We recommend that the Southwest Region Director of Multifamily Housing require the Eastwood Terrace Apartments owner to support that the subsidies for 77 tenants and units with income discrepancies, missing EIV reports, missing income verifications, missing annual certifications and missing signatures are supported and accurate or repay HUD $1,865,344 for those subsidies. Repayment must be from non-project funds.

We recommend that the Southwest Region Director of Multifamily Housing require the Eastwood Terrace Apartments owner to ensure tenants are housed in the correct unit size.

We recommend that the Southwest Region Director of Multifamily Housing require the Eastwood Terrace Apartments owner to ensure annual inspections are performed in a timely manner and in accordance with HUD requirements.

We recommend that the Southwest Region Director of Multifamily Housing require the Eastwood Terrace Apartments owner to ensure that its new property management agent is providing oversight to its onsite staff and that its recently implemented quality control program is working as designed and in accordance with HUD requirements.

We recommend that the Southwest Region Director of Multifamily Housing require the Eastwood Terrace Apartments owner to maintain tenant files in a manner that ensures they contain the correct records and all required documentation.

Designate an unclaimed asset recovery official as required by the Treasury Financial Manual.

Work with Treasury to identify and obtain reimbursement for FHA’s and Ginnie Mae’s portion of the $1.9 million in HUD funds that Treasury collected.

Establish and implement policies and procedures to ensure that all of its unclaimed funds are claimed and the money is appropriately routed to put $2.2 million to better use. At a minimum, these policies and procedures should address what constitutes FHA and Ginnie Mae funds, ensure that these funds are returned to FHA or Ginnie Mae as appropriate, and include policies to claim co-owned funds with any appropriate thresholds or limitations.

Develop and implement controls and procedures to ensure that HUD’s underwriters properly evaluate the creditworthiness of management agents when underwriting future loans.

Obtain the required depository agreements for two5 grantees to ensure that they invest program funds in investment securities for use in carrying out affordable housing activities in accordance with PIH Notices 2014-21, section 4, and 2015-08, section 7.

Strengthen monitoring controls to ensure that current and future grantees maintain the required depository agreements before allowing them to invest program funds in investment securities for use toward affordable housing activities.

Update HUD’s Indian Housing Block Grant Recipient Self-Monitoring Guidebook to replace the expired requirement for investing program funds with PIH Notice 2015-08 and ensure that the Guidebook is updated with the latest requirements to ensure that grantees remain compliant with program requirements.

Direct PIH and OCIO to develop a comprehensive project plan, documenting the milestones and dates for addressing the gaps in ONAP-LOS capabilities (functionality and reports) and the 25 recommendations made during HUD OCIO's project health assessment

Direct all stakeholders to identify all viable options to securely resolve the ONAP-LOS access issues, so authorized Section 184 lenders can access the system. The best solution should not impose unacceptable risk to business processes or sensitive data. Current program offices involved are OCIO, PIH, and FHA, while others may also be identified

Direct PIH and OCIO to ensure that the Section 184 program transitions away from dependency on CHUMS.

Continue to develop required ONAP-LOS capabilities using cloud environments as appropriate

Coordinate and participate in resolving all open recommendations from evaluation report IT System Management and Oversight of the Section 184 Program (2018-OE-0004)

We recommend that HUD’s Office of General Counsel, Office of Program Enforcement, acknowledge that the $40,000 in the settlement agreement represents an amount due HUD.

Acknowledge the settlement amount of $149,500,000 and that $115,000,000 of the settlement represents restitution due HUD less DOJ’s civil debt collection fees.

Develop and implement internal policies and procedures to ensure that approved underwriters are accurately maintained and kept current in the origination systems for the Section 184 program.