Reimburse the project from nonproject funds for the $542,443 in disbursements from the project’s general operating fund account that was not used for reasonable operating expenses or necessary repairs of the project.

Reimburse the State from nonproject funds for the additional $384,772 in Medicaid overpayments.

Support or reimburse the project from nonproject funds for the $189,524, as appropriate, in disbursements from the project’s general operating fund account without sufficient documentation showing that the disbursements were for reasonable operating expenses of the project.

Support or reimburse the project from nonproject funds for the $20,000 value of the project’s van, which was transferred without sufficient documentation showing that the transfer was for reasonable operating expenses.

Support or reimburse the project from nonproject funds for the $51,261, as appropriated, in credit card purchases without sufficient documentation showing that the purchases were for reasonable operating expenses or necessary repairs of the project.

Reimburse the project from nonproject funds for the $2,020 in credit card purchases that was not used for reasonable operating expenses of the project.

Reimburse the project from nonproject funds for the $5,302 in petty cash expenditures that was not used for reasonable operating expenses of the project.

Pay the project from nonproject funds for the $390,583 in uncollected rental revenue.

Determine the market value of the operating rights for the 10 licensed beds sold in April 2015. If the licensed beds were sold for less than market value, the owner should reimburse the project from nonproject funds for the difference between the market value and the $150,000 sales price of the operating rights for the 10 licensed beds.

Implement adequate procedures and controls to ensure that it (1) uses project funds for reasonable operating expenses or necessary repairs of the project, (2) obtains HUD approval before disposing of the project’s assets, (3) receives market value for the sale of licensed beds, (4) obtains HUD approval for the entities selected to manage the project before entering into management agent agreements with the entities, (5) properly completes…

Work with the project’s owner and Greystone for the owner to develop an action plan to bring the owner current on the project’s mortgage, reserve for replacements, and taxes and insurance to prevent a claim to HUD on the mortgage.

The County does not reimburse itself with program funds for the $452,444 in County bond proceeds originally budgeted for the Armstrong Park project and used to pay for flood protection improvements in the Graue Mill subdivision in Hinsdale.

The $7,677 ($460,121 - $452,444) in remaining County bond proceeds originally budgeted for the Armstrong Park project are used for eligible program activities.

Deobligate the $109,270 in program funds obligated for ineligible activities in its construction contracts for the West Branch DuPage River Flood Control and Springbrook Culvert projects.

Support or reimburse its program from non-Federal funds $98,507 for the program funds used for project management services without sufficient documentation to support that the use of the funds was reasonable.

Improve its procedures and controls to ensure that the County administers the program in accordance with Federal requirements.

Determine legal sufficiency and if legally sufficient, pursue civil and administrative remedies, civil money penalties, or both against Venta, 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 Deputy Assistant Secretary for Single Family Housing require MB Financial to indemnify HUD against potential losses of $178,811 for the four loans that did not comply with underwriting requirements (appendix C). HUD provided us copies of the four executed indemnification agreements in August and September 2017. Therefore, upon issuance of this report, we will enter a management decision into HUD’s Audit Resolution and…

We recommend that the Deputy Assistant Secretary for Single Family Housing require MB Financial to provide training to its underwriters on HUD’s underwriting requirements for approving and rejecting loans.

We recommend that the Deputy Assistant Secretary for Single Family Housing require MB Financial to update its policies and procedures to ensure that its staff understands underwriting requirements and the requirement that loans be manually underwritten when a refer decision is received from automated underwriting systems or when a loan is downgraded to a manual underwrite.