We recommend that HUD’s General Deputy Assistant Secretary for Community Planning and Development implement updated guidance and protocols for monitoring civil rights compliance and require CPD staff to incorporate civil rights monitoring into the risk analysis process.

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.

We recommend that HUD for grantees with delayed project activities (California, Connecticut, Louisiana, Tennessee, Virginia, New York City, Minot, and Shelby County), require each grantee to provide a detailed timeline with milestone dates of when projects should be completed and provide updates to ensure that grantees stay on schedule.

We recommend that HUD for its disaster-related program wide activities, require grantees to provide documentation showing that they have upfront collaboration with partnering entities in executing the grant program. If the grantee plans to hire contractors, HUD should ensure that grantees have a plan to quickly onboard contractors early in the program.

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.

Revise the Ginnie Mae Confidential Information Policy to state that in the future, (a) nondisclosure forms and agreements must include the anti-gag provision as required by law and (b) confidentiality clauses in personnel settlement agreements must include the anti-gag provision if the clause restricts disclosure of any other information beyond the terms and conditions of the agreement itself.

HUD OCIO should identify needs to address Federal requirements by performing a gap analysis on its zero trust architecture strategic plan.

HUD OCIO should establish a zero trust architecture implementation plan that includes milestones and resources to address all zero trust pillars.

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.

Update the Conveyance, Assignment, and Assumption Agreement to require purchasers to report final property outcomes and identifying information including those of third-party purchasers when applicable.

Enhance data collection and processing controls to ensure consistency in reporting data.

Enhance existing demonstration guidance within the Conveyance, Assignment, and Assumption Agreement to provide further detail regarding documentation retention requirements.

Housing should include zero trust requirements as part of the Housing Strategic Roadmap for Housing Modernization.

HUD OCIO should review its security training program and determine whether it should provide general cybersecurity awareness training to external users of its systems and data (IG FISMA metric 44).

Issue guidance to PHAs clarifying the timing of unit inspections and lead-based paint visual assessments to address the misinterpretation caused by the terms “annual” and “every 12 months.”

Implement a process to identify teleworkers most at risk of receiving incorrect locality payments, verify that their official duty stations are correct and they are reporting to their official duty stations as required, and if necessary, correct their locality payments.

Provide evidence to support that the owners corrected the 46 deficiencies for the 20 units with outstanding deficiencies. If the owners fail to provide evidence that they made the required corrections, HUD should require the Authority to implement its HAP enforcement procedures and provide supporting documentation to HUD evidencing that it did so.