Establish internal and financial controls to ensure that it allocates, tracks, and reports future non-Federal match costs separately from other disaster recovery costs within the DRGR system for future disasters, which will ensure that at least $1.3 million is correctly reported as other disaster recovery costs rather than as costs that Colorado is using to meet its non-Federal match requirements.

Provide documentary support in the DRGR system that it met and did not exceed the match percentage set by FEMA for its completed Public Assistance activities

Require grantees to include in their DRGR system’s reports their non-Federal match costs in a manner that documents that they have met FEMA’s set match percentage requirements and issue a template to grantees to ensure consistency of reporting in their systems of records.

Instruct PRDOH to remediate all outside installations that are directly exposed to sunlight and the elements or repay HUD $19,185,244 from non-Federal funds.

Instruct PRDOH to enforce its contract terms and conditions, which requires installers to install batteries and inverters outside of direct sunlight and exposure to the elements.

Instruct PRDOH to address and correct all the deficiencies noted for the properties inspected.

Require PRDOH to implement a review process to better structure its future contracts to ensure that the scope of work is clearly defined so that all parties understand the agreement. This includes, but is not limited to, ensuring that the basic subtasks needed to complete projects are considered and included only as necessary in future contracts.

Instruct PRDOH to re-evaluate its use of the IRS Form 1040 AGI calculation methodology to assess participants’ income compared to the income calculation methodology defined under Section 8 program at 24 CFR § 5.609 and determine whether it ensures consistent eligibility determination for the program.

Work with borrowers and lenders to develop a plan to address the issues for each of the 58 defaulted loans within a reasonable time frame and implement corrective actions for the 58 loans; thereby protecting HUD’s investment of $329,541,272.

Quantify the amount of unauthorized distributions in the portfolio of 21 properties with 35 loans reported by the independent public accountant on the borrowers’ audited financial statements covering fiscal years 2018 to 2024 and require the borrowers to repay the amount of unauthorized distributions or pursue enforcement of the borrowers’ regulatory agreements by a written referral to HUD’s DEC.

Flag all principals of the borrowers with unreimbursed and unauthorized distributions in the Active Partners Performance System (APPS) to ensure that HUD appropriately evaluates the risks associated with doing business with these principals.

Refer any borrowers to the DEC for a civil money penalty or any other appropriate enforcement actions within 60 days of borrowers’ financial statement receipts for all unauthorized distributions not repaid within 30 days. If HUD ORCF chooses to allow a longer repayment period, document in iREMS the amount of the loan, the longer repayment period, and the reasons for the longer period.

Document DEC decisions and any penalties awarded in iREMS for each affected property for any ORCF referrals to the DEC about unauthorized loans.

Flag any borrowers in APPS for each unpaid penalty to ensure that HUD appropriately evaluates the risks associated with doing business with these principals.

Determine and document in iREMS the reasons that the borrowers did not make the mortgage payments and the specific steps HUD is taking to address the borrowers’ failure to make mortgage payments for all failures to make mortgage payments listed in borrowers’ audited financial statements.

Train HUD Account Executives on how to evaluate borrower action plans to ensure that action plans identify specific risks, identify the root causes of each risk, develop actions to address each root cause, identify specific measurable goals for each risk, and establish a timetable to complete the planned actions. Also, train HUD Account Executives on how to work with borrowers and lenders to ensure that borrowers properly develop, implement, and adhere to their action plans.

Develop and implement policies and procedures to ensure that borrowers and lenders execute action plans that properly list all specific risks at a property, identify the root causes of each risk, specify the actions to address each root cause, and establish a timetable to complete each action.

Develop and implement policies and procedures to ensure that HUD Account Executives document each action plan, properly list all specific risks at a property, identify the root causes of these risks, specify the actions to address the root causes, establish the timetables for completion, and document monthly progress towards completion of the actions in iREMS.

Develop and implement policies and procedures for a course of action when borrowers and/or lenders do not timely develop action plans. These policies and procedures should include civil money penalties, flagging the borrower in APPS, and inclusion in the Excluded Parties List System.

Update the protocols to ensure that all HUD ORCF teams working with any subset of the portfolio have insight into the entire portfolio for any portfolio split amongst lenders.