Take HUD-approved training related to operating and maintaining a multifamily project.

Repay the project’s operating account from nonproject funds for the $142,805 spent on ineligible expenses.

Provide support for the $12,355 in project funds spent to pay individuals who were not on the payroll and for services provided for project operations. For any portion of this amount that is not supported, the owner should repay the project operating account using nonproject funds.

Obtain training on the eligible use of project funds.

Develop and implement detailed policies and procedures for procurement, travel, and the use of its credit cards. These controls should comply with HUD regulations regarding procurement and other disbursement documentation requirements.

Submit any outstanding audited financial statements.

Review the audited financial statements and determine the amount of outstanding mortgage payments due.

Work with the local multifamily office to make any outstanding mortgage payments or devise a plan to bring the property current through the use of available funds.

Develop and implement policies and procedures to ensure that the certified public accountant submits audited financial statements by the required HUD deadline.

Maintain separate books of account and submit audited financial statements solely for the project.

Reimburse the project’s operating account $50,400 from the reserve for replacement account.

Receive training on the proper use of its reserve for replacement account.

Develop and implement policies and procedures for the use of reserve for replacement funds, which ensure that the project does not use operating funds for any items that qualify for the use of reserve for replacement funds.

We recommend that the Southwest Region Director of Multifamily Housing require the Louis Manor Apartments’ owner to support that the subsidies for 14 tenants with missing income verifications, income discrepancies, incorrect annual income, and missing annual certifications were adequately supported and accurate or repay HUD $268,452 for those subsidies. Repayment must be from nonproject funds.

We recommend that the Southwest Region Director of Multifamily Housing require the Louis Manor Apartments’ owner to implement appropriate controls to ensure that it conducts annual recertifications for all tenants in a timely manner, as required.

We recommend that the Southwest Region Director of Multifamily Housing require the Louis Manor Apartments’ owner to properly house the five families discussed in the finding in the correct unit size when an appropriate sized unit is available and ensure that its other tenants are housed in the correct unit size.

We recommend that the Southwest Region Director of Multifamily Housing require the Louis Manor Apartments’ owner to perform inspections for the units that lacked inspection reports

We recommend that the Southwest Region Director of Multifamily Housing require the Louis Manor Apartments’ owner to implement appropriate controls to ensure that it performs annual inspections, as required.

We recommend that the Southwest Region Director of Multifamily Housing require the Louis Manor Apartments’ owner to implement appropriate controls to ensure that tenants are eligible, housing assistance subsidies are accurate, and tenant files contain all required documentation.

We recommend that the Deputy Assistant Secretary for REAC require REAC to develop and implement written policies and procedures requiring REAC to (1) select a sample of inspector candidates, (2) require the sampled inspector candidates to provide written documentation supporting their minimum qualifications, (3) verify the written documentation provided by the inspector candidates, and (4) document the completion of the verification and method(s) used to verify the documentation.