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.

We recommend that the Deputy Assistant Secretary for REAC require REAC to ensure that the nine contract inspectors, who did not meet the minimum requirements to begin the training, receive specialized training in residential or commercial building for electrical; heating, ventilation, and air conditioning; masonry; plumbing; and carpentry, as applicable.

We recommend that the Deputy Assistant Secretary for REAC require REAC to develop, use, and document an electronic checklist for each contract inspector’s file to ensure that inspectors (1) obtain and maintain the required insurance, and (2) have approved background checks before conducting inspections. In addition, support that the three sampled inspectors meet the minimum insurance limits for the current effective periods.

We recommend that the Deputy Assistant Secretary for REAC require REAC to execute administrative action related to outside standards determinations for five inspectors.

We recommend that the Deputy Assistant Secretary for REAC require REAC to develop and implement processes and procedures, in accordance with its system security plan and the HUD Handbook, Information Technology Security Policy, to ensure that annual assessments and continuous monitoring of the security controls are performed and that security control failures are prevented and corrected when identified.

We recommend that the Deputy Assistant Secretary for REAC require REAC to establish and implement written processes and procedures to verify the accuracy of the unit numbers sampled and entered for inspection by the inspector, which could include requiring (1) inspectors to upload a picture of the rent roll to the data collection device, (2) housing agencies to maintain a copy of the rent roll used, and (3) inspectors and public housing agencies to sign a certification stating that the units were inspected in accordance with the sample generated by the data collection device.

Acknowledge the settlement amount of $149,500,000 and that $115,000,000 of the settlement represents restitution due HUD less DOJ’s civil debt collection fees.

Develop and implement internal policies and procedures to ensure that approved underwriters are accurately maintained and kept current in the origination systems for the Section 184 program.

Develop a comprehensive plan to continue to seek indemnification statutory authority, including consideration to include indemnification authority language in draft regulations currently being considered. Until statutory authority is obtained, develop and implement internal policies and procedures for the voluntary indemnification process, to include a voluntary indemnification agreement, followup procedures, and resolution procedures. Procedures should be revised once statutory authority is obtained.