Strengthen controls to ensure that project advances are reimbursed only when the project is in a surplus-cash position.

Implement adequate controls to ensure the review of the management agent fee to ensure that it is properly calculated in accordance with the HUD management agent certification and approved prior to payment from project operating funds.

Implement adequate controls to ensure that project funds are used only for eligible and supported operating expenses.

Obtain a formal agreement and approval from HUD to specify who is authorized to use the project’s community and recreation rooms and what activities are authorized or prohibited. In addition, this agreement must ensure that sufficient legal and liability protections are in place, establish consequences for noncompliance, and determine who is to pay for the utilities and maintenance of the rooms.

Amend the management agent agreement compensation schedule to remove bookkeeping fees as a fee separate from the 8.9 percent management agent fee.

Reimburse its program from non-Federal funds for the $62,377 used to pay for the excess executive compensation.

Develop and implement written policies, procedures, and other financial controls to ensure that Sections 8 and 9 funds are not used to pay for compensation over the salary limit.

Reimburse the U.S. Treasury from non-Federal funds for the $5,000 in ineligible costs paid to its contractor.

Develop and implement written policies and procedures for the payment review process to comply with applicable regulations in 2 CFR Part 200.

Train its staff on its newly developed policies and procedures noted in recommendations 1B and 1D.

Acknowledge that the attached settlement agreement of $325,000 represents an amount due HUD from Pacific Horizon.

Acknowledge that the attached settlement agreement for $15,000 represents an amount due HUD from the two loan officers.

Acknowledge that $3,375,163 in the attached settlement agreement represents an amount due HUD, less DOJ’s civil debt collection fees

Acknowledge that the $6,749,673 in the attached indemnification agreement represents an amount due HUD.

Acknowledge that $32,500,000 in the attached settlement agreement represents an amount due HUD, less DOJ’s civil debt collection fees.

Reimburse its program $32,687 from non-Federal funds ($17,045 in overpayments of housing assistance and utility allowances4 $15,642 in administrative fees) due to inappropriate calculations.

Reimburse the appropriate households $1,276 ($1,211 in housing assistance underpayments $65 in utility allowances) from program funds for the underpayment of housing assistance due to calculation errors and discrepancies in the housing assistance payments register.

Support or reimburse the appropriate households $7,869 from non-Federal funds for the unsupported underpayment of housing assistance due to missing documentation for housing assistance payment calculations.

Support or reimburse its program $12,893 from non-Federal funds for the unsupported overpayment of housing assistance due to missing documentation for housing assistance payment calculations.

Pursue collection from the applicable landlords or reimburse its program $4,460 from non-Federal funds for the overpayment of housing assistance due to discrepancies in the housing assistance payments register.