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.

Research the survey responses received as part of OCFO’s validation of grant accrual estimates that resulted in a positive cash on hand to determine whether a cash advance exists. If so, OCFO should coordinate with CPD to (1) determine whether the grantees have proper documentation and approvals allowing for cash advances and (2) develop and implement procedures to estimate and account for cash advances for financial reporting purposes.

Develop and implement standard operating procedures for recording and periodically evaluating sustained audit receivables to ensure that (1) all receivables are supported by a claim to cash and (2) an allowance for loss is recorded that reasonably estimates uncollectible amounts to reduce the gross amount of receivables to its net realizable value.

Develop and implement procedures that require action officials to certify the validity of accounts receivables periodically, at least quarterly. OCFO should use this information to assess the reasonableness of the allowance for loss estimate.

Work with action officials to determine the validity of all receivables from OIG sustained audit findings, determine whether restatement is necessary, and adjust HUD’s current and prior-year accounts receivable balances accordingly, ensuring that all writeoffs are reported to the Treasury.

Perform a validation, comparing the data used in OCFO’s PIH prepayment estimate calculation to the data used by PIH in its RNP reports to ensure that all CAM 1 codes and VMS fields are appropriately included. If it is determined that CAM 1 codes or VMS codes are missing or not properly included, OCFO should update the standard operating procedure and all estimates made to ensure that they are included.

Design and implement a procedure that ensures periodic communication between OCFO and PIH regarding all events that impact the PIH prepayment estimate.

Review FMC’s final December 31, 2016, balances and update the PIH prepayment beginning balance accordingly.

Design and implement a policy or procedure that ensures the accuracy of all information provided to HUD OCFO related to the PIH prepayment estimation methodology.

Delegate responsibilities to the appropriate program office and assign risk owners to provide responses for the acceptance, mitigation, and elimination of risks identified in HUD’s ERM risk profile.

Develop, implement, and document internal controls in response to identified risks from HUD’s ERM risk profile in compliance with OMB Circular No. A-123, Management's Responsibility for Enterprise Risk Management and Internal Control.

Complete and issue final FERA policy to the Department and communicate the requirements within the policy to program offices in a timely manner.

Assign and communicate the responsibility of FERA policy implementation and oversight to ensure that program offices are performing FERAs on a routine and timely basis to ensure effectiveness and efficiency of operations at the HUD program level and compliance with HUD internal policy and procedure.

Assign and communicate the responsibility of the MCR program policy, implementation, and oversight to ensure that program offices routinely conduct reviews to support a compliant internal control framework.

Conduct the OOR more frequently than annually to ensure that all obligations are adequately reviewed and deobligations are processed by the end of the fiscal year