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Policy and Procedure Recommendations (PPR) Portal

The New York City Department of Investigation’s Policy and Procedure Recommendations (PPR) Portal provides the public with a greater understanding of the recommendations DOI issues to City agencies and entities. PPRs are formal written recommendations to City agencies that correct policy, procedural and operational vulnerabilities identified through DOI investigations. These PPRs are part of DOI’s distinct approach to attacking corruption: through prevention, education, arrests, public reports, and reforms that tighten internal controls and prevent fraud and corruption from re-occurring. PPRs help improve the efficiency and effectiveness of City government, defend the City from fraudulent activity, and protect City workers and the public from conditions that could affect health and safety. This dataset pulls the most recent information from DOIs PPR portal, available on their website.

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DYCD
Agency: DYCD • Date Issued: 2017-08-28T00:00:00.000 • Acceptance Status: Accepted
Agency
DYCD
Date Issued
2017-08-28T00:00:00.000
Recommendation
DYCD should clarify Section Nine of its Fiscal Manual to state explicitly that DYCD funds intended for a current contract period cannot be used to pay expenses incurred prior to the contract period (e.g., back tax debts).
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-10-19T00:00:00.000
DYCD
Agency: DYCD • Date Issued: 2017-08-28T00:00:00.000 • Acceptance Status: Accepted
Agency
DYCD
Date Issued
2017-08-28T00:00:00.000
Recommendation
DYCD should require that the target nonprofit's current board members, newly-appointed board members, and key employees complete the MOCS Capacity Building and Oversight Review training.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-10-24T00:00:00.000
DYCD
Agency: DYCD • Date Issued: 2017-08-28T00:00:00.000 • Acceptance Status: Rejected
Agency
DYCD
Date Issued
2017-08-28T00:00:00.000
Recommendation
DYCD should review its system of breaking PERS down by contract and consider consolidating monthly PERS into a single document, even when the organization holds multiple contracts. This would likely assist DYCD personnel in determining the full amount that an expenditure is actually billed to DYCD and would also facilitate subsequent audits, anti-fraud review, or investigations.
Acceptance Status
Rejected
Implementation Status
No
DYCD
Agency: DYCD • Date Issued: 2017-08-28T00:00:00.000 • Acceptance Status: Accepted
Agency
DYCD
Date Issued
2017-08-28T00:00:00.000
Recommendation
DYCD should provide payments personnel – who review and approve PERS – clear written guidance concerning the types of expenditures that should trigger further review or scrutiny.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-10-19T00:00:00.000
DYCD
Agency: DYCD • Date Issued: 2017-08-28T00:00:00.000 • Acceptance Status: Accepted
Agency
DYCD
Date Issued
2017-08-28T00:00:00.000
Recommendation
Payments personnel should receive training on these standards to ensure that they are familiar with “red flags” indicating an inappropriate expenditure.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-10-27T00:00:00.000
DYCD
Agency: DYCD • Date Issued: 2017-08-28T00:00:00.000 • Acceptance Status: Accepted
Agency
DYCD
Date Issued
2017-08-28T00:00:00.000
Recommendation
DYCD should establish protocols to increase coordination and communication between personnel who approve PERS and DYCD program staff, so that DYCD program staff are consulted when expenses billed on the PERS may be questionable or fall outside the scope of the contract
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-10-19T00:00:00.000
DYCD
Agency: DYCD • Date Issued: 2017-08-28T00:00:00.000 • Acceptance Status: Accepted
Agency
DYCD
Date Issued
2017-08-28T00:00:00.000
Recommendation
When DYCD staff, such as contract specialists or program officers, learn information that may reflect adversely on a not-for-profit contractor’s capacity to properly administer City funds (e.g., tax liens), that information should be reported to the team or department referenced in Recommendation 3 and handled appropriately.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-10-19T00:00:00.000
DYCD
Agency: DYCD • Date Issued: 2017-08-28T00:00:00.000 • Acceptance Status: Accepted
Agency
DYCD
Date Issued
2017-08-28T00:00:00.000
Recommendation
Indicators of poor financial health, such as a significant operating deficit, should be reported to the same team or department referenced in Recommendation 3 and handled appropriately.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-10-19T00:00:00.000
DYCD
Agency: DYCD • Date Issued: 2017-08-28T00:00:00.000 • Acceptance Status: Accepted
Agency
DYCD
Date Issued
2017-08-28T00:00:00.000
Recommendation
In the event that DYCD learns of any information that would reflect adversely on a contractor’s ability to properly administer City funds or that indicate poor financial health, the ACCO’s office and finance department should meet with the contractor’s Executive Director and Board Members to gain a better understanding of the organization’s overall financial picture and make appropriate decisions based on those understandings.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-09-27T00:00:00.000
DYCD
Agency: DYCD • Date Issued: 2017-08-28T00:00:00.000 • Acceptance Status: Accepted
Agency
DYCD
Date Issued
2017-08-28T00:00:00.000
Recommendation
In all cases, DYCD should closely review whether it is appropriate to require a contractor who accrues significant debts to federal, state, or local tax authorities to work with an outside fiscal agent.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-09-27T00:00:00.000
DYCD
Agency: DYCD • Date Issued: 2017-08-28T00:00:00.000 • Acceptance Status: Accepted
Agency
DYCD
Date Issued
2017-08-28T00:00:00.000
Recommendation
DYCD should clarify Section Eight of its Fiscal Manual to state explicitly that DYCD funds cannot be used for litigation expenses, costs of paying legal settlements, or costs of paying legal judgments.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-10-19T00:00:00.000
DYCD
Agency: DYCD • Date Issued: 2017-08-28T00:00:00.000 • Acceptance Status: Accepted
Agency
DYCD
Date Issued
2017-08-28T00:00:00.000
Recommendation
Payments personnel should be instructed to familiarize themselves with the type of services provided under the contract at issue.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-10-19T00:00:00.000
DYCD
Agency: DYCD • Date Issued: 2017-08-28T00:00:00.000 • Acceptance Status: Accepted
Agency
DYCD
Date Issued
2017-08-28T00:00:00.000
Recommendation
DYCD should establish a system requiring payments personnel to escalate PERS that contain such “red flags” to a supervisor for further review.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-10-19T00:00:00.000
DYCD
Agency: DYCD • Date Issued: 2017-08-28T00:00:00.000 • Acceptance Status: Accepted
Agency
DYCD
Date Issued
2017-08-28T00:00:00.000
Recommendation
DYCD should designate a single team or department, such as the Agency Chief Contracting Officer’s (“ACCO”) office, that is responsible for collecting and reviewing information that may reflect adversely on a not-for-profit contractor’s capacity to properly administer City funds (e.g., tax liens, audits by outside CPA firms).
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-09-27T00:00:00.000
DYCD
Agency: DYCD • Date Issued: 2017-08-28T00:00:00.000 • Acceptance Status: Accepted
Agency
DYCD
Date Issued
2017-08-28T00:00:00.000
Recommendation
One team or department at DYCD, such as the ACCO’s office, should be responsible for collecting and reviewing important publicly-filed documents, such as the IRS Form 990 and the audited financial statements posted on the website of the New York State Attorney General’s Office, as well as VENDEX filings.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-09-27T00:00:00.000
DYCD
Agency: DYCD • Date Issued: 2017-08-28T00:00:00.000 • Acceptance Status: Accepted
Agency
DYCD
Date Issued
2017-08-28T00:00:00.000
Recommendation
DYCD and MOCS should enter into a Corrective Action Plan with the target nonprofit to address the above findings.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-10-24T00:00:00.000
H+H
Agency: H+H • Date Issued: 2017-08-30T00:00:00.000 • Acceptance Status: Accepted
Agency
H+H
Date Issued
2017-08-30T00:00:00.000
Recommendation
Walkthroughs for the purpose of estimating the scope of work should, whenever possible, be scheduled for dates and times when areas to be altered are closed or in limited use.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2018-04-05T00:00:00.000
H+H
Agency: H+H • Date Issued: 2017-08-30T00:00:00.000 • Acceptance Status: Accepted
Agency
H+H
Date Issued
2017-08-30T00:00:00.000
Recommendation
As part of the RFP process, Health + Hospitals should interview several of the lowest bidders about the basis for their bids to determine why they may have listed work differently, in case each saw something different or had different ideas. These interviews may reduce change orders should Health + Hospitals still elect to go with the lowest bidder, who may not have identified everything needed to complete the project, or who may no longer be the lowest bidder should the missed items be added to the project.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2018-04-05T00:00:00.000
H+H
Agency: H+H • Date Issued: 2017-08-30T00:00:00.000 • Acceptance Status: Accepted
Agency
H+H
Date Issued
2017-08-30T00:00:00.000
Recommendation
All due consideration to cost should be given by facilities staff and administrators when planning upgrades or changes at their facilities. Project managers should be alert to the added cost of design alterations requested by administrators once the project has commenced; those requests should be scrutinized and rejected if unreasonable or unnecessary.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2018-04-05T00:00:00.000
H+H
Agency: H+H • Date Issued: 2017-08-30T00:00:00.000 • Acceptance Status: Accepted
Agency
H+H
Date Issued
2017-08-30T00:00:00.000
Recommendation
Vendors should be held responsible for additional project costs resulting from their own errors or omissions.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2018-04-05T00:00:00.000
H+H
Agency: H+H • Date Issued: 2017-08-31T00:00:00.000 • Acceptance Status: Accepted
Agency
H+H
Date Issued
2017-08-31T00:00:00.000
Recommendation
Health + Hospitals should return to a centralized security system, with all operations directed by the Office of Corporate Security, as mandated by Health + Hospitals OP 220-1.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2018-06-21T00:00:00.000
H+H
Agency: H+H • Date Issued: 2017-08-31T00:00:00.000 • Recommendation: Appoint an experienced and proactive Director for the OCS.
Agency
H+H
Date Issued
2017-08-31T00:00:00.000
Recommendation
Appoint an experienced and proactive Director for the OCS.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2018-06-21T00:00:00.000
H+H
Agency: H+H • Date Issued: 2017-08-31T00:00:00.000 • Recommendation: All facility security directors must report to the Director of OCS.
Agency
H+H
Date Issued
2017-08-31T00:00:00.000
Recommendation
All facility security directors must report to the Director of OCS.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2018-06-21T00:00:00.000
H+H
Agency: H+H • Date Issued: 2017-08-31T00:00:00.000 • Acceptance Status: Accepted
Agency
H+H
Date Issued
2017-08-31T00:00:00.000
Recommendation
Create a uniform operations manual to be used by all facilities, unless there is an articulable and documented reason for deviation.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2018-06-21T00:00:00.000
H+H
Agency: H+H • Date Issued: 2017-08-31T00:00:00.000 • Acceptance Status: Accepted
Agency
H+H
Date Issued
2017-08-31T00:00:00.000
Recommendation
Mandatory usage of the electronic Incident Reporting System by hospital security officers for all incidents in all facilities.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2018-06-21T00:00:00.000
H+H
Agency: H+H • Date Issued: 2017-08-31T00:00:00.000 • Recommendation: Create an Internal Affairs Bureau within OCS, with required reporting to DOI.
Agency
H+H
Date Issued
2017-08-31T00:00:00.000
Recommendation
Create an Internal Affairs Bureau within OCS, with required reporting to DOI.
Acceptance Status
Rejected
Implementation Status
No
H+H
Agency: H+H • Date Issued: 2017-08-31T00:00:00.000 • Recommendation: Properly identify personnel as security officers instead of hospital police.
Agency
H+H
Date Issued
2017-08-31T00:00:00.000
Recommendation
Properly identify personnel as security officers instead of hospital police.
Acceptance Status
Rejected
Implementation Status
No
NYCHA
Agency: NYCHA • Date Issued: 2017-09-01T00:00:00.000 • Acceptance Status: Accepted
Agency
NYCHA
Date Issued
2017-09-01T00:00:00.000
Recommendation
Conduct a review of HUD EIV income discrepancy reports, using threshold limits, for Section 8 tenants, or conduct an audit of already completed annual reviews, to identify circumstances where discrepancies between HUD EIV data and calculated household income have not yet been detected.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2020-02-11T00:00:00.000
NYCHA
Agency: NYCHA • Date Issued: 2017-09-01T00:00:00.000 • Acceptance Status: Accepted
Agency
NYCHA
Date Issued
2017-09-01T00:00:00.000
Recommendation
Implementation of a new policy, improvement of existing policy, or issuance of reminder to staff regarding any existing policies or any new or improved policies that may be adopted in response to these recommendations, that staff must conduct proper third-party income verification, namely regarding the proper use of HUD EIV as a mandatory and highest level verification method, and how staff must properly review and utilize such records, in order for an annual review to be processed. Supervisory audits of staff compliance with these policies should also be considered.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2020-02-11T00:00:00.000
NYCHA
Agency: NYCHA • Date Issued: 2017-09-01T00:00:00.000 • Acceptance Status: Accepted
Agency
NYCHA
Date Issued
2017-09-01T00:00:00.000
Recommendation
Consider the implementation of a policy or improvement of existing policy requiring that staff confirm HUD EIV results have been reviewed according to policy during the processing of an annual review. This could be done through enhancement to the existing annual recertification “Smartflow” in the Siebel system. When a substantial income difference exists between the reported and detected income, it is recommended that a note be required in Siebel which explains the action taken regarding the discrepancy.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2020-02-11T00:00:00.000
NYCHA
Agency: NYCHA • Date Issued: 2017-09-01T00:00:00.000 • Acceptance Status: Accepted
Agency
NYCHA
Date Issued
2017-09-01T00:00:00.000
Recommendation
In order to detect future instances of undetected income discrepancies from occurring for extended periods of time, the OIG recommends that the Leased Housing Department consider expanding their existing internal quality control process by increasing the number of audits/reviews of staff workflow or through more frequent review of the HUD EIV discrepancy reports.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2020-02-11T00:00:00.000
NYCHA
Agency: NYCHA • Date Issued: 2017-09-01T00:00:00.000 • Acceptance Status: Accepted
Agency
NYCHA
Date Issued
2017-09-01T00:00:00.000
Recommendation
The consideration of implementation of a policy or improvement/revision of existing policies and/or standard practice, that would require front-level staff (Housing Assistants and other similar employees) to engage with the TOR when a first occurrence income discrepancy is initially discovered during the annual review process in order to request additional proof of income from the TOR, prior to escalating the issue to LHD FAU, in order to more quickly detect and prevent the fraud from occurring.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2020-02-11T00:00:00.000
HRO
Agency: HRO • Date Issued: 2017-09-05T00:00:00.000 • Acceptance Status: Accepted
Agency
HRO
Date Issued
2017-09-05T00:00:00.000
Recommendation
Modify the format of the Hill daily inspection report to require inspectors’ feedback on quality of work and site safety.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-12-04T00:00:00.000
HRO
Agency: HRO • Date Issued: 2017-09-05T00:00:00.000 • Acceptance Status: Accepted
Agency
HRO
Date Issued
2017-09-05T00:00:00.000
Recommendation
For APP-006868, based on the video evidence of severe water leakage through the underside of the existing floor joists, DOI recommends that HRO perform an additional inspection of the floor joists to examine potential exposure to water damage.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-12-04T00:00:00.000
HRO
Agency: HRO • Date Issued: 2017-09-05T00:00:00.000 • Acceptance Status: Accepted
Agency
HRO
Date Issued
2017-09-05T00:00:00.000
Recommendation
If no work is underway at a home, require Hill inspectors to report on status of site security.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-12-04T00:00:00.000
DOT
Agency: DOT • Date Issued: 2017-09-18T00:00:00.000 • Acceptance Status: Accepted
Agency
DOT
Date Issued
2017-09-18T00:00:00.000
Recommendation
The DOT Staten Island Ferry ALT unit currently uses paper forms for equipment issuance and loss reports which are held in binder books that are too easily lost or discarded. The DOT ALT unit should utilize a more reliable computer inventory based program in which all DOT SIF issued clothing can be stored and maintained for future review.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-12-13T00:00:00.000
DOT
Agency: DOT • Date Issued: 2017-09-18T00:00:00.000 • Acceptance Status: Accepted
Agency
DOT
Date Issued
2017-09-18T00:00:00.000
Recommendation
When a DOT SIF Mate or Deckhand leaves City service it should be mandatory that all items of DOT SIF clothing issued to them should be returned to the DOT ALT unit.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-12-13T00:00:00.000
DOT
Agency: DOT • Date Issued: 2017-09-18T00:00:00.000 • Acceptance Status: Rejected
Agency
DOT
Date Issued
2017-09-18T00:00:00.000
Recommendation
Whenever a DOT SIF Mate or Deckhand losses an item of DOT SIF issued clothing it should be mandatory that a DOT Security Incident report be filled out by the DOT employee and kept on file at the DOT Security Office.
Acceptance Status
Rejected
Implementation Status
No
DOT
Agency: DOT • Date Issued: 2017-09-18T00:00:00.000 • Acceptance Status: Rejected
Agency
DOT
Date Issued
2017-09-18T00:00:00.000
Recommendation
For all future DOT SIF flotation jacket orders from the Stearns Jacket Company DOT SIF ALT should request that an individual serial number be included inside the jacket. These serial numbers can be recorded on an equipment issuance form which can be used to trace the jacket back to the assigned DOT employee. Jeff Gayer, the Government Sales Manager for the Coleman Company (that owns the Stearns Jacket Company, manufacturer of the flotation jacket), can install any type of individual serial number into the flotation jackets manufactured for DOT SIF.
Acceptance Status
Rejected
Implementation Status
No
SCA
Agency: SCA • Date Issued: 2017-09-19T00:00:00.000 • Acceptance Status: Accepted
Agency
SCA
Date Issued
2017-09-19T00:00:00.000
Recommendation
Although the allegation was not substantiated, the OIG recommended a new Policy, procedure and guildeline for how selection committees are formed, who serves on the selection committee and rules governing the selection committee process, including training for those serving on selection committee.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2018-02-07T00:00:00.000
HRO
Agency: HRO • Date Issued: 2017-09-19T00:00:00.000 • Acceptance Status: Accepted
Agency
HRO
Date Issued
2017-09-19T00:00:00.000
Recommendation
Beginning May 2017, HRO strengthened the Zipcar reservation requirements by mandating that the description clearly defines the business use; estimated mileage; estimated length of time the vehicle will be used; and the estimated time of pick up and drop off. DOI recommends that the program also require employees to complete a vehicle use log (to record dates and times of actual use, the actual purpose of trip, actual starting location and destination, and actual start and end odometer readings) when they use a Zipcar. These records (estimated and actual) should be maintained and compared during the routine audits.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-10-24T00:00:00.000
HRO
Agency: HRO • Date Issued: 2017-09-19T00:00:00.000 • Acceptance Status: Accepted
Agency
HRO
Date Issued
2017-09-19T00:00:00.000
Recommendation
Revoke employees’ memberships immediately upon determining misuse of Zipcar vehicles, as per NYC’s Zipcar User Agreement & Policy, to prevent waste and abuse.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-10-24T00:00:00.000
HRO
Agency: HRO • Date Issued: 2017-09-19T00:00:00.000 • Acceptance Status: Accepted
Agency
HRO
Date Issued
2017-09-19T00:00:00.000
Recommendation
Direct employees to complete a memorandum for all trip reservations exceeding 100 miles.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-10-24T00:00:00.000
LAW
Agency: LAW • Date Issued: 2017-09-22T00:00:00.000 • Acceptance Status: Rejected
Agency
LAW
Date Issued
2017-09-22T00:00:00.000
Recommendation
Law Department adopt the draft of the outside counsel policy that includes the DOI proposed clause stating that the Law Department shall not provide representation or pay for counsel for City employees in connection with a DOI investigation.
Acceptance Status
Rejected
Implementation Status
No
DEP
Agency: DEP • Date Issued: 2017-09-28T00:00:00.000 • Acceptance Status: Accepted
Agency
DEP
Date Issued
2017-09-28T00:00:00.000
Recommendation
Include the Outside Employment Notification Form in the hiring package and require employees sign the form even if they indicate no outside employment.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-12-28T00:00:00.000
DEP
Agency: DEP • Date Issued: 2017-09-28T00:00:00.000 • Recommendation: Remind employees annually to update their Outside Employment Notification Form.
Agency
DEP
Date Issued
2017-09-28T00:00:00.000
Recommendation
Remind employees annually to update their Outside Employment Notification Form.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-12-28T00:00:00.000
DCP
Agency: DCP • Date Issued: 2017-10-10T00:00:00.000 • Recommendation: Remind it’s employees to document properly DCP vehicle mileage sheets
Agency
DCP
Date Issued
2017-10-10T00:00:00.000
Recommendation
Remind it’s employees to document properly DCP vehicle mileage sheets
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-10-10T00:00:00.000
DCP
Agency: DCP • Date Issued: 2017-10-10T00:00:00.000 • Acceptance Status: Accepted
Agency
DCP
Date Issued
2017-10-10T00:00:00.000
Recommendation
Require the disclosure and its approval for its employees to be engaged in outside employment
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-10-10T00:00:00.000
HPD
Agency: HPD • Date Issued: 2017-10-12T00:00:00.000 • Acceptance Status: Accepted
Agency
HPD
Date Issued
2017-10-12T00:00:00.000
Recommendation
It should be a requirement for the building to report all checkbooks. For example, any additional checkbooks that are requested in addition to the initial checkbook should be reported to HPD
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-10-12T00:00:00.000
HPD
Agency: HPD • Date Issued: 2017-10-12T00:00:00.000 • Acceptance Status: Accepted
Agency
HPD
Date Issued
2017-10-12T00:00:00.000
Recommendation
Implement procedures as to actions to be taken when a checkbook is taken away form a Tenant Association.
Acceptance Status
Accepted
Implementation Status
Yes
Date Implemented
2017-10-12T00:00:00.000
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