Assign and communicate the responsibility of FERA policy implementation and oversight to ensure that program offices are performing FERAs on a routine and timely basis to ensure effectiveness and efficiency of operations at the HUD program level and compliance with HUD internal policy and procedure.

Assign and communicate the responsibility of the MCR program policy, implementation, and oversight to ensure that program offices routinely conduct reviews to support a compliant internal control framework.

Conduct the OOR more frequently than annually to ensure that all obligations are adequately reviewed and deobligations are processed by the end of the fiscal year

Develop departmental policy that outlines the open obligation review process, to include (1) internal controls, (2) timeframes, and (3) roles and responsibilities of OCFO, OCPO, and program offices. These policies must outline sufficient internal controls in place to ensure that the Secretary can certify that all of HUD’s obligations are valid as of the end of the fiscal year.

Update standard operating procedures on the departmentwide unliquidated obligations review to conduct a routine review of justifications provided by the program offices for retained obligations, while ensuring that they are for a bonafide need and to support the annual certification made by the Secretary on open obligations.

As part of the OOR process, conduct monitoring activities of obligations sent to OCPO for deobligation by developing a mechanism to routinely track the status, to include key information, such as but not limited to the owner (program), date transmitted to OCPO, point of contact, last contact date, and current status. OCFO should use this information to ensure that all information has been communicated among all parties involved to enable timely deobligation.

Implement a process to ensure that ongoing ADA violation investigations are properly documented as the investigation progresses to enable timely review of open cases.

Deobligate all obligations marked for deobligation during the departmentwide OOR, including as much as $168,198 in 29 obligations marked for deobligation as of September 30, 2018.

Review the five identified retained inactive obligations with remaining balances totaling $110,224 and close out and deobligate amounts tied to obligations that are no longer valid or needed.

Review the one identified retained inactive obligation with a remaining balance totaling $60,395 and deobligate amounts that are no longer valid or needed.

Correct the impact of all of the modeling errors identified in this report.

Revise the modeling policies and procedures to use the established HECM loan limits in the HECM LLG cash flow model.

Develop alternative policies and procedures that would enable the use of the final single-family LLG cash flow model results and HECM return on notes cash flow model results in the final ROA models.

Reassess the HECM assumption that mortgages with an unpaid principal balance greater than the maximum claim amount will not be assigned to HUD and perform the following: (1) compare this assumption to historical experience, (2) document the basis for selecting the assumption as opposed to alternative assumptions, and (3) determine the impact of this assumption and the associated risk.

Reassess the model design that was implemented to avoid the double counting of the cash flows for HECM mortgages in the LLG cash flow and ROA models and perform the following: (1) determine whether there are alternative methodologies that will not result in the exclusion of cash flows in both models, (2) document the basis of the selected methodology, and (3) determine the impact and risk of the selected methodology.

Restate the fiscal year 2017 financial statements to correct the impact of using the improper discounting methodology in the HECM ROA model in fiscal year 2017.

Implement an automated subsidiary ledger system with the capability of obtaining loan-level transaction data from FHA, Treasury, and FFB source systems.

Work with Treasury and FFB to receive monthly loan-level transaction reports.

Identify the cause for the accrued interest differences and determine the correct accounting treatment.

Establish policies and procedures for recording and accounting for manual transactions, including the accounting rationale for the principal and interest on the direct loans and accrued interest on the borrowings.