Develop and implement procedures to ensure that the methodology is reevaluated by PIH and OCFO annually and any changes do not compromise (1) the audit trial, (2) compliance with GAAP, or (3) the accuracy of the balance.

Reopen recommendation 2016-FO-0003-002-A, “Evaluate the IHBG investment process and implement a proper accounting treatment in accordance with Federal GAAP.”

Reopen recommendation 2016-FO-0003-002-B, “Work with the Office of Native American Programs to calculate the amounts advanced to grantees and restate HUD’s financial statements to recognize the prepayments on the financial statements.”

Reopen recommendation 2016-FO-0003-002-C, “Develop standard operating procedures for routinely obtaining information on grantee investment activity and accurately reporting amounts in HUD’s general ledger and financial statements.”

Remove the waiver concerning the completion and submission of the SF-425 by CPD’s grantees and implement a process to collect SF-425 information electronically. This process should begin with initial (and ongoing) grant documentation containing specific requirements stating that the Federal Financial Report should be properly completed and required to be submitted quarterly, semiannually, or annually (depending on the grant type and applicable program requirements).

During the implementation process of the waiver removal and collection of SF-425 data, ensure that CPD verifies the accuracy of the accrual data collected from the grantees and provided to its contractor conducting the validation methodology and retain documentation showing that it has independently verified that the contractors resulting accrual estimation information is accurate.

Develop and implement a formal process to (1) track and age the suspense accounts by individual transaction detail, (2) perform regular monitoring of all suspense (clearing) accounts, and (3) promptly research transactions entered into the suspense accounts to ensure that they are posted to the appropriate TAS within 60 days.

Implement an information system or system application that can produce HUD’s consolidated financial statement notes accurately and in a timely manner.

Establish and implement policies and procedures that require identification and performance of complementary controls and periodic evaluation of established complementary controls to ensure that they continue to address financial and operational risks and document, assign, and communicate user complementary controls roles and responsibilities.

Establish and approve funds control matrices for S&E transactions and ensure traceability to the program funds, adopting the policies for budget execution, obligation, and expenditure of funds.

Ensure that each program office maintains current reporting elements in its funds control documentation, including the appropriation fund, CAM1, and BOC, to provide traceability to the Oracle financial system and the transaction source.

Establish records maintenance policies and procedures to ensure the accurate recording of IPAC transaction details, including summary amount, detail amount, unit amount, and unit price.

Monitor the review and verification processes to ensure that each IPAC transaction is accurately posted to the appropriate fund (TAS) in the Oracle financial system in a timely manner.

Improve controls to ensure that the OOR process is successful. This includes but is not limited to the following: (1) providing clarity on what constitutes a reasonable justification for retaining obligations marked for review during the OOR and (2) ensuring that a reasonable amount of time is provided for program offices to adequately complete the markup review phase of the OOR.

Deobligate all obligations marked for deobligation during the departmentwide OOR, including as much as $212,447 in 46 administrative obligations and 1 program obligation totaling $135,956 marked for deobligation as of September 30, 2017.

Update policies and procedures to require evidence supporting component and program office assurance statements to ensure submissions’ completeness and accuracy, including but not limited to (1) outstanding material weaknesses, (2) remediation plans, and (3) overall scope of assurance statements.

Work with PIH to determine which debts should be transferred to the Departments of Treasury or Justice and which debts should be written off. The Deputy CFO should ensure that proper documentation is maintained to support a decision for writeoff.

Establish controls to ensure that program offices send all outstanding debts to the Fort Worth Accounting Center for appropriate recording and management in a timely manner and in accordance with the debt collection handbook.

Determine the amount of additional funds needed to cover the remaining administrative costs and any possible upward adjustment of current obligations and seek authority from Congress to return up to $329,370,982 of the unapportioned authority remaining in the EHLP program account that is not needed.

Deobligate all obligations marked for deobligation during the departmentwide OOR, including as much as $559,569 in 53 administrative and $641,110 in 9 program obligations marked for deobligation as of September 30, 2017.