Remove Skyline Crest Enterprises, LLC, as the operator and replace it with a HUD-approved independent operator.

Develop and implement written policies and procedures for the management of the project, including but not limited to financial policies for cash disbursements, cash receipts, and documentation requirements.

Create and implement policies and procedures or change program regulations to prevent multifamily housing properties from charging more for Section 8 units than for comparable non-Section 8 units. For the 25 properties reviewed, this measure would prevent as much as $3,144,894 of Section 8 funds from subsidizing non-Section 8 units in the next year.

Deobligate $542,289 in fiscal year 2015 capital funds in HUD’s system until binding agreements are executed for eligible and reasonable purposes, or coordinate with HUD for terminating its funding.

Reclassify $398,022 in fiscal year 2016 capital funds as authorized in HUD’s system to an eligible and reasonable activity, or coordinate with HUD for terminating its funding.

Coordinate with HUD for terminating the allocation of the remaining $217,553 funds given the Authority’s current intentions to not build or purchase public housing units.

Develop and implement adequate procedures and controls to ensure that the reporting of allocated capital funds in HUD’s system is accurate.

Provide adequate training to staff responsible for making entries into HUD’s system to ensure accurate reporting on allocated funds. The training should include but not be limited to ensuring that its staff understands all of HUD’s reporting requirements for obligations and authorizations.

Confirm the replacement of program units was appropriate for the number of units demolished at Johnson Ferry East, and submit a development proposal to construct new public housing units, transfer public housing assistance to another public housing agency, or terminate its annual contributions contract and return all unobligated and unexpended capital funds to HUD.

Certify, along with the owners of the 11 units cited in this finding, that the applicable housing quality standards violations have been corrected.

Reimburse its program $9,715 from non-Federal funds ($9,660 for housing assistance payments and $55 in associated administrative fees) for the unit that materially failed to meet HUD’s housing quality standards.

Provide training to its inspectors on conducting housing quality standards inspections.

Investigate the 14 loans with unpaid mortgage amounts totaling $3,035,819, and require the lenders to obtain the borrowers consent, reinstate the insurance coverage, or take other action as appropriate given the facts of each particular loan.

Remind lenders that voluntary termination is not the correct termination type to record third-party sales and that borrower consent is required to terminate insurance, even if the loans are indemnified.

Improve its procedures for detecting and sanctioning improper voluntary terminations.

Update Handbook 4000.1 to require the voluntary termination of insurance consent form to include an explanation that voluntary termination differs from mortgage insurance premium cancellation and the disclosure of any outstanding partial claims to put $285,215 to better use.

Provide documentation to show that prices paid for purchases of products and services totaling $970,381 were fair and reasonable or reimburse the project from nonproject funds for any amounts that were not fair and reasonable.

Provide documentation to show that payments for work totaling $716,693 complied with applicable building codes or reimburse the project from nonproject funds for payments that did not comply with the codes and take action to bring the work up to code.

Provide documentation to support payments totaling $163,885 or reimburse the project from nonproject funds for payments that it cannot support.

Develop and implement written procedures to ensure that it obtains written cost estimates as required and maintains complete documentation to support expenditures and that contractors performing or managing construction, removal, repair, or improvement work are properly licensed as required.