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.

Update its internal controls descriptions to reflect controls in place and implement monitoring activities to ensure that it carries out the controls and documents their performance and results.

Resolve the issues identified with the mastersubservicers to improve the data quality and timing of the raw data received for SLDB monthly processing and minimize manual adjustments.

Modify the standing operating procedures for the SLDB data quality checks that address mastersubservicer data deficiencies, data quality rules, and severity levels, to include periodic assessments of the appropriateness of the severity levels.

Review VAPE data validation procedures to improve preventive controls to determine the reasonableness of the inbound VAPE data before SLDB processing.

Implement the planned SLDB code fixes and enhancements to reduce future manual adjustments.

Ensure that all of the sampled amounts used for extrapolation in OCFO grant accrual validation estimates are properly supported with documentation that substantiates the amounts certified in the surveys.

Implement a refined accrual validation methodology, to include more comprehensive review procedures to substantiate the amounts certified by the grantee.

Review CPD’s grant accrual estimation methodology to ensure that all assumptions and variables used are properly supported and verifiable with the validation procedure.

After PIH prepayment validations are completed, apply all corrections to CAM 1 codes and Voucher Management System (VMS) expenses to all of the data supporting the fiscal year 2019 beginning balance, and recalculate the fiscal year 2019 PIH prepayment estimate. Based on the recalculation, determine whether restatement is needed to the correct errors in the fiscal year 2019 estimate calculation to ensure consistency between comparative statements.

Revise its review of the PIH prepayment estimate calculations performed by contractors to ensure that the contractors are following the established methodology and any changes to the methodology are applied to the data supporting the beginning balance, if appropriate.

Review all duties currently assigned to action officials to determine which duties can be centralized within OCFO or its Federal shared service provider. For any duties that cannot be centralized, (1) provide an explanation as to why they cannot be centralized and (2) assign these duties to appropriate positions within the program offices. Further, update the Debt Collection Handbook to include any changes made as a result of the review.