Implement a plan to annually survey all HUD program offices to identify nondisclosure policies, forms, and agreements issued and to determine whether they include the anti-gag provision as required by WPEA and, as necessary, to take corrective action to ensure that they include the anti-gag provision.

Communicate across HUD that (a) HUD employees are required to include the anti-gag provision in nondisclosure policies, forms, and agreements applicable to HUD employees and (b) program offices should consider requiring their employees to request OGC assistance when implementing and enforcing nondisclosure policies, forms, and agreements applicable to HUD employees.

The CDO should coordinate with HUD’s Records Office, Privacy Office, and program offices to develop data policies and procedures for data inventory, categorization, and labeling in support of zero trust architecture.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

We recommend that the General Deputy Assistant Secretary, Office of Policy Development and Research, and the Deputy Chief Information Officer, Office of the Chief Information Officer develop the project management documents, as required by HUD’s Project Planning and Management Life Cycle V2.0 policy, including obtaining required approvals and ensuring that an adequate project risk management process is established for identifying, analyzing, and responding to project risks.

We recommend that the General Deputy Assistant Secretary, Office of Policy Development and Research; the Deputy Chief Information Officer; and the Director, Office of Disaster Recovery, identify and incorporate at least one additional data source into the Disaster Recovery Data Portal to further assist grantees with duplication of benefits assessments.

Ensure there are resources available for further development of geocoding services that fulfill HUD’s responsibilities stated in 43 U.S.C. § 2808(a)(5) and 43 U.S.C. § 2808(a)(12) through the reactivation of the lapsed Geocode Service Center contract.

Take appropriate actions to prioritize the need for resources necessary to ensure that HUD fully implements the remaining four responsibilities as required by sections 759(a)(1), 759(a)(2), 759(a)(4), and 759(a)(5) of the Geospatial Data Act of 2018.

Take appropriate administrative action, up to and including debarment, against the owner for the violations cited in this report including, amongst others, failure to perform the required inspections to ensure that the units the owner were billing for assistance were decent, safe, and sanitary.

Take appropriate enforcement actions against the responsible parties and pursue civil action against the owner for improperly certifying to the eligibility of the project residents.

Pursue administrative actions, as appropriate, against the responsible parties for the improper certification included in form HUD-50059 and the Section 8 project-based voucher housing assistance payments contract.

Acknowledge that the attached settlement agreement of $325,000 represents an amount due HUD from Pacific Horizon.

Acknowledge that the attached settlement agreement for $15,000 represents an amount due HUD from the two loan officers.

Acknowledge that $3,375,163 in the attached settlement agreement represents an amount due HUD, less DOJ’s civil debt collection fees

Acknowledge that the $6,749,673 in the attached indemnification agreement represents an amount due HUD.

Acknowledge that $32,500,000 in the attached settlement agreement represents an amount due HUD, less DOJ’s civil debt collection fees.

Acknowledge that $7.23 million of the $14.5 million in the attached settlement agreement represents an amount due HUD, less DOJ’s civil debt collection fees.

Acknowledge that $6,076,741 of the $13,200,000 in the attached settlement agreement represents an amount due HUD, less DOJ’s civil debt collection fees.

Deobligate all obligations marked for deobligation during the departmentwide OOR, including as much as $54,909 in 13 administrative obligations marked for deobligation as of September 30, 2018

We also recommend that the Director of HUD’s Departmental Enforcement Center evaluate the apparent conflict-of-interest situations in this report and pursue administrative sanctions if warranted.