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.

Correct the error related to the allocation of the liquidating reestimates in fiscal years 2017 and 2018.

Restate salary and administrative costs on FHA’s fiscal year 2017 statement of net cost, statement of net position, and footnote disclosures.

Require FHA and HUD OCFO to work together to determine a policy and procedure to ensure that both parties receive and provide complete information related to salaries and administrative costs.

Establish and implement a review process for salary and administrative cost information that is received from HUD OCFO to ensure that the information is complete and accurate.

Ensure that $399.1 million identified as invalid obligations in fiscal year 2018 is deobligated as appropriate.

Document the rationale and policy for the crosswalks used to prepare the financial statement note line items.

Document and implement policies and procedures, which include a review process to ensure that the general ledger accounts are correctly crosswalked to financial statement note line items.

Restate the fiscal year 2017 financial statement notes to correct inaccurate classifications, expenses, and market value balances reported by FHA.

In conjunction with the loan-servicing contractor, determine what actions can be taken to ensure that recorded assignments are reviewed in a timely manner after receipt.

Develop and implement a billing and sanctioning process to ensure that FHA bills servicers for the costs incurred to obtain recorded assignments from the counties’ recorder’s offices and sanctions the servicers when they do not provide the recorded assignments within 6 months of claim payment.

Improve the tracking of recording assignments by modifying the HERMIT assignment timeline to include date fields for servicers’ (1) receipt of recorded assignments from counties and (2) mailing of recorded assignments to the loan-servicing contractor.