Develop and implement standard operating procedures for calculating and reporting HUD’s quarterly allowance for loss based on periodic evaluation of each type of HUD’s accounts receivables in accordance with GAAP. The procedures should also include steps to ensure proper note disclosure for significant classes of accounts receivables.

Reassess HUD’s SFFAS 50 implementation by correcting HUD’s IUS PP&E opening balance instead of the yearend balances and recognize capitalized IUS development, maintenance, and enhancement costs incurred during fiscal year 2019. If not reassessed, provide auditable documentation supporting the application of the methodology used supporting HUD’s assertion that the IUS zero balance valuation complies with SFFAS 50 and FASAB Technical Release…

Reevaluate capitalization and useful life thresholds included in HUD’s PP&E policy to ensure that they are comparable based on HUD’s funding level and size of operations and in accordance with capitalization thresholds and useful life requirements for leasehold improvements according to SFFAS 6 PP&E.

Recognize unrecorded assets and liabilities related to leasehold improvements and make proper disclosures regarding HUD’s leasehold improvement liability in the financial statements and notes.

Collaborate with OCFO to review methodologies used to produce grant accrual estimates, to include testing and verification of the resulting accrual estimates.

Implement a procedure to periodically, not less than annually, review HUD’s funds from dedicated collections to ensure that those funds fulfill the criteria established by FASAB. Additionally, update HUD’s financial reporting standard operating procedures with this new periodic review.

Collaborate with Treasury to correct the reporting type code for the funds associated with RAD to ensure that the reporting type code within HUD’s GTAS file reflects the correct reporting type.

Update all financial statement note checklists to include a review for completeness with the accounting standards and OMB Circular A-136.

Implement information security controls over the Section 108 loan guarantee database that prevent and detect unauthorized changes to program data (or implement an updated Section 108 loan guarantee database with information security controls that prevent and detect unauthorized changes to program data).

Develop a formal enterprise risk management policy for program offices’ risk owners, including guidance for completing the annual risk profile refresh, requirements for completing risk mitigation strategies, and reporting risk mitigation progress to the Risk Management Council

Cancel the Section 8 Project-Based Voucher Program housing assistance payments contract for 90 units improperly converted under RAD. The owner should work with HUD and the Authority to protect the tenancy of the affected tenants at the time of contract cancellation.

Reimburse HUD’s Section 8 program administered by the Authority $485,475 in housing assistance payments from nonproject funds for the improper issuance of tenant protection assistance and an improper RAD conversion to the Project-Based Voucher Program for the 90 units.

Develop and implement procedures to ensure that when tenant protection assistance is requested as a result of a housing conversion action, the forms HUD-50059 and or tenant profiles is generated only based on a completed action and that the forms or profiles are provided to HUD instead of the Authority.

Provide adequate training to staff associated with administering tenant protection and project-based assistance to help ensure compliance with program requirements.

Take appropriate enforcement actions against the responsible parties and pursue civil action against the owner for improperly certifying to the eligibility of the project residents.

Pursue administrative actions, as appropriate, against the responsible parties for the improper certification included in form HUD-50059 and the Section 8 project-based voucher housing assistance payments contract.

Implement adequate procedures and controls to ensure that all required data are complete, accurate, and reported in a timely manner. These procedures and controls should include but not be limited to ensuring that all transactions are recorded and reported within the proper period and listing the source of each of the data elements, including how to obtain the source documentation from HUD’s various program offices or systems.

Implement adequate procedures and controls to ensure that all data elements are traceable to the source documentation.

Revise internal DATA Act policy and procedure documents to resolve inconsistencies to ensure full, appropriate, and consistent implementation of the DATA Act.

Ensure that the HECM cash flow model assumptions capture all valid assignments or provide an analysis showing that the model results are not biased due to the exclusion of valid HECM assignments.