The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

Pursue departmental clearance for the 13 documents and policies identified that did not go through required departmental clearance. For any items that cannot be appropriately cleared, HUD should take appropriate action to recall the document or policy.

Obtain missing HUD-22 concurrence forms for the 13 identified directives and update the Clearance Calendar tracking system to properly document clearance of the 42 directives with incomplete Clearance Calendar documentation. For any items that cannot be appropriately cleared, HUD should take appropriate action to recall the document or policy.

Obtain repayment of $322,314 from nonproject funds from the management agent for the ineligible bookkeeper and accounts payable clerk’s salary and benefits, incurred during 2014 and 2015.

Decrease the payable to the management agent by $139,027 for ineligible employee services billed during 2014 and 2015, thereby reducing future expenditures because project funds will not be used for these ineligible expenses when funds become available.

Support or decrease the payables to its management agent for the amounts related to ineligible employee services charges before January 1, 2014, which we estimated to be $353,420.

Develop and implement controls over payments to include; ensuring that its management agreement clearly identifies services that are be provided by the management agent and paid for as part of the management fee, and the project is not charged for services that are part of the management fee.

Provide support showing that $17,414 in management fees charged to the projects using a budgeted amount represented actual amounts or repay the difference to each affected project.

Provide documentation to support that it paid itself $447,345 for eligible purposes or reimburse the appropriate projects for the balance.

Verify all management fees charged to the projects from 2013 through 2015 were appropriate.

Require Majestic Management to reimburse the appropriate projects their portion of $231,091 for work not completed or overbilled.

Require Majestic Management to provide support that $462,281 paid for procurements was reasonable or reimburse the appropriate projects for the balance.

Reimburse the appropriate projects their portion of $11,184 that it charged for ineligible items.

Provide documentation to support that $48,891 was spent for eligible purposes or reimburse the appropriate projects for the balance.

Issue a change to regulations at 24 CFR Part 203, which would avoid unnecessary costs to the FHA insurance fund, allowing an estimated $2.23 billion to be put to better use. These changes include (1) a maximum period for filing insurance claims and (2) disallowance of expenses incurred beyond established timeframes.

Status

The Federal Housing Administration (FHA) reported that the recommendation cannot be closed out without the publication of the FHA Maximum Claim Rule. The proposed changes have been on HUD’s regulatory agenda since Spring 2020 but, as of February 2025, the Office of Single Family Housing does not have an estimated publication date.

Analysis

To fully address this recommendation, HUD must publish the FHA Maximum Claim Rule. Implementation of this rule should result in HUD putting $2.23 billion to better use.

Reimburse FHA borrowers $25,700 for fees that were not customary or reasonable and $46,510 in discount fees that did not represent their intended purpose.

Reimburse $13,726 to FHA borrowers for the fees that were not customary or reasonable.

Comply with its Management Agent Handbook requirements that stipulate HUD must perform management reviews of the management agent’s central office activities as well as regular onsite reviews of functions carried out at the projects. These central office reviews should be performed at least once every 18 months.

Implement controls to prevent or reduce instances of borrowers violating HECM program residency requirements by concurrently participating in multifamily programs, including policies and procedures to at least annually coordinate with HUD’s Office of Multifamily Housing Programs to match borrower data in the Single Family Data Warehouse to member data in the Tenant Rental Assistance Certification System.