Implement procedures and controls for targeting non-FHA-insured RAD PBV projects to monitor the physical conditions and reserve for replacement accounts.

Implement procedures for monitoring property owners’ reserve for replacement accounts for compliance with HUD’s requirements, using reserve for replacement account data collected on projects from PHAs.

Provide inspection reports for the units identified in this report that failed to meet HQS showing that the units and associated buildings meet HUD’s current physical condition standards.

Implement a policy to ensure that monitoring of RAD PBV projects includes, at a minimum, a review of the accuracy of the reserve for replacement account balances and compliance with HUD’s physical condition and inspection requirements.

Review the reserve for replacement accounts for the 12 underfunded projects to ensure that the account balances are maintained in accordance with the applicable HUD requirements and executed HUD business documents and require owners to fully fund any underfunded reserves, as applicable.

Review the reserve for replacement accounts for the 14 project owners that did not make annual adjustments for inflation, as identified in the capital needs assessment, to determine whether the account balances are sufficient to meet anticipated capital needs. If the account balances are not sufficient, HUD should require the owners to appropriately fund the accounts.

Implement a plan to review the reserve for replacement accounts for all RAD PBV projects to ensure that reserve for replacement accounts are appropriately funded.

Obtain documentation from the PHAs to support that more than $1 million in withdrawals from the eight reserve accounts complied with HUD’s requirements or require the project owners to reimburse the reserve accounts for the unsupported withdrawals.

Implement a process, in conjunction with the Office of Recapitalization, to ensure that the reserve for replacement requirements in HUD’s business documents, such as the RAD conversion commitment, HAP contract, and operating agreement, are consistent for converted projects.

Collect data on projects’ reserve for replacement accounts to support the Office of Field Operations’ monitoring activities.

Update its QC plan and related processes and procedures to align with requirements for loan selection, including maintaining data and documenting how sample sizes and loan selections were determined.

Update its QC plan and related processes and procedures to align with requirements for (1) loan file reviews, including requirements to obtain new credit reports, reverify borrower information, and obtain appraisal field reviews; (2) documenting review results, including maintaining data on findings; (3) assessment of findings; (4) mitigation of findings; (5) reporting findings internally to lender management; and (6) reporting findings to HUD when required.

Provide annual training to its staff and management on HUD requirements for lender QC programs and provide proof of training to HUD.

Review the six EPD loans not previously selected for review and submit the results to HUD, including all findings of fraud or material misrepresentation, along with any other material findings that it is unable to mitigate. If required, Flat Branch should execute indemnification agreements or reimburse claims paid to help protect the FHA insurance fund from unacceptable risk.

Obtain credit reports and reverify borrower information for up to 279 EPD reviews performed and evaluate the risk of both new findings identified and existing findings contained in its QC files to confirm whether it self-reported to HUD all findings of fraud or material misrepresentation, along with any other material findings that its records did not show have been acceptably mitigated. If required, Flat Branch should execute indemnification agreements or reimburse claims paid to help protect the FHA insurance fund from unacceptable risk.

Evaluate its QC files for the 29 post-closing QC reviews in which it identified material findings to confirm whether it self-reported to HUD all findings of fraud or material misrepresentation, along with any other material findings that its records did not show have been acceptably mitigated. If required, Flat Branch should execute indemnification agreements or reimburse claims paid to help protect the FHA insurance fund from unacceptable risk.

Provide indemnification agreements or documentation to support the two loans in which it missed material deficiencies and the three loans in which it identified material findings that it did not acceptably mitigate or self-report to HUD. Implementation of this recommendation will protect the FHA insurance fund from an estimated loss of $228,793.

Develop and implement a policy that clearly defines roles and responsibilities for Office of Multifamily Housing Programs’ staff for EBLL-related requirements, including the oversight of property owners’ compliance with these requirements.

Establish processes to track reported EBLLs for the Office of Multifamily Housing Programs to easily identify the status of owners’ remediation efforts for units that were the source of the confirmed EBLL.

Develop and implement uniform procedures for the FSM desk monitoring review, including a second level review for the FSM monitoring reviews and process for each inspection type.