Support the eligibility of the $25,827 in personnel expenses from SPC (including offsetting the amount by applicable reimbursements) or repay its Housing Choice Voucher Program from the other applicable programs as appropriate or from non-Federal funds.

Support the eligibility of the $64,150 for accounting services charged to the Housing Choice Voucher Program that applied to other Authority programs (including offsetting the amount by applicable reimbursements) or repay the Program from the other applicable programs as appropriate or from non-Federal funds.

Support the reasonableness of the $340,701 Casterline contracts or repay the Housing Choice Voucher Program any amount that cannot be supported using non-Federal funds.

Support the reasonableness of the $33,415 Genesis contract or repay any amount that cannot be supported from non-Federal funds.

Establish and implement additional procedures and controls to ensure that City personnel responsible for administering procurement on the Authority’s behalf follow procurement and contracting requirements and maintain applicable supporting documentation in accordance with HUD requirements.

Repay the Housing Choice Voucher Program $5,648 from non-Federal funds for the unallowable expenses.

Develop and implement procedures and controls to ensure that ineligible food costs are not charged to the Program.

We recommend that the Office of Multifamily Housing Programs enforce written policies and procedures to ensure that the verification and payment of housing assistance payment subsidies for properties it subsidizes are based on accurate and supported information.

We recommend that the Office of Multifamily Housing Programs establish and implement policies to ensure effective contract administration, including providing funding approvals for project-based contract administrators in a timely manner.

We recommend that the Office of Multifamily Housing Programs develop contingency policies and procedures to ensure that the properties it subsidizes receive adequate and verifiable continuous monitoring.

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.