Implement controls to ensure that it does not enter into future third-party agreements unless the Authority follows applicable requirements in Notice PIH 2017-24 (HA), the annual contributions contract, 24 CFR Part 970, and the United States Housing Act of 1937.

Improve controls over the proper execution and recording of all declaration of trust documents.

Submit a Section 18 application to obtain HUD approval of any proposed new lease agreement prior to its execution, in compliance with the United States Housing Act of 1937 and 24 CFR Part 970.

Repay from non-Federal funds any proceeds used for unallowable expenses identified in recommendation 1C.

Correct the reporting and use of proceeds received from the current lease, thereby putting $1,278,260 to better use.

Execute and record the release of the current lease with the third party and ensure that the declaration of trust is returned to the first priority position.

Terminate the current lease and pay for any fees needed to terminate the lease from non-Federal funds.

We recommend that HUD’s Deputy Assistant Secretary for Public Housing and Voucher Programs ensure that personnel receive training on how to conduct the civil rights front-end reviews, including a review of PHAs reasonable accommodation policies and procedures.

We recommend that HUD’s Deputy Assistant Secretary for Public Housing and Voucher Programs review the joint agreement between HUD PIH and FHEO, including the Section 504 checklist, and modify, update, or recommit to it to ensure that the role of PIH and the responsibility for conducting civil rights front-end reviews is clearly defined.

We recommend that HUD’s Deputy Assistant Secretary for Public Housing and Voucher Programs require that PHAs track requests for reasonable accommodation, including the date of the request, the type of request, and the disposition and date of any action taken that should be made available to HUD at its request.