Develop and implement procedures to require owners, operators, and lenders to submit accurate and complete financial data.

Develop and implement internal controls to routinely compare financial data on mortgage payments to Multifamily Delinquency and Default Reporting System data on mortgage payments and follow up on any conflicting data.

Develop and implement procedures for referring operators who fail to provide required financial statements to the Departmental Enforcement Center.

Develop and implement metrics to evaluate each nursing home’s financial data for changes in utilization, payments, profitability, and solvency (debt service credit ratios).

Implement adequate procedures and controls to ensure that borrowers’ delinquent and default information is accurately reported.

Provide verification to HUD that it has taken the appropriate action to correct its delinquent or default status code reporting for the borrowers affected as a result of its system change.

Ensure that staff responsible for making entries into its servicing system is properly trained and understands HUD’s reporting requirements.

Procure appropriate HUD-approved investment accounts and move all Federal funds from the STAR Ohio investment accounts to HUD-approved accounts to ensure that $20,706,862 or the current balance of the STAR Ohio accounts is properly protected.

Implement adequate procedures and controls to ensure that the Authority complies with HUD’s requirements for its investments of Federal funds.

Ensure that its staff is properly trained and familiar with HUD’s requirements to ensure that it properly procures and invests Federal funds in HUD-approved investment accounts.

Ensure that the proceeds from the sale of Bollinger Tower proceeds are moved into a separate HUD-approved restricted investment account and appropriately recorded in a restricted account in the general ledger.

Implement adequate policies and procedures to ensure that future proceeds from the disposition or sale of public housing are appropriately recorded and reported in the Authority’s books of record and annual audited financial statements and HUD’s Financial Data Schedule system.

Ensure that its staff is appropriately trained and familiar with HUD’s requirements to ensure that proceeds from future dispositions or sales of public housing property or other HUD assets are appropriately recorded and reported.

Determine the source of funds for the Waggoner Senior Housing note to ensure that the funds were loaned appropriately and that when payments are received, the payments are applied to the appropriate account. If the source of funds cannot be determined, the Authority should reimburse its program $261,990 from non-Federal funds.

Ensure that the newly developed procedures are sufficient and fully implemented to ensure that the source of funds loaned is properly tracked and that payments received are applied to the appropriate accounts.

Support the reasonableness of the $258,412 paid for contract M-1449 or reimburse its Capital Fund program from non-Federal funds.

Support that the contract modification totaling $4,899 for contract number M-1449 was reasonable. The amount that cannot be shown to be reasonable should be reimbursed to its Capital Fund program from non-Federal funds.

Implement adequate procedures and controls to ensure that it complies with HUD’s procurement requirements.

Ensure that its staff is properly trained and familiar with HUD’s requirements to ensure that documentation necessary to support the reasonableness of contract costs is obtained and maintained.

Implement adequate procedures and controls to ensure that capital funds are drawn down and disbursed in accordance with HUD’s requirements.