HUD letter requires response from city

The city of Dunkirk, and Mayor Anthony J. Dolce specifically, received a letter recently that requires a response within 30 days. The federal Department of Housing and Urban Development sent the letter in response to the city’s answer to findings in a HUD Fiscal Year 2011 CDBG Monitoring Report that was reiterated in the subject Single Audit Report.

“HUD is encouraged with the progress the city has made in addressing the outstanding findings,” the letter stated.

First Ward Councilman Michael Michalski brought up the letter during Tuesday’s council meeting.

“Is this being run through committee or department as far as their requirements?” Michalski asked.

“We met briefly on that,” Dolce replied.

Michalski asked how it would be handled.

“We can craft something and shoot it off to you guys to see if you have anything you’d like added or subtracted,” Dolce replied.

After the meeting Michalski said the letter was not the response from the state on its audit. He said the response had more specific requirements “that are better spelled out than when they initially cited us a few months ago, going back and getting specific as to what the requirements are to get a satisfactory rating from HUD.”

Michalski was asked if the city could still lose funding from HUD.

“That has still not been addressed but HUD specifically said as far as any funding still being in jeopardy or any funds being paid back, those are still not being addressed from HUD,” he replied. “We’re still pretty much waiting for that response from them. … We look forward to seeing how the mayor wants to address it. I just wanted to make sure that the public is aware of it. … I didn’t want it to fall through the cracks.”

The date of the letter is Feb. 28 and the city has 30 days from that date to reply. The city’s stamp indicates the letter was received March 6.

Included as categories in the letter were inadequate monitoring system for subrecepients; inadequate subrecepient agreements; reporting and accounting of program income; inadequate documentation of the affirmative steps taken to ensure minority business and women business enterprise to participate in government contracting; inadequate Consolidated Annual Performance and Evaluation Report; insufficient oversight and documentation of national objective for economic development activities and individual loans are not reported in IDIS.

The status of all six categories is listed as open and some requirements are either refined from the city’s response or added to the city’s response on corrective action required. Basically, HUD wants more paperwork to document what the city is doing with the CDBG funds it gets in the future, along with filling in gaps in previous records.

Things the city will be required to do include providing a complete dollar for dollar accounting of CDBG program income received to date and file required information on loan repayments, which must be made to the city treasurer and recording loan repayments into IDIS and reporting them on the city’s Federal Financial Report effective for the quarter ended Sept. 30, 2012.

Subrecepient agreements must be sent to HUD and subrecepients will be required by the city to attend Common Council’s Economic Development Committee meetings on a quarterly basis. The city also has to submit its fiscal year 2012 monitoring schedule and the standardized monitoring checklist it will use, along with the name of the contact person responsible for the monitoring.

The city must contact HUD’s equal opportunity specialist regarding MBE/WBE opportunities. The city also needs to develop a more formal job creation and employment reporting system for future monitoring of CDBG economic development activities. The city must also verify and document employment creation or retention for each of the current economic development projects and compute them on a full-time equivalent basis.

Dolce was asked Wednesday about the letter from HUD.

“We are in the process of addressing the remaining concerns HUD has with previous program year spending. As I stated in my State of the City address, we will have to pay or reprogram money to different CDBG activities. That amount is yet be determined,” he replied. “We are working diligently to address the outstanding issues and mitigate the damages with the assistance of our independent contractor.”

Dolce added that along with independent contractor Harry Sicherman, city CDBG Coordinator Tim Gornikiewicz is working to meet the requirements.

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