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Facts: An owner’s site has had a history of “unsatisfactory” HUD audit reviews since 2005, and in 2009 and 2010 HUD refused to pay more than $700,000 in subsidies due to the site’s violations of HUD regulations. To satisfy HUD, the owner hired a HUD-approved managing agent in 2010, and subsidy payments to the owner resumed. According to HUD, during the approved management company’s tenure managing the site, the owner’s submissions fully complied with HUD requirements.