Develop and implement HUD-approved policies and procedures to ensure that the process for conducting an internal audit complies with HUD regulations and the policies and procedures are submitted and certified to HUD.

Immediately conduct an internal audit of the CDBG-DR grant funds.

Update, finalize, and implement its procurement policies to comply with 2 CFR 200.317-326.

Adequately support or reimburse its HOPWA program $31,157 from non-Federal funds for the inappropriate disbursements.

Reimburse its HOPWA program $14,017 from non-Federal funds for the inappropriate disbursements.

Provide adequate training to staff responsible for reviewing and approving the expenditures to ensure compliance with HUD’s and Louisville Metro’s requirements for the administration of the HOPWA program, including processing program disbursements and monitoring project sponsors’ cash management.

Implement adequate procedures for sufficiently monitoring its project sponsors’ cash management.

Provide adequate monitoring to the Land Bank to ensure that the subrecipient follows Federal regulations as required, including policies and procedures to help verify subrecipient compliance or address any deficiencies in need of correcting, such as annual audits, financial management systems, and file management.

Provide adequate support for expenses totaling $48,985. Any expenses that are not supported should be repaid to the appropriate NSP grant from non-Federal funds.

Ensure that the Land Bank completes and clears all outstanding annual audits for fiscal years 2012 through 2016.

Ensure that the Land Bank develops and implements adequate financial and file management policies and procedures to ensure that files are auditable and financial records adequately identify the source and application of federally sponsored activities in accordance with Federal regulations.

Reprogram the remaining NSP1 funds of $219,851 and NSP3 funds of $28,745 to another subrecipient or developer or return the funds to the U.S. Treasury.

Reimburse its program $25,133 ($17,174 in housing assistance payments $7,959 in associated administrative fees) from non-Federal funds for the overpayment of housing assistance and utility allowances due to inappropriate calculations.

Reimburse the appropriate households $2,213 from program administrative fee reserves for the underpayment of housing assistance due to inappropriate calculations.

Evaluate its administration of the program and take the appropriate actions to ensure that the program is managed effectively.

Implement adequate quality control procedures to ensure that it correctly calculates housing assistance payments to ensure that $32,960 in program funds is appropriately used for future payments.

Reimburse its program $25,231($15,061 in inappropriate graduation payments $10,170 in inappropriate interim disbursements) from non-Federal funds for the incorrect escrow account disbursements.

Support or reimburse its program $296 from non-Federal funds for the unsupported escrow account disbursements.

Reimburse the appropriate households $375 from program funds for the underpaid escrow disbursements.

Support its general ledger and bank account balances or transfer $2,547 ($2,334 for the overfunded general ledger account $213 for the overfunded program bank account) from its Family Self-Sufficiency program account to its Housing Choice Voucher program account for the overfunded accounts cited in the finding.