We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide documentation to justify $8,564 in excessive property management fees charged by the COCC or reimburse its Operating Fund from non-Federal funds for any amount it cannot support.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to reimburse its Operating Fund from non-Federal funds $82,907 for 16 document management services contract payments that should have been paid with COCC funds.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to strengthen its controls to ensure that operating funds are requested, received, and used in accordance with HUD, Federal, and Authority requirements.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide training to employees involved in the funding and expenditure processes to ensure compliance with HUD, Federal, and Authority requirements

Follow up on the 15 properties in our sample to ensure that the code enforcement violations have been corrected, that the necessary documentation has been gathered and retained in the code enforcement file for the property, and that the code enforcement process has been completed.

We recommend that the Southwest Region Director of Multifamily Housing require the Louis Manor Apartments’ owner to implement appropriate controls to ensure that it conducts annual recertifications for all tenants in a timely manner, as required.

We recommend that the Southwest Region Director of Multifamily Housing require the Louis Manor Apartments’ owner to properly house the five families discussed in the finding in the correct unit size when an appropriate sized unit is available and ensure that its other tenants are housed in the correct unit size.

We recommend that the Southwest Region Director of Multifamily Housing require the Louis Manor Apartments’ owner to perform inspections for the units that lacked inspection reports

We recommend that the Southwest Region Director of Multifamily Housing require the Louis Manor Apartments’ owner to implement appropriate controls to ensure that it performs annual inspections, as required.

We recommend that the Southwest Region Director of Multifamily Housing require the Louis Manor Apartments’ owner to implement appropriate controls to ensure that tenants are eligible, housing assistance subsidies are accurate, and tenant files contain all required documentation.

Put all project bank accounts in the name of the project.

Separate all owner bank accounts from the project’s bank accounts.

Develop and implement controls over the distinction between project funds and owner funds. These controls should include policies related to when the owner is allowed to take project funds owed to the owner.

Take HUD-approved training related to operating and maintaining a multifamily project.

Repay the project’s operating account from nonproject funds for the $142,805 spent on ineligible expenses.

Provide support for the $12,355 in project funds spent to pay individuals who were not on the payroll and for services provided for project operations. For any portion of this amount that is not supported, the owner should repay the project operating account using nonproject funds.

Obtain training on the eligible use of project funds.

Develop and implement detailed policies and procedures for procurement, travel, and the use of its credit cards. These controls should comply with HUD regulations regarding procurement and other disbursement documentation requirements.

Submit any outstanding audited financial statements.

Review the audited financial statements and determine the amount of outstanding mortgage payments due.