Determine legal sufficiency and if legally sufficient, pursue civil and administrative remedies, civil money penalties, or both against RMS, its principals, or both for incorrectly certifying to the eligibility for FHA mortgage insurance or that due diligence was exercised during the origination of FHA loans.

Work with HUD to nullify the restrictions on conveyance that violate HUD policy or indemnify HUD. This action will protect HUD against future losses of $2,434,204 for the 49 loans.

Repay HUD $26,242 for partial claims paid on two FHA loans that contained prohibited restrictive covenants.

Develop and implement policies and procedures to identify prohibited restrictions on conveyance to ensure that it does not originate FHA loans with prohibited restrictive covenants.

Provide training to its employees regarding HUD’s requirements related to prohibited restrictions on conveyance.

Support or reimburse its ESG program participants $705 from non-Federal funds for the inadequately supported pay request.

Support or reimburse HUD $13,058 from non-Federal funds for the drawdowns after program grant expiration.

Implement adequate policies and procedures to ensure that payments to subrecipients are issued in accordance with HUD’s requirements.

Provide adequate training to staff associated with the administration of the ESG program to ensure compliance with HUD’s requirements, including timely drawdowns.

Implement adequate policies and procedures for conducting complete and consistent monitoring of subrecipients’ matching requirements, including confirming eligibility and existence of matching funds to ensure compliance with HUD’s requirements.

Support that it met its $526,170 matching contribution requirement associated with the more than $2.1 million in program funds it drew down for supportive services and administrative expenses. If Travelers Aid cannot provide sufficient support, it should reimburse HUD $1,776,381 from non-Federal funds.

Support or reimburse HUD from non-Federal funds for the $305,936 in program administrative funds for which it did not provide sufficient documentation to support that the funds were used for eligible administrative expenses associated with the project for which the funds were drawn.

Support or reimburse HUD from non-Federal funds for the $170,995 in program income for which it did not provide sufficient documentation to support that the funds were used for the project that generated the income ($147,534) and for eligible activities ($23,461).

Support or reimburse HUD from non-Federal funds for the $54,770 in program funds for which it did not provide sufficient documentation to support that the funds were used for eligible project expenses for supportive services ($26,036) and leasing ($28,734).

Reimburse HUD from non-Federal funds for the $1,165 in program funds used for improper supportive service expenses.

Implement adequate procedures and controls to ensure that it maintains sufficient documentation to support that matching contributions, program funds, and program income are accounted for and used in accordance with Federal regulations and it uses program funds for the projects in accordance with Federal regulations.

Provide technical assistance to Travelers Aid to ensure that its staff is adequately trained on how to account for and use matching contributions, program funds, and program income in accordance with Federal regulations.

Reimburse its program $373,860 ($302,638 in ineligible housing assistance payments $63,643 in associated administrative fees $7,579 in program funds paid to the contractor) from non-Federal funds for the inappropriate payments cited in this finding.

Seek retroactive approval or reimburse its program $358,237 ($339,908 in housing assistance payments $18,329 in program funds paid to the contractor) for the housing quality standards inspections of units owned by entities substantially controlled by the Authority, completed by contractors that were not approved by HUD.

Implement adequate procedures and controls to ensure that the Authority complies with HUD’s requirements for program conflicts of interest, including but not limited to ensuring that (1) its staff does not complete inspections for units owned by entities substantially controlled by the Authority, (2) its staff is appropriately trained and familiar with HUD’s requirements for units owned by entities it substantially controls, and (3) future contracts to perform housing quality standards inspections for program units owned by entities substantially controlled by the Authority are with a HUD-approved independent third party.