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.

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.

Formalize and define coding best practices within Ginnie Mae’s model governance framework.

Apply coding best practices during model development processes and add a control for reviewing model code for compliance with best practices.