Require the Authority to determine whether the Authority improperly used Federal funds totaling $40,600 to make lease payments on the parking lot it already owned. If Federal funds were improperly used, the Authority should repay $40,600 from non-Federal funds to its Federal program accounts. If the Authority is unable to accurately determine the amount due to and due from each program or support that the funds charged to the Federal program were appropriate, the full $40,600 should be repaid to HUD.

Require the Authority to determine how much of the $243,442 in salaries for individuals assigned to work at multiple properties was improperly paid with Federal funds and repay the amounts to the appropriate programs from non-Federal funds. If the Authority is unable to accurately determine the amount due to and due from each program or support that the funds charged to the Federal programs were appropriate, the full $243,422 should be repaid to HUD.

Require the Authority to take action to reclaim its properties valued at $2,032,266 to improve its financial position, decrease its reliance on HUD program funding, and address its comingling issues.

Develop, document, and implement written procedures to ensure that fees charged to the asset management projects and Capital Fund program and expenses from the central office cost center are used to support HUD’s mission.

Establish and implement procedures to reassess the management and bookkeeping fees periodically to ensure that they are reasonable. HUD should retain the documentation justifying the calculation of the rates.

HUD should remove the provision that allows public housing authorities to charge asset management fees, which would ensure that at least $81.6 million in operating funds could be put to better use in meeting HUD program objectives.

Revise HUD’s asset management fee policy to refederalize the Operating Fund program’s management and bookkeeping fees and the Capital Fund program’s management fees.

Discontinue using its low-rent public housing fund as a general fund to pay costs associated with its business activities until it has established appropriate controls.

Require the Authority to support or repay its various program accounts $109,861 from nonfederal funds for unsupported payroll, other compensation, bonuses, travel, supplies, contractor payments and petty cash disbursements.

Implement a cost-effective method for automating the cash management process to include an electronic interface of transactions to the standard general ledger.