Implement adequate policies and procedures to ensure that payments to subrecipients are issued in accordance with HUD’s requirements.

Provide adequate training to staff associated with the administration of the ESG program to ensure compliance with HUD’s requirements, including timely drawdowns.

Implement adequate policies and procedures for conducting complete and consistent monitoring of subrecipients’ matching requirements, including confirming eligibility and existence of matching funds to ensure compliance with HUD’s requirements.

Acknowledge that $42,600,000 of the $65,000,000 in the attached settlement agreement represents an amount due HUD, less DOJ’s civil debt collection fees.

Acknowledge that $1,670,000 in the attached settlement represents an amount due HUD less DOJ’s civil debt collection fees.

Reimburse its program $373,860 ($302,638 in ineligible housing assistance payments $63,643 in associated administrative fees $7,579 in program funds paid to the contractor) from non-Federal funds for the inappropriate payments cited in this finding.

Seek retroactive approval or reimburse its program $358,237 ($339,908 in housing assistance payments $18,329 in program funds paid to the contractor) for the housing quality standards inspections of units owned by entities substantially controlled by the Authority, completed by contractors that were not approved by HUD.

Implement adequate procedures and controls to ensure that the Authority complies with HUD’s requirements for program conflicts of interest, including but not limited to ensuring that (1) its staff does not complete inspections for units owned by entities substantially controlled by the Authority, (2) its staff is appropriately trained and familiar with HUD’s requirements for units owned by entities it substantially controls, and (3) future…

Reimburse its program $163,316 from non-Federal funds ($29,074 in housing assistance due to calculation errors 74,957 due to inappropriate voucher sizes, payment standards, and utility allowances $18,141 $41,144 in administrative fees) for the inappropriate payments cited in this finding.

Reimburse the appropriate households $9,280 ($2,588 in housing assistance underpayments due to calculation errors $6,692 due to inappropriate voucher sizes, payment standards, and utility allowances) from program funds for the inappropriate underpayments cited in this finding.

Support or reimburse its program $2,533 from non-Federal funds for the unsupported payments of housing assistance cited in this finding.

Pursue collection from the applicable households or reimburse its program $470 from non-Federal funds for the overpayment of housing assistance due to unreported or underreported income.

Reimburse the appropriate households $3,178 from non-Federal funds for the rent amount paid in excess of 40 percent of the adjusted monthly income for the units that were not affordable.

For the five household’s residing in units that were not affordable, renegotiate the rent to the owners or require the households to move into units that are affordable.

Implement adequate procedures and controls to ensure that (1) housing assistance payments are appropriately calculated and supported, (2) households reside in units that are affordable, and (3) repayment agreements are created to recover overpaid housing assistance when unreported income is discovered during the examination process to ensure that $108,214 ($103,841 in potential overpayments $4,373 in potential underpayments of housing…

Evaluate its quality control process to ensure that calculation, voucher size, payment standard, and utility allowance errors are identified and appropriately corrected.

We recommend that the Director of HUD’s Houston Office of Community Planning and Development require the Department to train its staff regarding HUD requirements and regulations or seek technical assistance.

Revise servicing review and monitoring policies and procedures to emphasize increased controls on reviewing claim loans showing that no loss mitigation evaluation occurred. Revising the policies and procedures would reduce the risk to HUD and result in a projected $120,902,564 in funds to be put to better use (appendix A).

Develop and implement policies and procedures to ensure that the Office of Single Family Asset Management and Office of Lender Activities and Program Compliance communicate the results of their servicing reviews to each other.

Update and revise policies and procedures, including reinforcement of guidance (for example, mortgagee letters, notifications to servicers, or training) to ensure that servicers accurately report the status of delinquent loans to HUD.