Develop and implement policies and procedures to ensure that its required matching contributions are properly supported.

Develop and implement policies and procedures to ensure that it reports data through its CAPERs using data from its own financial management system instead of data from HUD’s information system.

Track and ensure that Volunteers returns to the Treasury any funds recovered through the ongoing litigation pertaining to the Yabucoa housing project.

Deobligate and recapture $1,440,165 in undrawn Section 202 funds assigned to the project.

Require Volunteers to reimburse to the United States Treasury $140,000 from non-Federal funds for ineligible project construction costs charged to the Section 202 project.

Return to the Puerto Rico Department of Housing $1,057,467, plus any interest earned, for the duplicate special escrow fund payments it received.

Conduct onsite management reviews of the projects to supplement the onsite use restriction agreement compliance monitoring reviews to ensure that the projects are operated in accordance with HUD’s requirements.

Work with the Office of Multifamily Asset Management and Portfolio Oversight to develop and issue guidance on requirements in the grant and use agreements that would benefit the grantees’ board members and staff of the projects’ management agents.

Adequately support or reimburse its NSP3 grant subrecipient $53,760 from non-Federal funds for the disbursements not adequately supported.

Update its records retention policy to meet HUD’s records retention requirements and notify its NSP subrecipients of the documentation retention requirements for the NSP grants.

Develop a retention strategy for its subrecipients to ensure that documentation is readily available for review.

Deobligate all obligations marked for deobligation during the departmentwide OOR, including as much as $11,463,971 in 189 program obligations and $13,640 in 10 administrative obligations marked for deobligation as of September 30, 2017.

Review the 1,110 identified inactive retained obligations with remaining balances totaling $229,327,332 and close out and deobligate amounts tied to obligations that are no longer valid or needed.

Close out and deobligate the remaining balances on 2,741 expired homeless assistance contracts of $159,437,069.

Deobligate all obligations marked for deobligation during the departmentwide OOR, including as much as $42,491,202 in 581 administrative obligations and $2,932,320 in 12 program obligations marked for deobligation as of September 30, 2017.

Review the 84 identified inactive retained obligations with remaining balances totaling $56,435,559 and close out and deobligate amounts tied to obligations that are no longer valid or needed.

Review and if necessary deobligate the 40 and 30 expired or inactive Section 236 and Section 202-811 projects totaling $17,416,572 and $86,715,301, respectively.

Require the operator to notify HUD of future management agents prior to participation and to complete the required management agent documents with the current management agent or seek reimbursement for the $2,666,082 in management fees paid in fiscal years 2015 and 2016.

Submit the operating lease for HUD review and complete the operating lease addendum in accordance with HUD requirements.

The County does not reimburse itself with program funds for the $452,444 in County bond proceeds originally budgeted for the Armstrong Park project and used to pay for flood protection improvements in the Graue Mill subdivision in Hinsdale.