Pursue collection from the applicable households or reimburse its program $1,877 from non-Federal funds for the overpayment of housing assistance due to unreported income.

Pursue collection from the applicable projects or reimburse its program $5,065 from non-Federal funds for the overpayment of housing assistance.

Reimburse the appropriate projects $177 from program funds for the underpayment of housing assistance.

Reimburse the appropriate households $263 from program funds for the underpayment of utility allowance reimbursements.

Review the payments for all certifications completed between December 2016 and February 2017 for the remaining Housing Choice Voucher and Project-Based Voucher program participants to ensure that adjustments were appropriately paid.

Implement adequate quality control procedures to ensure that it correctly pays housing assistance.

Ensure that the quality controls over the calculation of housing assistance payments implemented by the Commission are sufficient.

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

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.

We recommend that HUD’s Office of General Counsel, Office of Program Enforcement, acknowledge that $30,000 in the settlement agreement represents an amount due HUD.

We recommend that the Chief Financial Officer determine whether the summary expenditures totaling $160,360,714, which exceeded the grant round obligations for the two grantees, were ADA violations. If the transactions were violations, action should be taken as required by the ADA.

We recommend that the Chief Financial Officer determine whether the revised and completed detail transactions totaling to $435,263,268, which occurred before and after grant rounds obligation and expenditure dates, were ADA violations. If the transactions were violations, actions should be taken as required by the ADA.

We recommend that the Chief Financial Officer determine whether the revised and completed transactions totaling $496,913,235 and made more than a year after the original voucher entry were GAAP violations. If the transactions were violations, appropriate actions should be taken, including but not limited to adjusting the transactions in LOCCS and HUD’s financial statements.

We recommend that the Chief Financial Officer enter a 24-month expiration term into LOCCS for Disaster Recovery funding provided by the 2017 Act and monitor to ensure that expenses are not entered before or after the grant period.

We recommend that the Chief Financial Officer require CPD to enter into a separate grant agreement for each grantee’s round of disaster funding for funding provided by the 2017 and 2018 Acts.

We recommend that the Chief Financial Officer require CPD to monitor the detailed voucher transactions in the DRGR system to ensure that grantees appropriately record transactions.

We recommend that the Chief Financial Officer require CPD to prohibit grantees from revising completed vouchers in the DRGR system and require adjustments to be entered as new vouchers into the DRGR system, which will ensure that LOCCS records and tracks revisions.