Monitor the Authority after the recommended training and tenant file reviews are complete to ensure that the executive director understands and properly implements public housing occupancy requirements.

Require the Authority to address actual or potential conflict-of-interest relationships in its Admissions and Continued Occupancy Policy.

Work with the Authority to develop a plan to ensure that a third party reviews the initial tenant certifications and annual recertifications with an actual or potential conflict of interest.

Ensure that the Authority’s board of commissioners and staff receive HUD-approved training on conflicts of interest.

Monitor the Authority to ensure that initial tenant certifications and annual recertifications with an actual or potential conflict of interest are appropriately handled.

Require the Authority to develop and implement detailed policies and procedures to address collections, tracking, and use of its laundry machine revenue.

Require the Authority to determine how much laundry machine revenue was not deposited into its accounts and used for eligible purposes and reimburse its program from non-Federal funds.

Monitor the Authority to ensure compliance with its new laundry machine revenue policies.

Implement a change to regulations at 24 CFR Part 203 to require curtailment of preforeclosure interest and other costs that are caused by lender servicing delays, resulting in $413,513,975 in funds to be put to better use. This should include updating or seeking statutory authority to update HUD’s regulations as necessary and coordinating with HUD’s Office of Finance and Budget, well before any changes go through departmental clearance, to…

Provide documentation to show that $793,101 paid to the City for legal services was cost beneficial. Based on the documentation, it should reimburse its Housing Choice Voucher Program from non-Federal funds for any amount that exceeded the cost savings.

Follow the terms of the agreement, HUD requirements, and its own policies and procedures to ensure that any intergovernmental agreements for goods and services are in compliance.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide documentation to show that the $594,012 disbursed due to the use of multipliers was for eligible, reasonable, necessary, and supported costs or reimburse its program from non-Federal funds.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide documentation to show that the $2,689 disbursed due to a higher than required overtime rate was supported by documentation from the trade unions or reimburse its program from non-Federal funds.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to reimburse its program $1,198 from non-Federal funds for overpaid wages due to billing and payroll errors.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to pay $544 in unpaid wages to the subcontractors of the affected employees and submit evidence that these employees have been paid.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide training to its staff to help ensure compliance with applicable cost principle, procurement, and Davis-Bacon requirements.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide documentation showing that it has strengthened its invoice review process to ensure that costs are eligible and supported before disbursing Disaster Recovery funds.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide documentation showing that payments made under the Rockaway Boardwalk construction management services contract complied with Davis-Bacon and Related Acts requirements and that restitution is made to affected workers for any underpayments identified.

Ensure that $1,385,791 ($1,229,684 in housing assistance payments and $156,107 in associated administrative fees) used by the Lexington-Fayette Urban County Housing Authority is supported through a valid and retroactive exemption from HUD’s third-party requirements. If a retroactive exemption cannot be issued, HUD should follow recovery procedures prescribed in HUD Handbook 2000.06, REV-4.

Revise the standard MTW agreement for all existing 39 MTW housing agencies to clearly and specifically support which provision(s) waive the third-party inspection requirements.