We recommend that HUD’s Deputy Assistant Secretary for Fair Housing and Equal Opportunity review and update investigative processes followed by each regional office to identify best practices that can be implemented across all regions and identify and remove inefficiencies that can lead to longer investigation times.

Take corrective action for the subrecipient monitoring and agreement issues cited for eight of the ESG-CV grantees reviewed, and provide additional guidance and technical assistance as needed to ensure that they understand requirements.

Develop and implement additional subrecipient monitoring training and guidance for all ESG grantees.

Implement procedures and controls to ensure that visual assessments for lead-based paint are completed at least every 12 months.

Implement procedures and controls to ensure that risk assessments and reevaluations are conducted in accordance with HUD’s requirements.

Obtain lead-based paint risk assessments for the five developments for which hazard reduction work was completed and perform the required reevaluations.

Determine whether the remaining five developments (Imperial Courts, Mar Vista Gardens, Nickerson Gardens, Ramona Gardens, and Rancho San Pedro) have deteriorated paint and if so, obtain lead-based paint risk assessments and reevaluations when applicable.

Coordinate with HUD’s Office of Lead Hazard Control and Healthy Homes to obtain training for the Authority’s employees responsible for managing lead-based paint on the management of lead-based paint, including the requirements for visual assessments, risk assessments, reevaluations, and hazard reduction.

Require that the PLUS system for receiving, processing, and assigning applications tracks applications and captures application intake, screening, and status, including key dates; captures data on the type of underwriter used; includes a portal for receiving documents and communicating with lenders; and generates FHA loan numbers. This will allow HUD to identify, monitor, and address processing delays and issues on a continuous basis; evaluate its performance and processes; and manage future challenges.

Update policies and procedures to include methods that will be used when applications exceed underwriter capacity, align intake and screening processes, and explain when timeframes will be enforced, including in PLUS.

Issue an industry wide letter to reinforce how intake, screening, and enforcement of timeframes will be handled.

Improve or enhance its antifraud efforts for the ESG program and incorporate fraud risk management practices that are consistent with the best practices identified in the Government Accountability Office’s A Framework for Managing Fraud Risks in Federal Programs and Chief Financial Officers Council and Treasury Bureau of the Fiscal Services’ Antifraud Playbook.

Obtain training or technical assistance as needed on the implementation of fraud risk management practices.

Update relevant policies and procedures for appraiser roster management so that they align with each other and with regulations and reflect HUD practice. At a minimum, the policies and procedures should clearly cover appraiser roster status, license expiration, disciplinary actions, removals, data accuracy, and documentation.

Maintain historical data for each appraiser record, including history on expiration dates, when appraisers are moved on or off the appraiser roster and when they are and are not allowed to be assigned to conduct appraisals.

Improve quality assurance processes by adding steps to verify that the appraiser roster is accurate and reliable over time through testing of its logic-based system controls and data fields.

Develop and implement adequate procedures to ensure that confirmed EBLL cases, unconfirmed EBLL cases, and environmental investigations are reported to HUD.

Develop and implement adequate procedures and controls to ensure that environmental investigations are completed when required.

Perform a search for historical documentation to support the lead-free status of the 15 units and the associated developments. If adequate documentation is not found to support that all lead-based paint was identified and abated and clearance was achieved as required, the Authority should complete a lead-based paint inspection of the developments to determine whether they are lead free.

Develop a quality control process to ensure that records for the remaining 1,385 units contain evidence of lead-free status. If adequate documentation is not found to support that all lead-based paint was identified and abated and clearance was achieved as required, the Authority should complete a lead-based paint inspection of the developments to determine whether they are lead free.