Open Recommendations

Reconsider HUD's position on questioned borrower-financed downpayment assistance programs, including an analysis of the financial impact to FHA borrowers, risk to the FHA program, and whether current statute prohibits borrower-financed downpayment assistance programs as they are currently structured.

Develop specific requirements and guidance for lenders to review HFA downpayment assistance programs (for example, interest rates, fees, borrower certifications, lender reviews, impact to borrower, related agreements, etc.). Requirements and guidance should include evaluating the structure of downpayment assistance programs, including whether the programs' structure and funding mechanisms comply with all HUD requirements and guidelines.

Require lenders to obtain a borrower certification that details their participation in an HFA downpayment assistance program, including relevant details of the specific program (for example, impact on interest rate, mortgage payments, fees, equity, acknowledgement of other less costly loan products, etc.).

Ensure that lenders enter accurate and missing downpayment assistance gift data into FHA Connection when identified by HUD.

Implement new data fields where lenders would be required to enter specific downpayment assistance information (for example, name of the source, name of assistance program, name of government entity or HFA, etc.) to allow for auditability and for HUD to generate reports and perform risk assessments.

Review fees identified in this report that were charged as part of borrower-financed downpayment assistance programs and determine whether they are reasonable or necessary. HUD should immediately notify lenders to discontinue charging any fees that are determined to be unreasonable and unnecessary.

Require any participating lender to reimburse borrowers that received an FHA loan with borrower-financed downpayment assistance for any fees that were determined to be unreasonable and unnecessary.

Submit a plan showing how it will use the $7,984,429 in unspent escrow funds to meet program objectives and increase the supply of low- and moderate-income housing for the residents of Puerto Rico, including a schedule HUD can track to ensure the expenditure.

Submit supporting documentation so HUD can reevaluate the feasibility of the three activities and determine the eligibility of the $2,432,271 in escrow funds already disbursed. If HUD determines that an activity has been canceled or is not feasible, the Department must reimburse the escrow account from non-Federal funds.

Submit a plan showing how it will proceed regarding the Yabucoa, Juncos, and Barceloneta housing projects, including a schedule that HUD can track to ensure their completion.

Submit supporting documentation showing the reasonableness and allowability of $2,176,733 disbursed or reimburse its escrow account from non-Federal funds.

Develop and implement written policies detailing procedures and responsibilities related to program administration and monitoring of the escrow program.

Submit required certifications and supporting documentation showing that residents of escrow-funded activities met the established income limit requirements. Any amounts determined ineligible must be reimbursed to the escrow account from non-Federal funds.

Evaluate the results of its actions for the 77 beneficiaries and determine whether it should review the remaining population of 224,164 beneficiaries we identified.

The Executive Committee should direct Railroad Retirement Board management to elevate Railroad Retirement Board - Office of Inspector General auditor concerns regarding application of authoritative guidance and laws and regulations for Executive Committee determinations when Railroad Retirement Board management disagrees with Railroad Retirement Board - Office of Inspector General auditor assessments.

The Executive Committee should develop and implement Executive Committee procedures for enforcement of Railroad Retirement Board management responsibilities when Railroad Retirement Board management does not take appropriate corrective actions in regard to the application of authoritative guidance and laws and regulations.

Rec. 1.a: The DoD OIG recommended that the Deputy Assistant Secretary of the Army for Installations, Housing, and Partnerships, revise Army Regulation 420-1, "Army Facilities Management," to align the Army's definition of relocatable buildings to the definition in DoD Instruction 4165.56, "Relocatable Buildings," thus eliminating the requirement for the analysis pertaining to the disassembly, repackaging, and nonrecoverable costs of relocatable buildings.

Rec. 4.a: The DoD OIG recommended that the Chief, Directorate of Public Works at Joint Base Lewis-McChord perform the steps necessary to convert the six nonrelocatable buildings from relocatable to real property.

Chief of Management and Administration or designee develops a detailed implementation plan with remaining work to be completed, critical tasks, roles and responsibilities of key personnel, milestones for critical tasks, costs, locations, and any other necessary documentation that would allow the agency to successfully implement HSPD-12.

Chief of Management and Administration or designee uses existing budgetary resources to fully implement HSPD-12. 

Chief of Management and Administration or designee establishes a reasonable date to fully implement HSPD-12.

Rec. 1.a: The DoD OIG recommended that the Commander of U.S. Army Medical Command review the 21,742 medical service accounts that military treatment facility Uniform Business Offices determined were uncollectible to ensure all collection efforts have been exhausted and to obtain approval from the proper authority to terminate the accounts that are uncollectible.