Establish and implement procedures and controls, in coordination with FHA, to ensure that FHA information reported in the AFR is accurate and consistent with supporting documents.

Develop and implement steps to ensure that the description of corrective actions highlights current efforts and key milestones for ongoing efforts and explain in the AFR how it specifically tailored its corrective actions to better reflect the unique processes, procedures, and risks involved with RHAP as required by OMB.

Develop and implement steps to ensure that adequate disclosures are made when future-year reduction targets for improper payments reported in the AFR are higher than the current-year improper payment estimates.

Disclose in the AFR the results of HUD’s review concerning its current performance against program-specific improper payment reduction targets to promote transparency.

Reimburse NSP2 from non-Federal funds for the $59,523 in ineligible disbursements on the five vouchers.

Provide documentation to support that the $224,868 in NSP2 funds drawn down from the four vouchers was eligible or repay the program from non-Federal funds.

Provide documentation to support that the differences resulting from the payroll costs for the three vouchers, which netted $3,169, were offset in later drawdown vouchers or repay the program from non-Federal funds.

Review all administration drawdown vouchers and provide documentation to support that the drawdowns for estimated payroll costs are reconciled with the actual payroll costs for the pay periods. Any calculated overpayment by NSP should be returned to the program to meet program purposes.

Provide clearer guidance and instruction to PL 113-2 disaster grantees to assist them in establishing an effective internal audit activity.

Establish a recurring training and discussion forum among the PL 113-2 grantees and CPD that enables grantees to share ideas and receive guidance and information about CPD’s expectations regarding the internal audit requirement.

Reevaluate the feasibility of the two Section 108 activities that failed to meet a national objective and determine the eligibility of the $15,814,000 already invested. Any amount determined ineligible must be reimbursed to the program from non-Federal funds.

Require the borrowers to submit a plan for how they will proceed and use the $8,694,000 million in unused commitments to provide the intended benefits and meet program objectives.

Require the borrower to provide all supporting documentation and evaluate the allowability and eligibility of $75,000 used for the unauthorized activity. Any amount determined ineligible must be reimbursed to the program from non-Federal funds.

Develop procedures directing field offices to include the review of Section 108-funded activities when performing the annual reviews of Block Grant recipients.

Develop procedures to ensure that the information necessary to monitor program performance and compliance with program requirements is promptly provided to the field offices.

Implement procedures to ensure that borrowers comply with all loan contract provisions and that required documents are submitted, including bank agreements, monthly statements, and security documents. If a borrower does not provide evidence that it has complied with all program requirements, HUD must initiate appropriate remedial actions under paragraph 12 of the contract.

Develop and implement a tracking system for monitoring reviews of Section 108 loans.

We recommend that the Director, Departmental Enforcement Center take appropriate administrative sanctions, including suspension, limited denial of participation, or debarment against the executive director.

We recommend that the Director, Departmental Enforcement Center seek civil money penalties, as appropriate, against the executive director.

We recommend that the Associate General Counsel for Program Enforcement determine legal sufficiency and, if legally sufficient, pursue remedies under the Program Fraud Civil Remedies Act against the executive director.