Require public housing agencies to maintain support for any communication with a multifamily property listed on the Enterprise Income Verification existing tenant search.

Require HUD staff to review Enterprise Income Verification reports from the last 12-month period during onsite housing agency reviews to ensure that any multiple subsidies have been resolved.

Implement recommendations 1A through 1D to ensure that $2.24 million in housing assistance funds will be put to better use.

Reimburse its program $28,199 ($19,771 $7,793 $635) from non-Federal funds for the overpayment of housing assistance and ineligible administrative fees it received for the deficiencies cited in this report.

We recommend that the Director of the Public Housing Financial Management Division determine whether any of the overpayment of $3,630,286 was ineligible and take appropriate actions to recoup the ineligible payments.

We recommend that the Director of the Public Housing Financial Management Division validate the $1,191,767 in underpayments and determine if any corrections should be made.

We recommend that the Director of the Public Housing Financial Management Division recapture the overpayment of $116,218 disbursed for the units, which exceeded the PHAs’ Faircloth limit.

Provide documentation to support program accomplishment data related to disbursements totaling $292,611 or repay HUD from non-Federal funds for any amount that it cannot support.

Support the cost reasonableness of the nine contracts or reimburse $408,958 to the appropriate Operating Fund, Capital Fund, and Housing Choice Voucher programs from non-Federal funds.

Develop and implement written policies and procedures with an emphasis on increased controls toward the monitoring, tracking, underwriting, and evaluating of the Section 184 program. Implementing these controls would reduce the current high level of risk in the program and result in potentially $76,967,618 in funds to be put to better use (see appendix A).

Develop and implement policies and procedures for a standardized monthly delinquency report format that lenders must follow when submitting information to OLG.

Develop and implement policies and procedures to deny payments to direct guarantee lenders for claims on loans that have material underwriting deficiencies.

Develop and implement policies and procedures to ensure that OLG uses enforcement actions available under 12 U.S.C. 1715z-3a(g) for lenders that do not underwrite loans according to the Section 184 processing guidelines.

Ensure that only underwriters that are approved by OLG are underwriting Section 184 loans.

Develop and implement written policies and procedures for situations in which the borrower for a Section 184 loan is an Indian housing authority, a tribally designated housing entity, or an Indian tribe.

Reconcile the total list of guaranteed Section 184 loans to the complete loan file storage list and identify and locate any missing loan files.

We recommend that the Director of HUD’s New York Office of Public and Indian Housing require Authority officials to provide supporting documents for the proper use of $1,250,417 in sale proceeds from the scattered-site properties. Any amounts not supported or found to be improperly used should be repaid to the homeownership program from non-Federal funds.

Require the Authority to take action to reclaim its properties valued at $2,032,266 to improve its financial position, decrease its reliance on HUD program funding, and address its comingling issues.

Require the Authority to determine how much of the $243,442 in salaries for individuals assigned to work at multiple properties was improperly paid with Federal funds and repay the amounts to the appropriate programs from non-Federal funds. If the Authority is unable to accurately determine the amount due to and due from each program or support that the funds charged to the Federal programs were appropriate, the full $243,422 should be repaid to HUD.

Require the Authority to determine whether the Authority improperly used Federal funds totaling $40,600 to make lease payments on the parking lot it already owned. If Federal funds were improperly used, the Authority should repay $40,600 from non-Federal funds to its Federal program accounts. If the Authority is unable to accurately determine the amount due to and due from each program or support that the funds charged to the Federal program were appropriate, the full $40,600 should be repaid to HUD.