We recommend that the Chief Financial Officer determine whether the revised and completed detail transactions totaling to $435,263,268, which occurred before and after grant rounds obligation and expenditure dates, were ADA violations. If the transactions were violations, actions should be taken as required by the ADA.

We recommend that the Chief Financial Officer determine whether the revised and completed transactions totaling $496,913,235 and made more than a year after the original voucher entry were GAAP violations. If the transactions were violations, appropriate actions should be taken, including but not limited to adjusting the transactions in LOCCS and HUD’s financial statements.

We recommend that the Chief Financial Officer enter a 24-month expiration term into LOCCS for Disaster Recovery funding provided by the 2017 Act and monitor to ensure that expenses are not entered before or after the grant period.

We recommend that the Chief Financial Officer require CPD to enter into a separate grant agreement for each grantee’s round of disaster funding for funding provided by the 2017 and 2018 Acts.

We recommend that the Chief Financial Officer require CPD to monitor the detailed voucher transactions in the DRGR system to ensure that grantees appropriately record transactions.

We recommend that the Chief Financial Officer require CPD to prohibit grantees from revising completed vouchers in the DRGR system and require adjustments to be entered as new vouchers into the DRGR system, which will ensure that LOCCS records and tracks revisions.

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.

Repay to the program from non-Federal funds the $457,192 ($380,526 $48,420 $28,246) in NSP funds spent for the construction, air conditioning, and engineering services in instances in which procurement activities were not adequately performed.

Repay to the program from non-Federal funds $280,979 in NSP funds spent for property 1012 and identify and repay any additional costs spent on this property, including maintenance costs and any program income generated.

Repay to the program from non-Federal funds the $73,400 in NSP funds spent for mold and asbestos remediation work.

Reimburse the Housing Choice Voucher Program $10,861 from its various programs for the bank service charges inappropriately charged to its Program.

Determine the appropriate allocations of the bank service charges and reimburse its Housing Choice Voucher Program from the various programs to ensure that $1,848 is available for appropriate program use.

Ensure that its staff is appropriately trained and familiar with HUD’s expenditure and allocation requirements.

Develop and implement adequate procedures and controls to ensure that program expenditures are for eligible and supported program costs and that costs are appropriately allocated to its various programs as required.

Review the Authority’s Project-Based Voucher contracts, determine the total amount to be reimbursed to the project owners, and require the Authority to (1) remove all inappropriate language from its contracts, (2) issue amended contracts as necessary, and (3) reimburse the inappropriate charges to the applicable project owners from non-Federal funds.

Determine any remaining amounts for bank service charges inappropriately charged to the Housing Choice Voucher Program and ensure that the various programs reimburse the Program as appropriate for all bank service charges not appropriately allocated.

Determine whether the rent charged to the Housing Choice Voucher Program for the Family Self-Sufficiency program office space in the Authority’s main office and in its public housing property is appropriate and reasonable.

Require the Authority to reimburse its Housing Choice Voucher Program from non-Federal funds for any amounts determined not to be reasonable to ensure that $40,656 in program funds is available for appropriate program use.

Require the Authority to allocate any rents determined to be reasonable between its Housing Choice Voucher Program and Public Housing Family Self-Sufficiency program and require the Authority to reimburse its Housing Choice Voucher Program from its public housing program any amounts that should have been allocated among the programs.

Update and revise the CPD Notice to further improve the code enforcement guidance.