Recommendations

Transparency to stakeholders is a key priority within HUD OIG. The Recommendation Dashboard provides stakeholders and the public with data on open and closed recommendations for HUD programs and funding recipients. Through the dashboard, users can identify the total number of open recommendations, review the costs associated with specific recommendations, and visualize key data elements through graphs and charts. For additional information visit recommendations FAQs.

Open Recommendations by Oversight Area

Housing Assistance

Community Development

Disaster Recovery

Financial Risk and Accountability

Technology and Cybersecurity

Health and Safety

HUD's Operations

Priority Recommendations
Open Recommendations

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Open Recommendations by Oversight Area
Oversight Area	Priority Recommendations	Open Recommendations
Housing Assistance	75	100
Community Development	3	75
Disaster Recovery	3	82
Financial Risk and Accountability	6	130
Technology and Cybersecurity	4	88
Health and Safety	1	53
HUD's Operations	4	100
Total	96	628

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We audited the U.S. Department of Housing and Urban Development’s (HUD) resident home-ownership program grant for Lakeview East Cooperative (project) based on the results of a risk assessment of multifamily housing programs in Region 5’s jurisdiction (States of Illinois, Indiana, Michigan,…

Audit #: 2017-CH-1006 Oversight Area: Housing Assistance Date Published: September 5, 2017

Implement adequate procedures and controls to ensure that memberships are sold at or below the fair market value and HUD’s secured interest in the memberships is appropriately valued.

Have a representative of HUD at the closing for membership sales to sign the HUD notes.

Develop and maintain a waiting list for rental units that meets the requirements of the resident home-ownership plan and considers the tenant profile.

Implement adequate procedures and controls to ensure that any rental units vacated by current households or units associated with memberships which were repurchased by the Cooperative and then remained vacant more than 6 months, are rented to very low-, low-, or moderate-income households selected from a waiting list for rental units that meets the requirements of the resident homeownership plan and considers the tenant profile.

For the two units for which the Cooperative acquired the memberships associated with the units from members and which had been vacant for more than 6 months, rent the units to households that meet the tenant income profile.

Provide sufficient documentation to support that HUD had received 50 percent of the proceeds from initial membership sales as of May 2017. If the Cooperative cannot do this, it should pay HUD half of the principal on the promissory notes payable to the Cooperative for all of the membership sales less the amount the Cooperative can support that it paid HUD for initial membership sales.

Implement adequate procedures and controls to ensure that HUD receives its full share of the proceeds from future initial membership sales.

Provide sufficient documentation to support that the Cooperative used its share of the proceeds from initial membership sales in accordance with the grant agreement. If the Cooperative cannot do this, it should transfer funds from its operating account, in an amount equal to half of the principal on the mortgages to the Cooperative for all membership sales less the amount the Cooperative can support that it used for eligible purposes, to a reserve account to be used in accordance with the grant agreement.

Implement adequate procedures and controls to ensure that its share of the proceeds from initial membership sales is used in accordance with the grant agreement.

Implement adequate procedures and controls to ensure that the Cooperative receives HUD approval before using the $148,872 in proceeds from initial membership sales offset by undisbursed funds which was in the Cooperative’s reserve for replacements account for the project.

Sign the amendment to the use agreement which would require the Cooperative to ensure that monthly housing expenses did not exceed 35 percent of the members’ monthly adjusted gross income only at the time of sale. If the Cooperative does not sign the amendment, it should verify the current household income for all members to determine whether the members are paying more than 35 percent of their households’ monthly adjusted gross income for monthly housing expenses. For any members that are paying more than 35 percent of their households’ monthly adjusted gross income for monthly housing expenses, it should determine the amount the household overpaid and reimburse the household that amount. It should also implement adequate procedures and controls to ensure that members do not pay more than 35 percent of their households’ monthly adjusted gross income for monthly housing expenses.

Implement adequate procedures and controls to ensure that it sells memberships to the same proportion of very low-, low-, and moderate-income households as stated in the resident income profile in paragraph 4.a. and required by paragraph 10.b. of the use agreement.

Require the member for whom it tried to transfer the membership associated with a unit in which the remaining member passed away, to move into the unit or continue to pursue the release of the member’s membership rights to the Cooperative.

Require the members who did not maintain their unit at the project as their principal residence to move into the unit or continue to pursue the sale of their membership in the Cooperative.

Provide sufficient documentation to support that the single occupant of a unit was a member of the Cooperative. If the Cooperative cannot do this, it should determine who has the right to membership associated with the unit, transfer the membership to that person if appropriate, and require him or her to move into or sell the unit.

Implement adequate procedures and controls to ensure that members maintain their units at the project as their principal residence or sell their memberships.

Rent the unit that was used to provide rent-free housing to former employees of the management agent to a very low-, low-, or moderate-income household selected from a waiting list for rental units that meets the requirements of the resident home-ownership plan and considers the tenant profile.

Implement adequate procedures and controls to ensure that the project’s units are used for rental or cooperative housing unless otherwise approved by HUD.

Implement adequate procedures and controls to ensure that it submits the required reports to HUD to show continued compliance with the program.

Ensure that the Cooperative’s board members and responsible staff of the Cooperative’s management agent are provided training on HUD’s requirements and the grant agreement.

Consider removing from the Cooperative’s board the member who did not maintain their unit as their principal residence.

Make a preliminary determination as to whether the Cooperative is in default of the grant agreement. If it is preliminarily determined that the Cooperative is in default, HUD should provide the Cooperative notice of the determination and propose corrective or remedial actions to address the default and prevent the Cooperative from repaying the remaining $18,149,023, which HUD disbursed for the project ($18,607,467 in funds disbursed for the project – $458,444 in proceeds from initial membership sales the Cooperative remitted to HUD).

The U.S. Department of Housing and Urban Development (HUD), Office of Inspector General audited public housing agency compliance with HUD’s flat rent requirements. We initiated this audit based on multiple external audits conducted by the HUD Office of Inspector General, which showed that housing…

Audit #: 2017-KC-0007 Date Published: September 12, 2017

Finalize and implement monitoring procedures to ensure that $6,324,625 in flat rents are appropriately charged to tenants over the next year.

Follow up with the housing authorities in our sample, identified as noncompliant with flat rent requirements, to ensure that their rents are properly adjusted.

Clarify guidance to better enhance housing authority understanding of the requirement, including explaining that housing authorities must code ceiling rent tenants as flat rents and explaining what housing authorities should do when maximum rents for low-income housing tax credit properties are lower than the minimum flat rent amounts required by HUD.

We audited the City of Las Vegas’, Homebuyer Assistance Program under the U.S. Department of Housing and Urban Development’s (HUD) Neighborhood Stabilization Program 3 (NSP3). We initiated this review because of a prior HUD Office of Inspector General audit of Evergreen Home Loans issued September…

Audit #: 2017-LA-1008 Date Published: September 13, 2017

Modify the recapture provisions of the 35 home-buyer assistance agreements totaling $488,519 to meet HUD recapture requirements relating to the sales price, closing costs, and net proceeds.

Update its procedures to ensure that any additional home-buyer assistance agreements contain recapture provisions that meet HUD recapture requirements relating to the sales price, closing costs, and net proceeds.

Train its staff to ensure that recapture amounts do not exceed net sales proceeds.

Revise and implement written policies and procedures for managing and accurately tracking all NSP3 activity to ensure that the $12,275 in identified closing cost refunds and any additional refunds identified in recommendation 2B are not overpaid by recipients.

Identify any additional closing cost refunds for NSP3 properties using the general ledger, DRGR supporting documentation, and the property file and either repay the recipients from non-Federal funds or update its tracking spreadsheet.

Repay $95 from non-Federal funds to the two recipients who paid more than the assistance provided (appendix E).

Repay the program $1,495 for closing cost expenses not incurred from non-Federal funds and remove the expenses from program records if the City incorrectly recorded the refunds as program income.

Reclassify home-buyer assistance expenses and refunds from the City’s NSP3 ARR program to its NSP3 Homebuyer Assistance Program in DRGR and the general ledger.

Consolidate and reconcile all NSP3 home-buyer assistance tracking spreadsheets and the general ledger with HUD’s DRGR to ensure that all information is accurate and up to date.

Develop and implement written policies and procedures to periodically reconcile all NSP3 tracking spreadsheets to ensure that data remain accurate and up to date.

Provide training to all employees responsible for NSP3 to ensure that the City adequately determines repayment amounts and tracks and records NSP3 activities.

Very low REAC scores are not prevalent across ORCF’s portfolio. The majority of RCFs that received a REAC score scored at least 80 on their last inspection, and more than three quarters scored at least 60. Despite the small percentage of RCFs that scored below 31, we noticed an overall decline in…

Audit #: 2017-OE-0011 Oversight Area: Healthcare Programs Date Published: September 14, 2017

Identify and implement a method to ensure that eligible RCFs receive database adjustments when appropriate under local code

Identify and implement a method to ensure that HUD does not instruct facilities to negate safety features

Identify and implement a method that ensures the expeditious followup inspection of RCFs

We audited the U.S. Department of Housing and Urban Development’s (HUD) oversight of servicers’ use of loss mitigation programs. The audit was initiated in response to an Office of Inspector General preaudit analysis of HUD data, which determined that servicers may not always evaluate borrowers…

Audit #: 2017-LA-0004 Oversight Area: Financial Risk and Accountability Date Published: September 14, 2017

Revise servicing review and monitoring policies and procedures to emphasize increased controls on reviewing claim loans showing that no loss mitigation evaluation occurred. Revising the policies and procedures would reduce the risk to HUD and result in a projected $120,902,564 in funds to be put to better use (appendix A).

Develop and implement policies and procedures to ensure that the Office of Single Family Asset Management and Office of Lender Activities and Program Compliance communicate the results of their servicing reviews to each other.

Update and revise policies and procedures, including reinforcement of guidance (for example, mortgagee letters, notifications to servicers, or training) to ensure that servicers accurately report the status of delinquent loans to HUD.

Require indemnification for the 26 loans that had significant servicing deficiencies. In these cases, the loss to HUD was $1,673,117 (appendixes A and D).

Reinforce existing guidance (such as mortgagee letters, notifications to servicers, and training) to servicers to ensure that they engage in required loss mitigation.

Require that the servicers with significant and other deficiencies revise and update their policies and procedures, as necessary, to ensure that they comply with HUD requirements and guidance on loss mitigation evaluation.

We audited the Fort Bend County Community Development Department based on our risk analysis and as part of our annual audit plan to review Office of Community Planning and Development (CPD) funds. The audit objective was to determine whether the Department (1) properly carried out its activities…

Audit #: 2017-FW-1013 Oversight Area: Community Improvement Date Published: September 14, 2017

We recommend that the Director of HUD’s Houston Office of Community Planning and Development require the Department to support the $240,010 in unsupported procurement payments or repay its CDBG program from non-Federal funds.

We recommend that the Director of HUD’s Houston Office of Community Planning and Development require the Department to report $22,872 in program income to HUD and properly use program income.

We recommend that the Director of HUD’s Houston Office of Community Planning and Development require the Department to correct its HOME matching liability report to include the recalculated amount for 2014 and pay the matching liability of $3,301.

We recommend that the Director of HUD’s Houston Office of Community Planning and Development require the Department to confirm that it has developed and implemented written procurement procedures to ensure that future contracts and subrecipient agreements address the procurement and required provision issues identified in the report.

We recommend that the Director of HUD’s Houston Office of Community Planning and Development require the Department to ensure that all program files include required documentation and support.

We recommend that the Director of HUD’s Houston Office of Community Planning and Development require the Department to monitor subrecipients annually as stated in its monitoring policy.

We recommend that the Director of HUD’s Houston Office of Community Planning and Development require the Department to train its staff regarding HUD requirements and regulations or seek technical assistance.

We audited the State of New York’s Community Development Block Grant Disaster Recovery-funded Non-Federal Share Match Program. We conducted this audit because the State had used approximately $223 million for the program as of December 2016 and a U.S. Department of Housing and Urban Development…

Audit #: 2017-NY-1010 Oversight Area: Disaster Relief Date Published: September 15, 2017

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs direct the State to provide documentation to show that the $18,782,054 used for four activities was for eligible and supported costs and did not duplicate other benefits or repay from non-Federal funds any amount that it cannot support.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs direct the State to Implement procedures to ensure that remaining program costs reimbursed with disaster recovery funds are adequately reviewed for eligibility and support, thereby putting up to $8,932,630 to better use.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs direct the State to provide training to its staff on applicable HUD and Federal requirements for eligibility, documentation of costs, and duplication of benefits reviews.

We audited the U.S. Department of Housing and Urban Development’s (HUD) process for forgiving debts and terminating debt collections based on an Office of Inspector General (OIG) preaudit analysis that noted potential violations of debt collection requirements related to disallowed costs in a prior…

Audit #: 2017-LA-0005 Oversight Area: HUD Business Functions Date Published: September 20, 2017

Take appropriate steps to establish eligibility for collection termination or compromise for 10 debts totaling $1,210,278,5 including three debts that were closed without required DOJ approval. For debts that have a remaining appropriate means of collection, such as demand letters, administrative offset, or referral to Treasury, HUD should reinstate the debt and resume collections.

Conduct a complete analysis of existing procedures to strengthen controls over debt collection, including HUD’s Treasury Reports of Receivables reporting, resulting in funds to be put to better use of $3,247,078. Controls should include additional procedures for ensuring that DOJ approval is obtained when required, that all appropriate means of collection have been pursued (including referral to Treasury when required), and that all closed debts are tracked and were properly authorized for collection termination or forgiveness. The analysis should also include a review of HUD’s Treasury Reports on Receivables, and any other available records to verify that all closed debts were properly approved for collection termination or forgiveness when required. For any identified debts that were not properly approved, the Departmental Claims Collection Officer should coordinate with applicable program offices to obtain appropriate documentation to approve collection termination or reinstate the debt and resume collections.

We audited the U.S. Department of Housing and Urban Development’s (HUD) Office of Community Planning and Development’s administration of Economic Development Initiative – Special Project and Neighborhood Initiative congressional grants. This review was prompted by our Financial Audit Division’s…

Audit #: 2017-LA-0006 Oversight Area: Community Improvement Date Published: September 21, 2017

Support the eligibility of more than $4,187,560 in unsupported costs or require the grantees to repay the U.S. Treasury from non-Federal funds.

Require one grantee to repay the U.S. Treasury $343,000 from non-Federal funds for ineligible program costs incurred for the project identified in this report.

We audited Baker Tower Apartments, LLC (corporation), located in Denver, CO, based on data showing that the corporation had taken more than $3.4 million in owner distributions since 2013 and scored poorly on its most current Real Estate Assessment Center physical property inspection. The objective…

Audit #: 2017-DE-1003 Oversight Area: Housing Assistance Date Published: September 21, 2017

Develop and implement controls over owner contributions and owner distributions to ensure compliance with its regulatory agreement and HUD regulations.

Complete HUD-approved training regarding owner contributions and distributions.

Repay its project’s operating account for the ineligible $15,000 disbursement from non-project funds.

Perform an analysis of all security deposits and ensure that the security deposit account is fully funded.

Implement controls to ensure existing procedures are followed to maintain the project’s security deposit funds separately from all other accounts by depositing and disbursing all security deposit funds directly into and from the security deposit account.

Open Recommendations by Oversight Area

Oversight Area

Program Office

Topic

Status

Reports with Priority

The Cooperative and Management Agent Lacked Adequate Controls Over the Operation of Lakeview East Cooperative, Chicago, IL

HUD Subsidized 10,119 Units for Tenants Who Were Undercharged Flat Rents

The City of Las Vegas, NV, Did Not Administer Its Neighborhood Stabilization Program 3 Homebuyer Assistance Program in Accordance with HUD Requirements

The Office of Residential Care Facilities’ Use of Real Estate Assessment Center Scores

HUD Did Not Have Adequate Controls To Ensure That Servicers Properly Engaged in Loss Mitigation

The Fort Bend County Community Development Department, Richmond, TX, Did Not Always Comply With Office of Community Planning and Development Program Requirements

The State of New York Did Not Show That Disaster Recovery Funds under Its Non-Federal Share Match Program Were Used for Eligible and Supported Costs

HUD Did Not Always Follow Applicable Requirements When Forgiving Debts and Terminating Debt Collections

HUD Did Not Administer Economic Development Initiative – Special Project and Neighborhood Initiative Congressional Grants in Accordance With Program Requirements

Baker Tower, Denver, CO, Incorrectly Disbursed Funds and Did Not Correctly Administer the Project’s Security Deposit Account

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