Implement routine client outcome data analysis to identify trends, quantify performance metrics and benchmarks, and measure the impact of prepurchase and postpurchase counseling on advancing homeownership. This should include routine analysis that HUD’s Office of Housing Counseling can implement based on data collected as well as continuing to pursue an updated housing counseling data system to help overcome client outcome data limitations.

More clearly define successful prepurchase and postpurchase homeownership counseling outcomes and use these definitions to help establish performance metrics and benchmarks for HUD’s Office of Housing Counseling and HUD-approved housing counseling agencies. This should include the types of successful outcomes under the Homeownership Initiative Grant, as well as other positive outcomes for clients that do not involve immediate homeownership.

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.

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 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 implement training at the regional level to provide instruction on and stress the importance of monitoring civil rights compliance as part of the MORs.

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.

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.

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.

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.