Update its administrative plan to ensure compliance with applicable regulations. Minimally, the administrative plan should clearly define the weights and rankings of the preference system and ensure that the residency preference complies with regulations.

Reevaluate the cases of the 131 applicants to whom it did not award residency points and award points as appropriate.

Update its waiting list as needed after completing corrective action for recommendation 1B.

Develop and implement policies and procedures to ensure that it administers its waiting list according to the requirements in its administrative plan, including maintaining documentation to show that it properly selected applicants from the waiting list.

Develop and implement procedures for performing quarterly interim recertifications for families reporting zero income.

Develop and implement controls to ensure that it follows the procedures it develops and implements to resolve recommendation 1E.

Provide documentation to show that the family that received the benefit of the $2,463 overpayment in housing assistance reimbursed the program or repay its program from non-Federal funds for any amount not reimbursed by the family.

Provide technical assistance to the Authority to ensure that it properly manages its waiting list, properly uses its preference point system, and selects applicants in accordance with applicable requirements.

As part of reopened recommendation 1B, correct the deficiencies within applicable PTD reports, including missing or inaccurate records for the 10 grants identified in this CAV.

Provide support of eligibility or require lender repayment of $5,115,079 for the 822 identified claims with a reported partial claim or loan modification within the prior 24 months.

Further revise and implement Single Family Insurance System – Claims Subsystem controls to address deficiencies that allowed payment for a limited number of claims that were ineligible due to prior loan modification or FHA-HAMP option within 24 months.

Provide support of eligibility or require repayment of $333,178 for the 28 identified potential duplicate claims with reported matching partial claim note amounts and take appropriate action as necessary to ensure that related partial claim note amounts are correctly reflected within HUD’s Single Family Mortgage Asset Recovery Technology system for loan-servicing purposes.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to develop and implement a HUD-approved written plan and procedures and take actions that will correct and prevent the monitoring deficiencies in the finding, improve program administration effectiveness, and ensure compliance with HUD regulations and its own policies and procedures as required. This plan and written procedures should include controls to ensure that Northlake complies with HUD’s and its own requirements for monitoring recipients annually as well as documenting and maintaining the monitoring results. Implementing this recommendation should ensure that the $2,092,545 in HUD funds, allocated to Northlake’s four partners for program execution, is better used.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to support $81,013 or repay its program from non-Federal funds for disbursements made without adequate supporting documentation.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to develop and implement additional policies and controls and procedures, including but not limited to a disbursement file checklist, to ensure that adequate supporting documentation for disbursement is maintained in the files.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to support $47,679 or repay its program from non-Federal funds for payments made to contractors without written contracts and independent cost estimates.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to develop and implement written policies and procedures, which reflect the required HUD procurement policy standards and ensure compliance with those requirements.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to develop and implement written policies and procedures to ensure that its board members execute the proper forms annually, hold and document board meetings, and review its board governance and HMIS governance charters as required.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to evaluate its staffing level and determine if it should hire additional staff to carry out program activities.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to obtain technical assistance from HUD to evaluate the staff’s training needs and to ensure that responsible staff receives the appropriate training for effective program administration.