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This report reviewed the Office of Native American Programs – Office of Loan Guarantee’s (OLG) Section 184 program to determine whether its IT systems enabled effective management and oversight of the program. We found HUD had not successfully deployed an information technology (IT) system that enabled effective management and appropriate oversight of all Indian Home Loan Guarantee Program (Section 184 program) processes.  Multiple IT systems support the Section 184 program with limited functionality and multiple methods for loan processing.  Many Section 184 loan application processes are still processed manually or supported by a HUD Housing legacy IT system. 

HUD developed a modernized Office of Native American Programs - Loan Origination System (ONAP-LOS) that was deployed in 2017 and was still under development during our review, with no projected timelines to complete additional functionality.  The ONAP-LOS has significant limitations, requiring lenders and program officials to continue to use a HUD Office of Housing legacy IT system and manual processes for maintaining files, servicing loans, and managing claims.  Only 1 of 38 lenders supporting the Section 184 program are able to access ONAP-LOS due to HUD’s inability to administratively resolve an access issue.  That issue along with data compatibility concerns is preventing a complete transition from the legacy system, the original objective of one comprehensive information system to enable the effective management and oversight of the Section 184 program is not achieved. 

We recommend that HUD (1) develop a comprehensive project plan to address the gaps in the LOS capabilities, (2) identify all viable options to securely resolve the LOS access issues, so authorized Section 184 lenders can access the system, (3) ensure that the Section 184 program transitions away from dependency on a HUD Housing legacy IT system, (4) continue to develop required LOS capabilities using cloud environments as appropriate, and (5) that the Office of Native American Programs and OLG coordinate and participate in resolving all open recommendation from this evaluation report.

Recommendation Status Date Issued Summary
2018-OE-0004-01 Cerrado Agosto 13, 2018 Direct PIH and OCIO to develop a comprehensive project plan, documenting the milestones and dates for addressing the gaps in ONAP-LOS capabilities (functionality and reports) and the 25 recommendations made during HUD OCIO's project health assessment
2018-OE-0004-02 Cerrado Agosto 13, 2018 Direct all stakeholders to identify all viable options to securely resolve the ONAP-LOS access issues, so authorized Section 184 lenders can access the system. The best solution should not impose unacceptable risk to business processes or sensitive data. Current program offices involved are OCIO, PIH, and FHA, while others may also be identified
2018-OE-0004-03 Cerrado Agosto 13, 2018 Direct PIH and OCIO to ensure that the Section 184 program transitions away from dependency on CHUMS.
2018-OE-0004-04 Abierta Agosto 13, 2018 Continue to develop required ONAP-LOS capabilities using cloud environments as appropriate
2018-OE-0004-05 Abierta Agosto 13, 2018 Coordinate and participate in resolving all open recommendations from evaluation report IT System Management and Oversight of the Section 184 Program (2018-OE-0004)