Provide personnel tasked with handling Privacy Act requests with recurring training on Privacy Act exceptions

Establish documentation procedures for accounting of disclosures made under the Privacy Act, as required by 5 USC 552a(c)

Establish an annual computer matching activity reporting process to meet the requirements of OMB Circular A-108

Determine if general support system privacy threshold assessments or privacy impact assessments should be completed; if not, document the rationale

Develop the technical capability to identify, inventory, and monitor the existence of PII within the HUD environment

Develop and implement a process to inventory all agency PII holdings not less than annually.

Renew the PII minimization effort, to include a prioritization by the SAOP of specific minimization initiatives

Require all system owners to review the records retention practices for each information system and take any corrective actions necessary to ensure adherence to the applicable records retention schedule

A. Issue a clean desk policy prohibiting unattended and unsecured sensitive data in workplaces. B. Implement procedures to enforce the clean desk policy.

Put all project bank accounts in the name of the project.

Separate all owner bank accounts from the project’s bank accounts.

Develop and implement controls over the distinction between project funds and owner funds. These controls should include policies related to when the owner is allowed to take project funds owed to the owner.

Take HUD-approved training related to operating and maintaining a multifamily project.

Repay the project’s operating account from nonproject funds for the $142,805 spent on ineligible expenses.

Provide support for the $12,355 in project funds spent to pay individuals who were not on the payroll and for services provided for project operations. For any portion of this amount that is not supported, the owner should repay the project operating account using nonproject funds.

Obtain training on the eligible use of project funds.

Develop and implement detailed policies and procedures for procurement, travel, and the use of its credit cards. These controls should comply with HUD regulations regarding procurement and other disbursement documentation requirements.

Submit any outstanding audited financial statements.

Review the audited financial statements and determine the amount of outstanding mortgage payments due.

Work with the local multifamily office to make any outstanding mortgage payments or devise a plan to bring the property current through the use of available funds.