Determine whether it has complied with environmental review requirements for all activities since October 2010 and provide a copy of its determination to HUD. If it did not comply, either provide the necessary support for the activities or repay its program from non-Federal funds for any activity costs it cannot support.

Develop and implement controls to ensure that it complies with environmental review requirements.

Review accomplishment data that it reported in IDIS for open and completed activities to ensure that accomplishments were reported accurately.

Train its staff on reporting accomplishments in IDIS and develop and implement policies and procedures for supervisory review to ensure accuracy.

Include compliance with environmental review requirements in its project-specific reviews in its next periodic monitoring of the City’s Block Grant program.

Pay the project $282,578 from non-project funds for the fair value of the commercial rent not collected from the lessees.

Request approval from HUD to lease the commercial space. If HUD approves the request, then execute a lease at fair market rent thereby increasing the project’s rent revenue by at least $36,858 per year.

Request approval from HUD for the $31,769 in project operating funds spent on building improvements or repay the project from nonproject funds for any amount not approved.

Provide documentation to show that the $39,920 paid to replace an air conditioning system was fair and reasonable or repay the project from nonproject funds any amount determined not to be fair and reasonable (excluding any amount repaid as a result of recommendation 1C).

Remove the $25,000 lien on the project property.

Repay the project $8,597 from nonproject funds for the ineligible expenses it incurred for management fee and gas utility expenses that were identified by the audit and any additional management fee and gas utility expenses improperly paid outside of our review period.

Develop and implement controls to ensure that financial statements are submitted to HUD in a timely manner, including paying the correct amount of annual payments according to the terms of the mortgage.

Develop and implement controls to ensure that the project complies with applicable HUD requirements.

Recalculate the project’s annual surplus cash balances for 2013, 2014, and 2015 after resolution of recommendations 1A, 1C, 1D, and 1F to determine whether the project should make additional payment to HUD from surplus cash toward its mortgage beyond the $13,740 that it paid during the audit.

Provide training and technical assistance to the owner and its management agent to ensure compliance with the terms of its mortgage and other applicable HUD requirements.

Director for the Office of Field Management ensure that the CDBG-DR risk analysis worksheet includes risk factors that show the measurement of performance outputs to determine completed activities.

Director for the Office of Field Management update the risk analysis guidance for CDBG-DR grants to include the assessment of the likelihood of risk occurrence to help inform management which critical risks to address during monitoring.

Director for the DRSI Division ensure that monitoring strategies correlate to the high-risk areas identified during the risk analysis and are in compliance with the central risk factor categories identified in HUD’s Monitoring Desk Guide.

Ensure that CPD personnel that plan for, award, and manage grants and other forms of financial assistance receive formal risk analysis training.

Acknowledge that $45 million in the attached settlement agreement represents an amount due HUD, less the Department of Justice’s civil debt collection fees.