For the period October 1, 2020, to March 31, 2021

OFFICE OF INSPECTOR GENERAL

U.S. Department of Housing and Urban Development

SEMIANNUAL REPORT 

TO CONGRESS

OFFICE

INSPECTOR GENERAL

UNITED STATES DEPARTMENT OF

HOUSING AND URBAN DEVELOPMENT 

o f 
TABLE OF CONTENTS

HIGHLIGHTS......................................................................................................................................................................3

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

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

PROGRAM AREAS........................................................................................................................................................ 12

Housing......................................................................................................................................................................... 12

Public and Indian Housing..................................................................................................................................... 16

Community Planning and Development ......................................................................................................... 19

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

Other Significant Audits and Evaluations......................................................................................................... 23

Legislation, Regulations, and Other Directives............................................................................................... 27

Report Resolution ..................................................................................................................................................... 36

Whistleblower Ombudsman................................................................................................................................. 49

Peer Review Reporting............................................................................................................................................ 51

APPENDIXES.................................................................................................................................................................. 53

Appendix 1 – Reports Issued................................................................................................................................. 53

Appendix 2 – Tables.................................................................................................................................................. 58

Appendix 3 – Inspector General Empowerment Act ................................................................................... 92

Appendix 4 – Reporting Requirements...........................................................................................................101

Appendix 5 – Acronyms and Abbreviations..................................................................................................103

Appendix 6 – OIG Telephone Directory...........................................................................................................105
$

$

$

$

HIGHLIGHTS FOR THE PERIOD OCTOBER 1, 2020, TO MARCH 31, 2021

21 $90,201,682

$18,546,041 210

76

$12,864,667

$438,691,307 65 51

AUDIT AND EVALUATION

REPORTS PUBLISHED

COLLECTIONS FROM 

AUDITS

INDICTMENTS - 

INFORMATIONS

RECOMMENDED

QUESTIONED COSTS

RECOMMENDED FUNDS PUT 

TO BETTER USE

CONVICTIONS-PLEAS -

PRETRIAL DIVERSIONS

ARRESTS

TOTAL RECOVERIES - 

RECEIVABLES TO 

HUD PROGRAMS

SUBPOENAS

3 HIGHLIGHTS I HUD OIG Semiannual Report to Congress
A MESSAGE FROM

THE INSPECTOR GENERAL

4 A MESSAGE FROM THE INSPECTOR GENERAL I HUD OIG Semiannual Report to Congress

It is with great pride that I 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 from October 1, 2020 to March 31, 2021.

We faced challenges during this period unlike any that we have seen before. 

My office demonstrated our ability to adapt and produce quality, timely 

reports to inform policymakers and the public, and we continued protecting 

HUD funds from fraud, waste, and abuse. During this period our audit and 

evaluation work resulted in the publication of 21 reports identifying over 

$438 million in funds put to better use, over $12 million in questioned costs 

and $90 million in collections. Our investigations during this period resulted 

in over $18 million in recoveries for HUD programs. 

As the period closes, the fight against the COVID-19 pandemic continues 

and it will remain a central focus for HUD and my office. The assistance and 

relief provided through HUD’s pandemic response is crucial to the stability 

of American housing and communities. HUD was tasked with disbursing 

and overseeing more than $12 billion in grant funding provided under 

the Coronavirus Aid, Relief, and Economic Stability (CARES) Act, as well as 

implementing program changes to provide relief from evictions for renters 

and loan forbearance and foreclosure relief for homeowners. In March 2021, 

the passage of the American Rescue Plan (ARP) Act provided over $10 billion 

through HUD programs to fund emergency housing vouchers, homeless 

assistance and supportive services, fair housing initiatives, and housing 

assistance and supportive services for Native Americans. As an active 

member of the Pandemic Response Accountability Committee or PRAC, the 

OIG helps promote transparency and accountability of these funds through 

our independent oversight.

During this period, we concluded several audits, evaluations, and 

investigations related to HUD’s pandemic response. We used agile 

approaches and limited-scope reviews to examine HUD’s communications 

with the public regarding eviction protections, the drawdown levels of 

CARES Act grants, key considerations from prior audits relevant to FHA’s 

implementation of forbearance requirements, and the pandemic-related 

challenges disaster-recovery grantees were facing. 

We also initiated engagements focused on ensuring that timely and effective 

relief is provided to the intended recipients and those relief efforts are not 

undermined by fraud, waste, and abuse. We initiated work during the period 

to examine mortgage loan servicers compliance with HUD’s forbearance 

requirements and HUD’s communications to homeowners about forbearance 

options. We also initiated work to review HUD’s administration of $685 

million in supplemental operating funds provided to public housing agencies 

to prevent, prepare for, and respond to the pandemic. Additionally, we are 

working jointly with the PRAC to assess HUD’s identification of fraud risks 

in over $9 billion of CARES Act funding distributed through the Community 

Development Block Grant and Emergency Shelter Grant programs.
5 A MESSAGE FROM THE INSPECTOR GENERAL I HUD OIG Semiannual Report to Congress

In addition to our pandemic work, we concluded a number of audits, 

evaluations, and investigations focused on the health and safety of residents 

in HUD-assisted housing and protecting taxpayer funds. We identified that 

HUD needs to strengthen its approach for identifying HUD-assisted rental 

units near contaminated sites and mitigating resident exposure to those 

hazards. We also identified that the FHA needs to strengthen its controls to 

prevent ineligible mortgage loans on properties in special flood zones from 

becoming insured to prevent future losses to the FHA insurance fund. Based 

on the significant findings in that review, we initiated follow-on work in this 

area during the period to assess whether borrowers are maintaining flood 

insurance coverage. Additionally, we continue to utilize the False Claims Act 

in partnership with HUD and the Department of Justice as primary tool for 

combating fraud in HUD programs, evidenced by an agreement reached with 

an FHA lender to pay nearly $25 million to resolve allegations it knowingly 

submitting false claim to FHA for insurance benefits on defaulted mortgage 

loans. 

My office has also prioritized oversight of HUD’s Office of Fair Housing 

and Equal Opportunity (FHEO), which plays a vital role in eliminating 

discrimination in housing. To that end, we initiated an audit to examine how 

FHEO and its partners process discrimination complaints and determine 

whether full investigations are necessary.

The OIG continued influencing positive change in HUD programs during 

this period through our open recommendations “tiger team” collaboration 

with the Offices of the Chief Financial Officer. This collaboration reduced the 

number open recommendations to 1,116 at the end of this reporting period, 

which was 179 fewer than the prior period. HUD has addressed many OIG 

recommendations in the information technology and financial management 

areas resulting in a positive impact on HUD’s mission and operations allowing 

HUD to improve its maturity in financial management and information 

security. 

I want to express my sincere admiration to the staff of HUD OIG for their 

outstanding accomplishments and dedication. Throughout this challenging 

period, they demonstrated determination and excellence. Finally, I would like 

to thank you, our stakeholders, for your continued support and look forward 

to working together to further our efforts to improve housing opportunities 

for Americans nation-wide.

Inspector General

Rae Oliver Davis
SNAPSHOT

Spotlight

Our Fiscal Year 2021 performance has helped us deliver for the U.S. 

Department of Housing and Urban Development (HUD), Congress, and 

our other stakeholders, including HUD communities nationwide. Our 

work has helped the Department achieve its mission to create strong, 

sustainable, inclusive communities and quality affordable homes for all. 

Our scale, reach, and activities range from efforts to identify and mitigate 

health risks to residents living in HUD-funded properties to providing 

oversight of relief efforts provided by the Coronavirus Aid, Relief, and 

Economic Security Act (CARES Act), as well as providing oversight to more 

than 300 of HUD’s programs and operations. This section draws attention 

to our reports and performance since October 1, 2020.

FHA Insured $940 Million in Loans for Properties in Flood Zones 

Without the Required Flood Insurance

HUD’s Office of Inspector General (OIG) audited Federal Housing 

Administration (FHA)-insured loans that originated in calendar year 

2019. OIG’s audit objective was to determine whether FHA insured 

loans that were ineligible for insurance because they did not have the 

required flood insurance coverage. The National Flood Insurance Act 

of 1968 (Public Law 90-448) established the National Flood Insurance 

Program (NFIP). NFIP is a Federal program that enables property 

owners in participating communities to purchase flood insurance 

as protection against flood losses, while requiring State and local 

governments to enforce floodplain management ordinances that aim 

to reduce future flood damage. The Flood Disaster Protection Act 

of 1973 (Public Law 93-234) made the purchase of flood insurance 

mandatory for federally insured loans in special flood hazard areas 

(SFHA). The Biggert-Waters Insurance Reform Act of 2012 (Public 

Law 112-141) further amended the Federal flood insurance statutes 

to encourage private-sector participation. It did not apply to FHAinsured loans but, instead, applied to other types of loans. FHA’s 

current rules regarding the requirement to maintain flood insurance 

coverage on property located in an SFHA do not permit private flood 

insurance as an option to satisfy the purchase requirement. To qualify 

for FHA insurance, properties in an SFHA must be covered by NFIP 

insurance in an amount equal to either the outstanding balance of the 

mortgage, less estimated land costs, or the maximum amount of NFIP 

insurance available, whichever is less.

OIG found that FHA insured at least 3,870 loans that closed in 2019, 

totaling $940 million, which were not eligible for insurance because 

they were made for properties in flood zones without the required 

flood insurance coverage. 

OIG found loans that either did not have the required flood policies 

or had policies that did not meet the minimum amount required 

by FHA guidance. These conditions occurred because FHA did not 

require underwriters to enter information into HUD systems to show 

compliance with Federal flood insurance regulations. Underwriters 

did not enter information into FHA’s system regarding whether an NFIP 

flood insurance policy was obtained or the coverage amount. They 

6 SNAPSHOT I HUD OIG Semiannual Report to Congress
also did not enter the flood zone or the site value, both of which would 

be needed to determine whether insurance was required and if so, the 

minimum coverage amount. FHA also did not have a control mechanism 

in place to prevent endorsement of loans that did not comply with the 

flood insurance requirement.

OIG recommended that FHA require lenders to provide evidence of 

sufficient flood insurance or execute indemnification agreements for 

the 43 loans in the statistical sample that did not have sufficient flood 

insurance at the time of the audit. OIG also recommended that FHA add 

to HUD databases the information necessary to ensure that the required 

flood insurance is obtained. (Audit Report: 2021-KC-0002)

Opportunities Exist to Improve HUD’s Communication to Renters 

About Eviction Protections

As part of the CARES Act, OIG reviewed HUD’s communication to renters 

regarding the eviction moratorium found in Section 4024. The Section 

4024 eviction moratorium protects millions of households residing in 

properties that participate in certain housing programs or have federally 

backed mortgage loans. These households include renters connected 

to HUD’s public housing and rental assistance programs as well as those 

who rent in FHA-insured single-family homes, FHA-insured multifamily 

properties, and other properties related to HUD programs. 

OIG’s objective was to highlight HUD’s progress and identify areas for 

improvement. OIG found that HUD provided critical information to many 

of these renters through its website and published guidance. 

However, OIG identified several aspects of HUD’s communication to 

renters on its website and published guidance that could be strengthened 

and areas of the joint website that could be improved. 

For example, (1) guidance for renters can be difficult to locate, does 

not cover all impacted renters, and does not consistently provide key 

information; (2) search tools and other information on its website do not 

help all impacted renters determine whether they are protected; and (3) 

HUD’s website and published guidance do not consistently inform renters 

about additional eviction protections available. 

While the Section 4024 eviction moratorium expired on July 24, 2020,1

it is still crucial that HUD have clear, complete, and accessible guidance 

available to help renters at a time when their health and financial 

stability may be at risk. If HUD maintains up-to-date and easily accessible 

information for all impacted renters, it will help to ensure that renters 

know their rights, maintain housing stability through the pandemic, and 

avoid homelessness. (Audit Memorandum: 2021-NY-0801)

1

Mortgagee Letter 2021-05, published February 16, 2021, extends the foreclosure and eviction moratorium through June 20, 2021.

7 SNAPSHOT I HUD OIG Semiannual Report to Congress
HUD and Its CDBG-DR Grantees Have Experienced Challenges Related 

to the COVID-19 Pandemic

OIG completed a survey of the impact of the COVID-19 pandemic on 

HUD’s Community Development Block Grant Disaster Recovery (CDBGDR) grantees to determine the challenges that HUD and its grantees 

are experiencing related to the COVID-19 pandemic and to help inform 

the Office of Community Planning and Development and Congress on 

the issues faced in responding to the pandemic. The survey focused on 

key questions regarding the grantees’ challenges and experiences with 

respect to their ability to monitor CDBG-DR activities, future challenges in 

administering the program as a result of the pandemic, additional support 

they will need to effectively administer the program, and whether HUD’s 

revised requirements address the challenges. 

Many HUD CDBG-DR grantees reported facing challenges with 

alternative systems-technology and communications with program 

participants, subrecipients, contractors, and local governments and 

reported substantial challenges with project construction delays and 

incurring additional costs due to State-ordered shutdowns and scarcity of 

materials. 

Other challenges reported by the grantees included adjusting to the 

technology for virtual monitoring, construction resources and lack of 

capacity, travel restriction impact on tourism-based project activities, 

fear of possible COVID-19 infection and case resurgence, telework and 

managing work-home balance, and ensuring having essential equipment 

and technology. OIG determined that there were eight recurring themes 

faced by CDBG-DR grantees and HUD officials during the COVID-19 

pandemic. Although HUD’s assistance emerged as a recurring theme, 

grantees identified a range of actions and coordination efforts they 

received from HUD in response to the pandemic. OIG did not identify 

HUD assistance as a challenge but an opportunity for HUD to continue 

to cultivate its relationship with the grantees and collaborate with them 

to help them navigate and maintain continuity of operations during this 

emergency situation. OIG issued a memorandum, which contained no 

recommendations. (Audit Memorandum: 2021-GA-0801)

Contaminated Sites Pose Potential Health Risks to Residents at HUDFunded Properties

The West Calumet Housing Complex (WCHC), located in East Chicago, IN, 

is a housing development that opened on top of a former lead smelting 

plant in 1972. WCHC was built on the former site of Anaconda Lead 

Products and the International Lead Refining Company and downwind 

of the USS Lead facility, all part of the USS Lead Superfund site. Lead 

is one of the most commonly found hazards at Superfund sites. In 

2009, the Environmental Protection Agency (EPA) put the USS Lead site 

on the National Priorities List for contamination cleanup. As of 2016, 

approximately 1,100 residents, about 680 of whom were children, resided 

in WCHC. On August 3, 2016, HUD officially ordered the relocation of 

WCHC’s residents due to lead contamination. The City of East Chicago 

began demolition of WCHC in 2018 and completed it by June 2019. 

OIG’s objectives were to determine (1) the circumstances surrounding 

the resident lead poisoning at WCHC, (2) what steps HUD has taken to 

determine the potential health risks posed to residents in HUD-funded 

8 SNAPSHOT I HUD OIG Semiannual Report to Congress
properties by Superfund and non-Superfund sites contaminated with 

heavy metals, and (3) what HUD has done to mitigate these potential 

health risks.

HUD developed two environmental review regulations in response to 

the National Environmental Policy Act of 1969 (NEPA). The objective 

of NEPA was, in part, to stimulate the health and welfare of the people. 

NEPA also established a national policy that would encourage harmony 

between people and their environment and promoted efforts to prevent 

or eliminate damage to the environment. Both regulations state that it is 

HUD policy that “[a]ll property proposed for use in HUD programs be free 

of hazardous materials, contamination, toxic chemicals and gasses, and 

radioactive substances, where a hazard could affect the health and safety 

of occupants or conflict with the intended utilization of the property.” 

“They also state that particular attention should be given to any 

proposed site on or in the general proximity of such areas as dumps, 

landfills, industrial sites, or other locations that contain hazardous 

wastes.” 

HUD’s Office of Environment and Energy, within the Office of Community 

Planning and Development, has overall departmental responsibility 

for policies and procedures that implement NEPA and related laws and 

authorities known as compliance factors. 

HUD and other agencies missed multiple opportunities to identify site 

contamination at WHCH, resulting in residents’ continuing to live in unsafe 

conditions for decades, and inadequate oversight led to the lead poisoning 

of children. HUD would have become aware of lead contamination at 

WCHC sooner if HUD and the City of East Chicago had properly conducted 

environmental reviews or if better communication among Federal, State, 

and City authorities had occurred. HUD partnered with and relied on 

the EPA to identify and develop a mitigation strategy for contaminated 

HUD-funded properties. Since 2016, HUD and EPA have been working to 

update a list of HUD-funded properties on or near contaminated sites, and 

while HUD has taken steps to improve communication with EPA, it can do 

more with the information it receives to understand how contaminated 

sites might impact HUD-funded properties. OIG recommended that HUD 

develop and implement strategies to research properties and determine 

whether site contamination should be considered in future reviews 

and monitor those reviews. Also, OIG recommended that HUD monitor 

completed environmental reviews for properties identified as potentially 

contaminated to ensure that site contamination was appropriately 

considered. (Evaluation Report: 2019-OE-0003)

9 SNAPSHOT I HUD OIG Semiannual Report to Congress
Making an impact

OIG’s oversight work results in recommendations to encourage improvements 

in the conduct of government programs and operations. This section 

highlights connections between OIG’s work and positive impact for 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.

HUD Program Area: Office of the Chief Information Officer

HUD closed 27 recommendations associated with information technology 

(IT) and information security evaluations completed by HUD OIG. Some of 

those recommendations had been longstanding since 2014. Most of those 

recommendation impacted one of the eight Federal Information Security 

Modernization Act of 2014 (FISMA) domains. Three of the FISMA domains, 

including Risk Management, IT Security Training, and Incident Response, 

had maturity level improvements.

OIG’s fiscal year (FY) 2020 FISMA evaluation found that HUD consistently 

implemented the IT security metrics that are used to measure the 

maturity of HUD’s IT security program. 

HUD’s maturity had been at the “defined” level since FY 2018 when all 

Federal agencies began conducting annual evaluations in accordance 

with the maturity model criteria. The concerted effort to close 

recommendations correlates to HUD’s increased maturity level. This 

is a stepping-stone toward HUD’s achieving the next maturity level of 

“managed and measurable,” which the Office of Management and Budget 

associates with an effective program.

The Office of the Chief Financial Officer, Ginnie Mae, FHA

HUD closed 10 recommendations that focused on deobligating funds not 

needed, correctly accounting for and taking appropriate action to track 

and pursue funds owed to HUD, and recognizing unrecorded assets and 

liabilities related to leasehold improvements. The Government National 

Mortgage Association (Ginnie Mae), HUD’s component entity, also closed 

seven recommendations that focused on improving Ginnie Mae’s financial 

management governance, specifically in the areas of models used for its 

estimates and its financial systems.

Further, HUD closed three significant deficiencies and two instances 

of noncompliance with laws and regulations, Ginnie Mae closed two 

material weaknesses and one instance of noncompliance, and FHA closed 

one significant deficiency and reported no internal control findings or 

instances of noncompliance with laws and regulations in its audit report. 

Many of these findings represented longstanding deficiencies in HUD’s 

overall financial management environment.

The work that HUD and its component entities have done over the past 

year, along with the closure of recommendations and internal control 

findings during this semiannual reporting period, have helped HUD and 

Ginnie Mae to achieve clean opinions on their financial statements for the 

first time in 8 years. 

10 SNAPSHOT I HUD OIG Semiannual Report to Congress
This work reflects the improvements HUD and its component entities 

have made in their financial management environment, which we have 

reported as one of HUD’s top management challenges for the last several 

years. 

A clean opinion provides stakeholders of HUD’s financial statements with 

reasonable assurance that the information contained in HUD’s financial 

statements is accurate, which helps stakeholders make more informed 

decisions about HUD’s current operations and future needs. It also 

gives HUD more credibility with the public. Further, reducing material 

weaknesses and significant deficiencies in HUD’s controls is essential to 

building sound financial management. These improvements have allowed 

HUD to improve its financial management posture, based upon on the U.S. 

Department of the Treasury’s Financial Management Maturity Model.

11 SNAPSHOT I HUD OIG Semiannual Report to Congress
HOUSING AUDIT

INVESTIGATION

The Office of Housing plays a vital role for the nation’s homebuyers, homeowners, renters, and communities through its nationally administered programs. It 

includes Single Family Housing, Multifamily Housing, and the Federal Housing Administration (FHA), the largest mortgage insurer in the world. FHA singlefamily programs provide mortgage insurance to mortgage lenders that, in turn, provide financing to enable individuals and families to purchase, rehabilitate, 

or construct homes. With the multifamily housing developments with the Office of Housing and Urban Development-held (HUD) or HUD-insured mortgages 

and the Office of Healthcare Programs, HUD subsidizes rents for low-income households, finances the construction or rehabilitation of rental housing, and 

provides support services for the elderly and disabled. Some of the highlights from this semiannual period are noted in this chapter.

$0

RECOMMENDED

QUESTIONED COSTS

5

$437,835,534

KEY PROGRAM

RESULTS

RECOMMENDED FUNDS 

PUT TO BETTER USE

$32,908,467

INVESTIGATIVE

RECOVERIES

25

CONVICTIONS - PLEAS -

PRETRIAL DIVERSIONS

13

ADMINISTRATIVE - 

CIVIL ACTIONS

12 HOUSING I HUD OIG Semiannual Report to Congress
OFFICE OF AUDIT

Key Considerations From Prior Audits of the Single Family 

Default Monitoring System and the Partial Claim Loss 

Mitigation Option

The Office of Inspector General (OIG) provided a memorandum to HUD 

with key considerations from prior audits of the HUD Single Family 

Default Monitoring System (SFDMS) and the partial claim loss mitigation 

option. In past audits, OIG identified HUD’s lack of effective controls 

for ensuring that lenders reported timely and accurate information on 

defaults and promptly filed for partial claims and that partial claims fully 

reinstated delinquent loans. Additionally, OIG identified that the current 

design of partial claims results in an inferior lien position on the securing 

property during a foreclosure sale. OIG recommended that HUD address 

this situation now to ensure program integrity and minimize the risk of 

financial loss during the COVID-19 pandemic. 

Agencywide, Audit Memorandum: 2021-KC-0801

Necessary System Interfaces Between HERMIT and the 

National Servicing Center Were Not in Place

OIG audited selected general and application controls of the FHA Home 

Equity Reverse Mortgage Information Technology (HERMIT) system 

as part of the internal control assessments required for the fiscal year 

2019 financial statement audit under the Chief Financial Officer’s Act of 

1990. OIG’s objective was to review the selected controls over HERMIT 

for compliance with HUD information technology policies and Federal 

information system security and financial management requirements. This 

report is not available for public disclosure. 

Agencywide, Audit Report: 2021-DP-0002

FHA Insured $940 Million in Loans for Properties in Flood 

Zones Without the Required Flood Insurance

OIG audited FHA-insured loans that originated in calendar year 2019. 

OIG’s objective was to determine whether FHA insured loans that were 

not eligible for insurance because they did not have the required flood 

insurance coverage. OIG found that FHA insured at least 3,870 loans 

that closed in 2019, totaling $940 million, which were not eligible for 

insurance because they were made for properties in flood zones without 

the required flood insurance coverage. OIG recommended that FHA 

require lenders to provide evidence of sufficient flood insurance or execute 

indemnification agreements for the 43 loans in the statistical sample that 

did not have sufficient flood insurance at the time of the audit. OIG also 

recommended that FHA add to HUD databases the information necessary 

to ensure that the required flood insurance is in place at loan origination. 

Agencywide, Audit Report: 2021-KC-0002

13 HOUSING I HUD OIG Semiannual Report to Congress
HUD’s Office of Multifamily Housing Programs Did Not 

Always Follow Mitigation Requirements for Its FHA-Insured 

Multifamily Projects

OIG audited HUD’s Office of Multifamily Housing Programs. The 

objective was to determine whether (1) a complainant’s allegations were 

substantiated for the 8 properties reviewed and (2) HUD properly followed 

mitigation requirements for the 17 properties reviewed. OIG found 

that HUD did not always properly follow mitigation requirements for its 

Federal Housing Administration-insured multifamily projects and did not 

conduct the required radon mitigation for one of its projects before final 

endorsement because multifamily HUD Environmental Review Online 

System (HEROS) users lacked training, HUD did not have procedures in 

place, and radon requirements were not updated on the closing documents. 

OIG recommended that HUD (1) conduct and make available internal 

HEROS training for all multifamily HEROS users on how to document the 

environmental review mitigation measures, (2) establish and implement 

written procedures specifying which multifamily employees are required 

to upload mitigation resolutions after construction completion and at 

final endorsement, (3) upload the 17 missing mitigation resolutions and 

the 1 missing radon testing document into HEROS for the projects in this 

finding, (4) strengthen HEROS or internal procedures to add a requirement 

confirming that the mitigation resolutions have been uploaded at final 

endorsement, and (5) strengthen HEROS by adding a column on the 

dashboard to show the progress of the overall mitigation status. 

Agencywide, Audit Report: 2021-KC-0001

Interim Audit Memorandum – The HUD Single Family 

Insurance Operations Division Should Take Additional 

Action To Inform Homeowners of Changes to Its FHA Refund 

Process Resulting From the COVID-19 Pandemic

OIG audited HUD’s response to COVID-19 to determine (1) whether it 

appropriately, effectively, and efficiently tracked, monitored, and issued FHA 

refunds owed to homeowners with terminated loans, and (2) how COVID-19 

has affected policies, procedures, and distribution of FHA refunds and 

whether HUD’s response was appropriate. OIG determined that COVID-19 

generally did not affect the Single Family Insurance Operations Division’s 

(SFIOD) FHA refund policies and procedures; however, SFIOD did not fully 

notify homeowners of operational changes to its physical mail procedures, 

which potentially impacted its distribution of refunds. The audit prompted 

HUD to take immediate corrective action for all three recommendations, one 

of which will be closed concurrently with the issuance of this memorandum 

and two of which will be completed during audit resolution. 

Agencywide, Audit Memorandum: 2021-LA-0802

14 HOUSING I HUD OIG Semiannual Report to Congress
OFFICE OF INVESTIGATION

HUD-Approved Direct Endorsement Lender Agrees To Pay 

$24.9 Million

Guild Mortgage Company, a HUD-approved direct endorsement lender, 

entered into a settlement agreement with the United States and agreed 

to pay $24.9 million, of which $16.9 million will be paid to FHA to resolve 

allegations that the lender violated the False Claims Act. Guild Mortgage 

Company failed to comply with program rules that require lenders to 

maintain quality control programs and failed to follow the self-reporting 

requirements. Although Guild Mortgage Company’s participation in 

this settlement did not constitute an admission of liability, the defined 

unallowable costs make it clear that the company certified and approved 

loans that were not eligible for FHA mortgage insurance and that without 

the lender’s actions, HUD would not have insured or guaranteed the loans. 

The lender also indicated in the agreement that it would identify similar 

situations not covered by this agreement and reimburse the United States 

for additional unallowable costs. 

Washington, DC

Investors Agree To Pay HUD $200,000 in Real Estate-Owned 

Flipping Scheme

Laziza Abdullaeva and Aziz Ashurov, real estate investors, entered into a 

settlement agreement with the United States and agreed to pay $200,000 to 

HUD to resolve allegations that they violated HUD’s real estate-owned (REO) 

program rules. During the purchase of four REO properties, Abdullaeva 

and Ashurov falsely represented to HUD that they intended to occupy the 

properties as a primary residence for a period of 12 months. Abdullaeva 

and Ashurov failed to comply with the residency requirement and, instead, 

purchased, renovated, and resold the properties through their real estate 

investment company, Capital Invest, LLC. HUD OIG conducted this 

investigation. 

Nashville, TN

Trio Sentenced in Mortgage Loan Modification Scheme

Sara Cordry and Ruby Price, co-owners of The Arize Group, Incorporated 

(AGI), and Tylor Korn, co-owner of Reliant Home Financial Group (RHFG), 

were collectively sentenced in U.S. District Court to 63 months incarceration, 

6 years supervised release, and 1 year probation. Cordry was convicted of 

conspiracy, mail fraud, and wire fraud. She also pleaded guilty to defrauding 

HUD and was ordered to pay more than $1 million in restitution to FHA. 

Korn and Price were ordered to pay jointly and severally more than $1.3 

million in restitution to individual victims in connection with their guilty 

pleas to conspiracy to commit mail and wire fraud. During a 1-year span, 

the conspirators, through AGI and RHFG, orchestrated a mortgage loan 

modification scheme, whereby they promised struggling homeowners that 

they would provide them with mortgage modification services in exchange 

for an advance fee. However, no modification services were provided, 

and the homeowners often found themselves worse off financially than 

they were before dealing with the conspirators. HUD OIG and the Federal 

Housing Finance Agency OIG conducted this investigation. 

Kansas City, KS

15 HOUSING I HUD OIG Semiannual Report to Congress
PUBLIC AND INDIAN HOUSING AUDIT INVESTIGATION

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 assistance directly 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.

$0

RECOMMENDED

QUESTIONED COSTS

3

$1,550

KEY PROGRAM

RESULTS

RECOMMENDED FUNDS 

PUT TO BETTER USE

$3,699,065

INVESTIGATIVE

RECOVERIES

21

CONVICTIONS - PLEAS -

PRETRIAL DIVERSIONS

45

ADMINISTRATIVE - 

CIVIL ACTIONS

16 PUBLIC AND INDIAN HOUSING I HUD OIG Semiannual Report to Congress
OFFICE OF AUDIT

HUD’s PIH Office of Field Operations Generally Confirmed 

That PHAs Complied With the Implementing Guidance of 

HUD’s Smoke-Free Policy Requirements

HUD’s Office of Inspector General (OIG) audited HUD’s Office of Public 

and Indian Housing (PIH), Office of Field Operations’ (OFO) oversight 

of PHA compliance in implementing HUD’s smoke-free policy. OIG’s 

objective was to determine whether OFO ensured that PHAs complied 

with implementation guidance for HUD’s smoke-free policy requirements 

in public housing programs. OFO generally confirmed that it provided 

technical assistance to PHAs before the implementation deadline to help 

ensure their compliance and obtained self-reporting from a majority 

of more than 3,000 PHAs that they had obtained their board’s approval 

for implementing the policy and had amended their tenants’ leases as 

required. This report contains no recommendations. 

Agencywide, Audit Report: 2021-AT-0001

Use of Landlord Incentives in the Housing Choice Voucher 

Program

OIG conducted a limited review to determine the use of landlord 

incentives to increase landlord participation and retention and expand 

housing options for program participants outside areas of low-income 

or minority concentration. The majority (28 of 34) of responsive Moving 

to Work (MTW) PHAs used the program and funding flexibilities of the 

MTW program to offer landlord incentives. These PHAs generally stated 

that the incentives they offered were somewhat effective, but it should 

be acknowledged that the effectiveness of an incentive varied widely. 

HUD should consider conducting further studies of incentives to better 

understand their effectiveness, which can help HUD better serve and 

connect with its landlords. 

Agencywide, Audit Memorandum: 2021-LA-0803

Review of the Nampa Housing Authority’s Public Housing 

Program

OIG audited the Nampa Housing Authority’s public housing program. The 

objective was to determine whether the Authority followed HUD public 

housing requirements pertaining to (1) calculating contract rents, (2) 

maintaining its waiting lists, (3) providing its staff the credentials needed 

to access HUD systems, and (4) storing and securing tenant files. OIG 

found that the Authority charged 11 tenants the incorrect rent for at least 

1 month, improperly maintained its waiting lists for housing tenants out 

of order, could not show that all HUD system users had proper credentials 

and that only employees with credentials accessed the system, and 

generally stored and secured tenant files properly. OIG recommended that 

HUD require the Authority to (1) reimburse the six tenants who overpaid 

rent totaling $1,550 using non-Federal funds; (2) develop and implement 

internal control procedures that support its policy and ensure a proper 

tenant selection process when selecting tenants for housing; and (3) 

ensure that it follows all applicable HUD requirements related to accessing, 

using, and safeguarding credentials of HUD systems. 

Nampa, ID, Audit Memorandum: 2021-SE-1801

17 PUBLIC AND INDIAN HOUSING I HUD OIG Semiannual Report to Congress
OFFICE OF INVESTIGATION

Landlord Agrees to Pay $180,000 After Collecting Illegal 

Rents From HUD-Assisted Tenants

Hans Kuhn, Housing Choice Voucher Program (HCVP) landlord and 

owner of QN Corporation, entered into a settlement agreement with the 

United States and agreed to pay $180,000, of which $140,000 will be paid 

to HUD, to resolve allegations that he and QN Corporation knowingly 

violated the False Claims Act when they charged and collected rents from 

multiple tenants who received rental assistance through HUD’s HCVP. The 

additional rents collected violated contractual and regulatory certifications 

and conditions for rental subsidy payments by including rents for units 

subsidized under HUD’s HCVP that exceeded rents permitted by contract 

and the PHA. HUD OIG conducted this investigation. 

Chicago, IL

Former Public Housing Agency Executive Director 

Sentenced to 5 Years Probation

Tana Gutierrez, former executive director of a PHA, was sentenced in 

U.S. District Court in connection to her earlier guilty plea to theft from 

programs receiving Federal funds. Gutierrez was sentenced to 5 years 

probation and ordered to pay a $23,258 special assessment to HUD. For 

more than 3 years, Gutierrez awarded herself duplicate payroll checks, 

unauthorized overtime payments, and unauthorized payments from the 

PHA’s Public Housing Capital Fund program, resulting in an overpayment 

of payroll and bonuses, which were not approved by the PHA’s board of 

directors. HUD OIG and the Federal Bureau of Investigation conducted this 

investigation. 

Del Rio, TX

Convicted Sex Offender Found Living in HUD-Subsidized 

Housing Sentenced to 10 Years Incarceration

Kristopher Boutin, a previously convicted sex offender subject to 

lifetime sex offender registration, was sentenced in U.S. District Court 

to 10 years incarceration for failing to register as a sex offender with the 

State of California upon his arrival in the State in 2013 in violation of 

the Sex Offender Registration and Notification Act. While in California, 

Boutin resided in a HUD-subsidized Continuum of Care rental unit as an 

unauthorized tenant in violation of HUD’s program regulations. HUD 

OIG, the U.S. Marshals Service-Sex Offender Investigations Branch, and 

Homeland Security Investigations conducted this investigation. 

Los Angeles, CA

18 PUBLIC AND INDIAN HOUSING I HUD OIG Semiannual Report to Congress
COMMUNITY PLANNING AND DEVELOPMENT AUDIT INVESTIGATION

The Office of Community Planning and Development (CPD) seeks 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. The primary means toward this end is 

the development of partnerships among all levels of government and the private sector. 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) 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 $89.8 billion in CDBG-DR and CDBG Mitigation (CDBG-MIT) grants to help cities, counties, and States recover 

from presidentially declared disasters. Of the $89.8 billion in disaster allocations that have been allocated nationwide, nearly $69.3 billion has been obligated 

and more than $45.3 billion has been disbursed as of the end of the period.

$7,101,383

RECOMMENDED

QUESTIONED COSTS

4

$854,223

KEY PROGRAM

RESULTS

RECOMMENDED FUNDS 

PUT TO BETTER USE

$4,020,006

INVESTIGATIVE

RECOVERIES

19

CONVICTIONS - PLEAS -

PRETRIAL DIVERSIONS

8

ADMINISTRATIVE - 

CIVIL ACTIONS

19 COMMUNITY PLANNING AND DEVELOPMENT I HUD OIG Semiannual Report to Congress
OFFICE OF AUDIT

HUD and its CDBG-DR grantees have experienced 

challenges related to the COVID-19 Pandemic

HUD’s Office of Inspector General (OIG) completed a survey of the impact 

of the COVID-19 pandemic on HUD’s CDBG-DR grantees to determine 

the challenges that HUD and its grantees are experiencing related to the 

COVID-19 pandemic and to help inform HUD and Congress on the issues 

faced in responding to the pandemic. Many HUD CDBG-DR grantees 

reported facing challenges with systems-technology and communications 

and reported substantial challenges with project construction delays and 

incurring additional costs. Other challenges reported by the grantees 

included monitoring, construction resources and lack of capacity, travel 

restrictions and telework, and work-home balance. OIG determined that 

there were eight recurring themes faced by CDBG-DR grantees and HUD 

officials during the COVID-19 pandemic. OIG issued a memorandum, 

which contained no recommendations. 

Agencywide, Audit Memorandum: 2021-GA-0801

Neighborhood Housing Services of Los Angeles County, Los 

Angeles, CA, Did Not Always Follow Program Requirements 

in Administering Its NSP2

OIG audited the Neighborhood Housing Services of Los Angeles County’s 

(NHSLA) Neighborhood Stabilization Program 2 (NSP2). The objective 

was to determine whether NHSLA administered its NSP2 in accordance 

with program requirements, focusing on procurement and contracting 

expenditures of program income. NHSLA did not always follow program 

requirements in administering its NSP2. OIG found that HUD did not have 

assurance that more than $5.1 million in program income was used for its 

NSP2, $1.7 million in salary expenditures was in accordance with program 

requirements, and $85,692 in construction costs was reasonable. OIG 

provided HUD with six recommendations requiring NHSLA to support 

these costs or repay them. 

Los Angeles, CA, Audit Report: 2021-LA-1002

Drawdown Levels for the Initial Round of CARES Act 

Emergency Solutions Grants Were Minimal

OIG conducted a limited review to identify the HUD Coronavirus Aid, 

Relief, and Economic Security Act (CARES Act) drawdown levels for the 

initial round of Emergency Solutions Grants (ESG) funding. The objective 

was to highlight the grantees’ (1) drawdown levels for the initial round of 

ESG CARES Act funding and (2) published information on how the funds 

have been and will be used. The review determined that as of July 1, 2020, 

the ESG CARES Act drawdown levels for the initial round of funding of $1 

billion had been minimal. Most grantees in the sample had not elected to 

waive their citizen participation plans or indicated whether they would use 

their consultation waiver, and many had not published their planned uses 

of the funds. OIG did not make any recommendations to HUD. 

Agencywide, Audit Memorandum: 2021-LA-0801

20 COMMUNITY PLANNING AND DEVELOPMENT I HUD OIG Semiannual Report to Congress
The City of Compton, Compton, CA, Did Not Always 

Administer Neighborhood Stabilization Program Funds in 

Compliance With Procedures and Regulations

OIG audited the City of Compton’s Neighborhood Stabilization Programs 

(NSP) 1 and 3. The objective was to determine whether the City 

administered NSP1 and NSP3 funds in compliance with its own procedures 

and HUD regulations. The City did not implement its procurement controls 

and experienced high staff turnover, which did not allow it to administer 

these programs in compliance with HUD regulations. As a result, the City 

did not give vendors the opportunity to bid in fair and open competition 

for the services needed in the targeted areas. Also, the City disbursed 

a total of $272,206 in questioned program expenses, and the City’s late 

submission of required reports to HUD and lack of posting performance 

reports on its website prevented stakeholders from knowing the progress 

of its program-funded projects and activities. OIG recommended that 

HUD require the City to (1) implement procurement controls to maintain 

complete procurement documents, (2) provide adequate documents to 

support $270,656 in program expenses, and (3) submit future required 

reports to HUD on time and post the missing and future HUD quarterly 

performance reports on its website. 

Compton, CA, Audit Report: 2021-LA-1001

OFFICE OF INVESTIGATION

United Cerebral Palsy of Northern, Central, and Southern 

New Jersey Ordered To Dissolve and Pay $385,000 in 

Restitution and Fines

The United Cerebral Palsy of Northern, Central, and Southern New Jersey 

Inc. (UCPNCSNJ), a nonprofit corporation, was sentenced in the Superior 

Court of New Jersey in connection to its earlier guilty plea to theft by 

failure to make required disposition of property received. UCPNCSNJ 

was sentenced to dissolve the company and ordered to pay $225,000 in 

restitution to United Cerebral Palsy’s national organization and $160,000 

in civil fines to the State of New Jersey for failure to register as a charitable 

organization. For nearly 1 year, UCPNCSNJ failed to register as a charitable 

organization within the State of New Jersey and purposely obtained and 

retained funds that were to be used for helping individuals with cerebral 

palsy or similar charitable activities. UCPNCSNJ also applied as a nonprofit 

organization and received 2 HUD-funded CDBG-DR loans totaling 

$920,000, which were administered by the State of New Jersey and were 

for the construction of 9 single-family homes and the conversion of a 

hotel into an 84-unit condominium for low- to moderate-income families 

and housing to service disabled individuals. The allegations of fraud and 

misuse of the CDBG-DR loan funds were unsubstantiated. HUD OIG and 

the New Jersey Division of Criminal Justice conducted this investigation. 

Chester, NJ

21 COMMUNITY PLANNING AND DEVELOPMENT I HUD OIG Semiannual Report to Congress
13 Conspirators Sentenced in Scheme To Defraud 

Homeless-Serving Nonprofit

Clarissa Combs, Bridgit Michaud, Aishia Bell, former employees of a 

nonprofit organization that provides housing and related services to 

the homeless, and Jalonda Combs, Aisha Davis, Anthony Oliver, Leteaste 

Henry-Davis, Rachael Ekholm, Sharre Rush, Shaneka Mzee, Audrey Heath, 

Neal Burton, and Tyrone Burton, purported landlords and vendors of the 

nonprofit, were collectively sentenced in U.S. District Court to 10 years 

incarceration, 32 years supervised release, and 1,125 hours community 

service and ordered to pay $684,081 in restitution jointly and severally to 

the nonprofit. For nearly 7 years, the conspirators devised and participated 

in a scheme to defraud $684,081 in funds intended to help the homeless 

by recruiting other employees of the nonprofit, as well as friends, family 

members, and associates, to pose as landlords and vendors, causing the 

nonprofit to make direct payments to the fictitious landlords and vendors, 

who then provided Combs with monetary kickbacks. The nonprofit 

receives its funding from private donors, charitable foundations, and 

HUD’s ESG program, among others, to provide services to the homeless. 

An undetermined amount of the embezzled funds was attributable to the 

ESG program. HUD OIG, the U.S. Postal Inspection Service, and the Federal 

Bureau of Investigation conducted this investigation. 

Minneapolis, MN

22 COMMUNITY PLANNING AND DEVELOPMENT I HUD OIG Semiannual Report to Congress
OTHER SIGNIFICANT 

AUDITS AND 

EVALUATIONS

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

Inspector General’s (OIG) more significant reports are highlighted in this 

chapter.

OFFICE OF AUDIT

Reimbursements Received Through Rent Credits From the 

General Services Administration

OIG initiated an audit of the rent credits that HUD received from the 

General Services Administration (GSA) during fiscal years 2015 through 

2018 due to concerns OIG identified while completing a review of HUD’s 

use of funds approved by Congress for building improvements. OIG’s 

objective was to determine whether HUD accounted for and managed 

rent credits issued by GSA in exchange for HUD’s financial contributions for 

building improvements in accordance with applicable requirements. OIG 

found that HUD did not properly account for and manage reimbursements 

totaling nearly $7.8 million, which it obtained through rent credits issued 

to it by GSA in 2017 in exchange for improvements that it made in its 

headquarters building in 2016, that HUD exceeded its fiscal year 2017 

appropriated funding level and potentially violated the Antideficiency Act, 

and that HUD’s Chief Financial Officer has the sole authority to investigate 

this potential violation and determine whether HUD was required to 

deposit the value of rent credits into the U.S. Department of the Treasury’s 

general funds. OIG recommended that HUD’s Chief Financial Officer 

investigate the facts surrounding the potential Antideficiency Act violation 

and develop corrective action plans and take disciplinary actions if it is 

determined that a violation has occurred. 

Agencywide, Audit Report: 2021-PH-0002

Fiscal Year 2019 Review of Information Systems Controls in 

Support of the Financial Statements Audit

OIG audited the information systems controls over HUD’s computing 

environment as part of the internal control assessments for the fiscal year 

2019 financial statements audit under the Chief Financial Officer’s Act of 

1990. The objective was to assess general controls over HUD’s computing 

environment for compliance with HUD information technology policies 

and Federal information system security and financial management 

requirements, with a focus on the general controls over HUD’s IBM 

mainframe general support system. OIG has determined that the contents 

of this audit report would not be appropriate for public disclosure and 

has, therefore, limited its distribution to those officials listed on the report 

distribution list. 

Agencywide, Audit Report: 2021-DP-0001

23 OTHER SIGNIFICANT AUDITS AND EVALUATIONS I HUD OIG Semiannual Report to Congress
Audit of HUD’s Fiscal Year 2020 Consolidated Financial 

Statements

In accordance with the Chief Financial Officers Act of 1990, as amended, 

OIG is required to annually audit the consolidated financial statements of 

HUD. OIG’s objective was to express an opinion on the fair presentation 

of HUD’s consolidated financial statements in accordance with U.S. 

generally accepted accounting principles applicable to the Federal 

Government. OIG identified deficiencies that constituted one material 

weakness and one instance of noncompliance with applicable laws, 

regulations, contracts, and grant agreements. This report contains several 

current recommendations for corrective actions addressed to the Offices 

of the Chief Financial Officer, Community Planning and Development, 

Housing – Federal Housing Administration (FHA), and Public and Indian 

Housing. Most significant are those recommendations related to properly 

accounting for certain funding provided to HUD under the Coronavirus 

Aid, Relief, and Economic Security Act and improving and better 

documenting HUD’s estimation and validation methodologies for accrued 

grant liabilities. 

Agencywide, Audit Report: 2021-FO-0003

Audit of Ginnie Mae’s Fiscal Year 2020 Financial Statements

OIG audited the Government National Mortgage Association’s (Ginnie 

Mae) fiscal year 2020 financial statements, which included a report 

on Ginnie Mae’s internal control and test of compliance with selected 

provisions of laws, regulations, and contracts applicable to Ginnie Mae. 

OIG reported that Ginnie Mae had a significant deficiency in the control 

design of its organizational structure for two key functions, estimation 

model development and model verification. OIG further reported that this 

control deficiency potentially prevents an effective challenge to models 

used to develop significant estimates for financial reporting. 

Agencywide, Audit Report: 2021-FO-0002

Audit of the Federal Housing Administration’s Fiscal Years 

2020 and 2019 Financial Statements

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

requires OIG to audit the financial statements of FHA annually. OIG 

audited the accompanying FHA financial statements and notes as of and 

for the fiscal years ending September 30, 2020 and 2019, as well as FHA’s 

internal control and test of compliance with selected provisions of laws, 

regulations, and contracts applicable to FHA. This audit did not disclose 

any deficiencies in internal control that were material weaknesses or 

significant deficiencies and no instances of noncompliance with applicable 

laws, regulations, and contracts. OIG has no new recommendations in 

this report; however, the “Followup on Prior Audits” section contains 

recommendations from prior-year audits that remain unresolved. 

FHA should continue to track and resolve these recommendations in 

accordance with departmental procedures. 

Agencywide, Audit Report: 2021-FO-0001

24 OTHER SIGNIFICANT AUDITS AND EVALUATIONS I HUD OIG Semiannual Report to Congress
Opportunities Exist To Improve HUD’s Communication to 

Renters About Eviction Protections

As part of the Coronavirus Aid, Relief, and Economic Security Act, OIG 

reviewed HUD’s communication to renters regarding the eviction 

moratorium found in Section 4024. The objective was to highlight the 

progress HUD has made and identify areas for improvement. OIG found 

that HUD provided critical information to many of these renters through its 

website and published guidance. However, OIG identified several aspects 

of HUD’s communication to renters on its website and published guidance 

that could be strengthened and areas of the joint website that could be 

improved. While the Section 4024 eviction moratorium expired on July 

24, 2020, it is still crucial that HUD have clear, complete, and accessible 

guidance available to help renters at a time when their health and financial 

stability may be at risk. If HUD maintains up-to-date and easily accessible 

information for all impacted renters, it will help to ensure that renters 

know their rights, maintain housing stability through the pandemic, and 

avoid homelessness. 

Agencywide, Audit Memorandum: 2021-NY-0801

Wage Determinations for FHA-Insured Multifamily 

Construction Projects

OIG audited HUD’s implementation of the prevailing wage provisions 

of the Davis-Bacon Act for its FHA-insured multifamily construction 

projects. The objectives were to determine whether (1) the allegation in 

a complaint had merit and (2) HUD implemented the correct Davis-Bacon 

wage determinations for its multifamily construction projects. Based on 

the audit results, OIG recommended that HUD (1) seek guidance from 

the U.S. Department of Labor (DOL) to correct the wage determinations 

for the five projects addressed in this report; (2) determine the correct 

wages to be paid to workers and ensure that appropriate actions are 

taken to pay the workers; (3) update HUD’s guidance to comply with DOL’s 

policies and guidance on the application of multiple wage determinations 

for construction projects; and (4) develop and implement controls to 

ensure that the appropriate Davis-Bacon wage rate determinations are 

implemented in the contracts of FHA-insured multifamily construction 

projects that require multiple wage determinations, including the 

requirement that contract specifications clearly identify the portions of the 

contract subject to each assigned wage determination. 

Agencywide, Audit Report: 2021-PH-0001

OFFICE OF EVALUATION

Contaminated Sites Pose Potential Health Risks to 

Residents at HUD-Funded Properties

The West Calumet Housing Complex (WCHC), located in East Chicago, IN, 

is a housing development that opened on top of a former lead smelting 

plant in 1972. HUD and other agencies missed multiple opportunities to 

identify site contamination at WHCH, resulting in residents’ continuing 

to live in unsafe conditions for decades, and inadequate oversight led 

to the lead poisoning of children. HUD partnered with and relied on 

the Environmental Protection Agency (EPA) to identify and develop a 

mitigation strategy for contaminated HUD-funded properties. Since 

25 OTHER SIGNIFICANT AUDITS AND EVALUATIONS I HUD OIG Semiannual Report to Congress
2016, HUD and EPA have been working to update a list of HUD-funded 

properties on or near contaminated sites, and while HUD has taken steps 

to improve communication with EPA, it can do more with the information 

it receives to understand how contaminated sites might impact HUDfunded properties. OIG recommended that HUD develop and implement 

strategies to research properties, determine whether site contamination 

should be considered in future reviews, and monitor those reviews. 

Agencywide, Evaluation Report: 2019-OE-0003

HUD Fiscal Year 2020 Federal Information Security 

Modernization Act of 2014 (FISMA) Evaluation Report

The Federal Information Security Modernization Act of 2014 directs 

Inspectors General to conduct an annual evaluation of the agency 

information security program. OIG conducted this evaluation to assess 

the overall effectiveness of HUD’s information security program, assess its 

compliance with Federal guidance, and respond to Office of Management 

and Budget reporting questions for the fiscal year 2020 annual assessment. 

OIG has determined that the contents of this report would not be 

appropriate for public disclosure and has, therefore, limited its distribution 

to selected officials. 

Agencywide, Evaluation Report: 2020-OE-0001

26 OTHER SIGNIFICANT AUDITS AND EVALUATIONS I HUD OIG Semiannual Report to Congress
LEGISLATION, REGULATIONS, AND 

OTHER DIRECTIVES

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 600 hours to reviewing 150 issuances. The draft 

directives consisted of 89 notices, 30 mortgagee letters (ML), and 31 other directives. OIG provided comments on 40 (or 27 percent) of the issuances and 

nonconcurred on 12 (or 8 percent) but lifted 6 nonconcurrences. Of the 31 other directives, OIG reviewed 4 final rules and 1 interim rule, taking no position 

on 4 and commenting on 1; 17 handbooks and guidebooks; 6 research reports; 1 U.S. Department of Housing and Urban Development (HUD) legislative 

referral; and 2 sets of frequently asked questions, 1 of which was related to Section 3, a provision of the Housing and Urban Development Act of 1968, and the 

other was related to the extensions of the single-family foreclosure and eviction moratorium, the COVID-19 forbearance start date, and the COVID-19 home 

equity conversion mortgage extension period. A summary of selected reviews for this 6-month period follows. 

16

18

20

6

8

2

4

10

12

14

Research reports

Frequently asked 

questions

HUD legislative 

referral

Handbooks and 

guides

Final rules

TOTAL ISSUANCES OF THE 31 OTHER DIRECTIVES

Other directives Mortgagee 

letters Notices

59%

89 21%

31

20%

30

27 LEGISLATION, REGULATIONS, AND OTHER DIRECTIVES I HUD OIG Semiannual Report to Congress
NOTICES, MORTGAGEE LETTERS, AND OTHER DIRECTIVES

SINGLE FAMILY HOUSING

Catalyst: single-family claims and origination modules – On November 

19, 2020, and January 19, 2021, HUD issued MLs 2020-38 and 2021-02, 

announcing expanded functionality capabilities in the single-family claims 

and origination modules in Federal Housing Administration (FHA) Catalyst. 

Effective November 19, 2020, lenders could use the FHA Catalyst claims 

module to submit all claim types, and effective January 19, 2021, lenders 

could use the Uniform Closing Dataset for FHA Title II single-family forward 

mortgage programs. OIG provided a no position response to MLs 2020-38 

and 2021-02.

2021 nationwide forward mortgage limits – On December 2, 2020, HUD 

issued ML 2020-41, announcing the forward mortgage limits for calendar 

year 2021 effective for case numbers assigned on or after January 1, 2021. 

Loan limits are determined by the county in which a property is located, 

except for properties located in metropolitan statistical areas as defined 

by the Office of Management and Budget (OMB). The limits in these 

areas are set using the county with the highest median price within the 

metropolitan statistical area. OIG provided a no position response to this 

ML.

2021 home equity conversion mortgage limits – On December 2, 2020, 

HUD issued ML 2020-42, announcing the FHA maximum claim amounts 

for FHA-insured home equity conversion mortgage (HECM) loans. For 

the period January 1, 2021, through December 31, 2021, the maximum 

claim amount for FHA-insured HECMs is $822,375 (150 percent of the 

Federal Home Loan Mortgage Corporation’s national conforming limit of 

$548,250). OIG provided a no position response to this ML.

Extension of temporary guidance for endorsement of mortgages 

under forbearance for borrowers affected by the presidentially 

declared COVID-19 national emergency consistent with the 

Coronavirus Aid, Relief, and Economic Security Act – On December 17, 

2020, HUD issued ML 2020-45, further extending the temporary guidance 

published in ML 2020-16, dated June 4, 2020, and extended in ML 2020-

39, dated November 25, 2020, concerning endorsement processes for 

mortgages in which a borrower has been granted a forbearance related 

to the presidentially declared COVID-19 national emergency before the 

loan is endorsed for FHA insurance. OIG provided no position responses to 

these MLs.

Revised form HUD-92900-A, HUD Addendum to Uniform Residential 

Loan Application – On December 22, 2020, HUD issued ML 2020-

49, announcing the publication of a revised form HUD-92900-A, HUD 

Addendum to Uniform Residential Loan Application. This ML also 

announced the renewal of other FHA-insured mortgage application 

forms. The revised HUD-92000-A became effective March 22, 2021. OIG 

nonconcurred with this clearance item due to the changes in the lender 

certifications. 

Extension of foreclosure and eviction moratorium in connection 

with the presidentially declared COVID-19 national emergency – 

On January 21, 2021, HUD issued ML 2021-03, informing lenders of an 

extension to the foreclosure and eviction moratorium originally issued 

in ML 2020-04, extended in MLs 2020-13, 2020-19, and 2020-27 and 

28 LEGISLATION, REGULATIONS, AND OTHER DIRECTIVES I HUD OIG Semiannual Report to Congress
further extended in ML 2020-43 for borrowers with FHA-insured singlefamily mortgages for an additional period through March 31, 2021. 

The extension of the moratorium announced in this ML was effective 

immediately upon the expiration of the moratorium announced in ML 

2020-43 for all FHA-insured mortgages except for FHA-insured mortgages 

secured by vacant or abandoned properties. ML 2021-05 superseded this 

ML on February 16, 2021. OIG provided a no position response to the ML.

Update to the COVID-19 forbearance start date and the COVID-19 

HECM extension period – On January 26, 2021, HUD issued ML 2021-

04, further extending ML 2020-06 regarding the approval of the initial 

COVID-19 forbearance for FHA borrowers and HECM deadlines until March 

31, 2021. The means of communication regarding a COVID-19 forbearance 

and the terms of the COVID-19 forbearance remained the same as 

established in MLs 2020-06 and 2020-22. Through this ML, HUD also 

extended the deadlines associated with the extension period for HECM 

borrowers impacted by the COVID-19 pandemic. ML 2021-05 superseded 

this ML on February 16, 2021. OIG provided a no position response to the 

ML.

Extensions of single-family foreclosure and eviction moratorium, start 

date of COVID-19 initial forbearance, and HECM extension period; 

expansion of COVID-19 loss mitigation options – On February 16, 2021, 

HUD issued ML 2021-05, informing lenders of further extensions, effective 

immediately, for the foreclosure and eviction moratorium, the COVID-19 

forbearance start date, and the COVID-19 HECM extension period. This ML 

also expanded FHA’s COVID-19 loss mitigation options by implementing 

additional COVID-19 forbearance and HECM extension periods for certain 

borrowers, broadening borrower eligibility for COVID-19 loss mitigation 

options, and eliminating the restriction on the number of permanent 

COVID-19 home retention options a borrower can receive. This ML 

supersedes ML 2021-03, updates ML 2021-04, and updates section 

III.A.3.d., Presidentially Declared COVID-19 National Emergency, of HUD 

Handbook 4000.1, FHA Single Family Housing Policy Handbook. OIG 

provided a no position response to the ML.

Extension of reverification of employment and exterior-only appraisal 

scope of work option for FHA single-family programs Impacted by 

COVID-19 – HUD issued ML 2021-06 on February 23, 2021, announcing 

the extension of the reverification of employment guidance in ML 2020-05, 

published on March 27, 2020, and extending the exterior-only appraisal 

scope of work option in ML 2020-37, published on October 28, 2020. This 

ML supersedes ML 2020-05. Policy updates in this ML are temporary 

and will not be incorporated into Handbook 4000.1. The original ML, 

ML 2020-05, did not come through the clearance process so OIG did not 

have an opportunity to review and comment on it; however, OIG had the 

opportunity to review and comment on the subsequent related MLs. OIG 

provided a no position response to these MLs.

Extension of the end date for COVID-19 multisubject updated 

temporary guidance for verification of self-employment, rental 

income, and 203(k) rehabilitation escrow account – HUD issued ML 

2021-07 on February 23, 2021, announcing an extension through June 30, 

2021, of the effective period for ML 2020-24, published on July 29, 2020, 

and extended in ML 2020-46, dated December 17, 2020. This extension 

allowed industry partners additional opportunities to use flexible guidance 

related to verification of self-employment and verification of rental income 

for single-family Title II forward mortgage and HECM programs and 203(k) 

escrow administration for the 203(k) rehabilitation program in response to 

impacts from the presidentially declared COVID-19 national emergency. 

29 LEGISLATION, REGULATIONS, AND OTHER DIRECTIVES I HUD OIG Semiannual Report to Congress
The policy updates in this ML are temporary and will not be incorporated 

into Handbook 4000.1. OIG provided a no position response to this ML.

HECM program – changes to interest rate requirements, including 

removal of the London Interbank Offered Rate index – HUD issued 

ML 2021-08 on March 11, 2021, removing approval for use of the 

London Interbank Offered Rate index for adjustable interest rate HECMs, 

establishing the acceptance of the Secured Overnight Financing Rate 

(SOFR) index and permitting lenders to commingle index types for newly 

originated annual adjustable interest rate HECMs when establishing the 

expected average mortgage interest rate using the U.S. Constant Maturity 

Treasury and using the SOFR index to establish the initial mortgage 

interest rate (note rate) and periodic note rate adjustments, and setting 

zero as the “floor” for the index value used to determine the note rate. OIG 

provided a no position response to this clearance item.

PUBLIC AND INDIAN HOUSING

Housing Opportunity Through Modernization Act of 2016—Housing 

Choice Voucher and Project-Based Voucher Program implementation; 

additional streamlining changes – On October 8, 2020, HUD published 

a proposed rule (Federal Register (FR)-6092-P-01), which implements 

Housing Opportunity Though Modernization Act (HOTMA) provisions 

and includes regulatory changes that are intended to reduce the burden 

on public housing agencies (PHA) by either modifying requirements or 

simplifying and clarifying existing regulatory language. The proposed rule 

proposes codification of the HOTMA provisions to include initial inspection 

options, a definition of life-threatening deficiencies, and Project-Based 

Voucher Program and project caps. This notice did not come through the 

clearance process; therefore, OIG did not have an opportunity to review 

and comment on it.

Relief from HUD public housing and Section 8 requirements available 

during calendar years 2020 and 2021 to public housing agencies to 

assist with recovery and relief efforts on behalf of families affected 

by presidentially declared major disasters – On November 12, 2020, 

HUD published a notification (FR-6050-N-04), which advises the public 

that HUD, in order to more effectively and expeditiously respond to 

presidentially declared major disaster declarations (MDD), is establishing 

for calendar years 2020 and 2021 an expedited process for the review of 

requests for relief from HUD regulatory and administrative requirements 

for PHAs located in counties that are included in MDDs. PHAs located in 

areas covered by MDDs issued for which a related disaster occurs during 

calendar years 2020 and 2021 may request waivers of certain HUD public 

housing and Section 8 requirements and receive expedited review of such 

requests using the flexibilities and expedited waiver process set out by 

this notification. This notice did not come through the clearance process; 

therefore, OIG did not have an opportunity to review and comment on it.

Section 8 housing choice vouchers: implementation of the Housing 

Choice Voucher Program mobility demonstration, restrictions on 

participating in the mobility demonstration, and the Moving to Work 

Demonstration expansion – On January 6, 2021, HUD published a notice 

of restrictions (FR-6191-N-04), which partially restrict participation in both 

the Housing Choice Voucher Program (HCVP) mobility demonstration 

program and the Moving to Work (MTW) Demonstration expansion 

(MTW expansion) program that is necessary to ensure the integrity of 

the congressionally mandated evaluations of both demonstrations. 

After careful consideration, HUD’s Office of Policy Development and 

30 LEGISLATION, REGULATIONS, AND OTHER DIRECTIVES I HUD OIG Semiannual Report to Congress
Research, which has been directed by Congress to evaluate both the HCVP 

mobility demonstration and the MTW expansion, has determined that 

the congressionally mandated rigorous evaluation of the demonstrations 

creates significant barriers for PHAs to participate fully in both programs. 

HUD is expanding the MTW Demonstration in five separate and distinct 

cohorts: (1) MTW flexibility on small PHAs, (2) rent reform, (3) work 

requirements, (4) landlord incentives, and (5) MTW flexibility on PHAs with 

fewer than 27,000 units. OIG provided minor editorial-related comments 

regarding this notice.

Economic Growth Regulatory Relief and Consumer Protection Act: 

implementation of National Standards for the Physical Inspection of 

Real Estate – On January 13, 2021, HUD published a proposed rule (FR6086-P-01), which proposes a new approach to defining and assessing 

housing quality: The National Standards for the Physical Inspection of Real 

Estate (NSPIRE). The purpose of NSPIRE is to reduce regulatory burden 

and improve HUD oversight through the alignment and consolidation of 

the inspection regulations used to evaluate HUD housing across multiple 

programs, which currently evaluate housing quality through differing 

standards, protocols, and frequencies. The goal of this alignment and 

consolidation is to create a unified assessment of housing quality. OIG 

review of the rule resulted in a nonconcurrence based on the inclusion of 

elevators, emergency exits, and fire exits under the types of health and 

safety concerns. OIG requested the removal of these items as they are 

not health and safety hazards. HUD agreed to issue the notice with the 

suggested changes, and the nonconcurrence was lifted.

MULTIFAMILY HOUSING

Electronic signature, transmission, and storage – On November 

6, 2020, HUD issued a notice, H 2020-10, which provides guidance to 

HUD Office of Multifamily Housing Programs-assisted housing industry 

partners on electronic signatures, electronic transmission, and electronic 

storage of documents and forms required by Multifamily’s Office of 

Asset Management and Portfolio Oversight. For purposes of this notice, 

“industry partners” include owners of HUD Multifamily-assisted housing 

properties, management agents and service providers, and HUD and 

contract administrator staff. Industry partners choosing to use electronic 

signatures, electronic transmission, or storage of electronic documents 

must do so in compliance with Federal, State, and local laws. OIG provided 

a no position response regarding this notice. 

Continued availability of funds for COVID-19 supplemental payments 

for project-based rental properties – On November 24, 2020, HUD 

issued a notice, H 2020-11, which announced the continued availability 

of supplemental operating funds for Section 8, Section 202, and Section 

811 properties to prevent, prepare for, and respond to COVID-19. The 

notice also establishes an application process for owners of properties 

assisted under these programs to request funds for the applicable 

purposes. Further, the notice sets parameters for owners who did not 

submit requests under the previous notice, H 20-08, to make requests for 

expenses previously incurred and discusses allowable resubmission for 

previously disapproved requests. OIG provided a no position response 

regarding this notice. 

31 LEGISLATION, REGULATIONS, AND OTHER DIRECTIVES I HUD OIG Semiannual Report to Congress
COVID-19 contingency plan for multifamily rental project closing 

documents – On December 11, 2020, HUD issued a notice, FR-7024-N-50, 

which proposes a new collection of information based on situational 

conditions relating to the COVID-19 outbreak and the Presidential 

declaration that began a national emergency. This notice will serve as 

the authority for any new or future changes or revisions to Multifamily 

programs impacted by COVID-19 or related pandemics. OIG provided a no 

position response regarding this notice. 

Section 811 Project Rental Assistance for persons with disabilities

– On December 11, 2020, HUD issued a notice, FR-7027-N-40, which 

proposes the need for information necessary to assist HUD in determining 

applicant eligibility and capacity to award and administer the HUD Project 

Rental Assistance program funds within statutory and program criteria. A 

thorough evaluation of an applicant’s submission is necessary to protect 

the Government’s financial interest. OIG provided a no position response 

regarding this notice. 

Mortgagee’s application for partial settlement – On December 17, 

2020, HUD published a notice, FR-7027-N-36, which proposes the need 

for information using form HUD-2537. HUD requires a Multifamily lender 

to furnish form HUD-2537 when filing a claim with the HUD Secretary 

to receive insurance benefits. OIG nonconcurred on the warning and 

certification language on form HUD-2537. OIG recommended that HUD 

change the language. OIG explained that U.S. Department of Justice, 

State, or local prosecutorial offices, not HUD, prosecute false claims and 

statements; thus, the language change was recommended. HUD changed 

the language, and the nonconcurrence was lifted.

Housing finance agency risk-sharing program – On December 22, 2020, 

HUD published a final rule, FR-5881-F-02, which states that it entered into 

risk-sharing agreements with qualified State and local housing finance 

agencies (HFA) so they can provide FHA mortgage insurance and credit 

enhancement for new loans on multifamily affordable housing properties 

through the Section 542(c) HFA Risk-Sharing Program. In addition, this 

final rule amends the program’s existing regulations to better align with 

the policies of other HUD programs, reflect current industry and HUD 

practices, and conform to statutory amendments. OIG provided a no 

position response regarding this final rule. 

Request for withdrawals from replacements reserves and residual 

receipts funds – On January 21, 2021, HUD issued a notice, FR-7034-N-02, 

for the reinstatement and changes of previously approved collection 

using form HUD-92050. Project owners are required to submit this form 

and supporting documentation when requesting a withdrawal of funds 

from the reserves for replacement or residual receipt escrow accounts. 

OIG nonconcurred on this clearance item because form HUD-9250 does 

not contain a fraud warning. OIG recommended the use of the following 

certification and fraud warning as an example: “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 false statements is subject to criminal and civil penalties, 

including confinement for up to 5 years, fines, and civil penalties. (18 U.S.C. 

§§ 287, 1001 and 31 U.S.C. §3729).” HUD agreed, and the nonconcurrence 

was lifted.

Mortgagee’s application for partial settlement – On February 23, 2021, 

HUD issued a notice, FR-7034-N-10, which allows a Multifamily lender 

to file a claim for insurance benefits. Specifically, when an FHA-insured 

32 LEGISLATION, REGULATIONS, AND OTHER DIRECTIVES I HUD OIG Semiannual Report to Congress
Multifamily mortgage goes into default, the lender may file a claim with 

the HUD Secretary to receive the insurance benefits. The lender is required 

by HUD to furnish form HUD-2537 before receiving the telefax. OIG 

nonconcurred on the warning statement because U.S. Department of 

Justice, State, or local prosecutorial offices, not HUD, may prosecute. OIG 

recommended that HUD include a warning statement that may discourage 

fraud and help effectively prosecute the fraud when it occurs. In addition, 

OIG recommended that the certification statement be changed to include 

certifications under penalty of perjury and fraud to effectively prosecute 

those who commit fraud. HUD agreed, and OIG lifted the nonconcurrence.

COMMUNITY PLANNING AND DEVELOPMENT

Fiscal year 2020 Continuum of Care Program noncompetitive funding 

notice – On January 29, 2021, HUD issued Office of Community Planning 

and Development (CPD) Notice CPD-21-01 to noncompetitively renew 

funding for existing Continuum of Care renew projects expiring during 

calendar year 2021. The renewal amounts were to be adjusted to account 

for changes in fair market rent as applicable. OIG had minor editorial 

comments on this clearance item. 

Unemployment insurance benefits under the CARES Act, 2021 

Appropriations Act, and Presidential memorandum – On February 

24, 2021, HUD issued Notice CPD-21-03. The notice provides guidance 

to grantees in determining whether unemployment insurance benefits 

received by individuals under the Coronavirus Aid, Relief, and Economic 

Security Act (CARES Act) and a recent Presidential memorandum are 

income under Community Development Block Grant (CDBG) regulations. 

The notice states that CDBG grantees, using the definition of income 

at 24 CFR (Code of Federal Regulations) 570.3, should treat pandemic 

unemployment assistance and pandemic emergency unemployment 

compensation benefits as income but should exclude Federal pandemic 

unemployment compensation benefits from the income calculation. 

Further, the notice says that CDBG grantees should exclude benefits 

received under the Presidential memorandum from income. OIG provided 

a no position response on this clearance notice.

DISASTER FUNDING

Allocations, common application, waivers, and alternative 

requirements for disaster Community Development Block Grant 

Disaster Recovery grantees, second allocation – On January 6, 2021, 

HUD published a notice allocating nearly $85.3 million in disaster recovery 

funds appropriated by the Additional Supplemental Appropriations for 

Disaster Relief Act, 2019. The funding was to address unmet disaster 

recovery needs related to disaster relief, long-term recovery, restoration 

of infrastructure and housing, economic revitalization, and mitigation in 

the most impacted and distressed areas resulting from a qualifying major 

disaster in 2018 and 2019. OIG provided a no position response regarding 

this notice.

Allocations, common application, waivers, and alternative 

requirements for disaster Community Development Block Grant 

Disaster Recovery grantees – On January 6, 2021, HUD published a 

notice allocating more than $186 million in funds remaining from the 

Additional Supplemental Appropriations for Disaster Relief Act, 2019, as 

Community Development Block Grant-Mitigation (CDBG-MIT) funds. The 

notice imposes the requirements of prior CDBG-MIT notices, 84 FR-45838 

33 LEGISLATION, REGULATIONS, AND OTHER DIRECTIVES I HUD OIG Semiannual Report to Congress
(Main CDBG-MIT Notice) and 85 FR 60821 (2020 Omni Notice), on this 

allocation. OIG provided a no position response to this notice.

ADMINISTRATIVE-OTHER PROGRAM AREAS

Implementing Executive Order 13891 – On November 10, 2020, HUD 

published an interim rule, FR-6192-I-01, which implements Executive 

Order (E.O.) 13891, “Promoting the Rule of Law Through Improved Agency 

Guidance Documents.” This E.O. requires Federal agencies to publish 

regulations that establish processes and procedures for issuing guidance 

documents. The interim rule would create a new part 11 in Title 24 of 

the Code of Federal Regulations that outlines HUD policy on guidance 

documents and how HUD designates guidance documents. The interim 

rule would also establish a procedure by which the public may petition 

HUD for the withdrawal or modification of guidance documents and the 

process for the public to make comments on certain significant guidance 

documents. OIG provided a no position response regarding this interim 

rule. 

HUD environmental review – On December 30, 2020, HUD published a 

notice, FR-7024-N-58, which was seeking OMB’s approval for the revision 

of currently approved collection on environmental review procedures. 

Regulations at 24 CFR part 58, Environmental Review Procedures for 

Entities Assuming HUD Environmental Responsibilities, requires units of 

general local government receiving HUD assistance to maintain a written 

environmental review record for all projects receiving HUD funding, 

documenting compliance with the National Environmental Policy Act; 

the regulations of the Council on Environmental Quality; related Federal 

environmental laws, E.O.s, and authorities; and part 58 procedure. The 

HUD Environmental Review Online System (HEROS) allows users to 

complete, store, and submit their environmental review records and 

documents online. HEROS is currently optional for responsible entity 

and other non-HUD users, who may continue to use paper-based 

environmental review formats. OIG provided a no position response 

regarding this notice. 

Affirmative Fair Housing Marketing Plan – On January 25, 2021, HUD 

issued a notice, FR-7037-N-01, which seeks to revise a currently approved 

collection on the Affirmative Fair Housing Marketing Plan (AFHMP) 

forms. These AFHMP forms (HUD-935.2A, HUD-935.2B, and HUD-935.2C) 

collect information on the advertising and outreach activities of owners 

and developers of HUD multifamily, single-family, and condominium 

cooperative housing projects to attract applicants and buyers throughout 

the housing market area regardless of race, color, national origin, religion, 

sex, disability, or familial status. OIG provided a no position response 

regarding this notice. 

Section 3 reporting – On March 11, 2021, HUD issued a notice, FR7039-N-01, which reflects the changes to the Section 3 regulation, 

published in the Federal Register on September 29, 2020, “Enhancing and 

Streamlining the Implementation of Section 3 Requirements for Creating 

Economic Opportunities for Low- and Very Low-Income Persons and 

Eligible Businesses.” The changes are the implementation of form HUD60002A, Opportunity Portal and Business Registry. OIG’s comment was 

only on the supporting statement, which referenced to “both” but only 

the form HUD-60002-A was mentioned and not another item. If there was 

no other item, OIG recommended deleting the word “both”. If there was 

another item, OIG recommended including it, so the sentence is accurate.

34 LEGISLATION, REGULATIONS, AND OTHER DIRECTIVES I HUD OIG Semiannual Report to Congress
7-day notice of emergency approval of an information collection: 

collection of required information for CARES Act quarterly reporting

– On March 24, 2021, HUD published FR-7034-N-14, a notice informing 

the public that HUD has submitted to OMB a request for emergency 

approval of the collection of required information for CARES Act quarterly 

reporting. Clearance of this information collection request would 

prompt the immediate outreach to large covered funds recipients.2 This 

information collection request would allow HUD to collect the quarterly 

information required and ensure compliance with Section 15011 of the 

CARES Act. Each covered recipient is required to submit to the agency 

and the committee a report not later than 10 days after the end of 

each calendar quarter. This information will be reported by the grant 

recipients to HUD program offices, then combined with the related 

information already obtained. This combined information will form the 

required quarterly reporting for CARES Act funds that HUD submits to 

the Pandemic Response Accountability Committee. Public comments 

were due March 31, 2021. This notice did not come through the clearance 

process; therefore, OIG did not have an opportunity to review and provide 

comments.

2

Large covered funds recipients are recipients with CARES grant amounts over $150,000.

35 LEGISLATION, REGULATIONS, AND OTHER DIRECTIVES I HUD OIG Semiannual Report to Congress
REPORT RESOLUTION

In the 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 audit resolution, see appendix 2, 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.”

AUDIT REPORTS ISSUED BEFORE START OF PERIOD WITH NO 

MANAGEMENT DECISION AS OF MARCH 31, 2021

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 14 activities 

reviewed, 7 field offices did not provide adequate oversight of 8 property 

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 for Grant Programs 

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 had not provided the requested information and 

documentation, and OIG referred this recommendation to the Assistant 

Secretary for Community 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, 2021, had not received a 

decision. 

Audit Report: 2016-PH-0001

36 REPORT RESOLUTION I HUD OIG Semiannual Report to Congress
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 2013.4 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 of recommendations from 

OIG’s audit of New Jersey’s Sandy Integrated Recovery Operations and 

Management System. 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, 2021, had not received a decision. 

Audit Report: 2016-PH-0005

Additional Details To Supplement Our Fiscal Years 2016 and 2015 

(Restated) U.S. Department of Housing and Urban Development 

Financial Statement Audit

Issue Date: November 15, 2016

OIG audited HUD’s consolidated financial statements and reported on 

deficiencies in the areas of HUD’s loan guarantee balances. OIG rejected 

HUD’s initial management decision on April 24, 2017, as it did not contain 

adequate evidence to provide closure. OIG referred this recommendation 

to the Deputy Secretary on July 24, 2017. HUD has been working 

to address this recommendation and submitted a revised proposed 

management decision on March 31, 2021, which is under HUD OIG review. 

Audit Report: 2017-FO-0003

3

Public Law 113-2, dated January 29, 2013

37 REPORT RESOLUTION I HUD OIG Semiannual Report to Congress
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 

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 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, 2021, 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 

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 

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

38 REPORT RESOLUTION I HUD OIG Semiannual Report to Congress
$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 for Grant Programs 

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 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 for Grant Programs also noted that the Senate Appropriations 

Committee report on fiscal year 2018 U.S. Department of TransportationHUD appropriations legislation7

 addressed this issue. In addition, the 

Deputy Assistant Secretary for Grant Programs stated that HUD clarified its 

definition of proficient procurement processes and policies in subsequent 

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, 2021, 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. 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 riskbased monitoring of grantees, HUD’s controls were not always sufficient, 

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

7

Senate Report 1115-138, dated July 27, 2017

39 REPORT RESOLUTION I HUD OIG Semiannual Report to Congress
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 for Grant Programs 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. In an attempt to reach agreement, OIG held discussions 

with CPD officials on February 13 and March 8, 2018. On March 28, 2018, 

the Deputy Assistant Secretary for Grant Programs 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, 2021, OIG was awaiting 

an updated proposal from CPD. 

Audit Report: 2017-NY-0002

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 program (CDBG-DR) and found that although OBGA 

had managed billions in CDBG-DR funds since 2002, it had not codified 

the program, because it didn’t 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 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, 2021, was awaiting a decision. 

Audit Report: 2018-FW-0002 

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 

40 REPORT RESOLUTION I HUD OIG Semiannual Report to Congress
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 CDBGDR 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 September 30, 2020. On February 24, 2021, 

CPD indicated that it was working to update its proposed management 

decisions. 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 17, 2019, September 10, 2019, 

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 

41 REPORT RESOLUTION I HUD OIG Semiannual Report to Congress
was not reached, OIG referred the recommendations to the Deputy 

Secretary on February 20, 2020. On February 24, 2021, CPD indicated 

that it was preparing management decisions, and OIG agreed to provide 

documentation to assist with the preparation. As of March 31, 2021, 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 in a manner consistent with 

the regulations in 2 CFR parts 180 and 2424 so that ineligible applicants 

or tenants are not admitted or recertified to put up to an estimated $13.7 

million in annual rental subsidies 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 

from HUD’s Office of General Counsel in support of its position. OIG 

rejected this management decision because it does not resolve the 

recommendation, and 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 for Public and Indian 

Housing 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, as of March 31, 

2021, OIG had not received a decision from the Deputy Secretary. 

Audit Report: 2019-KC-0002

EVALUATION REPORTS ISSUED BEFORE START OF PERIOD WITH NO 

MANAGEMENT DECISION AS OF MARCH 31, 2021 

Risk-Based Enforcement Could Improve Program Effectiveness

Issue Date: February 12, 2016

OIG evaluated the risk analysis process for Hurricane Sandy grants 

performed by HUD CPD. OIG observed that (1) CPD’s risk analysis 

worksheet did not consider risk related to performance outputs, (2) the 

risk analysis did not consider the likelihood of risk events occurring, (3) no 

clear correlation between the risk analysis and monitoring existed, (4) CPD 

made limited use of data analytics in its risk management process, and (5) 

CPD staff were not trained to conduct a risk analysis.

42 REPORT RESOLUTION I HUD OIG Semiannual Report to Congress
OIG made five recommendations, two of which remain open, and 

do not have an agreed upon management decision. CPD provided 

documentation for these recommendations on March 9, 2021 and OIG was 

reviewing it as the reporting period ended. (Evaluation Report: 2019-OE0004S) 

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 Federal cross-cutting project, making nine recommendations 

for improvement to HUD. OIG assessed HUD’s capability to identify and 

mitigate critical information technology (IT) vulnerabilities in HUD’s 

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. To date, HUD has not provided 

management decisions for the nine open recommendations OIG provided 

or a required estimated completion date for these management decisions. 

On June 2, 2017, HUD concurred with all recommendations and agreed 

to work with OIG to assign responsibility and complete resolution. While 

management decisions for this report have not been provided, HUD’s 

Office of the Chief Information Officer (OCIO) is working closely with OIG 

to address the remaining open recommendations. OIG concurred to close 

five recommendations based on OCIO closure requests and associated 

evidence, leaving four open recommendations. 

Evaluation Report: 2016-OE-0002

Opportunities for Improvement Within CPD’s Risk Management 

Process for Hurricane Sandy Grants

Issue Date: March 29, 2017

OIG evaluated the risk analysis process for Hurricane Sandy grants 

performed by HUD CPD. OIG observed that (1) CPD’s risk analysis 

worksheet did not consider risk related to performance outputs, (2) the 

risk analysis did not consider the likelihood of risk events occurring, (3) 

no clear correlation between the risk analysis and monitoring existed, (4) 

CPD made limited use of data analytics in its risk management process, 

and (5) CPD staff was not trained to conduct a risk analysis. OIG made five 

recommendations, two of which remain open and do not have an agreedupon management decision. In February 2021, OIG met with staff from the 

Office of the Chief Financial Officer (OCFO) to discuss the status of these 

recommendations, among others. OCFO personnel agreed to contact CPD 

on these recommendations. OIG plans to refer these recommendations to 

the Deputy Secretary for final action during the next reporting period. 

Evaluation Report: 2016-OE-0004S 

43 REPORT RESOLUTION I HUD OIG Semiannual Report to Congress
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 

Program (ONAP) Indian Home Loan Guarantee Program (Section 184 

program) following concerns that HUD had not used provided resources 

to address shortcomings in internal controls and 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 the 

LOS due to HUD’s inability to resolve and implement a user access solution; 

(3) the LOS had no capability to conduct loan servicing and claims, which 

are still conducted using Excel spreadsheets; and (4) the LOS lacked 

critical management reporting capabilities. Despite HUD’s investing $4 

million into the development of the 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. OIG received a management decision for the 

fourth recommendation from HUD OCIO, and two recommendations 

have been closed due to the progress of OCIO’s implementing electronic 

document capabilities and resolving the lender access issues. Three 

recommendations remain open, as the HUD Deputy Secretary and ONAP 

have been unable to provide management decisions for two of those 

recommendations. 

Evaluation Report: 2018-OE-0004

HUD Has Not Referred Troubled Public Housing Agencies as the Law 

and Regulations Require

Issue Date: February 4, 2020

OIG evaluated whether PIH refers troubled PHAs as the law and regulations 

require. PIH is responsible for monitoring PHAs’ performance and should 

give a troubled PHA a maximum of 2 years to cure its negative conditions. 

If the PHA does not meet the 1- or 2-year recovery requirements, law 

and regulations require PIH to refer the PHA to the Assistant Secretary 

for Public and Indian Housing for action. OIG identified 18 PHAs that 

remained troubled for more than 2 years without being referred. While 

PIH is creating a process for referring troubled PHAs, OIG found that the 

draft process would provide more options to the Assistant Secretary than 

the law and regulations allow and that PIH cannot meet its statutory 

referral deadlines for referring a PHA without substantial changes to 

the assessment process or changes to the law and regulations. PIH had 

not submitted an annual troubled PHAs report to Congress for at least 

11 years as the law requires. OIG made five recommendations, three of 

which remain open. OIG has not reached an agreed-upon management 

decision for these three recommendations. After reviewing PIH’s 

proposed management decisions, OIG determined that PIH referral 

procedures meant to satisfy the recommendations allow more recovery 

options than specified in law. OIG will continue to work with PIH during 

the next reporting period to reach a management decision for these 

recommendations. 

 Evaluation Report: 2019-OE-0001

44 REPORT RESOLUTION I HUD OIG Semiannual Report to Congress
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 five significantly revised 

management decisions.

Bay Vista Methodists Heights, San Diego, CA, Violated Its Agreement 

With HUD When Administering Its Trust Funds

Issue Date: March 14, 2013

OIG audited Bay Vista Methodist Heights’ trust fund agreement with HUD 

and found that Bay Vista violated its trust fund agreement. Specifically, 

it used more than $5 million in trust funds for ineligible operating 

expenses and could not support more than $1 million in expenditures 

on draw requests. OIG provided four recommendations and in HUD’s 

original management decisions, dated May 15, 2013, agreed with the 

recommendation. On April 2, 2019, HUD submitted revised management 

decisions, stating that HUD was no longer doing business with the 

organization, the statute of limitations had expired, and any civil action 

taken to recover the funds would be unsuccessful. Therefore, HUD 

intended to seek forgiveness for more than $6.2 million in questioned 

costs. On April 3, 2019, OIG concurred with the revised management 

decision; however, OIG’s position is that HUD’s significant delays in 

pursuing enforcement action directly contributed to the expiration of 

the statute of limitations and need to forgive the questioned costs. HUD 

submitted the written request for concurrence to forgive disallowed 

costs on July 24, 2020, and OIG concurred on September 10, 2020. HUD’s 

Deputy Secretary signed the approval to forgive the questioned costs 

on November 23, 2020, and OIG closed the management decisions on 

December 15, 2020. 

Audit Report: 2013-LA-1003

Additional Details To Supplement Our Report on HUD’s Fiscal Years 

2013 and 2012 (Restated) Financial Statements

Issue Date: December 16, 2013 

OIG audited PIH’s implementation of U.S. Treasury cash management 

regulations as part of the annual audit of HUD’s consolidated financial 

statements for fiscal years 2013 and 2012. OIG found that HUD’s 

implementation of the new cash management process for the Housing 

Choice Voucher Program departed from U.S. Treasury cash management 

requirements and Federal generally accepted accounting principles and 

that there were no sufficient internal controls over the process to ensure 

accurate and reliable financial reporting. The OIG report included a 

recommendation, requiring PIH to implement a cost-effective method 

for automating the cash management process, to include an electronic 

interface of transactions to the standard general ledger, and two related 

recommendations to OCFO. OCFO submitted management decisions 

for these two recommendations in 2015, which OIG accepted. However, 

OCFO’s management decisions were dependent on PIH’s implementation 

of a cash management system, which has taken longer than expected. The 

45 REPORT RESOLUTION I HUD OIG Semiannual Report to Congress
implementation plan has changed since the agreed-upon management 

decision in 2015. On March 12, 2021, OIG accepted PIH’s management 

decision for implementing a cash management system. As a result, 

OCFO entered revised management decisions for its two related 

recommendations that were consistent with PIH’s implementation plan 

and timeline. OIG accepted these revised management decisions. 

Audit Report: 2014-FO-0003

HUD Did Not Always Provide Adequate Oversight of Its Section 203(k) 

Rehabilitation Loan Mortgage Insurance Program, Washington, DC

Issue Date: July 31, 2015

OIG audited HUD’s oversight of its Section 203(k) Rehabilitation Loan 

Mortgage Insurance Program to determine whether HUD had adequate 

oversight of its Section 203(k) program. OIG determined that HUD needed 

to improve its monitoring of lenders for compliance with Section 203(k) 

program requirements. OIG recommended that HUD require the lenders 

to (1) support or indemnify HUD for any future losses on the 40 loans 

with estimated losses totaling more than $1.2 million and (2) support 

or reimburse HUD for the actual losses incurred on two loans totaling 

$83,322. OIG also recommended that HUD (1) strengthen its controls over 

Section 203(k) program requirements, (2) adjust the formula for calculating 

the loan-to-value ratio, (3) determine the overpaid mortgage insurance 

premiums for loans with incorrect loan-to-value ratios, and (4) credit the 

accounts of active borrowers who overpaid their mortgage insurance 

premiums and refund overpaid premiums to borrowers for terminated 

loans. In its original management decision, due to its estimated labor and 

other costs to address the recommendation, HUD proposed an alternative 

action of posting a notice on its web page to the 203(k) participants during 

the period covered by the audit, explaining that mortgage insurance 

premiums may have been adversely impacted by incorrectly specified 

loan-to-value ratios. The notice would invite any such 203(k) participants 

to contact HUD for an assessment as to whether a reimbursement or 

principal reduction was in order. OIG accepted HUD’s proposed alternative 

action. On March 29, 2021, HUD submitted a revised management 

decision for recommendation 2C, stating that for active Federal Housing 

Administration loans that may have been impacted by an incorrect loanto-value ratio for mortgage insurance premium calculations, HUD will 

reduce the associated borrowers’ annual mortgage insurance premiums by 

five basis points, with a final action target date of December 29, 2021. On 

March 30, 2021, OIG agreed with the revised management decision. 

Audit Report: 2015-CH-0001

HUD Did Not Adequately Administer Its Housing Counseling Program

Issue Date: September 24, 2018

OIG audited HUD’s Housing Counseling Program, located within the 

Office of Housing Counseling, to determine whether HUD adequately 

46 REPORT RESOLUTION I HUD OIG Semiannual Report to Congress
administered its program. OIG determined that HUD did not adequately 

administer its program in accordance with Federal regulations and its 

requirements because HUD did not have adequate controls over its 

program and due to weaknesses in its Housing Counseling System. 

One recommendation OIG made was for HUD to ensure that its new 

Housing Counseling Agency Management System (HCAMS) provides 

it with the ability to adequately oversee the work of its staff and track 

important housing counseling agency milestones, including HUD approval 

expirations and required terminations. In its original management 

decision, HUD agreed with the recommendation and stated that it would 

implement version 1.0 of HCAMS with the ability to adequately oversee 

the work of its staff and track important housing counseling agency 

milestones by March 31, 2021. On March 10, 2021, HUD submitted a 

revised management decision, stating that the HCAMS project was 

approximately 66 percent complete and that due to funding restraints, it 

had not been able to complete development and implementation of the 

system. HUD planned to reevaluate whether to continue the development 

and implementation of HCAMS in fiscal year 2022. In the meantime, HUD 

implemented interim controls within its existing systems to address OIG’s 

concerns, including more involvement by management in tracking each 

performance review and creating spreadsheets to track its important 

milestone dates. On March 11, 2021, OIG agreed with the revised 

management decision. 

Audit Report: 2018-NY-0001

The Christian Church Homes, Oakland, CA, Did Not Ensure That the 

Rental Assistance Demonstration Program Conversion Was Accurate 

and Supported for Vineville Christian Towers

Issue Date: November 4, 2019

OIG audited Vineville Christian Towers’ (project) Rental Assistance 

Demonstration Program (RAD) conversion to determine whether 

the project’s RAD conversion to the Section 8 Project-Based Voucher 

Program was completed in accordance with the HUD requirements; 

specifically, whether Christian Church Homes of North California 

(owner) ensured that the project’s RAD conversion was accurate and 

supported. OIG determined that the owner did not ensure that the 

project’s RAD conversion was accurate and supported. OIG made four 

recommendations (1A through 1D) to the Director of HUD’s Atlanta, GA, 

PIH, and two recommendations (1E and 1F) to HUD’s Office of Program 

Enforcement and DEC to take appropriate enforcement and administrative 

actions against the responsible parties, including the owner. HUD has 

taken actions to address all recommendations. On February 18, 2021, 

PIH submitted a revised management decision and provided for its basis 

the Office of Program Enforcement’s memorandum (1) summarizing the 

context in which the facts at issue arose and (2) stating its belief that due 

to the various uncertainties in applying new program rules and the parties’ 

express uncertainties about how to proceed in those circumstances, HUD 

could not establish a clear case for administrative liability against the 

responsible parties. Therefore, PIH requested that recommendation 1B 

be closed as it could not require the owner to reimburse the program. On 

March 9, 2021, OIG agreed with the revised management decision and 

closed this recommendation. 

Audit Report: 2020-AT-1001

47 REPORT RESOLUTION I HUD OIG Semiannual Report to Congress
SIGNIFICANT MANAGEMENT DECISIONS 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 it disagrees. 

During the reporting period, there were no significant management 

decisions in which OIG disagreed.

FEDERAL FINANCIAL MANAGEMENT IMPROVEMENT ACT OF 

1996

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 required 

by FFMIA. 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. 

As of September 30, 2020, OIG and HUD noted noncompliance with the 

three Section 803(a) elements of FFMIA. Specifically, there were four 

financial systems8 that were noncompliant with one or more of the three 

Section 803(a) requirements. The latest target date for remediation is 

August 2021. HUD was on track to meet the intermediate target dates in 

its remediation plans as of March 31, 2021.

8

The four financial systems that were noncompliant with FFMIA as of September 30, 2020, were the Disaster Recovery Grant Reporting System, Tenant Rental Assistance Certification System, Single Family 

Information System, and Single Family Information System Claims Subsystem.

48 REPORT RESOLUTION I HUD OIG Semiannual Report to Congress
WHISTLEBLOWER OMBUDSMAN

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 HUD OIG employees are aware of their rights to disclose misconduct, 

waste, or abuse in HUD programs without reprisal and to assist HUD and HUD OIG employees in seeking redress when employees believe that they have been 

subject to retaliation for whistleblowing. HUD OIG also investigates complaints of whistleblower retaliation by government contractors and grantees.

9

Not all complainants are found to be whistleblowers under Section 4712. For example, many complainants raise questions regarding treatment by public housing agencies following their alleged 

disclosures of wrongdoing by the same housing agency. 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.

61

45

16

5

3

Number of complainants asserting 

whistleblower status9

Complaints currently under review by the 

Office of Investigation

Employee complaints referred to the 

Office of Special Counsel

Complaints declined by the 

Office of Investigation)

Contractor disclosure 

complaints reviewed

49 WHISTLEBLOWER OMBUDSMAN I HUD OIG Semiannual Report to Congress
HUD OIG’s Whistleblower Protection Coordinator Program works with HUD 

and HUD OIG employees to provide information on

• employee 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 under the Whistleblower Protection Act 

when an employee believes he or she has been retaliated against for 

making protected disclosures.

The HUD OIG Whistleblower Protection Coordinator Program continued 

its focus on staff training and individual assistance. The mandatory 

whistleblower training is presented in conjunction with the OIG annual 

ethics training. The 2020 training was presented on September 18, 2020. 

It was presented via a memorandum from the Inspector General, which 

explained employees’ rights to make disclosures of wrongdoing, free from 

retaliation. The memorandum also provided information about other 

prohibited personnel practices.

In October 2017, Congress enacted the Dr. Chris Kirkpatrick Whistleblower 

Protection Act of 2017, which contains new training and performance 

standards for supervisors regarding the handling of whistleblowers. HUD 

OIG is in the process of implementing these requirements.

The Whistleblower Protection Coordinator meets with HUD employees 

individually, upon request. Generally, HUD OIG will refer HUD employees 

with whistleblower retaliation complaints to the Office of Special Counsel. 

HUD 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 41 U.S.C. 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 

whistleblowing, he or she may file a complaint with OIG, and OIG will 

investigate the complaint and provide findings of fact to HUD. 

50 WHISTLEBLOWER OMBUDSMAN I HUD OIG Semiannual Report to Congress
PEER REVIEW 

REPORTING

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. 

The Offices of Audit, Investigation, and Evaluation 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 DOT 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. Department of Transportation 

(DOT) OIG on September 28, 2018. 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 the 

HUD OIG in effect for the year ended March 31, 2018, was suitably designed 

and complied with to provide the HUD OIG with reasonable assurance 

of performing and reporting in conformity with applicable professional 

standards in all material respects. Federal Audit organizations can receive a 

rating of pass, pass with deficiencies, or fail. The HUD OIG has received a 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 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.

51 PEER REVIEW REPORTING I HUD OIG Semiannual Report to Congress
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. HUD 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

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 team concluded that one report did follow all policies 

and procedures and quality standards. The team also concluded that all 

reviewed reports did not follow select quality standards. HUD OIG did not 

agree with all team observations and offered a written rebuttal. However, 

the Office of Evaluation made changes to its policies and procedures and 

reporting approaches to address the team’s observations. 

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. FHFA OIG received a peer 

review rating of pass.

A copy of the external quality control review report can be viewed at 

https://www.fhfaoig.gov/sites/default/files/Final%20Report%20-%20

External%20Peer%20Review%20of%20FHFA%20OIG.pdf.

52 PEER REVIEW REPORTING I HUD OIG Semiannual Report to Congress
APPENDIX 1 - REPORTS ISSUED

Internal Audit Reports

Chief Financial Officer

2021-FO-0003 Audit of HUD’s Fiscal Year 2020 Consolidated Financial Statements, 12/04/2020.

Chief Information Officer

2021-DP-0001 Fiscal Year 2019 Review of Information Systems Controls in Support of the Financial Statements 

Audit, 12/17/2020.

Field Policy and Management

2021-PH-0001 HUD Did Not Always Implement the Correct Davis-Bacon Wage Determinations and Maintain 

Documentation To Support Its Determinations, 10/06/2020.

Government National Mortgage Association

2021-FO-0002 Audit of the Government National Mortgage Association’s Fiscal Year 2020 Financial 

Statements, 11/16/2020.

53 APPENDIX 1 – REPORTS ISSUED I HUD OIG Semiannual Report to Congress
Housing

2021-DP-0002 Federal Housing Administration, Washington, DC, Necessary System Interfaces Between 

HERMIT and The National Servicing Center Were Not in Place, 03/02/2021.

2021-FO-0001 Audit of Federal Housing Administration’s Financial Statements for Fiscal Years 2020 and 2019, 

11/12/2020.

2021-KC-0001 Federal Housing Administration Mortgage Insurance Environmental Reviews, 10/02/2020.

2021-KC-0002 FHA Insured $940 Million in Loans for Properties in Flood Zones Without the Required Flood 

Insurance, 01/05/2021. Better use: $437,835,534.

Office of Administration

2021-PH-0002 HUD Improperly Accounted for and Managed Reimbursements It Received Through Rent 

Credits From the General Services Administration, 03/29/2021.

Public and Indian Housing

2021-AT-0001 HUD’s PIH Office of Field Operations Generally Confirmed That PHAs Complied With the 

Implementing Guidance of HUD’s Smoke-Free Policy Requirements, 03/19/2021.

Internal Audit Reports Continued

54 APPENDIX 1 – REPORTS ISSUED I HUD OIG Semiannual Report to Congress
Chief Financial Officer

2021-NY-0801 Opportunities Exist To Improve HUD’s Communication to Renters About Eviction Protections, 

10/13/2020.

Community Planning and Development

2021-GA-0801 HUD and its CDBG-DR Grantees Have Experienced Challenges Related to the COVID-19 

Pandemic, 03/23/2021.

2021-LA-0801 Drawdown Levels for the Initial Round of CARES Act Emergency Solutions Grants Were Minimal, 

11/16/2020.

Housing

2021-KC-0801 Key Considerations From Prior Audits of the Single Family Default Monitoring System and the 

Partial Claim Loss Mitigation Option, 03/12/2021.

2021-LA-0802

The HUD Single Family Insurance Operations Division Should Take Additional Action To Inform 

Homeowners of Changes to Its FHA Refund Process Resulting From the COVID-19 Pandemic, 

12/02/2020.

Audit-Related Memorandums10

10The 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.

55 APPENDIX 1 – REPORTS ISSUED I HUD OIG Semiannual Report to Congress
Public and Indian Housing

2021-LA-0803 Use of Landlord Incentives in the Housing Choice Voucher Program, 01/25/2021.

Public and Indian Housing

2021-SE-1801 Review of the Nampa Housing Authority’s Public Housing Program, Nampa, ID, 10/05/2020. 

Better use: $1,550.

Audit-Related Memorandums Continued

Audit-Related Memorandums11

Community Planning and Development

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. Questioned: 

$272,206. Unsupported: $270,656.

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. Questioned: $6,829,177. 

Unsupported: $6,829,177. Better use: $854,223.

External Audit Reports

11The 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.

56 APPENDIX 1 – REPORTS ISSUED I HUD OIG Semiannual Report to Congress
Housing and FHA

2019-OE-0003 Contaminated Sites Pose Potential Health Risks to Residents at HUD-Funded Properties, 

02/14/2021

Information Technology

2020-OE-0001 HUD Fiscal Year 2020 Federal Information Security Modernization Act of 2014 (FISMA), 

11/30/2020

Internal Evaluation Reports Issued

57 APPENDIX 1 – REPORTS ISSUED I HUD OIG Semiannual Report to Congress
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-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

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

APPENDIX 2 - TABLES

AUDIT REPORTS ISSUED BEFORE START OF PERIOD WITH NO MANAGEMENT DECISION AS OF 3/31/2021

TABLE A

*Significant Audit Reports Described in Previous Semiannual Reports

58 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
Report number Report title Issue date

* 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

* 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

59 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
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

2016-OE-0004S Opportunities for Improvement Within CPD’s Risk Management 

Process for Hurricane Sandy Grants 03/29/2017

2018-OE-0004 HUD IT System Management and Oversight of the Section 184 

Program 08/13/2018

2019-OE-0001 HUD Has Not Referred Troubled Public Housing Agencies as the Law 

and Regulations Require 02/04/2020

EVALUATION REPORTS ISSUED BEFORE START OF PERIOD WITH NO MANAGEMENT DECISION AS OF 03/31/2021

60 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
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 04/10/2021

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 04/10/2021

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 04/10/2021

2011-AT-1018 The Municipality of San Juan, PR, Did Not Properly Manage Its 

HOME Investment Partnerships Program 09/28/2011 01/12/2012 10/01/2021

APPENDIX 2 - TABLES

TABLE B

61 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
Report number Report title Issue date Decision date Final action 

target date

2012-NY-1002 The City of New York Charged Questionable Expenditures to Its 

HPRP, New York, NY 10/18/2011 02/16/2012 04/10/2021

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 04/10/2021

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 04/10/2021

2012-CH-1012

The Saginaw Housing Commission Did Not Always Administer 

Its Section 8 Housing Choice Voucher Program in Accordance 

With HUD’s and Its Own Requirements, Saginaw, MI

09/27/2012 01/07/2013 01/01/2023

2013-PH-1001 Luzerne County Did Not Properly Evaluate, Underwrite, and 

Monitor a High-Risk Loan, Wilkes-Barre, PA 10/31/2012 01/31/2013 Note 1

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 04/10/2021

62 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
Report number Report title Issue date Decision date Final action 

target date

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 04/10/2021

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 04/10/2021

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 07/31/2029

2014-AT-1001 The Municipality of Arecibo Did Not Properly Administer Its 

HOME Program 12/03/2013 01/24/2014 04/10/2021

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 04/10/2021

63 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
Report number Report title Issue date Decision date Final action 

target date

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 04/10/2021

2014-NY-0001 HUD Did Not Provide Effective Oversight of Section 202 

Multifamily Project Refinances 02/19/2014 06/10/2014 04/10/2021

2014-AT-0001 Violations Increased the Cost of Housing’s Administration of Its 

Bond Refund Program 03/14/2014 07/11/2014 04/10/2021

2014-FW-0002 Improvements Are Needed Over Environmental Reviews of 

Public Housing and Recovery Act Funds in the Kansas City Office 05/12/2014 03/17/2015 04/10/2021

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 04/10/2021

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 04/10/2021

64 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
Report number Report title Issue date Decision date Final action 

target date

2014-LA-0005

HUD Did Not Always Recover FHA Single-Family Indemnification 

Losses and Ensure That Indemnification Agreements Were 

Extended

08/08/2014 12/03/2014 04/10/2021

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

2014-FW-0005 Improvements Are Needed Over Environmental Reviews of 

Public Housing and Recovery Act Funds in the Detroit Office 09/24/2014 03/17/2015 04/10/2021

2015-FW-1801 The Management of the Housing Authority of the City of Taylor, 

Taylor, TX, Did Not Exercise Adequate Oversight of Its Programs 10/02/2014 01/21/2015 10/02/2021

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 04/10/2021

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 04/10/2021

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 04/10/2021

65 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
Report number Report title Issue date Decision date Final action 

target date

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 04/10/2021

2015-LA-0002 HUD Did Not Provide Adequate Oversight of the Section 184 

Indian Home Loan Guarantee Program 07/06/2015 10/28/2015 12/31/2021

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 12/29/2021

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 04/10/2021

66 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
Report number Report title Issue date Decision date Final action 

target date

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 04/10/2021

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 04/10/2021

2015-CH-1009

The State of Illinois' Administrator Lacked Adequate Controls 

Over the State's Community Development Block Grant Disaster 

Recovery Program-Funded Projects

09/30/2015 01/28/2016 06/28/2021

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 04/10/2021

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

67 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
Report number Report title Issue date Decision date Final action 

target date

2016-DP-0801 Review of Information System Controls Over the Government 

National Mortgage Association 11/30/2015 03/30/2016 04/10/2021

2016-DP-0002 Single Family Insurance System and Single Family Insurance 

Claims Subsystem 12/21/2015 03/31/2016 04/10/2021

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 04/10/2021

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 04/10/2021

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 04/10/2021

2016-BO-1003

The State of Connecticut Did Not Always Administer Its 

Neighborhood Stabilization Program in Compliance With HUD 

Regulations

06/28/2016 10/25/2016 04/10/2021

2016-PH-0001 HUD Did Not Always Provide Adequate Oversight of Property 

Acquisition and Disposition Activities 06/30/2016 02/16/2017 Note 3

68 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
Report number Report title Issue date Decision date Final action 

target date

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 Note 1

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-BO-1001 The State of Connecticut Did Not Always Comply With CDBG 

Disaster Recovery Assistance Requirements 10/12/2016 02/01/2017 04/10/2021

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 04/10/2021

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

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 Note 3

69 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
Report number Report title Issue date Decision date Final action 

target date

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 04/10/2021

2017-LA-0002 HUD Failed To Follow Departmental Clearance Protocols for FHA 

Programs, Policies, and Operations 01/25/2017 09/22/2017 04/10/2021

2017-DP-0001 HUD's Transition to a Federal Shared Service Provider Failed To 

Meet Expectations 02/01/2017 05/25/2017 04/10/2021

2017-DP-0002

Review of Information Systems Controls Over FHA’s Single 

Family Premiums Collection Subsystem – Periodic and the Single 

Family Acquired Asset Management System

02/09/2017 06/12/2017 04/10/2021

2017-KC-1801

Final Action Memorandum: Purchaser of HUD-Insured SingleFamily Property Settled Allegations of Causing the Submission 

of a False Claim

02/23/2017 02/23/2017 06/15/2021

2017-LA-0003 HUD Failed To Adequately Oversee FHA-Insured Loans With 

Borrower-Financed Downpayment Assistance 03/03/2017 06/22/2017 Note 1

70 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
Report number Report title Issue date Decision date Final action 

target date

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 04/10/2021

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 03/27/2022

2017-NY-0001 HUD PIH's Required Conversion Program Was Not Adequately 

Implemented 05/18/2017 09/15/2017 12/31/2023

2017-KC-0003

HUD Did Not Ensure That Lenders Properly Processed Voluntary 

Terminations of Insurance Coverage on FHA Loans and Disclosed 

All Implications of the Terminations to the Borrowers

05/22/2017 09/19/2017 Note 1

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 04/10/2021

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 04/10/2021

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 04/10/2021

71 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
Report number Report title Issue date Decision date Final action 

target date

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 04/10/2021

2017-LA-1006

The City of Fresno, CA, Did Not Administer Its Community 

Development Block Grant in Accordance With HUD 

Requirements

08/09/2017 11/21/2017 04/10/2021

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 Note 1

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 Note 2

2017-LA-0004 HUD Did Not Have Adequate Controls To Ensure That Servicers 

Properly Engaged in Loss Mitigation 09/14/2017 01/11/2018 04/10/2021

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 04/10/2021

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

72 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
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 09/30/2021

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 04/10/2021

2018-FW-1001 Jefferson Parish, Jefferson, LA, Did Not Always Properly 

Administer Its Rehabilitation Program 01/29/2018 05/22/2018 04/10/2021

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

73 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
Report number Report title Issue date Decision date Final action 

target date

2018-PH-1002

The Fairmont-Morgantown Housing Authority, Fairmont, WV, 

Did Not Always Ensure That Its Program Units Met Housing 

Quality Standards and That It Accurately Calculated Housing 

Assistance Payment Abatements

02/16/2018 06/12/2018 04/10/2021

2018-DP-0003 Fiscal Year 2017 Review of Information Systems Controls in 

Support of the Financial Statements Audit 03/09/2018 06/07/2018 04/10/2021

2018-KC-0802 Limited Review of HUD Multifamily Waiting List Administration 03/22/2018 07/25/2018 Note 1

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 04/10/2021

2018-KC-0001 FHA Insured $1.9 Billion in Loans to Borrowers Barred by Federal 

Requirements 03/26/2018 07/11/2018 Note 1

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 04/10/2021

2018-KC-1002 The Kansas City, MO, Health Department Did Not Spend Funds 

in Accordance With HUD Requirements 04/06/2018 08/02/2018 04/10/2021

74 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
Report number Report title Issue date Decision date Final action 

target date

2018-LA-0002

HUD Did Not Have Adequate Controls To Ensure That Grantees 

Submitted Accurate Tribal Enrollment Numbers for Program 

Funding

05/07/2018 08/23/2018 04/10/2021

2018-FW-1004 The City of Dallas, TX, HOME Investment Partnerships Program 

Was Not Always Administered in Accordance With Requirements 05/08/2018 08/30/2018 04/10/2021

2018-FW-0802

Interim Report - Potential Antideficiency Act and Generally 

Accepted Accounting Principle Violations Occurred With Disaster 

Relief Appropriation Act, 2013, Funds

05/15/2018 09/12/2018 04/10/2021

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 12/31/2021

2018-BO-1003 The City of Providence, RI, Did Not Properly Administer Its HOME 

Program 06/20/2018 09/28/2018 04/10/2021

2018-FW-0001 CPD’s Risk Assessment and Monitoring Program Did Not Provide 

Effective Oversight of Federal Funds 06/26/2018 10/16/2018 Note 1

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 12/31/2021

75 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
Report number Report title Issue date Decision date Final action 

target date

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 04/10/2021

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 04/10/2021

2018-KC-0004 HUD Did Not Always Identify and Collect Partial Claims Out of 

Surplus Foreclosure Proceeds 09/20/2018 04/18/2019 12/31/2021

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 04/10/2021

2018-NY-0001 HUD Did Not Adequately Administer Its Housing Counseling 

Program 09/24/2018 02/26/2019 04/01/2022

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 Note 2

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 04/10/2021

76 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
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 04/02/2021

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 04/10/2021

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 04/10/2021

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 04/10/2021

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 04/10/2021

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 04/10/2021

2019-CH-1001

The Housing Authority of the City of North Chicago, North 

Chicago, IL, Did Not Always Comply With HUD’s Requirements 

and Its Own Policies Regarding the Administration of Its Housing 

Choice Voucher Program

12/20/2018 03/28/2019 02/28/2024

77 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
Report number Report title Issue date Decision date Final action 

target date

2019-CH-1002

The Detroit Housing Commission, Detroit, MI, Did Not Always 

Administer Its Moderate Rehabilitation Program in Accordance 

With HUD’s and Its Own Requirements

02/06/2019 06/05/2019 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 04/10/2021

2019-DP-0004 Fiscal Year 2018 Review of Information Systems Controls in 

Support of the Financial Statements Audit 03/27/2019 06/20/2019 04/10/2021

2019-KC-0001 FHA Improperly Paid Partial Claims That Did Not Reinstate Their 

Related Loans 04/11/2019 08/02/2019 07/31/2021

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 04/10/2021

2019-BO-1002

The Housing Authority of the City of Woonsocket, RI, Did Not 

Always Comply With Capital Fund Program and Procurement 

Requirements

05/07/2019 10/22/2019 04/10/2021

78 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
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 Note 2

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-1008

The Compton Housing Authority, Compton, CA, Did Not 

Administer Its Housing Choice Voucher Program in Accordance 

With HUD Requirements

07/11/2019 10/23/2019 04/10/2021

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 Note 2

2019-NY-1003

New York City Department of Housing Preservation and 

Development, New York, NY, Did Not Always Ensure That Units 

Met Housing Quality Standards but Generally Abated Payments 

When Required

08/02/2019 11/25/2019 04/10/2021

2019-BO-1003

The Commonwealth of Massachusetts Did Not Always Ensure 

That Its Grantees Complied With Applicable State and Federal 

Laws and Requirements

08/05/2019 12/03/2019 04/10/2021

2019-FW-1006

The Bogalusa Housing Authority, Bogalusa, LA, Did Not Always 

Administer Its Public Housing Programs in Accordance With 

Requirements

08/16/2019 11/26/2019 05/31/2021

79 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
Report number Report title Issue date Decision date Final action 

target date

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 Note 2

2019-CF-1803

Pacific Horizon Bancorp, Inc., and Two Loan Officers Settled 

Allegations of Failing To Comply With HUD’s Federal Housing 

Administration Loan Requirements

09/30/2019 09/30/2019 08/01/2024

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 01/31/2022

2020-CH-1001

The City of Detroit’s Housing and Revitalization Department, 

Detroit, MI, Did Not Administer Its Lead Hazard Reduction 

Demonstration Grant Program in Accordance With HUD’s 

Requirements

10/02/2019 01/31/2020 Note 2

2020-CH-0001

HUD’s Office of the Chief Financial Officer Generally Complied 

With the Digital Accountability and Transparency Act of 2014 

With a Few Exceptions

11/07/2019 02/11/2020 04/30/2021

2020-LA-1001

Community Action North Bay, Fairfield, CA, Did Not Administer 

Its Continuum of Care Program in Accordance With HUD 

Requirements

01/31/2020 05/14/2020 05/13/2021

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

80 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
Report number Report title Issue date Decision date Final action 

target date

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 08/13/2021

2020-AT-0802

HUD Inaccurately Allotted Funding for Tenant Protection 

Assistance and Improperly Approved a Proposed RAD 

Conversion

02/18/2020 06/04/2020 04/10/2021

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 12/31/2021

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 06/30/2021

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 07/13/2021

2020-CH-0003 HUD Lacked Adequate Oversight of Public Housing Agencies’ 

Compliance With the Lead Safe Housing Rule 03/18/2020 09/03/2020 12/10/2022

81 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
Report number Report title Issue date Decision date Final action

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 08/10/2021

2020-PH-1001

The Philadelphia Housing Authority, Philadelphia, PA, Did 

Not Comply With Procurement and Conflict-of-Interest 

Requirements

04/20/2020 10/16/2020 04/15/2021

2020-KC-1001 Englewood Apartments, Kansas City, MO, Did Not Comply With 

Tenant Eligibility and Recertification Requirements 06/08/2020 09/22/2020 09/01/2021

2020-BO-0001 HUD Could Strengthen Controls Over Employee Benefits 

Expensed at Public Housing Agencies 08/12/2020 01/14/2021 09/30/2021

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 12/31/2021

2020-CH-0005 HUD Needs To Improve Its Oversight of Lead in the Water of 

Multifamily Housing Units 08/21/2020 01/26/2021 12/31/2021

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 03/31/2021

82 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
Report number Report title Issue date Decision date Final action

2020-AT-1003

The Housing Authority of the City of Macon-Bibb County, GA, 

Improperly Executed the HAP Contract for Vineville Christian 

Towers’ RAD Conversion

08/31/2020 11/20/2020 11/20/2021

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 12/31/2021

2020-DP-0002 HUD, Washington, DC, Information Security Weaknesses Existed 

Within NCIS 09/22/2020 01/22/2021 Note 2

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 09/20/2021

Audits Excluded:

77 audits under repayment plans

36 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

83 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
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 FY 2013 Federal Information Security Management Act (FY13 

FISMA) 11/29/13 11/29/13 Note 1

2014-ITED-0001 FY14 HUD Privacy Program Evaluation 04/30/14 04/30/14 Note 1

2014-OE-0002 Risk Based Enforcement Could Improve Program Effectiveness 02/12/16 04/9/19 Note 2

2014-OE-0003 FY 2014 Federal Information Security Modernization Act (FY14 

FISMA) 11/15/14 11/15/14 Note 1

2015-OE-0001 FY 2015 Federal Information Security Modernization Act (FY15 

FISMA) 11/15/15 11/15/15 Note 1

2015-OE-0002 HUD IT Modernization 09/28/15 09/25/15 Note 1

84 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
Report number Report title Issue date Decision date Final action

2016-OE-0002 HUD Web Application Security Evaluation 06/6/18 n/a Note 2

2016-OE-0004S Opportunities for Improvement within CPD’s Risk Management 

Process for Hurricane Sandy Grants 03/29/17 08/20/19 Note 2

2016-OE-0006 FY 2016 Federal Information Security Modernization Act (FY16 

FISMA) 11/10/16 11/10/16 Note 1

2017-OE-0007 FY 2017 Federal Information Security Modernization Act (FY17 

FISMA) 10/31/17 08/16/18 Note 1

2018-OE-0001 HUD Privacy Program Evaluation Report 09/13/18 11/27/18 Note 1

2018-OE-0002 Fire Safety Planning for the Weaver Building Needs Improvement 06/12/18 11/29/18 Note 1

2018-OE-0003 FY 2018 Federal Information Security Modernization Act (FY18 

FISMA) 10/31/18 05/17/19 Note 1

2018-OE-0004 HUD IT System Management and Oversight of the Section 184 

Program 08/13/18 n/a Note 2

2019-OE-0001 HUD Has Not Referred Troubled Public Housing Agencies as the 

Law and Regulations Require 02/04/20 09/30/20 Note 2

85 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
SIGNIFCANT 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 03/31/21

Report number Report title Issue date Decision date Final action

2019-OE-0002 HUD Fiscal Year 2019 Federal Information Security 

Modernization Act of 2014 (FY19 FISMA) Evaluation Report 06/24/20 01/19/21 Note 3

2019-OE-0002a HUD Personally Identifiable Information (PII) Records Protection 

and Management 06/25/20 12/21/20 Note 3

2020-OE-0001 HUD Fiscal Year 2020 Federal Information Security 

Modernization Act of 2014 (FY20 FISMA) Evaluation Report 11/30/20 03/30/21 Note 3

Notes: 

1 Management did not meet the target date. Target date is more than 1 year old.

2 No management decision

3 Management working to meet target date. Target data is less than 1 year old.

86 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
INSPECTOR GENERAL-ISSUED REPORTS WITH QUESTIONED AND UNSUPPORTED COSTS AS OF 03/31/2021 (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 7 $395,024 $390,913

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 - 5,763 3,634

A4  For which costs were added to noncost reports 0 0 0

B1  Which were issued during the reporting period 2 7,101 7,100

B2  Which were reopened during the reporting period 0 0 0

Subtotals (A+B) 9 407,888 401,647

APPENDIX 2 - TABLES

TABLE C

87 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
Audit reports Number of 

audit reports

Questioned

costs

Unsupported

costs

C     For which a management decision was made during 

the reporting period 412 7,440 4,765

 (1) Dollar value of disallowed costs:

 Due HUD

 Due program participants

2

2

1,648

5,792

1,148

3,167

 (2) Dollar value of disallowed costs: 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 

5

<17>13

400,448

<387,177>13

396,882

<383,615>13

12Two audit reports also contain recommendations with funds to be put to better use.

13The figures in brackets represent data at the recommendation level as compared to the report level. See Explanations of Tables C and D.

TABLE C CONTINUED

88 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
Audit reports Number of 

audit reports Dollar value

A1  For which no management decision had been made by 

the beginning of the reporting period 10 $8,499,523

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 - 0

A4  For which costs were added to noncost reports 0 0

B1  Which were issued during the reporting period 3 438,691

B2  Which were reopened during the reporting period 0 0

Subtotals (A+B) 13 8,938,214

INSPECTOR GENERAL-ISSUED REPORTS WITH QUESTIONED AND UNSUPPORTED COSTS AT 3/31/2021 (THOUSANDS)

APPENDIX 2 - TABLES

TABLE D

89 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
Audit reports Number of 

audit reports Dollar value

C     For which a management decision was made during 

the reporting period 714 2,977,713

 (1) Dollar value of recommendations that were agreed

 to by management:

 Due HUD

 Due program participants

4

3

2,642,388

293

 (2) Dollar value of recommendations that were not

 agreed upon by management 315 335,032

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 been made by 

the end of the reporting period 

6

<7>16

5,960,501

<5,417,766>16

14Two audit reports also contain recommendations with questioned costs.

15Three audit reports also contain recommendations with funds agreed to by management.

16The figures in brackets represent data at the recommendation level as compared to the report level. See Explanations of Tables C and D.

TABLE D CONTINUED

90 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
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 method 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 and require 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.

91 APPENDIX 2 – TABLES I HUD OIG Semiannual Report to Congress
APPENDIX 3 - 

INSPECTOR GENERAL 

EMPOWERMENT ACT

The Inspector General Empowerment Act (IGEA) requires the Office of 

Inspector General (OIG) to report on each audit and evaluation report 

for which the U.S. Department of Housing and Urban Development 

(HUD) did not return comments within 60 days of HUD OIG’s providing 

the report to the Department

SUMMARY OF REPORTS WITH NO ESTABLISHMENT COMMENT

OFFICE OF INVESTIGATION

On February 22, 2019, HUD OIG’s Office of Investigation delivered 

Systemic Implication Report (SIR) fiscal year (FY) 19-001, SIR Pertaining 

to the Housing Choice Voucher Program Initial Certification and Annual 

Recertifications, to HUD’s Office of Public and Indian Housing. Specifically, 

the SIR recommended that HUD standardize the initial certification and 

annual recertification questionnaire for the Housing Choice Voucher 

Program. It specifically recommended that HUD standardize and require 

the use of a personal declaration form regarding a tenant’s declaration of 

his or her income and assets. The Department did not respond within the 

requisite 60 days, and HUD OIG has still not received a response.

SUMMARY OF REPORTS WITH OPEN RECOMMENDATIONS 

The IGEA requires OIGs 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

The Department currently has 1,116 outstanding (open) unimplemented 

recommendations with a combined potential cost savings of more than 

$20 billion. The following table and charts reflect the reasons why they 

remain unimplemented:

1. 1,052 recommendations have active corrective action plans in place 

or valid repayment plans, but HUD has not finished implementing 

the recommendation. 

2. 64 recommendations are currently without management decisions 

(agreement between the Department and OIG), 34 of which are 

beyond the 180-day statutory requirements due to disagreement 

and were reported in table A of OIG’s Semiannual Report to Congress 

(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. 398 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.

92 APPENDIX 3 – INSPECTOR GENERAL EMPOWERMENT ACT I HUD OIG Semiannual Report to Congress
Calendar year Number of open 

recommendations

Cumulative estimated cost savings from 

open recommendations

Pre-2001 3 $1,820,555

2001 1 160,000

2002 7 1,379,626

2003 12 1,749,622

2004 8 8,267,893

2005 5 3,006,373

2006 12 10,404,273

2007 15 4,996,289

2008 29 71,766,547

2009 24 4,949,326

2010 16 18,271,251

2011 35 101,389,032

2012 14 10,725,709

2013 51 56,924,038

2014 111 390,353,129

2015 96 342,375,572

2016 137 7,287,072,531

2017 145 873,236,095

2018 148 4,408,573,144

2019 105 6,664,591,047

2020 118 6,800,820

2021 24 445,518,934

Total 1,116 20,714,331,806

OFFICE OF AUDIT SUMMARY

93 APPENDIX 3 – INSPECTOR GENERAL EMPOWERMENT ACT I HUD OIG Semiannual Report to Congress
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.

OFFICE OF EVALUATION

Calendar year Number of open recommendations

2013 4

2014 9

2015 13

2016 4

2017 12

2018 31

2019 0

2020 61

Total 138

94 APPENDIX 3 – INSPECTOR GENERAL EMPOWERMENT ACT I HUD OIG Semiannual Report to Congress
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 4.5.1, and the database is SQL 2017. HUD 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 referenced in the table provide additional guidance pertaining to each requested category 

of information.

REPORTING PERIOD: FY 2021, PERIOD 1 (SAR 85), OCTOBER 1, 2020, THROUGH MARCH 31, 2021

Measure Total

A. Total number of investigative reports issued during 

the reporting period17 204

B. Total number of persons referred to the U.S. 

Department of Justice for criminal prosecution during 

the reporting period 

123

C. Total number of persons referred to State and local 

prosecuting authorities for criminal prosecution during 

the reporting period 

23

D. Total number of indictments and criminal 

informations during the reporting period that resulted 

from any prior referral to prosecuting authorities18

77

17Includes approved reports of investigations

18Includes all charging documents reported: criminal complaints, indictments, information and superseding indictments

95 APPENDIX 3 – INSPECTOR GENERAL EMPOWERMENT ACT I HUD OIG Semiannual Report to Congress
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.

1. OIG initiated an investigation based on allegations that a senior 

HUD employee, who is also an attorney, had been involved in 

several violations of the Standards of Ethical Conduct for Employees 

of the Executive Branch and the Standards of Ethical Conduct for 

Employees of HUD, despite the provision of clear legal guidance 

from HUD’s Office of Regional Counsel. The employee is a 

mandatory OGE-450 filer with the Office of Government Ethics (OGE). 

In both 2013 and 2014, the employee’s 450 forms were not certified 

by HUD’s Regional Counsel because they failed to provide requested 

documentation. In 2014, the employee was cautioned regarding 

HUD’s pro bono policy because the employee’s OGE-450 indicated 

that the employee was operating an outside law office. Once again 

in 2016, Regional Counsel had concerns regarding the submission of 

OGE-450 forms and the lack of documentation to support activities 

outside of HUD employment. 

The investigation focused on examining the employee’s activity as a 

private attorney and outside employment. Eight separate instances 

were identified in which the employee represented individuals as an 

attorney in several county court districts and divisions, all of which 

occurred during the period 1992 through 2002. The employee was 

also involved in four court cases filed in U.S. District Court, which 

were all filed during the period 1993 through 2008. The employee 

admitted to failing to obtain permission to conduct pro bono legal 

work for every instance in which the employee did so. However, the 

investigation found no evidence that the employee was employed 

outside HUD past 2010.

This investigation was referred to and declined for criminal 

prosecution by the United States Attorney’s Office on July 22, 2020. 

The results of this investigation were referred to HUD’s Office of 

Regional Counsel, and the employee was suspended for 5 calendar 

days.

2. OIG initiated an investigation based on allegations that a senior HUD 

employee was not recused from HUD matters while negotiating 

future employment with a private-sector firm conducting business 

with HUD. The former employee, after leaving HUD, represented the 

private-sector firm to HUD on matters this individual had worked on 

while a HUD employee. 

The investigation determined that the employee engaged in 

misconduct during the employee’s tenure as well as after departing 

HUD. The investigation found that the former employee (1) while 

still a HUD employee, was not recused from and inappropriately 

intervened in a HUD matter involving a lender with which the 

former employee was negotiating postgovernment employment; (2) 

removed from HUD and brought to a new private-sector employer 

many HUD documents and reports about financial institutions, 

which contained confidential, nonpublic, proprietary information; 

and (3) made many communications with and appearances before 

HUD on behalf of private-sector clients regarding matters on which 

the former employee worked or supervised while employed at HUD, 

in violation of Federal ethics regulations.

OIG referred this matter to the U.S. Attorney’s Office in April 2019 and 

96 APPENDIX 3 – INSPECTOR GENERAL EMPOWERMENT ACT I HUD OIG Semiannual Report to Congress
HUD’s Office of Program Enforcement for any action they deemed 

appropriate. On April 21, 2020, the U.S. Attorney’s Office announced 

that the former employee agreed to pay $25,000 to settle allegations 

that the former employee had an improper conflict of interest with a 

company while serving as a senior employee at HUD. On November 

16, 2020, HUD settled with the former employee, resolving potential 

administrative allegations.

3. OIG initiated an investigation based on allegations that a senior HUD 

employee may have violated a Federal law that prohibits former 

Federal employees from appearing in matters pending before an 

agency in which they had personal and substantial participation 

before leaving Federal service. The investigation found no evidence 

to substantiate such a violation. However, there was evidence 

establishing that the employee violated various provisions of the 

Federal ethics regulations and the Federal statutory prohibition 

against conflicts of interest. This investigation was referred to and 

declined for criminal prosecution by the United States Attorney’s 

Office on October 10, 2018. 

4. OIG initiated an investigation of a senior HUD employee based on 

allegations of unauthorized use of substantial government time and 

equipment to conduct personal business, failure to disclose required 

information on the OGE-450 form, and failure to disclose a personal 

relationship with an individual who benefited from the subject’s 

official HUD duties. The investigation substantiated the allegations, 

and the case was referred to the United States Attorney’s Office for 

criminal prosecution on May 11, 2016, but was later declined by the 

United States Attorney’s Office on October 9, 2018. The investigation 

was referred to HUD. HUD declined to pursue administrative 

disciplinary action. 

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. 

OIG has no instances of whistleblower retaliation to report in this SAR 

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. 

OIG has no instances of attempts to interfere with OIG independence to 

report in this SAR period.

97 APPENDIX 3 – INSPECTOR GENERAL EMPOWERMENT ACT I HUD OIG Semiannual Report to Congress
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 AUDIT

The Office of Audit did not close any audits this semiannual period that 

were not disclosed to the public. 

OFFICE OF INVESTIGATION

During the current reporting period, OIG has seven investigative reports 

that were closed but not disclosed to the public. The allegations include 

the following:

1. OIG initiated an investigation based on allegations that a senior HUD 

employee may have violated a Federal law that prohibits former 

Federal employees from appearing in matters pending before an 

agency in which they had personal and substantial participation 

before leaving Federal service. The investigation found no evidence 

to substantiate such a violation. However, there was evidence 

establishing that the employee violated various provisions of the 

Federal ethics regulations and the Federal statutory prohibition 

against conflicts of interest. This investigation was referred to and 

declined for criminal prosecution by the United States Attorney’s 

Office on October 10, 2018. 

2. OIG initiated an investigation based on allegations of a potential 

conflict of interest involving a former senior HUD employee’s 

participation in potentially conflicting activity before leaving HUD. 

The investigation reviewed whether the employee participated 

in matters of policy significant to a private-sector entity while in 

negotiations for employment with that entity. The investigation 

determined that the employee did participate in the HUD decisionmaking process while negotiating employment. However, it was 

determined that the employee’s actions did not violate conflictof-interest laws because the private-sector entity with which the 

employee was negotiating did not itself have a financial interest in 

any matter in which the employee participated. The investigation 

did not substantiate the allegations, and the investigation was 

neither presented for prosecution nor referred to HUD.

3. OIG initiated an investigation based on whistleblower allegations 

that senior HUD employees were acting in a way that may constitute 

an abuse of authority, gross mismanagement, and a gross waste 

of funds. The whistleblower alleged that the Federal Housing 

Administration’s (FHA) approval of mortgage insurance on several 

large refinancing transactions under HUD’s Section 223(f) program 

resulted in a significant unrestricted cashout to borrowers, which 

posed an excessive risk to FHA’s insurance funding program and 

undermined HUD’s mission to provide affordable housing. The 

investigation did not substantiate the allegations, and this matter 

was referred to HUD. 

4. OIG initiated an investigation based on allegations that a senior 

HUD employee misused the employee’s position by directing 

a staff assistant to assist with work required for the employee’s 

master’s degree. It was further alleged that the employee used HUD 

98 APPENDIX 3 – INSPECTOR GENERAL EMPOWERMENT ACT I HUD OIG Semiannual Report to Congress
information technology (IT) equipment and supplies to complete 

assignments for this degree. The investigation did not substantiate 

the allegations; however, the employee resigned from HUD. This 

investigation was neither presented for prosecution nor referred to 

HUD

5. OIG initiated an investigation based on allegations that a senior 

HUD employee sent harassing and threatening emails and text 

messages to HUD employees and accessed inappropriate sexual 

content and messages through the employees’ HUD accounts. HUD 

previously placed the employee on administrative leave due to the 

alleged conduct and referred the threat allegations to the Federal 

Protective Service. The investigation found no evidence to support 

the allegation that the employee used government-issued IT 

equipment to access inappropriate sexual content or messages. The 

investigation was not referred to the United States Attorney’s Office 

because the threat allegations were unsubstantiated. This matter 

was referred to HUD to complete its administrative inquiry, and the 

employee was dismissed

6. OIG initiated an investigation based on allegations that a senior HUD 

employee was not recused from HUD matters while negotiating 

future employment with a private-sector firm conducting business 

with HUD. The former employee, after leaving HUD, represented the 

private-sector firm to HUD on matters this individual had worked on 

while a HUD employee. 

The investigation determined that the employee engaged in 

misconduct during the employee’s tenure as well as after departing 

HUD. The investigation found that the former employee (1) while 

still a HUD employee, was not recused from and inappropriately 

intervened in a HUD matter involving a lender with which the 

former employee was negotiating postgovernment employment; (2) 

removed from HUD and brought to a new private-sector employer 

many HUD documents and reports about financial institutions, 

which contained confidential, nonpublic, proprietary information; 

and (3) made many communications with and appearances before 

HUD on behalf of private-sector clients regarding matters on which 

the former employee worked or supervised while employed at HUD, 

in violation of Federal ethics regulations.

OIG referred this matter to the U.S. Attorney’s Office in April 2019 and 

HUD’s Office of Program Enforcement for any action they deemed 

appropriate. On April 21, 2020, the U.S. Attorney’s Office announced 

that the former employee agreed to pay $25,000 to settle allegations 

that the former employee had an improper conflict of interest with a 

company while serving as a senior employee at HUD. On November 

16, 2020, HUD settled with the former employee, resolving potential 

administrative allegations.

7. OIG initiated an investigation of a senior HUD employee based on 

allegations of unauthorized use of substantial government time and 

equipment to conduct personal business, failure to disclose required 

information on the OGE-450 form, and failure to disclose a personal 

relationship with an individual who benefited from the subject’s 

official HUD duties. The investigation substantiated the allegations, 

and the case was referred to the United States Attorney’s Office for 

criminal prosecution on May 11, 2016, but was later declined by the 

United States Attorney’s Office on October 9, 2018. The investigation 

was referred to HUD. HUD declined to pursue administrative 

disciplinary action. 

99 APPENDIX 3 – INSPECTOR GENERAL EMPOWERMENT ACT I HUD OIG Semiannual Report to Congress
OFFICE OF EVALUATION

HUD FISCAL YEAR 2020 FEDERAL INFORMATION SECURITY 

MODERNIZATION ACT OF 2014, ISSUE DATE: NOVEMBER 30, 2020

OIG assessed, for effectiveness, HUD’s information security (IS) program in 

accordance the Federal Information Security Modernization Act (FISMA), 

which directs OIGs to conduct an evaluation using the OIG FISMA metrics. 

The metrics consisted of eight domains aligned with the five functional 

areas (identify, protect, detect, respond, and recover) from the National 

Institute of Standards and Technology Framework for Improving Critical 

Infrastructure Cybersecurity. 

HUD’s IS program was evaluated as not effective based on the FY 2020 

Inspectors General FISMA metrics. Key components of HUD’s IS program 

remain ineffective or have inconsistent processes throughout the HUD 

program offices and among their IT contracts. 

HUD continued to address recommendations that OIG made in previous 

years. HUD’s Office of the Chief Information Officer had success in 

modernizing some of the HUD infrastructure and moving applications to 

modern technology. OIG recommend that HUD continue to address all 

outstanding FISMA recommendations and refine and further implement 

its IT strategic modernization roadmap. OIG made 26 recommendations 

to assist HUD in increasing its information security posture. OIG has 

determined that the contents of this report would not be appropriate for 

public disclosure and has, therefore, limited its distribution to selected 

officials. Evaluation report: 2020-OE-0001

100 APPENDIX 3 – INSPECTOR GENERAL EMPOWERMENT ACT I HUD OIG Semiannual Report to Congress
APPENDIX 4 - REPORTING REQUIREMENTS

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.

12-22

49-50

Section 5(a)(2)-description of recommendations for corrective action with respect to 

significant problems, abuses, and deficiencies. 36-48

Section 5(a)(3)-identification of each significant recommendation described in previous 

Semiannual Report on which corrective action has not been completed.

Appendix 2, 

table B, 61

Section 5(a)(4)-summary of matters referred to prosecutive authorities and the prosecutions 

and convictions that have resulted. 12-22

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 instance

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.

101 APPENDIX 4 – REPORTING REQUIREMENTS I HUD OIG Semiannual Report to Congress
Source requirement Pages

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 

the dollar value of recommendations that funds be put to better use.

Appendix 1, 

53

Section 5(a)(7)-summary of each particularly significant report. 12-22

Section 5(a)(8)-statistical tables showing the total number of audit reports and the total dollar 

value of questioned and unsupported costs.

Appendix 2, 

table C, 87

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, 89

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, 58

Section 5(a)(11)-a description and explanation of the reasons for any significant revised 

management decisions made during the reporting period. 45-47

Section 5(a)(12)-information concerning any significant management decision with which the 

Inspector General is in disagreement. 48

Section 5(a)(13)-the information described under section 05(b) of the Federal Financial 

Management Improvement Act of 1996. 48

102 APPENDIX 4 – REPORTING REQUIREMENTS I HUD OIG Semiannual Report to Congress
AFHMP..............................................................Affirmative Fair Housing Marketing Plan

AGI.......................................................................................The Arize Group, Incorporated

CARES Act......................................Coronavirus Aid, Relief, and Economic Security Act

CDBG.....................................................................Community Development Block Grant

CDBG-DR.............................Community Development Block Grant Disaster Recovery

CDBG-MIT........................................Community Development Block Grant-Mitigation

CFR...........................................................................................Code of Federal Regulations

CIGIE..............................Council of the Inspectors General on Integrity and Efficiency

CPD....................................................Office of Community Planning and Development

DEC..............................................................................Departmental Enforcement Center

DHS.......................................................................U.S. Department of Homeland Security

DoD...........................................................................................U.S. Department of Defense

DOL...............................................................................................U.S. Department of Labor

DOT...............................................................................U.S. Department of Transportation

EPA.................................................................................Environmental Protection Agency

ESG...........................................................................................Emergency Solutions Grants

E.O...................................................................................................................Executive order

FAQ.............................................................................................frequently asked questions

FFMIA................................................Federal Financial Management Improvement Act

FHA....................................................................................Federal Housing Administration

FHFA................................................................................Federal Housing Finance Agency

FISMA....................................Federal Information Security Modernization Act of 2014

FR....................................................................................................................Federal Register

FY...............................................................................................................................fiscal year

Ginnie Mae...............................................Government National Mortgage Association 

GSA...................................................................................General Services Administration

HCAMS............................................Housing Counseling Agency Management System

HCVP.............................................................................Housing Choice Voucher Program

HECM...........................................................................home equity conversion mortgage

HERMIT..................Home Equity Reverse Mortgage Information Technology system

HEROS.........................................................HUD Environmental Review Online System

HFA..................................................................................................housing finance agency

HOPWA....................................................Housing Opportunities for Persons With AIDS

HOTMA..............................Housing Opportunity Through Modernization Act of 2016

HUD............................................U.S. Department of Housing and Urban Development

IGEA.........................................................................Inspector General Empowerment Act

IS.............................................................................................................information security

IT.......................................................................................................information technology

LOS.................................................................................................Loan Origination System

MDD............................................................................................major disaster declaration

ML.................................................................................................................mortgagee letter

MTW.................................................................Moving to Work Demonstration program

NHSLA...................................Neighborhood Housing Services of Los Angeles County

NSP...........................................................................Neighborhood Stabilization Program

NSPIRE...........................National Standards for the Physical Inspection of Real Estate

OCFO...........................................................................Office of the Chief Financial Officer

OCIO.......................................................................Office of the Chief Information Officer

OE.............................................................................................................Office of Evaluation

OFO...............................................................................................Office of Field Operations

OGE..........................................................................................Office of Government Ethics

APPENDIX 5 - ACRONYMS AND ABBREVIATIONS

103 APPENDIX 5 – ACRONYMS AND ABBREVIATIONS I HUD OIG Semiannual Report to Congress
OI.........................................................................................................Office of Investigation

OIG..............................................................................................Office of Inspector General

OMB.............................................................................Office of Management and Budget

ONAP.........................................................................Office of Native American Programs

PHA....................................................................................................public housing agency

PIH...............................................................................Office of Public and Indian Housing 

PII..................................................................................personally identifiable information

PRWORA..............Personal Responsibility and Work Opportunity Reconciliation Act

RAD................................................................Rental Assistance Demonstration Program

REO.............................................................................................................real estate owned

RHFG.....................................................................................Reliant Home Financial Group

SAM...................................................................................System for Award Management

SAR....................................................................................Semiannual Report to Congress

SFDMS..............................................................Single Family Default Monitoring System

SFIOD..........................................................Single Family Insurance Operations Division

SIR..............................................................................................systemic implication report

SOFR.............................................................................Secured Overnight Financing Rate

UCPNCSN.......United Cerebral Palsy of Northern, Central, and Southern New Jersey

U.S.C.........................................................................................................United States Code

USDA...................................................................................U.S. Department of Agriculture

WCHC...............................................................................West Calumet Housing Complex

104 APPENDIX 5 – ACRONYMS AND ABBREVIATIONS I HUD OIG Semiannual Report to Congress
APPENDIX 6 - OIG TELEPHONE DIRECTORY

Headquarters Washington, DC 202-708-0364

Region 1 Boston, MA 617-994-8380

 Hartford, CT 860-240-9739

Region 2 New York, NY 212-264-4174

 Buffalo, NY 716-551-5755

 Newark, NJ 973-622-7900

Region 3 Philadelphia, PA 215-656-0500

 Baltimore, MD 410-962-2520

 Pittsburgh, PA 412-644-6428

 Richmond, VA 804-771-2100

Region 4 Atlanta, GA 404-331-3369

 Greensboro, NC 336-547-4001

 Miami, FL 305-536-5387

 San Juan, PR 787-766-5540

Region 5 Chicago, IL 312-913-8499

 Columbus, OH 614-280-6138

 Detroit, MI 313-226-6190

Region 6 Fort Worth, TX 817-978-9309

 Baton Rouge, LA 225-448-3975

 Houston, TX 713-718-3199

 New Orleans, LA 504-671-3000

 Albuquerque, NM 505-346-6463

 Oklahoma City, OK 405-609-8606

 San Antonio, TX 210-475-6800

REGION 7-8-10 Kansas City, KS 913-551-5870

 St. Louis, MO 314-539-6339

 Denver, CO 303-672-5475

 Seattle, WA 206-220-5360

REGION 9 Los Angeles, CA 213-894-8016

 Las Vegas, NV 702-366-2100

 Phoenix, AZ 602-379-7250

 San Francisco, CA 415-489-6400

OFFICE OF AUDIT

Headquarters Washington, DC 202-708-0430

OFFICE OF EVALUATION

105 APPENDIX 6 – OIG TELEPHONE DIRECTORY I HUD OIG Semiannual Report to Congress
Headquarters Washington, DC 202-708-0390

Region 1-2 New York, NY 212-264-8062

 Boston, MA 617-994-8450

 Hartford, CT 860-240-4800

 Manchester, NH 603-666-7988

 Newark, NJ 973-776-7342

Region 3 Philadelphia, PA 215-861-7676

 Baltimore, MD 410-209-6594

 Pittsburgh, PA 412-644-2857

 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

 Indianapolis, IN 317-957-7377

 

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 7-8-10 Denver, CO 303-672-5350

 Billings, MT 406-247-4080

 Kansas City, KS 913-551-5566

 Salt Lake City, UT 801-524-6090

 St. Louis, MO 314-539-6559

Region 9 Los Angeles, CA 213-894-8000

 Las Vegas, NV 702-366-2144

 Phoenix, AZ 602-379-7251

 San Francisco, CA 415-489-6400

 Seattle, WA 206-220-5138

OFFICE OF INVESTIGATION

Minneapolis- 612-370-3130

St. Paul, MN

106 APPENDIX 6 – OIG TELEPHONE DIRECTORY I HUD OIG Semiannual Report to Congress
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.

107 HUD OIG Semiannual Report to Congress
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

Scan to Report Fraud

Report #85