HUD Had Not Established Deadlines for Reporting FHA-HAMP Nonincentivized Loan Modifications and Filing Nonincentivized Partial Claims
Update HUD’s loss mitigation policies, to include deadlines for the servicers to report the new terms of the FHA-HAMP nonincentivized loan modifications, and consider imposing sanctions for noncompliance with these deadline requirements.
Audit of the Government National Mortgage Association's Financial Statements for Fiscal Year 2019
Test whether a cumulative housing price appreciation (HPA) variable should be added to the probability of prepayment, probability of default, foreclosure timeline, buyout time models, and cure rate assumptions. Ginnie Mae should provide an analysis if it believes that adding an HPA variable would not be appropriate to support its position.
Audit of the Government National Mortgage Association's Financial Statements for Fiscal Year 2019
Develop and implement policies and procedures to require a sufficiently granular decomposition analysis that can adequately explain the impact of all the model changes made.
Audit of the Government National Mortgage Association's Financial Statements for Fiscal Year 2019
Develop and implement policies and procedures or enhance or clarify, as appropriate, existing policies and procedures that will require additional analyses whenever thresholds are breached or other analyses indicate potential modeling issues.
Audit of the Government National Mortgage Association's Financial Statements for Fiscal Year 2019
Document the economic rationale behind unintuitive model coefficients to support that the unintuitive relationships are appropriate.
Audit of the Government National Mortgage Association's Financial Statements for Fiscal Year 2019
Document all model assumptions that are undocumented, providing the basis for any assumptions or decisions made when developing each model assumption.
Audit of the Government National Mortgage Association's Financial Statements for Fiscal Year 2019
Develop and implement policies and procedures to ensure compliance with model risk management guidance regarding adequate and well-documented model assumptions.
Audit of the Government National Mortgage Association's Financial Statements for Fiscal Year 2019
Develop and implement controls that ensure the updating of model documentation when model changes are made.
Audit of the Government National Mortgage Association's Financial Statements for Fiscal Year 2019
Improve model documentation by addressing the model documentation deficiencies cited in this report and narrowing or consolidating them into fewer pieces of documentation, as appropriate.
Audit of the Government National Mortgage Association's Financial Statements for Fiscal Year 2019
Formalize and define coding best practices within Ginnie Mae’s model governance framework.
Audit of the Government National Mortgage Association's Financial Statements for Fiscal Year 2019
Apply coding best practices during model development processes and add a control for reviewing model code for compliance with best practices.
Audit of the Government National Mortgage Association's Financial Statements for Fiscal Year 2019
Ensure that documentation is maintained to support reimbursable cost receivables recorded on Ginnie Mae’s financial statements or write off the reimbursable costs receivables that are not valid or cannot be supported.
Audit of the Government National Mortgage Association's Financial Statements for Fiscal Year 2019
Establish audit trails to ensure that supporting documentation can be easily traced and verified to the recorded transactions in the general ledger.
Audit of the Government National Mortgage Association's Financial Statements for Fiscal Year 2019
Establish and implement remedial action plans to document the implementation testing of the effectiveness of its internal control over financial reporting in accordance with OMB Circular A-123, appendix A.
Audit of the Government National Mortgage Association's Financial Statements for Fiscal Year 2019
Update its internal controls descriptions to reflect controls in place and implement monitoring activities to ensure that it carries out the controls and documents their performance and results.
Audit of the Government National Mortgage Association's Financial Statements for Fiscal Year 2019
Resolve the issues identified with the mastersubservicers to improve the data quality and timing of the raw data received for SLDB monthly processing and minimize manual adjustments.
Audit of the Government National Mortgage Association's Financial Statements for Fiscal Year 2019
Modify the standing operating procedures for the SLDB data quality checks that address mastersubservicer data deficiencies, data quality rules, and severity levels, to include periodic assessments of the appropriateness of the severity levels.
Audit of the Government National Mortgage Association's Financial Statements for Fiscal Year 2019
Review VAPE data validation procedures to improve preventive controls to determine the reasonableness of the inbound VAPE data before SLDB processing.
Audit of the Government National Mortgage Association's Financial Statements for Fiscal Year 2019
Implement the planned SLDB code fixes and enhancements to reduce future manual adjustments.
Additional Details To Supplement Our Fiscal Year 2019 U.S. Department of Housing and Urban Development Financial Statements Audit
Ensure that all of the sampled amounts used for extrapolation in OCFO grant accrual validation estimates are properly supported with documentation that substantiates the amounts certified in the surveys.