Ensure that all necessary information regarding terminated VA loans is included in the matching process.

Update applicable requirements to require assisted property owners, including PHAs, to maintain adequate documentation to support their determinations that maintenance and hazard reduction activities that disturb surfaces with lead-based paint qualify for the de minimis exemption from the lead-safe work practices under the Lead Safe Housing Rule.

Status

To address this recommendation, The Office of Lead Hazard Control and Healthy Homes (OLHCHH) agreed to:                                                                                                                      
1. Issue a notice to assisted target housing owners and public housing agencies on the de minimis exception citing the correct application of the de minimis threshold; describing appropriate documentation methods for the application of the de minimis threshold; and recommendations of best practices for documenting applications.
2. Collect additional data regarding the use of the de minimis threshold, including information on how private and public housing owners: (a) determine how much paint in target housing will be disturbed during a maintenance or rehabilitation project; (b) use the paint disturbance area information; (c) monitor the amount of paint disturbed in projects that are designed to disturb de minimis amounts of paint in target housing.
3. Design and conduct webinars, including at least one for each program office’s major categories of stakeholders on requirements and best practices pertaining to the de minimis exception under the Lead Safe Housing Rule and its implementation; record the webinars on the HUD website (e.g., on HUD Exchange) for future viewing by stakeholders; and conduct outreach promoting the webinars. 
The OLHCHH had drafted guidance on the de minimis exception to the Lead Safe Housing Rule for PIH, Multifamily Housing, and CPD and submitted it through the clearance process in September 2024.  As of January 2026, OLHCHH continues to revise the draft guidance in consideration of the comments it received during the clearance review process.  However, HUD has not provided an updated target date to complete the agreed upon actions, which was January 31, 2024.

Analysis

To implement this recommendation, HUD needs to provide evidence that it has implemented the three actions OLHCHH agreed to complete.

Implementation of this recommendation and associated corrective actions will ensure assisted property owners are sufficiently informed regarding the requirements to support their determinations that maintenance and hazard reduction activities that disturb surfaces with lead-based paint qualify for the de minimis exemption from the lead-safe work practices under the Lead Safe Housing Rule and that assisted property owners are conducting this work safely, thereby ensuring households are residing in safe and healthy HUD-assisted housing.

Provide the MOU with EPA designed to address radon contamination.

Create separate reporting lines between model development and model validation functions so that both critical model functions do not report to OER, are appropriately segregated in accordance with industry guidance, and follow the foundational component of internal control standards.

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.

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.

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.

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.

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.

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.

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.

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.

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.

Test whether a cumulative housing price appreciation (HPA) variable should be added to the probability of prepayment, probability of default, foreclosure timeline, buyout time models, and cure rate assumptions. Ginnie Mae should provide an analysis if it believes that adding an HPA variable would not be appropriate to support its position.

Develop and implement policies and procedures to require a sufficiently granular decomposition analysis that can adequately explain the impact of all the model changes made.

Develop and implement policies and procedures or enhance or clarify, as appropriate, existing policies and procedures that will require additional analyses whenever thresholds are breached or other analyses indicate potential modeling issues.

Document the economic rationale behind unintuitive model coefficients to support that the unintuitive relationships are appropriate.

Document all model assumptions that are undocumented, providing the basis for any assumptions or decisions made when developing each model assumption.

Develop and implement policies and procedures to ensure compliance with model risk management guidance regarding adequate and well-documented model assumptions.

Develop and implement controls that ensure the updating of model documentation when model changes are made.