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While not memorialized in writing, OHCD said historically, they were advised not to <br />interfere with private -party credit transactions. However, credits have significant potential <br />values. When used as intended, credits provide developers with a means to liquidity, <br />which in turn contributes to housing production. However, when bought and held, the lack <br />of liquidity means less overall capital investing in developments, and production suffers. <br />As public stewards, behaviors, actions, and decisions must be made in the public's best <br />interest. OHCD should have a solid understanding of credits' impact on production. <br /> <br />The program has underserved communities around the island. Excess credits are bought <br />and held for long periods rather than used to produce housing units. For OHCD to <br />successfully achieve its mission of providing affordable housing, foundational reforms <br />must accompany improvements to its internal control system. <br /> <br />While this audit discusses program deficiencies at length, our report intends to provide <br />OHCD with meaningful recommendations that, when implemented, will provide <br />department personnel, management, administration, elected officials, and the public with <br />reasonable assurance that the actual performance aligns with expectations. <br />Our report offers seven recommendations, including clarifying county code, establishing <br />administrative rules, updating and enforcing written policies and procedures, increasing <br />monitoring and program oversight, using technology as a monitoring tool, segregating <br />incompatible duties, and providing training. <br /> <br />In response to a draft of this report, management expressed general agreement with our <br />audit results. A copy of management's complete response can be found in Chapter 4. <br /> <br />We want to express our sincere appreciation to the Office of Housing and Community <br />Development for their assistance and cooperation during the audit process. We greatly <br />appreciate their valuable time and effort in providing us with information. <br /> <br />To improve government accountability and ensure audit recommendations are <br />implemented or resolved, we will continuously monitor the status of recommendations <br />using our remediation tracker. To view the department's status, visit us at: <br />https://www.Hawai`icounty.gov/our-county/legislative/office-of-the-county-auditor. <br /> <br />If you have any questions or concerns about the status of the recommendations <br />discussed, feel free to contact me at 961-8386. Thank you. <br /> <br />Respectfully, <br />Tyler J. Benner <br />County Auditor <br />