Finding Text
Federal Program Title: HOME Investment Partnership Program
Federal Catalog Number: 14.239
Federal Agency: Department of Housing and Urban Development
Category of Finding: Eligibility
Criteria: The City entered into loan agreements with developers to provide affordable housing within the
City using HOME Investment Partnership Program funds. The loan agreements contain continuing
compliance requirements to 1) restrict occupancy of the housing units to low-income or very low income
households, and 2) to limit the monthly rent to certain amounts, among other requirements. The City
should monitor the developer's compliance with these requirements. Pursuant to the Office of
Management and Budget (OMB) 24 CFR. Only low-income or very low-income persons, as defined in 24
CFR section 92.2, can receive housing assistance (24 CFR section 92.1). Therefore, the participating
including all persons in the household, as provided for in 24 CFR section 92.203. Participating
jurisdictions must maintain records for each family assisted (24 CFR section 92.508).
Condition: The City was unable to provide evidence that it has conducted any monitoring activities to
determine whether the developers were in compliance with the eligibility requirements.
Cause: Lack of internal controls and record maintenance over federal requirement for eligibility.
Effect or Potential Effect: Due to the lack of evidence, we were unable to obtain reasonable assurance
on the City's compliance with the eligibility requirement. As such, our opinion on this particular
compliance requirement is qualified.
Questioned Cost: None
Context: During the audit, we requested records to prove that individuals were eligible under the HOME
program, but the City was unable to provide such records.
Statistical Sampling Validity: Not applicable. No sampling was performed
Repeat of a Prior-Year Finding: No.
Recommendation: We recommend the City establish and design internal controls over eligibility, which
should include monitoring each developer's compliance with HOME requirements and maintaining copies
of records and reports submitted for the audit.
Management Response and Corrective Action Plan
City's Response: The City concurs with the recommendation.
Corrective Action Plan: The City will work with vendor to provide hard copies of all work done to
assist in compliance.
Planned Implementation Date: Implemented during Quarter 1 of Fiscal Year 2025