Implement a plan to annually survey all HUD program offices to identify nondisclosure policies, forms, and agreements issued and to determine whether they include the anti-gag provision as required by WPEA and, as necessary, to take corrective action to ensure that they include the anti-gag provision.

Communicate across HUD that (a) HUD employees are required to include the anti-gag provision in nondisclosure policies, forms, and agreements applicable to HUD employees and (b) program offices should consider requiring their employees to request OGC assistance when implementing and enforcing nondisclosure policies, forms, and agreements applicable to HUD employees.

Enforce the indemnification agreement in the attached settlement agreement to prevent an estimated $95,769 loss to HUD. This represents an amount due HUD from MetLife for indemnifying and holding HUD harmless for any and all losses HUD incurs or has incurred in connection with FHA loan number 137-4740973.

Provide documentation to show that payroll costs totaling $2,019,496 and any payroll costs incurred outside our audit period, including fiscal year 2017, were reasonable and necessary expenses for the operation of the project or repay the project from nonproject funds for any amount that it cannot support.

Provide documentation to show that other direct costs totaling $56,021 and any direct costs incurred outside our audit period, including fiscal year 2017, were reasonable and necessary expenses for the operation of the project or repay the project from nonproject funds for any amount that it cannot support.

Acknowledge that the attached settlement agreement for $510,000 represents an amount due HUD.