Develop and implement adequate procedures and controls to ensure that its quality control inspection program functions properly to include adequately monitoring the inspection contractor to prevent $20,566,345 in program funds from being spent over the next year on units that do not materially comply with requirements.

Reimburse the program $2,492 ($2,286 in housing assistance payments and $206 in administrative fees received) from non-Federal funds for rental subsidies not abated on four units.

Complete a review of rental subsidy abatements for all current units for which a retroactive abatement was not conducted. The Authority should reimburse the program from non-Federal funds for any overpaid rental subsidy.

Develop and implement written procedures and a process for retroactively abating housing assistance payments.

Complete a rent reasonableness determination for all current units for which a determination was required but not completed. The Authority should reimburse the program from non-Federal funds for any overpaid rental subsidy.

Develop and implement written procedures to ensure that a rent reasonableness determination is performed before rent increases are approved.

Complete a review that owners of current assisted units are not debarred, suspended, or subject to a limited denial of participation.

Develop and implement written procedures for conducting a complete owner eligibility determination.

Provide adequate training to its staff to ensure compliance with HUD’s requirements for program units.

Develop and implement HUD-approved policies and procedures to ensure that the process for conducting an internal audit complies with HUD regulations and the policies and procedures are submitted and certified to HUD.

Immediately conduct an internal audit of the CDBG-DR grant funds.

Update, finalize, and implement its procurement policies to comply with 2 CFR 200.317-326.

Adequately support or reimburse its HOPWA program $31,157 from non-Federal funds for the inappropriate disbursements.

Reimburse its HOPWA program $14,017 from non-Federal funds for the inappropriate disbursements.

Provide adequate training to staff responsible for reviewing and approving the expenditures to ensure compliance with HUD’s and Louisville Metro’s requirements for the administration of the HOPWA program, including processing program disbursements and monitoring project sponsors’ cash management.

Implement adequate procedures for sufficiently monitoring its project sponsors’ cash management.

Provide adequate monitoring to the Land Bank to ensure that the subrecipient follows Federal regulations as required, including policies and procedures to help verify subrecipient compliance or address any deficiencies in need of correcting, such as annual audits, financial management systems, and file management.

Provide adequate support for expenses totaling $48,985. Any expenses that are not supported should be repaid to the appropriate NSP grant from non-Federal funds.

Ensure that the Land Bank completes and clears all outstanding annual audits for fiscal years 2012 through 2016.

Ensure that the Land Bank develops and implements adequate financial and file management policies and procedures to ensure that files are auditable and financial records adequately identify the source and application of federally sponsored activities in accordance with Federal regulations.