Implement a process to periodically review approving officials’ span of control to ensure that the requirement is not exceeded.

Implement a process with ARC to ensure that cardholders and approving officials are notified before purchase card training is due to allow training to be completed in a timely manner.

Implement a process to ensure that purchase cards are suspended when a cardholder or approving official fails to complete training.

Research why ARC provided incomplete monthly transactional data and identify a solution to ensure the completeness of future transmissions.

Enhance the process to periodically analyze data for split transactions or improper MCCs and follow up on any potential issues identified.

Require ARC to update its MCC tracking log, to include the amount, the date of MCC override removal, and staff assigned, to ensure that an override is removed after the approved purchase is made.

Implement a process with Citibank and ARC to provide global notifications to cardholders and approving officials before autoclosures of credit card statements.

Implement a process to suspend cardholders or approving officials who repeatedly cause HUD to pay interest.

Obtain supporting documentation for the $1,807 spent on two cardholders’ purchase cards or require the vendors or cardholders to repay the funds to the applicable HUD program.

Take appropriate enforcement actions against the responsible parties and pursue civil action against the owner for improperly certifying to the eligibility of the project residents.

Pursue administrative actions, as appropriate, against the responsible parties for the improper certification included in form HUD-50059 and the Section 8 project-based voucher housing assistance payments contract.

Acknowledge that the attached settlement agreement of $325,000 represents an amount due HUD from Pacific Horizon.

Acknowledge that the attached settlement agreement for $15,000 represents an amount due HUD from the two loan officers.

Acknowledge that $3,375,163 in the attached settlement agreement represents an amount due HUD, less DOJ’s civil debt collection fees

Acknowledge that the $6,749,673 in the attached indemnification agreement represents an amount due HUD.

Acknowledge that $32,500,000 in the attached settlement agreement represents an amount due HUD, less DOJ’s civil debt collection fees.

Acknowledge that $7.23 million of the $14.5 million in the attached settlement agreement represents an amount due HUD, less DOJ’s civil debt collection fees.

Acknowledge that $6,076,741 of the $13,200,000 in the attached settlement agreement represents an amount due HUD, less DOJ’s civil debt collection fees.

We also recommend that the Director of HUD’s Departmental Enforcement Center evaluate the apparent conflict-of-interest situations in this report and pursue administrative sanctions if warranted.

Evaluate the apparent conflict-of-interest situations in this report and pursue administrative sanctions if warranted.