Develop and implement controls to ensure that the independent entity approved in recommendation 1J performs rent reasonableness determinations for program units that it substantially controls.

Pursue the collection of the $5,690,000 in surplus proceeds that HUD was entitled to receive from 2017 loan terminations.

Implement a policy to require servicers to send surplus proceeds notifications to the HUD Secretary-held assets servicing contractor and establish procedures to improve HUD’s surplus proceeds collection efforts.

Redesign the partial claim program to eliminate its weaknesses and ensure that partial claims benefit from a stronger lien position to put $6,770,000 to better use.

Obtain HUD approval of policies and procedures before executing its subrecipient agreements and ensure that its finalized policies and procedures include but not limited to financial management, procurement, duplication of benefits, and monitoring.

Establish adequate financial controls to ensure that its disaster funds are properly classified and allocated to the correct grant and ensure that DRGR drawdowns are conducted in a timely manner.

Provide adequate training to staff on the appropriate classification of disaster recovery activities to ensure costs are accurately allocated and recorded.

Continue to establish a data sharing agreement with FEMA for Hurricanes Hermine and Matthew to ensure that all sources of funding are included in its disaster policies and procedures to prevent duplication of benefits and ensure that the term of the agreement is sufficient.

Continue to negotiate with SBA to extend its data-sharing agreements for the term of the expenditure requirements set forth in public laws or the Federal Register.

Continue to fill its vacancy and assess staffing resources as it prepares for additional disaster 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.

Submit any outstanding audited financial statements.

Review the audited financial statements and determine the amount of outstanding mortgage payments due.

Work with the local multifamily office to make any outstanding mortgage payments or devise a plan to bring the property current through the use of available funds.

Develop and implement policies and procedures to ensure that the certified public accountant submits audited financial statements by the required HUD deadline.

Maintain separate books of account and submit audited financial statements solely for the project.

Reimburse the project’s operating account $50,400 from the reserve for replacement account.

Receive training on the proper use of its reserve for replacement account.

Develop and implement policies and procedures for the use of reserve for replacement funds, which ensure that the project does not use operating funds for any items that qualify for the use of reserve for replacement funds.

Require the 12 grantees to correct their action plans to ensure that they comply with program requirements and submit the corrected plans to HUD for review or require the grantees to repay HUD from non-Federal funds for any amount of the $7,779,450 they received that they cannot support.