Coordinate with the NSC to take all the actions necessary required by HUD Handbook 4000.1 to ensure that FHA’s interests are protected with respect to the partial claims for which FHA has not received the original promissory note and recorded mortgage.

Develop and implement procedures to review the reasonableness of the amounts included in the Missing Documents Report before recording the reclassification entry. Include steps to be followed if the amounts in the report do not appear reasonable.

Develop effective detective controls to ensure HECM loan receivables are accurate and complete, exist, and FHA appropriately holds or controls the rights to any collateral property in connection with the receivable.

Coordinate with the Deputy Assistant Secretary for Single Family Housing and HUD’s Office of the Chief Procurement Office (OCPO) in developing effective communication channels between FHA’s NSC and OFAR, and in developing effective monitoring controls to ensure the timely identification and remediation of issues, such as unprocessed documentation and inaccurate records, which may impact the balances reported within FHA’s financial statements.

Perform a thorough review of the SF 132 to SF 133 reconciliations and work with Financial Analysis and Controls Division and other divisions and groups to resolve material reconciling items timely.

Strengthen controls over the preparation of the SF 132 to the SF 133 reconciliation by preparing such reconciliations (1) first, with the unadjusted trial balance and later, with the adjusted trial balance and (2) at the fund level, with detailed documentation of differences, and with sufficient detailed explanations that describe the general ledger impact of the differences.

Implement procedures to enhance the review of all journal entries recorded in the general ledger by requiring a two-level review that includes the review of source documents for the journal entry (for example, the OMB approved SF 132).

Receive a final opinion from HUD’s Office of the Chief Financial Officer’s Appropriation Law Division on whether FHA was in violation of the Antideficiency Act.

Establish internal control procedures around the borrowings process to include verifying sufficient borrowing authority exists within the SF 132, prior to executing the borrowing request. Such verification should also be included as part of the borrowing review and approval controls.

Establish and ensure appropriate and effective communication protocols between OFAR, FHA, and HUD’s Office of Budget to ensure (1) funding type is clearly indicated within the SF 132 and clear communications are made in differentiating between definite and indefinite borrowing authority, (2) legislative changes in FHA’s borrowing authority are vetted with OMB to ensure appropriate treatment, and (3) – draft SF-133s are reviewed and vetted with HUD and FHA’s budget officers prior to OFAR’s finalization with Treasury and OMB.