Review the Clearance Calendar and ensure that appropriate form HUD-22 concurrence forms were obtained and documented for directives issued by other HUD offices.

Implement controls to ensure that future directives are reviewed and documented in the Clearance Calendar tracking system as required.

Update policies and procedures for the directives process, including responsibilities for process oversight and clear guidance defining when clearance is required.

Develop and provide training to appropriate staff and required reviewing offices regarding the departmental clearance process requirements.

Support that $1,432,222 in central office cost center expenses allocated to the public housing program projects were eligible, necessary, and reasonable costs of the program. Costs that cannot be supported, or were unnecessary, unreasonable, or for ineligible program costs should be reimbursed to the program from non-Federal funds.

Implement adequate procedures and controls, including but not limited to developing a plan to manage its central office cost center expenses and determining an appropriate fee structure with HUD’s approval that would allow it to operate its program within HUD’s requirements.

Implement adequate procedures and controls, including but not limited to providing training to its staff to ensure that the Commission fully implements asset management and operates its program in accordance with HUD’s requirements.

Require public housing agencies to run the Enterprise Income Verification existing tenant search during the admission process and retain the results in the tenant file, which would avoid unnecessary costs to HUD’s subsidy programs, allowing an estimated $935,283 to be put to better use.

Require public housing agencies to report the program admission date to any multifamily property listed on the Enterprise Income Verification existing tenant search during the admission process.

Require public housing agencies to maintain support for any communication with a multifamily property listed on the Enterprise Income Verification existing tenant search.

Require HUD staff to review Enterprise Income Verification reports from the last 12-month period during onsite housing agency reviews to ensure that any multiple subsidies have been resolved.

Implement recommendations 1A through 1D to ensure that $2.24 million in housing assistance funds will be put to better use.

Reimburse its program $28,199 ($19,771 $7,793 $635) from non-Federal funds for the overpayment of housing assistance and ineligible administrative fees it received for the deficiencies cited in this report.

We recommend that the Director of the Public Housing Financial Management Division determine whether any of the overpayment of $3,630,286 was ineligible and take appropriate actions to recoup the ineligible payments.

We recommend that the Director of the Public Housing Financial Management Division validate the $1,191,767 in underpayments and determine if any corrections should be made.

We recommend that the Director of the Public Housing Financial Management Division recapture the overpayment of $116,218 disbursed for the units, which exceeded the PHAs’ Faircloth limit.

Provide documentation to support program accomplishment data related to disbursements totaling $292,611 or repay HUD from non-Federal funds for any amount that it cannot support.

Develop and implement written policies and procedures with an emphasis on increased controls toward the monitoring, tracking, underwriting, and evaluating of the Section 184 program. Implementing these controls would reduce the current high level of risk in the program and result in potentially $76,967,618 in funds to be put to better use (see appendix A).

Develop and implement policies and procedures for a standardized monthly delinquency report format that lenders must follow when submitting information to OLG.

Develop and implement policies and procedures to deny payments to direct guarantee lenders for claims on loans that have material underwriting deficiencies.