Conduct a privacy impact assessment for accepting homeowner FHA refund applications and supporting documentation that contain PII electronically to identify potential risks and develop and implement plans to mitigate those risks.

Develop and implement written policies and procedures for SFIOD to quickly respond to emergency situations when staff cannot return to the office. Procedures should include steps to quickly notify homeowners of any changes made to the FHA refund process.

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.

Conduct and make available internal HEROS training for all multifamily HEROS users on how to document the environmental review mitigation measures.

Establish and implement written procedures specifying which multifamily employees are required to upload mitigation resolutions after construction completion and at final endorsement.

Upload the 17 missing mitigation resolutions and the 1 missing radon testing document into HEROS for the projects in this finding.

Strengthen HEROS or internal procedures to add an additional requirement confirming that the mitigation resolutions have been uploaded at final endorsement.

Strengthen HEROS by adding a column on the dashboard to show the progress of the overall mitigation status.

Require lenders to obtain the borrowers’ consent to verify the existence of delinquent Federal taxes with the IRS during loan origination and deny any applicant with delinquent Federal tax debt and no payment plan or a noncompliant payment plan or an applicant refusing to provide consent from receiving FHA insurance to put at least $6.1 billion to better use by avoiding potential future costs to the FHA insurance fund.

Status

To fully address this recommendation, HUD will need to provide evidence that it established a method of borrower consent to verify the existence of delinquent federal taxes including, but not limited to one of the options OIG provided, which were (1) lenders obtaining the borrowers' consent to obtain their tax records directly from the IRS or (2) borrowers accessing their own tax information and submitting it to the lenders.

Implementation of this rule should result in HUD putting $6.1 billion to better use.

Analysis

To fully address this recommendation, HUD will need to provide evidence that it established a method of borrower consent to verify the existence of delinquent federal taxes including, but not limited to one of the options OIG provided, which were (1) lenders obtaining the borrowers' consent to obtain their tax records directly from the IRS or (2) borrowers accessing their own tax information and submitting it to the lenders.

Implementation of this rule should result in HUD putting $6.1 billion to better use.

Designate a Senior Agency Official for Records Management at the Assistant Secretary level or its equivalent.

Update and issue agency formal records policy, including detailed procedures and requirements for completing and maintaining program office and agencywide inventories of systems, records, and PII.

Update and obtain final NARA approval of all HUD records retention schedules, including the Capstone email schedule, to comply with Federal requirements, including OMB M-19-21.

Develop and approve an enterprise strategy to meet all M-19-21 electronic transition requirements.

Issue a formal policy and requirements for managing CUI.

Establish and disseminate a policy on safeguarding or prohibiting the transportation of PII records out of the office for telework purposes.

Complete the development of performance measures and establish a formal records evaluation process to measure the effectiveness and progress of the records management program.

Standardize processes and duties for all RMLOs.

Conduct a staffing resource assessment for the HUD records program and identify any skills gaps or resource needs.

Require the Englewood Apartments’ owner to repay HUD from non-project funds the projected $377,108 in housing assistance payments for tenants who were not eligible for assistance.

Require Englewood Apartments to support that $24,295 in unsupported housing assistance payments was eligible and accurate. Englewood Apartments’ owner should repay any subsidy overpayments to HUD from non-project sources. Further, the owner should reimburse tenants for overcharged rents or enter into a repayment agreement with tenants who were undercharged due to nondisclosure of income.