Open Recommendations

We recommend that the Director of HUD's Cleveland Office of Public Housing require the Agency to determine the appropriate administrative fees for the applicable households for which it is unable to provide supporting documentation cited in recommendation 2D and reimburse its program the applicable amount from nonfederal funds.

We recommend that the Director of HUD's Detroit Office of Public Housing require the Commission to provide supporting documentation or reimburse its Public Housing program $153,223 ($22,092 for household eligibility and $131,131 for continued occupancy) from nonfederal funds for the unsupported operating subsidies related to the 36 household files cited in this finding.

We recommend that the Director of HUD's Detroit Office of Public Housing require the Commission to reimburse its Public Housing program $28,663 ($16,262 plus $12,401) from nonfederal funds for the lost total household payments for 23 households cited in this finding.

We recommend that the Director of HUD's Detroit Office of Public Housing require the Commission to reimburse the appropriate households $13,070 for the underpayment of housing assistance and utility allowance payments cited in this finding.

We recommend that the Director of HUD's Detroit Office of Public Housing require the Commission to reimburse its Public Housing program $7,932 in operating subsidies from nonfederal funds for the two properties sold by the City.

We recommend that the Director of HUD's Detroit Office of Public Housing require the Commission to provide supporting documentation for the use of $61,202 for work performed under its Public Housing Capital Fund program or reimburse its program from nonfederal funds for the applicable amount.

We recommend that the Director of HUD's Detroit Office of Public Housing require the Commission to provide support that the use of $82,774 ($27,286 to three family members, $23,418 to two independent contractors, $22,150 to CLM Architects, and $9,920 to Harold Dunne, Attorney at Law) in Public Housing program funds for housing maintenance, cleaning, and professional services were reasonable or reimburse its program from nonfederal funds for the applicable amount.

The Bureau of Information Services should perform a physical inventory of information technology hardware and update the agency’s official fixed asset inventory system.

We recommend that the director of HUD's Office of Public Housing instruct the Authority to reimburse HUD for the excessive administrative fee charge of $692,990 in capital funds in accordance with the procedures described in 24 CFR 905.120.

We recommend that the director of HUD's Cleveland Office of Public Housing require the Authority to provide documentation to support that the $913,365 in refunding savings cited in this finding was used to provide affordable, decent, safe, and sanitary housing to very low-income households or reimburse from nonfederal funds its refunding savings account(s), as appropriate, to be able to trace its use of the savings.

We recommend that the director of HUD's Detroit Office of Public Housing require the Commission to Reimburse its program $535,903 from nonfederal funds ($507,860 for the property purchase plus $28,043 for legal costs) for the improper use of program funds to pay for the property's acquisition costs.

Require the Commonwealth to provide documentation to substantiate the eligibility of $150,000 provided to Southampton or repay the HOME program from nonfederal funds.

Obtain and review support (as identified in recommendation 1D) for $15.1 million in unsupported phase-down funding in fiscal years 2004 and 2005, determine the correct amount of phase-down funding, and require the public housing agencies to reimburse HUD for any ineligible funding received.

For the overpayments of phase-down funding identified in appendix C, recover $20.6 million in ineligible phase-down funding requests from the public housing agencies for fiscal years 2004 and 2005.

Continue its FBI Headquarters-managed asset validation review process and provide sufficient resources for the Analytical Unit to devote to these reviews.

Require that any analytical products relating to the asset, together with red flags, derogatory reporting, anomalies, and other counterintelligence concerns be documented in a subsection of the asset's file.

Require the field SSA, the ASAC, and the FBI Headquarters SSA responsible for each asset to signify that they have reviewed the entries in this subsection as part of the routine file review or of semi-annual or annual asset re-evaluations. If anomalies exist, the SSA should note what action has been taken with respect to them, or explain why no action is necessary, and the ASAC's agreement should be noted.

Require agents to record in the asset file any documents passed and all matters discussed with the asset, as well as each person who was present for the meeting.

Require alternate case agents to meet with the source on a regular basis, together with the case agent.

Limit the number of years any Special Agent can continue as an asset's handler. Exceptions should be allowed for good cause only.

We recommend that the director of HUD's Public Housing Hub, Cleveland Field Office, require the Authority to provide support or reimburse its Section 8 program $812,967 ($738,708 in housing assistance payments plus $74,259 in related administrative fees) from nonfederal funds for unsupported housing assistance payments and unearned administrative fees related to the 65 tenants cited in this finding.

Require the Municipality to obtain and submit all supporting documentation and HUD determine the eligibility and propriety of $1,011,801 in administrative costs the Corporation charged to the Block Grant revolving fund. Any amounts determined ineligible must be reimbursed to the Block Grant program from nonfederal funds.

Require the Municipality to obtain and submit all supporting documentation and HUD determine the eligibility and compliance with national objectives of the $631,195 the Corporation disbursed for the four loans. Any amounts determined ineligible must be reimbursed to the Block Grant program from nonfederal funds.

We recommend that HUD's Director of Public Housing Hub, Detroit Field Office, assure the Royal Oak Township Housing Commission: Reimburse its Public Housing Program $367,516 from non-Federal funds for the improper use of HUD operating subsidy funds cited in this finding.

We recommend that HUD's Director of Public Housing Hub, Detroit Field Office, assure the Royal Oak Township Housing Commission: Reimburse its Public Housing Program $45,220 from non-Federal funds for the operating subsidy that was not used in accordance with HUD's One Strike Policy.