Strengthen HEROS or internal procedures to add an additional requirement confirming that the mitigation resolutions have been uploaded at final endorsement.

Strengthen HEROS by adding a column on the dashboard to show the progress of the overall mitigation status.

Require the Englewood Apartments’ owner to repay HUD from non-project funds the projected $377,108 in housing assistance payments for tenants who were not eligible for assistance.

Require Englewood Apartments to support that $24,295 in unsupported housing assistance payments was eligible and accurate. Englewood Apartments’ owner should repay any subsidy overpayments to HUD from non-project sources. Further, the owner should reimburse tenants for overcharged rents or enter into a repayment agreement with tenants who were undercharged due to nondisclosure of income.

Require the Englewood Apartments’ owner to implement appropriate controls, including a formalized process, to use when conducting initial certifications and interim and annual recertifications to ensure that tenants are eligible, housing assistance payments are accurate, and tenant files contain all required documentation to comply with HUD’s and its own requirements. In addition, the updated controls should ensure a layer of management oversight to review all certifications before final approval until such time as onsite management is trained and has been proven to follow HUD’s and its own requirements.

Ensure that the owner, management agent, and staff complete training to ensure that they understand their duties, including HUD’s and local tenant eligibility and certification requirements.

Monitor Englewood Apartments to ensure that its staff properly maintains tenant files and completes required certifications in accordance with HUD’s and its own requirements.

Ensure that Englewood Apartments’ owner and its identity-of-interest management agent provide necessary oversight to its onsite staff.

Require Englewood Apartments’ owner to further develop a formalized process to use when running and reviewing EIV reports.

Require Englewood Apartments’ owner to ensure that the management agent and staff complete EIV training to ensure that staff members understand their duties and both HUD’s and Englewood Apartments’ own requirements.

Monitor Englewood Apartments to ensure that it properly runs and reviews the EIV reports.

Ensure that Englewood Apartments’ owner and its identity-of-interest management agent provide necessary oversight to its onsite staff.

Continue testing the financial and credit history variables, including default data, and include the appropriate reliable and sufficient variables for the cash flow model used to estimate and reestimate the credit subsidy for the cohorts of mortgages within the Section 232 program.

We recommend that the Office of Multifamily Housing Programs enforce written policies and procedures to ensure that the verification and payment of housing assistance payment subsidies for properties it subsidizes are based on accurate and supported information.

We recommend that the Office of Multifamily Housing Programs establish and implement policies to ensure effective contract administration, including providing funding approvals for project-based contract administrators in a timely manner.

We recommend that the Office of Multifamily Housing Programs develop contingency policies and procedures to ensure that the properties it subsidizes receive adequate and verifiable continuous monitoring.

Update and implement the internal procedures for processing housing conversion actions to require documentation, including but not limited to expired contracts or financial documentation from HUD’s Line of Credit Control System, to show when the last payment was made for the contract to support the proposed housing conversion actions before allotment of tenant protection funds.

Update and implement internal procedures to require verification that tenant protection funds were not previously allotted for the same type of housing conversion action.

For the remaining retroactive RAD conversion not completed, to take steps, including but not limited to maintaining adequate approval documentation to ensure that it enforces its requirement that the tenant protection assistance is provided to tenants before the submission of the RAD application.

For the remaining retroactive RAD conversion not completed, to take steps including but not limited to training staff responsible for reviewing and approving RAD applications to ensure that it enforces its requirement that the tenant protection assistance is provided to tenants before the submission of the RAD application.