Update HUD’s loss mitigation policies, to include deadlines for the servicers to report the new terms of the FHA-HAMP nonincentivized loan modifications, and consider imposing sanctions for noncompliance with these deadline requirements.

Implement a process to periodically audit or reconcile ARC’s records.

Implement a process to periodically review approving officials’ span of control to ensure that the requirement is not exceeded.

Implement a process with ARC to ensure that cardholders and approving officials are notified before purchase card training is due to allow training to be completed in a timely manner.

Implement a process to ensure that purchase cards are suspended when a cardholder or approving official fails to complete training.

Research why ARC provided incomplete monthly transactional data and identify a solution to ensure the completeness of future transmissions.

Enhance the process to periodically analyze data for split transactions or improper MCCs and follow up on any potential issues identified.

Require ARC to update its MCC tracking log, to include the amount, the date of MCC override removal, and staff assigned, to ensure that an override is removed after the approved purchase is made.

Implement a process with Citibank and ARC to provide global notifications to cardholders and approving officials before autoclosures of credit card statements.

Implement a process to suspend cardholders or approving officials who repeatedly cause HUD to pay interest.

Obtain supporting documentation for the $1,807 spent on two cardholders’ purchase cards or require the vendors or cardholders to repay the funds to the applicable HUD program.

Support that it met its $161,957 matching contribution required for the $647,827 it drew down for expenses related to its four HUD-funded programs. If the Community cannot provide support, it should reimburse HUD $577,6707 from non-Federal funds.

Develop and implement written policies and procedures to ensure that it maintains documentation to support matching contributions received in compliance with HUD requirements.

Repay HUD $15,163 from non-Federal funds for the rental assistance provided to five ineligible individuals.

Support the eligibility of the 11 individuals who received rental assistance through its rapid rehousing program or repay HUD $26,676 from non-Federal funds.

Work with HUD to determine the eligibility of current permanent supportive housing residents and if residents are determined ineligible, take appropriate action.

Implement its written policies and procedures to ensure that only eligible individuals receive rapid rehousing assistance.

Implement its written policies and procedures to ensure that individuals entering its permanent supportive housing are eligible.

Support or repay HUD $17,025 from non-Federal funds for the questioned payroll costs charged to the programs.

Develop and implement written policies and procedures to ensure accurate and complete reporting of staff hours charged to each program.