Develop and implement policies and procedures for the use of reserve for replacement funds, which ensure that the project does not use operating funds for any items that qualify for the use of reserve for replacement funds.

We recommend that the Southwest Region Director of Multifamily Housing require the Louis Manor Apartments’ owner to support that the subsidies for 14 tenants with missing income verifications, income discrepancies, incorrect annual income, and missing annual certifications were adequately supported and accurate or repay HUD $268,452 for those subsidies. Repayment must be from nonproject funds.

We recommend that the Southwest Region Director of Multifamily Housing require the Louis Manor Apartments’ owner to implement appropriate controls to ensure that it conducts annual recertifications for all tenants in a timely manner, as required.

We recommend that the Southwest Region Director of Multifamily Housing require the Louis Manor Apartments’ owner to properly house the five families discussed in the finding in the correct unit size when an appropriate sized unit is available and ensure that its other tenants are housed in the correct unit size.

We recommend that the Southwest Region Director of Multifamily Housing require the Louis Manor Apartments’ owner to perform inspections for the units that lacked inspection reports

We recommend that the Southwest Region Director of Multifamily Housing require the Louis Manor Apartments’ owner to implement appropriate controls to ensure that it performs annual inspections, as required.

We recommend that the Southwest Region Director of Multifamily Housing require the Louis Manor Apartments’ owner to implement appropriate controls to ensure that tenants are eligible, housing assistance subsidies are accurate, and tenant files contain all required documentation.

Acknowledge the settlement amount of $149,500,000 and that $115,000,000 of the settlement represents restitution due HUD less DOJ’s civil debt collection fees.

We recommend that HUD’s Office of General Counsel, Office of Program Enforcement, acknowledge that the $40,000 in the settlement agreement represents an amount due HUD.

Develop and implement controls and procedures to ensure that HUD’s underwriters properly evaluate the creditworthiness of management agents when underwriting future loans.

We recommend that the Southwest Region Director of Multifamily Housing require the Eastwood Terrace Apartments owner to support that the subsidies for 77 tenants and units with income discrepancies, missing EIV reports, missing income verifications, missing annual certifications and missing signatures are supported and accurate or repay HUD $1,865,344 for those subsidies. Repayment must be from non-project funds.

We recommend that the Southwest Region Director of Multifamily Housing require the Eastwood Terrace Apartments owner to ensure tenants are housed in the correct unit size.

We recommend that the Southwest Region Director of Multifamily Housing require the Eastwood Terrace Apartments owner to ensure annual inspections are performed in a timely manner and in accordance with HUD requirements.

We recommend that the Southwest Region Director of Multifamily Housing require the Eastwood Terrace Apartments owner to ensure that its new property management agent is providing oversight to its onsite staff and that its recently implemented quality control program is working as designed and in accordance with HUD requirements.

We recommend that the Southwest Region Director of Multifamily Housing require the Eastwood Terrace Apartments owner to maintain tenant files in a manner that ensures they contain the correct records and all required documentation.

Provide supporting documentation for subsequent review to show that it properly calculated relocation rental assistance payments for the 10 tenants and if there is an overpayment, reimburse the applicable RAD relocation account from non-Federal funds.

Repay the project the $1,168,000 in ineligible distributions made to affiliated healthcare facilities during fiscal years 2015 and 2016.

Implement controls to ensure that project distributions are made from surplus cash and comply with the regulatory agreement and HUD requirements.

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

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.