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.

Housing should refine access controls within the FHA Catalyst modules that are dynamic, are tailored to user actions, and require continuous reauthentication to ensure that users have access only to information needed.

Housing should coordinate with HUD’s SOC to a. Ensure that FHA Catalyst user behavior monitoring logs are regularly captured and adequately reviewed for discrepancies in user activities. b. Establish program office responsibility for the log review process.  

HUD OCIO should a) resolve the conflicts between its Inventory of Automated Systems (IAS) policy and web applications policy to clarify if web applications will be inventories in IAS, the web application Sharepoint site, or both; and b) implement the chosen resolution to this conflict to develop a consistent inventory of web applications (IG FISMA metric 1).

HUD OCIO should implement an automated governance, risk, and compliance tool to manage risk from all sources across the three tiers of the organization in a timely manner. This recommendation updates FY 2021 FISMA recommendation number 5 (IG FISMA metrics 5, 9, and 10).

HUD OCIO should employ automation to maintain a timely and accurate view of security configuration information for all systems connected to its network (IG FISMA metric 20).

HUD OCIO should demonstrate that it can implement its defined security responses if a baseline configuration is changed without authorization. This can be shown by either a response to a real incident if one happens or through a testing exercise if there are no applicable incidents (IG FISMA metric 23).

HUD’s Office of the Chief Financial Officer (OCFO), in coordination with other appropriate program offices, should define and implement a risk-based process to assess and document IT risk management personnel resourcing needs and that those personnel are allocated effectively to support HUD’s risk management program (IG FISMA metric 7).

HUD OCFO, in coordination with other appropriate program offices, should define and implement a process to document and allocate non-personnel risk management resources in a risk-based manner, to include but not limited to funding, processes, and technology (IG FISMA metric 7).

HUD OCIO should implement a process to consistently update and maintain its inventory of software assets and ensure that the inventory is consistent with the automated discovery scans used to perform vulnerability, configurations, and continuous diagnostics and mitigation scans and use this inventory to consistently remove unauthorized software assets from the HUD network (IG FISMA metrics 2, 20, and 21).

HUD OCIO should in coordination with the Chief Risk Officer (CRO), document cybersecurity risk management roles and responsibilities in a consolidated list and; define procedures to hold personnel accountable to their assigned roles in the consolidated list (IG FISMA metric 7)

HUD OCIO should consistently implement personnel accountability procedures to ensure that assigned cybersecurity risk management roles are being performed in an effective manner (IG FISMA metric 7).

HUD OCIO should define and implement metrics to monitor the effectiveness of ICAM program activities and assist in identifying areas for improvement (IG FISMA metric 26).

HUD OCIO should develop a comprehensive ICAM policy, strategy, process, and technology solution roadmap, including milestones, budget estimates, and appropriate technology solution details (IG FISMA metric 27). This recommendation replaces FY 2020 FISMA recommendation 11.

HUD OCIO should define policies and guidance for the use of system-specific access agreements (IG FISMA metric 29).

HUD OCIO should develop a plan that includes milestones and funding requirements for implementing phishing-resistant MFA for all users in alignment with Federal requirements (IG FISMA metrics 30 and 31).

HUD OCIO, in coordination with other appropriate HUD offices, should define and communicate policies and procedures for use of MFA at HUD facilities (IG FISMA metrics 30 and 31).

HUD OCIO should define a plan to meet the logging requirements at all event logging maturity levels (basic, intermediate, advanced) in accordance with OMB M-21-31. This plan should include logging sufficient to allow for reviewing privileged user activities (IG FISMA metrics 32 and 54).

HUD OCIO should develop and implement monitoring and enforcement procedures to ensure that non-GFE devices (for example, BYOD), such as those owned by contractors or HUD employees, are either: (a) prohibited from connecting to the HUD network; or (b) properly authorized and configured before connection to the HUD network (IG FISMA metrics 2, 21, and 33).

HUD OCIO should develop and implement procedures and contract terms to enforce forfeiture of non-GFE devices (for example, BYOD), to allow for analysis when security incidents occur (IG FISMA metrics 33 and 55).