Federal Reports

We performed an audit of loan servicers’ compliance with the Federal Housing Administration’s (FHA) requirements for providing loss mitigation assistance to borrowers after their COVID-19 forbearance ended. We initiated the audit based on the large number of borrowers exiting forbearance, because the loss mitigation programs available to these borrowers were new and created a risk for both borrowers and the FHA insurance fund when servicers do not properly provide loss mitigation. Our audit objective was to determine whether servicers provided borrowers of FHA-insured loans proper loss mitigation assistance after the COVID-19 forbearance ended.Servicers did not provide proper loss mitigation assistance to approximately two-thirds of delinquent borrowers after their COVID-19 forbearance ended. Based on a statistical sample drawn from 231,362 FHA-insured forward loans totaling $41 billion, servicers did not meet HUD requirements for providing loss mitigation assistance to borrowers of 155,297 FHA-insured loans. Nearly half of the borrowers did not receive the correct loss mitigation assistance. These borrowers did not receive the loss mitigation option for which they were eligible, had their loss mitigation option not calculated properly, or received a loss mitigation option that did not reinstate arrearages, which refers to any amount needed to bring the borrower current. Approximately one-quarter of the borrowers received the correct loss mitigation option, but servicers did not follow COVID-19 loss mitigation guidance to help borrowers with payments that were missed during forbearance.

The report presents the results of our review of the Office for Civil Rights (OCR) process for resolving web accessibility complaints that were previously dismissed and subsequently reopened as directed investigations and OCR’s approach to evaluating web accessibility complaints submitted after the November 2018 revision of its Case Processing Manual. Among our findings, we determined that OCR’s resolution of web accessibility complaints previously dismissed under section 108(t) and subsequently reopened as directed investigations differed from how these reviews were resolved in the past, specifically with regard to whether or not a compliance determination was made, and that determinations made were inappropriate based on the level of testing performed. As a result of OCR’s changes to its procedures and the unclear way these changes were implemented, it could be difficult for people unfamiliar with OCR’s process to understand OCR’s procedures for processing these complaints.

We audited the Virgin Islands Housing Finance Authority’s monitoring of its Community Development Block Grant Disaster Recovery (CDBG-DR)-funded activities. We initiated the audit because of the large amount of CDBG-DR funds awarded to the U.S. Virgin Islands for the 2017 disasters and to aid in the U.S. Department of Housing and Urban Development’s (HUD) strategic objective to support effectiveness and accountability in long-term disaster recovery. Our objective was to determine whether the Authority effectively monitored its CDBG-DR-funded activities administered by itself and its subrecipients to ensure that the national objectives and performance measures were met.The Authority did not effectively monitor its CDBG-DR-funded activities. Specifically, it did not (1) assess the activities’ performance during its monitoring, (2) consistently track the status of corrective actions, (3) verify that the activities’ national objectives were or are being met, and (4) consistently monitor the activities. These deficiencies occurred because the Authority lacked policies and detailed procedures to guide its staff on effectively monitoring and tracking corrective actions and ensure performance metrics included in subrecipient agreements were assessed. Therefore, HUD could not be assured that activities were progressing, identified deficiencies were corrected, and funds were used for authorized purposes.We recommend that the Deputy Assistant Secretary for Grant Programs require the Authority to develop and implement monitoring policies and detailed procedures to ensure that an activity’s performance is assessed, corrective actions in monitoring reports are tracked, and documentation supporting the national objectives is verified. In addition, we recommend that the Authority revise subrecipient agreements to include performance metrics and milestones that are tailored to the activity.

Objective: To determine the accuracy and costs of edit routines the Social Security Administration (SSA) uses to reinstate wage items from the Earnings Suspense File (ESF).

The BIA has not actively managed the closeout process for Public Law 93–638 agreements.

We audited the Virgin Islands Housing Finance Authority’s Non-Federal Match Program for Community Development Block Grant Disaster Recovery (CDBG-DR) funds. This Match Program was developed to assist non-Federal entities in paying for their share of projects that addressed unmet needs because of the 2017 Hurricanes Irma and Maria. We initiated this audit due to the $415 million of CDBG-DR funds allocated by the Authority and to support the U.S. Department of Housing and Urban Development’s (HUD) strategic objective of promoting effectiveness and accountability in long-term disaster recovery.Our audit objective was to determine whether the Authority effectively administered its Match Program by identifying and assessing any challenges that hindered its ability to achieve program goals.We determined that the Authority’s administration of its Match Program had weaknesses. Specifically, the Authority had (1) insufficient financial controls, (2) insufficient oversight of its Match Program-funded projects, (3) inaccurate performance measures reported in its quarterly performance reports, and (4) insufficient documentation to support its national objectives. This condition occurred because the Authority did not have adequate policies and procedures or did not implement its existing policies to ensure effective administration of its Match Program. As a result, the Authority was at risk of not managing its Match Program in compliance with HUD requirements and achieving program goals. Further, this condition could result in the Authority providing program benefits to the intended beneficiaries late and increasing the risk of the Authority issuing improper payments. We recommend that the Deputy Assistant Secretary for Grant Programs require the Authority to (1) develop and implement policies and procedures to address the challenges identified and (2) conduct training for its staff and CDBG-DR Match Program recipients.