Ensure that the management agent’s staff is properly trained and familiar with HUD’s and the project’s requirements regarding housing assistance payments calculations.

Conduct criminal record background checks in accordance with the project’s policies and procedures to ensure that adult members of all households, including the 11 households for which HUD made housing assistance payments totaling $239,500, were eligible to participate in the program. If the participants are deemed ineligible, the owner should follow applicable regulations to terminate or modify assistance and reimburse HUD from nonproject funds for those housing assistance payments deemed ineligible.

Review and update the project’s waiting lists to include the missing dates and required notations.

Develop and implement adequate procedures and controls to ensure that the project complies with HUD’s requirements and its own policies regarding the management of its waiting lists.

Determine whether the households residing in the project’s assisted units received housing in accordance with the program’s requirements and if not, consider a referral to HUD’s Office of Fair Housing and Equal Opportunity.

Provide documentation to support housing assistance payments the projects received totaling $497,762 or reimburse HUD from nonproject funds for any amount that it cannot support.

Implement controls to ensure that it maintains adequate documentation in the tenant files to show that tenants were eligible for assistance and that the housing assistance payments were supported.

Provide support of eligibility or require lender repayment of $5,115,079 for the 822 identified claims with a reported partial claim or loan modification within the prior 24 months.

Further revise and implement Single Family Insurance System – Claims Subsystem controls to address deficiencies that allowed payment for a limited number of claims that were ineligible due to prior loan modification or FHA-HAMP option within 24 months.

Provide support of eligibility or require repayment of $333,178 for the 28 identified potential duplicate claims with reported matching partial claim note amounts and take appropriate action as necessary to ensure that related partial claim note amounts are correctly reflected within HUD’s Single Family Mortgage Asset Recovery Technology system for loan-servicing purposes.

We recommend that the Southwest Region Director of Multifamily Housing require the Northline Point Apartments’ owner to support that the subsidies for 51 units without annual physical inspections, without required EIV reports, or missing files were eligible and accurate or repay HUD $1,054,150 for those subsidies. Repayment must be from nonproject funds.

We recommend that the Southwest Region Director of Multifamily Housing require the Northline Point Apartments’ owner to use correct dates for tenants who move in or out of subsidized units or transfer to other units. The move-ins, move-outs, and transfers must be adequately documented and supported.

We recommend that the Southwest Region Director of Multifamily Housing require the Northline Point Apartments’ owner to ensure that form HUD-50059 transactions are properly coded and adequately document and support the transactions.

We recommend that the Southwest Region Director of Multifamily Housing require the Northline Point Apartments’ owner to ensure that tenant income is properly verified and maintain EIV reports as required.

We recommend that the Southwest Region Director of Multifamily Housing require the Northline Point Apartments’ owner to perform and document annual inspections as required.

We recommend that the Southwest Region Director of Multifamily Housing require the Northline Point Apartments’ owner to implement appropriate controls to ensure that tenants are eligible, housing assistance subsidies are accurate, tenants are properly moved and transferred, transactions are properly coded, units are inspected as required, and tenant files contain all required documentation.

We also recommend that the Southwest Region Director of Multifamily Housing verify that the owner is providing oversight to its onsite staff and its recently implemented quality control procedures are working as designed and in accordance with HUD requirements.

Take corrective action against lenders for 43 improper partial claims totaling $2.3 million that did not reinstate the delinquent loans, to include repayment of the partial claims where appropriate. This amount excludes $336,699 for four partial claims that have already been repaid (see appendix D).

Design controls to protect the insurance fund from improper partial claims that did not reinstate the loans to put $27.1 million to better use.

Update the FHA-HAMP guidance, clarifying that upon application of the partial claim funds, the mortgage must be fully reinstated with no unpaid amounts.