Investigate other methods for validating CPD’s accrued grant liabilities estimate, including the use of other sampling units, which could provide additional relevant information that can be used to produce more reasonable results and reduce estimation uncertainty to a low level.

Review the 21 loans with improperly administered forbearance to ensure that the borrowers were remedied by the servicers, if possible, and ensure that these servicers updated their forbearance procedures to prevent future noncompliance.

Ensure that the issues found during our audit are incorporated into QAD’s servicing monitoring reviews.

Provide additional guidance to the servicers so they will limit their communication and collection efforts for the borrowers in forbearance.

We recommend that the Director of the Office of Block Grant Assistance require the Texas GLO to include milestones and appropriate consequences for not meeting those milestones in future subrecipient agreements to ensure that expenditure deadlines remain on track. Implementing this recommendation could assist the Texas GLO in avoiding possible future litigation based on the lack of required benchmarks in its contracts.

We recommend that the Director of the Office of Block Grant Assistance require the Texas GLO to provide its plan to ensure that processes are in place to assist those participants transitioning from the City’s programs to the Texas GLO’s programs.

With HUD’s approval of action plan amendment 8, we recommend that the Director of the Office of Block Grant Assistance require the Texas GLO to provide its plan to continuously monitor the City’s pace and performance in its remaining Hurricane Harvey CDBG-DR program and take appropriate action to ensure that program goals are met. The plan should include a process for repurposing additional grant funds, if necessary, to avoid potential…

With HUD’s approval of action plan amendment 8, we recommend that the Director of the Office of Block Grant Assistance require the Texas GLO to set performance and financial milestones, including approval of the City’s projects and obligation and expenditure of funds, for all programs and activities funded under the City’s subrecipient agreement through the remainder of the contract and deadlines for the City to achieve those milestones. This…

With HUD’s approval of action plan amendment 8, we recommend that the Director of the Office of Block Grant Assistance require the Texas GLO to provide its plan to ensure that the City will comply with the Texas GLO’s program guidelines and required onsite technical assistance and supportive services. This plan would include (1) precise instructions and deadlines for submitting or resubmitting program and implementation guidelines, (2) terms…

Revise its methodology to identify slow spenders, including appropriate baselines and the definition of slow spenders.

Update its policies and procedures for tracking expenditures related to slow-spending grantees, including steps for assisting the grantees to expedite spending (including the grantee’s steps or actions to address slow spending), identifying the reasons for the delays with the grant, and documenting the outcome of its efforts. Corrective Action Taken CPD updated guidance addressing grantee slow spending through technical…

Establish a reasonable timeframe for grantees to resolve DRGR flags or at a minimum, if a flag cannot be resolved within the established timeframe, have the grantee provide a remediating comment explaining why the flag could not be resolved and a proposed timeline for resolution.

Resolve or remediate outstanding flags for grants B-12-MT-01-0001, B-13-MS-36-0002, B-16-MH-48-0001, and B-16-DL-12-0001 in DRGR.

Require updated projections for grants B-12-MT-01-0001, B-13-MS-36-0002, and B-16-DL-12-0001 and provide assistance to the grantees to ensure that the expenditure deadlines will be met.

Update its policies and procedures to require grantees to identify the reason for variances between the actual and projected expenditures to enhance CPD’s oversight.

Update monitoring exhibit 6-1 to include (1) reasons for differences between actual and estimated projections and (2) a question to determine whether the grantee is meeting the timelines established and if the timelines are not met, providing reasons.

Update policies and procedures to require CPD staff to sufficiently document its basis for conclusions to meet the monitoring handbook and QPR checklist requirements and intentions.

Consider suggestions made by grantees to assist with the progress of spending funds and provide support for the guidance it plans to share with grantees based on these suggestions. (See bullets under Grantees Generally Considered CPD’s Assistance With the Progress of Their Grants Helpful.)

Develop and implement written policies and procedures and controls for the FHA refund process to address the deficiencies identified in the audit report. These should include (1) controls to ensure that the website for the public listing of all unpaid refunds is complete, (2) controls to ensure that refund applications are sent only to the homeowners who requested them, (3) controls to ensure that refund applications are sent to all homeowners…

Develop and implement written policies and procedures (1) for locating homeowners who have unpaid refunds (for both existing and new refunds), (2) to establish a standard timeframe for mailing refund applications to homeowners after they are requested, and (3) to establish requirements for verifying the termination date based on supporting documents provided by homeowners.