HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 1

SEMIANNUAL REPORT 

TO CONGRESS

OFFICE OF INSPECTOR GENERAL

U.S. Department of Housing and Urban Development

For the period October 1, 2021, to March 31, 2022
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TABLE of

CONTENTS

PROFILE OF PERFORMANCE...................................................................................3

A MESSAGE FROM THE INSPECTOR GENERAL...........................................4

SNAPSHOT............................................................................................................................6

HOUSING.............................................................................................................................10

PUBLIC AND INDIAN HOUSING...........................................................................15

COMMUNITY PLANNING AND DEVELOPMENT.......................................19

ADDITIONAL REPORTS............................................................................................23

LEGISLATION, REGULATIONS, AND OTHER DIRECTIVES................27

REPORT RESOLUTION...............................................................................................36

WHISTLEBLOWER PROTECTION COORDINATOR.................................47

PEER REVIEW..................................................................................................................49

APPENDIXES ....................................................................................................................51

Appendix 1 - Reports Issued.............................................................................52

Appendix 2 - Tables................................................................................................57

Appendix 3 - Inspector General Empowerment Act...........................80

Appendix 4 - Reporting Requirements.......................................................86

Appendix 5 - Acronyms and Abbreviations .............................................88

Appendix 6 - OIG Directory ...............................................................................90
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AUDIT RESULTS

Recommendations that funds be put to better use $6,944,124,017

Recommended questioned costs $6,425,094

Collections from audits $6,835,239

Administrative sanctions 1

Civil actions 0

Subpoenas 1

Personnel actions 0

INVESTIGATIVE RESULTS

Total restitutions and judgments $20,815,837

Total recoveries and receivables to HUD programs $3,116,978

Arrests 35

Indictments and informations 51

Convictions, pleas, and pretrial diversions 49

Civil actions 14

Total administrative sanctions 23

Suspensions 7

Debarments 5

Program or professional license-certification 1

Evictions 1

Other1 9

Systemic implication reports 0

Search warrants 13

Subpoenas 355

PROFILE of

PERFORMANCE

For the period October 1, 2021, to 

March 31, 2022

1 Includes employee actions (reprimands, suspensions, 

demotions, or terminations of the employees of Federal, State 

or local governments or of Federal contractors and grantees as 

the result of OIG activities) and limited denial of participation 
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A MESSAGE FROM THE 

INSPECTOR GENERAL

I am pleased to submit the U.S. Department of Housing and Urban Development (HUD), Office of Inspector General’s (OIG) 

Semiannual Report to Congress, which covers the period October 1, 2021, through March 31, 2022. As we transition back into 

the workplace, I am proud of the resilience, dedication, flexibility, and commitment my office continues to demonstrate to meet 

the challenges presented by the COVID-19 pandemic. We take seriously our responsibility to HUD, Congress, and the public to 

conduct influential oversight that is both timely and relevant. 

under my leadership as Inspector General, which provides a roadmap for 

how we intend to build on progress and continue to evolve over the next 

4 years. Our goals and objectives are deliberately structured to assist us in 

accomplishing our oversight mission, to safeguard HUD’s programs from 

fraud, waste, abuse, and mismanagement and identify opportunities for 

HUD programs to progress and succeed. This is not a static plan—we will 

monitor and evaluate its progress and adjust when necessary to address 

emerging trends related to HUD programs and operations. I am excited to 

work with my team to execute the strategies and goals we set forth in this 

strategic plan. 

Additionally, we issued our FY 22 Top Management Challenges Report, 

summarizing our analyses of the most serious management and 

performance challenges facing the Department. To identify the top 

management challenges, we considered several factors, including issues 

and open recommendations identified by our previous oversight work, 

reports published by other OIGs and the Government Accountability 

Office, and feedback from our HUD colleagues regarding their perceptions 

about the top challenges they face. Beyond the longstanding challenges 

that remain, such as eliminating hazards in HUD assisted housing, we 

added grants management, fraud risk management, and mitigating 

As discussed in greater detail throughout this report, our audits, evaluations, 

and investigations have promoted the integrity and efficiency of HUD’s 

critical programs and protected the investment of taxpayer dollars. During 

this reporting period, our audit and evaluation work resulted in the 

publication of 24 reports identifying over $6.9 billion in funds put to better 

use, over $6.4 million in questioned costs, and $6.8 million in collections. 

In addition, during this reporting period our investigations, some of which 

are joint investigations with other law enforcement agencies, have resulted 

in 49 convictions, 14 civil actions, and over $20 million in criminal, civil and 

administrative recoveries, which includes over $3 million to HUD programs. 

We also issued the FY 2021 Federal Information Security Modernization 

Act (FISMA) Evaluation, as mandated, and determined that HUD’s overall 

information security program maintained its maturity of “consistently 

implemented” for a second year. Additionally, we determined that HUD’s 

Office of the Chief Information Officer had addressed previous HUD OIG 

FISMA recommendations and implemented key initiatives that contributed 

to sustaining the maturity level. We also made additional recommendations 

to assist HUD in making further progress.

To reflect my vision for our oversight work and priorities, in February 2022, 

we published the HUD OIG 2022-2026 Strategic Plan, the first such plan 
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Our office partnered with our PRAC colleagues to develop a Fraud Risk 

Inventory for the CDBG and ESG CARES Act Funds, which identified 

five overall risk factors that contribute to the risk of fraud for the CDBG 

and ESG CARES Act funds to assist HUD with its fraud risk management 

practices in the administration of its programs. 

With respect to our work with Congressional stakeholders, on January 

19, 2022, HUD OIG’s Deputy Inspector General testified before the 

House Committee on Financial Services, Subcommittee on Oversight and 

Investigations about our critical work related to HUD’s disaster recovery 

and mitigation program. Our testimony focused on the most significant 

challenges HUD faces in administering disaster assistance, our recent 

disaster recovery oversight work, and provided context for the broader 

challenges HUD faces when addressing equity-related issues. 

Finally, I am pleased to announce our partnership with the Secretary and 

our HUD colleagues, detailed in our joint statement of cooperation issued 

earlier this year. I commend the Secretary and HUD’s senior leadership 

team for their commitment to work collaboratively to strengthen the 

accountability of HUD’s programs and sustain the ethical conduct and 

integrity of all HUD employees, contractors, grantees, and recipients. 

In closing, I want to thank our HUD OIG staff for their exceptional work in 

fulfilling our critical oversight mission. Their perseverance and flexibility 

throughout the pandemic are a testament to their commitment to 

public service. I am honored to work alongside this dedicated group of 

professionals. 

counterparty risk in mortgage programs, highlighting how each challenge 

aligns with the strategic goals in HUD’s 2018-2022 Strategic Plan. Further, 

we intentionally noted HUD’s progress regarding each challenge and 

identified areas where more work can be done. We also recognized 

challenges posed by the pandemic, and shared references to our oversight 

work and other related resources. 

These two critical work products have been instrumental in shaping our 

cross-cutting oversight work moving forward. For example, we are pursuing 

audits, evaluations, and investigations to help strengthen HUD’s controls and 

protect its beneficiaries from lead-based hazards in HUD assisted housing, 

to include an evaluation focusing on HUD’s oversight of lead-based paint 

remediation in public housing and its processes for addressing cases of 

children residing in public housing with elevated blood levels.

To effectively help HUD achieve its mission, we continue to garner our 

efforts towards protecting HUD programs and beneficiaries from bad 

actors. Towards that end, we’ve had two successful prosecutions related 

to a Fraud Scheme involving HUD Funds Intended for lead remediation and 

Failure to Properly Notify Tenants About Lead Hazards during the reporting 

period. Further, a joint investigation with the Department of Justice’s 

(DOJ) Civil Rights Division, resulted in DOJ’s largest civil settlement in a 

case alleging sexual harassment in housing. A Section 8 Housing Choice 

Voucher landlord in New Jersey agreed to pay $4.5 million to resolve a 

Fair Housing Act lawsuit concerning his sexual harassment of tenants and 

housing applicants spanning 15 years. 

As a member of the Pandemic Response Accountability Committee 

(PRAC), I understand the significant role our oversight community shares 

in helping to ensure that the $12.4 billion of taxpayer funds appropriated 

to HUD under the Coronavirus Aid, Relief, and Economic Stability (CARES) 

Act funding are spent responsibly and in the manner Congress intended. Inspector General

Rae Oliver Davis
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(1) monthly CDBG-DR grant financial report, (2) use of Disaster Recovery 

Grant Reporting system flags, (3) use of grantee expenditure projections, 

(4) documentation of quality performance report reviews, and (5) 

documentation for monitoring reviews. OIG made nine recommendations 

for CPD to identify, define, and track slow spenders; update policies 

and procedures to address variances between actual and projected 

expenditures; and resolve the red flags identified in the report.

(Agencywide, Audit Report: 2022-AT-0001)

City of Houston, TX, Faced Challenges in Administering Its 

Hurricane Harvey Program and Risked Losing Its Funding

This audit assessed the efficiency and effectiveness of the City of 

Houston’s Hurricane Harvey CDBG-DR program. The audit found that 

3 years after Hurricane Harvey, the City had spent only $22.8 million 

(1.8 percent) of its $1.275 billion suballocated grant funds, which 

substantially delayed assistance to participants and assisted only 297 

of 8,784 participants (3.4 percent) in housing programs. OIG made five 

recommendations to monitor the City’s pace and performance and set 

milestones and appropriate consequences for the Texas General Land 

Office to ensure that expenditure deadlines remain on track.

(Houston, TX, Audit Report: 2022-FW-1001)

Opportunities Exist To Improve CPD’s Oversight of and 

Monitoring Tools for Slow-Spending Grantees 

This audit assessed the HUD, Office of Community Planning and 

Development’s (CPD) monitoring and oversight tools related to the 

progress of grant expenditures and determined the status of grants and 

impacts of coronavirus disease 2019 grantee spending. OIG found that 

although CPD has tools available for the oversight and monitoring of 

its grantees, there are opportunities for it to improve its oversight and 

monitoring, specifically for slow-spending Community Development 

Block Grant Disaster Recovery (CDBG-DR) grantees. CPD can enhance its 

SNAPSHOT

SpotlightThe U.S. Department of Housing and Urban Development, Office of 

Inspector General’s (HUD OIG) fiscal year 2022 performance to date 

has helped HUD, Congress, and other stakeholders, including HUD 

communities nationwide. Each year, in compliance with the Reports 

Consolidation Act of 2000, HUD OIG issues a report summarizing what it 

considers to be the most serious management challenges for HUD. This 

year’s report includes the top 10 challenges facing HUD, organized to 

align with HUD’s strategic goals. This work supports HUD in achieving 

its mission to create strong, sustainable, inclusive communities and 

quality, affordable homes for all. Also, during this reporting cycle, HUD 

OIG published its 2022-2026 Strategic Plan, which provides a roadmap 

for HUD OIG to build on progress from previous years and continue to 

evolve over the next 4 years. It establishes clear goals and deliberate 

strategies for accomplishing each goal. This section highlights HUD 

OIG’s reports and performance since October 1, 2021.

The audit found that 3 years after Hurricane Harvey, the 

City spent only $22.8 million (1.8 percent) of its $1.275 

billion suballocated grant funds, which substantially 

delayed assistance to participants and assisted only 297 

of 8,784 participants (3.4 percent) in housing programs. 
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Fraud Risk Inventory for the CDBG and ESG CARES Act Funds 

This engagement was conducted in coordination with the Pandemic 

Response Accountability Committee to gain an understanding of HUD’s 

fraud risk management practices and develop an inventory of fraud risks 

that HUD had not already identified for the funds appropriated by the 

Coronavirus Aid, Relief, and Economic Security (CARES) Act for its CDBG 

and Emergency Solutions Grant (ESG) programs. OIG identified five 

overall risk factors that contribute to the risk of fraud for the CDBG and 

ESG CARES Act funds and used the results of its brainstorming sessions, 

interviews, reviews of audits reports, investigations, and press releases to 

develop a fraud risk map containing 31 fraud schemes that can be used 

to misappropriate CDBG and ESG CARES Act funds. OIG also identified 

opportunities to improve HUD’s fraud risk management practices. 

OIG made six recommendations addressing roles and responsibilities, 

completing program-specific fraud risk assessments and risk profiles, 

implementing efforts to increase awareness of fraud at all levels, 

implementing a fraud risk checklist as part of CPD’s monitoring efforts, 

and developing and implementing a fraud analytics strategy to identify 

potential fraud risks for further review.

(Agencywide, Memorandum: 2022-FO-0801)

HUD’s Process for Managing IT Acquisitions

This evaluation was conducted to review HUD’s ability to effectively 

complete information technology (IT) acquisitions. HUD’s IT systems 

and its modernization plans depend heavily on contractors, yet HUD 

has historically faced significant challenges with implementing effective 

acquisition processes. HUD’s acquisition capacity represents a key 

potential risk within HUD’s IT environment. OIG found that HUD had 

a lack of staffing capacity, ineffective coordination and communication 

practices, and ineffective oversight of management controls over 

acquisition processing. HUD officials acknowledged that IT acquisition 

process improvements are needed and have taken steps to address these 

deficiencies. This evaluation report contains five recommendations to 

assist in continued successes for future acquisition efforts.

(Agencywide, Evaluation Report: 2020-OE-0004)

HUD officials acknowledged that IT acquisition process 

improvements are needed and have taken steps to 

address these deficiencies. 
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construction company, DR Horton. Hill assisted borrowers in submitting 

fraudulent information to lenders, who closed 108 Federal Housing 

Administration-insured loans. HUD’s loss, due to the loan modifications 

and subsequent claims, is approximately $1.2 million. HUD indemnified 

a number of loans because of lender self-reporting and HUD Quality 

Assurance Division audits. 

On December 14, 2021, the U.S. Department of Justice (DOJ) announced 

that a settlement has been reached, through a consent decree, between 

DOJ’s Civil Rights Fair Housing Unit and Joseph Centanni, a high-volume 

Section 8 Housing Choice Voucher Program landlord in Elizabeth, NJ. 

Centanni has agreed to pay $4.5 million in monetary damages and 

civil penalties to resolve the Fair Housing Act lawsuit alleging that he 

sexually harassed tenants and applicants spanning a 15-year period. This 

settlement is the largest monetary settlement DOJ has obtained in a case 

alleging sexual harassment in housing. The terms of the consent decree 

reflect that Centanni has sold all of his residential rental properties and will 

be permanently prohibited from owning or managing residential rental 

properties in the future.

Significant Investigation Cases 

On February 24, 2022, the Boys and Girls Club of Santa Fe (BGCSF) finalized 

a civil settlement agreement with the United States and agreed to pay 

approximately $1.4 million to HUD. BGCSF obtained nearly $751,000 in 

special purpose grants from HUD’s CDBG program to purchase land and 

build a new facility. BGCSF signed grant closeout agreements indicating 

that it followed the grant’s terms; however, it never built the facility and 

sold or rented portions of the property. 

On January 10, 2022, former real estate agent Eric Hill was sentenced 

in U.S District Court for the Northern District of Georgia pursuant to his 

earlier guilty plea to conspiracy to defraud the United States in a mortgage 

fraud scheme. He was sentenced to 30 months incarceration and 36 

months supervised release and ordered to pay more than $1.69 million, 

of which $1.2 million is to go to HUD and the remaining $483,419 to the 

HUD OIG oversight work results in recommendations to encourage 

improvements in the conduct of Government programs and 

operations. This section highlights the connections between 

OIG’s work and its positive impact on HUD’s programs, operations, 

mission, and beneficiaries. While there are many factors that may 

cause programmatic change, OIG’s reviews and other work often 

play a role. This section draws attention to recommendations 

closed during this semiannual reporting period that have made a 

positive impact on HUD’s mission and operations.

Making an

 Impact

Centanni has agreed to pay $4.5 million in monetary 

damages and civil penalties to resolve the Fair Housing 

Act lawsuit alleging he sexually harassed tenants and 

applicants spanning a 15-year period. This settlement 

is the largest monetary settlement DOJ has obtained in a 

case alleging sexual harassment in housing.
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In October 2021, Kenneth Johnson, a former Cleveland city councilman, 

was sentenced to 6 years in prison after a trial conviction of Federal 

program theft, tax violations, witness tampering, and falsifying records. 

In addition, his executive assistant, Garnell Jamison, was sentenced 

to 5 years in prison after trial convictions of the same offenses, and, 

together, they were ordered to pay $746,839 to the Internal Revenue 

Service (IRS) and HUD. The defendants conspired to induce the City of 

Cleveland to issue reimbursement checks to the councilman totaling 

$127,000 for services that were never performed; diverted $50,000 

from Federal community development funds distributed by the City; 

submitted false and fraudulent tax returns to the IRS; attempted 

to persuade and influence the testimony of a grand jury witness 

by providing that person with false and fraudulent information and 

records purporting to document charitable donations; and falsifying a 

donation receipt with the intent to impede, obstruct, and influence an 

investigation.

Collaborative Work

On January 20, 2022, an OIG special agent, along with the Chief of 

the Civil Rights Division and assistant United States attorneys (AUSA) 

with the U.S. Attorney’s Office, District of New Jersey, provided a 

nationwide 90-minute training session to more than 80 housing and civil 

enforcement trial attorneys and AUSAs, which focused on prosecutions 

connected to DOJ’s Sexual Harassment in Housing Initiative. The training 

centered on the sexual harassment investigation conducted on the 

Housing Choice Voucher Program landlord, Joseph Centanni.

Disaster Grantee Fraud Training

From October 12 to 14, 2021, OIG’s Office of Audit held the October 

Disaster Grantee Fraud Training for the California Department of Housing 

and Community and Development. 

From November 16 to 18, 2021, OIG’s Office of Audit held the November 

Disaster Grantee Fraud Training for the States of Georgia, North Carolina, 

and South Carolina. 

Fraud Bulletins

On March 10, 2022, HUD OIG joined the OIG community to participate 

in the National Slam the Scam Campaign to raise public awareness of 

pervasive scams related to HUD housing programs. The initiative, hosted 

by the Social Security Administration OIG, began in 2020 to combat 

Social Security-related scams and was recently expanded to include 

other Government imposter scams. As part of this initiative, HUD OIG 

published four OIG fraud bulletins, which generated significant interest 

from the media, resulting in two news articles. HUD OIG also extended 

its outreach to stakeholders on social media.
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The Office of Housing plays a vital role for the Nation’s home buyers, homeowners, renters, and 

communities through its nationally administered programs. It includes the Offices of Single Family 

Housing and Multifamily Housing Programs and the Federal Housing Administration (FHA), the 

largest mortgage insurer in the world. FHA single-family programs provide mortgage insurance 

to mortgage lenders that, in turn, provide financing that enables individuals and families to 

purchase, rehabilitate, or construct homes. The Office of Multifamily Housing Programs’ mortgage 

insurance programs facilitate the construction, substantial rehabilitation, purchase, and refinancing 

of multifamily properties. The office also administers subsidized housing programs that provide 

rental assistance to low-income families, the elderly, and those with disabilities, as well as the 

preservation of assisted affordable housing.

HOUSING

AUDIT INVESTIGATION

administrativecivil actionskey program 

results

convictions-pleaspretrial diversionsrecommended funds 

put to better use

recommended financial recoveries

questioned costs

$0

5 8

$6,937,978,632 11

$9,287,805
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HUD Did Not Always Implement Corrective Actions To Further 

Ensure That HECM Borrowers Complied With Principal Residency 

Requirements

OIG completed a corrective action verification (CAV) of recommendations 

from four prior home equity conversion mortgage (HECM) audit 

reports. The CAV was initiated because one of HUD’s top management 

challenges is to protect the FHA mutual mortgage insurance fund. The 

prior audits determined that HUD lacked controls to prevent HECM 

borrowers from violating principal residency requirements. The CAV 

objectives were to determine whether HUD implemented adequate 

corrective actions in response to (1) recommendation 1B from audit 

report 2012-PH-0004, (2) recommendation 1B from audit report 2013-

PH-0002, (3) recommendation 1B from audit report 2014-PH-0001, and 

(4) recommendation 1C from audit report 2015-PH-0004. OIG found 

that HUD implemented the agreed-upon corrective action for one 

recommendation, did not implement the ongoing corrective action for 

one recommendation, and did not implement corrective actions for two 

recommendations. 

(Agencywide, Memorandum: 2022-PH-0801)

Office of Audit

FHA Borrowers Did Not Always Properly Receive COVID-19 

Forbearances From Their Loan Servicers

The U.S. Department of Housing and Urban Development (HUD), 

Office of Inspector General (OIG), completed an audit to determine 

whether FHA-insured borrowers properly received the coronavirus 

disease 2019 (COVID-19)-related forbearance. The Coronavirus Aid, 

Relief, and Economic Security (CARES) Act, signed into law on March 

27, 2020, provided a mortgage payment forbearance option for all 

borrowers who suffered financial hardship due to the COVID-19 national 

emergency. OIG found that in November 2020, at least one-third of the 

nearly 335,000 borrowers who were delinquent on their FHA-insured 

loans and not on forbearance were either not informed or misinformed 

about the COVID-19 forbearance. As a result, borrowers experiencing 

a hardship due to COVID-19 did not benefit from the COVID-19 

forbearance. OIG also found that servicers improperly administered 

the forbearance for at least one-sixth of the nearly 815,000 borrowers 

on forbearance plans in November 2020. OIG recommended that FHA 

identify borrowers who were both delinquent and did not fully benefit 

from the COVID-19 forbearance and ensure that information about the 

CARES Act and COVID-19 forbearance is distributed to these borrowers. 

OIG also recommended that FHA ensure that the issues found during 

the audit are incorporated into servicing monitoring reviews to deter 

future noncompliance and prevent potential loss to the FHA fund and 

provide additional guidance to the servicers so that they limit their 

communication and collection efforts for the borrowers in forbearance. 

(Agencywide, Audit Report: 2022-KC-0001)
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OIG recommended that HUD develop and implement written policies 

and procedures and controls (1) for locating homeowners, (2) for the 

refund process to address the deficiencies identified, and (3) to reduce 

the number of refunds that have remained unclaimed for an extended 

period. 

(Agencywide, Audit Report: 2022-LA-0001)

Approximately 31,500 FHA-Insured Loans Did Not Maintain the 

Required Flood Insurance Coverage in 2020 

OIG audited the FHA-insured loans serviced in calendar year 2020 to 

determine whether borrowers of FHA-insured loans maintained proper 

flood insurance coverage. OIG found that FHA insured at least 31,500 

loans serviced during calendar year 2020 for properties in special 

flood hazard area flood zones that did not maintain the required flood 

insurance coverage. As a result, the FHA insurance fund was potentially 

exposed to greater risk from more than $4.5 billion in loans that did not 

maintain adequate National Flood Insurance Program coverage. OIG 

recommended that FHA require lenders to provide evidence of sufficient 

flood insurance coverage or execute indemnification agreements for 

the 21 loans in the statistical sample that did not have sufficient flood 

insurance at the time of the audit, develop a control to detect loans that 

did not maintain the required flood insurance to avoid potential future 

costs to the FHA insurance fund from inadequately insured properties, 

and consult with HUD’s Office of General Counsel to review the language 

in the statutes, regulations, and handbooks and make any necessary 

adjustments to the forward mortgage and HECM handbooks. 

(Agencywide, Audit Report: 2022-KC-0002)

Audit of FHA’s Fiscal Years 2021 and 2020 Consolidated Financial 

Statements

OIG contracted with the independent public accounting firm of 

CliftonLarsonAllen LLP (CLA) to audit the financial statements of FHA as 

of and for the fiscal years ending September 30, 2021 and 2020, and to 

provide reports on FHA’s (1) internal control over financial reporting and 

(2) compliance with laws, regulations, contracts, and grant agreements 

in its financial reporting. In its audit of FHA, CLA reported that the 

consolidated financial statements under review were presented fairly, 

in all material respects, and in accordance with U.S. generally accepted 

accounting principles. CLA found one material weakness in FHA’s controls 

over financial accounting and reporting and a significant deficiency in 

the FHA econometric modeling activities used to estimate the agency’s 

loan guarantee liability. For fiscal year 2021, CLA found no reportable 

noncompliance issues with provisions of applicable laws, regulations, 

contracts, and grant agreements tested and no other matters. 

(Agencywide, Audit Report: 2022-FO-0003)

HUD Did Not Have Adequate Controls in Place To Track, Monitor, 

and Issue FHA Refunds Owed to Homeowners

OIG audited HUD’s oversight of FHA refunds based on a hotline 

complaint alleging that HUD was trying to make it difficult for claimants 

to obtain refunds or would discourage them from pursuing the refunds, 

which are due to eligible homeowners from the unearned portion of 

the upfront mortgage insurance premium paid. The audit found that 

HUD did not have adequate controls in place to ensure that refunds 

were appropriately tracked, monitored, and issued. As a result, HUD 

could not ensure that it implemented a consistent refund process, and 

homeowners and third-party tracers were not able to search for all 

refunds HUD owed, which may have reduced the chance for homeowners 

of at least 23,579 loans to obtain approximately $15.8 million in refunds. 
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Office of Investigation

Real Estate Professionals Sentenced to 48 Months Incarceration

William Elias, former real estate broker and owner of Elias Realty 

LLC, and Kimberly Doren, former real estate salesperson and branch 

manager for Gold Star Mortgage Financial, were collectively sentenced 

in U.S. District Court to 48 months and 1 day incarceration and 6 years 

supervised release. For more than 2 years, Elias and Doren orchestrated 

a short sale scheme by fraudulently misrepresenting borrowers’ primary 

residences as rental properties and inflating the market value of the 

primary residences on the borrowers’ loan applications to obtain FHAinsured or conventional loans for the purchase of new homes. Elias 

and Doren then falsely submitted short sale requests for the borrowers’ 

primary residences, based on purported financial hardships. Elias and 

Doren improperly collected profits, commissions, fees, and kickbacks 

as part of this scheme. Doren was sentenced in connection with her 

earlier guilty plea to bank fraud and was ordered to pay jointly and 

severally with Elias $253,013 in restitution to the Federal Home Loan 

Mortgage Corporation (Freddie Mac) and various financial institutions. 

Elias was sentenced in connection with his earlier guilty plea to bank 

fraud and money laundering and was ordered to pay an additional $4.87 

million in restitution to Freddie Mac and the Federal National Mortgage 

Association. HUD OIG and the Federal Housing Finance Agency (FHFA) 

OIG conducted this investigation. 

(Detroit, MI)

Challenges Faced by Section 232 Nursing Homes During the 

Pandemic

OIG conducted a limited review of nursing home owners to identify 

their operational challenges and needs of nursing homes responding to 

the COVID-19 pandemic. OIG’s objective was to determine the biggest 

challenges operators of Section 232 nursing home facilities face related 

to the COVID-19 pandemic and whether nursing homes are prepared 

to meet their future financial obligations. Most of the owners who 

responded to the survey indicated that nursing homes experienced 

financial and operational challenges during the pandemic. These 

challenges included staffing shortages; COVID-19 infections in residents 

and staff; large fluctuations in occupancy levels; rising operating costs; 

and difficulties in responding to local, State, and Federal requirements. 

(Agencywide, Audit Memorandum: 2022-KC-0801)
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guilty plea to aggravated identity theft and conspiracy to commit wire 

fraud, and Mulvihill was sentenced in connection with her earlier guilty 

plea to conspiracy to commit wire fraud. HUD OIG, Federal Bureau of 

Investigation, Internal Revenue Service Criminal Investigation, and FHFA 

OIG conducted this investigation. 

(North Andover, MA)

Nine Swindlers Collectively Sentenced to 16 Years Incarceration

Eduardo Toro, a real estate agent and business owner; Ana Toro, Veronica 

Toro, and Maria Gil, paralegals; Emmanuel Lopez and Gladys Velasquez, 

employees of Toro; Filiverto Gomez and Veronica Marquez, notaries; and 

Leticia Mora, a credit repair specialist, were collectively sentenced in 

Superior Court of California to 16 years incarceration, 10 years probation, 

and 11 years supervised release and ordered to pay $606,815, of which 

$598,335 was ordered jointly and severally, in restitution to various 

victims. For more than 7 years, the conspirators participated in an 

advance fee mortgage relief scheme, which resulted in foreclosure delays 

of more than 200 properties, impacting 15 FHA-insured mortgages. 

The conspirators submitted false deeds and petitions in support of 

bankruptcies filed with the courts to delay the foreclosures. HUD OIG 

and FHFA OIG conducted this investigation. 

(Los Angeles, CA)

Mortgage Industry Professionals Sentenced in Short Sale Scheme

Gabriel Tavarez and Jaime Mulvihill, the founders and operators of 

Loss Mitigation Services (LMS), LLC, a mortgage short sale assistance 

company, were collectively sentenced in U.S. District court to 13 months 

incarceration and 4 years supervised release and ordered to pay $475,458 

in restitutions. For nearly 3 years, Tavarez and Mulvihill defrauded 

mortgage lenders and investors out of less than $500,000 in proceeds from 

approximately 90 short sale transactions of conventional and FHA-insured 

mortgages when they, directly or through their employees, falsely claimed 

to homeowners, real estate agents, and closing attorneys that mortgage 

lenders had agreed to pay LMS fees known as “seller paid closing costs” 

or “seller concessions” from the proceeds of the short sales. Tavarez 

and Mulvihill fabricated the transaction documents or caused them to 

be fabricated to justify the additional fees and conceal that they were 

being paid to LMS. Tavarez was sentenced in connection with his earlier 
Public and Indian Housing | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 15

The U.S. Department of Housing and Urban Development (HUD) provides grants and subsidies 

to more than 3,100 public housing agencies (PHA) nationwide. Many PHAs administer both 

public housing and Section 8 programs. HUD also provides direct assistance to PHAs’ resident 

organizations to encourage increased resident management entities and resident skills programs. 

Programs administered by PHAs are designed to enable low-income families, the elderly, and 

persons with disabilities to obtain and reside in housing that is safe, decent, sanitary, and in good 

repair. Some of the highlights from this semiannual period are noted in this chapter.

PUBLIC AND INDIAN 

HOUSING

AUDIT INVESTIGATION

administrativecivil actions

convictions-pleaspretrial diversions

financial recoveries

23

24

$6,754,173

key program 

results

recommended funds 

put to better use

recommended 

questioned costs

$2,870,374

5

$2,514,470
Public and Indian Housing | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 16

field offices to help administer their HUD VASH programs. In addition, 

the respondents believed that the local HUD and U.S. Department of 

Veterans Affairs field offices had excellent or good working relationships. 

Respondents expressed that the HUD requirements, including waivers and 

alternative requirements, were helpful in meeting their program goals and 

objectives. However, OIG found that respondents were not able to use 

all of their allocated program vouchers, with one of the reasons being the 

high cost of housing. 

(Agencywide, Audit Report: 2022-LA-0801)

The Buffalo Municipal Housing Authority, Buffalo, NY, Needs 

To Improve Its Management of the Commodore Perry Homes 

Development To Address Longstanding Concerns

OIG audited the Buffalo Municipal Housing Authority’s management 

of its Commodore Perry Homes development based on congressional 

interest. The objective of the audit was to determine whether the 

Authority properly managed its Commodore Perry Homes development. 

OIG found that the Authority did not properly manage the Commodore 

Perry Homes development to address longstanding redevelopment needs 

and health and safety issues. While the Authority had made various 

redevelopment plans for the property since 2013, none fully materialized, 

and all dwelling units in the development are now vacant. HUD and the 

Authority had recently taken steps toward developing a plan forward, but 

no redevelopment had occurred at the site. OIG recommended that HUD 

determine (1) whether the development represents an imminent threat 

to public safety and what activities to control the situation could be taken 

before the full environmental review process and (2) which environmental 

review process would be most beneficial to ensure that it is completed 

as soon as possible. Further, OIG recommended that HUD continue to 

provide training and technical assistance to the Authority and require it to 

(1) identify and address urgent health and safety issues, (2) develop and 

Office of Audit

Public Housing Agencies’ Experiences and Challenges in the 

Administration of HUD’s CARES Act Funds

The Office of Inspector General (OIG) conducted a limited review of 

HUD’s Coronavirus Aid, Relief, and Economic Security (CARES) Act 

supplemental public housing operating funds (supplemental funds) to 

assess PHAs’ experiences and challenges and HUD’s efforts in providing 

guidance related to the administration of the supplemental operating 

funds under the CARES Act. OIG found that the PHA survey respondents 

generally cited positive experiences and no major challenges related to 

the administration of supplemental funds under the CARES Act. Although 

OIG had no recommendations, it provided two key considerations for 

HUD. HUD should continue to keep the lines of communication open 

with PHAs to (1) clarify guidance when warranted and ensure that 

the PHAs know how to properly use the reporting portal to meet the 

quarterly reporting requirements and (2) monitor the PHAs that are slow 

in drawing down supplemental funds and help to ensure that funds are 

spent by the deadline of December 31, 2021. 

(Agencywide, Audit Memorandum: 2022-CH-0801)

Evaluating Public Housing Agency Challenges With the HUD 

Veterans Affairs Supportive Housing Program

OIG conducted this evaluation due to the growing national homeless 

crisis and HUD’s goal of ending homelessness. OIG’s objective was to 

evaluate the challenges that participating PHAs face in meeting the goals 

and objectives of the HUD Veterans Affairs Supportive Housing (VASH) 

program. OIG sent an electronic questionnaire to 662 PHAs with a HUD 

VASH program. The majority of responding PHA executives and designated 

points of contact found that they had excellent or good relationships 

with their designated Veterans Affairs Medical Centers and local HUD 
Public and Indian Housing | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 17

The Housing Authority of Plainfield, NJ, Did Not Always Comply 

With Requirements When Administering Its Public Housing 

Programs

OIG audited the Housing Authority of Plainfield, NJ’s administration of its 

public housing programs to determine whether the Authority administered 

its Public Housing Operating Fund and Capital Fund programs in accordance 

with HUD, Federal, and Authority requirements. OIG found that the 

Authority did not always comply with Federal, HUD, State, and Authority 

requirements when administering its public housing programs. As a result, 

(1) HUD did not have assurance that its interest and investment were 

adequately protected and that $1.3 million in rooftop lease proceeds was 

properly accounted for and used for planned, approved purposes, and (2) 

the Authority paid nearly $2.9 million in unsupported costs and may pay 

an additional $1.2 million for procurements not adequately performed 

and documented. OIG recommended that HUD require the Authority to 

(1) terminate the current rooftop lease, (2) remedy the reporting and use 

of proceeds issues related to the nearly $1.3 million in proceeds received 

under the lease, (3) repay from non-Federal funds any proceeds used for 

unallowable expenses, (4) obtain HUD approval of any new lease agreement, 

and (5) implement controls to ensure compliance with requirements 

for third-party agreements and that disposition proceeds are properly 

accounted for and used. Further, OIG recommended that HUD require the 

Authority to (1) support that nearly $2.9 million paid for goods and services 

was reasonable in accordance with applicable requirements or repay from 

non-Federal funds any amount that it cannot support; (2) support that 

$1.2 million in funds not yet spent on the contracts reviewed, along with 

any new procurements, would be reasonable or reallocate the funds; (3) 

ensure that its staff receives training on applicable requirements; and (4) 

improve its controls to ensure that future procurement actions comply with 

requirements and that prices paid for goods and services are reasonable. 

(Plainfield, NJ, Audit Report: 2022-NY-1002)

implement a plan to routinely identify and address recurring urgent health 

and safety issues, and (3) develop and implement plans for the remaining 

public housing units at the development and for the original property 

related to the units converted during previous redevelopment efforts. 

(Buffalo, NY, Audit Report: 2022-NY-1001)

HUD Did Not Have Adequate Policies and Procedures for 

Ensuring That Public Housing Agencies Properly Processed 

Requests for Reasonable Accommodation

OIG audited HUD’s oversight of its PHAs’ reasonable accommodation 

policies and procedures to determine whether HUD had adequate policies 

and procedures for ensuring that PHAs properly addressed, assessed, and 

fulfilled requests for reasonable accommodation, including coronavirus 

disease 2019 (COVID-19)-related requests. HUD did not have adequate 

policies and procedures in place and did not perform the civil rights 

front-end reviews as required. OIG recommended that HUD (1) update 

its compliance monitoring guidance to require personnel to review PHAs’ 

reasonable accommodations policies and procedures; (2) update and 

consolidate its reasonable accommodation policies and procedures to 

ensure that there is centralized guidance available for the field offices 

and PHAs; (3) conduct additional outreach efforts to educate tenants and 

PHAs on their rights and responsibilities for reasonable accommodation 

requests; (4) require that PHAs track requests for reasonable 

accommodation; (5) review the joint agreement between HUD’s Offices 

of Public and Indian Housing and Fair Housing and Equal Opportunity and 

a related Section 504 checklist and modify, update, or recommit to it to 

ensure that the roles and responsibilities of the Office of Public and Indian 

Housing for conducting civil rights front-end reviews are clearly defined; 

and (6) ensure that personnel receive training on how to conduct the civil 

rights front-end reviews. 

(Agencywide, Audit Report: 2022-BO-0001)
Public and Indian Housing | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 18

Property Manager Agrees To Pay $750,000 To Resolve Fair 

Housing Act Lawsuit

Reese Pfeiffer, property manager for multiple single-family and 

multifamily rental properties, entered a consent decree with the United 

States to resolve allegations that he violated the Fair Housing Act by 

subjecting 23 women, of whom at least 5 were Housing Choice Voucher 

Program participants, to repeated sexual harassment and retaliation. 

Pfeiffer agreed to pay $736,000 in monetary damages, to be divided 

among the 23 victims, and $14,000 in civil penalties to the United States. 

For at least 5 years, Pfeiffer engaged in unwelcomed sexual advances 

and entered the tenants’ homes under the pretense of collecting rent 

to solicit sexual favors. The settlement also states that Michael Fruen, 

Jeremy Martineau, Jeanne Pfeiffer, F&P LLC, and MF Properties were 

vicariously liable for Pfeiffer’s discriminatory conduct because Pfeiffer 

acted as their agent when he sexually harassed tenants at properties 

in which they had an ownership interest. HUD OIG, the Civil Division 

of the U.S. Attorney’s Office for the District of Minnesota, and the U.S. 

Department of Justice’s Civil Rights Division conducted this investigation. 

(Minneapolis, MN)

Office of Investigation

Housing Choice Voucher Program Landlord Agrees To Pay $4.5 

Million To Resolve Fair Housing Act Lawsuit

Joseph Centanni, a Housing Choice Voucher Program landlord, 

entered into a consent decree with the United States and agreed to 

pay $4.5 million to resolve a Fair Housing Act lawsuit concerning his 

sexual harassment of tenants and housing applicants for more than 

15 years. Of the $4.5 million settlement, $4.39 million will be divided 

among the aggrieved parties as monetary damages, and $107,050 

will be paid to the United States as civil penalties. The Fair Housing 

Act prohibits discrimination on the basis of sex, which includes sexual 

harassment and discrimination on the basis of sexual orientation and 

gender identity. Centanni focused his harassment on women and gay 

or bisexual men and threatened eviction if they did not comply with his 

sexual demands. HUD OIG conducted this investigation. 

(Newark, NJ)
Community Planning and Development | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 19

The Office of Community Planning and Development (CPD) works in conjunction with all levels of government 

and the private sector to develop viable communities by promoting integrated approaches that provide decent 

housing, suitable living environments, and expanded economic opportunities for low- and moderate-income 

persons. Some of the highlights from this semiannual period are outlined in this chapter. Additionally, in 

response to disasters, Congress may appropriate additional funding to Community Development Block Grant 

Disaster Recovery (CDBG-DR) grants to rebuild the affected areas and provide crucial seed money to start the 

recovery process. Since fiscal year 2001, the U.S. Department of Housing and Urban Development (HUD) has 

allocated $95.5 billion in CDBG-DR and CDBG Mitigation grants to help cities, counties, and States recover from 

presidentially declared disasters. Of the $95.5 billion in disaster allocations nationwide, nearly $85.0 billion has 

been obligated, and more than $48.4 billion has been disbursed as of the end of the period.

COMMUNITY PLANNING 

AND DEVELOPMENT

AUDIT INVESTIGATION

administrativecivil actions

convictions-pleaspretrial diversions

financial recoveries

6

11

$4,736,935

key program 

results

recommended funds 

put to better use

recommended 

questioned costs

$986,883

6

$3,500,000
Community Planning and Development | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 20

similarities, OIG reviewed 132 CDBG-DR program audits and evaluations 

issued from May 2002 to March 2020 to summarize the common CDBGDR program weaknesses and risks for CPD to consider to help its CDBGCV grantees effectively and efficiently manage their CDBG-CV program 

operations. OIG found that more than 44 percent of grantees reviewed 

(32 of 72) did not follow program requirements, resulting in questioned 

costs totaling more than $1.7 billion. As of September 11, 2020, CPD had 

awarded the CDBG-CV grant funds to 1,265 formula and joint grantees 

to respond to the pandemic, and 1,195 grantees, or about 94 percent, 

lacked experience with CDBG-DR activities. To ensure program integrity 

and the timeliness of CDBG-CV activities and to mitigate the risk of 

financial loss, CPD should (1) provide grantees with training or other 

technical assistance to help familiarize them with program requirements; 

(2) ensure that grantee coronavirus activities are allowed and are needed 

to prevent, prepare for, and respond to the coronavirus pandemic; 

(3) ensure that grantees without disaster experience become familiar 

with the program rules and have the capacity to directly administer the 

coronavirus funding if needed; (4) ensure that grantees are aware of the 

requirements to prevent duplication of benefits issues; and (5) ensure 

that grantees become familiar with Federal procurement requirements, 

cost principles, and other administrative requirements. 

(Agencywide, Audit Memorandum: 2022-FW-0801)

The City of Houston, Houston, TX, Faced Challenges in 

Administering Its Hurricane Harvey Program and Risked Losing 

Its Funding

OIG audited the City of Houston’s Hurricane Harvey CDBG-DR program. 

OIG initiated this audit based on congressional interest and to help 

HUD address its top management challenges and strategic objective to 

support effectiveness and accountability in long-term disaster recovery. 

OIG’s objective was to assess the efficiency and effectiveness of the 

Office of Audit

Fraud Risk Inventory for the CDBG and ESG CARES Act Funds

The Office of Inspector General (OIG) worked with with the Pandemic 

Response Accountability Committee (PRAC) to gain an understanding 

of HUD’s fraud risk management practices and develop an inventory 

of fraud risks that HUD had not already identified for the funds 

appropriated by the Coronavirus Aid, Relief, and Economic Security 

(CARES) Act for the CDBG and Emergency Solutions Grant (ESG) 

programs. OIG identified five risk factors that contribute to the risk of 

fraud and developed a fraud risk map containing 31 fraud schemes that 

can be used to misappropriate CDBG and ESG CARES Act funds. OIG 

also identified opportunities to improve HUD’s fraud risk management 

practices, including clarifying roles and responsibilities, performing 

fraud-specific risk assessments, and raising awareness of fraud and 

fraud risks. OIG recommended that HUD (1) clarify the roles and 

responsibilities for fraud risk identification, assessment, and mitigation; 

(2) complete program-specific fraud risk assessments and risk profiles 

for the CDBG and ESG programs; (3) consider OIG’s fraud risk inventory 

to improve its fraud risk assessments; (4) implement efforts to increase 

the awareness of fraud at all levels; (5) develop and implement a fraud 

risk checklist or other instrument to be completed as part of each 

monitoring review; and (6) develop and implement a fraud analytics 

strategy using available data. 

(Agencywide, Audit Memorandum: 2022-FO-0801)

Lessons Learned and Key Considerations From Prior Audits and 

Evaluations of the CDBG Disaster Recovery Program

On March 27, 2020, the CARES Act made available $5 billion in 

supplemental CDBG funding for grants to prevent, prepare for, and 

respond to the coronavirus pandemic (CDBG-CV grants). Because of 
Community Planning and Development | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 21

of coronavirus disease 2019 (COVID-19) on grantee spending. As of 

July 30, 2021, of the $18.5 billion appropriated in CDBG-DR funds 

for disasters that occurred from 2011 through 2016, more than $3.7 

billion remained unspent, and the pandemic has slowed the progress 

of these grants. OIG recommended that HUD require CPD to (1) 

continue developing proper methodology to identify slow spenders and 

update policies, procedures, and its monitoring exhibit; (2) establish a 

reasonable timeframe for grantees to adequately address the system 

flags in the Disaster Recovery Grant Reporting system and resolve or 

remediate outstanding flags; (3) require updated grantee projections; 

(4) sufficiently document its basis for conclusions in its monitoring and 

quarterly performance reviews; and (5) consider grantee suggestions to 

assist with the progress of spending funds. 

(Agencywide, Audit Report: 2022-AT-0001)

The Los Angeles Homeless Services Authority, Los Angeles, CA, 

Did Not Always Administer Its Continuum of Care Program in 

Accordance With HUD Requirements

OIG audited the Los Angeles Homeless Services Authority’s Continuum 

of Care (CoC) program to determine whether the Authority met the 

goals and objectives of housing and helping the homeless become 

self-sufficient through its CoC program and administered the program 

in accordance with HUD requirements. OIG found that the Authority 

(1) did not use $3.5 million in CoC grant awards and left the funds 

to expire, (2) did not support Homeless Management Information 

System and planning grant costs, and (3) did not submit timely annual 

performance reports. As a result, the unused CoC funds represented 

a missed opportunity to meet the program’s goals of assisting the 

homeless, HUD did not have assurance that $879,847 in salary and rent 

costs were for the CoC grants, and CoC funds may have unnecessarily 

sat idle and unavailable for future awards. OIG recommended that 

City’s program. OIG found that 3 years after Hurricane Harvey, the 

City had spent only 1.8 percent of its suballocated grant funds and had 

assisted only 297 of 8,784 housing program participants, leaving affected 

Houstonians without the help they needed. This weak performance 

contributed to HUD’s designating the Texas General Land Office (Texas 

GLO) as a slow spender. As a result, the City’s slow performance risked 

its missing HUD’s spending deadlines, recapture of the Texas GLO’s grant 

funds, and potential loss of the City’s $1.275 billion in suballocated 

Hurricane Harvey grant funds. OIG recommended that HUD require 

the Texas GLO to ensure that (1) it includes milestones and appropriate 

consequences for not meeting them in future subrecipient agreements 

and (2) processes are in place to assist participants transitioning from 

the City’s programs to the Texas GLO’s programs. With HUD’s approval 

of action plan amendment 8, OIG recommended that HUD require the 

Texas GLO to also (1) provide its plan to continuously monitor the City’s 

pace and performance in its remaining program and take appropriate 

action to ensure that program goals are met, (2) set performance and 

financial milestones for all programs and activities funded under the 

City’s subrecipient agreement, and (3) provide its plan to ensure that 

the City complies with the Texas GLO’s guidelines and requirements. 

Implementation of these recommendations would include a process for 

repurposing additional grant funds if necessary. 

(Houston, TX, Audit Report: 2022-FW-1001)

Opportunities Exist To Improve CPD’s Oversight of and 

Monitoring Tools for Slow-Spending Grantees

OIG audited HUD CPD oversight and monitoring of its CDBG-DR slowspending grantees. This was a self-initiated audit, consistent with OIG’s 

oversight activities and current top priority areas, with the objective to 

assess CPD’s monitoring and oversight tools related to the progress of 

grant expenditures and determine the status of the grants and impacts 
Community Planning and Development | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 22

Former Building Inspector Sentenced to 30 Months Incarceration

Kevin Richardson, a former building inspector for a local municipality, 

was sentenced in U.S. District Court in connection with his earlier guilty 

plea to use of an interstate facility with intent to carry on unlawful 

activity. For more than 8 years, Richardson used the local municipality’s 

internet-based system to alter, delete, and submit documents and 

information. Richardson solicited and accepted approximately $65,000 

in bribe payments from individuals seeking favorable inspection reports 

and certificates of completion for properties that did not comply with 

city and State building codes and for properties that had not been 

inspected. He also paid bribe money to a local municipality permit 

analyst for the issuance of permits without proper documentation and 

plan review. Many of the properties involved received funding through 

HUD’s Housing Choice Voucher Program. Richardson was sentenced 

to 30 months incarceration and 1 year supervised release. HUD OIG, 

the City of New Orleans OIG, and the Federal Bureau of Investigation 

conducted this investigation. 

(New Orleans, LA)

HUD require the Authority to (1) develop and implement policies and 

procedures to ensure that grant agreements are executed in a timely 

manner and effective monitoring is performed to prevent similar 

occurrences of grant funds’ going unused, (2) support payroll and rent 

costs or repay its CoC grants $879,847 from non-Federal funds, and (3) 

develop policies and procedures to ensure that annual performance 

reports are submitted in a timely manner and personnel are routinely 

trained on the grant closeout process. 

(Los Angeles, CA, Audit Report: 2022-LA-1001)

Office of Investigation

Santa Fe Boys and Girls Club Agrees To Pay HUD $1.4 Million

The Santa Fe Boys and Girls Club (SFBGC), CDBG grant recipient, 

entered into a settlement agreement with the United States and agreed 

to pay $1.4 million to HUD to resolve allegations that it violated the 

False Claims Act. SFBGC obtained $750,986 in CDBG special purpose 

grants to purchase land and build a new facility.  SFBGC failed to use 

the funds, as outlined in the agreements, when it failed to build a new 

facility and then did not return the funds as prescribed by HUD, Federal 

law, and the grant agreements. Instead, SFBGC began to incumber the 

property by selling off portions of the land to businesses and renting 

the remaining land that was still under its control. HUD OIG conducted 

this investigation. 

(Santa Fe, NM)  
Additional Reports | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 23

The U.S. Department of Housing and Urban Development (HUD), Office of Inspector 

General’s (OIG) additional significant reports are highlighted in this chapter.

ADDITIONAL REPORTS

Office of Audit

DATA Act Compliance Audit of the U.S. Department of Housing 

and Urban Development, Office of the Chief Financial Officer

In accordance with the statutory requirements of the Digital Accountability 

and Transparency Act of 2014 (DATA Act) and standards established by 

the Office of Management and Budget (OMB) and the U.S. Department 

of the Treasury, OIG audited the HUD, Office of the Chief Financial 

Officer’s (OCFO) compliance with the DATA Act for the third quarter of 

fiscal year 2020. The audit was statutorily mandated by Congress. OIG’s 

objectives were to assess the (1) completeness, accuracy, timeliness, 

and quality of HUD OCFO’s fiscal year 2020, third quarter, financial and 

award data submitted for publication on USASpending.gov and (2) HUD’s 

implementation and use of the governmentwide financial data standards 

established by OMB and Treasury. While HUD OCFO generally complied 

with the reporting requirements of the DATA Act, OIG found that (1) award 

data reported in File C were not always reported in File D2 in a timely 

manner and (2) inaccuracies existed between the data reported and the 

source documentation for the business type, action type, and other data 

elements. OIG had no new recommendations and determined that HUD 

had satisfactorily addressed the reasons why program award data were not 

submitted in a timely manner. Also, the remaining exceptions related to 

potential errors in the business type, action type, and other data elements 

were immaterial or due to causes outside HUD’s control. Further, HUD had 

taken corrective actions that addressed all open recommendations from 

OIG’s prior audit, and these actions address the remaining issues identified 

in the current-year audit. 

(Agencywide, Audit Report: 2022-FO-0001)

Government National Mortgage Association, Audit of Fiscal Year 

2021 Financial Statements

The Chief Financial Officers Act of 1990 (Public Law 101-576), as 

amended, requires OIG to audit the financial statements of the 

Government National Mortgage Association (Ginnie Mae) annually. 

OIG contracted with the independent public accounting firm of 

CliftonLarsonAllen LLP (CLA) to audit the financial statements of Ginnie 

Mae as of and for the fiscal years ended September 30, 2021 and 

2020, to provide reports on Ginnie Mae’s internal control over financial 

reporting and compliance with laws, regulations, contracts, and grant 

agreements in its financial reporting. In its audit of Ginnie Mae, CLA 

reported that (1) Ginnie Mae’s financial statements as of and for the 

fiscal years ended September 30, 2021 and 2020, were presented fairly, 

in all material respects, in accordance with U.S. generally accepted 

accounting principles; (2) there were no material weaknesses for fiscal 
Additional Reports | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 24

when deciding whether or when to require Federal employees to 

return to their offices. OIG’s audit objective was to determine whether 

the memorandums that HUD’s regional administrators and Assistant 

Secretary for Administration submitted to the Deputy Secretary, which 

recommended allowing the voluntary reentry of employees to HUD’s 

offices (reentry memorandums), sufficiently addressed the criteria 

in the Resuming Normal Operations Guide, COVID-19 Response, for 

Headquarters and Field Offices. OIG found that HUD did not always 

comply with its guide when transitioning its offices. Specifically, 

the reentry memorandums reviewed for seven selected offices that 

transitioned did not sufficiently address the gating criteria. HUD also did 

not (1) provide sufficient documentation to support that the gating criteria 

were met and (2) establish metrics for determining whether the offices 

met the gating criteria to transition. As a result, HUD lacked assurance 

that its offices were transitioned to maximum telework in accordance 

with its guide and in a consistent manner. OIG recommended that HUD 

ensure that future policies and guidance developed to return HUD’s 

offices to normal operations include the specific criteria, metrics, and 

defined geographic area to be used by all offices as applicable. OIG also 

recommended that HUD develop and implement sufficient policies and 

controls to ensure that (1) applicable criteria in any future guidance are 

met and all safety measures are sufficiently completed before returning 

HUD’s offices to normal operations and (2) sufficient documentation is 

maintained to support that the applicable criteria were met. 

(Agencywide, Audit Report: 2022-CH-0002)

HUD Did Not Implement Adequate Grant Closeout and Reporting 

Processes To Ensure Consistent Application of GONE Act 

Requirements

OIG audited HUD’s grant closeout processes and compliance with the 

Grants Oversight and New Efficiency (GONE) Act. OIG’s objectives 

year 2021 in internal control over financial reporting, based on limited 

procedures performed; and (3) there were no reportable noncompliance 

issues for fiscal year 2021 with provisions of applicable laws, regulations, 

contracts, and grant agreements tested and no other matters. 

(Agencywide, Audit Report: 2022-FO-0002)

Audit of HUD’s Fiscal Years of 2021 and 2020 Consolidated 

Financial Statements

OIG contracted with CLA to audit the financial statements of HUD as of and 

for the fiscal years ended September 30, 2021 and 2020, and to provide 

reports on HUD’s (1) internal control over financial reporting and (2) 

compliance with laws, regulations, contracts, and grant agreements and 

other matters, including whether financial management systems complied 

substantially with the requirements of the Federal Financial Management 

Improvement Act of 1996. In its audit, CLA found (1) that the consolidated 

financial statements as of and for the fiscal year ended September 

30,2021, were presented fairly, in all material respects, in accordance with 

U.S. generally accepted accounting principles; (2) one material weakness 

and one significant deficiency in internal control over financial reporting, 

based on the limited procedures that it performed; and (3) two reportable 

matters of noncompliance with provisions of applicable laws, regulations, 

contracts, and grant agreements or other matters. 

(Agencywide, Audit Report: 2022-FO-0004)

HUD Did Not Always Comply With Its Internal Guide When 

Transitioning Offices From Mandatory to Maximum Telework 

During the COVID-19 Pandemic

OIG audited HUD’s transitioning of offices from mandatory to maximum 

telework during the coronavirus disease 2019 (COVID-19) pandemic, 

based on a request from Representative Gerald Connolly, to review 

whether HUD was employing best practices and existing guidance 
Additional Reports | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 25

were to determine whether HUD (1) implemented adequate grant 

closeout processes to ensure compliance with GONE Act requirements 

and (2) ensured that reports related to its compliance with the GONE 

Act were accurate. HUD did not implement adequate GONE Act grant 

closeout processes, and related data and reports were not always 

accurate. Specifically, it implemented bulk closeout procedures that 

bypassed requirements, and its data used to compile reports included 

inconsistencies and incorrect information. As a result, HUD made errors 

in grant closeouts and was unable to ensure that related data and 

reports to Congress and other stakeholders were accurate. Although 

HUD’s reporting responsibilities under the GONE Act have ended, it 

should address the weaknesses identified to ensure future compliance 

with grant closeout requirements and consistent and accurate reporting 

of grant information to stakeholders. OIG recommended that HUD 

develop and implement controls (1) for use of the bulk grant closeout 

process going forward to ensure that grants are closed in accordance 

with all applicable requirements and (2) to ensure that future grant data 

reporting to stakeholders is consistent and accurate. 

(Agencywide, Audit Report: 2022-NY-0001)

Office of Evaluation

Fiscal Year 2021 Federal Information Security Modernization Act 

(FISMA) Evaluation Report: February 17, 2022 

The Federal Information Security Modernization Act of 2014 (FISMA) 

directs inspectors general to conduct an annual evaluation of the agency 

information security program. FISMA, the U.S. Department of Homeland 

Security, the Office of Management and Budget (OMB), and the National 

Institute of Standards and Technology establish information technology 

security guidance and standards for Federal agencies. OIG conducted 

this evaluation to assess the overall effectiveness of HUD’s information 

security program, assess its compliance with Federal guidance, and 

respond to OMB reporting questions for the fiscal year 2021 annual 

assessment. OIG has determined that the contents of this report would 

not be appropriate for public disclosure and, therefore, limited its 

distribution to selected officials. 

(Agencywide, Evaluation Report: 2021-OE-0001) 

Delays in Federal Housing Administration Catalyst’s Development

In February 2021, the Office of the Chief Information Officer (OCIO) 

identified funding risks with the contract under which HUD contracted 

for the Federal Housing Administration’s (FHA) development of FHA 

Catalyst. FHA has embarked on a multiyear information technology 

modernization initiative through this new web-based platform, which 

enables FHA to manage its programs and processes more efficiently and 

effectively, benefiting those who do business with FHA. In response, HUD 

officials took steps to slow FHA Catalyst spending on the contract while 

awaiting approval for additional contract funds. Despite efforts to slow 

project spending, it was not enough to prevent funding shortfalls before 

the contract’s base yearend. Poor contract oversight enabled OCIO to 

exhaust funds before the end of the base year, which stopped work on FHA 
Additional Reports | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 26

Catalyst. Additionally, several issues hindered FHA Catalyst development 

activities. As of August 2021, HUD had resumed FHA Catalyst development 

work at limited capacity. As of October 2021, HUD estimated that it would 

complete FHA Catalyst development in March 2025. 

(Agencywide, Evaluation Topic Brief: 2021-OE-0003a)

HUD’s Processes for Managing IT Acquisitions

OIG reviewed HUD’s ability to effectively complete information 

technology (IT) acquisitions. HUD’s IT systems and its modernization 

plans depend heavily on contractors, yet HUD has historically faced 

significant challenges with implementing effective acquisition processes. 

Therefore, HUD’s acquisition capacity represents a key potential risk 

within HUD’s IT environment. OIG found a lack of staffing capacity, 

implementation of effective coordination and communication practices, 

and effective oversight of management controls over acquisition 

processing. HUD officials acknowledged that IT acquisition process 

improvements are needed and have taken steps toward addressing 

deficiencies. OIG made five recommendations to assist in continued 

successes for future acquisition efforts. 

(Agencywide, Evaluation Report: 2020-OE-0004)
Legislation, Regulations , and Other Directives | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 27

Reviewing and making recommendations on legislation, regulations, and policy issues is a critical part of the Office of Inspector General’s (OIG) 

responsibilities under the Inspector General Act. During this 6-month reporting period, OIG has committed more than 630 hours to reviewing 155 

issuances. The draft directives consisted of 112 notices, 17 mortgagee letters (ML), and 26 other directives. OIG provided comments on 49 (or 32 

percent) of the issuances and nonconcurred on 18 (or 12 percent) but lifted 8 nonconcurrences. Of the 26 other directives, OIG reviewed 4 final rules 

and 5 proposed rules, taking no position on 5, commenting on 3, and nonconcurring on 1; 6 handbooks-guidebooks; 8 research reports; 1 other agency 

report on the National Radon Action Plan 2021-2025; and 2 sets of frequently asked questions in which 1 was related to fair housing issues and the 

other was related to Afghan evacuees in the United States - questions and answers regarding housing assistance for Afghan evacuees and parolees. The 

following is a summary of selected reviews for this 6-month period.

LEGISLATION, 

REGULATIONS, AND 

OTHER DIRECTIVES

17 mortgagee letters

11%

155 TOTAL ISSUANCES OTHER DIRECTIVES SUMMARY

26 other directives

17%

112 notices

72%

final

rules

proposed 

rules

handbooks and 

guidebooks

research 

reports

other agency 

report

frequently 

asked 

questions
Legislation, Regulations, and Other Directives | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 28

Home equity conversion mortgage limits – On November 30, 2021, 

HUD issued ML 2021-29 announcing the home equity conversion 

mortgage (HECM) limit for the calendar year beginning on January 1, 

2022. The maximum claim amount for FHA-insured HECMs for seniors 

will be $970,800 (150 percent of the Federal Home Loan Mortgage 

Corporation’s (Freddie Mac) national conforming limits of $647,200). 

This maximum claim amount of $970,800 is also applicable to Freddie 

Mac’s special exception areas: Alaska, Hawaii, Guam, and the Virgin 

Islands. OIG provided a no position response to this ML.

Delay of effective date of ML 2021-21, FHA Catalyst: Single Family 

Default Monitoring System Reporting Module and associated changes 

to the Single-Family Default Monitoring System reporting codes 

and reporting data elements – On November 30, 2021, HUD issued 

ML-2021-30 announcing the delay of the effective dates in ML 2021-

21. HUD issued ML 2021-21 on September 13, 2021, announcing the 

transition of the Single-Family Default Monitoring System (SFDMS) from 

FHA Connection (FHAC) to FHA Catalyst. This ML also updated and 

added default reporting error codes and streamlined the data elements. 

HUD will publish a future ML at least 60 days before the transition to 

announce new effective dates. OIG provided a no position response to 

both MLs.

Update to FHA Catalyst transition for the Single Family Default 

Monitoring System Reporting Module – On December 30, 2021, HUD 

issued ML-2021-31 announcing the new effective dates for the transition 

of the SFDMS from FHAC to FHA Catalyst, the added and updated default 

reporting error codes, and the streamlined data elements. The last 

day that lenders will have access to FHAC for default reporting will be 

February 7, 2022. SFDMS reporting capabilities will move from FHAC 

to the FHA Catalyst platform on March 1, 2022. Beginning March 1, 

2022, lenders must report in the SFDMS module through FHA Catalyst or 

Notices, Mortgagee Letters, and Other 

Directives

Single Family Housing

Handbook 4000.1, FHA Single Family Housing Policy Handbook – On 

October 6 and November 9, 2021, HUD issued updates to the FHA Single 

Family Housing Policy Handbook (Handbook 4000.1). Handbook changes 

incorporated previously issued MLs and changes to the Federal Housing 

Administration’s (FHA) Title I program. OIG provided a no position 

response to both issuances.

Appraisal fair housing compliance and updated general appraiser 

requirements – On November 17, 2021, HUD issued ML 2021-27 

clarifying FHA’s requirements for appraisers and lenders regarding 

compliance with fair housing laws related to the appraisal of properties 

that will serve as security for FHA-insured mortgages. This ML was issued 

in response to President Biden’s creation of an interagency initiative to 

address inequity in home appraisals and root out discrimination and 

bring about systemic change in the appraisal and home-buying process. 

OIG provided a no position response to this ML.

Nationwide forward mortgage limits – On November 30, 2021, HUD 

issued ML 2021-26 announcing the forward mortgage limits for the 

calendar year beginning on January 1, 2022. FHA calculates forward 

mortgage limits based on the median house prices in accordance with 

the National Housing Act. FHA’s single family forward mortgage limits 

are set by metropolitan statistical area and county and are published 

periodically. FHA publishes updated limits effective for each calendar 

year. It sets these limits at or between the low-cost area and high-cost 

area limits based on the median house prices for the area. OIG provided 

a no position response to this ML.
Legislation, Regulations, and Other Directives | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 29

with FHA’s coronavirus disease 2019 (COVID-19)-related foreclosure 

moratorium for FHA-insured single family mortgages. OIG provided a no 

position response to this ML.

Update to the mandatory use date for the FHA Catalyst: Electronic 

Appraisal Delivery Module – On February 15, 2022, HUD issued ML2022-04 announcing an extension of the mandatory use dates in ML 

2021-23, Mandatory Transition to the FHA Catalyst: Electronic Appraisal 

Delivery (EAD) Module. Effective on and after March 14, 2023, appraisal 

delivery through the FHA Catalyst: EAD Module is mandatory for all cases 

unless a previous appraisal version was submitted to the legacy EAD. 

For cases with a previous appraisal submission to the legacy EAD before 

March 14, 2023, appraisal resubmissions may continue to be delivered 

through the legacy EAD portal until April 17, 2023. After April 17, 2023, 

appraisal submissions for all cases, regardless of previous submissions, 

must be delivered through the FHA Catalyst: EAD Module. OIG provided 

a no position response to this ML.

Public and Indian Housing

Notice of intent to establish a tribal intergovernmental advisory 

committee; request for comments on committee structure – On 

November 15, 2021, HUD published a notice (Federal Register (FR) -6289-

N-01) announcing HUD’s intention to form its first standing tribal advisory 

committee. The committee will be called the Tribal Intergovernmental 

Advisory Committee (TIAC). The TIAC will be made up of a diverse group of 

duly elected tribal leaders representing small, medium, and large federally 

recognized tribes. The TIAC is intended to further communications 

between HUD and federally recognized tribes on HUD programs, make 

recommendations to HUD regarding current program regulations, provide 

advice in the development of HUD’s American Indian and Alaska Native 

housing priorities, and encourage peer learning and capacity building 

Electronic Data Interchange. The effective date for the updated default 

reporting error codes found in the SFDMS reporting codes are changed 

to March 1, 2022. OIG provided a no position response to this ML.

Expansion of the exclusive listing period for HUD real estate owned – 

On January 13, 2022, HUD issued ML 2022-01 announcing an 

extension to the exclusive listing period during which owner-occupants, 

governmental entities, and HUD-approved nonprofits are eligible to bid 

on HUD single-family (one- to four-unit) real estate-owned properties, 

which became effective March 1, 2022. OIG provided a no position 

response to this ML.

Manufactured housing installation program reporting requirements – 

On January 14, 2022, OIG completed the review of the PRA (Paperwork 

Reduction Act)-60-Day Notice related to OMB Collection 2502-0578, 

in which HUD is seeking approval from the Office of Management and 

Budget (OMB) for the information collection that HUD will use for the 

enforcement of the Model Manufactured Home Installation Standards 

in each State that does not have an installation program established by 

State law, to ensure that the minimum criteria of an installation program 

are met. OIG provided nonconcurrence on this request related to the 

certification statements included in Forms HUD-307, HUD Manufactured 

Home Installer License Application; HUD-308, HUD Manufactured 

Home Installation Trainer Registration Application; HUD-309, HUD 

Manufactured Home Installation Certification and Verification Report; 

and HUD-312, State Installation Program Certification Form. As of March 

22, 2022, the nonconcurrence had not been lifted.

Technical update to the extension of the deadlines for the first legal 

action and reasonable diligence timeframe – On February 7, 2022, HUD 

issued ML-2022-02 to clarify the extension of the deadlines for the first 

legal action and reasonable diligence timeframe provided in connection 
Legislation, Regulations, and Other Directives | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 30

emergency payments for low- and moderate-income individuals or 

families impacted by a disaster for a period not to exceed 6 months. This 

notice did not come through the clearance process; therefore, OIG did 

not have an opportunity to review and comment on it.

Regulatory and administrative requirement waivers and flexibilities 

available to HUD public housing and Section 8 during calendar years 

2022 and 2023 to public housing agencies to assist with recovery 

and relief efforts on behalf of families affected by presidentially 

declared disasters – On January 5, 2022, HUD published a notice (FR6301-N-01) advising the public of HUD’s expedited process for waivers 

and flexibilities from HUD regulatory and administrative requirements 

during PDDs. This notice establishes an expedited process for the review 

of waiver requests and flexibilities for calendar years 2022 and 2023 for 

public housing agencies (PHA) located within PDDs. Some of the HUD 

requirement waivers and flexibilities available include (1) the eligibility of 

operating subsidies for vacant public housing units that are vacant due to a 

federally declared, State declared, or other declared disaster; (2) a waiver 

of physical inspection and scoring of public housing projects for PDD PHAs 

with fiscal yearend dates within 4 months before and up to 10 months 

after the effective date of the PDD; (3) a waiver of the total development 

cost and housing cost cap limits for all work funded by the Capital Grant 

(with unexpended Capital Grant funds and HOPE VI funds) until the next 

issuance of total development cost levels to facilitate the use of capital 

funds for repairs and construction for needed housing in the disaster 

areas; (4) a waiver to allow all unexpended Capital Fund Replacement 

Housing Factor Grants to be used for public housing modernization to help 

address housing needs because of the displacement caused by the PDD; 

(5) a waiver of the requirement that each dwelling unit have at least one 

bedroom or living-sleeping room for each two persons to house families 

displaced due to natural disasters; and (6) consideration of a written 

request to carry forward the last Section Eight Management Assessment 

among tribes and nontribal entities. This notice solicits comments and 

recommendations regarding the establishment and structure of the TIAC. 

OIG provided minor editorial-related comments regarding this notice.

Regulatory and administrative requirement flexibilities available to 

Native American programs during calendar years 2022 and 2023 to 

tribal grantees to assist with recovery and relief efforts on behalf of 

families affected by presidentially declared disasters – On January 5, 

2022, HUD published a notice (FR-6301-N-02) advising the public of 

waivers and flexibilities from HUD requirements for its Indian Housing 

Block Grant (IHBG), Indian Community Development Block Grant 

(ICDBG), and Native Hawaiian Housing Block Grant (NHHBG) grantees 

located in areas that are covered by presidentially declared disasters 

(PDD). Grantees may use any of the waivers and flexibilities to assist 

their communities in addressing challenges and issues that result from 

a disaster covered by a PDD. Some of the HUD requirement waivers 

and flexibilities available for IHBG, ICDBG, and NHHBG grantees located 

within PDD areas include (1) income verification – Under this waiver, (a) 

IHBG recipients may deviate from their current written admissions and 

occupancy policies and may allow less frequent income recertifications, 

and (b) IHBG recipients may carry out intake and other tasks necessary to 

verify income through alternative means; (2) assistance to middle-income 

families impacted by a disaster – Under this waiver, IHBG recipients in 

PDDs may provide IHBG assistance to middle-income Native American 

families whose income is at or below 120 percent of area median income 

without HUD approval; (3) purchasing equipment – Under this waiver, 

HUD authorized the use of ICDBG funds for the purchase of equipment 

necessary to carry out ICDBG-eligible activities that assist with clearance, 

rehabilitation, construction, and other uses related to housing, public 

facilities, improvements, and works and other disaster-recovery-related 

purposes; and (4) emergency payments for up to 6 months – Under 

this waiver, HUD will allow ICDBG grant funds to be used to provide 
Legislation, Regulations, and Other Directives | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 31

opportunity to secure emergency funding and additional time to secure 

such funding before eviction. OIG provided a comment on web links that 

were not active and an editorial comment regarding a typographical error. 

Supplemental guidance to the interim final rule, Extension of Time 

and Required Disclosures for Notification of Nonpayment of Rent – 

On October 7, 2021, HUD issued notices, PIH 2021-29 and H 2021-06, 

which provide supplemental guidance to implement the requirements 

included in the interim final rule, entitled Extension of Time and Required 

Disclosures for Notification of Nonpayment of Rent. This notice also 

serves as the required determination by the HUD Secretary that the 

existence of a national emergency necessitates the activation of the 

required minimum 30-day notification period and other required actions 

to support families at risk of eviction for nonpayment of rent. As of 

October 7, 2021, the Coronavirus Aid, Relief, and Economic Security 

(CARES) Act provision requiring 30 days’ notice to vacate for nonpayment 

of rent remains in effect for all CARES Act-covered properties, including 

both public housing and properties assisted under HUD’s project-based 

rental assistance programs. OIG provided comments on web links that 

were not active and did not provide any web page results. 

Federal Housing Administration (FHA) Catalyst: Multifamily 

Application Portal – On October 19, 2021, HUD issued a notice (FR7034-N-55) informing the public that HUD has submitted to OMB a 

request for approval of the information collection on the FHA multifamily 

mortgage insurance program. HUD FHA’s Office of Multifamily Housing 

Programs has developed a web-based portal for FHA-approved multifamily 

lenders to submit applications for FHA multifamily mortgage insurance 

to HUD electronically. The FHA Catalyst: Multifamily Application Portal 

was released in the fall of 2020 to aid in the collection of information 

for FHA multifamily mortgage insurance program applications. The 

National Housing Act (12 U.S.C. (United States Code) 1701 et. seq.) and 

Program (SEMAP) score received by the PHA for a PDD PHA that has a 

SEMAP score due during calendar years 2022 or 2023. OIG provided a no 

position response on this clearance item.

Multifamily Housing

Certain operating cost adjustment factors for 2022 – On October 4, 

2021, HUD issued a notice, FR-6288-N-01, which establishes operating 

cost adjustment factors (OCAF) for project-based assistance contracts 

issued under Section 8 of the United States Housing Act of 1937 and 

renewed under the Multifamily Assisted Housing Reform and Affordability 

Act of 1997 (MAHRA) for eligible multifamily housing projects having an 

anniversary date on or after February 11, 2022. OCAFs are annual factors 

used to adjust Section 8 rents renewed under Section 515 or Section 524 

of MAHRA. OIG provided a no position response regarding this notice.

Extension of time and required disclosures for notification of 

nonpayment of rent – On October 7, 2021, HUD issued an interim final 

rule (FR-6286-I-01), which applies when, during emergencies such the 

current COVID-19 pandemic, Federal funding is available to assist tenants 

with nonpayment of rent and tenants facing eviction for nonpayment of 

rent in public housing and properties with project-based rental assistance 

(PBRA) (for purposes of this rule, PBRA includes projects in the following 

programs: Section 8, Section 8 Moderate Rehabilitation, Section 202-

162 Project Assistance Contract, Section 202 Project Rental Assistance 

Contract (PRAC), Section 811 PRAC, Section 236 Rental Housing 

Assistance Program, and Rent Supplement) who need sufficient time 

and information to seek and receive such emergency rent relief. This 

interim final rule will allow the HUD Secretary, upon making the requisite 

findings and providing the requisite notice, to require housing providers 

participating in those programs to provide tenants facing eviction for 

nonpayment of rent with notification of and information about the 
Legislation, Regulations, and Other Directives | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 32

FHA Catalyst: Multifamily Applications Module – On November 10, 

2021, HUD issued ML 2021-26, announcing the FHA Catalyst: Multifamily 

Applications Module and requiring that multifamily accelerated 

processing (MAP) lenders electronically submit applications for FHA 

multifamily mortgage insurance through the secure and centralized 

web-based portal. The applications module provides multifamily lenders 

with a fully paperless solution for the submission of mortgage insurance 

applications and related documents to FHA. Previously, applications 

for FHA multifamily mortgage insurance were submitted in hardcopy 

and electronic format via removable USB drives or various cloud 

storage services used by lenders. This module provides a simplified, 

standardized, and secure means for multifamily lenders to submit 

applications and related documents to FHA as the Office of Multifamily 

Housing Programs strives to become fully electronic. FHA has embarked 

on a multiyear information technology modernization initiative through 

this new web-based platform, which enables FHA to manage its programs 

and processes more efficiently and effectively, benefiting those who do 

business with FHA. OIG provided a no position response regarding this 

ML.

Termination of underwriting mitigants – In 2022, HUD issued ML-2022-

03, which terminates all underwriting mitigants required under ML 

2020-11 (Section 223(f) Underwriting Mitigants for Multifamily Housing 

Projects Due to Economic Impact of COVID-19 Emergency), including 

the 9-month debt service reserve fund, the 250 percent repair escrow, 

and all guidance relating to treatment of cashout transactions. All 

refinance transactions resulting in cashout loan proceeds will follow the 

MAP Guide instructions. This ML became effective immediately for all 

insured transactions that have yet to reach endorsement. OIG provided a 

comment to correct the date or year of this ML. 

implementing regulations at 24 CFR (Code of Federal Regulations) parts 

200-266 authorize HUD and FHA to administer the multifamily mortgage 

insurance programs. The specific authority to require a mortgage 

insurance application is found at 24 CFR 200.45(b): “[a]n application for a 

firm commitment must be made by an approved mortgagee for any project 

for which a mortgagor seeks mortgage insurance under the Act.” OIG 

provided a no position response regarding this notice. 

Requisition for disbursements of Sections 202 and 811 capital advanceloan funds – On October 25, 2021, HUD issued a notice, FR-7038-N-20, 

which seeks approval from the OMB for the information collection on 

requisition of disbursements. Owner entities are required to submit 

requisitions to HUD during construction to obtain Section 202/811 capital 

advance-loan funds. This collection helps to identify the owner, project, 

type of disbursement, items covered, name of the depository, and account 

number. OIG provided a no position response regarding this notice. 

Request for prepayment of Section 202 or 202-8 direct loan project

– On November 10, 2021, HUD issued a notice, FR-7034-N-65, which 

informs the public that it had submitted to OMB a request for approval of 

the information collection regarding prepayment of Section 202 or 202-

8 project. Such a request is a reinstatement, with change, of previously 

approved collection for which approval has expired. The owner of the 

project is required to execute the Section 202 Prepayment Use Agreement 

(HUD-9808 form) that will ensure the continued operation of the project 

until at least 20 years following the maturity date of the original loan 

under terms at least as advantageous to existing and future tenants as 

the terms required by the original loan agreement. The Use Agreement 

must be executed by the owner and the Department and recorded upon 

HUD’s approval of the prepayment transaction. OIG provided a no position 

response regarding this notice. 
Legislation, Regulations, and Other Directives | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 33

amounts were revised by the Consolidated Appropriations Act, 2008 

(Public Law 110-161, approved December 26, 2007) (Fiscal Year (FY) 

2008 Appropriations Act). Section 221 of the General Provisions of Title 

II of Division K of the FY 2008 Appropriations Act revises the statutory 

exceptions to maximum mortgage amounts for the FHA multifamily 

housing programs, listed in Section 221 of the FY 2008 Appropriations 

Act, by substituting 170 percent for the 140 percent exception of any 

geographical area and substituting 215 percent for 170 percent as 

the maximum exception allowed for a specific project. Accordingly, 

the statutory revision allows the HUD Secretary to grant exceptions to 

maximum mortgage limits for certain multifamily housing programs by 

up to 170 percent (equivalent to a 270 percent multiplier) in geographical 

areas where cost levels so require or up to 215 percent in high-cost 

areas (equivalent to a 315 percent multiplier) where necessary on a 

project-by-project basis. The law does not determine which areas are to 

be considered “high-cost areas.” Accordingly, the Office of Multifamily 

Production has developed a list of high-cost areas for 2022. The threshold 

for a high-cost area has been set for all areas (special limit areas excepted) 

with a “calculated” high-cost percentage of 437.99 or greater. For these 

high-cost areas, the maximum mortgage amount may be increased by up 

to 215 percent (equivalent to a 315 percent multiplier) where necessary 

on a project-by-project basis. For the remaining geographical areas, the 

maximum mortgage amount may be increased by up to 170 percent 

(equivalent to a 270 percent multiplier). The 315 percent multiplier is not 

available for projects in these areas. OIG provided a no position response 

regarding this notice and the corresponding ML. 

Annual indexing of basic statutory mortgage limits – On March 17, 

2022, HUD issued a notice (FR-6314-N-01), which provides adjustment 

to the basic statutory mortgage limits for multifamily housing programs 

for calendar year 2022 in accordance with Section 206A of the National 

Housing Act. HUD is also providing notice of adjustment to the per 

Multifamily housing mortgage and housing assistance restructuring 

program – On February 25, 2022, HUD issued a notice (FR-7056-N-03) 

seeking approval from OMB for the information collection on the 

multifamily housing mortgage and housing assistance restructuring 

program. This information collection is to be used for determining the 

eligibility of FHA-insured or -formerly insured multifamily properties for 

participation in the Mark-to-Market Program and the terms on which such 

participation should occur, as well as for processing eligible properties 

from acceptance into the program through closing of the mortgage 

restructure in accordance with program guidelines. OIG nonconcurred 

on this clearance item because the certification statement on various 

forms needed to be changed. OIG recommended that the forms use the 

following language for the certification statement: “I/We, the undersigned, 

certify under penalty of perjury that the information provided above is 

true and correct. WARNING: Anyone who knowingly submits a false claim 

or makes a false statement is subject to criminal and/or civil penalties, 

including confinement for up to 5 years, fines, and civil and administrative 

penalties. (18 U.S.C. §§ 287, 1001, 1010, 1012; 31 U.S.C. §3729, 3802).” 

Inclusions of certifications under penalty of perjury and fraud warnings 

help discourage fraud and help effectively prosecute those who commit 

fraud. Further, any language indicating that HUD will prosecute false 

claims and statements or similar language, if it exists in any forms or 

documents, should be removed because HUD does not prosecute. The 

U.S. Department of Justice, State, or local prosecutorial offices prosecute 

criminal matters. HUD modified the language for both the warning and 

certification statements, and the nonconcurrence was lifted.

Annual revisions to base city high-cost percentage, high-cost area, 

and per unit substantial rehabilitation threshold – On March 2, 2022, 

HUD issued notice H 2022-02 and ML 2022-05, which provide the 

revisions to the base city high-cost percentage, high-cost area, and 

per unit substantial rehabilitation for 2022. The maximum mortgage 
Legislation, Regulations, and Other Directives | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 34

appropriation acts. OIG commented that HUD should emphasize that 

grantees must be able to distinguish and document how the funds from 

each award were used. HUD did not address this comment. 

Waiver and alternative requirement related to tourism and business 

marketing (Commonwealth of Puerto Rico only) – On February 10, 

2022, HUD granted an extension of a previously granted waiver and 

alternative requirement authorizing activities related to tourism and 

business marketing for an additional 180 days for the Commonwealth 

of Puerto Rico. Puerto Rico was granted an initial waiver in an August 

2018 notice allowing it to spend $15 million on tourism and marketing 

activities. The amount was increased by $10 million in a notice published 

on February 19, 2019. The grantee may spend no more than $25 million 

on these activities. OIG did not review this issuance. 

Administrative and Other Program Areas

Comprehensive listing of transactional documents for borrowers, 

lenders, and contractors – On November 12, 2021, HUD issued a notice 

(FR-7038-N-17) informing the public that it is seeking approval from 

OMB for the information collection that includes documents related to the 

application for FHA mortgage insurance of residential care facilities and 

for servicing of the mortgages. Specifically, the documents are necessary 

for the application, review, commitment, initial and final endorsement, 

administration, servicing, technical oversight, and audit of the Office of 

Residential Care Facilities’ projects under FHA programs 232, 241, 223(f), 

223(a)(7), 223(d), and 232(i) as authorized by the National Housing 

Act (Sections 232 and 241). The issuance of this notice is modeled 

on the public review and input process that HUD used in establishing 

the healthcare facility documents for the Section 232 program. OIG 

nonconcurred on this clearance item because multiple forms contained 

the warning statement, “Warning: HUD will prosecute false claims & 

unit cost threshold for determining substantial rehabilitation in the 

multifamily housing programs under its administrative guidance for 

calendar year 2022. OIG provided a no position response regarding this 

notice.

Community Planning and Development

Applying to be a high-performing community – On January 20, 2022, 

HUD issued Notice CPD-22-03, which provides collaborative applicants 

the information necessary to understand and complete the highperforming community forms available as part of the annual Continuum 

of Care registration process. OIG provided a no position response 

regarding this notice. 

Disaster Funding

Allocations for Community Development Block Grant Disaster 

Recovery grantees and implementation of the consolidated waivers 

and alternative requirements notice – On February 3, 2022, HUD 

published FR-6303-N-1 governing the use of $5 billion made available in 

the Disaster Relief Supplemental Appropriations Act, 2022. Included in 

the notice was $7 million to be made available for capacity building and 

technical assistance, including assistance on contracting and procurement, 

to support existing and future Community Development Block Grant 

Disaster Recovery grantees and their subrecipients. The notice also 

allowed grantees that received funding under this notice and prior 

appropriations to use the funds interchangeably and without limitation 

for the same activities related to unmet recovery needs in the most 

impacted and distressed areas (MID) resulting from a major disaster in the 

Appropriation Act or in prior or future appropriation acts when the MID 

areas overlap and when the use of the funds will address unmet recovery 

needs of major disasters in the Appropriation Act or in any prior or future 
Legislation, Regulations, and Other Directives | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 35

statements, which may result in criminal conviction and/or the imposition 

of criminal fines and/or civil penalties, to the full extent allowed by law” 

or statements of similar nature. HUD does not prosecute. The U.S. 

Department of Justice, State, or local prosecutorial offices prosecute 

these matters. Thus, OIG recommended that the language be changed 

to a statement more like the following: “I/We, the undersigned, certify 

under penalty of perjury that the information provided above is true and 

correct. WARNING: Anyone who knowingly submits a false claim or makes 

a false statement is subject to criminal and/or civil penalties, including 

confinement for up to 5 years, fines, and civil and administrative penalties. 

(18 U.S.C. §§ 287, 1001, 1010, 1012; 31 U.S.C. §3729, 3802).” Inclusion of 

certifications under penalty of perjury and fraud warnings help discourage 

fraud and help effectively prosecute those who commit fraud. HUD 

modified the language, and the nonconcurrence was lifted.

HUD Office of Hearings and Appeals – On February 14, 2022, HUD 

issued final rule, FR-6285-F-01, updating HUD’s regulations in 24 CFR 

parts 14, 17, 20, 26, 28, 30, 81, 103, 180, and 570 to reflect that the 

office’s title is ‘‘Office of Hearings and Appeals,’’ as changed by the HUD 

Secretary. These HUD regulations contain outdated references to the 

‘‘Office of Administrative Law Judges,’’ ‘‘Office of Appeals,’’ and ‘‘Board of 

Contract Appeals.’’ This final rule updates HUD regulations throughout 

Title 24. While this final rule updates those sections of Title 24, there are 

other sections of Title 24 that rely on the hearing procedures at 24 CFR 

part 180. However, the other sections do not require the amendments 

made by this final rule, including 24 CFR parts 1, 3, 6, 8, and 146. These 

sections of Title 24, which implement Federal civil rights statutes, 

continue to rely on 24 CFR part 180 for administrative enforcement 

procedures. This final rule was effective March 16, 2022. OIG provided a 

no position response regarding this final rule.
Report Resolution | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 36

acquisition and disposition activities totaling more than $26.2 million.

The OIG report included a recommendation that the Deputy Assistant 

Secretary for Grant Programs direct field offices to include property 

acquisition and disposition activities as an area of special emphasis 

when assessing grantee risk and establishing their monitoring plans and 

grantee monitoring strategies. The Deputy Assistant Secretary proposed 

a management decision in December 2016. OIG rejected the proposed 

management decision because it did not specifically address directing 

field offices to include property acquisition and disposition activities as 

an area of special emphasis when assessing grantee risk and establishing 

its monitoring plans and grantee monitoring strategies as recommended. 

OIG requested clarification and documentation from HUD; however, HUD 

did not provide the requested information and documentation, and OIG 

referred this recommendation to the Assistant Secretary for Community 

Audit Reports Issued Before Start of Period 

With No Management Decision as of March 

31, 2022

HUD Did Not Always Provide Adequate Oversight of Property 

Acquisition and Disposition Activities | Issue Date: June 30, 2016

OIG audited HUD’s Community Development Block Grant (CDBG) 

program’s property acquisition and disposition activities. OIG’s objective 

was to determine whether HUD had adequate oversight of property 

acquisition and disposition activities under its CDBG program.

OIG found that HUD did not always provide adequate oversight of property 

acquisition and disposition activities. Specifically, of the 14 activities 

reviewed, 7 field offices did not provide adequate oversight of 8 property 

REPORT RESOLUTION

In the report resolution process, Office of Inspector General (OIG) and U.S. Department of 

Housing and Urban Development (HUD) management agree upon needed actions and timeframes 

for resolving recommendations. Through this process, OIG strives to achieve measurable 

improvements in HUD programs and operations. The overall responsibility for ensuring that 

the agreed-upon changes are implemented rests with HUD managers. This chapter describes 

audit and evaluation reports issued before the start of the period that do not have management 

decisions, have significantly revised management decisions, or have significant management 

decisions with which OIG disagrees. It also has a status report on HUD’s implementation of the 

Federal Financial Management Improvement Act of 1996 (FFMIA). In addition to this chapter on 

report resolution, see appendix 3, table B, “Significant Reports for Which Final Action Had Not 

Been Completed Within 12 Months After the Date of the Inspector General’s Report.”
Report Resolution | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 37

of recommendations from OIG’s audit of New Jersey’s Sandy Integrated 

Recovery Operations and Management System.3

 The General Deputy 

Assistant Secretary asserted that the legal opinion for the New Jersey 

audit applied to this audit. Based on this information, the General 

Deputy Assistant Secretary believed it was appropriate to close all of the 

recommendations. OIG disagreed with the General Deputy Assistant 

Secretary’s request to close the recommendations in this audit based 

on the Deputy Secretary’s decision to resolve recommendations from 

OIG’s audit of New Jersey’s Sandy Integrated Recovery Operations 

and Management System. OIG disagreed with the Deputy Secretary’s 

decision to resolve the recommendations from that audit. Further, the 

Deputy Secretary’s decision did not address all of the issues with HUD’s 

process for certifying State disaster grantee procurement processes 

that were identified in the subject audit report. OIG referred these 

recommendations to the Deputy Secretary on March 31, 2017, and as of 

March 31, 2022, had not received a decision. 

Audit Report: 2016-PH-0005

HUD Needs To Clarify Whether Illegal-Undocumented Aliens 

Are Eligible for Assistance Under the Housing Opportunities for 

Persons With AIDS Program | Issue Date: August 21, 2017

OIG assisted the U.S. Attorney’s Office, Southern District of New York, 

in a civil investigation related to illegal-undocumented aliens receiving 

Housing Opportunities for Persons With AIDS (HOPWA) assistance.

Noncitizen or alien ineligibility for federally funded programs is a 

recurring issue in Congress. Two laws primarily govern noncitizen or alien 

eligibility for housing programs: Title IV of the Personal Responsibility 

and Work Opportunity Reconciliation Act of 1996 - 8 U.S.C. (United States 

Code) 1611 (PRWORA) and Section 214 of the Housing and Community 

3 2015-PH-1003, dated June 4, 2015

Planning and Development on March 30, 2017. HUD proposed another 

management decision in April 2017; however, OIG rejected it because 

it also did not directly address the intent of the recommendation. OIG 

referred this recommendation to the Deputy Secretary on August 23, 

2017, and as of March 31, 2022, had not received a decision. 

Audit Report: 2016-PH-0001

HUD Did Not Always Provide Accurate and Supported 

Certifications of State Disaster Grantee Procurement Processes | 

Issue Date: September 29, 2016

OIG audited HUD’s controls over its certifications of State disaster 

recovery grantee procurement processes to determine whether HUD’s 

certifications were accurate and supported. OIG found that HUD did not 

always provide accurate and supported certifications of State disaster 

grantee procurement processes and did not have adequate controls over 

the certification process. Due to the weaknesses identified, HUD did not 

have assurance that State grantees had proficient procurement processes 

in place, and the Secretary’s certifications did not meet the intent of the 

Disaster Relief Appropriations Act of 2013.2

 

The report included five recommendations for the Deputy Assistant 

Secretary for Grant Programs, who in turn proposed corrective actions 

on January 11, 2017. OIG rejected the proposed actions on January 

27, 2017. OIG referred the recommendations to the General Deputy 

Assistant Secretary for Community Planning and Development on 

February 6, 2017. The General Deputy Assistant Secretary responded 

to the referral on February 21, 2017. For all of the recommendations, 

the General Deputy Assistant Secretary stated that OIG’s disagreement 

was closed by the Deputy Secretary in her decision regarding resolution 

2 Public Law 113-2, dated January 29, 2013
Report Resolution | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 38

to determine whether HUD provided sufficient guidance and oversight to 

ensure that disaster grantees followed proficient procurement processes 

when purchasing products and services. OIG found that HUD did not 

provide sufficient guidance and oversight to ensure that State disaster 

grantees followed proficient procurement processes. Since HUD agreed 

to correct procurement issues from a previous audit,4

 OIG has issued 17 

audit reports on disaster grantees with questioned costs totaling nearly 

$391.7 million related to procurement. 

In this audit, OIG made four recommendations to the Deputy Assistant 

Secretary for Grant Programs, who in turn proposed corrective actions 

on November 24, 2017. For two of the recommendations, the Deputy 

Assistant Secretary stated that the matter of the applicability of the Federal 

procurement standards at 2 CFR (Code of Federal Regulations) 200.318 

through 200.3265

 (or 24 CFR 85.36(b) through (i)) and the requirements 

of the Federal Register notices on procurement was closed by the Deputy 

Secretary in her decision regarding resolution of recommendations from 

OIG’s audit of New Jersey’s Sandy Integrated Recovery Operations and 

Management System.6

 In the January 10, 2017, decision, the Deputy 

Secretary wrote that the State had certified that its procurement standards 

were equivalent to the standards at 24 CFR 85.36 and HUD had also 

certified to the proficiency of the State’s policies and procedures. 

The Deputy Assistant Secretary also noted that the Senate 

Appropriations Committee report on fiscal year 2018 U.S. Department 

4 Audit Report 2013-FW-0001, Generally, HUD’s Hurricane Disaster Recovery Program 

Assisted the Gulf Coast States’ Recovery; However, Some Program Improvements Are 

Needed, issued March 28, 2013

5 Before December 26, 2014, the relevant procurement requirements were found at 24 

CFR 85.36. HUD has since moved its uniform administrative requirements, cost principles, and audit requirements for Federal awards to 2 CFR part 200.

6 2015-PH-1003, dated June 4, 2015

Development Act of 1980, as amended. PRWORA states that illegal aliens 

do not meet the definition of qualified aliens and as a result, are ineligible 

for Federal public benefits. However, PRWORA exempted certain Federal 

public benefits from the alien eligibility restrictions, and the issue of 

nonqualified aliens receiving assistance under HOPWA or other homeless 

assistance programs has not been clearly addressed in HUD regulations 

and guidance. There is a conflict as to whether “housing assistance” and 

“homeless assistance” are synonymous. OIG recommended that HUD’s 

Office of Community Planning and Development (CPD) (1) clarify whether 

assistance provided under its community development programs, such 

as HOPWA, are considered “Federal public benefits” and are, therefore, 

subject to PRWORA’s noncitizen eligibility restrictions and (2) consult with 

the Office of the Attorney General to establish whether HOPWA and other 

homeless assistance programs are a Federal public benefit that meets the 

definition of “providing assistance for the protection of life or safety” and 

are, therefore, exempt from PRWORA noncitizen eligibility restrictions.

CPD submitted management decisions for both recommendations on 

December 18, 2017, but the management decisions stated that CPD was 

not able to act on the recommendations, and OIG rejected them. This 

issue was referred to the Assistant Secretary for Community Planning and 

Development on December 19, 2017. In January 2018, OIG attempted 

to meet with HUD regarding the recommendations but was unsuccessful. 

The issue was referred to the Deputy Secretary on February 27, 2018. As 

of March 31, 2022, OIG was awaiting a decision from the Deputy Secretary. 

Audit Memorandum: 2017-CF-0801

HUD Did Not Provide Sufficient Guidance and Oversight To 

Ensure That State Disaster Grantees Followed Proficient 

Procurement Processes | Issue Date: September 22, 2017

OIG audited HUD’s oversight of disaster grantee procurement processes 
Report Resolution | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 39

OIG found that HUD could improve its oversight of the disposition of real 

properties assisted with CDBG funds. Although HUD’s drawdown and 

reporting system allowed grantees to enter identifying information for 

assisted properties and its field offices performed risk-based monitoring 

of grantees, HUD’s controls were not always sufficient, and HUD did not 

fully implement guidance related to the applicability of change of use 

requirements after voluntary grant reductions. As a result, HUD could 

not track and monitor its interest in the properties and did not have 

assurance that grantees properly handled changes in use and properly 

reported program income. OIG recommended that the Deputy Assistant 

Secretary for Grant Programs develop a process to ensure that grantees 

properly report the addresses of assisted properties in HUD’s Integrated 

Disbursement and Information System and properly calculate and report 

program income from the disposition of these properties regularly. 

The Deputy Assistant Secretary proposed a management decision in 

January 2018, which OIG rejected. OIG referred this recommendation 

to the Assistant Secretary for Community Planning and Development on 

February 6, 2018, and to the Deputy Secretary on March 26, 2018. To 

reach agreement, OIG held discussions with CPD officials on February 13 

and March 8, 2018. On March 28, 2018, the Deputy Assistant Secretary 

submitted a revised proposal; however, OIG rejected HUD’s proposal. 

In January 2021, OIG met with HUD to discuss a possible management 

decision. On March 8, 2021, CPD indicated that it was working on an 

updated proposal that would address the concerns discussed. As of 

March 31, 2022, OIG was awaiting an updated proposal from CPD. 

Audit Report: 2017-NY-0002

of Transportation-HUD appropriations legislation7

 addressed this issue. 

In addition, the Deputy Assistant Secretary stated that HUD clarified its 

definition of proficient procurement processes and policies in Federal 

Register notices that it published for later disasters. Based on this 

information, the Deputy Assistant Secretary believed it was appropriate 

to close these two recommendations. OIG disagreed with the Deputy 

Assistant Secretary’s request to close these two recommendations 

based on the Deputy Secretary’s decision to resolve recommendations 

from OIG’s audit of New Jersey’s Sandy Integrated Recovery Operations 

and Management System and rejected the Deputy Assistant Secretary’s 

request to close the recommendations. 

OIG also rejected the proposed management decisions for the other 

two recommendations because the proposed actions did not address 

States that chose to certify that their procurement processes and 

standards were equivalent to the Federal procurement standards at 

2 CFR 200.318 through 200.326. OIG referred the recommendations 

to the Assistant Secretary for Community Planning and Development 

on January 25, 2018. The Assistant Secretary did not respond. OIG 

referred these recommendations to the Deputy Secretary on March 16, 

2018, and as of March 31, 2022, had not received a decision. 

Audit Report: 2017-PH-0002

HUD Could Improve Its Controls Over the Disposition of Properties 

Assisted With CDBG Funds | Issue Date: September 29, 2017

OIG audited HUD’s oversight of the disposition of real properties assisted 

with CDBG funds. OIG’s objective was to determine whether HUD had 

adequate controls over the disposition of real properties assisted with 

CDBG funds. 

7 Senate Report 1115-138, dated July 27, 2017
Report Resolution | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 40

The State of New York Did Not Ensure That Properties Purchased 

Under the Acquisition Component of Its Program Were Eligible | 

Issue Date: March 29, 2019

OIG audited the State of New York’s CDBG-DR-funded New York Rising 

Buyout and Acquisition program. OIG’s objective was to determine 

whether the State ensured that properties purchased under the 

acquisition component of the program met applicable HUD, Federal, and 

State requirements. 

OIG found that the State did not ensure that properties purchased under 

the acquisition component of its program met eligibility requirements. 

Specifically, it did not ensure that properties (1) were substantially 

damaged and (2) complied with flood hazard requirements. Further, 

it may have improperly purchased properties that did not comply with 

flood insurance requirements. As a result, the State disbursed more than 

$3.5 million for ineligible properties and incentives and more than $5.9 

million for properties that it could not show met applicable requirements, 

and HUD did not have assurance that CDBG-DR funds were used for their 

intended purpose. OIG recommended that HUD require the State to (1) 

reimburse more than $3.5 million in settlement costs and incentives paid 

for properties that did not meet eligibility requirements or should not 

have received incentives; (2) provide documentation showing that 15 

properties met requirements related to substantial damage, flood hazards, 

and flood insurance or reimburse more than $5.9 million paid to purchase 

the properties; and (3) conduct a review of the other properties purchased 

under its program to ensure that properties were eligible and reimburse 

the amount paid for any additional properties found to be ineligible. 

The Principal Deputy Assistant Secretary for Community Planning and 

Development proposed management decisions on October 8, 2019. OIG 

rejected the proposed actions and referred the recommendations to 

the Assistant Secretary for Community Planning and Development on 

HUD’s Office of Block Grant Assistance Had Not Codified the 

Community Development Block Grant Disaster Recovery 

Program | Issue Date: July 23, 2018

OIG audited the HUD Office of Block Grant Assistance’s (OBGA) CDBG 

Disaster Recovery (CDBG-DR) program and found that although OBGA 

had managed billions in CDBG-DR funds since 2002, it had not codified 

the program, because it did not believe it had the authority to do so. 

However, OBGA’s use of multiple Federal Register notices to operate the 

program presented challenges to the grantees. For example, 59 grantees 

with 112 active CDBG-DR grants, which totaled more than $47.4 billion as 

of September 2017, had to follow requirements contained in 61 different 

Federal Register notices to manage the program. 

In April 2019, OBGA acknowledged that the issuance of multiple Federal 

Register notices created a compliance burden for CDBG-DR grantees, but 

it disagreed that codification was necessary. OBGA made the following 

statements to support why it will not implement the recommendation: 

(1) codification is not necessary, (2) Federal Register notices are 

required, and (3) codification has limited or no applicability for future 

disasters. On September 30, 2019, OIG referred the disagreement and 

recommendation to the Deputy Secretary for resolution and, as of March 

31, 2022, was awaiting a decision. 

Audit Report: 2018-FW-0002
Report Resolution | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 41

17, September 10, and September 24, 2019, but did not reach an 

agreement. As a result, OIG referred the 10 recommendations to 

the Assistant Secretary for Community Planning and Development on 

October 3, 2019, and held a discussion with CPD officials on November 

21, 2019, but when agreement was not reached, OIG referred the 

recommendations to the Deputy Secretary on February 20, 2020. In 

June 2021, OIG provided CPD with requested documentation to assist 

with preparation of the management decisions. As of March 31, 2022, 

OIG was awaiting a decision while continuing to work with CPD. 

Audit Report: 2019-NY-1002

HUD Paid Rental Subsidies To Benefit Public Housing and 

Voucher Tenants Reported as Excluded From Federal Programs or 

Deceased | Issue Date: June 25, 2019

OIG audited HUD to determine whether HUD provided public housing 

agencies (PHA) with access to the information contained in the Do Not 

Pay system. Do Not Pay is a collection of data sources, one of which is 

the General Services Administration’s System for Award Management 

(SAM) database of excluded parties. OIG found that HUD paid potentially 

improper rental subsidies to benefit 1,550 tenants who were reported as 

excluded from Federal programs. 

OIG recommended that HUD issue guidance to PHAs to ensure that 

any applicant for or tenant of public or assisted housing whose 

name appears on the SAM excluded parties list is reviewed by PHAs 

to determine eligibility, per the requirements of 2 CFR parts 180 

and 2424. By doing so, ineligible applicants or tenants would not be 

admitted or recertified, which could result in $13.7 million in annual 

rental subsidies being put to better use. In its October 8, 2019, 

management decision, the Office of Public and Indian Housing (PIH) 

disagreed with this recommendation and submitted a legal opinion 

September 30, 2020. As of March 31, 2022, CPD was working to update 

its proposed management decisions in conjunction with its work related 

to audit report 2019-NY-1002. OIG will continue to communicate with 

CPD to attempt to reach an agreement. If OIG is unable to reach an 

agreement with CPD, OIG will refer the recommendations to the Deputy 

Secretary for a decision. 

Audit Report: 2019-NY-1001

The State of New York Did Not Ensure That Appraised Values Used 

by Its Program Were Supported and Appraisal Costs and Services 

Complied With Requirements | Issue Date: May 29, 2019

OIG audited the State of New York’s CDBG-DR-funded New York Rising 

Buyout and Acquisition program. OIG’s objectives were to determine 

whether the State ensured that (1) the appraised fair market values used 

to determine award amounts under its program were supported and (2) 

appraisal costs for its program complied with applicable requirements 

and were for services performed in accordance with Federal, State, and 

industry standards. OIG found that HUD and the State did not have 

assurance that (1) more than $367.3 million paid to purchase properties 

was supported; (2) more than $3.4 million disbursed for appraisal 

services was for costs that were reasonable, necessary, and adequately 

documented; and (3) appraisal services were properly procured and 

performed. OIG provided 10 recommendations to the State to provide 

support for appraised fair market values, appraisal prices, and other 

expenses related to more than $370 million in unsupported costs and 

to improve controls over its program, which can ensure that up to $93.4 

million not yet disbursed is put to better use. 

The Deputy Assistant Secretary for Grant Programs did not propose 

management decisions to address the 10 recommendations contained 

in the audit report. OIG held discussions with CPD officials on June 
Report Resolution | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 42

Evaluation Reports Issued Before Start of 

Period With No Management Decision as of 

March 31, 2022

Risk-Based Enforcement Could Improve Program Effectiveness | 

Issue Date: February 12, 2016

OIG evaluated the effectiveness of the Departmental Enforcement Center 

(DEC). Historically, HUD program managers have not wanted to enforce 

program requirements. That reluctance increases the risk that program 

funds will not provide maximum benefits to recipients and allows 

serious noncompliances to go unchecked. When it was created, DEC 

had independent enforcement authority, but it lost that authority when 

it moved from the Deputy Secretary’s office to OGC. DEC lost control of 

funding and staffing levels and contended with inadequate information 

technology (IT) systems and support. Although program offices were 

asking for more DEC financial analyses, they did not consistently use 

enforcement actions to remedy noncompliances. Further, managers’ 

reluctance to enforce program requirements limited DEC’s effectiveness 

in most programs. OIG concluded that turnover, retirements, and 

hiring limitations could leave DEC without enough skilled staff to 

support future workloads needed to service HUD programs and enforce 

program requirements. Risk-based monitoring and enforcement offers 

the opportunity to provide quality, affordable rental housing, improve 

the quality of life, and build strong, resilient communities. 

OIG made eight recommendations, one of which remains open. 

OIG had not reached an agreed-upon management decision 

for this recommendation. The remaining open recommendation 

states that HUD needs to strengthen DEC’s authority to enforce 

program requirements. In April 2019, OIG changed the status of this 

recommendation to resolved-open based on HUD’s proposed actions in 

response to a U.S. Government Accountability Office report. However, 

from HUD’s Office of General Counsel (OGC) in support of its position. 

OIG rejected this management decision because it does not resolve 

the recommendation. OIG continues to recommend that HUD issue 

guidance to PHAs to ensure that any applicant for or tenant of public or 

assisted housing whose name appears on the SAM excluded parties list 

is reviewed by PHAs to determine eligibility. Because OIG did not reach 

agreement with the Deputy Assistant Secretary for Public Housing and 

Voucher Programs, on February 19, 2020, OIG referred its disagreement 

to the Assistant Secretary for Public and Indian Housing. However, 

OIG did not reach agreement with the Assistant Secretary on the 

corrective actions identified in the report. Therefore, OIG referred the 

recommendation to the official serving as Deputy Secretary on March 

31, 2020, for his final decision as the Departmental Audit Resolution 

Official. HUD began scheduling regular meetings with OIG during 2021 

to attempt to reach a resolution; however OIG and HUD have not had a 

meeting on this topic since February 2021. As of March 31, 2022, OIG 

had not received a decision from the Deputy Secretary. 

Audit Report: 2019-KC-0002
Report Resolution | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 43

HUD IT System Management and Oversight of the Section 184 

Program | Issue Date: August 13, 2018

OIG evaluated the IT systems supporting the Office of Native American 

Programs (ONAP), Indian Home Loan Guarantee Program (Section 

184 program), following concerns that HUD did not use its resources 

to address shortcomings in internal controls and lacked the ability to 

deploy a reliable IT system. OIG observed that (1) a newly developed 

IT system, called the Loan Origination System (LOS), had significant 

limitations, requiring lenders and program officials to continue to use 

a HUD legacy IT system and manual processes for maintaining files, 

servicing loans, and managing claims; (2) only 1 of 38 lenders was able 

to access and use LOS due to HUD’s inability to resolve and implement a 

user access solution; (3) LOS had no capability to conduct loan servicing 

and claims, which were still conducted using Excel spreadsheets; and 

(4) LOS lacked critical management reporting capabilities. Despite 

HUD’s investing $4 million into the development of LOS, the system did 

not satisfy all management and oversight objectives.

OIG made five recommendations. HUD and ONAP concurred with all 

five recommendations in August 2018 with a suspense of November 

26, 2018, to provide OIG with management decisions. In addition, 

two recommendations were closed during the previous semiannual 

reporting period due to the progress of OCIO’s implementing electronic 

document capabilities and resolving the lender access issue using 

the FHA Catalyst IT system. Three recommendations remained open, 

with HUD providing closure requests for all three. Despite the closure 

requests, OIG lacked an approved management decision. 

(Evaluation Report: 2018-OE-0004)

after reviewing the protocols developed between DEC and PIH, OIG 

determined that the protocol does not strengthen DEC’s authority to 

enforce program requirements or include provisions for DEC to make 

independent assessments. Therefore, OIG changed the status of this 

recommendation to unresolved-open. On March 31, 2020, OIG referred 

this recommendation to the Deputy Secretary for final action. OIG was 

awaiting a response from the Deputy Secretary on the final action. 

(Evaluation Report: 2014-OE-0002)

HUD Web Application Security Evaluation | Issue Date: June 6, 

2018

OIG completed a targeted web application security evaluation of HUD in 

support of a Counsel of the Inspectors General on Integrity and Efficiency 

(CIGIE) Federal cross-cutting project, making nine recommendations 

for improvement to HUD. OIG assessed HUD’s capability to identify 

and mitigate critical IT vulnerabilities in its publicly accessible web 

applications. OIG identified key deficiencies in HUD’s practices that 

put HUD’s extensive collection of sensitive data, including personal 

information of private citizens, at increased risk of unauthorized 

access and compromise. Of particular concern was the discovery of 

multiple operating web applications unknown to the Office of the Chief 

Information Officer (OCIO). 

On June 2, 2017, HUD concurred with all recommendations and agreed 

to work with OIG to assign responsibility and complete resolution. OIG 

concurred to close five recommendations based on HUD OCIO closure 

requests and associated evidence during the previous semiannual 

reporting period, leaving four open recommendations. OIG had not 

received management decisions for these four recommendations. 

(Evaluation Report: 2016-OE-0002)
Report Resolution | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 44

Deputy Secretary’s approval. Therefore, based on HUD’s entry in its 

Audit Resolution and Corrective Action Tracking System, OIG wrote 

off the outstanding balances totaling $293,544 for recommendation 

3A and $331,665 for recommendation 3B and closed the 

recommendations accordingly. 

Audit Report: 2002-AT-1002

The Housing Authority of City of Durham, Durham, NC | Issue 

Date: November 19, 2004

OIG audited the Durham, NC, Housing Authority’s financial operations 

and procurement procedures. OIG initiated the audit based on potential 

deficiencies noted in a previous audit. The audit objectives were to 

determine whether the Authority’s misuse of funds jeopardized its 

ability to operate its projects in a manner that promotes serviceability, 

economy, efficiency, and stability and whether the Authority followed 

HUD procurement regulations.

The Authority jeopardized project stability by misusing funds to 

subsidize operations of Development Ventures, Inc. (DVI), a nonprofit 

subsidiary. As of June 30, 2004, DVI owed $4.1 million to the Authority. 

At its current rate of spending, it was estimated that the Authority had 

enough funds to continue operations for about 7 months. The Authority 

inappropriately procured about $6.9 million and could not support 

another $953,000 for goods and services. In OIG’s opinion, the Authority 

could increase the effectiveness of its procurement activities for the 

$2.2 million in capital funds by developing and implementing improved 

procurement procedures that comply with procurement regulations. OIG 

issued nine recommendations, of which two questioned costs and two 

identified funds to be put to better use. Specifically, in recommendation 

2E, which questioned costs, OIG recommended that HUD require the 

Authority to repay its program more than $6.8 million spent for ineligible 

Significantly Revised Management Decisions

Section 5(a)(11) of the Inspector General Act, as amended, requires 

that OIG report information concerning the reasons for any significantly 

revised management decisions made during the reporting period. 

During the current reporting period, there were four significantly revised 

management decisions.

The Housing Authority of the City of Tupelo, Housing Programs 

Operations, Tupelo, MS | Issue Date: July 3, 2002

Due to HUD’s concerns with the Authority’s questionable financial 

condition and its involvement with a limited partnership, OIG completed 

an audit of the Housing Authority of the City of Tupelo’s operations. 

OIG’s objectives were to determine whether the Authority operated 

its housing activities in accordance with HUD requirements and had 

established controls to ensure the effective and efficient administration 

of program funds.

OIG determined that the Authority (1) improperly advanced public 

housing program funds for non-Federal development activities, (2) did 

not maintain its conventional low-income housing in good repair and 

condition, (3) did not spend its Comprehensive Grant Program funds as 

approved, (4) inappropriately pledged its assets as collateral for loans; 

and (5) did not adequately control its appliance inventory. OIG issued 

16 recommendations, 4 of which disallowed certain costs. 

Upon the request of the Assistant Secretary for Public and Indian 

Housing, HUD’s former Deputy Secretary approved the forgiveness 

of the disallowed costs in four recommendations due to the unique 

situation. Specifically, the Authority lacked meaningful non-Federal 

funds sources to practically accomplish even a repayment agreement. 

OIG’s former Assistant Inspector General for Audit concurred with the 
Report Resolution | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 45

provide support for $316,883 disbursed for unsupported costs or return 

the funds to the project operating account. In its original management 

decision, HUD planned to send a letter demanding either documentation 

supporting the costs or repayment of any unsupported or ineligible costs. 

On March 16, 2022, HUD submitted a revised recommendation, which 

stated that DEC had settled for $80,000 and no further collections could 

take place due to the binding legal settlement agreement. On March 21, 

2022, OIG concurred with the revised management decision. 

Audit Report: 2013-KC-1003 

Final Civil Action: Owner of HUD-Insured Multifamily Property 

Settled Allegations of Authorizing and Paying Out Project Funds 

for Unallowable Expenses | Issue Date: September 30, 2015, 

Revised November 4, 2015

OIG performed a review of The Retreat at Church Ranch bank records 

based on OIG’s audit of the project. OIG’s review disclosed that the 

owner allegedly made payments for personal expenses from the project’s 

bank account. OIG requested that HUD pursue proceedings against the 

owner. On March 31, 2015, HUD filed a complaint seeking more than 

$12.9 million in civil money penalties against the owner. The owner 

denied HUD’s allegations. However, to avoid the uncertainty of litigation 

and to arrive at a settlement that was satisfactory to both parties, the 

parties negotiated in good faith and reached a settlement in which the 

owner will pay HUD $500,000. On October 26, 2021, HUD submitted 

a revised management decision, explaining that due to a change in 

the owner’s ability to pay the full amount, HUD elected to enter into 

a revised settlement agreement with the owner for the payment of 

$154,000. HUD stated that it believed this was a substantial recovery for 

HUD, given the owner’s reduced ability to pay. On November 2, 2021, 

OIG concurred with the revised management decision. 

Audit Report: 2015-DE-1802

procurements and stated that the repayment should be from non-Federal 

funds and paid in the following amounts and to the following programs: 

Conventional Public Housing General Fund $2.8 million, Capital Fund 

$3.6 million, HOPE VI $259,289, Section 8 $115,128, Drug Elimination 

$12,048, Economic Development Support Services $13,831, and the 

Turnkey III program $6,429.

While HUD agreed with OIG on requiring the recommended repayments 

from the Authority, it revised its management decision, identifying a 

portion of the questioned costs to be returned to HUD as opposed to 

the specified programs in recommendation 2E because the programs no 

longer exist. With an effective date of December 23, 2021, OIG agreed to 

HUD’s revised management decision, reclassified $92,350 to be returned 

to HUD, and kept the remaining outstanding funds totaling more than 

$6.8 million as payable to the applicable programs. 

 Audit Report: 2004-AT-1004 

The Temtor Disbursed Project Funds for Ineligible and 

Unsupported Expenses | Issue Date: August 8, 2013

OIG audited the Temtor project in St. Louis, MO. The project reached 

final endorsement on January 30, 2012, and failed to make timely 

mortgage payments beginning March 1, 2012. OIG’s audit objective was 

to determine whether the Temtor’s project funds were used for ineligible 

expenses. OIG found that the Temtor used project funds for ineligible and 

unsupported expenses, including payments of developer fees, unsecured 

loans, and excessive funds to the management agent. In addition, the 

Temtor transferred funds out of its tenant security deposit reserve account 

and submitted incorrect accounting reports that concealed the transfers. 

OIG recommended that HUD require the project owners to return 

$401,705 in ineligible disbursements to the project operating account and 
Report Resolution | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 46

Significant Management Decision With 

Which OIG Disagrees

Section 5(a)(12) of the Inspector General Act, as amended, requires that 

OIG report information concerning any significant management decision 

with which OIG disagrees. 

During the reporting period, there were no audit reports in which OIG 

disagreed with the significant management decisions.

Federal Financial Management Improvement Act of 1996

Section 803(a) of FFMIA requires that each agency establish and maintain 

financial management systems that comply with (1) Federal financial 

management system requirements, (2) Federal accounting standards, and 

(3) the United States Standard General Ledger at the transaction level. 

Section 803(c) of FFMIA requires an agency to establish a remediation 

plan if it is determined that the agency’s financial management systems 

do not comply with the requirements of section 803(a). Section 804(b) 

of FFMIA requires OIG to report in its semiannual reports to Congress 

instances and reasons when an agency has not met the intermediate 

target dates established in its remediation plans.

As of March 31, 2022, OIG and HUD had identified noncompliance with 

the three section 803(a) elements of FFMIA. Specifically, there was one 

financial system, the Tenant Rental Assistance Certification System (TRACS),

that was noncompliant with the three section 803(a) requirements. While 

the Office of Housing expected to complete TRACS remediation activities 

in fiscal year 2022 (March 21, 2021), the timeline to address TRACS’ FFMIA 

noncompliance has been pushed back to fiscal year 2023 (December 

31, 2022) as the new TRACS release needs to address the Office of Asset 

Management and Portfolio Oversight’s Housing Opportunity Through 

Modernization Act of 2016 Final Rule and Requirements. 
Whistleblower Protection Coordinator | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 47

WHISTLEBLOWER 

PROTECTION 

COORDINATOR

Whistleblowers play a critical role in keeping our Government programs honest, efficient, and 

accountable. The U.S. Department of Housing and Urban Development, Office of Inspector 

General (HUD OIG), continues to ensure that HUD and OIG employees are aware of their rights 

to disclose misconduct, waste, or abuse in HUD programs without reprisal and to assist HUD 

and OIG employees in seeking redress when employees believe that they have been subject to 

retaliation for whistleblowing. OIG also investigates complaints of whistleblower retaliation by 

Government contractors and grantees.

OIG’s Whistleblower Protection Coordinator works with HUD and OIG 

employees to provide information on

• options for disclosing misconduct, waste, or abuse in HUD 

programs; 

• statutory protections for Federal employees who make such 

disclosures; and

• how to file a complaint when an employee believes he or she has 

been retaliated against for making protected disclosures.

The OIG Whistleblower Protection Coordinator has continued to focus 

on staff training and individual assistance. The 2021 mandatory 

whistleblower training for OIG personnel was an interactive, virtual 

training experience about whistleblower rights and protections, making 

protected disclosures, and making disclosures about investigative 

agencies such as OIGs. Completion of the course was due by March 7, 

2022. 

The Whistleblower Protection Coordinator meets with HUD employees 

individually, upon request. Generally, OIG will refer HUD employees with 

whistleblower retaliation complaints to the U.S. Office of Special Counsel 

(OSC). 

OIG received several complaints filed under 41 U.S.C. (United 

States Code) Section 4712. In December 2016, Congress passed 

the Enhancement of Whistleblower Protection Act. It made the 

whistleblower protections under Section 4712 permanent. Section 4712 

extends whistleblower protection to employees of Federal contractors, 

subcontractors, grantees, and subgrantees. If the employee of a HUD 

grantee or contractor believes he or she has been retaliated against for 
Whistleblower Protection Coordinator | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 48

whistleblowing, the employee may file a complaint with OIG, and OIG 

will investigate the complaint and either close the complaint for failure 

to meet the elements prescribed in Section 4712 or provide a report of 

findings to HUD.

The chart below provides further information on those complaints.

Number of complainants asserting 

whistleblower status8

 73

Complaints declined by the Office of 

Investigation (OI) 42

Complaints accepted for further review 29

Complaints currently under review by OI 2

Employee complaints referred to OSC 0

Contractor disclosure complaints reviewed 1

8 Not all complainants are found to be whistleblowers under Section 4712. For example, 

many complainants raise questions regarding treatment by public housing agencies 

(PHA) following their alleged disclosures of wrongdoing by the same PHA. They claim 

to be whistleblowers, but they are not employees of the grantee. These complaints are 

referred to OIG’s hotline for appropriate referral and disposition. 
Peer Review | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 49

PEER REVIEW

BACKGROUND. The Dodd-Frank Wall Street Reform and Consumer Protection Act (Public Law 

No. 111-203), section 989C, requires inspectors general to report the latest peer review results 

in their semiannual reports to Congress. The purpose in doing so is to enhance transparency 

within the Government. Both the Office of Audit and Office of Investigation are required to 

undergo a peer review of their individual organizations every 3 years. The purpose of the review 

is to ensure that the work completed by the respective organizations meets the applicable 

requirements and standards. The following is a summary of the status of the latest round of 

peer reviews for the organization. 

OFFICE OF AUDIT

Peer Review Conducted on HUD OIG by USAID OIG

The U.S. Department of Housing and Urban Development, Office of 

Inspector General (HUD OIG), received a grade of pass (the highest 

rating) on the peer review report issued by the U.S. Agency for 

International Development (USAID) OIG on December 17, 2021. There 

were no recommendations included in the System Review Report. The 

report stated: 

In our opinion, the system of quality control for the audit organization of 

HUD OIG in effect for the year ended March 31, 2021, has been suitably 

designed and complied with to provide HUD OIG with reasonable 

assurance of performing and reporting in conformity with applicable 

professional standards and applicable legal and regulatory requirements 

in all material respects. Audit organizations can receive a rating of pass, 

pass with deficiencies, or fail. HUD OIG has received an External Peer 

Review rating of pass.

Peer Review Conducted by HUD OIG on DoD OIG

HUD OIG conducted an external peer review of the U.S. Department of 

Defense (DoD) OIG, Office of Audit, and issued a final report on September 

27, 2018. DoD OIG received a peer review rating of pass. A copy of the 

external quality control review report can be viewed at https://media.

defense.gov/2018/Oct/05/2002048826/-1/-1/1/TRANSMITTAL%20

MEMO%20AND%20SYSTEM%20REVIEW%20REPORT.PDF.

OFFICE OF INVESTIGATION

Peer Review Conducted on HUD OIG by DHS OIG 

The U.S. Department of Homeland Security (DHS) OIG conducted a peer 

review of the HUD OIG, Office of Investigation, and issued a final report on 

July 3, 2017. DHS OIG determined that HUD OIG was in compliance with 

the quality standards established by the Council of the Inspectors General 

on Integrity and Efficiency (CIGIE) and the Attorney General’s guidelines.
Peer Review | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 50

Peer Review Conducted by HUD OIG on DHS OIG 

HUD OIG conducted an external peer review of the DHS OIG, Office 

of Investigation, and issued a final report on June 5, 2020. OIG 

determined that DHS OIG was in compliance with the quality standards 

established by CIGIE.

OFFICE OF EVALUATION

Peer Review Conducted on HUD OIG by CIGIE Team 

On March 12, 2020, a CIGIE external review team reviewed the HUD OIG, 

Office of Evaluation. The team concluded that the Office of Evaluation’s 

policies and procedures generally complied with the Quality Standards 

for Inspection and Evaluation. The team also offered observations 

regarding four reports reviewed. The peer review team observed that all 

reviewed reports did not fully follow established quality control policies 

and procedures. However, the Office of Evaluation made changes to its 

policies and procedures and reporting approaches to address the team’s 

observations. A copy of the report can be viewed at https://www.hudoig.

gov/sites/default/files/2020-05/HUD%20OIG%20Evaluation%20Peer%20

Review_20200512.pdf. 

Peer Review Conducted by HUD OIG on FHFA OIG 

HUD OIG conducted an external peer review of the Federal Housing 

Finance Agency (FHFA) OIG’s inspection and evaluation functions and 

issued a final report on September 10, 2019. A copy of the external 

quality control review report can be viewed at https://www.fhfaoig.

gov/sites/default/files/Final%20Report%20-%20External%20Peer%20

Review%20of%20FHFA%20OIG.pdf.
Appendixes | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 51

APPENDIXES

APPENDIX 1: Reports Issued

APPENDIX 2: Tables

APPENDIX 3: Inspector General Empowerment Act

APPENDIX 4: Reporting Requirements

APPENDIX 5: Acronyms and Abbreviations

APPENDIX 6: OIG Directory
Appendix 1: reports Issued | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 52

Appendix 1 - Reports Issued

Internal Audit Reports Issued

Chief Financial Officer

2022-FO-0001 HUD’s Office of the Chief Financial Officer Generally Complied With the Digital Accountability and Transparency Act of 2014, With 

a Few Exceptions, 11/08/2021.

2022-FO-0004 Independent Public Accountant’s Audit Report on the U.S. Department of Housing and Urban Development’s Fiscal Years 2021 

and 2020 Consolidated Financial Statements, 12/09/2021.

2022-NY-0001 HUD Did Not Implement Adequate Grant Closeout and Reporting Processes To Ensure Consistent Application of GONE Act 

Requirements, 03/09/2022.

Community Planning and Development

2022-AT-0001 Opportunities Exist To Improve CPD’s Oversight of and Monitoring Tools for Slow-Spending Grantees, 01/05/2022.

Government National Mortgage Association

2022-FO-0002 Transmittal of Independent Public Accountant’s Audit Report on the Government National Mortgage Association Fiscal Years 2021 

and 2020 Financial Statements, 11/16/2021.
Appendix 1: reports Issued | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 53

Internal Audit Reports Issued (Continued)

Housing

2022-FO-0003 Independent Public Accountant’s Audit Report on the Federal Housing Administration’s Fiscal Years 2021 and 2020 Consolidated 

Financial Statements, 12/09/2021.

2022-KC-0001 FHA Borrowers Did Not Always Properly Receive COVID-19 Forbearances From Their Loan Servicers, 12/15/2021. Better use: 

$5,430,000,000.

2022-KC-0002 Approximately 31,500 FHA-Insured Loans Did Not Maintain the Required Flood Insurance Coverage in 2020, 03/22/2022. Better 

use: $1,507,978,632.

2022-LA-0001 HUD Did Not Have Adequate Controls in Place To Track, Monitor, and Issue FHA Refunds Owed to Homeowners, 01/07/2022.

Office of Administration

2022-CH-0002 HUD Did Not Always Comply With Its Internal Guide When Transitioning Offices From Mandatory to Maximum Telework During 

the COVID-19 Pandemic, 02/15/2022.

Public and Indian Housing

2022-BO-0001 HUD Did Not Have Adequate Policies and Procedures for Ensuring That Public Housing Agencies Properly Processed Requests for 

Reasonable Accommodation, 02/07/2022.
Appendix 1: reports Issued | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 54

Audit-Related Memorandums9

Community Planning and Development

2022-FO-0801 Fraud Risk Inventory for the CDBG and ESG CARES Act Funds, 10/12/2021.

2022-FW-0801 Lessons Learned and Key Considerations From Prior Audits and Evaluations of the CDBG Disaster Recovery Program, 11/02/2021.

Housing

2022-KC-0801 COVID-19: Challenges Faced by Section 232 Nursing Homes During the Pandemic, 03/29/2022.

2022-PH-0801 HUD Did Not Always Implement Corrective Actions To Further Ensure That HECM Borrowers Complied With Principal Residency 

Requirements, 12/10/2021.

Public and Indian Housing

2022-CH-0801 Public Housing Agencies’ Experiences and Challenges Regarding the Administration of HUD’s CARES Act Funds, 11/16/2021.

2022-LA-0801 Evaluating Public Housing Agency Challenges With the HUD Veterans Affairs Supportive Housing Program, 11/30/2021.

9 The memorandum format is used to communicate the results of reviews not performed in accordance with generally accepted government audit standards; to close out assignments 

with no findings and recommendations; to respond to requests for information; or to report on the results of a survey, an attestation engagement, or civil actions or settlements.
Appendix 1: reports Issued | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 55

External Audit Reports

Community Planning and Development

2022-AT-1001

The State of Florida Administered Its Housing Repair and Replacement Program Effectively but Not Always in a Cost-Efficient 

and Prudent Manner for the Projects and Activity Delivery Costs Reviewed, 03/30/2022. Questioned: $107,036. Unsupported: 

$107,036. 

2022-FW-1001 The City of Houston, Houston, TX, Faced Challenges in Administering Its Hurricane Harvey Program and Risked Losing Its Funding, 

01/04/2022.

2022-LA-1001 The Los Angeles Homeless Services Authority, Los Angeles, CA, Did Not Always Administer Its Continuum of Care Program in 

Accordance With HUD Requirements, 01/20/2022. Questioned: $879,847. Unsupported: $879,847. Better use: $3,500,000.

Public and Indian Housing

2022-NY-1001 The Buffalo Municipal Housing Authority, Buffalo, NY, Needs To Improve Its Management of the Commodore Perry Homes 

Development To Address Longstanding Concerns, 01/11/2022.

2022-NY-1002 The Housing Authority of Plainfield, NJ, Did Not Always Comply With Requirements When Administering Its Public Housing 

Programs, 03/30/2022. Questioned: $2,870,374. Unsupported: $2,870,374. Better use: $2,514,470.
Appendix 1: reports Issued | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 56

Internal Evaluation Reports Issued

Information Technology

2020-OE-0004 HUD’s Processes for Managing IT Acquisitions, 11/17/2021

2021-OE-0001a Topic Brief - Fiscal Year 2021 FISMA Vulnerability Testing and Assessment, 02/15/2022

2021-OE-0001 Fiscal Year 2021 Federal Information Security Modernization Act (FISMA) Evaluation, 02/17/2022

Chief Information Officer

2021-OE-0003a Topic Brief - Delays in Federal Housing Administration Catalyst’s Development, 11/17/2021
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 57

Appendix 2 - Tables

Table A

Audit Reports Issued Before Start of Period With No Management Decision as of 3/31/2022

*Significant Audit Reports Described in Previous Semiannual Reports

Report number Report title Issue date

*2016-PH-0001 HUD Did Not Always Provide Adequate Oversight of Property Acquisition and Disposition 

Activities 06/30/2016

*2016-PH-0005 HUD Did Not Always Provide Accurate and Supported Certifications of State Disaster Grantee 

Procurement Processes 09/29/2016

2017-CF-0801 HUD Needs To Clarify Whether Illegal-Undocumented Aliens Are Eligible for Assistance Under 

the Housing Opportunities for Persons With AIDS Program 08/21/2017

*2017-PH-0002 HUD Did Not Provide Sufficient Guidance and Oversight To Ensure That State Disaster Grantees 

Followed Proficient Procurement Processes 09/22/2017

* 2017-NY-0002 HUD Could Improve Its Controls Over the Disposition of Real Properties Assisted With 

Community Development Block Grant Funds 09/29/2017

*2018-FW-0002 HUD’s Office of Block Grant Assistance Had Not Codified the Community Development Block 

Grant Disaster Recovery Program 07/23/2018

*2019-NY-1001 The State of New York Did Not Ensure That Properties Purchased Under the Acquisition 

Component of Its Program Were Eligible 03/29/2019
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 58

Report number Report title Issue date

*2019-NY-1002 The State of New York Did Not Ensure That Appraised Values Used by Its Program Were 

Supported and Appraisal Costs and Services Complied With Requirements 05/29/2019

*2019-KC-0002 HUD Paid Rental Subsidies To Benefit Public Housing and Voucher Tenants Reported as 

Excluded From Federal Programs or Deceased 06/25/2019

Evaluation Reports Issued Before Start of Period With No Management Decision as of 03/31/2022

Report number Report title Issue date

2014-OE-0002 Risk Based Enforcement Could Improve Program Effectiveness 02/12/2016

2016-OE-0002 HUD Web Application Security Evaluation 06/06/2018

2018-OE-0004 HUD IT System Management and Oversight of the Section 184 Program 08/13/2018
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 59

Table B 

Significant Audit Reports for Which Final Action Had Not Been Completed Within 12 Months After the Date of 

the Inspector General’s Report

Report number Report title Issue date Decision 

date 

Final action 

target date

2005-AT-1013

Corporacion para el Fomento Economico de la Ciudad Capital, San Juan, 

Puerto Rico, Did Not Administer Its Independent Capital Fund in Accordance 

with HUD Requirements

09/15/2005 01/11/2006 04/15/2022

2006-CH-1021 Housing Authority of the County of Cook, Chicago, Illinois, Had Weak Controls 

over Its Section 8 Housing Choice Voucher Program 09/30/2006 01/26/2007 09/30/2037

2010-AT-1003 The Housing Authority of Whitesburg Mismanaged Its Operations, 

Whitesburg, KY 04/28/2010 08/26/2010 11/29/2035

2011-PH-1005 The District of Columbia Did Not Administer Its HOME Program in Accordance 

With Federal Requirements, Washington, DC 12/23/2010 04/22/2011 Note 2

2011-NY-1010 The City of Buffalo Did Not Always Administer Its CDBG Program in 

Accordance With HUD Requirements, Buffalo, NY 04/15/2011 01/25/2012 04/15/2022

2011-AT-1018 The Municipality of San Juan, PR, Did Not Properly Manage Its HOME 

Investment Partnerships Program 09/28/2011 01/12/2012 04/15/2022

2012-NY-1002 The City of New York Charged Questionable Expenditures to Its HPRP, New 

York, NY 10/18/2011 02/16/2012 04/15/2022
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 60

Report number Report title Issue date Decision 

date 

Final action 

target date

2012-PH-0001 HUD Needed To Improve Its Use of Its Integrated Disbursement and 

Information System To Oversee Its CDBG Program 10/31/2011 02/28/2012 Note 1

2012-LA-0001 HUD Did Not Adequately Support the Reasonableness of the Fee-for-Service 

Amounts or Monitor the Amounts Charged 11/16/2011 03/27/2012 04/15/2022

2012-PH-1011 Prince George’s County Generally Did Not Administer Its HOME Program in 

Accordance With Federal Requirements, Largo, MD 08/03/2012 11/30/2012 Note 2

2013-PH-1001 Luzerne County Did Not Properly Evaluate, Underwrite, and Monitor a HighRisk Loan, Wilkes-Barre, PA 10/31/2012 01/31/2013 Note 1

2013-PH-0002 HUD Policies Did Not Always Ensure That Borrowers Complied With Program 

Residency Requirements 12/20/2012 04/19/2013 02/28/2023

2013-NY-1006 Nassau County Did Not Administer Its HOME Investment Partnerships 

Program in Accordance With HUD Requirements, Nassau County, NY 05/13/2013 09/06/2013 04/15/2022

2013-LA-1009 The City of Hawthorne Inappropriately Used Nearly $1.6 Million in HOME 

Funds for Section 8 Tenants, Hawthorne, CA 09/13/2013 01/06/2014 Note 1

2013-LA-1010 The City of Hawthorne Did Not Administer Its CDBG Program Cost Allocations 

in Accordance With HUD Rules and Requirements, Hawthorne, CA 09/20/2013 01/06/2014 Note 2

2013-NY-1010 The City of Auburn Did Not Always Administer Its CDBG Program in 

Accordance With HUD Requirements, Auburn, NY 09/26/2013 01/24/2014 04/15/2022

2013-CH-1011 The Michigan State Housing Development Authority Did Not Follow HUD’s 

Requirements Regarding the Administration of Its Program, Lansing, MI 09/30/2013 01/15/2014 04/15/2022
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 61

Report number Report title Issue date Decision 

date 

Final action 

target date

2014-AT-1001 The Municipality of Arecibo Did Not Properly Administer Its HOME Program 12/03/2013 01/24/2014 Note 2

2014-FO-0003 Additional Details To Supplement Our Report on HUD’s Fiscal Years 2013 and 

2012 (Restated) Financial Statements 12/16/2013 07/09/2014 09/30/2022

2014-AT-1004

The State of Mississippi Did Not Ensure That Its Subrecipient and Appraisers 

Complied With Requirements, and It Did Not Fully Implement Adequate 

Procedures for Its Disaster Infrastructure Program, Jackson, MS

12/30/2013 04/15/2014 04/15/2022

2014-FW-0001

The Boston Office of Public Housing Did Not Provide Adequate Oversight 

of Environmental Reviews of Three Housing Agencies, Including Reviews 

Involving Recovery Act Funds

02/07/2014 03/17/2015 Note 2

2014-NY-0001 HUD Did Not Provide Effective Oversight of Section 202 Multifamily Project 

Refinances 02/19/2014 06/10/2014 04/15/2022

2014-LA-0004

HUD Could Not Support the Reasonableness of the Operating and Capital 

Fund Programs’ Fees and Did Not Adequately Monitor Central Office Cost 

Centers

06/30/2014 10/20/2014 04/15/2022

2014-KC-0002 The Data in CAIVRS Did Not Agree With the Data in FHA’s Default and Claims 

Systems 07/02/2014 10/27/2014 Note 1

2014-NY-1008 Palladia, Inc., Did Not Administer Its Supportive Housing Program in 

Accordance With HUD Requirements, New York, NY 07/25/2014 11/21/2014 04/15/2022

2014-PH-1008 The State of New Jersey Did Not Fully Comply With Federal Procurement and 

Cost Principle Requirements in Implementing Its Tourism Marketing Program 08/29/2014 09/02/2015 Note 1
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 62

Report number Report title Issue date Decision 

date 

Final action 

target date

2014-PH-0001 HUD Policies Did Not Always Ensure That HECM Borrowers Complied With 

Residency Requirements 09/30/2014 01/28/2015 02/28/2023

2015-NY-1001

The City of New York Did Not Always Disburse CDBG Disaster Recovery 

Assistance Funds to Its Subrecipient in Accordance With Federal Regulations, 

New York, NY

11/24/2014 03/23/2015 04/15/2022

2015-AT-0001

HUD’s Office of Community Planning and Development Did Not Always 

Pursue Remedial Actions but Generally Implemented Sufficient Controls for 

Administering Its Neighborhood Stabilization Program

03/31/2015 08/28/2015 04/15/2022

2015-LA-1004

The Housing Authority of the County of San Bernardino, San Bernardino, 

CA, Used Shelter Plus Care Program Funds for Ineligible and Unsupported 

Participants

05/29/2015 09/16/2015 04/15/2022

2015-PH-1003 The State of New Jersey Did Not Comply With Federal Procurement and Cost 

Principle Requirements in Implementing Its Disaster Management System 06/04/2015 10/02/2015 Note 1

2015-FW-0001 HUD Did Not Adequately Implement or Provide Adequate Oversight To Ensure 

Compliance With Environmental Requirements 06/16/2015 10/07/2015 04/15/2022

2015-LA-0002 HUD Did Not Provide Adequate Oversight of the Section 184 Indian Home 

Loan Guarantee Program 07/06/2015 10/28/2015 04/15/2022

2015-LA-1005 NOVA Financial & Investment Corporation’s FHA-Insured Loans With 

Downpayment Assistance Gifts Did Not Always Meet HUD Requirements 07/09/2015 09/11/2015 Note 1

2015-CH-0001 HUD Did Not Always Provide Adequate Oversight of Its Section 203(k) 

Rehabilitation Loan Mortgage Insurance Program 07/31/2015 11/27/2015 04/15/2022
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 63

Report number Report title Issue date Decision 

date 

Final action 

target date

2015-KC-0002

The Office of Community Planning and Development’s Reviews of Matching 

Contributions Were Ineffective, and Its Application of Match Reductions Was 

Not Always Correct

08/11/2015 12/09/2015 Note 1

2015-AT-0002 HUD’s Office of Multifamily Asset Management and Portfolio Oversight Did 

Not Comply With Its Requirements for Monitoring Management Agents’ Costs 08/21/2015 12/16/2015 04/15/2022

2015-PH-0004 HUD Policies Did Not Always Ensure That HECM Borrowers Complied With 

Residency Requirements 08/21/2015 12/18/2015 02/28/2023

2015-NY-1010 New York State Did Not Always Administer Its Rising Home Enhanced Buyout 

Program in Accordance With Federal and State Regulations 09/17/2015 03/01/2016 04/15/2022

2015-NY-1011 Program Control Weaknesses Lessened Assurance That New York Rising 

Housing Recovery Program Funds Were Always Disbursed for Eligible Costs 09/17/2015 03/18/2016 04/15/2022

2015-LA-1009 loanDepot’s FHA-Insured Loans With Downpayment Assistance Funds Did Not 

Always Meet HUD Requirements 09/30/2015 01/12/2016 Note 1

2015-LA-1010 loanDepot’s FHA-Insured Loans With Golden State Finance Authority 

Downpayment Assistance Gifts Did Not Always Meet HUD Requirements 09/30/2015 01/12/2016 Note 1

2016-FO-0001 Audit of Fiscal Years 2015 and 2014 (Restated) Financial Statements 11/13/2015 03/24/2016 Note 2

2016-FO-0003

Additional Details To Supplement Our Fiscal Years 2015 and 2014 (Restated) 

U.S. Department of Housing and Urban Development Financial Statement 

Audit

11/18/2015 03/22/2016 09/30/2022

2016-DP-0801 Review of Information System Controls Over the Government National 

Mortgage Association 11/30/2015 03/30/2016 04/15/2022
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 64

Report number Report title Issue date Decision 

date 

Final action 

target date

2016-NY-1003 The City of Rochester, NY, Did Not Always Administer Its Community 

Development Block Grant Program in Accordance With HUD Requirements 02/05/2016 06/17/2016 04/15/2022

2016-NY-1006

New York State Did Not Always Disburse Community Development Block 

Grant Disaster Recovery Funds in Accordance With Federal and State 

Regulations

03/29/2016 07/27/2016 04/15/2022

2016-NY-1007 The City of Jersey City, NJ’s Community Development Block Grant Program 

Had Administrative and Financial Control Weaknesses 03/30/2016 06/08/2016 04/15/2022

2016-PH-0001 HUD Did Not Always Provide Adequate Oversight of Property Acquisition and 

Disposition Activities 06/30/2016 02/16/2017 Note 3

2016-NY-0001 Operating Fund Calculations Were Not Always Adequately Verified 09/12/2016 12/22/2016 04/01/2025

2016-FW-1010

The State of Oklahoma Did Not Obligate and Spend Its Community 

Development Block Grant Disaster Recovery Funds in Accordance With 

Requirements

09/30/2016 01/17/2017 04/15/2022

2016-PH-1009 The State of New Jersey Did Not Disburse Disaster Funds to Its Contractor in 

Accordance With HUD, Federal, and Other Applicable Requirements 09/30/2016 01/27/2017 Note 1

2017-KC-0001 FHA Paid Claims for an Estimated 239,000 Properties That Servicers Did Not 

Foreclose Upon or Convey on Time 10/14/2016 02/28/2017 04/15/2022

2017-NY-1001

The City of New York, NY, Implemented Policies That Did Not Always Ensure 

That CDBG Disaster Recovery Funds Were Disbursed in Accordance With Its 

Action Plan and Federal Requirements

11/02/2016 05/08/2017 Note 1
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 65

Report number Report title Issue date Decision 

date 

Final action 

target date

2017-FO-0003

Additional Details To Supplement Our Fiscal Years 2016 and 2015 (Restated) 

U.S. Department of Housing and Urban Development Financial Statement 

Audit

11/15/2016 09/13/2017 04/01/2022

2017-NY-1004

The City of New York, NY, Lacked Adequate Controls To Ensure That the Use of 

CDBG-DR Funds Was Always Consistent With the Action Plan and Applicable 

Federal and State Requirements

12/21/2016 04/17/2017 Note 1

2017-NY-1005 Union County, NJ’S HOME Investment Partnerships Program Was Not Always 

Administered in Compliance With Program Requirements 01/13/2017 05/11/2017 04/15/2022

2017-LA-0002 HUD Failed To Follow Departmental Clearance Protocols for FHA Programs, 

Policies, and Operations 01/25/2017 09/22/2017 04/15/2022

2017-KC-1801 Final Action Memorandum: Purchaser of HUD-Insured Single-Family Property 

Settled Allegations of Causing the Submission of a False Claim 02/23/2017 02/23/2017 Note 2

2017-LA-0003 HUD Failed To Adequately Oversee FHA-Insured Loans With BorrowerFinanced Downpayment Assistance 03/03/2017 06/22/2017 Note 1

2017-PH-1001 The City of Pittsburgh, PA, Did Not Always Administer Its CDBG Program in 

Accordance With HUD and Federal Requirements 03/22/2017 07/19/2017 04/15/2022

2017-CF-1803 United Shore Financial Services, LLC, Settled Allegations of Failing To Comply 

With HUD’s Federal Housing Administration Loan Requirements 03/29/2017 03/29/2017 04/15/2022

2017-NY-0001 HUD PIH’s Required Conversion Program Was Not Adequately Implemented 05/18/2017 09/15/2017 12/31/2023
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 66

Report number Report title Issue date Decision 

date 

Final action 

target date

2017-PH-1003

The Yorkville Cooperative, Fairfax, VA, Did Not Administer Its HUD-Insured 

Property and Housing Assistance Contract According to Applicable 

Requirements

05/22/2017 09/19/2017 04/15/2022

2017-KC-0005 Owners of Cooperative Housing Properties Generally Charged More for Their 

Section 8 Units Than for Their Non-Section 8 Units 06/12/2017 10/06/2017 04/15/2022

2017-LA-1005 The City of Huntington Park, CA, Did Not Administer Its Community 

Development Block Grant Program in Accordance With Requirements 06/16/2017 10/17/2017 04/15/2022

2017-KC-0006 HUD Did Not Conduct Rulemaking or Develop Formal Procedures for Its 

Single-Family Note Sales Program 07/14/2017 10/19/2017 04/15/2022

2017-FW-1011 BLM Companies LLC Failed To Ensure That It Protected and Preserved HUD 

Properties Under Its Field Service Manager Contract for Area 1D 08/29/2017 12/26/2017 04/15/2022

2017-FW-1012 The City of New Orleans, New Orleans, LA, Did Not Always Properly 

Administer Its HOME Program 09/06/2017 12/19/2017 04/15/2022

2017-LA-0004 HUD Did Not Have Adequate Controls To Ensure That Servicers Properly 

Engaged in Loss Mitigation 09/14/2017 01/11/2018 04/15/2022

2017-NY-1010

The State of New York Did Not Show That Disaster Recovery Funds Under 

Its Non-Federal Share Match Program Were Used for Eligible and Supported 

Costs

09/15/2017 01/12/2018 04/15/2022

2017-PH-1006 The Owner of Schwenckfeld Manor, Lansdale, PA, Did Not Always Manage Its 

HUD-Insured Property in Accordance With Applicable HUD Requirements 09/25/2017 01/23/2018 02/01/2030
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 67

Report number Report title Issue date Decision 

date 

Final action 

target date

2017-CF-1807 Residential Home Funding Corp. Settled Allegations of Failing To Comply With 

HUD’s Federal Housing Administration Loan Requirements 09/28/2017 09/28/2017 04/15/2022

2017-NY-0002 HUD Could Improve Its Controls Over the Disposition of Real Properties 

Assisted With Community Development Block Grant Funds 09/29/2017 01/26/2018 Note 3

2018-FO-0003 Fiscal Years 2017 and 2016 (Restated) Financial Statements Audit 11/15/2017 04/03/2018 Note 1

2018-FO-0004

Additional Details To Supplement Our Fiscal Years 2017 and 2016 (Restated) 

U.S. Department of Housing and Urban Development Financial Statement 

Audit

11/15/2017 07/02/2018 Note 1

2018-AT-1802 Yabucoa Housing Project, Yabucoa Volunteers of America Elderly Housing, 

Inc., Yabucoa, PR, Section 202 Supportive Housing for the Elderly Program 12/29/2017 04/20/2018 04/15/2022

2018-FW-1001 Jefferson Parish, Jefferson, LA, Did Not Always Properly Administer Its 

Rehabilitation Program 01/29/2018 05/22/2018 12/31/2022

2018-NY-1003 The Housing Authority of the City of Asbury Park, NJ, Did Not Always 

Administer Its Operating and Capital Funds in Accordance With Requirements 02/08/2018 06/07/2018 01/28/2050

2018-CF-1801

MetLife Home Loans, LLC, and a Borrower’s Son Settled Allegations of 

Failing To Comply With HUD’s Federal Housing Administration HECM Loan 

Requirements

03/23/2018 08/09/2018 04/15/2022

2018-KC-0001 FHA Insured $1.9 Billion in Loans to Borrowers Barred by Federal 

Requirements 03/26/2018 07/11/2018 04/15/2022
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 68

Report number Report title Issue date Decision 

date 

Final action 

target date

2018-LA-1003 The City of South Gate, CA, Did Not Administer Its Community Development 

Block Grant Program in Accordance With HUD Requirements 03/29/2018 07/25/2018 04/15/2022

2018-CH-0002 HUD Lacked Adequate Oversight of Lead-Based Paint Reporting and 

Remediation in Its Public Housing and Housing Choice Voucher Programs 06/14/2018 12/06/2018 Note 2

2018-LA-0801 The Office of Native American Programs Section 184 Program Continues To 

Operate Without Adequate Oversight 3 Years After the Prior OIG Audit 08/27/2018 12/21/2018 04/15/2022

2018-BO-0001 HUD’s Office of Residential Care Facilities Did Not Always Have and Use 

Financial Information To Adequately Assess and Monitor Nursing Homes 09/17/2018 03/07/2019 04/15/2022

2018-BO-1005 The State of Connecticut Did Not Ensure That Its Grantees Properly 

Administered Their Housing Rehabilitation Programs 09/19/2018 03/27/2019 04/15/2022

2018-KC-0004 HUD Did Not Always Identify and Collect Partial Claims Out of Surplus 

Foreclosure Proceeds 09/20/2018 04/18/2019 Note 2

2018-LA-0005 HUD Did Not Have Adequate Controls To Ensure That Partial Claim Notes for 

FHA Loans Were Properly Tracked for Future Collection 09/21/2018 03/08/2019 04/15/2022

2018-NY-0001 HUD Did Not Adequately Administer Its Housing Counseling Program 09/24/2018 02/26/2019 04/01/2023

2018-PH-1007 The Crisfield Housing Authority, Crisfield, MD, Did Not Properly Administer Its 

Public Housing Program Operating and Capital Funds 09/25/2018 03/01/2019 04/15/2022

2018-PH-1008

The City of Erie, PA, Did Not Always Administer Its Code Enforcement 

and Community Policing Activities in Accordance With HUD and Federal 

Requirements

09/26/2018 03/07/2019 Note 2
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 69

Report number Report title Issue date Decision 

date 

Final action 

target date

2018-LA-0007 HUD Paid an Estimated $413 Million for Unnecessary Preforeclosure Claim 

Interest and Other Costs Due to Lender Servicing Delays 09/27/2018 04/03/2019 04/15/2022

2018-NY-1007 The City of New York, NY, Did Not Always Use Disaster Recovery Funds Under 

Its Program for Eligible and Supported Costs 09/27/2018 02/28/2019 04/15/2022

2018-FW-1007 The State of Louisiana, Baton Rouge, LA, Did Not Always Maintain Adequate 

Documentation or Comply With Website Reporting Requirements 09/28/2018 03/29/2019 04/15/2022

2018-CH-1010

The City of Chicago’s Department of Public Health, Chicago, IL, Did Not 

Administer Its Lead Hazard Reduction Demonstration Grant Program in 

Accordance With HUD’s and Its Own Requirements

09/30/2018 03/14/2019 04/15/2022

2019-FO-0002 Audit of the Federal Housing Administration’s Financial Statements for Fiscal 

Years 2018 and 2017 (Restated) 11/14/2018 05/30/2019 Note 1

2019-FO-0003

Additional Details To Supplement Our Fiscal Years 2018 and 2017 (Restated) 

U.S. Department of Housing and Urban Development Financial Statement 

Audit

11/15/2018 07/11/2019 Note 2

2019-AT-1002 Louisville Metro, Louisville, KY, Did Not Always Administer the TBRA Activity in 

Its HOME and CoC Programs in Accordance With Program Requirements 03/18/2019 07/16/2019 04/15/2022

2019-KC-0001 FHA Improperly Paid Partial Claims That Did Not Reinstate Their Related Loans 04/11/2019 08/02/2019 04/15/2022

2019-FW-1001 The Little Rock Housing Authority, Little Rock, AR, Did Not Fully Meet Rental 

Assistance Demonstration Program Requirements 04/23/2019 09/20/2019 10/31/2022

2019-BO-1001 The City of Bridgeport, CT, Did Not Properly Administer Its HOME Program 04/25/2019 08/07/2019 04/15/2022
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 70

Report number Report title Issue date Decision 

date 

Final action 

target date

2019-AT-1004 The North Carolina Department of Commerce Did Not Administer Its 

Neighborhood Stabilization Program Grants as Required by HUD 06/14/2019 01/14/2020 04/15/2022

2019-KC-0002 HUD Paid Rental Subsidies To Benefit Public Housing and Voucher Tenants 

Reported as Excluded From Federal Programs or Deceased 06/25/2019 10/17/2019 Note 3

2019-LA-0801

HUD Completed the Agreed-Upon Corrective Actions for One of the Two 

Recommendations Reviewed From Prior OIG Audit Report 2015-LA-0001 on 

FHA-HAMP Partial Claims

07/15/2019 10/08/2019 04/15/2022

2019-CH-1003 The Management Agent for Lake View Towers Apartments, Chicago, IL, Did 

Not Always Comply With HUD’s Section 8 HAP Program Requirements 09/03/2019 12/18/2019 04/15/2022

2019-KC-0003 FHA Insured at Least $13 Billion in Loans to Ineligible Borrowers With 

Delinquent Federal Tax Debt 09/30/2019 01/15/2020 04/15/2022

2020-AT-0801 HUD Had Not Established Deadlines for Reporting FHA-HAMP Nonincentivized 

Loan Modifications and Filing Nonincentivized Partial Claims 02/04/2020 06/01/2020 05/31/2022

2020-FO-0003 Additional Details To Supplement Our Fiscal Year 2019 U.S. Department of 

Housing and Urban Development Financial Statements Audit 02/07/2020 09/08/2020 04/15/2022

2020-FW-0001

HUD Did Not Have Adequate Oversight To Ensure That Its Payments to 

Subsidized Property Owners Were Accurate and Supported When It 

Suspended Contract Administrator Reviews

02/26/2020 06/09/2020 04/15/2022

2020-LA-1002 The Housing Authority of the City of Long Beach, CA, Did Not Administer Its 

Housing Choice Voucher Program in Accordance With HUD Requirements 03/05/2020 06/19/2020 04/15/2022
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 71

Report number Report title Issue date Decision 

date 

Final action 

target date

2020-AT-1002 The Puerto Rico Department of Housing, San Juan, PR, Should Strengthen Its 

Capacity To Administer Its Disaster Grants 03/16/2020 07/13/2020 04/15/2022

2020-CH-0003 HUD Lacked Adequate Oversight of Public Housing Agencies’ Compliance 

With the Lead Safe Housing Rule 03/18/2020 09/03/2020 04/15/2022

2020-LA-1003 The City of Mesa, AZ, Did Not Administer Its Community Development Block 

Grant in Accordance With HUD Requirements 04/13/2020 08/11/2020 04/15/2022

2020-CH-0004 HUD Needs To Improve Its Oversight of Lead in the Water of Housing Choice 

Voucher and Public Housing Program Units 08/21/2020 02/10/2021 04/15/2022

2020-CH-0005 HUD Needs To Improve Its Oversight of Lead in the Water of Multifamily 

Housing Units 08/21/2020 01/26/2021 04/15/2022

2020-LA-1005 Mid America Mortgage, dba 1st Tribal Lending, Pinole, CA, Did Not Always 

Follow HUD’s Section 184 Program Requirements 09/03/2020 12/14/2020 04/15/2022

2020-LA-0002 HUD Had Implemented Most of the Required Responsibilities Stated in the 

Geospatial Data Act of 2018 09/24/2020 01/11/2021 04/15/2022

2021-LA-1001 The City of Compton, Compton, CA, Did Not Always Administer Neighborhood 

Stabilization Program Funds in Compliance With Procedures and Regulations 10/27/2020 01/26/2021 04/15/2022

2021-DP-0001 Fiscal Year 2019 Review of Information Systems Controls in Support of the 

Financial Statements Audit 12/17/2020 04/08/2021 04/15/2022

2021-KC-0002 FHA Insured $940 Million in Loans for Properties in Flood Zones Without the 

Required Flood Insurance 01/05/2021 04/26/2021 Note 2
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 72

Report number Report title Issue date Decision 

date 

Final action 

target date

2021-LA-1002 Neighborhood Housing Services of Los Angeles County, Los Angeles, CA, Did 

Not Always Follow Program Requirements in Administering Its NSP2 01/05/2021 04/29/2021 04/25/2022

2021-PH-0002 HUD Improperly Accounted for and Managed Reimbursements It Received 

Through Rent Credits From the General Services Administration 03/29/2021 05/28/2021 05/26/2022
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 73

Significant Audit Reports Issued Within the Past 12 Months That Were Described in Previous Semiannual 

Reports for Which Final Action Had Not Been Completed as of 03/31/2022

Report number Report title Issue date Decision date Final action

2021-AT-0002 HUD Did Not Fully Comply With the Payment Integrity Information Act of 

2019 05/17/2021 06/17/2021 05/16/2022

2021-FW-1001 Harris County Community Services Department, Houston, TX, Was Inefficient 

and Ineffective in Operating Its Hurricane Harvey Program 06/02/2021 09/14/2021 04/29/2022

2021-FW-1002

The City of Houston’s Housing and Community Development Department, 

Houston, TX, Did Not Always Ensure That Its Program Followed Procurement 

Requirements

06/21/2021 10/06/2021 10/05/2022

2021-KC-0003 HUD’s Major Program Offices Can Improve Their Preparedness To Respond to 

Upcoming Natural Disasters 07/26/2021 11/05/2021 12/31/2022

2021-KC-0004 HUD’s Office of Multifamily Housing Programs’ Complaint Process Did Not 

Ensure That Health and Safety Complaints Were Resolved in a Timely Manner 07/28/2021 09/28/2021 10/01/2024

2021-CH-0001 HUD Remains Challenged To Serve the Maximum Number of Eligible Families 

Due to Decreasing Utilization in the Housing Choice Voucher Program 09/15/2021 01/14/2022 01/13/2023

2021-FW-1003 The Bay City Housing Authority, Bay City, TX, Did Not Follow Requirements for 

Its Legal Services Contract, Administrative Costs, and Board Meetings 09/29/2021 01/26/2022 12/31/2022

Audits Excluded: 

73 audits under repayment plans

30 audits under debt claims collection processing, formal judicial review, investigation, 

or legislative solution

Notes: 

1 Management did not meet the target date. Target date is more than 1 year old. 

2 Management did not meet the target date. Target date is less than 1 year old. 

3 No management decision
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 74

Significant Evaluation Reports for Which Final Action Had Not Been Completed Within 12 Months After the 

Date of the Inspector General’s Report

Report number Report title Issue date Decision date Final action

2013-ITED-0001 Federal Information Security Management Act (FISMA) Fiscal Year 

2013 Evaluation Report 11/29/2013 11/29/2013 Note 1

2014-ITED-0001 HUD Privacy Program Evaluation Report 04/30/2014 04/30/2014 Note 1

2014-OE-0002 Risk Based Enforcement Could Improve Program Effectiveness 02/12/2016 n/a Note 2

2014-OE-0003 Federal Information Security Management Act (FISMA) Fiscal Year 

2014 Evaluation Report 11/15/2014 11/15/2014 Note 1

2015-OE-0001 Federal Information Security Modernization Act (FISMA) Fiscal Year 

2015 Evaluation Report 11/15/2015 11/15/2015 Note 1

2015-OE-0002 HUD IT Modernization Evaluation Report 09/29/2015 09/29/2015 Note 1

2016-OE-0002 HUD Web Application Security Evaluation Report 06/07/2017 n/a Note 2

2016-OE-0006 HUD Fiscal Year 2016 Federal Information Security Modernization Act 

of 2014 (FISMA) Evaluation Report 11/10/2016 11/10/2016 Note 1

2017-OE-0007 HUD Fiscal Year 2017 Federal Information Security Modernization Act 

of 2014 (FISMA) Evaluation Report 10/31/2017 08/16/2018 Note 1

2018-OE-0001 HUD Privacy Program Evaluation Report 09/13/2018 11/27/2019 Note 1
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 75

Report number Report title Issue date Decision date Final action

2018-OE-0003 HUD Fiscal Year 2018 Federal Information Security Modernization Act 

of 2014 (FISMA) Evaluation Report 10/31/2018 05/27/2019 Note 1

2018-OE-0004 HUD IT System Management and Oversight of the Section 184 Program 08/13/2018 n/a Note 2

2019-OE-0002 HUD Fiscal Year 2019 Federal Information Security Modernization Act 

of 2014 (FISMA) Evaluation Report 06/24/2020 01/19/2021 Note 1

2019-OE-0002a HUD Personally Identifiable Information (PII) Records Protection and 

Management 06/25/2020 12/21/2020 Note 1

2019-OE-0003 Contaminated Sites Pose Potential Health Risks to Residents at HUDFunded Properties 02/14/2021 08/31/2021 Note 1

2020-OE-0001 HUD Fiscal Year 2020 Federal Information Security Modernization Act 

of 2014 (FISMA) Evaluation Report 11/30/2020 03/30/2021 Note 1
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 76

Significant Evaluation Reports Issued Within the Past 12 Months That Were Described in Previous 

Semiannual Reports for Which Final Action Had Not Been Completed as of March 31, 2022

Report number Report title Issue date Decision date Final action

2020-OE-0002 Opportunities Exist To Improve HUD’s Hiring Process 08/02/2021 12/02/2021 Note 3

2020-OE-0003 HUD Program Offices’ Policies and Approaches for Radon 04/08/2021 08/06/2021 Note 3

2020-OE-0004 HUD’s Processes for Managing IT Acquisitions 11/17/2021 TBD Note 3

2021-OE-0001 Fiscal Year 2021 Federal Information Security Modernization Act (FISMA) 

Evaluation Report 02/15/2022 TBD Note 3

2021-OE-0003 HUD IT Modernization Roadmap Evaluation Report 06/30/2021 09/28/2021 Note 3

Notes:

1 Management did not meet the target date. Target date is more than 1 year old.

2 No management decision (for one or more recommendations)

3 Management is working to meet the target date. Target date is less than 1 year old.
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 77

Table C

Inspector General-Issued Reports With Questioned and Unsupported Costs as of 3/31/2022 

(Dollars in Thousands)

Audit reports Number of audit 

reports

Questioned 

costs

Unsupported 

costs

A1 For which no management decision had been made by the beginning of the reporting period 6 $394,924 $391,346

A2  For which litigation, legislation, or investigation was pending at the beginning of the 

reporting period 0 0 0

A3  For which additional costs were added to reports in beginning inventory - 2,568 261

A4 For which costs were added to noncost reports 0 0 0

B1 Which were issued during the reporting period 3 3,857 3,857

B2 Which were reopened during the reporting period. 0 0 0

Subtotals (A+B) 9 401,349 395,464

C For which a management decision was made during the reporting period 210 3,872 1,553

 (1)Dollar value of disallowed costs:

 Due HUD 

Due program participants 

0 

2

2,374

1,498

169

1,384

 (2) Dollar value of costs not disallowed 0 0 0

D For which a management decision had been made not to determine costs until 

completion of litigation, legislation, or investigation 0 0 0

E For which no management decision had been made by the end of the reporting period 

7

<16>11

397,477

<384,205>11

393,911

<380,643>11

10 Two audit reports also contain recommendations with funds be put to better use. 

11 The figures in brackets represent data at the recommendation level as compared to the report level. See Explanations of Tables C and D.
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 78

Table D

Inspector General-Issued Reports With Recommendations That Funds Be Put to Better Use as of 

3/31/2022 (Dollars in Thousands)

Audit reports Number of 

audit reports Dollar value

A1 For which no management decision had been made by the beginning of the reporting period 5 $4,994,932

A2 For which litigation, legislation, or investigation was pending at the beginning of the reporting period 0 0

A3 For which additional costs were added to reports in beginning inventory - 131

A4 For which costs were added to noncost reports 0 0

B1 Which were issued during the reporting period 4 6,943,993

B2 Which were reopened during the reporting period 0 0

Subtotals (A+B) 9 11,939,056

C  For which a management decision was made during the reporting period 212 9,892

 (1) Dollar value of recommendations that were agreed to by management:

 Due HUD

 Due program participants 

0

2

131

9,761

 (2) Dollar value of recommendations that were not agreed to by management 0 0

D  For which a management decision had been made not to determine costs until completion of litigation, 

legislation, or investigation 0 0

E For which no management decision had made by the end of the reporting period 

7

<8>13

11,929,164

<6,493,069>5

12 Two audit reports also contain recommendations with questioned costs. 

13 The figures in brackets represent data at the recommendation level as compared to the report level. See Explanations of Tables C and D.
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 79

Explanations of Tables C and D

The Inspector General Act Amendments of 1988 require inspectors 

general and agency heads to report cost data on management decisions 

and final actions on audit reports. The current method of reporting at 

the “report” level rather than at the individual audit “recommendation” 

level results in misleading reporting of cost data. Under the Act, an audit 

“report” does not have a management decision or final action until all 

questioned cost items or other recommendations have a management 

decision or final action. Under these circumstances, the use of the 

“report” based rather than the “recommendation” based method of 

reporting distorts the actual agency efforts to resolve and complete 

action on audit recommendations. For example, certain cost items or 

recommendations could have a management decision and repayment 

(final action) in a short period of time. Other cost items or nonmonetary 

recommendation issues in the same audit report may be more complex, 

requiring a longer period of time for management’s decision or final 

action. Although management may have taken timely action on all but 

one of many recommendations in an audit report, the current “all or 

nothing” reporting format does not recognize their efforts.

The closing inventory for items with no management decision in 

tables C and D (line E) reflects figures at the report level as well as the 

recommendation level.
Appendix 3: Inspector General Empowerement Act | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 80

Appendix 3 - Inspector 

General Empowerment Act

The Inspector General Empowerment Act (Public Law 114-317) (IGEA), 

enacted in December 2016, contains several reporting requirements 

regarding offices of inspectors general’s (OIG) semiannual reports 

to Congress (SAR). Below are the U.S. Department of Housing and 

Urban Development, Office of Inspector General’s (HUD OIG) statutory 

requirements as stated in the IGEA, with hyperlinks to the detailed 

information located on its website at www.hudoig.gov.

Summary of Reports with No Establishment 

Comment

The IGEA requires OIG to report on each audit and evaluation report for 

which the Department did not return comments within 60 days of HUD 

OIG’s providing the report to the Department.

There are no instances of reports with no establishment comment this 

semiannual reporting period. 

Summary of Reports with Open 

Recommendations

The IGEA requires OIG to report on each audit and evaluation 

report for which there are any outstanding unimplemented 

recommendations, including the combined potential cost savings of 

these recommendations. Summaries for the Office of Audit and Office of 

Evaluation (OE) are presented below.

Office of Audit

As of March 31, 2022, the Department currently has 972 outstanding 

(open) unimplemented recommendations with a combined potential cost 

savings of more than $20 billion. The following table and charts reflect 

the reasons for why they remain unimplemented:

1. 859 recommendations have active corrective action plans 

in place or valid repayment plans, but HUD has not finished 

implementing the recommendation. 

2. 113 recommendations are currently without management 

decisions (agreement between the Department and OIG), 33 

of which are beyond the 180-day statutory requirements due 

to disagreement and were reported in table A of OIG’s SAR. 

The remainder are within the 180-day limit, during which time 

management and OIG can arrive at an agreed-upon corrective 

action plan.

3. 350 open recommendations have management decisions 

in place but are currently under investigative, legislative, 

or judicial action or under a valid repayment plan and are, 

therefore, suspended pending resolution.
Appendix 3: Inspector General Empowere ment Act | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 81

Office of Audit Summary

Calendar 

year

Number of open 

recommendations

Cumulative estimated 

cost savings from open 

recommendations14

Pre-2001 2 $1,688,555

2001 1 160,000

2002 3 83,604

2003 12 1,746,990

2004 7 8,044,177

2005 5 2,999,361

2006 12 8,837,577

2007 14 4,977,549

2008 28 71,061,854

2009 23 4,896,451

2010 15 17,697,521

2011 33 100,291,653

14 The amounts shown include both questioned costs and funds to be put to better use

Calendar 

year

Number of open 

recommendations

Cumulative estimated 

cost savings from open 

recommendations14

2012 13 10,405,830

2013 47 55,738,748

2014 68 241,170,980

2015 77 318,833,562

2016 112 7,274,866,445

2017 130 635,987,329

2018 96 2,842,270,212

2019 68 6,660,743,216

2020 54 3,969,908

2021 81 456,556,037

2022 71 1,517,850,359

Total 972 20,240,877,918
Appendix 3: Inspector General Empowerement Act | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 82

Office of Evaluation

OE conducts evaluations focused on improving departmental operations and programs. OE’s recommendations do not focus on direct cost savings but, 

rather, on improving program effectiveness, reducing the likelihood of negative outcomes, and addressing HUD’s top management challenges. The 

following table summarizes OE’s reports with open recommendations:

Calendar year Number of open recommendations

2013 1

2014 4

2015 3

2016 3

2017 6

2018 19

2019 0

2020 33

2021 26

2022 23

Total 118
Appendix 3: Inspector General Empowerement Act | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 83

Statistical Table Showing Investigative Report Metrics

The data used in this statistical table were extracted from HUD OIG’s Case Management System. The Case Management System and its underlying 

infrastructure allow for data input and maintain data integrity during the complete investigative case cycle, while ensuring data privacy and 

confidentiality. The system was developed in .Net 4.7.2, and the database is SQL 2017. OIG develops queries to extract data from the Case Management 

System to meet business requirements, such as the information used to create this statistical table. The footnotes provide additional guidance pertaining 

to each requested category of information. 

Reporting Period: Fiscal Year, Period 1 (SAR 87), October 1, 2021, through March 31, 2022

Measure Total

A. Total number of investigative reports issued during the reporting period15 124

B. Total number of persons referred to the U.S. Department of Justice for 

criminal prosecution during the reporting period. 96

C. Total number of persons referred to State and local prosecuting authorities 

for criminal prosecution during the reporting period. 12

D. Total number of indictments and criminal informations during the reporting 

period that resulted from any prior referral to prosecuting authorities.16 51

15 Includes approved reports of investigation

16 Includes all charging documents reported: criminal complaints, indictments, informations, and superseding indictments
Appendix 3: Inspector General Empowerement Act | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 84

Investigations of Senior Government 

Employees

The IGEA requires OIG to summarize in the SAR each investigation 

involving a senior government employee when allegations of misconduct 

were substantiated. Listed below are the cases for this reporting period.

HUD OIG has no instances of allegations of misconduct that were 

substantiated. 

Instances of Whistleblower Retaliation

The IGEA requires OIG to include in the SAR a detailed description 

of any instance of whistleblower retaliation, including information 

about the official found to have engaged in retaliation and what, if 

any, consequences the establishment imposed to hold that official 

accountable. 

HUD OIG has no instances of whistleblower retaliation to report in this 

semiannual reporting period. 

OIG Independence

The IGEA requires OIG to include in the SAR a detailed description of any 

attempt by the establishment to interfere with the independence of OIG, 

including incidents in which the establishment has resisted or objected 

to oversight activities or restricted or significantly delayed access to 

information. 

HUD OIG has no instances of attempts to interfere with OIG 

independence to report in this semiannual reporting period.

Reports That Were Closed During the Period 

That Were Not Disclosed to the Public 

Section 5(a)(22) of the IGEA, as amended, requires that OIG report 

on each audit and investigation conducted by the office that is closed 

during the reporting period and was not disclosed to the public.

Office of Investigation

OIG initiated an investigation based on allegations that a former 

senior HUD employee had a potential conflict of interest by allegedly 

participating in the award of a noncompetitive contract to a vendor 

before the employee’s departure from HUD. The employee was later 

hired by the vendor in a management role. OIG investigated whether 

the employee participated in matters affecting the financial interests 

of the vendor while seeking or negotiating employment with it. The 

investigation did not substantiate the allegations and was neither 

presented for prosecution nor referred to HUD.

OIG initiated an investigation based on allegations that two senior HUD 

employees provided inaccurate information regarding appropriations 

for various programs in violation of the Antideficiency Act. The 

information provided is used to determine housing program funding. 

The investigation did not substantiate the allegations and was neither 

presented for prosecution nor referred to HUD. 

Office of Evaluation

Fiscal Year 2021 Federal Information Security Modernization Act 

(FISMA) Evaluation Report: February 17, 2022 

The Federal Information Security Modernization Act of 2014 (FISMA) 

directs inspectors general to conduct an annual evaluation of the agency 
Appendix 3: Inspector General Empowere ment Act | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 85

information security program. FISMA, the U.S. Department of Homeland 

Security, the Office of Management and Budget (OMB), and the National 

Institute of Standards and Technology establish information technology 

security guidance and standards for Federal agencies. OIG conducted 

this evaluation to assess the overall effectiveness of HUD’s information 

security program, assess its compliance with Federal guidance, and 

respond to OMB reporting questions for the fiscal year 2021 annual 

assessment. OIG has determined that the contents of this report would 

not be appropriate for public disclosure and, therefore, limited its 

distribution to selected officials. 

(Agencywide, Evaluation Report: 2021-OE-0001)

Topic Brief—Fiscal Year 2021 FISMA Vulnerability Testing and 

Assessment Topic Brief: February 15, 2022

FISMA requires all Federal agencies to conduct independent security 

technical verification testing on a sampling of information systems 

annually. In conjunction with its fiscal year 2021 FISMA evaluation 

(2021-OE-0001), OIG conducted a targeted security testing assessment 

of sample systems, which resulted in a topic brief. The objective of this 

application vulnerability testing was to determine whether HUD’s FISMA 

sample systems contained security weaknesses. OIG identified potential 

vulnerabilities among the tested HUD applications and categorized them 

into low, medium, and high risk. HUD should prioritize those risks for 

review and remediation. No formal recommendations were included 

in the report. OIG has determined that the contents of this report 

would not be appropriate for public disclosure and, therefore, limited its 

distribution to selected officials. 

(Agencywide, Topic Brief: 2021-OE-0001a)
Appendix 4: Reporting Requirements | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 86

Appendix 4 - Reporting Requirements

The specific reporting requirements as prescribed by the Inspector General Act of 1978, as amended by the Inspector General Act of 1988, are listed 

below.

Source requirement Pages

Section 4(a)(2) - review of existing and proposed legislation and regulations. 27-35

Section 5(a)(1) – description of significant problems, abuses, and deficiencies relating to the 

administration of programs and operations of the Department. 10-22, 47-48

Section 5(a)(2) – description of recommendations for corrective action with respect to significant 

problems, abuses, and deficiencies. 36-46

Section 5(a)(3) – identification of each significant recommendation described in previous 

Semiannual Reports on which corrective action has not been completed.

Appendix 2, 

Table B, 59

Section 5(a)(4) – summary of matters referred to prosecutive authorities and the prosecutions 

and convictions that have resulted. 10-22

Section 5(a)(5) – summary of reports made on instances where information or assistance was 

unreasonably refused or not provided, as required by Section 6(b)(2) of the Act. No instances

Section 5(a)(6) – listing of each audit report completed during the reporting period, and for each 

report, where applicable, the total dollar value of questioned and unsupported costs and dollar 

value of recommendations that funds be put to better use.

Appendix 1, 

52

Section 5(a)(7) – summary of each particularly significant report. 10-22
Appendix 4: Reporting Requirements | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 87

Source requirement Pages

Section 5(a)(8) – statistical tables showing the total number of adult reports and the total dollar 

value of questioned and unsupported costs.

Appendix 2, 

table C, 77

Section 5(a)(9) – statistical tables showing the total number of audit reports and the dollar value 

of recommendations that funds be put to better use by management.

Appendix 2, 

table D, 78

Section 5(a)(10) – summary of each audit report issued before the commencement of the 

reporting period for which no management decision had been made by the end of the period.

Appendix 2, 

table A, 57

Section 5(a)(11) – a description and explanation of the reasons for any significant revised 

management decisions made during the reporting period. 44-45

Section 5(a)(12) – information concerning any significant management decision with which the 

Inspector General is in disagreement. No instances

Section 5(a)(13) – the information described under section 05(b) of the Federal Financial 

Management Improvement Act of 1996. 46
Appendix 5: Acronyms and Abbreviations | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 88

Appendix 5 - Acronyms and 

Abbreviations

AUSA Assistant United States Attorney

CARES Act Coronavirus Aid, Relief, and Economic Security Act

CAV corrective action verification

CDBG Community Development Block Grant

CDBG-CV CDBG coronavirus grants

CDBG-DR Community Development Block Grant Disaster Recovery

CFR Code of Federal Regulations

CLA CliftonLarsonAllen LLP

CIGIE Council of the Inspectors General on Integrity and Efficiency

CPD Office of Community Planning and Development

CoC Continuum of Care

COVID-19 Coronavirus Disease 2019

DATA Act Digital Accountability and Transparency Act of 2014

DEC Departmental Enforcement Center

DHS U.S. Department of Homeland Security

DoD U.S. Department of Defense

DOJ U.S. Department of Justice

DVI Development Ventures, Inc.

EAD Electronic Appraisal Delivery

ESG Emergency Solutions Grant

FFMIA Federal Financial Management Improvement Act

FHA Federal Housing Administration

FHAC FHA Connection

FHFA Federal Housing Finance Agency

FISMA Federal Information Security Modernization Act of 2014

FR Federal Register

Freddie Mac Federal Home Loan Mortgage Corporation

FY fiscal year

GAO U.S. Government Accountability Office

Ginnie Mae Government National Mortgage Association

GONE Act Grants Oversight and New Efficiency Act

HECM home equity conversion mortgage

HOPWA Housing Opportunities for Persons With AIDS

HUD U.S. Department of Housing and Urban Development

IGEA Inspector General Empowerment Act

ICDBG Indian Community Development Block Grant

IHBG Indian Housing Block Grant

IRS Internal Revenue Service

IT information technology

LOS Loan Origination System

MAP multifamily accelerated processing

MID most impacted and distressed

ML mortgagee letter

NHHBG Native Hawaiian Housing Block Grant

OBGA Office of Block Grant Assistance

OCFO Office of the Chief Financial Officer

OCIO Office of the Chief Information Officer

OE Office of Evaluation

OGC Office of General Counsel

OI Office of Investigation

OIG Office of Inspector General

OMB Office of Management and Budget

ONAP Office of Native American Programs

OSC Office of Special Counsel
Appendix 5: Acronyms and Abbreviations | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 89

PBRA project-based rental assistance

PDD presidentially declared disaster

PHA public housing agency

PIH Office of Public and Indian Housing 

PRAC Pandemic Response Accountability Committee

PRAC Section 202 Project Rental Assistance Contract

PRWORA Personal Responsibility and Work Opportunity Reconciliation Act

SAM System for Award Management

SAR Semiannual Report to Congress

SEMAP Section Eight Management Assessment Program

SFBGC Santa Fe Boys and Girls Club

SFDMS Single Family Default Monitoring System

Texas GLO Texas General Land Office

TIAC Tribal Intergovernmental Advisory Committee

TRACS Tenant Rental Assistance Certification System

USAID U.S. Agency for International Development

U.S.C. United States Code

VASH Veterans Affairs Supportive Housing
Appendix 6: OIG Directory | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 90

Appendix 6 - OIG Directory

Washington, DC 202-708-0364

Boston, MA 617-994-8380

Hartford, CT 860-240-9739

Philadelphia, PA 215-656-0500

Baltimore, MD 410-962-2520

Pittsburgh, PA 412-644-6428

Richmond, VA 800-842-2610

New York, NY 212-264-4174

Buffalo, NY 716-551-5755

Newark, NJ 973-622-7900

Atlanta, GA 404-331-3369

Greensboro, NC 336-547-4001

Miami, FL 305-536-5387

San Juan, PR 787-766-5540

Chicago, IL 312-913-8499

Columbus, OH 614-280-6138

Detroit, MI 313-226-6190

Headquarters

Fair Housing Audit 

Division

Single Family Housing 

(Originations)-Multifamily 

Insurance Audit Division

Disaster Recovery Audit 

Division (East)

Rental Assistance-Safe 

and Affordable Housing 

Audit Division Headquarters

Disaster Recovery Audit 

Division (West)

Ginnie Mae-Single 

Family Housing 

(Servicing) Audit Division

Grants Management

Fort Worth, TX 817-978-9309

Baton Rouge, LA 225-448-3975

Houston, TX 713-718-3199

New Orleans, LA 504-671-3000

Oklahoma City, OK 405-609-8606

San Antonio, TX 210-475-6800

Kansas City, KS 913-551-5870

Denver, CO 303-672-5471

Los Angeles, CA 213-894-8016

Las Vegas, NV 702-366-2100

Phoenix, AZ 602-379-7250

San Francisco, CA 415-489-6400

Washington, DC evaluations@hudoig.gov

Office of Evaluation

Office of Audit
Appendix 6: OIG Directory | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 91

Office of Investigation

Headquarters Washington, DC 202-708-0390

Region 1-2 New York, NY 212-264-8062

Buffalo, NY 212-264-8062

Boston, MA 617-994-8450

Hartford, CT 860-240-4800

Newark, NJ 973-776-7342

Region 3 Philadelphia, PA 215-861-7676

Richmond, VA 804-822-4890

Region 4 Atlanta, GA 404-331-5001

Greensboro, NC 336-547-4000

Miami, FL 305-536-3087

San Juan, PR 787-766-5872

Region 5 Chicago, IL 312-353-4196

Cleveland, OH 216-357-7800

Columbus, OH 614-280-6137

Detroit, MI 313-226-6280

Region 6 Fort Worth, TX 817-978-5440

Baton Rouge, LA 225-448-3941

Houston, TX 713-718-3097

New Orleans, LA 504-671-3700

Region 7-8 Denver, CO 303-672-5350

Kansas City, KS 913-551-5566

St. Louis, MO 314-539-6559

Region 9-10 Los Angeles, CA 213-894-8000

Phoenix, AZ 602-379-7251

San Francisco, CA 415-489-6400
HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 92

Diversity and Equal Opportunity

The promotion of high standards and equal employment opportunity for

employees and job applicants at all levels. HUD OIG reaffirms its commitment

to nondiscrimination in the workplace and the recruitment of qualified employees

without prejudice regarding their gender, race, religion, color, national origin,

sexual orientation, disability, or other classification protected by law. HUD OIG

is committed and proactive in the prevention of discrimination and ensuring

freedom from retaliation for participating in the equal employment opportunity 

process in accordance with departmental policies and procedures.
HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 93

WWW.HUDOIG.GOV

Report fraud, waste, and mismanagement

in HUD programs and operations by

Calling the HUD OIG Hotline: 

1-800-347-3735

Visiting online at

https://www.hudoig.gov/hotline

Report #87 Scan to report fraud