Review and update the project’s waiting lists to include the missing dates and required notations.

Develop and implement adequate procedures and controls to ensure that the project complies with HUD’s requirements and its own policies regarding the management of its waiting lists.

Determine whether the households residing in the project’s assisted units received housing in accordance with the program’s requirements and if not, consider a referral to HUD’s Office of Fair Housing and Equal Opportunity.

Reimburse the project $17,761 from nonproject funds for the project operating funds disbursed for ineligible expenses.

Support or reimburse the project $17,653 from nonproject funds for the project operating funds disbursed without sufficient supporting documentation.

Reclassify and properly record $45,000 in owner advances misclassified as loans.

Strengthen controls to ensure that project advances are reimbursed only when the project is in a surplus-cash position.

Implement adequate controls to ensure the review of the management agent fee to ensure that it is properly calculated in accordance with the HUD management agent certification and approved prior to payment from project operating funds.

Implement adequate controls to ensure that project funds are used only for eligible and supported operating expenses.

Obtain a formal agreement and approval from HUD to specify who is authorized to use the project’s community and recreation rooms and what activities are authorized or prohibited. In addition, this agreement must ensure that sufficient legal and liability protections are in place, establish consequences for noncompliance, and determine who is to pay for the utilities and maintenance of the rooms.

Amend the management agent agreement compensation schedule to remove bookkeeping fees as a fee separate from the 8.9 percent management agent fee.

Reimburse its program from non-Federal funds for the $62,377 used to pay for the excess executive compensation.

Develop and implement written policies, procedures, and other financial controls to ensure that Sections 8 and 9 funds are not used to pay for compensation over the salary limit.

Reimburse the U.S. Treasury from non-Federal funds for the $5,000 in ineligible costs paid to its contractor.

Develop and implement written policies and procedures for the payment review process to comply with applicable regulations in 2 CFR Part 200.

Train its staff on its newly developed policies and procedures noted in recommendations 1B and 1D.

Acknowledge that the attached settlement agreement of $325,000 represents an amount due HUD from Pacific Horizon.

Acknowledge that the attached settlement agreement for $15,000 represents an amount due HUD from the two loan officers.

Acknowledge that $3,375,163 in the attached settlement agreement represents an amount due HUD, less DOJ’s civil debt collection fees

Acknowledge that the $6,749,673 in the attached indemnification agreement represents an amount due HUD.