Issue clarifying guidance to all existing 39 MTW housing agencies advising that HUD intended to waive the third-party inspection requirements via attachment C to the standard agreement.

Revise the standard MTW agreement for all existing 39 MTW housing agencies to clearly and specifically support which provision(s) waive the third-party inspection requirements.

Ensure that $1,385,791 ($1,229,684 in housing assistance payments and $156,107 in associated administrative fees) used by the Lexington-Fayette Urban County Housing Authority is supported through a valid and retroactive exemption from HUD’s third-party requirements. If a retroactive exemption cannot be issued, HUD should follow recovery procedures prescribed in HUD Handbook 2000.06, REV-4.

Follow the terms of the agreement, HUD requirements, and its own policies and procedures to ensure that any intergovernmental agreements for goods and services are in compliance.

Provide documentation to show that $793,101 paid to the City for legal services was cost beneficial. Based on the documentation, it should reimburse its Housing Choice Voucher Program from non-Federal funds for any amount that exceeded the cost savings.

Monitor the Authority to ensure compliance with its new laundry machine revenue policies.

Require the Authority to determine how much laundry machine revenue was not deposited into its accounts and used for eligible purposes and reimburse its program from non-Federal funds.

Require the Authority to develop and implement detailed policies and procedures to address collections, tracking, and use of its laundry machine revenue.

Monitor the Authority to ensure that initial tenant certifications and annual recertifications with an actual or potential conflict of interest are appropriately handled.

Ensure that the Authority’s board of commissioners and staff receive HUD-approved training on conflicts of interest.