Establish underwriting policies and procedures to ensure that HOME activities are consistent and meet Federal requirements.

Develop and implement adequate environmental policies and procedures to ensure that environmental reviews are properly documented and supported and that HUD and Federal environmental requirements have been followed before committing HOME funds to an activity.

Develop and implement adequate policies and procedures to ensure that fixed HOME units are identified and adequate documentation is maintained to support tenant eligibility and compliance with HOME rental limits for the entire affordability period.

Develop and implement tools to improve record-keeping practices to support the eligibility, necessity, and reasonableness of the HOME activities.

Provide technical assistance to the City to ensure that responsible staff receives necessary environmental, underwriting, and overall program administration training.

We recommend that the Little Rock Acting PIH Director require the Authority to develop and implement an achievable plan to close the remaining projects and complete its RAD program conversions.

We recommend that the Little Rock Acting PIH Director require the Authority to support or repay $1,925,814 in predevelopment costs to its program from nonfederal funds.

We recommend that the Little Rock Acting PIH Director require the Authority to design and implement financial controls to ensure that $829,544 in remaining predevelopment costs is properly accounted for and supported.

We recommend that the Little Rock Acting PIH Director require the Authority to develop and implement procedures to identify, report, and resolve conflict-of-interest and ethics concerns.

We recommend that the Little Rock Acting PIH Director require the Authority to design and implement adequate control systems to ensure that the executive management team provides oversight of its RAD program.

Provide supporting documentation for the participant’s eligibility (tenant code t0019221) or repay its program $13,885 from non-Federal funds for the housing assistance payments and any subsequent payments made.

Provide support for the administrative fees or repay the Continuum of Care grants $663,070 from non-Federal funds. (See appendix D.)

Submit an indirect cost rate schedule for its Continuum of Care grants to HUD for approval.

Develop and implement written policies and procedures for its administrative fee charges.

Take corrective action against lenders for 43 improper partial claims totaling $2.3 million that did not reinstate the delinquent loans, to include repayment of the partial claims where appropriate. This amount excludes $336,699 for four partial claims that have already been repaid (see appendix D).

Update the FHA-HAMP guidance, clarifying that upon application of the partial claim funds, the mortgage must be fully reinstated with no unpaid amounts.

Support the $126,824 in total incentive payments. For any amount it cannot support, HUD should require the project development group, LP, to pay the equivalent, from any of its reserves other than reserve for replacement, toward the project mortgage principle.

Develop and implement controls over its incentives program, including record-keeping requirements; defined processes, such as a detailed checklist of available incentives, including monetary limits; and supervisory review requirements.

Require the Authority to support the $9,608 payment with the required 2 years of average annual net earnings. For any amount that cannot be supported, HUD should require the Oak Towers Housing Development Group, LP, to pay the equivalent, from any of its reserves other than reserve for replacement, toward the Oak Towers mortgage principle.

Take appropriate administrative actions against Authority staff for noncompliance.