necessary to support program costs and
activities. Examples included program files that did not
contain; (a) the required audited financial statements, (b)
documentation supporting claimed costs, and (c) activity
progress reports.
Details pertaining to the more significant weaknesses are
discussed separately by subrecipient below.
1. Camden Redevelopment Agency (CRA)
The CRA was established by City Council ordinance to
carry out certain redevelopment activities. In addition to
administering certain activities for the Grantee, CRA was
also under contract to perform monitoring of selected
subrecipients.
Although under contract to monitor several subrecipients,
Formal Monitoring Not
we found that no monitoring reports were provided to the
Documented
Grantee during our review period. In addition, we found
that CRA's files contained insufficient documentation
supporting its monitoring activities. In addition, CRA has
not had timely audits performed on its operations as
required. The latest audit was for the period ended
12/31/93. The audit report contains findings identifying
weaknesses in the internal controls over cash receipts and
disbursements. These findings remain unresolved.
Our review of selected activities and subrecipients under
CRA's oversight disclosed several significant deficiencies
including the unsupported use of grant funds and poor
performance as follows:
Morgan Village Community Center - In June 1992, the
CRA contracted with the Grantee to administer this project
involving $100,000 in rehabilitation work funded from
CDBG funds.
96-NY-241-1005 Page 14
Finding 3
Four years and $119,875.36 later, the project remains
incomplete. More significantly, we were unable to
determine the propriety and reasonableness of these costs
because the Grantee and CRA were unable to provide us
with a construction contract or adequate work
specifications. Moreover, we found that the work was
procured without the benefit of bidding. An examination of
the documentation supporting the payments disclosed that
the documentation did not adequately identify the scope of
work performed or that the work was properly inspected
prior to the payments.
T & C Child Development Company, Inc. - CRA had
administrative oversight of T & C's construction of 12 units
of new housing in East Camden. The project began in
March 1995, and is funded from the 1993 HOME and 1994
CDBG programs in the amount $88,000. To date, $43,685,
in funding has been provided with no discernable progress.
In fact, construction has not begun in part due to T & C's
failure to secure approximately one million dollars in
financing. The Grantee advised that the financial viability
of the project is now uncertain.
2.Cooperative Business Assistance Corp.(CBAC)
CBAC is a non-profit corporation that administers several
economic development loan programs for the Grantee. The
programs include CDBG and UDAG, as well as Section
108.
Because the Grantee did not thoroughly review the transfer
of its assets from the defunct Camden Economic
Development Corp. (CEDC) to CBAC, at least $251,400 in
CDBG funds have been misclassified as from other sources.
In 1993, the Grantee had an independent accountant
perform an analysis of all loans and funds at CEDC. The
analysis clearly identified $251,400 in unexpended CDBG
funds. Despite the analysis, HUD was advised that all of the
assets transferred to CBAC were from non-CDBG sources.
As a result, the Grantee has little assurance that the funds
will be used in accordance with CDBG regulations and that
the mandated program objectives are met. As a result of
our review, these funds are now available for program use
Page 15 96-NY-241-1005
Finding 3
and are considered to be a "cost efficiency" for report
purposes.
Furthermore, we noted that CBAC has repeatedly
requisitioned CDBG funds for administration even though
it has significant amounts of funds in its accounts. As of
December 31, 1995, CBAC had $183,000 in its
administrative cash account and over $840,000 in cash from
all sources. The Grantee must monitor CBAC's requests for
administrative funds and require full disclosure of all
funding sources.
3. Jersey Counselling & Housing Development (JCHD)
JCHD is implementing the $1,495,051, 1994 HOPE 3 Grant
for the City. The grant is being used to develop home
ownership opportunities to 26 low income, first time home
buyers. Our review of the HOPE 3 grant showed that the
Grantee has not adequately addressed weaknesses
associated with JCHD.
JCHD has been delinquent in submitting annual audits of
operations to the Grantee. More significantly, the audits
submitted in 1991, 1992, and 1993, contain adverse
opinions by the independent auditor. The reports describe
JCHD's lack of adequate accounting records and an
inability to separate expenses by program. Despite the lack
of audits for 1994 and 1995, and no meaningful attempt to
address and correct issues raised in the prior audits, the
Grantee has continued to fund JCHD.
In addition to the unresolved audit problems, progress in
completing the grant activities has been slow. A January
1995, technical assistance visit from HUD cited the Grantee
for slow progress. HUD approved a one year extension to
facilitate property transfers. To date, only $129,973 of
HOPE funds have been expended with $94,613 of the
amount pertaining to administrative and other soft costs.
We believe that the results of our review and subrecipient
site-visits underscore the need for improvements in the
Grantee's monitoring of its HUD programs. Unless
corrective actions are implemented, the Grantee will not
96-NY-241-1005 Page 16
Finding 3
have adequate assurance that subrecipients are complying
with program regulations.
Recommendations We recommend that you instruct the Grantee to:
3A. Monitor program activities as required by Title 24,
Part 85 of the Code of Federal Regulations. The
monitoring should include procedures to ensure that
fiscal and performance reports are accurate and
submitted within prescribed time frames.
3B. Implement corrective actions that will bring the
financial management systems of the subrecipients
into compliance with program regulations.
We further recommend that you:
3C. Determine the eligibility of the unsupported costs of
$119,875.36 pertaining to the Morgan Village
Community Center, and the $43,685 associated with
T & C Development. The Grantee should reimburse
the programs from non-Federal funds for any
amount determined ineligible.
3D. Determine whether corrective actions are needed to
improve the Grantee's progress in completing its
HOPE 3 project.
3E. Advise the Grantee to implement actions to ensure
that CBAC's use of the misclassified CDBG funds
conform to program regulations and meet the
required National Objectives.
Page 17 96-NY-241-1005
Finding 3
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96-NY-241-1005 Page 18
Finding 4
Section 108 Loan Repayments Made Without
Complying With CDBG Regulations
The Grantee did not fulfill its commitment to use municipal appropriations to repay the Section
108 loan used to purchase a fire station located on Liberty and Mechanic Streets. Instead, CDBG
funds totaling $1,835,052 were used to make payments on the debt without filing the required
program amendments. The use of the CDBG funds remained undetected because adequate
accounting and program records were not maintained by the Grantee. Using CDBG funds in this
manner jeopardizes the Grantees ability to complete its approved activities, adversely affects
HUD's ability to evaluate the program's progress, and diminishes the rights of citizens to
participate in program matters.
Title 24, CFR Section 570.302 provides that a grantee must
Criteria
submit a final statement including a projected use of funds,
with a description of each activity in sufficient detail to
allow citizens to determine the degree to which they are
affected.
Further, Title 24, CFR Section 570.305 provides that
grantees shall provide citizens with reasonable notice of,
and opportunity to comment on, such proposed changes in
its use of funds.
In 1991, the Grantee received approval to use $3,000,000
Background and Scope
in Section 108 funds to purchase a fire station developed
and built by a nonprofit developer. The project was
designed to meet the criteria of economic development
through job creation and retention for moderate and low
income persons. According to the Section 108 application,
the loan would be repaid through annual municipal budget
appropriations with future CDBG grant funds serving as
security for repayment.
From the first repayment due in February 1992 through
February 1996, $2,235,052 has been paid on the debt. Of
the amount, $400,000 was from unspent funds remaining in
the Section 108 fund and $1,835,052 in CDBG funds. On
April 10, 1996, subsequent to our inquiries, the City
reimbursed the CDBG program with a $154,318 general
Page 19 96-NY-241-1005
Finding 4
fund check for" interest only" due on the loan for 8/1/95
and 2/1/96.
Our review included an examination of the Section 108
loan application, purchase agreements and other supporting
documentation. Specifics concerning our review are
discussed below:
The Grantee has not implemented effective financial
controls to account for any of the HUD grants it
administers. The Grantee has not established a general
ledger that records the receipt and disbursement of funds by
approved grant activity or program year. No receivable or
payable from the City has been established, nor was
$916,808 of the $1,835,052 in payments recorded. In
addition, the use of these funds was not fully reported in its
performance reports to HUD.
The remaining $918,244 in CDBG funds used for the
repayments were charged to various economic development
and public facilities activities identified in the applicable
final statements. For example, $462,300 was shown in the
1994 Grantee Performance Report as a special activity
related to debt service.
We discussed this matter with the City's Business
Administrator who agreed that the City had not made the
required payments. He said that he believed that the City
had only an obligation to repay the interest on the 108
notes. Contrary to his assertion, the Section 108 loan
application states that annual municipal budget
appropriations would be used to retire the Section 108 debt.
Moreover, a memorandum dated April 13, 1993, prepared
by the Business Administrator informing the Fire
Department that the CDBG program had advanced funds
for the repayment of the loan and must be reimbursed.
However, no action was taken.
We believe that the matters discussed in this finding
constitute violations of Title 24, CFR Sections 570.302 and
570.305 of the CDBG Regulations. The undisclosed use of
CDBG funds to repay the Section 108 loan could jeopardize
ongoing approved activities, as well as future ones.
Moreover, funding for prior and future program years could
96-NY-241-1005 Page 20
Finding 4
be over obligated. Without adequately prepared final
statements and the submission of program amendments,
citizens have not been provided with sufficient information
to allow them to determine the effect that the use of funds
to pay the City's debt will have on program activities.
Additionally, Title 24, Part 85.20 of the CFRs requires that
the grantee's financial management system have accurate,
current and complete disclosure of financial transactions
and that a grantee maintain records which adequately
identify the source and application of funds.
Recommendations We recommend that you require the Grantee to:
4A. Either reimburse the CDBG Program for the
$762,490 ($916,808 less the $154,318 City
reimbursement) related to the unaccounted for use
of program funds, or submit the appropriate
program amendments.
4B. Implement procedures to ensure that sufficient
financial management controls exist to properly
account for HUD funds and that will result in
accurate reporting of program progress.
Page 21 96-NY-241-1005
Finding 4
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96-NY-241-1005 Page 22
Finding 5
Inadequate Administrative Practices Resulted
in Uneconomical and Unsupported Use of
CDBG Funds
Effective administrative practices necessary to ensure that costs paid from grant funds are
allowable and reasonable have not been implemented. Consequently, the program has been
charged for costs that are not adequately supported, not necessary or reasonable, or that do not
meet the objectives of the program. The finding can be attributed to the absence of a grants
management structure that clearly defines lines of authority and communication.
OMB Circular A-87, Cost Principles for State and Local
Criteria
Governments provides that grantees are responsible for the
efficient and effective administration of grant programs
through sound management practices. In addition, Title 24
CFR, Part 85.40 provides that grantees are responsible for
managing the day-to-day operations of grant and subgrant
supported activities to ensure compliance with applicable
Federal requirements.
Apart from the above, the procurement of property and
services by grantees are governed by the requirements of
Title 24 CFR, Part 85.36.
We reviewed selected transactions that occurred during our
Scope of Review
audit period and extended the review to prior or subsequent
periods, where necessary. The review examined the
procurement and contracting processes used for the
transactions, the documentation supporting the costs related
to the transactions, and the allowability and reasonableness
of the expenditures.
Widespread weaknesses were found in the methods used to
Results of Review
procure and contract for services, to purchase supplies and
equipment, and in reviewing costs for allowability and
reasonableness. The weaknesses will be discussed generally
Page 23 96-NY-241-1005
Finding 5
in the subsections below, followed by specific costs that are
unallowable or not adequately supported.
Grantee Routinely Circumvents State Procurement Statutes
The Grantee routinely uses the "Extraordinary
Unspecifiable Services" (EUS) provision of State Statutes
to avoid bidding or competitive negotiations. We share the
concerns expressed in the State Treasurer's Report on
Camden that the use of EUS contracts is one of the most
troubling aspects of the purchasing system. Our review
found the following conditions:
• Sole or limited source designations were used to avoid
bidding even though it is obvious that the contracted
service was offered by numerous vendors in the
community. (See Finding 6 for example)
• Services to be provided were described as
"unspecifiable" even though the services were not of an
unusual nature and were of the type generally seen in
grant programs.
• EUS designations were used to approve contracts for
services already provided.
Payments Processed Without Executed Contracts
Our review of disbursements found several instances where
the Grantee paid for services without executing a contract.
This was particularly evident in the Department of
Community Affairs where at least fifteen vendors were
providing services without contracts. At least three of these
vendors were funded through the CDBG program.
Contract Provisions Are Poorly Defined
Many of the contracts reviewed during the audit did not
contain scope of services provisions that adequately
described the actual services to be performed. Instead, the
contracts contained similar boilerplate language and
references to attachments that consisted of little more than
budgetary information submitted by the vendor.
96-NY-241-1005 Page 24
Finding 5
Additionally, many of the contracts did not contain well
defined time frames in which the services were to be
performed.
Grantee Payment Advice Forms Improperly Prepared
Improvements are needed in the preparation of payment
Advices prepared by the Grantee to document the receipt of
goods and services. The Advice is one of the primary
documents used to support disbursements. Examples of
problems found included Advices that were not signed by
the receiver of the goods or services, and missing dates.
System of Purchasing Supplies and Equipment Needs
Improvement
Better control and coordination is needed between
departments purchasing supplies and equipment. Currently,
departments purchase supplies and equipment without
regard to collective purchasing procedures. As a result,
departments may be ordering supplies that are available or
stockpiled in other departments.
We also noted that program funds have been used to
purchase over $95,000 in computer equipment with little
evidence that the Grantee evaluated it needs prior to the
purchases. Much of the equipment purchased was far more
sophisticated than would be ordinarily needed, including
high-tech sound cards, stereo speakers, CD ROMs and a
preponderance of software. In addition, practically all work
stations contained laserjet or color jet printers.
We believe that more planning should be involved in
decisions to purchase expensive equipment to ensure that
only necessary items are purchased in amounts reasonable
to complete the required tasks.
During our review of controls over the disbursement of
Unallowable and
program funds we found certain expenditures that were
Unsupported costs
either not allowable or were inadequately supported. The
costs were incurred because effective procedures were not
established to ensure costs were eligible and supported prior
to incurrence.
Page 25 96-NY-241-1005
Finding 5
Grant Funds Used For Parades, Parties, Entertainment
Our review of program funds expended for public service
for the period January 1, 1995 through February 16, 1996,
showed that $47,309 was charged for entertainment type
costs. Examples of the costs included:
• Purchase of ten floats for the Christmas parade
($6,500).
• Television coverage of Holiday parade ($3,500).
• Purchase of pumpkins for pumpkin hunt event ($1,850).
• Two Senior citizen bus trips ($3,943).
While we realize the desirability of providing entertainment
to the residents of Camden, we believe that the grant funds
would be more beneficially used to improve the
deteriorating conditions of the City's neighborhoods.
We believe that a HUD determination as to the
reasonableness of the $47,309 in costs is needed. Further,
a HUD eligibility determination will be needed to ascertain
whether the activities meet the National Program objective
of low to moderate income designation, and represent a
public service as defined by 24 CFR, Section 570.201.
Contract For Intergovernmental Relations Services
CDBG funds were used to pay $35,000 to a consultant for
intergovernmental relations. We reviewed the necessity and
reasonableness of the costs, as well as the procurement and
work product produced. The review found several
deficiencies that render the costs as unallowable. Particulars
are as follows:
1. Services were deemed to be extraordinary and
unspecifiable, so no bidding or Request For
Proposals process was followed.
2. Contract for the services was prepared but never
executed.
96-NY-241-1005 Page 26
Finding 5
3. Scope of services provisions of the contract required
the contractor to perform many and varied services
over a 12 month period beginning July 1993.
However, the total contract was paid by August 6,
1993, with no evidence that most of the services
were provided.
4. Documentation supporting the services provided
consisted mainly of documents prepared prior to the
contract. Some of the documents were prepared as
early as 1992.
5. Documents prepared after the contract award were
all dated in July 1993. The documents were of
questionable value since they consisted of press
releases, newspaper articles, and photocopied faxes
of an evaluation of the Community Development
Banking Act of 1993, performed by an unrelated
entity.
6. Evidence that any of the materials or services were
used by the Grantee could not be found. Grantee
personnel were unable to demonstrate the
reasonableness, use, or need for the services.
Accordingly, we consider the $35,000 to be
unallowable since it does not represent a necessary
and reasonable expense to the program.
Services Provided Without Executed Contract
We consider costs amounting to $24,800, paid to two
vendors without the benefit of competition or executed
contracts to be unsupported. Particulars are as follows:
Contract 11-95-281 (Payment $10,000)
Funds were paid to a weekly publication for unspecified
advertising of community affairs. The total contract is for
$14,000, disbursed at a rate of $1,750 to $2,000 per month.
Contract 6-95-134 ($14,800)
Page 27 96-NY-241-1005
Finding 5
Funds were paid to a music school for an unspecified music
program. The payments were made between August and
December 1995.
Recommendations We recommend that you require the Grantee to:
5A. Cease its practice of routinely designating contracts
as extraordinary and unspecifiable unless it can
adequately document the condition.
5B. Implement procedures to ensure that goods and
services are procured according to HUD
requirements.
5C. Institute contracting procedures that will ensure that
all services procured are supported by an executed
contract containing a detailed scope of services and
performance time frames.
5D. Implement controls to ensure that costs are eligible,
reasonable, and documented prior to payment.
5E. Adopt policies and procedures that will control and
coordinate the purchase of supplies and equipment.
Prior to the purchase of equipment, the Grantee
should carefully analyze it's needs to ensure that the
appropriate items are purchased.
5F. Reimburse the program with non-Federal funds for
the unallowable cost of $35,000.
5G. Provide justification or documentation on the
unsupported costs to enable the necessary eligibility
determinations to be made.
5H. Reimburse the program with non-Federal funds for
any of the unsupported costs found to be ineligible.
96-NY-241-1005 Page 28
Finding 6
Improvements Needed in the Administration
of Housing Rehabilitation Programs
The Grantee has incurred high delivery and administrative costs under its housing rehabilitation
programs. We attribute the high cost to inefficient management caused by the absence of an
effective organizational structure. As a result, we are questioning the reasonableness of certain
personnel costs charged to CDBG and are recommending procedural and procurement
improvements to lower the cost of delivering rehabilitation activities.
The Grantee's rehabilitation programs are administered by
Background
the Division of Housing Services (DHS), a component of
the Department of Housing and Community Development.
DHS administers four single family programs, one HOME
First Time Home Buyers Program, and oversees a
subrecipient's administration of a HOPE 3 project.
DHS charges the salaries of ten employees directly to
rehabilitation delivery costs for processing applications for
assistance. In addition, DHS contracts with five consultants
who perform initial inspections and prepare work write-ups.
Further, administrative costs are charged for 100 percent of
the Commissioner of the Department of Housing and
Community Development and two of his support staff,
despite the fact that they provide minimal administrative
support.
We randomly selected 36 of 163 rehabilitation cases
Scope of Review
completed during the 1995 program year. The examination
included an analysis of the processing and a review of
documentation contained in the case files. Moreover, we
selected 12 of the cases for inspections to determine if the
rehabilitation had been successfully completed.
Apart from the above, we analyzed program delivery and
related administrative costs charged to the CDBG program.
Page 29 96-NY-241-1005
Finding 6
We also reviewed the procedures used to select consultants
and evaluated the reasonableness and necessity of the cost.
Our case file reviews and property inspections found that
Results
the cases were processed in accordance with the Grantee's
procedures and that all the required rehabilitation work had
been performed. However, we found that the Grantee has
incurred an inordinate amount of costs to administer and
deliver its rehabilitation programs. Further, we found
weaknesses in the procurement methods used to employ
consultants. The weaknesses are discussed in detail below.
High Program Delivery Costs
Our analysis of the program charges related to delivery of
the rehabilitation programs found that the costs exceeded
the established national average reported in CPD-91-22,
Productivity Guide for CDBG Rehabilitation Programs. For
example, the delivery costs for single family and HOME
programs for 1995, were 32.59 percent of the total funds
expended. Conversely, the Productivity Guide established
22 percent as a national average.
While we recognize that the Productivity Guide is not an
absolute criteria on which to solely base conclusions, we
believe it is a useful measure of productivity. Especially,
considering the simplistic nature of the rehabilitation
programs administered by the Grantee and the relatively
moderate work load in process.
The high delivery costs can in part be attributed to the use
of consultants in addition to the ten employees assigned to
DHS. We believe that this arrangement may not be efficient
or economical. Moreover, the Grantee's current
organizational structure does not provide a system of
checks and balances needed to ensure that the cost of
administering activities is reasonable. The Grantee should
determine if duplications of effort are occurring and
whether more productivity should be expected of its staff.
Administrative Costs Related to Rehabilitation Are
Excessive
96-NY-241-1005 Page 30
Finding 6
Apart from the delivery cost, we noted that the full salary of
Administrative costs are
the Commissioner and his support staff totaling $124,132
unsupported
for 1995 was charged to the CDBG program.
Our review of these charges showed that they were not
reasonable and could not be supported. Our determination
is based on the organization structure of the Department of
Housing and Community Development. Contrary to the
Departments name, it does not administer all CDBG
programs, but is limited to the rehabilitation programs
identified above. DHS is only one of five bureaus under the
auspices of the Commissioner and his support staff.
Four of these bureaus employing over forty people perform
City, not CDBG duties (Examples, include rent control,
licensing and inspections, etc.). We found little
documentary evidence to justify the charges, and believe
that actual administrative duties performed by the
Commissioner take up a proportionally small amount of his
time. Accordingly, we consider the charges to be
unsupported pending a HUD determination identifying the
correct allocation of costs to CDBG.
Reassigned DHS Employee Charge to Program
Our review of payroll transactions found that the CDBG
program has been charged $3,874.40 in salary costs for a
DHS employee transferred to the Bureau of Licenses. Since
the Bureau of licenses does not perform CDBG eligible
activities, the salary is not an allowable charge to the
program.
Reasonableness of Costs Related to Consultant Services
Not Supported
During the period under review, the Grantee entered into
contracts with five consultants to provide rehabilitation
work write-ups and perform inspections. The aggregate
amount of the contracts totalled $103,000.
Our review showed that the Grantee has not established
effective procedures as required by Part 85.36 of the
Regulations. The Grantee avoided the bidding requirements
established by the New Jersey State statutes by declaring
Page 31 96-NY-241-1005
Finding 6
the contract work as "extraordinary and unspecifiable".
Moreover, the Grantee certified to the City Council that this
type of contract was required because of "scarce
availability" of firms available to bid on the work. The mere
fact that five consultants were involved in the contract work
seems to dispute this contention.
In addition to the above, we found that the contracts
executed with the consultants were not applicable for the
services to be rendered. The contracts used were identical
in form to contracts executed with subrecipients and
contained many nonapplicable clauses. Examples of clauses
included program income, relocation, acquisition and
disposition of real property, etc.
In summary, the weaknesses and deficiencies discussed in
this finding have unnecessarily increased the costs of
administering the Grantee's rehabilitation programs. Close
adherence to the provisions of the CDBG regulations, State
of New Jersey statutes, and the cost provisions of OMB
Circular A-87 will enable the Grantee to establish a reliable
system to evaluate the reasonable of costs.
Recommendations We recommend that you require the Grantee to:
6A. Reimburse the program with non-Federal funds for
the ineligible salary costs of $3,874.40.
6B. Provide all documentation on the unsupported and
excessive administrative costs to enable the
necessary eligibility determination to be made.
6C. Reimburse the program with non-Federal funds for
the unsupported costs found to be ineligible.
6D. Assess the cost that it is incurring to deliver the
rehabilitation programs and streamline the process
to ensure that delivery costs are reasonable.
6E. Adopt procurement procedures that will result in
open competition and ensure that costs attributed to
consultants are necessary and reasonable. Also,
96-NY-241-1005 Page 32
Finding 6
ensure that the contracts executed with consultants
contain only applicable clauses.
Page 33 96-NY-241-1005
Internal Controls
In planning and performing our audit, we evaluated internal management controls with respect
to selected auditing procedures. The evaluation was not intended to provide an opinion on the
overall adequacy of the internal controls.
Internal controls are management's adopted plan, methods and procedures to assure resource use
is consistent with laws, regulations, and policies; resources are safeguarded against waste, loss,
and misuse; and reliable data are obtained, maintained, and fairly disclosed in reports.
We determined that the following internal control
Relevant Internal
categories were relevant to our audit objectives:
Controls
• Controls over cash receipts and disbursements.
• Controls over the monitoring HUD programs.
• Controls over procurement and contracting.
• Controls over supporting documentation for costs.
• Controls over property and equipment.
A significant weakness exists if internal controls do not
give reasonable assurance that: (a) resource use is
consistent with laws, regulations, and policies; (b) resources
are safeguarded against waste, loss and misuse; and (c)
reliable data are obtained, maintained, and fairly disclosed
in reports.
Our review found significant weaknesses in all of the
internal controls tested. The control weaknesses are detailed
in the six findings contained in this report.
Page 33 96-NY-241-1005
Internal Controls
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96-NY-241-1005 Page 34
Follow Up On Prior Audits
An audit of the Grantee was performed by an Independent Auditor (IA) for the period ended June
30, 1995. The report contained one audit finding pertaining to the Grantee's inability to reconcile
its accounting records with various Federal and State Funding documentation. This finding was
repeated in both the 1993 and 1994 audits. To date, meaningful corrective actions have not been
implemented.
Page 35 96-NY-241-1005
Follow Up On Prior Audits
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96-NY-241-1005 Page 36
General Comment
In December 1994, President Clinton announced the designation of the Philadelphia/Camden
Empowerment Zone (EZ) . Camden's portion of the $100 million funding is $21 million. The
Camden Empowerment Zone Trust Commission is the governing structure and consists of 35
members made up of community residents.
Since receiving the designation, progress in implementing the program has been slow. The
reasons for the slow progress are varied, but tend to mirror the organizational problems impeding
the administration of other HUD programs.
To accelerate the progress, HUD, the Grantee, and the State of New Jersey has begun to
implement actions to improve the administration and delivery of EZ funds to the City. In this
regard, a non-profit organization called the Camden Empowerment Zone Corporation has been
established, a Board of Trustees have been appointed, and By-Laws have been adopted. It
appears that these actions have put the implementation of the EZ back on schedule and should
result in a successful implementation of program activities.
Page 37 96-NY-241-1005
General Comments
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96-NY-241-1005 Page 38
Appendix A
Schedule of Ineligible and Unsupported Costs,
and Cost Efficiencies
Finding Cost
Number Ineligible (1) Unsupported (2) Efficiency (3)
3 $163,560 $251,400
4 $762,490 918,244
5 35,000 72,109
6 3,874 227,132
Total $801,364 $1,381,045 $251,400
(1) Costs clearly not allowed by law, contract, HUD or local agency policies and regulations.
(2) Costs not clearly eligible or ineligible but warrant being contested (e.g. lack of satisfactory
documentation to support the eligiblity of the costs, etc.).
(3) A cost efficiency is an action by management in response to the Inspector General's
recommendations to prevent improper obligation or expenditure of funds or to avoid further
unnecessary expenditures.
Page 39 96-NY-241-1005
Appendix A
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96-NY-241-1005 Page 40
Appendix B
Auditee Comments
Page 41 96-NY-241-1005
Appendix B
96-NY-241-1005 Page 42
Appendix B
Page 43 96-NY-241-1005
Appendix B
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96-NY-241-1005 Page 44
Appendix C
Distribution
Secretary's Representative, 2AS, New York/New Jersey
Director, Community Planning and Development Division, 2FD (2)
Director, Accounting Division, 2AAF, New York/New Jersey
Special Assistant, 2FS, New Jersey State Office (3)
Assistant to the Deputy Secretary for Field Management, SDF,
Room 7106
Office of the Deputy Assistant Secretary for Grant Programs, DG
(Attention: Audit Liaison Officer, Room 7212) (3)
Acquisitions Librarian, AS (Room 8141)
Chief Financial Officer, F, Room 10164 (2)
(Acting) Deputy Chief Financial Officer, FF Room 10166 (2)
Associate General Counsel, CD, Room 8162
Field Comptroller, Midwest Field Office, 5AF
Assistant Director in Charge, US GAO, 820 lst Street NE, Union
Plaza, Building 2, Suite 150, Washington, DC 20002 (2)
Mayor, City of Camden, Camden, New Jersey
Commissioner, Department of Development and Redevelopment, City of Camden, New Jersey
Page 45 96-NY-241-1005
City of Camden, Camden, NJ
Published by the Department of Housing and Urban Development, Office of Inspector General on 1996-09-06.
Below is a raw (and likely hideous) rendition of the original report. (PDF)