Work with borrowers and lenders to develop a plan to address the issues for each of the 58 defaulted loans within a reasonable time frame and implement corrective actions for the 58 loans; thereby protecting HUD’s investment of $329,541,272.

Quantify the amount of unauthorized distributions in the portfolio of 21 properties with 35 loans reported by the independent public accountant on the borrowers’ audited financial statements covering fiscal years 2018 to 2024 and require the borrowers to repay the amount of unauthorized distributions or pursue enforcement of the borrowers’ regulatory agreements by a written referral to HUD’s DEC.

Flag all principals of the borrowers with unreimbursed and unauthorized distributions in the Active Partners Performance System (APPS) to ensure that HUD appropriately evaluates the risks associated with doing business with these principals.

Refer any borrowers to the DEC for a civil money penalty or any other appropriate enforcement actions within 60 days of borrowers’ financial statement receipts for all unauthorized distributions not repaid within 30 days. If HUD ORCF chooses to allow a longer repayment period, document in iREMS the amount of the loan, the longer repayment period, and the reasons for the longer period.

Document DEC decisions and any penalties awarded in iREMS for each affected property for any ORCF referrals to the DEC about unauthorized loans.

Flag any borrowers in APPS for each unpaid penalty to ensure that HUD appropriately evaluates the risks associated with doing business with these principals.

Determine and document in iREMS the reasons that the borrowers did not make the mortgage payments and the specific steps HUD is taking to address the borrowers’ failure to make mortgage payments for all failures to make mortgage payments listed in borrowers’ audited financial statements.

Train HUD Account Executives on how to evaluate borrower action plans to ensure that action plans identify specific risks, identify the root causes of each risk, develop actions to address each root cause, identify specific measurable goals for each risk, and establish a timetable to complete the planned actions. Also, train HUD Account Executives on how to work with borrowers and lenders to ensure that borrowers properly develop, implement, and adhere to their action plans.

Develop and implement policies and procedures to ensure that borrowers and lenders execute action plans that properly list all specific risks at a property, identify the root causes of each risk, specify the actions to address each root cause, and establish a timetable to complete each action.

Develop and implement policies and procedures to ensure that HUD Account Executives document each action plan, properly list all specific risks at a property, identify the root causes of these risks, specify the actions to address the root causes, establish the timetables for completion, and document monthly progress towards completion of the actions in iREMS.

Develop and implement policies and procedures for a course of action when borrowers and/or lenders do not timely develop action plans. These policies and procedures should include civil money penalties, flagging the borrower in APPS, and inclusion in the Excluded Parties List System.

Update the protocols to ensure that all HUD ORCF teams working with any subset of the portfolio have insight into the entire portfolio for any portfolio split amongst lenders.

Require PRDOH to submit supporting documentation so HUD can evaluate the basis of the contract amendments and determine the eligibility of more than $31 million in disaster recovery funds. If HUD determines that the contract amendments were not supported, PRDOH must reimburse HUD from non-Federal funds.

Develop and implement a review and verification process to ensure that data provided by MTW PHAs as support for compliance with the statutory requirements, that is not reported in HUD systems is accurate, complete, and supported.

Develop and implement a process to ensure that corrections or updates to PHA information are reflected in either restated or subsequent MTW annual reports.

Require PHAs to retain supporting documentation for all data elements reported in their annual reports and program data not captured in HUD systems.

Develop and implement a process to ensure that appropriate outcomes are assessed for each PHA’s local MTW program.

Conduct an analysis to determine whether the changes to form HUD-50900 allow PHAs and HUD to appropriately measure the benefits and impacts of PHAs’ MTW program to include whether additional changes to the form are warranted to appropriately evaluate results of the MTW program.

Use the OIG’s fraud risk inventory to enhance its program-specific fraud risk inventory for the Single Family Housing program.

Include lenders and servicers in the fraud risk identification process and communicate the fraud risks and schemes identified for the Single Family Housing program to relevant stakeholders, including relevant HUD program and support staff, lenders, and servicers.