HUD OCIO should identify needs to address Federal requirements by performing a gap analysis on its zero trust architecture strategic plan.

HUD OCIO should establish a zero trust architecture implementation plan that includes milestones and resources to address all zero trust pillars.

HUD OCIO should capture risks that are associated with zero trust architecture implementation and document these risks in its risk register.

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.

HUD’s Privacy Office should require program offices to periodically review systems in all environments (testing, development, production) for unnecessary disclosure of personally identifiable information (PII).

Housing should include zero trust requirements as part of the Housing Strategic Roadmap for Housing Modernization.

Housing should refine access controls within the FHA Catalyst modules that are dynamic, are tailored to user actions, and require continuous reauthentication to ensure that users have access only to information needed.

Housing should coordinate with HUD’s SOC to a. Ensure that FHA Catalyst user behavior monitoring logs are regularly captured and adequately reviewed for discrepancies in user activities. b. Establish program office responsibility for the log review process.