Reimburse its program $279 from non-Federal funds for the ineligible payment it made due to the conflict-of-interest situation identified by the audit.

Develop and implement controls to prevent and detect conflict-of-interest situations.

Provide documentation to show that indirect payroll expenses totaling $225,182 charged to the program were reasonable and necessary or repay its program from non-Federal funds for any amount that it cannot support.

Develop and implement a cost allocation plan to use as a basis for charging indirect payroll expenses to the program.

Provide documentation to show that administrative fees totaling $47,376 were used to perform administrative duties for the program or repay its program from non-Federal funds for any amount that it cannot support.

Develop and implement controls to ensure that administrative fees are used to perform administrative duties for the program.

Certify, along with the owners of the 10 units cited in the finding, that the applicable housing quality standards violations have been corrected.

Provide training to its inspector on conducting housing quality standards inspections.

Develop and implement controls to ensure that an independent entity performs housing quality standards inspections of units that it substantially controls.

Submit a request for approval of an independent entity to perform rent reasonableness determinations for program units that it substantially controls.

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.