Require the Authority to determine whether the Authority improperly used Federal funds totaling $50,000 which were used to pay unnecessary severance contract costs. If Federal funds were improperly used, the Authority should repay $50,000 to its Federal program accounts from non-Federal funds. If the Authority is unable to accurately determine the amount due to and due from each program or support that the funds charged to the Federal program were appropriate, the full $50,000 should be repaid to HUD.

Update selection rules for CAIVRS to provide for complete reporting of all ineligible borrowers to put $9.5 million to better use.

Status

In 2020, HUD suspended reporting delinquencies and defaults to the Credit Alert Verification Reporting System (CAIVRS) because these debts are owed to the lender and are not delinquent Federal debt. A debt is not delinquent until a payment is past due to HUD for a deficiency judgment against the borrower in connection with an FHA claim. Rather than add the missing borrowers to CAIVRS, HUD determined it would remove default and claim data from the system and use it to exclusively identify borrowers with delinquent Federal debt. This will resolve the issue of incomplete reporting of delinquent federal debts greater than 3 years old. As of early June 2024, the Office of Single Family Housing stated that it was on target to complete its action plan by June 28, 2024.

Analysis

To fully address this recommendation, HUD must provide evidence that it removed default and claim data from CAIVRS.

Implementation of this recommendation should result in HUD putting $9.5 million to better use.

Revise HUD’s asset management fee policy to refederalize the Operating Fund program’s management and bookkeeping fees and the Capital Fund program’s management fees.

HUD should remove the provision that allows public housing authorities to charge asset management fees, which would ensure that at least $81.6 million in operating funds could be put to better use in meeting HUD program objectives.

Establish and implement procedures to reassess the management and bookkeeping fees periodically to ensure that they are reasonable. HUD should retain the documentation justifying the calculation of the rates.

Develop, document, and implement written procedures to ensure that fees charged to the asset management projects and Capital Fund program and expenses from the central office cost center are used to support HUD’s mission.

Discontinue using its low-rent public housing fund as a general fund to pay costs associated with its business activities until it has established appropriate controls.

Require the Authority to support or repay its various program accounts $109,861 from nonfederal funds for unsupported payroll, other compensation, bonuses, travel, supplies, contractor payments and petty cash disbursements.

We recommend that the Director, Office of Multifamily Asset Management, require that each Hub or field office review its refinanced Section 202/223(f) projects for debt service savings amounts, utilizing data provided from this audit for possible additional debt service savings. Where legally possible each Hub or field office should identify, account for by project, and use these amounts for current and future opportunities benefiting tenants or to fund reductions in housing assistance payments.

Implement a cost-effective method for automating the cash management process to include an electronic interface of transactions to the standard general ledger.

We recommend that the Director of HUD’s Detroit Office of Multifamily Housing Programs require the Authority to ensure that $31,148,477 in residual receipts for the 15 projects as of May 31, 2013, is used to reduce or offset housing assistance payments in accordance with HUD’s requirements.

We recommend that the Director of HUD’s Detroit Office of Multifamily Housing Programs require the Authority to reimburse the U.S. Treasury $608,337 ($77,856 436,759 $93,722) for the three projects with terminated program contracts.

We recommend that the Director of HUD’s Detroit Office of Multifamily Housing Programs require the Authority to reimburse the U.S. Treasury $12,830 from non-Federal funds for the lost interest.

We recommend that the Director of HUD’s Detroit Office of Public Housing require the Commission to support or reimburse its program $425,193 ($19,924 $384,755 in housing assistance payments $46 in utility allowances $20,468 in associated administrative fees) from non-Federal funds for the unsupported overpayment of housing assistance and utility allowances due to unsupported calculations, missing eligibility documentations, and discrepancies in the housing assistance payments register.

We recommend that the Director of HUD’s Detroit Office of Public Housing require the Commission to reimburse its program $21,650 form non-Federal funds for the overpayment of escrow funds to the participants cited in this finding.

We recommend that the Director of HUD’s Detroit Office of Public Housing require the Commission to provide supporting documentation or reimburse its program $17,008 from non-Federal funds for the unsupported payments cited in this finding.

Establish and implement procedures to reassess the safe harbor percentage and rates periodically to ensure that they are reasonable. HUD should retain the documentation justifying the calculation of those percentages and rates. In addition, HUD should assess the feasibility of requiring the agencies to periodically justify and retain documentation showing the reasonableness of using the maximum rates, or lower them as appropriate.

We recommend that the Director of HUD’s Detroit Office of Public Housing require the Commission to reimburse its Capital Fund $1,539,629 from non-Federal funds for the ineligible payments cited in this finding.

We recommend that the Director of HUD’s Detroit Office of Public Housing require the Commission to return the $411,228 in excess capital fund draws cited in this finding.

We recommend that the Director of HUD’s Detroit Office of Public Housing require the Commission to provide supporting documentation or reimburse its Capital Fund $394,683 from non-Federal funds for the unsupported costs cited in this finding.