For the remaining retroactive RAD conversion not completed, to take steps, including but not limited to maintaining adequate approval documentation to ensure that it enforces its requirement that the tenant protection assistance is provided to tenants before the submission of the RAD application.

For the remaining retroactive RAD conversion not completed, to take steps including but not limited to training staff responsible for reviewing and approving RAD applications to ensure that it enforces its requirement that the tenant protection assistance is provided to tenants before the submission of the RAD application.

Assign independent, contract officers to review and certify the initiating contract buyer’s compliance with policies for initiating and authorizing interagency agreements and later modifications for all amounts in accordance with Acquisition Instruction 13-07, HUD Contracting Officers.

Ensure that contracting officers and OCPO field offices review and follow the records management policies and procedures, including completing and signing Forms 7600A and 7600B, to ensure consistency among contract officers approving interagency agreements in the procurement system of record.

Collaborate with OCFO to review methodologies used to produce grant accrual estimates, to include testing and verification of the resulting accrual estimates.

Implement information security controls over the Section 108 loan guarantee database that prevent and detect unauthorized changes to program data (or implement an updated Section 108 loan guarantee database with information security controls that prevent and detect unauthorized changes to program data).

Develop and implement policy and procedures for the incremental obligation process used for project-based Section 8 funds, including documentation for determining the incremental amounts and controls to review the amounts for accuracy.

Test whether a cumulative housing price appreciation (HPA) variable should be added to the probability of prepayment, probability of default, foreclosure timeline, buyout time models, and cure rate assumptions. Ginnie Mae should provide an analysis if it believes that adding an HPA variable would not be appropriate to support its position.

Develop and implement policies and procedures to require a sufficiently granular decomposition analysis that can adequately explain the impact of all the model changes made.

Develop and implement policies and procedures or enhance or clarify, as appropriate, existing policies and procedures that will require additional analyses whenever thresholds are breached or other analyses indicate potential modeling issues.

Document the economic rationale behind unintuitive model coefficients to support that the unintuitive relationships are appropriate.

Document all model assumptions that are undocumented, providing the basis for any assumptions or decisions made when developing each model assumption.

Develop and implement policies and procedures to ensure compliance with model risk management guidance regarding adequate and well-documented model assumptions.

Develop and implement controls that ensure the updating of model documentation when model changes are made.

Improve model documentation by addressing the model documentation deficiencies cited in this report and narrowing or consolidating them into fewer pieces of documentation, as appropriate.

Formalize and define coding best practices within Ginnie Mae’s model governance framework.

Apply coding best practices during model development processes and add a control for reviewing model code for compliance with best practices.

Ensure that documentation is maintained to support reimbursable cost receivables recorded on Ginnie Mae’s financial statements or write off the reimbursable costs receivables that are not valid or cannot be supported.

Establish audit trails to ensure that supporting documentation can be easily traced and verified to the recorded transactions in the general ledger.

Establish and implement remedial action plans to document the implementation testing of the effectiveness of its internal control over financial reporting in accordance with OMB Circular A-123, appendix A.