Pursue departmental clearance for the July 25, 2013, guidance that did not go through required departmental clearance. For any items that cannot be appropriately cleared, HUD should take appropriate action to recall the document or policy.

Develop guidance that helps the public understand its options for assistance between CDBG-DR and SBA and how to comply with Federal requirements.

Develop and implement a written methodology for employees’ time allocations for its HUD grant programs in accordance with program requirements.

Provide training on compensation for personal services grant program requirements to employees working on HUD grants.

Support $142,181 spent on payroll allocated to HUD grants or repay the program from non-Federal funds.

Provide supporting documentation or reimburse its Program $81,654 from non-Federal funds for unsupported on-the-job training costs incurred under project FL0220L4D001407.

Provide supporting documentation or reimburse its Program $1,023 from non-Federal funds for unsupported personal cell phone costs incurred under project FL0220L4D001407.

Provide guidance to subrecipients to ensure that (1) on-the-job training hours are supported by source documents, such as signed attendance or time sheets, and (2) personal goods and services are supported by documents that show the allocation between business and personal use.

Report Program income of $31,724 for FL0199L4D001407 to HUD.

Provide supporting documentation to show that participant 87487 from FL0431L4D001403 was chronically homeless or reimburse its Program $15,756.

Perform onsite monitoring of the subrecipient that administered project FL0431L4D001403 to ensure that participants are eligible and annual income re-certifications are performed.

Review the issues identified in this audit report and if appropriate, pursue administrative sanctions against the board of directors for the violations cited in this report.

Provide documentation to show that prices paid for purchases of products and services totaling $970,381 were fair and reasonable or reimburse the project from nonproject funds for any amounts that were not fair and reasonable.

Provide documentation to show that payments for work totaling $716,693 complied with applicable building codes or reimburse the project from nonproject funds for payments that did not comply with the codes and take action to bring the work up to code.

Provide documentation to support payments totaling $163,885 or reimburse the project from nonproject funds for payments that it cannot support.

Develop and implement written procedures to ensure that it obtains written cost estimates as required and maintains complete documentation to support expenditures and that contractors performing or managing construction, removal, repair, or improvement work are properly licensed as required.

Investigate the 14 loans with unpaid mortgage amounts totaling $3,035,819, and require the lenders to obtain the borrowers consent, reinstate the insurance coverage, or take other action as appropriate given the facts of each particular loan.

Remind lenders that voluntary termination is not the correct termination type to record third-party sales and that borrower consent is required to terminate insurance, even if the loans are indemnified.

Improve its procedures for detecting and sanctioning improper voluntary terminations.

Update Handbook 4000.1 to require the voluntary termination of insurance consent form to include an explanation that voluntary termination differs from mortgage insurance premium cancellation and the disclosure of any outstanding partial claims to put $285,215 to better use.