The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

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.

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.

We recommend that the Director of HUD’s Newark Office of Public Housing to require the Authority to provide documentation to show that the $800,439 paid for supplies and services purchased under the intergovernmental agreement for capital improvement projects was reasonable or reimburse its Capital Fund from non-Federal funds for any amount that it cannot support or that is not considered reasonable.

We recommend that the Director of HUD’s Newark Office of Public Housing to require the Authority to provide documentation to show that the $217,403 paid for legal, fee accounting, management consulting, and auditing services was reasonable or reimburse its Capital Fund or Operating Fund from non-Federal funds for any amount that it cannot support or that is not considered reasonable.

We recommend that the Director of HUD’s Newark Office of Public Housing to require the Authority to provide training to its staff related to HUD and Federal procurement requirements, including the requirements for using intergovernmental agreements and preparing independent cost estimates and cost analyses.

We recommend that the Director of HUD’s Newark Office of Public Housing to require the Authority to provide documentation to show that $187,492 in 2013 and 2014 capital fund obligations or reimburse HUD from non-Federal funds for any amount that it cannot support.

We recommend that the Director of HUD’s Newark Office of Public Housing to require the Authority to reimburse HUD $139,423 in replacement housing factor funds not disbursed by the expenditure deadline from its replacement housing factor funds or reduce its future capital funds.

We recommend that the Director of HUD’s Newark Office of Public Housing to require the Authority to improve its policies and procedures to ensure that capital funds, including replacement housing factor funds, are obligated and spent for eligible activities in a timely manner.

We recommend that the Director of HUD’s Newark Office of Public Housing to require the Authority to reimburse its project from non-Federal funds for $87,116 in excessive management fees charged for units undergoing demolition.

We recommend that the Director of HUD’s Newark Office of Public Housing to require the Authority to submit a request to the HUD field office to revise its budget so that it reflects actual expenditures for 2014 capital funds.

We recommend that the Director of HUD’s Newark Office of Public Housing to require the Authority to improve its policies and procedures to ensure that its budget, financial reports, and accounting data are accurate and up to date.

We also recommend that the Director of HUD’s Newark Office of Public Housing consider reducing future capital funds as a penalty for the Authority’s obligating its 2009, 2010, and 2011 replacement housing factor funds after the deadline.

Certify, along with the owners of the 61 units cited in the finding, that the applicable housing quality standards violations have been corrected.

Reimburse its program $46,605 from non-Federal funds ($44,214 for housing assistance payments and $2,391 in associated administrative fees) for the 22 units that materially failed to meet HUD’s housing quality standards.

Develop and implement procedures and controls to monitor the inspection process to ensure that program units meet housing quality standards, thereby ensuring that an estimated $2,668,680 in program funds is spent for units that are decent, safe, and sanitary.