Item - 2021.AU9.16

The Audit Committee recommends that:

1.  City Council request the General Manager, Shelter, Support and Housing Administration, the Chief Planner and Executive Director, City Planning and the Executive Director, Housing Secretariat to consider the audit recommendations from past Auditor General reports included in Attachment 1 to the report (June 8, 2021) from the Auditor General and to implement any recommendations that are relevant to the broader context of affordable rental housing.

2.  City Council request the General Manager, Shelter, Support and Housing Administration, the Chief Planner and Executive Director, City Planning and the Executive Director, Housing Secretariat to consider how access plans, tenant selection, eligibility verification requirements and compliance monitoring can be incorporated and standardized in all agreements for affordable rental housing units.

3.  City Council request the General Manager, Shelter, Support and Housing Administration, the Chief Planner and Executive Director, City Planning and the Executive Director, Housing Secretariat, in consultation with the City Solicitor, to review template agreements for rental replacement and affordable housing developments to determine whether additional provisions are needed in any of these agreements to ensure appropriate tenant access, selection and eligibility for replacement rental housing and affordable rental housing units and to ensure compliance with such provisions.

In December 2020, City Council adopted a motion requesting the Auditor General to consider adding to the Auditor General's 2021 Work Plan an audit of previous replacement rental units to assess whether the CreateTO incident was an isolated issue and whether units were allocated in accordance with City policy.

This report provides a response to City Council's request.

It is the Auditor General's view that the City already has the roadmap it needs to strengthen how it administers new and replacement affordable rental units. Specifically,

1.  The Auditor General has already completed several audits along the housing continuum and made recommendations to support the City in how it provides access to affordable and deeply affordable housing so that the City can prioritize households who need assistance the most. Implementation of these audit recommendations will help strengthen how the City administers and oversees financial assistance for housing to ensure households are eligible and meet the spirit of the City's housing programs. The City should consider the findings and recommendations from these audits and apply them more broadly to affordable rental housing.

2.  City Planning has committed to reviewing compliance of existing agreements that secure replacement rental units in the third quarter of 2021 to verify that owners are advertising and filling units on a fair and open basis. The Auditor General's Office will consider the outcomes of City Planning's review.

3.  The Auditor General's 2021 Work Plan already includes operational reviews of City Planning and affordable rental housing in the project horizon for 2021-2022, contingent upon the availability of resources.

For these reasons, the Auditor General will not be updating her 2021 Work Plan to include a separate audit of replacement rental units.

At this time, the Auditor General recommends that as Shelter, Support and Housing Administration, City Planning, and the Housing Secretariat consider integrating and harmonizing processes and requirements for access to affordable rental housing and/or financial assistance for eligible households, they:

-  consider recommendations raised in previous Auditor General audit reports regarding the centralized social housing waiting list, rent-geared-to-income eligibility, and the affordable home ownership program; and

-  implement any relevant recommendations in the broader context of affordable rental housing (e.g., income and asset limits, eligibility assessments, income verification, etc.).

Attachment 1 includes a summary of recommendations made in those reports that may be of greater relevance. The Auditor General will assess whether further work is needed in this area after the City has implemented the above referenced recommendations.