Review the Clearance Calendar and ensure that appropriate form HUD-22 concurrence forms were obtained and documented for directives issued by other HUD offices.

Implement controls to ensure that future directives are reviewed and documented in the Clearance Calendar tracking system as required.

Update policies and procedures for the directives process, including responsibilities for process oversight and clear guidance defining when clearance is required.

Develop and provide training to appropriate staff and required reviewing offices regarding the departmental clearance process requirements.

Pursue departmental clearance for the 13 documents and policies identified 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.

Obtain missing HUD-22 concurrence forms for the 13 identified directives and update the Clearance Calendar tracking system to properly document clearance of the 42 directives with incomplete Clearance Calendar documentation. For any items that cannot be appropriately cleared, HUD should take appropriate action to recall the document or policy.

Obtain repayment of $322,314 from nonproject funds from the management agent for the ineligible bookkeeper and accounts payable clerk’s salary and benefits, incurred during 2014 and 2015.

Decrease the payable to the management agent by $139,027 for ineligible employee services billed during 2014 and 2015, thereby reducing future expenditures because project funds will not be used for these ineligible expenses when funds become available.

Support or decrease the payables to its management agent for the amounts related to ineligible employee services charges before January 1, 2014, which we estimated to be $353,420.

Develop and implement controls over payments to include; ensuring that its management agreement clearly identifies services that are be provided by the management agent and paid for as part of the management fee, and the project is not charged for services that are part of the management fee.

Support that $1,432,222 in central office cost center expenses allocated to the public housing program projects were eligible, necessary, and reasonable costs of the program. Costs that cannot be supported, or were unnecessary, unreasonable, or for ineligible program costs should be reimbursed to the program from non-Federal funds.

Implement adequate procedures and controls, including but not limited to developing a plan to manage its central office cost center expenses and determining an appropriate fee structure with HUD’s approval that would allow it to operate its program within HUD’s requirements.

Implement adequate procedures and controls, including but not limited to providing training to its staff to ensure that the Commission fully implements asset management and operates its program in accordance with HUD’s requirements.

Require public housing agencies to run the Enterprise Income Verification existing tenant search during the admission process and retain the results in the tenant file, which would avoid unnecessary costs to HUD’s subsidy programs, allowing an estimated $935,283 to be put to better use.

Require public housing agencies to report the program admission date to any multifamily property listed on the Enterprise Income Verification existing tenant search during the admission process.

Require public housing agencies to maintain support for any communication with a multifamily property listed on the Enterprise Income Verification existing tenant search.

Require HUD staff to review Enterprise Income Verification reports from the last 12-month period during onsite housing agency reviews to ensure that any multiple subsidies have been resolved.

Implement recommendations 1A through 1D to ensure that $2.24 million in housing assistance funds will be put to better use.

Acknowledge that $3,129,000 of the $5 million in the attached settlement agreement represents an amount due HUD.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development instruct County officials to reimburse $3,536,974 to the County’ HOME program line of credit for assistance spent on the four activities that were partially terminated or noncompliant with program requirements.