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.

Require the 12 grantees to correct their action plans to ensure that they comply with program requirements and submit the corrected plans to HUD for review or require the grantees to repay HUD from non-Federal funds for any amount of the $7,779,450 they received that they cannot support.

Require the Housing Authority of Brevard County to repay $1,520 in ineligible escrow funds to HUD from non-Federal funds for the program participant that exceeded allowable contract terms of the FSS program.

Monitor the grantees’ efforts to improve the accuracy and completeness of the PIC program data to ensure that program outcomes reported to Congress are accurately supported.

Develop and implement a plan to monitor grantee FSS programs, including to ensure that escrow accounts are calculated correctly.

Develop and implement policies and procedures to ensure that documentation is maintained by grantees to support program participants’ contractual agreements.

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.