Update its procedures to ensure that any additional home-buyer assistance agreements contain recapture provisions that meet HUD recapture requirements relating to the sales price, closing costs, and net proceeds.

Train its staff to ensure that recapture amounts do not exceed net sales proceeds.

Revise and implement written policies and procedures for managing and accurately tracking all NSP3 activity to ensure that the $12,275 in identified closing cost refunds and any additional refunds identified in recommendation 2B are not overpaid by recipients.

Identify any additional closing cost refunds for NSP3 properties using the general ledger, DRGR supporting documentation, and the property file and either repay the recipients from non-Federal funds or update its tracking spreadsheet.

Repay $95 from non-Federal funds to the two recipients who paid more than the assistance provided (appendix E).

Repay the program $1,495 for closing cost expenses not incurred from non-Federal funds and remove the expenses from program records if the City incorrectly recorded the refunds as program income.

Reclassify home-buyer assistance expenses and refunds from the City’s NSP3 ARR program to its NSP3 Homebuyer Assistance Program in DRGR and the general ledger.

Consolidate and reconcile all NSP3 home-buyer assistance tracking spreadsheets and the general ledger with HUD’s DRGR to ensure that all information is accurate and up to date.

Develop and implement written policies and procedures to periodically reconcile all NSP3 tracking spreadsheets to ensure that data remain accurate and up to date.

Provide training to all employees responsible for NSP3 to ensure that the City adequately determines repayment amounts and tracks and records NSP3 activities.

Repay to the program from non-Federal funds the $457,192 ($380,526 $48,420 $28,246) in NSP funds spent for the construction, air conditioning, and engineering services in instances in which procurement activities were not adequately performed.

Repay to the program from non-Federal funds $280,979 in NSP funds spent for property 1012 and identify and repay any additional costs spent on this property, including maintenance costs and any program income generated.

Repay to the program from non-Federal funds the $73,400 in NSP funds spent for mold and asbestos remediation work.

Provide documentation to support the $8,919 in NSP funds spent on rehabilitation costs or repay to the program from non-Federal funds.

Provide documentation to support a reconciliation between financial records and DRGR and report in HUD’s DRGR system the appropriate amount of program income generated from all NSP1 and NSP3 funds from the inception of the grants.

Provide documentation to support that all NSP properties are properly classified and recorded in HUD’s DRGR system.

Develop and implement policies and procedures to include but not be limited to oversight, effective internal controls, separation of duties, procurement, and overall administration of the program.

Conduct a review of the remaining 10 properties not reviewed during our audit to ensure compliance with HUD requirements and identify and repay costs related to ineligible or unsupported activities (see appendix C).

For Property 1504, provide documentation to support the recording in HUD’s DRGR system, the repayment of $144,004 in NSP funds and $1,120 in program income.

Initiate appropriate administrative actions and debarments against parties, including the former grants manager and contractors, who contributed to the mismanagement of program funds.