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.

Repay the Housing Choice Voucher Program $77,542 from non-Federal funds for the unreasonable professional auditing service payments.

Establish and implement additional procedures and controls to ensure that City personnel responsible for administering procurement on the Authority’s behalf follow procurement and contracting requirements and maintain applicable supporting documentation in accordance with HUD requirements.

Establish and implement additional procedures and controls to ensure that audited financial statements are prepared and submitted in accordance with HUD requirements.

Complete and submit to HUD the audited financial statements for all past-due fiscal years in accordance with HUD regulations.

Consider imposing administrative sanctions and remedies on the Authority for the nonsubmission of audited financial statements for all overdue fiscal years.

Develop and implement additional procedures and controls to ensure that City employees properly calculate administrative fees for portability HAP related to the Authority.

Update its intergovernmental agreements for supplemental law enforcement services to include the current HUD requirements at 2 CFR Part 200 to comply with its procurement bulletin and HUD Notice SD-2015-01. By doing so, the Authority will ensure that current and future intergovernmental agreements include the current HUD requirements and focus Federal resources toward improving program performance and outcomes.

Issue guidance to PHAs to ensure any applicant for or tenant of public or assisted housing whose name appears on the SAM excluded parties list are reviewed by PHAs to determine eligibility in a manner consistent with the regulations in 2 CFR 180 and 2424 so that ineligible applicants or tenants are not admitted or recertified to put up to $13.7 million to better use.