Repay the project from non-project funds $99,160 for ineligible personal health insurance expenses of the owner.

Repay the project from non-project funds $4,179 for excessive bank fees.

Repay the project from non-project funds $1,352 for expenses related to the identity-of-interest hair salon.

Obtain approval from HUD for a lease agreement with the hair salon.

Provide documentation to support that $65,232 in disbursements was used on reasonable and necessary operating expenses or repay the project from non-project funds.

Pay the project $620,937 in uncollected rent from non-project funds.

Pay the project from non-project funds $162,462 in lease agreement charges not deposited into Cypress Meadows’ bank account.

Remove Skyline Crest Enterprises, LLC, as the operator and replace it with a HUD-approved independent operator.

Develop and implement written policies and procedures for the management of the project, including but not limited to financial policies for cash disbursements, cash receipts, and documentation requirements.

Create and implement policies and procedures or change program regulations to prevent multifamily housing properties from charging more for Section 8 units than for comparable non-Section 8 units. For the 25 properties reviewed, this measure would prevent as much as $3,144,894 of Section 8 funds from subsidizing non-Section 8 units in the next year.

Deobligate $542,289 in fiscal year 2015 capital funds in HUD’s system until binding agreements are executed for eligible and reasonable purposes, or coordinate with HUD for terminating its funding.

Reclassify $398,022 in fiscal year 2016 capital funds as authorized in HUD’s system to an eligible and reasonable activity, or coordinate with HUD for terminating its funding.

Coordinate with HUD for terminating the allocation of the remaining $217,553 funds given the Authority’s current intentions to not build or purchase public housing units.

Develop and implement adequate procedures and controls to ensure that the reporting of allocated capital funds in HUD’s system is accurate.

Provide adequate training to staff responsible for making entries into HUD’s system to ensure accurate reporting on allocated funds. The training should include but not be limited to ensuring that its staff understands all of HUD’s reporting requirements for obligations and authorizations.

Confirm the replacement of program units was appropriate for the number of units demolished at Johnson Ferry East, and submit a development proposal to construct new public housing units, transfer public housing assistance to another public housing agency, or terminate its annual contributions contract and return all unobligated and unexpended capital funds to HUD.

Certify, along with the owners of the 11 units cited in this finding, that the applicable housing quality standards violations have been corrected.

Reimburse its program $9,715 from non-Federal funds ($9,660 for housing assistance payments and $55 in associated administrative fees) for the unit that materially failed to meet HUD’s housing quality standards.

Provide training to its inspectors on conducting housing quality standards inspections.

Develop improved procedures and provide training to appropriate staff regarding the departmental clearance process requirements, including • Determining which guidance is considered to be a directive, including public communications, and • Ensuring that HUD program participants have clear, instructive, and helpful information to comply with the applicable requirements and procedures for HUD programs.