Update all financial statement note checklists to include a review for completeness with the accounting standards and OMB Circular A-136.

Develop a formal enterprise risk management policy for program offices’ risk owners, including guidance for completing the annual risk profile refresh, requirements for completing risk mitigation strategies, and reporting risk mitigation progress to the Risk Management Council

Execute system code requests, including new program-level class and code, CAM 1 codes, in accordance with internal OCFO system standard operating procedures. Specifically, the CFO system code coordinator should verify that OCFO budget officers and program budget officers provide adequate documentation showing that the new CAM1 code is covered by an approved funds control matrix or sufficient justification for not requiring a funds control matrix.

Implement a process to periodically audit or reconcile ARC’s records.

Implement a process to periodically review approving officials’ span of control to ensure that the requirement is not exceeded.

Implement a process with ARC to ensure that cardholders and approving officials are notified before purchase card training is due to allow training to be completed in a timely manner.

Implement a process to ensure that purchase cards are suspended when a cardholder or approving official fails to complete training.

Research why ARC provided incomplete monthly transactional data and identify a solution to ensure the completeness of future transmissions.

Enhance the process to periodically analyze data for split transactions or improper MCCs and follow up on any potential issues identified.

Require ARC to update its MCC tracking log, to include the amount, the date of MCC override removal, and staff assigned, to ensure that an override is removed after the approved purchase is made.

Implement a process with Citibank and ARC to provide global notifications to cardholders and approving officials before autoclosures of credit card statements.

Implement a process to suspend cardholders or approving officials who repeatedly cause HUD to pay interest.

Obtain supporting documentation for the $1,807 spent on two cardholders’ purchase cards or require the vendors or cardholders to repay the funds to the applicable HUD program.

Suspend the travel cards for 35 employees who made 166 improper, illegal, or erroneous purchases, if warranted based on the nature of misuse, and coordinate with the related program offices, the Office of the Chief Human Capital Officer, and the Office of Employee Labor Relations to take appropriate disciplinary actions against these employees and their supervisors who did not follow up on the monitoring reports.

Ensure that ARC has properly updated the monitoring report criteria to include transaction categories that were previously missing from the monitoring reports.

Coordinate with the Office of Employee Labor Relations and the Office of the Chief Human Capital Officer to update HUD’s travel card policy with the table of penalties and disciplinary actions for travel card misuse and provide the updated policy and tiered instructions for disciplinary actions to administrative officers and approving officials.

Require program offices to report all disciplinary actions taken against employees who made improper purchases.

Generate a periodic report of travel cards for employees who do not travel and cancel the travel cards if not needed.

Inform all travel cardholders and approving officials about specific travel program requirements and repercussions for disregarding these requirements.

Verify with ARC on a regular basis that all travel cardholders have completed their training as required.