Update its QC plan and related processes and procedures to align with requirements for (1) loan file reviews, (2) assessment of findings, (3) mitigation of findings, and (4) reporting findings to HUD when required.

Provide annual training to its staff and management on HUD requirements for lender QC programs and provide proof of training to HUD.

Conduct up to 1,190 additional post-closing QC reviews to meet sample size and composition requirements and submit the results to HUD, including all findings of fraud or material misrepresentation, along with any other material findings that it is unable to mitigate. If required, loanDepot should execute indemnification agreements or reimburse claims paid to help protect the FHA insurance fund from unacceptable risk.

Review the 32 EPD loans not previously selected for review and submit the results to HUD, including all findings of fraud or material misrepresentation, along with any other material findings that it is unable to mitigate. If required, loanDepot should execute indemnification agreements or reimburse claims paid to help protect the FHA insurance fund from unacceptable risk.

Evaluate its QC files for the 1,579 loans in which it identified material findings to confirm whether it self-reported to HUD all findings of fraud or material misrepresentation, along with any other material findings that its records did not show have been acceptably mitigated. If required, loanDepot should execute indemnification agreements or reimburse claims paid to help protect the FHA insurance fund from unacceptable risk.

Provide indemnification agreements or documentation to support the 14 loans in which it identified material findings that it did not acceptably mitigate or self-report to HUD. Implementation of this recommendation will protect the FHA insurance fund from an estimated loss of $1,136,089.

Develop a strategy to comprehensively assess and respond to fraud risks across NYCHA. The strategy should identify who within NYCHA is responsible for designing and overseeing activities to prevent and detect fraud. The strategy should also include how NYCHA will (1) assess fraud risks across NYCHA methodically and periodically, (2) create response plans for fraud risks that are identified, and (3) monitor and evaluate the effectiveness of…

Based on the strategy, (1) complete an assessment of fraud risks across NYCHA, (2) create response plans for fraud risks that are identified, and (3) develop procedures to monitor and evaluate the effectiveness of fraud risk management activities.

Assess whether HUD’s other extra-large PHAs have mature fraud risk management programs and use the assessment to develop a strategy to reduce the fraud risk exposure to HUD. The strategy should include working with extra-large PHAs to implement appropriate fraud mitigation activities.

Work with HUD’s Chief Risk Officer to issue a notice to all PHAs explaining that PHAs are responsible for fraud risk management and play a role in fulfilling HUD’s requirement to identify and mitigate fraud risks. This notice should clearly indicate that PHAs should implement fraud risk management, which includes (1) completing an assessment of fraud risks, (2) creating response plans for fraud risks that are identified, and (3) developing…

We recommend that HUD’s General Deputy Assistant Secretary for Community Planning and Development implement training on civil rights monitoring reviews. Additionally, CPD should ensure that training on civil rights monitoring reviews is regularly provided to CPD staff.

We recommend that HUD’s General Deputy Assistant Secretary for Community Planning and Development develop guidance clarifying the use of the exhibit for on-site, hybrid, and remote monitoring to ensure a full review of grantees’ compliance with civil rights requirements, and incorporate this guidance into the training developed as a result of recommendation 1A.

We recommend that HUD’s Deputy Assistant Secretary for Multifamily Housing implement training at the regional level to provide instruction on and stress the importance of monitoring civil rights compliance as part of the MORs.

We recommend that HUD’s Deputy Assistant Secretary for Multifamily Housing direct HUD staff to perform all required monitoring of civil rights compliance as part of the MORs conducted.

We recommend that HUD’s Deputy Assistant Secretary for Multifamily Housing instruct the PBCAs to include the completion of the addendum B checklist as part of the MORs performed by the PBCAs.

We recommend that HUD’s Deputy Assistant Secretary for Multifamily Housing provide technical training to the multifamily property owners and management agents on completing addendum B accurately as part of the MORs.

Work with the prime award recipients that had subaward reporting deficiencies to ensure that their subaward information is reported or reported accurately.

Update and expand the guidance on FFATA subaward reporting requirements provided to prime award recipients by (1) updating program website(s) with comprehensive information about FFATA, (2) implementing training, (3) issuing formal communication, and (4) implementing a feedback mechanism to ensure that all prime award recipients have the opportunity to share challenges with HUD and ask questions.

Integrate FFATA reporting requirements into program monitoring procedures for all programs and conduct regular reviews to assess compliance.

Ensure that programs with subaward activity include specific clauses related to FFATA compliance in their grant agreements, and notices of funding opportunities.