Develop and implement policies and procedures to assess the validity of all program complaints to ensure that they are addressed and resolved in a timely manner.

Provide additional guidance to its grantees regarding its policy stating that the repair or replacement of paved surfaces should be minimal in cost and incidental to the rehabilitation of the dwelling, including whether grantees are required to consult with the State before starting the work.

Reimburse its program $279 from non-Federal funds for the ineligible payment it made due to the conflict-of-interest situation identified by the audit.

Develop and implement controls to prevent and detect conflict-of-interest situations.

Provide documentation to show that indirect payroll expenses totaling $225,182 charged to the program were reasonable and necessary or repay its program from non-Federal funds for any amount that it cannot support.

Develop and implement a cost allocation plan to use as a basis for charging indirect payroll expenses to the program.

Provide documentation to show that administrative fees totaling $47,376 were used to perform administrative duties for the program or repay its program from non-Federal funds for any amount that it cannot support.

Develop and implement controls to ensure that administrative fees are used to perform administrative duties for the program.

Certify, along with the owners of the 10 units cited in the finding, that the applicable housing quality standards violations have been corrected.

Provide training to its inspector on conducting housing quality standards inspections.

Develop and implement controls to ensure that an independent entity performs housing quality standards inspections of units that it substantially controls.

Submit a request for approval of an independent entity to perform rent reasonableness determinations for program units that it substantially controls.

Develop and implement controls to ensure that the independent entity approved in recommendation 1J performs rent reasonableness determinations for program units that it substantially controls.

Implement adequate procedures and controls to ensure that borrowers’ delinquent and default information is accurately reported.

Provide verification to HUD that it has taken the appropriate action to correct its delinquent or default status code reporting for the borrowers affected as a result of its system change.

Ensure that staff responsible for making entries into its servicing system is properly trained and understands HUD’s reporting requirements.

Procure appropriate HUD-approved investment accounts and move all Federal funds from the STAR Ohio investment accounts to HUD-approved accounts to ensure that $20,706,862 or the current balance of the STAR Ohio accounts is properly protected.

Implement adequate procedures and controls to ensure that the Authority complies with HUD’s requirements for its investments of Federal funds.

Ensure that its staff is properly trained and familiar with HUD’s requirements to ensure that it properly procures and invests Federal funds in HUD-approved investment accounts.

Ensure that the proceeds from the sale of Bollinger Tower proceeds are moved into a separate HUD-approved restricted investment account and appropriately recorded in a restricted account in the general ledger.