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.

Put all project bank accounts in the name of the project.

Separate all owner bank accounts from the project’s bank accounts.

Develop and implement controls over the distinction between project funds and owner funds. These controls should include policies related to when the owner is allowed to take project funds owed to the owner.

Take HUD-approved training related to operating and maintaining a multifamily project.

Repay the project’s operating account from nonproject funds for the $142,805 spent on ineligible expenses.

Provide support for the $12,355 in project funds spent to pay individuals who were not on the payroll and for services provided for project operations. For any portion of this amount that is not supported, the owner should repay the project operating account using nonproject funds.

Obtain training on the eligible use of project funds.

Develop and implement detailed policies and procedures for procurement, travel, and the use of its credit cards. These controls should comply with HUD regulations regarding procurement and other disbursement documentation requirements.

Develop and implement policies and procedures to ensure that the property owners receive the required information concerning lead-based paint disclosure requirements, risk assessment results, summaries of treatments and clearances, and ongoing maintenance activities, including how to report paint deterioration.

Amend its 2015 annual action plan to include the Main Street Revitalization program.

Implement controls and procedures to ensure that all future action plans include all methods of distributing grant funds or amend the plan as required if programs are added after approval.

Require the Authority to design and implement controls to ensure that employees comply with RAD relocation requirements and that its RAD conversion plans submitted to HUD accurately address any tenant relocations.

Monitor the Authority to ensure that it does not improperly relocate tenants during its planned conversion of the remaining public housing units.

Conduct a compliance review of relocation and pursue corrective action as necessary on behalf of the permanently relocated tenants.

Support the $797,222 in code enforcement costs, including meeting code enforcement and salary and benefits requirements, or repay its program from non-Federal funds.

Develop and implement written policies and procedures to define deteriorated or deteriorating areas, which would apply to its CDBG-eligible target areas, and establish a written plan for using the program, in conjunction with public or private improvements, rehabilitation, or services, that may be expected to arrest the decline in CDBG-eligible target areas.

Develop and implement written procedures and controls to properly track and charge code enforcement officers’ costs among different CDBG activities and other funding sources.

Provide training to code enforcement staff on HUD CDBG regulations and requirements.