Letter from the U.S. Department of Housing and Urban Development

7/28/2019 Letter from the U.S. Department of Housing and Urban Development

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U.S. Department of Housing and Urban Development,* * Honolulu Field Office Region IXIII II 1132 Bishop Street, Suite 1400

I Honolulu, Hawaii 96813-4918www.hud.govespanol.hud.gov

June 3, 2013

The Honorable Kirk CaldwellMayor -City and County of Honolulu530 South King Street, Room 300Honolulu, HI 96813 c

Dear Mayor Caidwell ,SUBJECT: On-Site Program MonitoringCommunity Development Block Grant (CDBG)April 11-25, 2011 and May 2013 Follow-up

This is in response to the City and County of Honolulus (City) letter datedJanuary 31, 2013, regarding its subrecipient, Opportunities and Resources, Inc. (ORI) AnuenueHale, and its two projects known as the Anuenue Hale Aloha Gardens project and the CampPineapple 808 project. In April 2011, th e HUD Honolulu Field Office conducted an on-sitemonitoring of the Citys CDBG program. The review focused on four areas of compliance:(1) property acquisition and use; (2) record keeping; (3) public service costs; (4) financialmanagement and oversight. The monitoring and follow-up monitoring resulted in eight findingsrelated to ORI and two conflict of interest issues involving City management and staff.

The attached enclosure summarizes HUDs findings and the recommended correctiveactions in accordance with 24 CFR 570.9 10. A finding is a determination of non-compliancewith a program regulation and requires corrective action. A concern is a deficiency in programperformance; a concern is not statutory, regulatory, or a program requirement. To close thefinding noted herein and the 2011 open ORI finding, the City has 45 days from the date of thisletter to comply with the corrective actions.As part of HUDs on-going efforts to assist the City in managing its CDBG funds HUDhas selected the National Association for Latino Community Asset Builders (NALCAB), a HUD

approved CDBG technical assistant provider, to provide CDBG technical assistance to the City.The NALCAB has made initial contacts with Ms. Holly Kawano of your staff to arrange thetechnical assistance. HUD anticipates the NALCAB will begin its on-site technical assistancelate June or early July 2013.


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The Honolulu Field Office appreciates the cooperation and courtesy provided by yourstaff during the reviews and are available to provide program technical assistance as needed. Ifyou have any questions regarding this report, please call me at (808) 457-4678.

Sincerely,

Mark A. ChandlerDirectorCommunity Planning and DevelopmentHUD Honolulu Field Office

Enclosurecc:Mr. Nelson Koyanagi (w/enclosure)Director, ActingDepartment of Budget and Fiscal ServicesCity and County of Honolulu530 South King Street, Room 208Honolulu, HI 96813Ms. Pamela Witty Oakland (w/enclosure)Director DesignateDepartment of Community ServicesCity and County of Honolulu715 South King Street, Room 311Honolulu, HI 96813Ms. Holly Kawano (w/enclosure)Federal Grants CoordinatorDepartment of Budget and Fiscal ServicesCity and County of Honolulu530 South King Street, Room 208Honolulu, HI 96813


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EnclosureMONITORING REPORT - May 2013

This report is based on documentation provided by the Citys Department of Budget andFiscal Services including letters dated April 5, 2012, July 31, 2012, October 31, 2012, andJanuary 31, 2013, regarding open monitoring findings related to the Citys subrecipientOpportunities and Resources, Inc. (ORI) Anuenue Hale. ORI received CDBG assistance todevelop the Aloha Gardens Project with two facilities (Wellness Center and Camp Pineapple808). Both facilities have failed to meet the CDBG Program national objective requirement.HUD has also advised the City of additional project issues that are ofmajor concern and so notedin this report.CPD Finding 1: Non-Compliance with a CDBG National Objective

In 2003, the Citys subrecipient, ORI, used CDBG funds to acquire 30 acres of land andconstruct the Aloha Gardens Wellness Center and the Camp Pineapple 808 facilities.Acquisition is an eligible CDBG activity under 24 CFR 570.20 1(a). The purpose of the facilitieswas to serve elderly and developmentally disabled persons, which are presumed benefitcategories under the CDBG national objectives at 24 CFR 570.208(a)(2). Despite the proposedcompliance with the national objective, ORI used and marketed Camp Pineapple 808 toindividuals and organizations that did not exclusively serve the elderly and d isabled. TheWeilness Center was a lso underutilized in this regard.Criteria:

This activity does not qualify under the national objective of limited clientele presumedbenefit. In order to meet this requirement, an activity must exclusively serve a group of personsin the following categories: abused children, battered spouses, elderly persons, adults meetingthe Bureau of Census Current Population Reports definition of severely disabled, homelesspersons, illiterate adults, persons living with AIDS, and migrant farm workers, as set forth in24 CFR 570.208(a)(2)(A).Condition:

HUD acknowledges that the City has worked with ORI for the last two years in anattempt to increase the appropriate use ofAloha Gardens (Weilness Center and Camp Pineapple808 facilities) to ensure compliance with the CDBG national objective of serving the elderly anddevelopmentally disabled adults. The City indicated that ORI provides services to a sufficientnumber of seniors and clients with disabilities at the Wellness Center. In addition, the City hasconfirmed that Camp Pineapple 808 has served more clients bymoving day clients from theWellness Center to Camp Pineapple 808.


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For the quarters ending June 30 thru December 2012, the City reported Camp Pineapple808 use as follows:1. Increased its number of overnight eligible clients to 30 users per month, but the usewas primarily day usage .2. The actual overnight usage by the eligible clients was 56 clients fo r two overnightstays in July,3. No actual overnight use in August and September 2012, and4. Fifty-six (56) clients used the facility for two overnight stays in November 2012.

Based on these facts , ORI failed to meet the 25-person per-night standard used to justify theCDBG eligibility of the projects.In May 2013 HUD noted, ORI reinstated its marketing of Camp Pineapple 808 to thepublic for weddings, parties, banquets, fundraisers, corporate retreats, conferences and familyreunions despite failing to meet a CDBG national objective and in direct conflict of its CDBG

subrecipient agreement. ORIs advertisement can be found easily on the on the internet atwww.carnppineapple808.com and is being implemented at the same time the City is reportedlyconducting regular ORI CDBG compliance reviews. ORIs noncompliance and the Citys failureto report the noncompliance raising serious questions about the C itys ORI CDBG compliancereviews.Cause:

Since 2003, the City and ORI have documented ORIs obligation to comply with theCDBG requirements related to the CDBG national objective and eligible use requirements forthe CDBG-assisted Aloha Gardens facilities. The City wrote ORI reminding it of its obligationto serve exclusively the elderly and disabled persons, and ORI regularly acknowledged theserequirements. However, the City took and continues to take no action to enforce its writtenrequirements and ORI operated and continues to operate the facilities in non-compliance with theCDBG national objectives requirements.Effect:

After extensive follow-up analysis of the Citys ORI Aloha Gardens project records, staffand management interviews, and Aloha Gardens program implementation over the last seven toten years, HUD has concluded that there is insufficient documentation or records to demonstrateprogram compliance with a national objectives as required by 24 CFR 570.208, and 570.506.Additionally, records available support the conclusion that the City will no t enforce and takeaction to ensure CDBG program compliance on ORIs CDBG assisted projects.


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Corrective Action:1. The City is advised to reimburse its CDBG program $7,924,850 with non-federal funds.2. Until the funds are repaid to the CDBG program the City must record the $7,924,850

payable to the CDBG program as an accounts payable in its accounting records fordisallowed program costs.

3. Upon receipt of the funds in to the City s local CDBG account, the C ity must revise theIDIS draws and cance l the Aloha Gardens activities. The funds sha ll be noted as a returnof grant funds and must be promptly reprogrammed for other CDBG-eligible activities.


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CPD Finding 2: Acquisition and Construction PaymentsCriteria:

HUD regulations at 24 CFR 570.506(h) require grantees to maintain documentation offinancial records in accordance with the requirements at 24 CFR 570.502(b). This includesrecords of a subrecipients CDBG expenditures. Such documentation must include, to the extentapplicable, invoices, schedules containing comparisons of budgeted amounts and actualexpenditures, construction progress payments (signed by appropriate parties, e.g., generalcontractor and/or a project architect), and/or other financial documentation appropriate to thenature of the activity.In accordance with 24 CFR 570.502 and 503 CDBG recipient and subrecipients arerequired to comply with uniform administrative requirements and cost principles in theirexpenditure of CDBG funds. All cost reimbursements are subject to federal cost principlesapplicable to the particular organization, If a sub-award is provided to a non-profit organization,Circular A-122 shall apply; if a sub-award is provided to a State or local government, CircularA-87 shall apply. Costs must be allowable, reasonable, and allocable.

Condition:The City authorized $7,924,850 in CDBG payments for the Aloha Gardens project.Analysis of the payments (Table 1) revealed construction contract payments for the AlohaGardens project included work that d id not pertain to CDBG activities/projects. ORI usedCDBG funds to pay for cos ts not associated with the CDBG-assisted Aloha Gardens project,payment requests were not detailed enough to confirm the costs were attributable to theCDBG-assisted sites and therefore, these costs are disallowed.

Cause:The City d id not have adequate oversight of the Aloha Gardens project. Contracts andpayment requests that included CDBG and non-CDBG sites usually did no t break down the costbetween the sites and, on occasion, ORI submitted to the City payment application numbers forconstruction related costs that were not sequential or were missing from the Citys files.

Effect:The Citys processing of misidentified project sites and failure to identify sites properly

raise serious concerns about the reliability of the CDBG payments, prevent CDBG fundaccountability, and raise the likelihood of duplicate/overlapping payments. In addition, the Cityand ORIs use of CDBG funds on the private residence and ORI Housing Duplex subject theseproperties to CDBG program requirements.Corrective Action:

Resolution of this finding is subject to completion of the corrective action in Finding 1.


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CPD Finding 3: Property Acquisition Unpermitted Parking LotCriteria:

As set forth in 24 CFR 570.502 and 503 , CDBG grantees and subrecipients must complywith the policies, guidelines, and requirements of the uniform administrative requirementscodified at 24 CFR 85 for governments and 24 CFR 84 for nonprofits, and the costs principles in0MB Circulars A-87 for governments and A-122 for nonprofits. Costs must be allowable,reasonable, and allocable to federal funds.Condition:

The City authorized ORI to acquire a, City Department of Planning and Permittingidentified illegal, three-acre parking lot adjacent to ORIs Planation Hale project with CDBGfunds for a training facility for mentally challenge clients. In April and December 2003, theCitys Department of Community Services affirmed the unpermitted status of the parking lot andnotified ORI that property could only be used for ingress and egress. The ORI acknowledgedand agreed to replace the parking lo t with landscaping but reversed its decision and kept theparking lot, in spite of being in violation of the Citys permits.Cause:

The City took no action toward enforcing its own land-use requirements, thus allowingthe parking lot acquisition to proceed as if it were a permitted parking lot. The City did not actto enforce the CDBG or its local requirements.Effect:

The City and ORI knowingly used $597,780 in CDBG funds to acquire property inviolation of local land-use law resulting in an overpayment and ineligible use of CDBG funds.Corrective Action:

Resolution of this finding is subject to the corrective action in Finding 1.


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CPD Finding 4: Property Acquisition Cost ReasonablenessCriteria:

CDBG regulations at 24 CFR 570.6 10 require CDBG grantees and subrecipients tocomply with uniform administrative requirements and cost principles as set forth at 24 CFR570.202. All cost reimbursements are subject to those federal cost principles applicable to theparticular organization. If a sub-award is to a non-profit organization, Circular A-122 shallapply; if a sub-award is to a State or local government, Circular A-87 shall apply. Costs must beallowable, reasonable, and allocable.

Grantees and subrecipients must establish the costs basis for real property transactionsand are advised by HUD to obtain appraisals of the market value of the property to determine thecost-reasonableness of the asking price or proposed sales offer price. Appraisals must meetrequirements of 49 CFR 24.103. There is a three-step process for determining justcompensation:

1. Appraiser estimates propertys fair market value;2. Review appraiser evaluates appraisal; used as basis for estimate of just compensation;and3. Agency establishes the estimate of just compensation to be offered (may no t be less thanthe approved fair market value).

Condition:The City authorized a $597,780 CDBG payment for an unpermitted parking lot, failed toensure the property appraisal was based on the City permitted use of the site (agricultural), and

permitted ORI to use CDBG funds to pay nearly eight (8) times the cost of a similarly zonedproperty adjoining the site.Cause:

Based on records available for review it appears the City and ORI did no t notify theappraiser that the parking lot was unpermitted even though the City documented and advisedORI that th e parking lot had to be removed and that the three acres could only be used for ingressand egress to the Helemano training facility.Effect:

It is appears the City and ORI used CDBG funds to pay more than the fair-market valuefor the acquired property, raising serious questions about the C ity and ORIs use of CDBGfunds.Corrective Action:

Resolution of this finding is subject to the corrective action in Finding 1.


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Public Service CostsIn addition to the $7.9 million in CDBG funds to construct the Aloha Gardens project, theCity awarded CDBG public service funds to ORI to provide services to persons with physicaland mental disabilities. HUD s review of the Citys CDBG public service agreements with ORI

and CDBG expenses revealed issues resulting in the CDBG program finding below.CPD FindingS: Public Service Costs and ExpendituresCriteria:

In accordance with 24 CFR 570.506(h) grantees are required to maintain evidence tosupport how subrecipients use CDBG funds. Such documentation must include, to the extentapplicable, invoices, schedules containing comparisons of budgeted amounts and actualexpenditures, construction progress schedules signed by appropriate parties (e.g., generalcontractor and/or a project architect), and/or other documentation appropriate to the nature of theactivity.

CDBG regulations at 24 CFR 570.6 10 require CDBG grantees and subrecipients tocomply with uniform administrative requirements and cost principles in their expenditure ofCDBG funds. All cost reimbursements are subject to those federal cost principles applicable tothe particular organization. If a sub-award is to a non-profit organization, Circular A-122 shallapply; if a sub-award is to a State or local government, Circular A-87 shall apply. Costs must beallowable, reasonable, and allocable.Condition:

HUDs follow-up review of the Citys public service subrecipient agreements with ORIrevealed that the City authorized payment to ORI for questionable and ineligible CDBGexpenses, as follows:City SubrecipientContract # Expense Amount Public Service Cost EligibilitF76820 Grant Research $6.000.00 Ineligible

F76820 Start Up $25,000.00 QuestionableF76820 Administration $20,000.00 IneligibleF84461 - FY2004 Office Rent $37,800.00 QuestionableF84461 - FY2004 Office Supplies $12,000.00 QuestionableF84461 PY2004 Auto Lease $12,000.00 IneligibleF84461 - FY2004 Auto Insurance $2,500.00 IneligibleF84461 - FY2004 Medical Clerk $21,600.00 QuestionableF84461 - FY2004 Medical Director/Consultants $45,449.00 QuestionableP84461 - FY2006 Office Rent $18,900.00 QuestionableF84461 - FY2006 Office Supplies $2,931.00 QuestionableF8446 1 - FY2006 Auto Lease $7,200.00 IneligibleF8446 1 - FY2006 Auto Insurance $300.00 IneligibleF8446 1 - FY2006 Medical Director/Consultants $15,000.00 QuestionableTotal Ineligible &Questionable Cost $226,680


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Cause:Analysis of the Citys records revealed that the C ity d id not analyzed ORIs proposedCDBG public service budget for program eligibility and cost reasonableness. As a result, theCity authorized, through budgets incorporated as part of th e ORI public service subrecipientagreement, ineligible and questionable CDBG expenses.

Effect:The Citys records fail to demonstrate that payments to ORI under the public service

subrecipient agreements were direct costs for implementing a public service activity, resulting inineligible and questionable CDBG program payments that include, but are no t limited to, grantresearch and management fees.Corrective Action:

The City needs to reimburse, with non-federal funds, the CDBG program for $226,680 orprovide supporting documentation for the eligibility of the CDBG expenditures on the publicservices costs identified by HUD as ineligible or questionable.


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Loan ForgivenessIn addition to the $7.9 million in CDBG funds to construct the Aloha Gardens project, theCity awarded and loaned $815,000 and $350,000 in 1989 and 1995, respectively, in CDBG fundsto ORI for its Helemano Planation facilities to provide services to persons with physical and

mental disabilities. On July 26, 2010, and October 15, 2010, the $815,000 and $350,000 loanagreements were amended to forgive ORI of its CDBG debt. O n April 26 , 2011, the Cityofficially canceled the notes payable. HUDs review of the Citys CDBG loan forgivenessrevealed issues resulting in the CDBG program finding below.

CDBG Finding 6: Loan ForgivenessCriteria:

CDBG grantees are responsible for ensuring that CDBG funds are used in accordancewith program requirements, 24 CFR 570.50 1(b). Grantees need to have systems and proceduresin place for the overall management of the CDBG program. Grantees must also provide for andencourage citizens to participate in the development of any consolidated plan and action plan,any substantial amendment to the consolidated plan and action plan, and the performance reportin accordance with 24 CFR 9 1.105. Finally, grantees must comply with HUDs conflict ofinterest requirements in accordance with 24 CFR 570.611(b) by preventing employees andelected officials with potential conflict of interests from exercising any function and authorityover CDBG activities.Condition:

The City made a decision to forgive ORI nearly $1.2 million in CDBG loans in whichCity employees, running for elected office, were directly involved in approving, developing, orrecommending the ORI CDBG loan forgiveness while receiving campaign donations from ORIrepresentatives. The financial relationship with ORI and City staff created a CDBG conflict ofinterest situation. The Citys decision to forgive ORI was out of the ordinary, not consistent withthe Citys practice to deny loan forgiveness, and processed without established loan forgivenprocedures raises further questions related to the conflict of interest and the decision to forgiveORIs CDBG loans.Cause:

CDBG regulations do not prevent the City from deciding to change a CDBG loan to agrant; however, the City is required to follow grants management, citizen participation, andconflict of interest requirements. City management did not follow the requirements and decidedto forgive ORIs CDBG loans despite the concerns raised by the Citys Budget Director in aDecember 18, 2009, memorandum that:

Noted loan forgiveness is not the normal position of Department of CommunityServices and raises concerns of favoritism and access to federal funds; and


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Suggested avoid being unfair to projects by considering forgiving loans goingforward and not forgive repayments that are already owed

The Citys failure to follow the CDBG process supports the Citys Budget Directorsconcerns of favoritism and access to federal funds, especially given the fact that the forgivenesswas finalized immediately after an election in which a conflict of interest existed.Effect:

The Citys decision to forgive ORIs $1.2 million loan and not follow the citizenparticipation and conflict of interest requirements resulted in th e loss of $1.2 million in potentialCDBG program income that could have been used for other CDBG projects to support the Cityslow- and moderate-income citizens.Corrective Action:

1. The City needs to, immediately, reinstate the ORI loans and interest due until it issues apublic notice and complies with the 30-day comment period advising the public of theCitys ORI loan forgiveness, including the total amount forgiven (loan and interest) andthe situation involving the ORJJCity conflict of interest.

2. The City needs to provide HUD with a copy of the public notice and accounting entriesreinstating the ORI CDBG loan and interest account payable addressing CorrectiveAction 1 above.

3. The City needs to provide a copy of the Citys loan forgiveness policy to its subrecipientsthat currently have an outstanding CDBG loan with the City and provide HUD with acopy of the subrecipients written receipt of the policy.


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CPD Concern 1: Failure to Follow Up on Possible Program ViolationsCriteria:

As a recipient of CDBG funds, the City is obligated to administer its grant in accordancewith Subpart J, Grant Administration [24 CFR 570.500 series], and Subpart K, Other FederalRequirements [24 CFR 570.600 series], and related provisions.Condition:

HUD found many questionable management decisions regarding the Citys oversight ofORI that revealed the Citys standard oversight and enforcement practice towards ORT was alimited or no action approach toward program enforcement. A few of the no action issuesare as follows:

The City files contained a September 22 , 2004 letter from ORI documenting that it hadnegotiated a $90,000 payment from the contractor in exchange for a $5.3 million CDBGcontract. Despite possible violation of the anti-kickback of the CDBG program, the Citytook no action to address the issue until HUD, after obtaining the document, provided acopy to the letter to the Citys Budget Director nearly seven (7) years after the Cityreceived the ORI letter.

The Citys Department of Planning and Permitting (DPP) advised the Citys Departmentof Community Services (DCS) that the Parking Lot acquired by ORI (using CDBGfunds) was illegal and would fall under the 15-acre Special Use Permit (SUP)limitations and recommended that the parking lot be eliminated. Despite ORIsagreement to the terms of the SUP, on or about August 30, 2004, ORI decided to keep theparking lot against the terms established by the City and the SUP and advised DCS of itsdecision. DCS took no action against ORI to enforce the Citys own SUP requirementsdespite knowledge of the Citys position that the parking lot is illegal.

In 2004 and 2007, the City reviewed ORI but failed to identify any noncompliance issuesalthough the Citys own files contained many documented noncompliance issues.Cause:

ORI has maintained significant support over many years by the direct involvement ofhigh ranking City and State officials regarding ORI s projects. The direct involvement of theofficials appears to have placed pressure on staff resulting in the City ignoring regulatoryviolations in favor of completing the project and satisfying ORIs requests.Effect:

The City cannot assure future ORI CDBG program compliance based on the Cityshistory of implementing a non-enforcement approach towards ORI.


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Corrective Action:1. The City needs to ensure proper authorities are reviewing the possible kickback situation.2. The City needs to train current City officials, staff, and management, including bu t no t

limited to, individuals that have and had a direct role in the oversight of the ORI AlohaGardens project on the Copeland Anti-Kickback Act 18 USC 874.3. The City needs to establish a system that will ensure subrecipient compliance with CPD

program requirements, as measured through a decrease in non-compliance CPD programfindings for the City and its subrecipients.


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Concern 2: Records Missing and WithheldCriteria:

HUD regulations found at 24 CFR 85.42(e) require grantees and subgrantees to provideaccess to records by the awarding agency and Comptroller General of United States, or any oftheir authorized representatives. HUD has the right of access to any books, documents, papers,or other records of grantees and subgrantees, which are pertinent to the grant, in order to reviewaudits, examinations, excerpts, and transcripts, and draw conclusions regarding questionablecosts.CDBG regulations at 24 CFR 570.506 require grantees to maintain records providing afull description of each activity assisted with CDBG funds. The records must demonstrate thateach activity undertaken meets one of the criteria for national objective set forth in 24 CFR570.208.

Condition:During the follow up monitoring the C ity withheld documents from HUD claiming

attorney-client privilege, and limited HUDs access to some of th e C ity s files. G iven the lackof documentation, HUD was unable to determine the exact circumstances that caused the C ity toalter its long-standing policy to no t approve requests for CDBG loan forgiveness in favor offorgiving $1.2 million in CDBG loans to ORI.HUD found that the C ity could not initially produce the ent ire ORI Aloha Garden projectfiles. City staff confirmed that 40 to 50 percent of the records were missing when initially

provided to HUD. After HUD inquired several times about the lack of ORI records and notedtha t the lack of records was ou t of character for the City, the C ity discovered more than fourboxes of records in a storage complex and produced them for HUDs review.The records produced contained gaps in information that occasionally spanned years andwere insufficient to demonstrate that the C ity reviewed expenditures for program eligibility.When questioned about the poor record keeping City management agreed that records

management needed improvement. Management suggested that the C ity could develop a systemsimilar to the system used by the Sta te of Hawaii Attorney Generals Office, which has a centralelectronic based system that tracks and scans all incoming, outgoing, and internalcommunications (email, memos, letters, e tc .) and is accessible by all staff involved in the project.Cause:

The Citys claim to withhold CDBG records from HUD by citing attorney-clientprivilege in direct conflict of the CDBG program regulations. Additionally, the Citys CDBGproject management is split between three and, in some cases four or five differentdivisions/departments. Finally, files created by the individual divisions/departments were notregularly shared between the divisions/departments.


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Although the City has attempted over several years to address file management issues,the attempts did not improve the Citys project file management because the system lacks acentral project documentation filing system that allows for cross divisionldepartment file access.Additionally, the system lacks the ability to track and scan all incoming, outgoing, and internalcommunications (email, memos, letters, etc.) to ensure a complete, and accurate project file andprevent the temporary or permanent loss of the project files.Effect:

The Citys initial lack of or missing ORI records and decision to prevent HUDsunencumbered review of the records reduces the Citys ability to assure HUD that it isimplementing the CDBG program within regulatory compliance and raises concerns about theintegrity of the Citys ORI records and the Citys overall recordkeeping system.Corrective Action:

1. The City must notify all subrecipients in writing of the subrecipients obligation toprovide HUD access to their records and that failure to do so is a violation of programregulations that could result in disallowance of the subrecipients CPD funds.

2. The City must provide HUD with a listing of the subrecipients notified and a copy of thenotice provided to the subrecipients.

3. The City needs to establish a centralized records system for documenting all grantsmanagement activity. Until the City establishes a centralized records system, the Cityneeds to maintain all documents generated for a CPD Annual Action Plan Activity(CDBG, HOME, HOPWA and ESG), regardless of the City division creating thedocument, within the department responsible for developing and submitting the CitysAnnual Action Plan (currently Budget and Fiscal Services).

Documents

Letter from the U.S. Department of Housing and Urban Development