The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

Conduct a study to project HUD’s capacity needs for ESI collections

Give its completed study to OCIO for consideration during future contract award decisions regarding E-Discovery services

Deobligate all obligations marked for deobligation during the departmentwide OOR, including as much as $174,132 in 160 administrative obligations marked for deobligation as of September 30, 2017.

Develop standard operating procedures for implementing accounting changes, including steps to assess the appropriate impact on each treasury account symbol.

Review all of Ginnie Mae’s TAS’s to determine the appropriate accounting treatment for anticipated collections, make the appropriate adjustments as determined necessary, apply this process going forward, and make restatements if necessary. The CFO should ensure that the accounting treatment follows the USSGL guidance through all phases of the anticipated collection (before collection and after collection).

Deobligate all obligations marked for deobligation during Ginnie Mae’s open obligation review, including as much as $34,814,053 in eight contract obligations marked for deobligation.

Notify OCFO to disregard Ginnie Mae’s previously provided FMFIA and FFMIA assurance statements and issue corrected FMFIA and financial management system OMB A-123, appendix D (FFMIA), assurance statements that reflect Ginnie Mae’s noncompliance with FFMIA.

Require its mission support contractors to submit a capitalization report and other supporting documentation in a timely manner, which would allow Ginnie Mae to record fixed asset activities during the proper period.

Acknowledge that $42,600,000 of the $65,000,000 in the attached settlement agreement represents an amount due HUD, less DOJ’s civil debt collection fees.

Acknowledge that $1,670,000 in the attached settlement represents an amount due HUD less DOJ’s civil debt collection fees.

Determine legal sufficiency and if legally sufficient, pursue civil and administrative remedies, civil money penalties, or both against RMS, its principals, or both for incorrectly certifying to the eligibility for FHA mortgage insurance or that due diligence was exercised during the origination of FHA loans.

Provide documentation to show that payroll costs totaling $2,019,496 and any payroll costs incurred outside our audit period, including fiscal year 2017, were reasonable and necessary expenses for the operation of the project or repay the project from nonproject funds for any amount that it cannot support.

Provide documentation to show that other direct costs totaling $56,021 and any direct costs incurred outside our audit period, including fiscal year 2017, were reasonable and necessary expenses for the operation of the project or repay the project from nonproject funds for any amount that it cannot support.

Develop and implement controls to ensure that the project complies with the regulatory agreement and applicable HUD requirements.

Pursue civil money penalties and administrative sanctions, as appropriate, against the owner and its parent company and their principals for their part in the violations cited in this report.

Determine legal sufficiency and if legally sufficient, pursue civil and administrative remedies, civil money penalties, or both against SecurityNational, its principals, or both for incorrectly certifying to the eligibility for FHA mortgage insurance or that due diligence was exercised during the origination of FHA loans.

Develop and implement controls to ensure that policies and procedures for account executives are continually reviewed and updated to reflect changes in Ginnie Mae’s operations.