We recommend that the Director of HUD’s Office of Davis-Bacon and Labor Standards seek guidance from the Department of Labor to correct the wage determinations where applicable for the five projects addressed in this report.

We recommend that the Director of HUD’s Office of Davis-Bacon and Labor Standards based on the outcome of recommendation 1A, determine the correct wages to be paid to workers and ensure that appropriate actions are taken to pay the workers.

We recommend that the Director of HUD’s Office of Davis-Bacon and Labor Standards update HUD Handbook 1344.1, REV-2, CHG-2, and Labor Relations Letter No. LR-96-03 to comply with the Department of Labor’s policies and guidance on the application of wage determinations for construction projects.

We recommend that the Director of HUD’s Office of Davis-Bacon and Labor Standards develop and implement controls to ensure that the appropriate Davis-Bacon wage rate determinations are implemented in the contracts of FHA-insured multifamily construction projects that require multiple wage determinations, including the requirement that contract specifications clearly identify the portions of the contract subject to each assigned wage determination, and that adequate documentation to support wage determinations is maintained.

Require the Authority to reimburse the six tenants who overpaid rent totaling $1,550 using non-Federal funds.

Require the Authority to develop and implement internal control procedures that support its policy and ensure a proper tenant selection process when selecting tenants for housing.

Ensure that the Authority follows all applicable HUD requirements related to accessing, use, and safeguarding credentials of HUD systems.

Conduct a nationwide assessment of the impact of portability and determine whether technical assistance is necessary for certain public housing agencies. Consider seeking input from public housing agencies and industry groups to evaluate the potential impact of portability and (1) determine whether improvements to the portability aspect of the program are warranted, and (2) if deemed warranted, determine how the improvements will be implemented for public housing agencies portable vouchers (both port-in and port-out).

Pursue collection or recapture $248,514 ($115,335 $133,179) from the applicable public housing agencies for the overpayment of category 2b portability set-aside funds and special administrative fees cited in this finding.

Distribute $35,189 to the applicable public housing agencies for the underpayment of special administrative fees for portability cited in this finding.

Review the calculations and distributions of funds for the 2019 category 2b portability set-aside and special administrative fees for portability to ensure that the spreadsheet errors did not carry forward from the previous calculations.

Request indemnification for the 7 of the 11 loans that had material underwriting deficiencies (appendix D). The unpaid balance for these loans is $1.3 million and the estimated potential loss to HUD is $607,598.

Require the lender to develop and implement enhanced policies and procedures to ensure electronic signatures from borrowers are properly supported.

Require the lender to fully implement its quality control plan with respect to reverifications and provide HUD with periodic reports for 12 months to ensure that it conducts its quality control reviews in accordance with the requirements.

Put $256,824 to better use by cancelling the project-based voucher housing assistance payments contract resulting from the RAD conversion. The Authority should work with HUD and the owner to protect the tenancy of the affected tenants at the time of contract cancellation.

Reimburse its Section 8 program $138,925 in associated administrative fees from non-Federal funds for the improper issuance of tenant protection assistance and an improper conversion to the project-based voucher program.

Develop and implement procedures to ensure that forms HUD-50059 and or tenant profiles is received from HUD before providing tenant protection assistance resulting from a completed housing conversion action.

Provide adequate training to staff associated with administering tenant protection and project-based vouchers to help address its lack of familiarity with requirements and ensure compliance with program requirements.

Develop and implement procedures for executing Section 8 Project-Based Voucher Program housing assistance payments contracts related to RAD conversions.

Develop and implement an action plan that includes sufficient policies, procedures, and controls that address households living in assisted units having a sufficient supply of safe drinking water. Such policies, procedures, and controls should include but not be limited to (1) developing and implementing internal procedures to be notified, and share with public housing agencies, when the public water systems’ water exceeds the Environmental Protection Agency’s lead action level and (2) revising HUD’s applicable regulations, providing guidance to public housing agencies and Housing Choice Voucher Program landlords, and taking appropriate actions so that households living in assisted units have a sufficient supply of safe drinking water.