Implement adequate procedures and controls to ensure that members maintain their units at the project as their principal residence or sell their memberships.

Rent the unit that was used to provide rent-free housing to former employees of the management agent to a very low-, low-, or moderate-income household selected from a waiting list for rental units that meets the requirements of the resident home-ownership plan and considers the tenant profile.

Implement adequate procedures and controls to ensure that the project’s units are used for rental or cooperative housing unless otherwise approved by HUD.

Implement adequate procedures and controls to ensure that it submits the required reports to HUD to show continued compliance with the program.

Ensure that the Cooperative’s board members and responsible staff of the Cooperative’s management agent are provided training on HUD’s requirements and the grant agreement.

Consider removing from the Cooperative’s board the member who did not maintain their unit as their principal residence.

Make a preliminary determination as to whether the Cooperative is in default of the grant agreement. If it is preliminarily determined that the Cooperative is in default, HUD should provide the Cooperative notice of the determination and propose corrective or remedial actions to address the default and prevent the Cooperative from repaying the remaining $18,149,023, which HUD disbursed for the project ($18,607,467 in funds disbursed for the project – $458,444 in proceeds from initial membership sales the Cooperative remitted to HUD).

We recommend that the Associate Deputy Assistant Secretary for Single Family Housing require BLM to certify and provide supporting documentation that the identified deficiencies have been corrected for the 57 properties cited in this audit report.

We recommend that the Associate Deputy Assistant Secretary for Single Family Housing require BLM to repay $8,034 in ineligible monthly management and inspection fees for 57 sample properties with health and safety hazards or significant not-ready-to-show conditions.

We recommend that the Associate Deputy Assistant Secretary for Single Family Housing require BLM to support or repay $488,883 in unearned property management and inspection fees for 1,028 properties with three or more consecutive unresolved discrepancies in its routine exceptions reports.

We recommend that the Associate Deputy Assistant Secretary for Single Family Housing require BLM to implement an effective quality control system, including specifying how many quality control field inspections it will perform, how it will select properties for review and inspection, reviewing exception reports by case number, completing the routine inspection form during field inspections, documenting quality control findings and how it resolved them, and retaining records that allow it to identify and correct patterns of deficiencies and poor performance. This would put an estimated $891,000 to better use in the next 12 months.

We recommend that the Associate Deputy Assistant Secretary for Single Family Housing require BLM to evaluate the structure of its exception reports to ensure that they do not omit existing hazards and other issues reported by inspectors.

We recommend that the Associate Deputy Assistant Secretary for Single Family Housing require BLM to perform required background investigations before allowing individuals and vendors to work under the contract, and prevent those who have not had background checks from performing further work under the contract until it determines that they are suitable for the duties assigned.

We recommend that the Associate Deputy Assistant Secretary for Single Family Housing require BLM to sign its contracts with vendors.

We recommend that HUD’s Associate Deputy Assistant Secretary for Single Family Housing assess BLM’s performance under the area 1D contract at least quarterly to determine whether it has improved its performance. If its performance does not improve, coordinate with the Office of the Chief Procurement Officer to determine whether BLM was in default of its contract and take appropriate action.

Reimburse HUD $52,932 from non-project funds for the overpayment of housing assistance and utility allowances due to incorrect calculations.

Reimburse the appropriate households $566 from non-project funds for the underpayment of housing assistance due to incorrect calculations.

Reimburse HUD $32,334 for the overpayment of housing assistance due to unreported, and underreported income, or income reported late. This reimbursement is either from non-project funds or collections from applicable households.

Support or reimburse HUD $6,444 from non-project funds for the unsupported payments of housing assistance cited in the finding.

Implement adequate quality control procedures to ensure that housing assistance payments are appropriately calculated and supported. These procedures and controls should ensure that $76,107 in program funds are appropriately used for future payments.