Develop and implement an indirect cost allocation plan, which ensures that indirect costs are charged to the correct program.

Provide technical assistance to the Community to ensure that its staff receives training on documentation of matching contributions and the use of program funds.

Reclassify the $28,576 as program income to the specific permanent supportive housing program that generated it and ensure these funds are used for that specific program.

Develop and implement written policies and procedures to ensure that all program income is recorded and used in accordance with HUD requirements.

Support that $2,687 in payments to the board member for legal services was allowed through a HUD-approved waiver that occurred before the legal services or repay HUD from non-Federal funds.

Refer troubled PHAs directly to the Assistant Secretary for Public and Indian Housing when they have not met the 1- or 2-year recovery requirements.

Ensure that referrals to the Assistant Secretary for Public and Indian Housing recommend only recovery options allowed by the law and regulations.

Update training to include the actions that PIH must take when a troubled PHA does not meet the 1- or 2-year recovery requirements.

Provide training on remedies for long-term troubled PHAs to All PIH staff members who routinely interact with troubled PHAs.

Submit an annual troubled PHAs report to congress in accordance with the statute.

Update HUD’s loss mitigation policies, to include deadlines for the servicers to file the FHA-HAMP nonincentivized partial claims, and consider imposing sanctions for noncompliance with these deadline requirements.

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.

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.

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.

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.

Document the economic rationale behind unintuitive model coefficients to support that the unintuitive relationships are appropriate.

Document all model assumptions that are undocumented, providing the basis for any assumptions or decisions made when developing each model assumption.

Develop and implement policies and procedures to ensure compliance with model risk management guidance regarding adequate and well-documented model assumptions.

Develop and implement controls that ensure the updating of model documentation when model changes are made.

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.