Take appropriate enforcement actions against the responsible parties and pursue civil action against the owner for improperly certifying to the eligibility of the project residents.

Pursue administrative actions, as appropriate, against the responsible parties for the improper certification included in form HUD-50059 and the Section 8 project-based voucher housing assistance payments contract.

Cancel the Section 8 Project-Based Voucher Program housing assistance payments contract for 90 units improperly converted under RAD. The owner should work with HUD and the Authority to protect the tenancy of the affected tenants at the time of contract cancellation.

Reimburse HUD’s Section 8 program administered by the Authority $485,475 in housing assistance payments from nonproject funds for the improper issuance of tenant protection assistance and an improper RAD conversion to the Project-Based Voucher Program for the 90 units.

Develop and implement procedures to ensure that when tenant protection assistance is requested as a result of a housing conversion action, the forms HUD-50059 and or tenant profiles is generated only based on a completed action and that the forms or profiles are provided to HUD instead of the Authority.

Provide adequate training to staff associated with administering tenant protection and project-based assistance to help ensure compliance with program requirements.

Support that healthy homes assessment and data collection services were cost reasonable or reimburse its Program $361,850 from non-Federal funds.

Support that landlords gave preference in renting eight vacant units to families with children under 6 years of age or reimburse its Program $112,917 from non-Federal funds for the lead-based paint hazard control activities completed at these assisted units.

Support that lead-based paint hazard control activities were necessary at 19 assisted units or reimburse its Program $70,266 from non-Federal funds for the unsupported lead-based paint hazard control activities completed at these assisted units

Coordinate with HUD’s Office of Lead Hazard Control and Healthy Homes to determine whether $51,930 in healthy homes supplemental funds used for four units in excess of $5,000 per unit was for eligible activities. If the activities are deemed ineligible, the Department should reimburse its Program the appropriate amount from non-Federal funds.

Support that one household residing in an assisted unit was income eligible or reimburse its Program $19,500 from non-Federal funds for the lead-based paint hazard control activities completed in the assisted unit.

Implement adequate procedures and controls to ensure that (1) documentation is maintained to support that contracted services are cost reasonable, (2) landlords give preference in renting assisted vacant units to families with children under 6 years of age, (3) lead inspection documentation properly supports lead-based paint hazard control activities, (4) HUD approval is obtained when more than $5,000 per unit in healthy homes supplemental funds is budgeted to assist units, and (5) its staff is fully knowledgeable of the Program requirements.

Acknowledge that the attached settlement agreement of $325,000 represents an amount due HUD from Pacific Horizon.

Acknowledge that the attached settlement agreement for $15,000 represents an amount due HUD from the two loan officers.

Acknowledge that $3,375,163 in the attached settlement agreement represents an amount due HUD, less DOJ’s civil debt collection fees

Acknowledge that the $6,749,673 in the attached indemnification agreement represents an amount due HUD.

Acknowledge that $32,500,000 in the attached settlement agreement represents an amount due HUD, less DOJ’s civil debt collection fees.

We recommend that the Director of the Office of Block Grant Assistance require the Texas General Land Office to implement appropriate cost controls, including limits for reconstruction and rehabilitation costs, to ensure that it uses limited government resources in a more economical and efficient manner. Those costs should not exceed the costs that would be incurred by a prudent person under similar circumstances.

We recommend that the Director of the Office of Block Grant Assistance require the Texas General Land Office to evaluate whether its programs would benefit from a longer affordability period and take appropriate actions to ensure that low- and moderate-income communities have access to affordable homes for an adequate period.

We recommend that the Director of the Office of Block Grant Assistance require the Texas General Land Office to ensure that the tax burden implications are a part of the determination of whether to spend significantly more than the damaged home’s appraised value to replace the home. This measure would include ensuring that participants are fully informed of the substantial and material property tax consequences that they could incur based on the increased values of their reconstructed homes (appendix B).