Develop a standard operating procedure for the monthly transaction review that aligns with the HUD policy and includes specific procedures on how to (1) identify and review common transactions that raise the level of risk in the program (for example, personal use purchases, other prohibited purchases, unauthorized purchases or services, split purchases, fraudulent purchases, FAR violation purchases, etc.), (2) methodically select transactions for investigation, and (3) follow up on identified potential improper transactions, including record-keeping requirements.

Develop and implement adequate procedures and controls to ensure that (1) staff issues notices of violation and default within 15 calendar days of the inspection report release date and (2) the Office of Multifamily Asset Management and Portfolio Oversight is made aware when notices are not issued within 15 calendar days after the inspection report release date and takes action as appropriate to ensure that future notices are issued in a timely manner.

Status

HUD has implemented a process of sending notifications to the field offices' centralized inboxes when a failed inspection has been released with instructions to issue a Notice of Default or Notice of Violation within 15 days. The field office logs this task into the Asset Management Processing System (AMPS) and assigns it to an Account Executive. Field office management tracks the progress of the task in AMPS. HUD is building a reporting tool to see if the task has been properly entered into iREMS and addresses the field office instances where it has not. The construction of this tool has been delayed due to limited staff resources. As of January 2025, the reporting tool was undergoing review and testing prior to implementation. The final action target date was November 29, 2024.

Analysis

Implementing procedures and controls for the timely issuing of notices would ensure that property owners are held accountable for correcting life-threatening deficiencies in a timely manner thus reducing the risk of families living in units that are unsafe for longer periods.

The implementation of this recommendation has the potential to directly impact the health and safety of families.

Include language in future notices of violation and default clearly stating that owners are required to inspect all units (including vacant units), common areas, grounds, building systems, and sites as part of the owner survey and require owners to include sufficient detail in the surveys to show (1) when the survey was conducted and (2) that the survey was a complete survey of the project.

Status

HUD will update the Notice of Default and Notice of Violation in conjunction with updates related to NSPIRE. These updates have been delayed by limited staff resources and pending policy clarifications and system changes for NSPIRE.

The final action target was November 29, 2024.

Analysis

The inclusion of language in the notices would ensure that property owners are aware of their responsibilities to inspect all units, common areas, grounds, building systems, and sites and perform repairs of identified deficiencies to protect families from living in units that are not decent, safe, and sanitary.

The implementation of this recommendation has the potential to directly impact the health and safety of families.

Develop and implement adequate controls to ensure that HUD staff with the appropriate level of authority approves extensions to the notices of violation and default cure periods in writing and that documentation is maintained to support such approvals.

Modify the queries used to generate the schedules of properties that accompany the reports to Congress to consider a larger range of dates to ensure that properties that failed consecutive inspections are appropriately identified on all applicable schedules.

Assess and streamline the processes for preparing, reviewing, and approving the reports as appropriate to ensure that the reports are submitted to Congress on or before the required due date.

We recommend that HUD’s Deputy Assistant Secretary for Single Family Housing update policies and procedures regarding discrimination complaints to ensure consistency among customer service representatives in rerouting these complaints to FHEO.

We recommend that HUD’s Deputy Assistant Secretary for Single Family Housing ensure that the FHA Resource Center updates its training program to ensure that refresher training on housing discrimination is regularly provided to staff (such as monthly, quarterly, semiannually, etc.).

Develop a plan and a timeline that ensures all due and payable partial claims are transferred to the FOC, and subsequently processed by the FOC.

Develop and implement procedures to i) monitor the transfer of due and payable partial claims from NSC to the FOC for collection, ii) determine the financial statement impact of not referring due and payable partial claims to the FOC, and iii) decide when FHA will record a reclassification entry to accounts receivable for those due and payable partial claims that are not transferred to the FOC timely.

Consider accounting implications to the gross HECM loans receivable balance for the $20 million lost in security interests.

Record an adjusting entry to remove the duplicate $44 million from the gross HECM loans receivable balance as of September 30, 2023.

Identify and remove all duplicate transactions from the accounting module and prevent future occurrences.

Develop and enhance training for servicing the HECM portfolio.

Develop corrective procedures to bring the HECM portfolio servicing current, initiate collection proceedings for due and payable loans, redeem the tax certificates for properties for which FHA lost its security interest, and implement a solution to monitor tax payments to prevent tax delinquencies and avoid FHA’s risk of loss in loan security interest.

Review the loans in our sample that did not receive appropriate loss mitigation options to ensure that the borrowers were remedied by the servicers, when possible, and take administrative actions if appropriate.

Engage with the servicers in our sample to determine reasons for noncompliance and develop a plan to mitigate it going forward.

Provide additional guidance and training to servicers to address common loss mitigation issues found during this audit.

Update HUD’s FHA FAQs to clarify current loss mitigation requirements and ensure that outdated guidance is removed.

Update the Save Your Home - Tips to Avoid Foreclosure brochure to include new loss mitigation options as they are introduced and require servicers to send this additional information to delinquent homeowners. This could be done as a redesign of the existing brochure or as addendums to the brochure for temporary programs.