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

SEMIANNUAL REPORT 

TO CONGRESS

OFFICE OF INSPECTOR GENERAL

U.S. Department of Housing and Urban Development

For the period April 1, 2022, to September 30, 2022
 | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 2

TABLE of

CONTENTS

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Appendix 6 - OIG Directory ...............................................................................90
Profile of Performance | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 3

AUDIT RESULTS

Recommended funds put to better use $131,396,220 $7,075,520,237

Questioned costs $5,544,208 $11,969,302

Collections from audits $11,295,572 $18,130,811

Administrative sanctions 1 2

Civil actions 0 0

Subpoenas 0 1

Personnel actions 0 0

INVESTIGATIVE RESULTS

Total restitutions and judgments $19,687,745 $40,503,582

Total recoveries and receivables to HUD programs $7,578,993 $10,695,971

Arrests 27 62

Indictments and informations 45 96

Convictions, pleas, and pretrial diversions 47 96

Civil actions 9 23

Total administrative sanctions 11 34

Suspensions 0 7

Debarments 2 7

Program or professional license-certification 3 4

Evictions 2 3

Other1 4 13

Search warrants 24 37

Subpoenas 310 665

PROFILE of

PERFORMANCE

For the period April 1, 2022, to 

September 30, 2022

This Reporting Period Fiscal Year 2022

1 Includes employee actions (reprimands, suspensions, 

demotions, or terminations of the employees of Federal, 

State or local governments or of Federal contractors and 

grantees as the result of OIG activities) and limited denials 

of participation 

This Reporting Period Fiscal Year 2022
A Message from the Inspector General | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 4

A MESSAGE FROM THE 

INSPECTOR GENERAL

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

Semiannual Report to Congress, which covers the period April 1, 2022, through September 30, 2022. My office has continued to 

focus our independent audits, evaluations, and investigations on the most pressing issues facing HUD. We understand the need 

to do the right work at the right time and remain steadfast in holding ourselves and the Department accountable for protecting 

the integrity of taxpayer-funded programs and those who rely on HUD’s programs for their critical housing needs. 

We have taken a forward leaning approach towards helping HUD achieve its mission of providing housing that is decent, safe, 

sanitary, and in good repair. During this semiannual reporting period, we have focused our resources on developing high impact 

oversight projects directed at protecting HUD beneficiaries from health and safety hazards in HUD-assisted housing. 

Our Office of Evaluations produced Risk Indicators of Lead-Based Paint Hazards in Public Housing Agencies, identifying nine 

indicators of potential risk for lead-based paint hazards in HUD-assisted housing, five of which had not been included in HUD’s 

current list of risk indicators. Further, applying these nine risk indicators, the report identified five HUD regions and six states 

within those regions with the most potential of having PHAs with lead-based paint hazards. We produced this report to HUD as a 

resource in its efforts to reduce lead hazards for its beneficiaries. 

Further, we have initiated and are carrying out multiple oversight projects directed at addressing and improving health and safety 

conditions for HUD beneficiaries, to include: 

• Philadelphia Housing Authority Management of Lead Based Paint in Public Housing

• HUD’s Oversight of the Physical Conditions of PBRA and FHA-insured PBV Units Converted Under the RAD Program

• Carbon-Monoxide in HUD-Assisted Housing

• HUD’s Oversight of the Physical Conditions of Public Housing Agencies’ Developments

• HUD’s Processes for Addressing Cases of Children Residing in Public Housing with Elevated Blood Lead Levels
A Message from the Inspector General | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 5

Notably, after receiving our draft report, HUD closed all three of our open 

recommendations concerning contaminated sites. We commend HUD 

for its steadfast commitment towards addressing its top management 

challenges and look forward to continuing to work with the Department 

to address its remaining open recommendations. 

Our team continues to actively collaborate with the Pandemic Response 

Accountability Committee (PRAC). We recognize that it is our joint 

responsibility to help protect the billions of dollars in taxpayer funds 

appropriated by Congress to support families and communities 

throughout the country impacted by the pandemic. This semiannual 

period, our office collaborated with the PRAC to develop a Fraud Risk 

Inventory for the Tenant- and Project-Based Rental Assistance, HOME, 

and Operating Fund Programs’ CARES and ARP Act Funds. This report 

identified six overall, and three program-specific, fraud risk factors, and 

an inventory of 66 potential fraud schemes that HUD had not previously 

identified for funds appropriated by the Coronavirus Aid, Relief, and 

Economic Security (CARES) Act, and American Rescue Plan (ARP). These 

fraud schemes could be used to misappropriate emergency funds and 

divert them from the intended beneficiaries. We recommended that HUD 

use the identified fraud risk factors and inventory of potential fraud risk 

schemes to enhance its fraud risk assessments to increase HUD’s ability 

to safeguard its CARES and ARP Act funds from fraud and ensure funds 

are used as intended by Congress. 

 

Also, in partnership with state, local and Federal law enforcement partners, 

our Office of Investigation has continued to focus on holding accountable 

bad actors who seek to exploit HUD programs and its beneficiaries. For 

example, a joint investigation resulted in $10 million in restitution, of which 

over $6 million is payable to the Federal Housing Administration, and the 

conviction and incarceration of three real estate professionals for bank 

fraud involving falsified mortgage loan applications. In a separate HUD OIG 

Finally, in early October, we issued two more work products aimed at 

protecting HUD beneficiaries from lead hazards: A Management Alert

to notify HUD of significant gaps in its program that pose a risk to HUD 

beneficiaries, and an audit report regarding HUD’s Oversight of LeadBased Paint Hazard Remediation in Public Housing. Our goal through 

this robust oversight is to help HUD ensure that the laws and regulations 

that are in place to protect HUD beneficiaries are followed so that our 

vulnerable communities who rely on HUD assistance are afforded safe 

and decent living conditions. 

Recognizing the need to understand these and other challenges, during 

this reporting period, we have proactively engaged in listening sessions 

with industry groups, Congress, HUD, and other stakeholders. Our 

goal was to better understand HUD’s capacity and resource limitations, 

which impact its ability to efficiently administer its programs; barriers 

HUD stakeholders face in obtaining and administering HUD program 

funds, including disaster relief; and external factors that impact HUD’s 

goal of identifying a sufficient supply of decent and affordable housing. 

These listening sessions have been instrumental in helping to inform our 

upcoming FY 2023 Top Management Challenges report and strengthen 

our oversight capabilities around emerging issues facing HUD. 

In addition, we developed and issued our inaugural Priority Open 

Recommendations Report, which identifies approximately 25 priority 

open recommendations directly linked to seven key challenges 

identified in our FY 2022 Top Management Challenges Report , including 

eliminating hazards in HUD-assisted housing, administering disaster 

relief, ensuring access to and availability of affordable housing, and fraud 

risk management. We issued this product to assist HUD in directing its 

limited resources towards resolving open recommendations likely to 

have the highest impact on addressing its most significant challenges. We 

recognize the progress HUD has made in many of these priority areas. 
A Message fro m the Inspector General | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 6

investigation, a landlord and owner of over 90 Housing Choice Voucher 

Program properties and a management company entered into a $430,000 

False Claims Act settlement with the United States to resolve allegations 

that they charged HUD-assisted tenants higher rents for Housing Choice 

Voucher-funded units compared to non-HUD assisted units, in violation of 

their contract with HUD. 

HUD beneficiaries deserve to be protected from fraud, misconduct, and 

criminal activities that impact their health, safety, and access to affordable 

housing. My office is working with HUD to protect its program funds and 

beneficiaries from fraud and provide proactive Outreach towards fraud 

prevention, protection of recipients, and education about how to report 

fraud, waste and abuse, and health and safety violations through our 

Hotline. We also recognize the critical role that whistleblowers play in our 

ability to protect HUD programs, stakeholders, and beneficiaries and are 

seeking ways to enhance our ability to reach those in the best position to 

help us conduct the most impactful oversight. 

In closing, I want to thank our HUD OIG staff for their commitment, 

engagement, and influential oversight. It is my privilege to work alongside 

this dedicated group of professionals.

Inspector General

Rae Oliver Davis
Snapshot | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 7

• Ensuring access to affordable housing

• Administering disaster recovery

• Protecting the mortgage insurance fund 

• Managing information technology

• Managing human capital

• Fraud risk management 

OIG recognizes the progress HUD has made in many of these areas 

along with HUD’s steadfast commitment to improve its programs and 

operations. OIG will continue to monitor HUD’s progress and assist 

HUD’s leadership as they work to resolve and implement OIG’s priority 

recommendations. 

Permanent Authorization of the Community Development Block 

Grant – Disaster Recovery (CDBG-DR) program 

The Community Development Block Grant – Disaster Recovery (CDBGDR) grant funds are not provided under a program codified in the Code 

of Federal Regulations (CFR). Instead, HUD must issue Federal Register 

notices with additional, disaster-specific program requirements and 

waivers for each supplemental appropriation. With each newly issued 

Federal Register notice, grantees must navigate the various preceding 

notices, consider their communities’ pressing unmet needs, and develop 

a program that navigates both. These steps are expected to be completed 

during a time of great uncertainty, given that personnel, operations, and 

infrastructure may have been impacted following a disaster.

OIG and GAO have issued multiple oversight reports with 

recommendations to ensure HUD’s disaster recovery funding reaches 

vulnerable communities quickly. OIG has recommended that HUD codify 

Priority Open Recommendations

OIG issued its inaugural Priority Open Recommendations report to highlight 

those open recommendations that, if implemented, will have the greatest 

impact in helping HUD achieve its mission to create strong, sustainable, 

and inclusive communities and quality affordable homes for all. 

The priority open recommendations fall within several categories that 

OIG identified in its FY 2022 Top Management Challenges , highlighting 

key outstanding recommendations in the following areas: 

• Eliminating hazards in HUD-assisted housing

SNAPSHOT

SpotlightIn accordance with our 2022-2026 Strategic Plan, OIG seeks to 

influence positive outcomes for HUD programs and operations through 

timely and relevant oversight, and optimize HUD’s program success 

by combating fraud, waste, abuse, and mismanagement. During this 

semiannual reporting period we conducted oversight work intended to 

protect HUD’s most vulnerable beneficiaries from lead hazards, such as 

Risk Indicators of Lead-Based Paint Hazards in Public Housing Agencies, 

and protect HUD’s emergency funding from fraud, such as Fraud Risk 

Inventory for the Tenant- and Project-Based Rental Assistance, HOME, 

and Operating Fund Programs’ CARES and ARP Act Funds. Further, to 

assist HUD with addressing its FY 2022 Top Management Challenges, 

during this semiannual reporting period, OIG issued a Priority Open 

Recommendations Report highlighting the most significant open 

recommendations, which, if implemented, will have the greatest impact 

on helping HUD achieve its mission to create strong, sustainable, 

inclusive communities and quality affordable homes for all.
Snapshot | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 8

Risk Indicators of Lead-Based Paint Hazards in Public Housing 

Agencies

OIG conducted an evaluation of HUD’s oversight and monitoring of leadbased paint hazards in public housing due to the significant challenges 

HUD faces in controlling and addressing lead-related hazards. This year, 

OIG identified “eliminating hazards in HUD-assisted housing” as a HUD 

top management challenge. Using the best available data collected 

from both HUD and external sources, OIG identified nine indicators of 

potential risk for lead-based paint hazards in public housing, Based on 

the analysis of these nine risk indicators, OIG identified five HUD regions 

and six States within those regions that have the greatest potential risk 

of having public housing agencies (PHA) with lead-based paint hazards. 

The evaluation found that HUD’s Office of Public and Indian Housing 

(PIH) and Office of Lead Hazard Control and Healthy Homes (OLHCHH) 

collaborate on lead hazard work, with PIH responsible for oversight 

of PHA compliance and OLHCHH is responsible for writing policy and 

providing guidance. As of March 2022, HUD’s Real Estate Assessment 

Center, an office within PIH, was establishing the Environmental Shared 

Services office (ESS) to improve its risk assessment and inspection 

capabilities for health and safety hazards, including lead-based paint 

hazards. ESS will provide insight into potential and existing environmental 

hazards, compliance issues, and data gaps to improve HUD’s decision 

making, resource allocation, and hazard management strategies. As part 

of its strategy, ESS will rank risks related to four environmental hazards—

carbon monoxide, mold, lead, and radon. ESS identified five indicators for 

its lead risk ranking. The report did not include any recommendations; 

however, OIG concluded that the results of the analysis may be helpful 

to HUD, as the report identifies risk indicators, which could prove useful 

as ESS continues to identify risk factors and develop its risk-ranking 

approach. 

the CDBG-DR program through regulations to simplify and standardize 

the process, and more recently, that HUD pursue codification of the 

CDBG-DR program through regulations or, if necessary, legislative action. 

HUD has maintained that it does not have the statutory authority 

to codify the CDBG-DR program through the regulatory process. 

However, HUD has taken consistent, meaningful steps to address OIG’s 

recommendations to pursue codification through legislative action. 

Secretary Fudge and former Secretary Carson have both expressed public 

support for codification in testimony before Committees of Congress. 

HUD’s Fiscal Year 2023 Congressional Budget Justification expressly 

supports Congressional authorization of the CDBG-DR program, noting:

“Permanent authorization of CDBG-DR would improve the 

transparency and predictability of CDBG-DR funds made available 

to impacted communities. Permanent authorization would also 

require HUD to establish consistent regulatory requirements 

for CDBG-DR across all future disasters, eliminating the current 

practice of establishing new requirements in response to each 

supplemental appropriation of CDBG-DR funds.”

HUD has maintained that it needs statutory authority to codify the CDBGDR program, and is seeking that authority from Congress. Bipartisan, 

bicameral Congressional support for codification has resulted in bills such 

as the House and Senate versions of The Reforming Disaster Recovery 

Act, which are responsive to OIG’s recommendations. 

Legislation codifying the CDBG-DR program would streamline, reform, 

and inject greater fiscal responsibility into the program, while also 

mitigating funding lags and duplicative requirements. OIG believes 

Congressional efforts to codify the CDBG-DR program will help HUD meet 

its mission of timely serving communities struck by natural disasters with 

critical housing assistance. 
Snapshot | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 9

release, and ordered to pay jointly and severally more than $10 million 

in restitution, of which more than $6 million is payable to the Federal 

Housing Administration (FHA). For more than 3 years, the conspirators 

recruited buyers to purchase multiunit residential properties owned 

by a business entity controlled by one of the subjects and used false 

information about the buyers’ assets and income to support fraudulent 

mortgage loan applications to a mortgage company. They falsified 

the buyers’ loan applications by falsely increasing assets. They then 

transferred cash from the business entity’s and others’ accounts to the 

buyers’ bank accounts and falsified documents to hide the transfers. 

After the loans were approved, the conspirators returned the funds to 

the business entity. When the transactions were closed, the conspirators 

defrauded the mortgage company by hiding that the business entity and 

others, not the buyers, had provided the cash to close the transactions. 

Ultimately, the buyers were not able to repay the loans, which resulted in 

losses to several financial institutions and FHA. 

Housing Choice Voucher Program Landlord Agrees to Pay 

$430,000 to Settle False Claims Act Allegations of Collecting 

Excess Rent

A landlord and owner of more than 90 Housing Choice Voucher 

(HCV) Program properties and a Management company entered into 

a $430,000 settlement agreement with the United States to resolve 

allegations that they violated the False Claims Act when they charged 

tenants higher rents for HCV Program-funded units compared to nonHUD-assisted units in violation of their contract with HUD. 

Fraud Risk Inventory for the Tenant- and Project-Based Rental 

Assistance, HOME, and Operating Fund Programs’ CARES and 

ARP Act Funds

In coordination with the Pandemic Response Accountability Committee, 

OIG conducted an audit to identify potential fraud schemes that could 

affect HUD’s pandemic funds. OIG reviewed the funds appropriated by 

the Coronavirus Aid, Relief, and Economic Security (CARES) Act and the 

American Rescue Plan (ARP) Act for the Tenant-Based Rental Assistance 

(TBRA), Project-Based Rental Assistance (PBRA), HOME Investment 

Partnerships, and Public Housing Operating Fund programs to identify 

the fraud risks and potential fraud schemes that these programs face 

when delivering services to the public. OIG’s objective was to develop 

an inventory of fraud risks that HUD had not previously identified for 

the funds appropriated by the CARES and ARP Acts for the TBRA, PBRA, 

HOME, and Operating Fund programs. OIG identified six overall and 

three program-specific fraud risk factors that increase the chance of 

fraud occurring based on an individual’s increased incentive, opportunity, 

and likelihood to commit fraud. OIG used these fraud risk factors, along 

with the results of brainstorming sessions; interviews; and reviews of 

audit reports, investigations, and press releases from OIG and other 

agencies, to develop an inventory of 66 potential fraud schemes that 

HUD had not previously identified. OIG recommended that HUD use the 

identified fraud risk factors and inventory of potential fraud risk schemes 

to enhance its fraud risk assessments, which will increase HUD’s ability 

to safeguard its CARES and ARP Act funds from fraud and ensure that the 

funds are used for their intended beneficiaries. 

Real Estate Professionals Sentenced to More Than 14 Years 

Incarceration and More Than $10 Million in Restitution 

Three real estate professionals were collectively sentenced in U.S. District 

Court to more than 14 years’ incarceration and 15 years supervised 
Snapshot | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 10

or at risk of being improperly managed. These sites include manufacturing 

facilities, processing plants, landfills, and mining sites. A February 2021 

OIG report, Contaminated Sites Pose Potential Health Risks to Residents at 

HUD-Funded Properties, recommended that HUD develop and implement 

strategies to research properties and to determine whether the proximity 

to site contamination should be considered in future environmental 

reviews and then monitor those reviews. 

OIG is pleased to share that during this semiannual reporting period, while 

circulating the draft of its priority open recommendations report, HUD’s 

Office of Public and Indian Housing and Office of Multifamily took action to 

close three of OIG’s recommendations: 

Recommendation 1:

Develop and implement a strategy to review Multifamily-funded properties 

with potential contamination to determine whether site contamination 

should be considered in future environmental reviews. 

Recommendation 3:

Develop and implement a strategy to review PIH-funded properties with 

potential contamination to determine whether site contamination should 

be considered in future environmental reviews. 

Recommendation 4:

Monitor environmental reviews of PIH-funded properties with potential 

contamination

Both program offices collaborated with the U.S. Environmental Protection 

Agency to improve the accuracy of the contaminated sites proximity 

analysis, allowing them to better identify which HUD-funded properties 

Recommendations Related to Contaminated Sites 

During this semiannual reporting period, OIG issued a Priority Open 

Recommendations Report to highlight several open recommendations 

that, if implemented, will have the greatest impact on helping HUD achieve 

its mission to create strong, sustainable, inclusive communities and quality 

affordable homes for all. The recommendations were linked to OIG’s 

FY 2022 Management Challenges Report, which identified several key 

challenges HUD faces with eliminating hazards in HUD-Assisted Housing. 

Previously, OIG expressed its concerns around public housing properties 

located near contaminated sites, including superfund sites, which are areas 

contaminated by hazardous waste that was dumped, left out in the open, 

SNAPSHOT

Making an ImpactThe U.S. Department of Housing and Urban Development (HUD), 

Office of Inspector General’s (OIG) oversight work results in 

recommendations for improvements in HUD’s programs and 

operations. This section highlights the connections between OIG’s 

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

and beneficiaries. While there are many factors that may cause 

programmatic change, OIG’s reviews and other work often play a 

significant role. This section draws attention to recommendations that 

have been closed during this semiannual reporting period which made 

a positive impact on HUD’s mission and operations, as well as OIG’s 

proactive efforts to educate its stakeholders and help prevent and 

detect fraud, waste, and abuse.
Snapshot | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 11

accuracy and truthfulness under penalty of perjury, as well as warnings, 

play an important role in promoting accountability and enabling effective 

prosecution of those who commit fraud. 

Based on the above, OIG recommended that HUD include the following 

language in multiple policies that we reviewed in this semiannual period: 

“I/We, the undersigned, certify under penalty of perjury that the 

information provided above is true and correct. 

WARNING: Anyone who knowingly submits a false claim or makes 

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

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

administrative penalties. (18 U.S.C. §§ 287, 1001, 1010, 1012; 31 

U.S.C. §3729, 3802).” 

HUD has been receptive to these recommendations and has accepted 

and incorporated OIG’s recommended warning and certification language 

in several of its policies as set forth in this report, under “Legislation, 

Regulations, and other Directives.” 

Fraud Bulletins

As highlighted OIG’s 2022-2026 Strategic Plan, a key goal for OIG is to 

optimize HUD’s program success by combatting fraud, waste, abuse, and 

mismanagement with the specific objectives to improve and expand 

OIG’s outreach and keep the public informed about red flags and 

common fraud schemes. 

OIG develops fraud bulletins to protect HUD beneficiaries and the public 

from criminal schemes that misuse HUD’s name and programs to victimize 

HUD’s stakeholders, to encourage the public to report fraud, and to share 

information about the OIG’s hotline and other available resources. 

had the greatest potential for exposure to site contaminants. Their efforts 

resulted in the identification of 40 superfund sites that had HUD-funded 

properties within the site boundaries and did not have human exposure 

under control. Since that point, HUD has facilitated getting EPA access 

to those HUD-funded properties to collect samples and, if determined 

necessary, will collaborate with EPA to facilitate cleanup. 

Recommendations Related to Hiring

During the month of July, HUD OIG closed three recommendations 

from the August 2021 Report, Opportunities Exist To Improve the U.S. 

Department of Housing and Urban Development’s Hiring Process, 

that pertained to the top management challenge of Human Capital 

Management. The recommendations closed included, standardize 

position descriptions and job Analyses for mission-critical occupations, 

High-Risk Occupations, and Positions with High-Volume Staffing Needs; 

Develop and Share Best practices with HUD’s program offices on how 

hiring managers can execute hiring process responsibilities to meet 

timeliness goals; and develop and implement regular training for process 

owners on the hiring process. 

Recommendations to HUD to Include Warnings and Certifications

Pursuant to section 4(a) of the Inspector General Act, as amended, 5 

U.S.C. App., OIG is responsible for providing policy direction for HUD’s 

programs and operations, recommending policies to promote economy 

and efficiency in the administration of, and preventing and detecting 

fraud and abuse in HUD’s programs and operations, to include the 

identification and prosecution of participants in such fraud or abuse. 

HUD OIG regularly makes recommendations to HUD to include standard 

warnings and certifications in its policies and forms to protect HUD’s 

programs from fraud. Clear warnings on HUD documents put fraudsters 

on notice that there can be serious criminal, civil, and administrative 

consequences to their actions to help discourage fraud. Certifications of 
Snapshot | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 12

This fraud bulletin shares red flags and provides multiple resources for 

individuals who are facing potential foreclosure or who feel that they 

have been the victim of a mortgage loan modification scheme. 

HUD OIG Outreach

Over the past several years, OIG has successfully partnered with HUD, 

the Department of Justice, and other entities to provide anti-fraud 

training to grantees, subrecipients, and contractors, primarily for the 

Community Development Block Grant – Disaster Recovery program. 

This ongoing training identifies potential fraud schemes; provides 

resources for preventing, detecting, and reporting fraud; and outlines the 

consequences for committing fraud. 

During this semiannual reporting period, OIG’s Disaster Grantee Fraud 

Training became a National Association of State Boards of Accountancy 

certified and sponsored training. Further, HUD OIG, the Department of 

Justice, and other entities offered Disaster Fraud training to the Virgin 

Island Housing Finance Authority, Government of Puerto Rico Office of 

Inspector General, and the State of Alaska.

During this semiannual reporting period, OIG issued the following two 

fraud bulletins: 

Section 8 Housing Voucher Fraud Scheme Bulletin

This bulletin advises the public about fraud schemes involving HUD’s 

Section 8 Voucher program, which is the Federal Government’s major 

program for assisting very low-income families, the elderly, and the 

disabled afford decent, safe, and sanitary housing in the private market. 

Section 8 vouchers are administered locally by public housing agencies 

(PHAs) who receive Federal funding from HUD to administer the voucher 

program. 

This fraud bulletin shares red flags for Section 8 fraud schemes in 

which fraudsters falsely claim to be owners of legitimate participating 

properties, such as “property owners” who want to communicate only by 

personal email, require an application fee, or demand payment through 

third parties, such as a cash app. 

Mortgage Loan Modification Fraud Bulletin 

This bulletin provides information about scammers who falsely claim 

to be from a mortgagee’s mortgage company and reach out to offer 

mortgage loan modifications, which are meant to take money by making 

false promises of saving victims from foreclosure. 

Mortgage loan modification scammers target the most vulnerable and 

struggling homeowners, which are often senior citizens. The fraudsters 

may offer lower mortgage rates using phony loan modifications, and 

sometimes threaten foreclosure if the borrower does not agree to the 

loan modification. Victims then send their mortgage payments to the 

fraudsters, believing they are paying their actual mortgage companies. In 

a recent related investigation, over 1,000 victims lost approximately $3.8 

million to this scheme.
Housing | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 13

The Office of Housing plays a vital role for the Nation’s home buyers, homeowners, 

renters, and communities through its nationally administered programs. It includes the 

Offices of Single Family Housing and Multifamily Housing Programs and the Federal 

Housing Administration (FHA), the largest mortgage insurer in the world. FHA singlefamily programs provide mortgage insurance to mortgage lenders that, in turn, provide 

financing that enables individuals and families to purchase, rehabilitate, or construct 

homes. The Office of Multifamily Housing Programs’ mortgage insurance programs 

facilitate the construction, substantial rehabilitation, purchase, and refinancing of 

multifamily properties. The office also administers subsidized housing programs that 

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

as well as the preservation of assisted affordable housing.

HOUSING

INVESTIGATION

administrativecivil actionsconvictions-pleaspretrial diversionsfinancial recoveries

9 24 $16,738,137
Housing | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 14

of subject 1’s companies sold a property. The U.S. Department of Housing 

and Urban Development (HUD OIG), FHFA OIG, and the Federal Bureau of 

Investigation conducted this investigation. 

(New Jersey)

Money Mules Ordered To Pay More Than $1.2 Million in 

Restitution

Money mules John Fuss, Jeremy Christopher, Tracey Brookshier, Mary 

Booth, Ronnie Booth, and Perry Crenshaw were collectively sentenced 

in U.S. District Court to 64 months incarceration, 6 years supervised 

release, and 13 years probation and ordered to pay more than $1.2 

million in restitution to various victims. Ronnie Booth, Mary Booth, and 

Brookshier were sentenced in connection with their earlier guilty pleas to 

aiding and abetting the operation of an unlicensed money-transmitting 

business. Fuss, Jones, and Crenshaw were sentenced in connection with 

their earlier guilty pleas to conspiracy to commit money laundering. For 

more than 7 years, the conspirators participated in a money-laundering 

operation involving multiple fraud schemes in which victims were 

instructed to send funds to the conspirators through intimidation or 

the promise of receiving a service or product in return. Victims of the 

mortgage modification scheme included FHA-insured borrowers, who 

were solicited by individuals purporting to be with the victims’ mortgage 

companies and falsely promised lower interest rates and monthly 

mortgage payments. More than 1,000 victims were impacted by the 

various schemes. HUD OIG, The U.S. Secret Service, Internal Revenue 

Service Criminal Investigation, and U.S. Department of the Treasury’s 

Inspector General for Tax Administration conducted this investigation. 

(Tyler, TX)

Office of Investigation

Real Estate Professionals Sentenced to More Than 14 Years 

Incarceration and More Than $10 Million in Restitution 

Three real estate professionals were collectively sentenced in U.S. District 

Court to more than 14 years incarceration and 15 years supervised 

release and ordered to pay jointly and severally more than $10 million 

in restitution, of which more than $6 million is payable to FHA. Subject 1 

was ordered to pay more than $10 million in restitution, of which more 

than $981,000 was to be paid jointly and severally with subjects 2 and 

3. Subject 1 was sentenced in connection with an earlier guilty plea to 

bank fraud and securities fraud, and subjects 2 and 3 were sentenced 

in connection with their earlier guilty pleas to bank fraud. For more 

than 3 years, the conspirators recruited buyers to purchase multiunit 

residential properties owned by a business entity controlled by subject 

1. The conspirators used false information about the buyers’ assets and 

income to support fraudulent mortgage loan applications to a mortgage 

company. They falsified the buyers’ loan applications by falsely increasing 

assets. They then transferred cash from the business entity’s and others’ 

accounts to the buyers’ bank accounts and falsified documents to hide 

the transfers. After the loans were approved, the conspirators returned 

the funds to the business entity. When the transactions were closed, 

the conspirators defrauded the mortgage company by hiding that the 

business entity and others, not the buyers, had provided the cash to 

close the transactions. Ultimately, the buyers were not able to repay 

the loans, which resulted in losses to several financial institutions and 

FHA. Additionally, for nearly 1 year, subject 1 deceived an individual into 

investing in subject 1’s real estate companies. Subject 1 told the victim 

that subject 1 would invest money in companies that subject 1 owned 

and that were in the business of buying foreclosed-on homes, renovating 

the homes, and then reselling the properties. Subject 1 falsely promised 

the victim a 12 percent return on investment and $10,000 each time one 
Housing | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 15

Conspiracy To Undervalue Broker Price Opinions Results in 24 

Months Incarceration

Stacy Hall, a real estate agent, and David Litman, a business owner and 

real estate investor, were collectively sentenced in U.S. District Court 

in connection with their earlier guilty pleas to conspiracy to commit 

bank fraud and bank fraud. Hall and Litman were collectively sentenced 

to 24 months incarceration and 36 months supervised release, and 

Litman was ordered to pay $279,900 in restitution to various financial 

institutions. For nearly 2 years, Hall and Litman caused false broker price 

opinions undervaluing residential properties to be submitted to financial 

institutions holding the mortgages of the properties, including FHAinsured mortgages, which Litman intended to purchase via a short sale. 

Litman submitted additional false documents to the financial institutions 

to induce them to approve requested short sales, including falsified 

listing agreements and proof-of-funds letters. The financial institutions, 

relying on the false broker price options, false real estate commission 

expenses, false listing agreements, and other false documentation, 

approved short sales of properties to Litman. HUD OIG, the Federal 

Bureau of Investigation, and the U.S. Postal Inspection Service conducted 

this investigation.

(Champaign, IL)

Direct Endorsement Lender Agrees To Pay More Than $1 Million 

To Resolve False Claims Act Violations

American Financial Network, an FHA direct endorsement lender, 

entered into a settlement agreement with the United States to resolve 

allegations that the company approved mortgages that did not meet FHA 

requirements. American Financial Network agreed to pay more than $1 

million, of which $518,572 is payable to FHA. For nearly 8 years, American 

Financial Network knowingly failed to perform required quality control 

reviews and approved loans that did not qualify for FHA insurance. HUD 

OIG conducted this investigation. 

(Spokane, WA)
Public and Indian Housing | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 16

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

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

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

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

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

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

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

PUBLIC AND INDIAN 

HOUSING

AUDIT INVESTIGATION

administrativecivil actions

convictions-pleaspretrial diversions

financial recoveries

11

16

$2,051,535

report

recommended funds 

put to better use

questioned costs

$2,598,312

1

$697,912
Public and Indian Housing | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 17

Office of Investigation

Former Mayor and Public Officials Collectively Sentenced to 

More Than 7 Years Incarceration

Jose Salinas, the former mayor of the City of La Joya and former 

president of an economic development corporation; Frances Salinas 

De Leon, the daughter of Salinas and former interim executive director 

of a local PHA; Ramiro Alaniz, a former maintenance director of a local 

PHA; and Mike Alaniz, a former city administrator, were collectively 

sentenced in U.S. District Court to more than 7 years incarceration and 

11 years supervised release and ordered to pay more than $326,000 in 

restitution to the City, PHA, and economic development corporation. 

Sylvia Valdez, a former PHA board member, was sentenced in Hidalgo 

County State Court in connection with her earlier guilty plea to 

improper influence. Valdez was sentenced to 24 months community 

service and ordered to pay $22,000 in restitution to the City. For 

more than 1 year, Salinas, De Leon, and Ramiro Alaniz orchestrated 

a scheme to award a municipal contract worth $22,000 to Valdez. 

Valdez then awarded a contract for De Leon to be improperly paid for 

working as the interim executive director of the PHA. Due to conflictof-interest rules, De Leon could not receive a salary because of her 

familial relationship with Salinas. Additionally, De Leon and Ramiro 

Alaniz conspired to create a nonprofit, for which Ramiro Alaniz served 

as a general contractor for the sole purpose of providing monetary 

kickbacks to De Leon with non-HUD funds obtained from the economic 

development corporation. In 2018, Mike Alaniz overinflated the 

value of a tract of land he owned and then used his position with the 

City to cause the City to purchase the land using HUD Community 

Development Block Grant funds. Salinas, De Leon, and Ramiro Alaniz 

were sentenced in connection with their earlier guilty pleas to wire 

fraud, and Mike Alaniz was sentenced in connection with his earlier 

guilty plea to theft from a program receiving Federal funds. HUD OIG, 

Office of Audit

Long Branch Housing Authority, Long Branch, NJ, Did Not 

Properly Handle Income and Expenses Related to Agreements 

With Other Housing Agencies

The Office of Inspector General (OIG) audited the Long Branch Housing 

Authority to determine whether Long Branch properly handled income 

and expenses associated with its agreements with the Asbury Park and 

Red Bank Housing Authorities in accordance with requirements. Long 

Branch did not properly handle income and expenses related to services 

provided under agreements with two other PHAs. Additionally, it did 

not properly allocate and support base payroll expenses and maintain 

adequate documentation to substantiate incentive payments. As a result, 

HUD did not have assurance that $1.5 million in incentives paid from 

agreement income was eligible and reasonable, and nearly $700,000 

in unspent agreement income that had not been used continued to 

improperly reside in a Long Branch account. OIG recommended that HUD 

require Long Branch to (1) provide support to show the reasonableness 

and eligibility of the $1.5 million in employee incentives paid from 

agreement income or reimburse its program for any amount it cannot 

support, (2) provide support for a reasonable estimate of employee time 

used to perform services for the two agencies and reimburse its program 

for any program funds improperly used for those expenses, and (3) 

implement adequate controls to ensure that it properly classifies income 

received under any future agreements or activities and to ensure future 

compliance with applicable cost principle requirements. Additionally, 

OIG recommended that HUD make a determination regarding nearly 

$700,000 in outstanding agreement income, including whether those 

unspent funds should be returned to the PHAs. 

(Long Branch, NJ, Audit Report: 2022-NY-1003)
Public and Indian Housing | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 18

the U.S. Department of Agriculture OIG, and the Federal Bureau of 

Investigation conducted this investigation. 

(La Joya, TX)

Housing Choice Voucher Program Landlord Agrees To Pay HUD 

and the U.S. Department of Justice $430,000 To Resolve False 

Claims Act Violations

Christopher Lukacs, a landlord and owner of more than 90 Housing 

Choice Voucher (HCV) Program properties, and Goodfish Enterprises and 

Reliant Property Management, companies controlled by Lukacs, entered 

into a settlement agreement with the United States to resolve allegations 

that they violated the False Claims Act when they charged tenants higher 

rents for HCV Program-funded units compared to non-HUD-assisted units 

in violation of their contract with HUD. Lukacs agreed to pay $430,000, 

of which $215,000 is payable to HUD and $215,000 in penalties and 

damages will be paid to the U.S. Department of Justice. HUD OIG 

conducted this investigation. 

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

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

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

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

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

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

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

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

allocated $94.8 billion in CDBG-DR and CDBG Mitigation grants to help cities, counties, and States recover from 

presidentially declared disasters. Of the $94.8 billion in disaster allocations nationwide, nearly $87.4 billion has 

been obligated, and more than $50.09 billion had been disbursed as of the end of the period.2

2 In prior SARs the allocated amount of funds was presented as $95.5 billion however, HUD’s Disaster Recovery and Special Issues Division recently underwent financial updates in the 

Disaster Recovery Grant Reporting system, during which HUD discovered approximately $730 million in 2020 disaster numbers were overstated between January and April 2022. The 

current balance of $94.8 billion reflects the reconciliation.

COMMUNITY PLANNING 

AND DEVELOPMENT

AUDIT INVESTIGATION

administrativecivil actions

convictions-pleaspretrial diversions

financial recoveries

0

7

$883,047

reports

recommended funds 

put to better use

questioned costs

$2,588,362

4

$0
Community Planning and Development | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 20

Office of Audit

Emergency Solutions Grants CARES Act Implementation 

Challenges

The Office of Inspector General (OIG) audited the HUD Emergency 

Solutions Grants (ESG) Coronavirus Aid, Relief, and Economic 

Security Act (CARES Act) (ESG-CV) program. The audit objective 

was to determine what challenges ESG-CV grant recipients faced in 

implementing the program and using grant funds. OIG used a survey 

questionnaire to gather feedback and insight directly from the 362 

recipients of ESG-CV grants. The survey questionnaire found that 

ESG-CV recipients faced challenges in implementing the program and 

using grant funds. The grant recipients needed an extension beyond 

the spending deadline of September 30, 2022, to use a majority or 

all of their ESG-CV funds. HUD later extended the spending deadline 

to help address this issue. The top challenges identified by the grant 

recipients included staff capacity and coordinating with other sources 

of pandemic-related funding. In addition, most of the grant recipients 

that provided ESG-CV funds to subrecipients stated that the pandemic 

impacted their ability to effectively monitor their ESG-CV subrecipients. 

As a result, while HUD has taken action to help address the spending 

deadline concerns, the grantees’ challenges with capacity, multiple 

funding sources, and monitoring their subgrantees may increase the 

risk of misuse of the funds. OIG recommended that HUD consider 

including grant recipients’ challenges with capacity, multiple sources of 

funding, and subgrantee monitoring as part of CPD’s risk assessments.

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

The State of North Carolina Generally Had Capacity and Mostly 

Followed Disbursement Requirements, but Its Procurement 

Process Needs Improvement

OIG audited the State of North Carolina’s CDBG-DR funds as part of OIG’s 

commitment to helping HUD address its top management challenges 

and to support HUD’s strategic objective to support effectiveness and 

accountability in long-term disaster recovery. The audit objective was 

to determine whether the State had sufficient capacity to administer 

its CDBG-DR funds and followed disbursement and procurement 

requirements related to those funds. The State generally had capacity. 

It had staffing capacity, maintained an internal auditor position, and had 

policies in place for administering CDBG-DR funds. The State also mostly 

followed disbursement requirements. However, the State’s procurement 

process needs improvement. As a result, the State could not provide 

reasonable assurance to HUD that more than $2.5 million of $5.4 million 

in CDBG-DR funds reviewed was spent properly. OIG recommended 

that HUD require the State to (1) provide adequate documentation 

to support that more than $2.5 million in CDBG-DR funds was spent 

for necessary and reasonable costs or repay the funds, (2) update 

its procurement policy, and (3) provide training to its staff to ensure 

that it understands and follows requirements to maintain adequate 

documentation to support program disbursements that are eligible 

and reasonable and procurement requirements, including completing 

independent cost estimates and cost analyses. 

(The State of North Carolina, Audit Report: 2022-AT-1002)
Community Planning and Development | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 21

and three program-specific fraud risk factors that increase the chance 

of fraud occurring by increasing an individual’s incentive, opportunity, 

and likelihood for committing fraud. OIG used these fraud risk factors, 

along with the results of brainstorming sessions; interviews; and reviews 

of audit reports, investigations, and press releases from OIG and other 

agencies, to develop an inventory of 66 potential fraud schemes that 

HUD had not previously identified. OIG recommended that HUD use the 

identified fraud risk factors and inventory of potential fraud risk schemes 

to enhance its fraud risk assessments, which will increase HUD’s ability 

to safeguard its CARES and ARP Act funds from fraud and ensure that the 

funds are used for their intended beneficiaries. 

(Agencywide, Audit Report: 2022-FO-0007)

Office of Investigation

Conspirators Sentenced for Scheme To Defraud Local Housing 

Programs

Leopoldo Bitte, Jr., housing specialist, and Realene Rodrigues, Gregory 

Lau, and Kalani Lopez, associates of Bitte, were collectively sentenced 

in U.S. District Court to 51 months and 1 day incarceration, 8 years 

supervised release, and 3 years probation. For more than 2 years, Bitte 

defrauded his employer, a nonprofit corporation funded in part through 

HUD’s HOME Investment Partnerships and ESG programs, by falsely 

representing that Rodrigues, Lau, and Lopez were landlords eligible 

to receive funds dedicated to the nonprofit’s Homeless Prevention 

and Rapid Rehousing and Clean and Sober programs. The nonprofit 

is a human services organization that provides financial assistance 

to individuals and families at risk of homelessness. Bitte created 

fake rental agreements by using the names and personal identifying 

information of other individuals, who had applied legitimately for 

services with the nonprofit, and falsely identified Rodrigues, Lau, and 

Community Development Block Grant CARES Act 

Implementation Challenges

OIG audited HUD’s CDBG CARES Act program. OIG’s audit objective was 

to determine what challenges grantees faced in using program funds 

for activities that prepare for, prevent, or respond to the coronavirus 

and its impact. OIG used a survey questionnaire to gather feedback and 

insight directly from 1,047 program grantees. Grantees responding to 

the survey questionnaire reported facing challenges in (1) managing 

multiple funding sources, (2) spending program funds within required 

timeframes, and (3) meeting program objectives and requirements. 

Grantees attributed these conditions to capacity issues, HUD’s program 

rules and regulations, and other competing CARES Act application and 

expenditure deadlines. OIG recommended that HUD consider looking 

into (1) extending the spending deadline and (2) streamlining program 

requirements. 

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

Fraud Risk Inventory for the Tenant- and Project-Based Rental 

Assistance, HOME, and Operating Fund Programs’ CARES and 

ARP Act Funds

In coordination with the Pandemic Response Accountability Committee, 

OIG conducted an audit to identify potential fraud schemes that could 

affect HUD’s pandemic funds. OIG reviewed the funds appropriated by 

the CARES Act and the American Rescue Plan (ARP) Act for the TenantBased Rental Assistance (TBRA), Project-Based Rental Assistance (PBRA), 

HOME Investment Partnerships, and Public Housing Operating Fund 

programs to identify the fraud risks and potential fraud schemes that 

they face while delivering services to the public. OIG’s objective was to 

develop an inventory of fraud risks that HUD had not previously identified 

for the funds appropriated by the CARES and ARP Acts for the TBRA, 

PBRA, HOME, and Operating Fund programs. OIG identified six overall 
Community Planning and Development | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 22

Landlord Sentenced in Disaster-Related Mortgage Fraud Scheme 

Theodore Kurz, a CDBG-DR grant recipient, was sentenced in U.S. 

District Court in connection with his earlier guilty plea to making 

false statements to a lending institution. Kurz was sentenced to 1 day 

incarceration and 5 years probation and ordered to pay $751,900 in 

restitution, of which $423,000 will be paid to a State authority and 

$328,900 will be paid to a lending institution. In February 2016, Kurz 

received multiple grants in the form of forgivable loans through a State 

entity to repair eight damaged rental housing properties for lowincome tenants. The forgivable loan is a nonrecourse loan, secured by 

a mortgage on the property held by the State. Kurz forged mortgage 

cancellations, which he filed with the local clerk of court office to falsely 

make it appear that the loans had been satisfied. Kurz then obtained 

mortgages through a different lender, falsely claiming that there were 

no outstanding mortgages or liens on the properties, in an effort to 

obtain additional funds through conventional loans. The State used 

HUD CDBG-DR funds to administer its rental property repair program 

to assist small-scale landlords whose rental properties were damaged 

by Hurricanes Katrina and Rita. HUD OIG and the Federal Bureau of 

Investigation conducted this investigation. 

(New Orleans, LA)

Lopez as the landlords. Bitte used these fake rental agreements and 

other documentation to cause the nonprofit to generate 34 checks 

payable to Rodrigues, Lau, and Lopez, who then cashed the checks and 

split the proceeds with Bitte. Bitte was sentenced in connection with his 

earlier guilty plea to conspiracy to commit wire fraud and aggravated 

identity theft and was ordered to pay jointly and severally with 

Rodrigues, Lau, and Lopez $101,053 in restitution to the nonprofit and 

an insurance company. Rodrigues, Lau, and Lopez previously pleaded 

guilty to conspiracy to commit wire fraud, and Rodrigues also pleaded 

guilty to wire fraud. HUD OIG conducted this investigation. 

(Honolulu, HI)
Additional Reports | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 23

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

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

ADDITIONAL REPORTS

Priority Open Recommendations

OIG issued its inaugural Priority Open Recommendations report to highlight 

those open recommendations that, if implemented, will have the greatest 

impact on helping HUD achieve its mission to create strong, sustainable, 

inclusive communities and quality affordable homes for all. These priority 

open recommendations fall within several areas identified in OIG’s FY 2022 

Top Management Challenges. 

OIG recognizes the forward progress HUD has made in many of these areas 

and HUD’s steadfast commitment to improve its programs and operations. 

OIG will continue to monitor HUD’s progress and provide assistance to 

HUD’s leadership as they work towards resolution and implementation of 

OIG’s priority recommendations. 

Office of Audit

HUD Compliance With the Payment Integrity Information Act of 

2019

OIG audited HUD’s fiscal year (FY) 2021 compliance with the Payment 

Integrity Information Act of 2019 (PIIA) and implementation of Office of 

Management and Budget (OMB) guidance. PIIA was enacted to prevent 

and reduce improper payments and require each agency’s inspector 

general to perform an annual review of the agency’s compliance with 

PIIA. OIG’s objectives were to assess (1) whether HUD had met all 

requirements of PIIA and OMB Circular A-123, Appendix C-Requirements 

for Payment Integrity Improvement, and (2) HUD’s efforts to prevent 

and reduce improper and unknown payments. OIG found that HUD was 

noncompliant with PIIA in FY 2021. While HUD made some progress 

in FY 2021, significant efforts are needed to bring the Office of Public 

and Indian Housing’s Tenant-Based Rental Assistance (PIH-TBRA) and 

Office of Multifamily Housing Programs’ Rental Subsidy programs into 

compliance. For HUD’s noncompliant programs, OIG recommended 

that HUD (1) develop and implement a sampling methodology that 

allows for the timely testing of the full payment cycle and (2) consult 

with OMB on the appropriate reporting for untested portions of the 

payment cycle. OIG recommended that HUD develop and implement a 

plan that ensures adequate internal controls over the PIH-TBRA program 

to detect and prevent improper payments, which can be implemented 

in a virtual environment. OIG also recommended that HUD work with 

grantees to better identify the risks of improper and unknown payments 

throughout the payment cycle in its Office of Community Planning and 

Development programs and ensure that its risk assessments and improper 

and unknown payment estimates fully consider these risks. Finally, OIG 

recommended that HUD coordinate with OMB to ensure that its data on 

PaymentAccuracy.gov are accurate. 

(Agencywide, Audit Report: 2022-FO-0005)
Additional Reports | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 24

public and private sector. OIG’s audit objective was to determine whether 

HUD met the 13 responsibilities stated in the Act regarding its collection, 

production, acquisition, maintenance, distribution, use, and preservation 

of geospatial data. The Act also generally requires covered agencies to 

provide access to geospatial data and metadata to the public and enhance 

reporting to Congress. HUD met 11 of the 13 responsibilities stated in the 

Act but did not meet 2 of the responsibilities. HUD’s lapse in its contract 

for services to manage its Geocode Services Center created challenges 

in meeting the responsibilities stated in the Act. As a result, HUD risks 

not having accurate and open access to geospatial data available for use 

by Federal, State, local, and tribal governments; the public; and other 

interested stakeholders to make decisions. OIG recommended that HUD 

provide adequate resources for the further development of geocoding 

services through the reactivation of the lapsed Geocode Service Center 

contract. In addition, OIG will reopen recommendation 1A from OIG audit 

report 2020-LA-0002, issued on September 24, 2020, so that HUD can 

implement the agreed-upon action to meet the responsibility stated in 43 

U.S.C. (United States Code) 2808(a)(5). 

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

Office of Evaluation

Fiscal Year 2022 Federal Information Security Modernization Act 

(FISMA) Evaluation Report

OIG assessed HUD’s information security (IS) program for effectiveness in 

accordance with the Federal Information Security Modernization Act of 

2014 (FISMA), which directs OIGs to conduct an evaluation using the OIG 

FISMA metrics. The metrics consist 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. 

Corrective Action Verification of Government Purchase 

Card Program and Government Travel Card Program Audit 

Recommendations

OIG completed a corrective action verification (CAV) of recommendations 

from prior audit reports on HUD government purchase cards and 

government travel cards, both issued January 31, 2020. During the CAV, 

OIG followed up on all 10 recommendations from OIG audit report 2020-

KC-0001 and all 13 recommendations from OIG audit report 2020-KC0002. OIG’s CAV objective was to determine whether HUD implemented 

adequate corrective actions in response to the recommendations. 

Corrective actions were not fully implemented or completed for 2 of 

10 recommendations from audit report 2020-KC-0001 and 3 of 13 

recommendations from audit report 2020-KC-0002. The Office of the 

Chief Procurement Officer and the Office of the Chief Financial Officer did 

not fully implement the agreed-upon corrective action plans but closed 

the recommendations without revising the management decisions or 

fully implementing or completing the corrective actions. As a result, HUD 

lacked assurance that the agency used efficient and effective techniques 

to prevent or detect inappropriate use of government purchase and 

travel cards. OIG recommended that HUD submit a revised management 

decision to address the recommendation and fully implement those 

actions for two recommendations from OIG audit report 2020-KC-0001 

(2020-KC-0001-001A and 002A) and three recommendations from OIG 

audit report 2020-KC-0002 (2020-KC-0002-001A, 001D, and 002C). 

(Agencywide, Audit Report: 2022-FO-0006)

Geospatial Data Act of 2018, Fiscal Year 2022

OIG audited HUD’s efforts to comply with the Geospatial Data Act of 

2018. The Act formalizes governance processes related to geospatial 

data, provides policy and guidance to empower the use of geospatial 

data and technology, and facilitates broad cooperation between the 
Additional Reports | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 25

OMB modified the FISMA evaluation methodology in FY 2022, asking IG’s 

to evaluate 20 core metrics instead of approximately 60 FISMA metric 

that had been assessed in previous years. While HUD continued to take 

positive steps to improve its information technology (IT) security posture, 

based on the FY 2022 FISMA Core IG [Inspector General] Metrics issued 

by OMB, HUD’s IS program was evaluated as not effective. Significant 

limitations and challenges continue to impact the Office of the Chief 

Information Officer’s ability to establish an effective IS program. The 

longstanding inability to modernize key IT systems and consistently 

implement enterprise efforts and budget and resource constraints in FY 

2022 affected HUD’s ability to mature. This outcome is despite HUD’s 

increasing maturity in 3 of the 20 core metrics, while remaining at 

the same maturity level for 16 of the 20 core metrics and dropping in 

maturity for 1 core metric. HUD continued to make significant progress 

in addressing OIG’s prior-years’ recommendations. During FY 2022, HUD 

closed 21 prior FISMA recommendations. In this report, OIG issued five 

new recommendations and offered opportunities for improvement for 

the enterprise and the program offices. 

(Agencywide, Evaluation Report: 2022-OE-0001)

Risk Indicators of Lead-Based Paint Hazards in Public Housing 

Agencies

OIG conducted an evaluation of HUD’s oversight and monitoring of leadbased paint hazards in public housing, in large part due to the significant 

challenges HUD faces in controlling and addressing lead-related hazards. 

OIG identified “eliminating hazards in HUD-assisted housing” in 2022 

as a HUD top management challenge. OIG identified nine indicators of 

potential risk for lead-based paint hazards in public housing using the best 

available data collected from both HUD and external sources. Based on 

the analysis of these nine risk indicators, OIG identified five HUD regions 

and six States within those regions that have the greatest potential risk of 

having public housing agencies (PHA) with lead-based paint hazards. The 

evaluation found that HUD’s Office of Public and Indian Housing (PIH) and 

Office of Lead Hazard Control and Healthy Homes (OLHCHH) collaborate 

on lead hazard work. PIH is responsible for oversight of PHA compliance, 

and OLHCHH is responsible for writing policy and providing guidance. As 

of March 2022, HUD’s Real Estate Assessment Center, an office within PIH, 

was in the process of establishing the Environmental Shared Services office 

(ESS) to improve its risk assessment and inspection capabilities for health 

and safety hazards, including lead-based paint hazards. ESS will provide 

insight into potential and existing environmental hazards, compliance 

issues, and data gaps to improve HUD’s decision making, resource 

allocation, and hazard management strategies. As part of its strategy, ESS 

will rank risks related to four environmental hazards—carbon monoxide, 

mold, lead, and radon. In establishing its risk-ranking model, ESS identified 

five indicators for its lead risk ranking. The report did not include any 

recommendations; however, OIG concluded that the results of the analysis 

may be helpful to HUD, as the report identifies risk indicators, which could 

prove useful as ESS continues to identify risk factors and develop its riskranking approach. 

(Agencywide, Evaluation Report: 2021-OE-0011a)
Legislation, Regulations, and Other Directives | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 26

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 460 hours to reviewing 163 

issuances. The draft directives consisted of 125 notices, 10 mortgagee letters, and 28 other directives. OIG provided comments on 54 (or 33 percent) 

of the issuances and nonconcurred on 14 (or 9 percent) but lifted 10 nonconcurrences. Of the 28 other directives, OIG reviewed 2 final rules and 9 

proposed rules, took no position on 7, and commented on 4; 12 handbooks-guidebooks; 3 research reports; one notice of Delegation of Authority; and 

one set of frequently asked questions related to Community Health Worker Placed-based Approach to Health initiative, which was a 3-year pilot project 

(2019-2022) that assessed the feasibility and effectiveness of hiring and embedding public housing residents within their own communities to address 

population-level health and social needs. Below is a summary of selected reviews for this 6-month period.

LEGISLATION, 

REGULATIONS, AND 

OTHER DIRECTIVES

10 mortgagee letters

6%

163 TOTAL ISSUANCES

28 other directives

17%

125 notices

77%

OF THE 28 OTHER DIRECTIvES

final

rules

proposed 

rules

handbooks and 

guidebooks

research 

reports

delegation of 

authority

frequently asked 

questions
Legislation, Regulations , and Other Directi ves | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 27

transparency and predictability of CDBG-DR funds made available 

to impacted communities. Permanent authorization would also 

require HUD to establish consistent regulatory requirements 

for CDBG-DR across all future disasters, eliminating the current 

practice of establishing new requirements in response to each 

supplemental appropriation of CDBG-DR funds.”

HUD has maintained that it needs statutory authority to codify the 

CDBG-DR program and sought that authority from Congress. Bipartisan, 

bicameral Congressional support for codification has resulted in bills, 

such as the House and Senate versions of The Reforming Disaster 

Recovery Act, which are responsive to HUD OIG’s recommendations. 

Legislation codifying the CDBG-DR program would streamline, reform, 

and inject greater fiscal responsibility into the program, while also 

mitigating funding lags and duplicative requirements. HUD OIG believes 

Congressional efforts to codify the CDBG-DR program will help HUD meet 

its mission of timely serving communities struck by natural disasters with 

critical housing assistance. 

Notices, Mortgagee Letters, and Other 

Directives

Single Family Housing

Calculating effective income after a reduction or loss of income for 

borrowers affected by the presidentially declared COVID-19 national 

emergency – On July 7, 2022, the U.S. Department of Housing and 

Urban Development (HUD) issued Mortgagee Letter 2022-09, which 

instructs lenders on how to calculate effective income for borrowers 

who were affected by gaps in employment, which led to reductions 

Legislative

Permanent Authorization of the Community Development Block Grant 

– Disaster Recovery (CDBG-DR) program – Community Development 

Block Grant – Disaster Recovery (CDBG-DR) grant funds are not provided 

under a program codified in the Code of Federal Regulations (CFR). 

Although the CDBG program requirements provide a framework, HUD 

must issue Federal Register (FR) notices with additional, disaster-specific 

program requirements and waivers for each supplemental appropriation. 

With each newly issued FR notice, grantees must navigate the various 

notices, consider their communities’ pressing unmet needs, and develop 

a program that navigates both. These steps are expected to be completed 

during a time of great uncertainty, given that personnel, operations, and 

infrastructure may have been impacted following a disaster.

OIG and GAO have issued multiple oversight reports with 

recommendations to ensure HUD’s disaster recovery funding reaches 

vulnerable communities quickly. HUD OIG has recommended that 

HUD codify the CDBG-DR program through regulations to simplify 

and standardize the process, and more recently that HUD pursue 

codification of the CDBG-DR program through regulations or, if necessary, 

legislative action. HUD has consistently maintained that it does not 

have the statutory authority to codify the CDBG-DR program through 

the regulatory process. However, HUD has taken consistent, meaningful 

steps to address OIG’s recommendations to pursue codification through 

legislative action. Secretary Fudge and former Secretary Carson 

have both expressed public support for codification in testimony 

before Committees of Congress. Importantly, HUD’s Fiscal Year 2023 

Congressional Budget Justification expressly supports Congressional 

authorization of the CDBG-DR program, noting:

“Permanent authorization of CDBG-DR would improve the 
Legislation, Regulations , and Other Directi ves | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 28

and Digital Accountability and Transparency Act of 2014. OIG provided a 

no position response to this notice. 

Update to HECM program requirements for notice of due and payable 

status – On August 31, 2022, HUD issued Mortgagee Letter 2022-15, 

which modifies the requirements for lenders to provide notice to a 

borrower’s estate after a HECM becomes due and payable due to the 

death of the last surviving borrower. OIG provided a no position response 

regarding this mortgagee letter. 

New construction subterranean termite protection for new homes – 

On August 31, 2022, HUD issued a notice, FR-7056-N-27, which seeks 

approval from OMB regarding subterranean termite protection for new 

homes. HUD regulations at 24 CFR 200.926d(b)(3) require that the sites 

for HUD-insured structures be free of termite hazards. The form HUDNPMA-99-A requires the builder to certify that all required treatment 

for termites was performed by an authorized pest control company with 

the builder’s guarantee of the treated area against infestation for 1 year. 

The form HUD-NPMA-99-B requires a licensed pest control company 

to provide to the builder a record of specific treatment information for 

the prevention of termites. When applicable, the form HUD-NPMA-99-B 

must accompany the form HUD-NPMA-99-A. If the requested data are 

not collected, HUD risks insuring a mortgage loan for a home that is 

infested by termites. OIG nonconcurred on this clearance item because 

form HUD-NPMA-99-A and form HUD-NPMA-99-B both state “Warning: 

HUD will prosecute false claims and statements. Conviction may result 

in criminal and/or civil penalties. (18 U.S.C. [United States Code] 

1001, 1010, 1012; 31 U.S.C. 3729, 3802).” HUD does not prosecute. 

U.S. Department of Justice (DOJ), State, or local prosecutorial offices 

prosecute these matters. The language should be changed to a statement 

similar to the following: “I/We, the undersigned, certify under penalty 

of perjury that the information provided above is true and correct. 

in or loss of income due to COVID-19-related economic events. This 

policy allows industry partners additional opportunities to use flexible 

underwriting guidance to help borrowers qualify for home ownership. 

OIG provided a no position response to this mortgagee letter. 

Revised appraisal validity periods – On July 12, 2022, HUD issued 

Mortgagee Letter 2022-11, which increases the Federal Housing 

Administration (FHA) initial appraisal validity period to 180 days from 

the effective date of the appraisal. This mortgagee letter also extends 

the appraisal update validity period to 1 year from the effective date of 

the initial appraisal report, which is being updated. OIG provided a no 

position response to this mortgagee letter. 

Unique entity identifier for FHA-approved lenders, mortgagees, and 

institutions seeking FHA approval – On August 23, 2022, HUD issued 

Mortgagee Letter 2022-14, which requires all FHA-approved lenders, 

mortgagees, and institutions seeking FHA approval to provide an active 

unique entity identifier (UEI) as part of their institution data in the 

Lender Electronic Assessment Portal or application for FHA approval. OIG 

provided a no position response to this mortgagee letter. 

FHA lender approval, annual renewal, periodic updates, and required 

reports by FHA-approved lenders – On August 29, 2022, HUD issued a 

notice, Federal Register (FR)-7056-N-28, which seeks approval from the 

Office of Management and Budget (OMB) for the revised requirements 

for FHA lenders to follow when providing annual renewals, periodic 

updates, and reports to HUD. Specifically, the revision incorporates the 

requirements of 2 C.F.R. §§ 25 and 170, requiring all entities currently 

conducting or seeking to do business with the Federal Government to 

have a UEI registered in the General Services Administration’s System of 

Award Management. Collection of the UEI is vital to HUD’s compliance 

with the Federal Funding Accountability and Transparency Act of 2006 
Legislation, Regulations , and Other Directi ves | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 29

submissions; therefore, PHAs spend widely varying amounts of time and 

effort compiling information that may or may not facilitate HUD’s review 

of their request. OIG provided a no position response on this notice.

Remote video inspection – On April 29, 2022, HUD issued a notice, FR7061-N-07, which seeks approval from OMB for information collection 

regarding remote video inspection (RVI). The information collection 

is required to continuously apply the RVI criteria for Uniform Physical 

Condition Standards, National Standards for the Physical Inspection of 

Real Estate, Remote Video Collaborative Quality Assurance, and any 

other Real Estate Assessment Center inspections. OIG nonconcurred on 

this clearance item because there was no warning statement listed on 

a disclosure form in which the individual acknowledges the statement 

to be true. OIG recommended adding the following statement above 

the signature section: “I/We, the undersigned, certify under penalty 

of perjury that the information provided above is true and correct. 

WARNING: Anyone who knowingly submits a false claim or makes a 

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

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

penalties. (18 U.S.C. §§ 287, 1001, 1010, 1012, 1014; 31 U.S.C. §3729, 

3802).” The form should be modified to include a statement similar to the 

one suggested above. Including certifications under penalty of perjury 

and fraud warnings helps to discourage fraud and helps to effectively 

prosecute those who commit fraud. HUD added the warning statement 

to the disclosure form, and the nonconcurrence was lifted.

Notice of reallocation of unaccepted Indian Housing Block 

Grant American Rescue Plan Act funds to the Indian Community 

Development Block Grant Imminent Threat – American Rescue Plan 

Act program – On May 6, 2022, HUD issued a notice, PIH-2022-13, which 

provides Indian tribes and tribally designated housing entities (TDHE) 

with notice that the deadline to submit their abbreviated Indian housing 

WARNING: Anyone who knowingly submits a false claim or makes a 

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

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

penalties. (18 U.S.C. §§ 287, 1001, 1010, 1012, 1014; 31 U.S.C. §3729, 

3802).” The forms should be modified to include a statement similar 

to the one suggested above. Including certifications under penalty 

of perjury and fraud warnings helps to discourage fraud and helps 

to effectively prosecute those who commit fraud. HUD modified the 

warning language, and the nonconcurrence was lifted. 

Consideration of positive rental payment history for first time 

homebuyers in forward mortgage purchase transactions – 

On September 27, 2022, HUD issued Mortgagee Letter 2022-17, which 

provides guidance to lenders regarding the introduction of positive rental 

history for first time home buyers on forward purchase transactions in 

FHA’s Technology Open To Approved Lenders Mortgage Scorecard. OIG 

provided a no position response regarding this mortgagee letter.

Public and Indian Housing

Public housing flat rent exception request market analysis – On April 

29, 2022, HUD issued a notice, FR-7061-N-06, which seeks approval 

from OMB for information collection on market analysis. A form will 

be used to streamline the process and reduce the burden on public 

housing agencies (PHA) when submitting a market analysis as part of a 

flat rent exception request in accordance with Office of Public and Indian 

Housing (PIH) Notice PIH 2015-13(HA), which implements Section 238 

of Title II of Public Law 113-235, the Department of Housing and Urban 

Development Appropriations Act of 2015. Notice PIH 2015-13(HA) allows 

PHAs to request flat rents that are based on the local rental market 

conditions, when the PHAs can demonstrate through a market analysis 

that the fair market rents (FMR) are not reflective of the local market. 

The current submission process does not stipulate a template for PHA 
Legislation, Regulations , and Other Directi ves | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 30

the Consolidated Appropriations Act, 2022. The notice apportions 

the expected percentage change in national per unit cost for the HCV 

Program, 4.68 percent, to each PHA based on the change in FMRs 

for their operating area to produce the FY 2022 RFIFs. HUD’s FY 2022 

methodology is the same as that used in FY 2021. OIG provided a 

comment, which was for HUD to correct a weblink error. 

Total development cost for affordable housing under NAHASDA – On 

June 9, 2022, HUD issued a notice, PIH 2022-16, which transmits the 

updated schedule for the maximum amount of funds that may be used 

for affordable housing under the Native American Housing Assistance 

and Self-Determination Act of 1996 (NAHASDA) (25 U.S.C. § 4101 et 

seq.), based on Marshall Valuation Service, Marshall & Swift/Boeckh, 

LLC, and RSMeans Residential Cost Data for 2022. The requirement 

for the development and implementation of these limits is found at 

24 CFR 1000.156 through 1000.162 of IHBG regulations. This notice 

also preserves previously provided regulatory relief with respect to the 

total development cost limits for the IHBG Coronavirus Aid, Relief, and 

Economic Security (CARES) Act and IHBG-ARP programs. This notice 

supersedes Notice PIH 2010-47, dated November 19, 2010, and all 

notices extending that notice, up to and including Notice PIH 2019-19, 

dated July 18, 2019. OIG provided a comment regarding the date error 

under the “Applicability” section of the notice. 

Implementation of Public Housing Operating Fund shortfall funding 

from Federal FY 2022 appropriations – On June 13, 2022, HUD issued a 

notice, PIH-2022-17, which implements a provision in the Federal Fiscal 

Year 2022 Consolidated Appropriations Act (Public Law 117-103), which 

provides for a $25 million set-aside in the Public Housing Operating Fund 

to assist PHAs experiencing or at risk of financial shortfalls. Specifically, 

plan to receive their Indian Housing Block Grant American Rescue Plan 

Act (IHBG-ARP) grant funding is July 5, 2022. OIG commented that this 

notice stated, “On February 18, 2022, the Office of Native American 

Programs (ONAP) issued a ‘Dear Tribal Leader Letter’ suspending 

acceptance of applications for Indian Community Development Block 

Grant Imminent Threat – American Rescue Plan Act (ICDBG-ARP) grants 

on March 1, 2022.” Since it was anticipated that additional funds were 

being reallocated to ICDBG-ARP, the proposed notice might be clearer if 

HUD stated, “it is anticipated that the suspension will be lifted.” 

Implementation of the Federal fiscal year funding provisions for the 

Housing Choice Voucher Program – On May 19, 2022, HUD issued a 

notice, PIH 2022-14, which implements the Housing Choice Voucher 

(HCV) Program funding provisions of the Consolidated Appropriations 

Act, 2022 (Public Law 117-103), referred to hereafter as “the 2022 Act,” 

enacted on March 15, 2022. The 2022 Act establishes the allocation 

methodology for calculating housing assistance payments renewal funds, 

new incremental vouchers, and administrative fees. OIG suggested 

that “under penalty of perjury” wording be added to the certificationwarning statement in appendixes C, F, G, H, I, J, and K of this notice. 

The sentence in which the signer states that he or she certifies that the 

information is true and accurate should read as follows: “I hereby certify, 

under penalty of perjury, that all the information stated herein, as well 

as any information provided in the accompaniment herewith, is true 

and accurate.” Including certifications under penalty of perjury helps to 

discourage fraud. 

Section 8 housing assistance payments program for FY 2022 inflation 

factors for public housing agency renewal funding – On May 25, 

2022, HUD issued a notice, FR-6329-N-01, which establishes the 

renewal funding inflation factors (RFIF) to adjust fiscal year (FY) 2022 

renewal funding for the HCV Program of each PHA, as required by 
Legislation, Regulations , and Other Directi ves | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 31

of budget receipts and expenditures by the PHA and HUD. The related 

form provides a record of PHA board approval of how the amount shown 

on the operating budget was arrived at, as well as justification of certain 

specified amounts. The information is reviewed by HUD to determine 

whether the plan of operation adopted by the PHA and amounts 

included in it are reasonable for the efficient and economical operation 

of the development(s) and the PHA follows HUD procedures to ensure 

that sound management practices will be followed in the operation of the 

development. PHAs are still required to prepare their operating budgets 

and submit them to their boards for approval before their Operating 

Fund grant is approved by HUD. OIG nonconcurred on this clearance 

item because the warning language on form HUD 52574 indicated that 

HUD would prosecute. HUD does not prosecute. DOJ, State, or local 

prosecutorial offices prosecute these matters. The language should be 

changed to a statement similar to the following: “I/We, the undersigned, 

certify under penalty of perjury that the information provided above 

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

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

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

administrative penalties. (18 U.S.C. §§ 287, 1001, 1010, 1012; 31 U.S.C. 

§3729, 3802).” The form should be modified to include a statement 

similar to the one suggested above. Including certifications under penalty 

of perjury and fraud warnings helps to discourage fraud and helps 

to effectively prosecute those who commit fraud. HUD modified the 

warning language, and the nonconcurrence was lifted.

Public-private partnerships for the mixed-finance development of 

public housing units – On July 28, 2022, HUD issued a notice, FR7061-N-09, which seeks approval from OMB for information collection 

regarding public-private partnerships for the mixed-finance development 

of public housing units. The Quality Housing and Work Responsibility Act 

of 1998 (Public Law 195-276, approved October 21, 1998), also known as 

this notice provides guidance regarding eligibility, the process for 

applying, and other requirements for the set-aside. OIG provided a no 

position response to this notice.

Use of HCV and mainstream voucher administrative fees for other 

expenses to assist families to lease units – On June 13, 2022, HUD 

issued a notice, PIH 2022-18 (HA), which provides guidance on the use of 

HCV and mainstream voucher ongoing administrative fees for expenses 

related to assisting HCV and mainstream voucher families to lease units, 

including the costs of security deposit assistance and landlord incentive 

and retention payments. Also, this notice supersedes section 3 of Notice 

PIH 2015-17 with respect to the description of the restricted use of 

administrative fees. OIG provided a no position response to this notice.

Family Self-Sufficiency Program: establishment of the escrow account 

and use of forfeited program escrow – On July 27, 2022, HUD issued 

a notice, PIH-2022-20 (HA), which clarifies a few sections of the new 

rule (24 CFR part 984) related to the establishment of the Family SelfSufficiency (FSS) escrow account, the use of forfeited FSS escrow, and 

the reporting of FSS escrows in the Financial Assessment Sub-System for 

Public Housing Authorities. OIG commented that there were subsections 

that were not included in 24 CFR § 984.305(a)(2). OIG recommended 

revising the sentence; for example, “For convenience, some regulatory 

language of 24 CFR § 984.305 (a)(1) and (a)(2) is provided below.”

Public Housing Operating Fund program: operating budget and related 

form – On July 28, 2022, HUD issued a notice, FR-7061-N-10, which 

seeks approval from OMB for information collection regarding the 

public housing operating budget and a related form that are required 

to be submitted by PHAs for the low-income housing program. The 

operating budget provides a summary of proposed budget receipts and 

expenditures by major category, as well as blocks for indicating approval 
Legislation, Regulations , and Other Directi ves | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 32

CARES Act funding reconciliation and closeout – On August 3, 2022, 

HUD issued a notice, PIH 2022-21, which describes the closeout 

procedures under 2 CFR 200.344 (Closeout) for funds awarded 

to PHAs under the CARES Act (Public Law 116-136) to prevent, 

prepare for, and respond to the coronavirus. The CARES Act provided 

supplemental housing assistance payments and administrative fees 

to PHAs administering the HCV Program and mainstream vouchers 

and supplemental housing assistance payments to the Moderate 

Rehabilitation program. The period of availability (also known as period 

of performance) for this notice for the CARES Act supplemental funding 

ended on December 31, 2021; therefore, HUD is providing instructions 

PHAs must follow to complete and submit the OMB Form SF-425, Federal 

Financial Report, to HUD. This submission will include all CARES Act 

financial activity certified by the PHA’s executive director or designee, 

stating that the information on the SF-425 is true and accurate. OIG 

provided a no position response regarding this notice. 

Revocation and reallocation of emergency housing voucher awards

– On August 11, 2022, HUD issued a notice, PIH 2022-22 (HA), which 

explains HUD’s process for revocation and reallocation of emergency 

housing voucher awards. As part of this process, the notice updates 

the award allocation formula found in section 4 of notice PIH 2021-15 

in connection with the reallocation of these awards. OIG provided a no 

position response regarding this notice.

Administrative requirements for investing IHBG funds – On August 15, 

2022, HUD issued a notice, PIH 2022-23, which describes the requirements 

for investing IHBG funds and establishes the basis upon which HUD will 

determine whether a recipient of IHBG funds has the administrative 

capacity to draw down those funds for investment purposes as authorized 

under section 204(b) of NAHASDA. Also, this notice replaces Notice PIH 

2019-16. OIG provided a no position response regarding this notice. 

the Public Housing Reform Act, created Section 35 of the U.S. Housing Act 

of 1937, 42 U.S.C. 1437z-7.1437. Section 35 allows PHAs to own, operate, 

assist, or otherwise participate in the development and operation of mixedfinance projects. Mixed-finance development refers to the development 

or rehabilitation of public housing in which the public housing units are 

owned in whole or in part by an entity other than a PHA. Before this, 

all public housing had to be developed and owned by a PHA. However, 

Section 35 allows PHAs to provide Section 9 capital funds and operating 

funds to mixed-finance projects, which are also financially assisted by 

private financing and other resources, including tax credit equity; private 

mortgages; and other Federal, State, or local funds. Section 35 also allows 

non-PHA owner entities to own and operate mixed-finance projects that 

contain only public housing units or both public housing and nonpublic 

housing units. Mixed-finance real estate development or rehabilitation 

transactions also help to extend public housing appropriations for 

housing development and to support the development of mixed-income 

housing in which public housing residents are anonymously mixed in with 

affordable and market rate housing residents. OIG nonconcurred on this 

clearance item because the warning statement on forms HUD 50158, 

HUD-50160, and HUD-50161 stated that HUD would prosecute. HUD does 

not prosecute. DOJ, State, or local prosecutorial offices prosecute these 

matters. The language should be changed to a statement similar to the 

following: “I/We, the undersigned, certify under penalty of perjury that 

the information provided above is true and correct. WARNING: Anyone 

who knowingly submits a false claim or makes a false statement is subject 

to criminal and/or civil penalties, including confinement for up to 5 years, 

fines, and civil and administrative penalties. (18 U.S.C. §§ 287, 1001, 1010, 

1012; 31 U.S.C. §3729, 3802).” The forms should be modified to include 

a statement similar to the one suggested above. Including certifications 

under penalty of perjury and fraud warnings helps to discourage fraud and 

helps to effectively prosecute those who commit fraud. HUD modified the 

warning statement on the forms, and the nonconcurrence was lifted.
Legislation, Regulations , and Other Directi ves | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 33

Voluntary reallocation or recapture of HUD-Veterans Affairs Supportive 

Housing vouchers – On August 16, 2022, HUD issued a notice, PIH 

2022-25 (HA), which establishes the processes under which a HUDVeterans Affairs Supportive Housing (HUD-VASH) PHA may be approved 

to voluntarily (1) reallocate all or a portion of its HUD-VASH vouchers 

and any associated funding to another HUD-VASH PHA within the same 

Veterans Affairs Medical Center catchment area or (2) if reallocation 

is not an option, have all or a portion of its HUD-VASH vouchers and 

associated funding recaptured and returned to HUD. All HUD-VASH 

vouchers and associated funding returned to HUD will be awarded 

as part of a future HUD-VASH national allocation process, based on 

need and any other congressionally mandated factors. OIG provided a 

comment for HUD to update the number and date of this notice.

Registration of interest for HUD-VASH vouchers – On August 16, 2022, 

HUD issued a notice, PIH 2022-26 (HA), which announces the availability 

of approximately $79 million in HUD-VASH. Based on average costs, HUD 

anticipates that this funding will support approximately 8,500 new HUDVASH vouchers. These vouchers are administered in partnership with the 

U.S. Department of Veterans Affairs and enable homeless veterans and 

their families to access affordable housing with an array of supportive 

services. HUD-VASH vouchers are authorized under section 8(o)(19) of the 

United States Housing Act of 1937, as modified by the requirements in 

the Consolidated Appropriations Act, 2022 (Public Law 117-103, approved 

March 15, 2022). The Act provides $50 million in funding for the vouchers 

made available under this notice. The additional $29 million in funding 

is available from prior-year appropriations. OIG provided a no position 

response to this notice.

Determining and using program income under NAHASDA – On August 

23, 2022, HUD issued a notice, PIH 2022-28, which provides guidance 

for determining and using program income generated by the use or 

Notice of annual factors for determining administrative fees for the 

Section 8 HCV, mainstream, and Moderate Rehabilitation programs 

for calendar year 2021 – On August 15, 2022, HUD issued a notice, 

FR-6327-N-01, which provides the per unit, monthly fee rates used to 

determine the ongoing administrative fees for PHAs administering the 

HCV, mainstream, and Moderate Rehabilitation programs, including 

the Moderate Rehabilitation Single Room Occupancy program, for 

calendar year 2021. This is required by section 8(q) of the U.S. Housing 

Act of 1937. PHAs use administrative fees to cover costs associated with 

administering the HCV Program. Publishing the calendar year 2021 fees 

allows PHAs to budget appropriately and is important for PHA recordkeeping purposes. Additionally, publishing this notice retroactively allows 

PHAs to continue portability billing for families that ported in calendar 

year 2021. This notice follows HUD’s previous publication of the rates on 

HUD’s website and makes no changes to those rates. OIG provided a no 

position response regarding this notice. 

Stability Voucher program – On August 16, 2022, HUD issued a notice, 

PIH 2022-24 (HA), which explains HUD’s noncompetitive allocation strategy 

and program requirements for the new Stability Voucher program. HUD 

is awarding up to $43.4 million to support approximately 4,000 new 

incremental vouchers. This funding opportunity is designed to encourage 

a communitywide commitment to the goal of ending homelessness. 

Stabillity vouchers may assist households that are homeless, as defined in 

section 103(a) of the McKinney-Vento Homeless Assistance Act (42 U.S.C. 

11302(a)), or at-risk of homelessness; those fleeing or attempting to flee 

domestic violence, dating violence, sexual assault, stalking, or human 

trafficking; and veterans and families that include a veteran family member 

that meet one of the preceding criteria. Also, HUD clarifies that persons 

who are fleeing or attempting to flee human trafficking are an eligible 

category for stability vouchers and adds the definition of “homeless” in 

section 9 of this notice. OIG provided a no position response to this notice.
Legislation, Regulations , and Other Directi ves | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 34

must submit an annual report on two specific data points: (1) the number 

of overincome families residing in public housing and (2) the number of 

families on the public housing waiting lists. OIG provided a no position 

response regarding this notice. 

Public Housing Reform Act: changes to admission and occupancy 

requirements – On August 31, 2022, HUD issued a notice, FR-7061-N-12, 

which seeks approval from OMB for information collection that will 

implement changes to the admission and occupancy requirements for 

the public housing program made by the Quality Housing and Work 

Responsibility Act of 1998 (Title V of the FY 1999 HUD Appropriations 

Act, Public Law 105-276, 112 Stat. 2518, approved October 21, 1998) and 

HOTMA, Section 103, which amends the United States Housing Act of 

1937. OIG provided a no position response to this notice. 

FMRs for the HCV Program, Moderate Rehabilitation Single Room 

Occupancy Program, and other programs, FY 2023 – On September 

1, 2022, HUD issued a notice, FR-6343-N-01, which announces the 

availability of FY 2023 FMRs; describes the methods used to calculate 

the FY 2023 FMRs; responds to comments submitted on the notice, 

entitled Proposed Changes to the Methodology Used for Calculating 

Fair Market Rents; and enumerates the procedures for PHAs and other 

interested parties to request reevaluations of their FMRs as required by 

HOTMA. OIG provided comments on this clearance item. Specifically, 

OIG suggested that HUD edit the contradicting sentences on margin 

of error because the margin of error should be simultaneously less 

than half but greater than 50 percent. In addition, OIG suggested that 

HUD reexamine the contradiction regarding whether or not to use the 

American Community Survey data or a local survey to establish the 

base rent. Further, the notice did not identify how third parties needing 

to use the adjusted FMRs would know that the areas have adjusted 

FMRs; therefore, OIG suggested that HUD consider adding a website or 

disbursement of IHBG funds under NAHASDA. Also, this notice replaces 

Notice PIH 2019-07. OIG provided a no position response to this notice.

Notice of annual factors for determining administrative fees for the 

Section 8 HCV, Mainstream, and Moderate Rehabilitation programs 

for calendar year 2022 – On August 25, 2022, HUD issued a notice, 

FR-6328-N-01, which announces the per unit, monthly fee rates to 

determine the ongoing administrative fees for PHAs administering the 

HCV, Mainstream, and Moderate Rehabilitation programs, including 

Single Room Occupancy, during calendar year 2022. PHAs use 

administrative fees to cover costs associated with administering the HCV 

Program. Publishing the calendar year 2022 administrative fees allows 

PHAs to budget appropriately and is important for PHA record-keeping 

purposes. This notice follows HUD’s previous publication of the rates on 

HUD’s website and makes no changes to those rates. OIG provided a no 

position response to this notice. 

Public housing waiting list data collection tool – On August 31, 2022, 

HUD issued a notice, FR-7061-N-11, which seeks approval from OMB for 

its proposed information collection regarding a public housing waiting 

list collection tool. This collection of information implements a statutory 

requirement made by Section 103 of the Housing Opportunity Through 

Modernization Act of 2016 (HOTMA). HOTMA was signed into law on 

July 29, 2016 (Public Law 114-201, 130 Stat. 782). Section 103 of HOTMA 

amends section 16(a) of the United States Housing Act of 1937 (42 U.S.C. 

1437n(a)). Section 103 of HOTMA states that after a public housing 

family has been overincome for 2 consecutive years, a PHA must either: 

(1) charge the overincome family a monthly rent that is the higher of 

FMR under section 8(c) for the dwelling unit or the monthly amount of 

public housing subsidy provided for the dwelling unit or (2) terminate the 

tenancy of the overincome family no later than 6 months after the end 

of the 2-year period. Additionally, under section 103 of HOTMA, PHAs 
Legislation, Regulations , and Other Directi ves | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 35

ONAP training and technical assistance evaluation – On September 

28, 2022, HUD issued a notice, FR-7061-N-13, which seeks approval 

from OMB for information collection regarding its ONAP training and 

technical assistance. ONAP administers the IHBG program and offers 

contracted training and technical assistance to IHBG recipients on 

program requirements. ONAP’s Notice of Funding Opportunity for 

training and technical assistance services includes the requirement for 

the contractor(s) to use an OMB-approved evaluation form at all ONAPsponsored events. At the end of each training and technical assistance 

event, participants are invited to voluntarily complete the Training and 

Technical Assistance Evaluation Form (form HUD-5879) to assess training 

and technical assistance effectiveness and solicit ideas for improvement. 

OIG provided a no position response regarding this notice.

Mainstream Vouchers – noncompetitive opportunity for additional 

vouchers authorized by the CARES Act and extraordinary 

administrative funding update – On September 30, 2022, HUD issued 

a notice, PIH 2022-31, in which HUD increases the available funding for 

new mainstream vouchers from $40 million to $48 million after additional 

funding has been identified. There will be no new Mainstream vouchers 

being received through this notice. In a previous notice, PIH 2022-07, HUD 

used its authority provided by the CARES Act to use Mainstream carryover 

funding from previous appropriations Acts to noncompetitively award up 

to $35 million in new mainstream vouchers. Notice PIH 2022-19 increased 

the available funding for new mainstream vouchers from $35 million to $40 

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

publication through which third parties (such as PHAs) can easily identify 

the correct FMRs for the areas or locations.

Extension of certain regulatory waivers for the HCV, including 

mainstream program and streamlined review process – On September 

26, 2022, HUD issued a notice, PIH 2022-30, which provides for the 

extension of currently approved regulatory waivers for (1) increasing 

the payment standard during the housing assistance payments contract 

term and (2) new payment standard amounts through December 31, 

2023. This notice includes regulatory waivers specifically related to 

assisting PHAs in responding to ongoing fluctuations and disruptions 

in the rental market by providing more flexibility with establishing and 

applying payment standards. OIG provided a no position response 

regarding this notice.

Public housing mortgage program and Section 30 – On September 27, 

2022, HUD issued a notice, FR-7061-N-14, which seeks approval from 

OMB for information collection related to public housing mortgage 

program. Section 516 of the Quality Housing and Work Responsibility 

Act of 1998 added Section 30, Public Housing Mortgages and Security 

Interest, to the United States Housing Act of 1937. Section 30 authorizes 

the Secretary of HUD to approve a PHA’s request to mortgage public 

housing real property or grant a security interest in other tangible forms 

of personal property if the proceeds of the loan resulting from the 

mortgage or security interest are used for low-income housing uses. 

PHAs must provide information to HUD for approval to allow PHAs to 

grant a mortgage in public housing real estate or a security interest 

in some tangible form of personal property owned by the PHA for 

the purposes of securing loans or other financing for modernization 

or development of low-income housing. OIG provided a no position 

response regarding this notice.
Legislation, Regulations , and Other Directi ves | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 36

Multifamily Housing

Personal financial and credit statement – On July 13, 2022, HUD 

issued a notice, FR-7056-N-25, which seeks approval from OMB for 

information collection regarding project participants’ personal financial 

and credit statements. The financial analysis of the project’s principal 

participants is an integral part of the underwriting process. Thus, HUD, 

in accordance with regulations cited in 24 CFR 207.1, is legally required 

to collect information to evaluate the character, ability, and capital of 

the sponsor, borrower, and general contractor for mortgage insurance. 

OIG provided a no position response to this notice.

Standards for success reporting – On July 20, 2022, HUD issued a 

notice, FR-7051-N-01, which seeks approval from OMB for information 

collection regarding its standards for success reporting. This request is for 

the continued clearance of data collection and reporting requirements 

to enable HUD’s Office of the Chief Financial Officer to better assess 

the effectiveness of discretionary-funded programs included in this 

information collection request. The discretionary-funded programs 

included in this information collection request are the Multifamily 

Housing Service Coordinator Grant program, the Multifamily Housing 

Budget-Based Service Coordinator program, and the Resident 

Opportunity and Self Sufficiency Service Coordinator Grant program. OIG 

provided a no position response regarding this notice. 

HUD multifamily energy assessment – On August 30, 2022, HUD issued 

a notice, FR-7056-N-22, which seeks approval from OMB to extend 

currently approved information collection with the purpose of assisting 

owners of multifamily housing projects with assessing energy needs in 

an effort to reduce energy costs and improve energy conservation. OIG 

provided a comment regarding this notice. Specifically, the form HUD9614 states that it takes an average of 4 hours per response, while the 

“Supporting Statement A” shows an average of 8 hours per response. 

OIG recommended that HUD make a correction regarding the conflicting 

average hours per response.

Increase in frequency of the distribution of surplus cash for 

nonassisted HUD-insured properties – On September 7, 2022, HUD 

issued Mortgagee Letter 2022-16, which permits modification of 

section 13 of the regulatory agreement (form HUD-92466M) to allow 

distributions from surplus cash as frequently as monthly for eligible 

borrowers. This policy is limited to FHA-insured multifamily properties 

not subject to a Section 8 project-based rental assistance payments 

contract or a HUD-held mortgage note. This policy aligns HUD’s 

multifamily insurance for unassisted projects with industry standards and 

increases its competitive standing in the lending industry. OIG provided a 

no position response to this mortgagee letter.

Multifamily Accelerated Processing – On September 12, 2022, HUD 

issued a notice, FR-7056-N-35, which seeks approval from OMB for 

information collection regarding the Multifamily Accelerated Processing 

(MAP) Guide 4430.G, which applies only to FHA multifamily mortgage 

insurance programs. The MAP Guide is designed to establish uniform 

national standards for FHA-approved lenders to prepare, process, and 

submit loan applications for multifamily mortgage insurance. The MAP 

Guide has been updated to reflect various organizational, policy, and 

processing changes implemented since the last edition was published in 

2016. Two new chapters have been added to this edition of the Guide: 

The “Water and Energy Conservation” chapter and the “Closing Guide.” 

All MAP-eligible projects must be submitted using MAP processing unless 

a waiver is granted to process under traditional application processing. 

OIG provided a no position response to this notice.
Legislation, Regulations, and Other Directives | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 37

recovery. HUD modified the warning language on both forms, and the 

nonconcurrence was lifted. 

Green and Resilient Retrofit Program – On September 27, 2022, HUD 

issued a notice, FR-6350-N-01, which was a request for information (RFI). 

The purpose of this RFI is to solicit information regarding the design and 

implementation of the Green and Resilient Retrofit Program to support the

improvement of energy and water efficiency retrofits and climate resilience

of HUD-assisted multifamily properties. HUD expects to make multiple

rounds of funding available to support energy and water efficiency retrofits

and climate resilience of HUD-assisted multifamily properties. OIG provided

a no position response regarding this notice.

Renewal of expiring project rental assistance contracts for projects

under the Section 202 program of Supportive Housing for the Elderly

and the Section 811 program of Supportive Housing for Persons with

Disabilities – On September 29, 2022, HUD issued Notice H 2022-05,

which updates the contract renewal procedures and standard renewal

contract language for project rental assistance contracts (PRAC) under the

Section 202 program of Supportive Housing for the Elderly and Section 811

program of Supportive Housing for Persons With Disabilities. The notice

also establishes a process to move all Section 202 PRAC properties into

contracts with a 5-year term. This change will reduce paperwork associated

with annual renewals and streamline the annual funding process. To assist

in balancing HUD’s workload and improve the timely completion of all

renewals going forward, the conversion from annual to 5-year terms will

be phased in over the next 3 years. OIG provided the following comments

regarding this notice.

In section III.D, the proposed notice states, “The calculation of new 

funding increments will consider undisbursed balances from prior year 

allocations to the contract.” The notice does not say how HUD would 

Multifamily coinsurance claims package, section 223(f) – On September 

16, 2022, HUD issued a notice, FR-7056-N-39, which seeks approval 

from OMB for information collection regarding multifamily coinsurance 

claims. The request is about the reinstatement, with change, of a 

previously approved collection for which approval has expired. A lender 

with an insured multifamily mortgage pays an annual insurance premium 

to HUD. When and if the mortgage goes into default, the lender may 

elect to file a claim for FHA multifamily insurance benefits with HUD. 

HUD needs this information to determine whether FHA multifamily 

insurance claims submitted to HUD are accurate and valid and support 

payment of an FHA multifamily insurance claim. OIG nonconcurred on 

this clearance item because both forms HUD-27008 and HUD-27009-F 

state, “HUD will prosecute...” and do not give warnings of penalties 

for violating the referenced criminal and civil violations. HUD does not 

prosecute. DOJ, State, or local prosecutorial offices prosecute these 

matters. The language should be changed to a statement similar to 

the following: “I/We, the undersigned, certify under penalty of perjury 

that the information provided above is true and correct. WARNING: 

Anyone who knowingly submits a false claim or makes a false statement 

is subject to criminal and/or civil penalties, including confinement for 

up to 5 years, fines, and civil and administrative penalties. (18 U.S.C. §§ 

287, 1001, 1010, 1012; 31 U.S.C. §3729, 3802).” The forms should be 

modified to include a statement similar to the one suggested above. 

Including certifications under penalty of perjury and fraud warnings helps 

to discourage fraud and helps to effectively prosecute those who commit 

fraud. Additionally, form HUD-27009-F does not require a signature. If 

it has warning statements, as it currently does, consideration should 

be given to requiring a signature like form HUD-27008, if applicable. 

Requiring a signature ensures that the authorizer of the report on 

proceeds can and should be held responsible for any criminal or civil 

violations. Acknowledging the responsibility aids in protecting HUD 

funds and allows for reclamation through administrative, civil, or criminal 
Legislation, Regulations , and Other Directi ves | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 38

says no to a PRAC due to its workload considerations.

In section IV.B, the proposed notice assigns PRACs to cohorts by the last 

digit of their project number. The project number can be the FHA insurance 

number (for example, 063-EExxx) or the Real Estate Management System 

(REMS) project ID (for example, 8000xxxxx). Most PRACs have both an 

FHA insurance number and a REMS project ID. The examples used in the 

proposed notice identify that HUD is using the FHA insurance number. To 

avoid potential confusion, HUD could replace the term “project number” 

with “FHA insurance number” and keep its examples. This change could 

avoid confusion on the part of its stakeholders.

In section IV.B, the proposed notice authorizes the multifamily regional 

directors to approve requests for cohort changes. A cohort change will 

affect multiple years of a PRAC’s operations and how HUD employees 

monitor an operation. The proposed notice does not identify how and 

where the directors should document that they authorized a change. 

HUD should consider adding statements to the notice identifying how the 

directors should document that they authorized a change. HUD should also 

consider adding statements to the notice to identify a consistent location 

in its computer systems (for example, specific screens in its Integrated Real 

Estate Management System) where the directors should document that 

they authorized a change. Having a consistent location for this information 

could help HUD employees better understand that PRAC and better 

monitor its operations.

Community Planning and Development

Small Cities program performance assessment report – On May 6, 

2022, HUD issued a notice, FR-7052-N-04, which seeks an extension 

without change of a currently OMB-approved collection regarding the 

annual performance assessment reports that are submitted by the 

consider the undisbursed balances. When undisbursed funds are tied 

to a specific contract, HUD does not have the opportunity to resource 

those funds for another contract. Instead, HUD should consider spelling 

out in this notice that HUD will use up any undisbursed balances before 

allocating additional funds.

In section III.E, the proposed notice states, “Any rent adjustments for 

either Section 202 PRACs or Section 811 PRACs proposed to be effective 

at a point-in-time other than renewal or in the month of the renewal 

contract anniversary date will be subject to secondary funding reviews by 

HUD.” It does not describe the secondary funding review process. HUD 

should consider adding a statement about the secondary funding review 

process that either spells out the process or links to the criteria in which 

it spelled out this process.

In section IV.A, the proposed notice states, “No more than 40 percent 

of renewals administered within an individual Regional or Satellite office 

that expire within each month may be approved for a 5-year term during 

this initial opt-in period.” This sentence is confusing as it contains multiple 

ideas. It appears to mean that HUD is limiting the number of properties 

eligible to change to 5-year renewals to maintain operating efficiency. It 

may mean that HUD is limiting the number of properties to 40 percent of 

an individual regional or satellite office’s monthly workload of renewals. 

Maintaining operating efficiency while ensuring that renewals are accurate 

is important. HUD could split these ideas to limit confusion on the part 

of stakeholders (owners, management agents, operators, etc.). This 

procedure may create challenges at certain times of the year when there 

are large numbers of renewals coming due at the same time. Renewals are 

not evenly distributed across all 12 months. The notice does not explain 

what happens when HUD says no to an owner because of its workload 

considerations. For example, when would the PRAC be eligible to convert 

to 5-year renewals? HUD should consider identifying the next steps when it 
Legislation, Regulations , and Other Directi ves | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 39

rental assistance programs. The rent standard is used in conjunction with 

“rent reasonableness” and the “resident rent payment” to determine 

the maximum subsidy for a family receiving HOPWA rental assistance. 

Under 24 CFR 574.320(a)(2), the rent standard may be no more than 

the published Section 8 FMR or the HUD-approved communitywide 

exception rent for the unit size. In addition, on a unit-by-unit basis, 

the grantee may increase that amount by up to 10 percent for up 

to 20 percent of the units assisted. OIG suggested that HUD cite the 

appropriate subpart of 24 CFR 574.320 regarding maximum subsidy 

and rent reasonableness. In addition, regarding the two standards 

(comparable units in the private market and not-in-excess-of rents 

charged of other comparable unassisted units by the same landlord), OIG 

recommended that HUD make a clarification at the front of the section 

and include the specific CFR citation. 

Housing Trust Fund – On July 13, 2022, HUD issued a notice, FR7050-N-33, which seeks approval from OMB regarding information 

collection on the Housing Trust Fund (HTF). The information collected 

through the Integrated Disbursement and Information System (IDIS) (24 

CFR 93.402) is used by HUD field offices, HUD headquarters, and HTF 

grantees. Specifically, the information on program funds committed and 

disbursed is used by HUD to track grantee performance and determine 

compliance with the statutory 24-month commitment deadline and 

the regulatory 5-year expenditure deadline (section 93.400(d)). In 

addition, the project-specific property, tenant, owner, and financial 

data are used to make program management decisions about how 

well program participants are achieving the statutory objectives of the 

HTF program. Program management reports are generated by IDIS to 

provide data on the status of program participants’ commitment and 

disbursement of HTF funds. These reports are provided to HUD staff as 

well as to HTF grantees. OIG provided comments regarding this notice by 

recommending that HUD review 24 CFR 93.404 to determine whether it 

grantees under the Small Cities program. Such information will enable 

HUD to track the progress of the program. Section 104(e) of the Housing 

and Community Development Act of 1974 requires that each grantee 

submit a performance and evaluation report to HUD. OIG provided a no 

position response regarding this notice. 

Procedural guidance for FY 2022 Housing Opportunities for Persons 

With AIDS permanent supportive housing renewal and replacement 

grant applications – On June 13, 2022, HUD’s Office of Community 

Planning and Development (CPD) issued a notice, CPD-22-08, which 

announces the renewal grant application and replacement grant 

application requirements for eligible expiring Housing Opportunities for 

Persons With AIDS (HOPWA) Permanent Supportive Housing (PSH) grants. 

Under the renewal authority provided by the Consolidated Appropriations 

Act, 2020 (Public Law 116-94), and the renewal or replacement authority 

provided by both the Consolidated Appropriations Act, 2022 (Public Law 

117-103), and the Consolidated Appropriations Act, 2021 (Public Law 116-

260), HUD will renew or replace all eligible expiring HOPWA PSH grants 

that meet all program requirements and were initially funded under a 

HUD competition for FY 2010 or earlier FY funds. HUD’s mission is to 

create strong, sustainable, inclusive communities and quality, affordable 

homes for all. HUD’s FYs 2022-2026 Strategic Plan establishes strategic 

goals in line with the work supported through the notice of funding for 

HOPWA PSH grants. OIG recommended that HUD change the citations of 

the Federal regulations for specificity and accuracy.

Clarification of rent standard requirement for the HOPWA program

– On June 29, 2022, HUD issued a notice, CPD-22-10, which clarifies 

HUD’s guidance on applying the program rent standard requirements 

at 24 CFR 574.320(a)(2), while HUD considers potential rulemaking to 

update HOPWA rental assistance requirements. Under 24 CFR 574.320(a)

(2), HOPWA grantees are required to establish rent standards for their 
Legislation, Regulations , and Other Directi ves | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 40

issued a Federal Register notice, FR-6349-N-01, which governs Community 

Development Block Grant Disaster Recovery (CDBG-DR) funds awarded 

under the appropriations acts identified in the table of contents of this 

notice. Specifically, this notice provides waivers and establishes alternative 

requirements for certain CDBG-DR grantees that have submitted waiver 

requests for grants provided under the public laws cited in this notice. OIG 

provided a no position response regarding this notice.

Disaster Funding

Allocations for Community Development Block Grant Disaster 

Recovery and implementation of the consolidated waivers and 

alternative requirements – On May 24, 2022, HUD issued a notice, 

FR-6326-N-01, which identifies grant requirements for the nearly $3 

billion allocated CDBG-DR funds, including requirements in HUD’s CDBGDR Consolidated Notice and some amendments to the Consolidated 

Notice that apply to CDBG-DR grants for disasters occurring in 2020 

and 2021. The Consolidated Notice, as amended by this allocation 

announcement notice, includes waivers and alternative requirements, 

relevant regulatory requirements, the grant award process, criteria for 

action plan approval, and eligible disaster recovery activities. This notice 

also includes a modification to the February 3, 2022, notice (87 FR 6364) 

that announced CDBG-DR grants for disasters occurring in 2020. OIG 

recommended that HUD replace the warning language to “WARNING: 

Anyone who knowingly submits a false claim or makes a false statement 

is subject to criminal and/or civil penalties, including confinement for 

up to 5 years, fines, and civil and administrative penalties. (18 U.S.C. 

§§ 287, 1001, 1010, 1012, 1014; 31 U.S.C. §3729, 3802).” In addition, 

OIG recommended that HUD modify the certification statement; make 

a correction to the uniform guidance citation and the HUD OIG hotline 

information; and make clarifications regarding (1) whether an amended 

action plan is required for the smaller grantees, (2) the difference 

should also cite 24 CFR 93.405 regarding program cost limits; expand the 

range of 24 CFR 93.201 (d)(1) by including 24 CFR 93.201 (d)(2) through 

(d)(5); and add 24 CFR 93.302(e)(1), 24 CFR 93.302 (e)(2), 24 CFR 

93.350(b)(1), and 24 CFR 93.350(b)(2).

Section 108 Loan Guarantee Program: announcement of fee to cover 

credit subsidy costs for FY 2023 – On September 1, 2022, HUD issued 

a notice, FR-6341-N-01, which announces the fee that HUD will collect 

from borrowers of loans guaranteed under HUD’s Section 108 Loan 

Guarantee Program to offset the credit subsidy costs of the guaranteed 

loans under commitments awarded in FY 2023 in the event that HUD 

is required or authorized by statute to do so, despite subsection (m) of 

Section 108 of the Housing and Community Development Act of 1974. 

OIG provided a no position response regarding this notice.

Changes to Home Investment Partnerships program commitment 

requirement – On September 22, 2022, HUD issued a final rule, FR 

5792-F-03, which finalizes the December 2, 2016, interim rule without 

change. The interim rule changed the method by which HUD determines 

participating jurisdictions’ compliance with the statutory 24-month 

commitment requirements on the use of Home Investment Partnerships 

program funds, including the set-aside for community housing 

development organizations, under the Cranston-Gonzalez National 

Affordable Housing Act of 1990. Specifically, it implemented a grantspecific method for determining compliance with such requirements. In 

addition, the interim rule revised the method of administering program 

income to prevent participating jurisdictions from losing allocated HOME 

funds when they spend program income. OIG provided a no position 

response regarding this final rule. 

Waivers and alternative requirements for Community Development 

Block Grant Disaster Recovery grantees – On September 28, 2022, HUD 
Legislation, Regulations , and Other Directi ves | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 41

Administrative and Other Program Areas

General applicability waiver of Build America, Buy America provisions 

as applied to recipients of HUD Federal financial assistance – On May 

3, 2022, HUD issued a notice, FR-6331-N-01, which, in accordance with 

the Build America, Buy America Act, advises that it is proposing a general 

applicability waiver for 6 months to the Buy America Domestic Content 

Procurement Preference (BAP) to provide the agency with sufficient time 

to solicit information from the public relating to the agency’s potential 

information collection needs and the associated burdens that would be 

placed on recipients arising from compliance and monitoring with the 

BAP in connection with Federal financial assistance awards made by HUD. 

In accordance with the Act, HUD has found that this proposed general 

applicability waiver is in the public interest as HUD must complete the 

required public comment process under the Paperwork Reduction Act 

to establish an approved collection for the information identified. The 

information collection is necessary to establish compliance with the BAP. 

OIG provided a no position response to this notice.

General applicability waiver of Build America, Buy America provisions 

as applied to tribal recipients of HUD Federal financial assistance

– On May 3, 2022, HUD issued a notice, FR-6331-N-02, which, in 

accordance with the Build America, Buy America Act, advises that HUD 

is proposing a general applicability waiver for 1 year to the BAP as applied 

to Federal financial assistance provided to tribes, TDHEs, and other tribal 

entities. In accordance with the Act, HUD has found that this general 

applicability waiver is in the public interest. Such a waiver provides HUD 

with the opportunity to first engage in consultation as described in HUD’s 

Tribal Government-to-Government Consultation Policy, consistent with 

President Biden’s Tribal Consultation and Strengthening Nation-to-Nation 

Relationships memorandum, regarding the potential application of the BAP 

to such entities. OIG provided a no position response to this notice.

between evaluation of the cost (for example, before issuing for proposals) 

and price analysis (for example, after receiving proposals), and (3) 

whether the grantees that can rely on their prior financial certifications 

still have to submit an action plan for program administrative costs if 

they want to access funds for such use. Further, OIG suggested that 

HUD consider inserting a sentence, under the “Timely Distribution and 

Expenditure of Funds” section that expressly recognizes that HUD has a 

reversionary interest in any unused and improperly applied funds.

Healthcare Programs

Additional operator and FHA lender notice requirement for accounts 

receivable availability reduction – On July 11, 2022, HUD issued 

Housing Notice 22-03, which implements an additional notice 

requirement for FHA lenders and operators of Section 232 projects 

that receive accounts receivable financing from an accounts receivable 

lender. The requirement will allow FHA lenders and HUD to better 

monitor the financial health of such projects and position FHA lenders 

and HUD to take timely action when necessary. OIG provided a no 

position response regarding this notice. 

Green Mortgage Insurance Premium program guidance for the 

Office of Residential Care Facilities – On August 18, 2022, HUD issued 

Mortgagee Letter 2022-13, which provides program guidance and 

reporting requirements for Office of Residential Care Facilities’ (ORCF) 

Green Mortgages as announced in ORCF’s Green Mortgage Insurance 

Premium (MIP) Notice (FR-6302-N-01). This mortgagee letter is effective 

upon publication, and it applies to firm commitments issued or reissued 

on or after October 1, 2022. Applications with firm commitments issued or 

reissued on or before September 30, 2022, are not eligible for the Green 

MIP rate. OIG provided a comment on this clearance item, correcting the 

name of the program office so it would match with the acronym.
Legislation, Regulations , and Other Directi ves | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 42

Multiple Program Areas

Proposed changes to the methodology used for calculating FMRs – On 

July 13, 2022, HUD issued a notice, FR-6334-N-01, which states that 

section 8(c)(1) of the United States Housing Act of 1937 requires the 

HUD Secretary to publish FMRs periodically but not less than annually, 

adjusted to be effective on October 1 of each year. The primary uses 

of FMRs are to determine (1) payment standards for the HCV Program, 

(2) initial renewal rents for some expiring project-based Section 

8 contracts, and (3) initial rents for housing assistance payments 

contracts in the Moderate Rehabilitation Single Room Occupancy 

Program and to serve as rent ceilings for rental units in both the HOME 

Investment Partnerships program and the ESG Program and a primary 

rent standard option for the HOPWA program. HUD also uses FMRs 

in the calculation of maximum award amounts for Continuum of Care 

grantees and in the calculation of flat rents for public housing units. 

In furtherance of that effort, HUD proposes changes in how FMRs are 

calculated in this notice and seeks public comment on the proposed 

changes. OIG provided a comment regarding a missing web link in the 

first paragraph of section III of the notice. 

Adjustment of civil monetary penalty amounts: request for comments 

– On September 21, 2022, HUD issued a notice, FR-6346-N-01, which 

seeks public input on the impact of applying inflation-adjusted penalty 

amounts on the date the penalty is assessed rather than the date 

of the violation. Consistent with the Federal Civil Penalties Inflation 

Adjustment Act of 1990, as amended by the Federal Civil Penalties 

Inflation Adjustment Act Improvements Act of 2015 (2015 Act), HUD 

annually publishes a final rule adjusting its civil money penalty amounts 

for inflation according to the formula provided by the 2015 Act. In these 

Request for information related to the implementation of the Build 

America, Buy America Act – On June 1, 2022, HUD issued a notice, 

FR-6331-N-03, which seeks public input on the implementation of the 

Build America, Buy America Act as it applies to HUD’s Federal financial 

assistance. In this request for information, HUD is seeking input on 

several topics relating to the potential information collection burden 

on recipients, including existing mechanisms for demonstrating 

compliance with the Act’s BAP, potential costs of compliance for 

recipients and contractors, and the potential impact on projects funded 

by HUD Federal financial assistance. OIG provided comments for HUD 

to consider, such as a brief description of what “de minimis” is and 

revising the document number or updating the applicable portal to 

match the document number. The e-Rulemaking portal listed only FR6331-N-01 and did not list FR-6331-N-03. 

Standardization of form for race and other demographic data reporting 

– On September 27, 2022, HUD issued a notice, FR-7051-N-03, which 

seeks approval from OMB for information collection using form HUD27061. HUD program offices use this form when collecting information 

concerning the race, ethnicity, and other protected class data of the 

populations intended to benefit from HUD funding as required by 

Title VI of the Civil Rights Act of 1964, the Fair Housing Act, and HUD’s 

regulations. OIG provided a comment regarding this notice. Specifically, 

OIG suggested that HUD revise the incomplete statement under the 

Members of Affected Public section. For example, the incomplete 

sentence can be revised to “Members of the affected public include 

applicants for HUD’s competitively funded financial assistance programs 

that are subject to Title VI of the Civil Rights Act of 1964.” 
Legislation, Regulations , and Other Directi ves | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 43

rules, HUD does not apply the adjustments retroactively and provides 

that the inflation-adjusted penalty amounts apply to violations occurring 

on or after the rule’s effective date. HUD is considering revising this 

approach, however, and annually applying inflation-adjusted penalty 

amounts to violations assessed after the date of inflation, if the violation 

occurred after the enactment of the 2015 Act. OIG provided a no position 

response regarding this notice.
Report Resolution | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 44

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 

Audit Reports Issued Before Start of Period 

With No Management Decision as of 

September 30, 2022

HUD Did Not Always Provide Adequate Oversight of Property 

Acquisition and Disposition Activities | Issue Date: June 30, 2016

OIG audited HUD’s Community Development Block Grant (CDBG) 

program’s property acquisition and disposition activities. OIG’s objective 

was to determine whether HUD had adequate oversight of property 

acquisition and disposition activities under its CDBG program.

OIG found that HUD did not always provide adequate oversight of 

property acquisition and disposition activities. Specifically, of the 14 

REPORT RESOLUTION

In the report resolution process, Office of Inspector General (OIG) and U.S. Department of 

Housing and Urban Development (HUD) management agree upon needed actions and timeframes 

for resolving recommendations. Through this process, OIG strives to achieve measurable 

improvements in HUD programs and operations. The overall responsibility for ensuring that the 

agreed-upon changes are implemented rests with HUD managers. This chapter describes audit and 

evaluation reports issued before the start of the period that do not have management decisions, 

have significantly revised management decisions, or have significant management decisions with 

which OIG disagrees. It also has a status report on HUD’s implementation of the Federal Financial 

Management Improvement Act of 1996 (FFMIA). In addition to this chapter on report resolution, 

see appendix 3, table B, “Significant Reports for Which Final Action Had Not Been Completed 

Within 12 Months After the Date of the Inspector General’s Report.”
Report Resolution | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 45

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.4

 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 

September 30, 2022, had not received a decision

(Audit Report: 2016-PH-0005)

HUD Needs To Clarify Whether Illegal-Undocumented Aliens 

Are Eligible for Assistance Under the Housing Opportunities for 

Persons With AIDS Program | Issue Date: August 21, 2017

OIG assisted the U.S. Attorney’s Office, Southern District of New York, 

in a civil investigation related to illegal-undocumented aliens receiving 

Housing Opportunities for Persons With AIDS (HOPWA) assistance.

Noncitizen or alien ineligibility for federally funded programs is a 

recurring issue in Congress. Two laws primarily govern noncitizen or alien 

4 2015-PH-1003, dated June 4, 2015

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 

September 30, 2022, had not received a decision. 

(Audit Report: 2016-PH-0001)

HUD Did Not Always Provide Accurate and Supported 

Certifications of State Disaster Grantee Procurement Processes | 

Issue Date: September 29, 2016

OIG audited HUD’s controls over its certifications of State disaster 

recovery grantee procurement processes to determine whether HUD’s 

certifications were accurate and supported. OIG found that HUD did not 

always provide accurate and supported certifications of State disaster 

grantee procurement processes and did not have adequate controls over 

the certification process. Due to the weaknesses identified, HUD did not 

have assurance that State grantees had proficient procurement processes 

in place, and the HUD Secretary’s certifications did not meet the intent of 

the Disaster Relief Appropriations Act of 2013.3

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 

3 Public Law 113-2, dated January 29, 2013
Report Resolution | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 46

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,5

 OIG has issued 17 

audit reports on disaster grantees with questioned costs totaling nearly 

$391.7 million related to procurement. 

In this audit, OIG made four recommendations to the Deputy Assistant 

Secretary for Grant Programs, who in turn proposed corrective actions 

on November 24, 2017. For two of the recommendations, the Deputy 

Assistant Secretary stated that the matter of the applicability of the 

Federal procurement standards at 2 CFR (Code of Federal Regulations) 

200.318 through 200.3266

 (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.7

 In the January 10, 2017, 

5 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

6 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.

7 2015-PH-1003, dated June 4, 2015

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 for Community 

Planning and Development on December 19, 2017. In January 2018, 

OIG attempted to meet with HUD regarding the recommendations 

but was unsuccessful. The issue was referred to the Deputy Secretary 

on February 27, 2018. As of September 30, 2022, OIG was awaiting a 

decision from the Deputy Secretary. 

(Audit Memorandum: 2017-CF-0801)
Report Resolution | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 47

HUD Could Improve Its Controls Over the Disposition of Real 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 risk-based monitoring 

of grantees, HUD’s controls were not always sufficient, and HUD did not 

fully implement guidance related to the applicability of change of use 

requirements after voluntary grant reductions. As a result, HUD could not 

track and monitor its interest in the properties and did not have assurance 

that grantees properly handled changes in use and properly reported 

program income. OIG recommended that the Deputy Assistant Secretary for 

Grant Programs develop a process to ensure that grantees properly report 

the addresses of assisted properties in HUD’s Integrated Disbursement and 

Information System and properly calculate and report program income from 

the disposition of these properties regularly. 

The Deputy Assistant Secretary proposed a management decision in January 

2018, which OIG rejected. OIG referred this recommendation to the Assistant 

Secretary for Community Planning and Development on February 6, 2018, 

and to the Deputy Secretary on March 26, 2018. To reach agreement, OIG 

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

March 28, 2018, the Deputy Assistant Secretary submitted a revised proposal; 

however, OIG rejected HUD’s proposal. In January 2021, OIG met with HUD 

to discuss a possible management decision. On March 8, 2021, CPD indicated 

that it was working on an updated proposal that would address the concerns 

discussed. As of September 30, 2022, OIG continues to work with CPD while 

awaiting an updated proposal. 

(Audit Report: 2017-NY-0002)

decision, the Deputy Secretary wrote that the State had certified that its 

procurement standards were equivalent to the standards at 24 CFR 85.36 

and HUD had also certified to the proficiency of the State’s policies and 

procedures. 

The Deputy Assistant Secretary also noted that the Senate Appropriations 

Committee report on fiscal year 2018 U.S. Department of TransportationHUD appropriations legislation8

 addressed this issue. In addition, the 

Deputy Assistant Secretary stated that HUD clarified its definition of 

proficient procurement processes and policies in Federal Register notices 

that it published for later disasters. Based on this information, the 

Deputy Assistant Secretary believed it was appropriate to close these two 

recommendations. OIG disagreed with the Deputy Assistant Secretary’s 

request to close these two recommendations based on the Deputy 

Secretary’s decision to resolve recommendations from OIG’s audit of 

New Jersey’s Sandy Integrated Recovery Operations and Management 

System and rejected the Deputy Assistant Secretary’s request to close the 

recommendations. 

OIG also rejected the proposed management decisions for the other 

two recommendations because the proposed actions did not address 

States that chose to certify that their procurement processes and 

standards were equivalent to the Federal procurement standards at 2 

CFR 200.318 through 200.326. OIG referred the recommendations to 

the Assistant Secretary for Community Planning and Development on 

January 25, 2018. The Assistant Secretary did not respond. OIG referred 

these recommendations to the Deputy Secretary on March 16, 2018, 

and as of September 30, 2022, had not received a decision. 

(Audit Report: 2017-PH-0002)

8 Senate Report 1115-138, dated July 27, 2017
Report Resolution | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 48

whether the State ensured that properties purchased under the 

acquisition component of the program met applicable HUD, Federal, 

and State requirements. 

OIG found that the State did not ensure that properties purchased under 

the acquisition component of its program met eligibility requirements. 

Specifically, it did not ensure that properties (1) were substantially 

damaged and (2) complied with flood hazard requirements. Further, it 

may have improperly purchased properties that did not comply with flood 

insurance requirements. As a result, the State disbursed more than $3.5 

million for ineligible properties and incentives and more than $5.9 million 

for properties that it could not show met applicable requirements, and 

HUD did not have assurance that CDBG-DR funds were used for their 

intended purpose. OIG recommended that HUD require the State to (1) 

reimburse more than $3.5 million in settlement costs and incentives paid 

for properties that did not meet eligibility requirements or should not 

have received incentives; (2) provide documentation showing that 15 

properties met requirements related to substantial damage, flood hazards, 

and flood insurance or reimburse more than $5.9 million paid to purchase 

the properties; and (3) conduct a review of the other properties purchased 

under its program to ensure that properties were eligible and reimburse 

the amount paid for any additional properties found to be ineligible. 

The Principal Deputy Assistant Secretary for Community Planning and 

Development proposed management decisions on October 8, 2019. 

OIG rejected the proposed actions and referred the recommendations 

to the Assistant Secretary for Community Planning and Development 

on September 30, 2020. As of September 30, 2022, CPD was working to 

update its proposed management decisions in conjunction with its work 

related to audit report 2019-NY-1002. OIG will continue to communicate 

with CPD to attempt to reach an agreement. 

(Audit Report: 2019-NY-1001)

HUD’s Office of Block Grant Assistance Had Not Codified the 

Community Development Block Grant Disaster Recovery 

Program | Issue Date: July 23, 2018

OIG audited the HUD Office of Block Grant Assistance’s (OBGA) CDBG 

Disaster Recovery (CDBG-DR) program and found that although OBGA 

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

the program, because it did not believe it had the authority to do so. 

However, OBGA’s use of multiple Federal Register notices to operate the 

program presented challenges to the grantees. For example, 59 grantees 

with 112 active CDBG-DR grants, which totaled more than $47.4 billion as 

of September 2017, had to follow requirements contained in 61 different 

Federal Register notices to manage the program. 

In April 2019, OBGA acknowledged that the issuance of multiple Federal 

Register notices created a compliance burden for CDBG-DR grantees, but 

it disagreed that codification was necessary. OBGA made the following 

statements to support why it will not implement the recommendation: 

(1) codification is not necessary, (2) Federal Register notices are required, 

and (3) codification has limited or no applicability for future disasters. On 

September 30, 2019, OIG referred the disagreement and recommendation 

to the Deputy Secretary for resolution and, as of September 30, 2022, was 

awaiting a decision. While the recommendation is awaiting a decision, 

HUD has sought statutory codification of the CDBG-DR program. For more 

information, see page 7 of this report.

(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 
Report Resolution | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 49

2022, OIG was awaiting a decision while continuing to work with CPD. 

(Audit Report: 2019-NY-1002)

HUD Paid Rental Subsidies To Benefit Public Housing and 

Voucher Tenants Reported as Excluded From Federal Programs or 

Deceased | Issue Date: June 25, 2019

OIG audited HUD to determine whether HUD provided public housing 

agencies (PHA) with access to the information contained in the Do Not 

Pay system. Do Not Pay is a collection of data sources, one of which is 

the General Services Administration’s System for Award Management 

(SAM) database of excluded parties. OIG found that HUD paid potentially 

improper rental subsidies to benefit 1,550 tenants who were reported as 

excluded from Federal programs. 

OIG recommended that HUD issue guidance to PHAs to ensure that 

any applicant for or tenant of public or assisted housing whose name 

appears on the SAM excluded parties list is reviewed by PHAs to 

determine eligibility, according to the requirements of 2 CFR parts 

180 and 2424. By doing so, ineligible applicants or tenants would 

not be admitted or recertified, which could result in $13.7 million in 

annual rental subsidies being put to better use. In its October 8, 2019, 

management decision, the Office of Public and Indian Housing (PIH) 

disagreed with this recommendation and submitted a legal opinion 

from HUD’s Office of General Counsel (OGC) in support of its position. 

OIG rejected this management decision because it does not resolve 

the recommendation. OIG continues to recommend that HUD issue 

guidance to PHAs to ensure that any applicant for or tenant of public or 

assisted housing whose name appears on the SAM excluded parties list 

is reviewed by PHAs to determine eligibility. Because OIG did not reach 

agreement with the Deputy Assistant Secretary for Public Housing and 

Voucher Programs, on February 19, 2020, OIG referred its disagreement 

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 an agreement was not reached, OIG referred the 

recommendations to the Deputy Secretary on February 20, 2020. In 

June 2021, OIG provided CPD with requested documentation to assist 

with preparation of the management decisions. As of September 30, 
Report Resolution | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 50

Single Audit Act Analytics Dashboard that could be used to implement 

the controls required by 2 CRF 200. However, because HUD’s operations 

are decentralized, fully implementing this dashboard at the enterprisewide level is difficult and will take considerable time. Consequently, 

HUD has entered interim solutions as management decisions that 

are not comprehensive and do not explain how HUD will implement 

an enterprise-wide solution that allows the Single Audit Accountable 

Official to perform the duties outlined in 2 CFR 200. Although OIG 

can appreciate the challenges that HUD faces in implementing this 

enterprise-wide solution, OIG cannot accept management decisions that 

do not fully address the recommendations. OIG will continue to work 

with HUD to reach an agreeable decision.

(Audit Report: 2022-FO-0004)

Opportunities Exist To Improve CPD’s Oversight of and 

Monitoring Tools for Slow-Spending Grantees | Issue Date: 

January 5, 2022

OIG audited HUD CPD’s oversight and monitoring of its CDBG-DR slowspending grantees. OIG’s objective was to assess CPD’s monitoring and 

oversight tools related to the progress of grant expenditures and determine 

the status of the grants and impacts of COVID-19 on grantee spending.

OIG found that, although CPD has tools available for the oversight and 

monitoring of its grantees, opportunities exist to improve its oversight 

and monitoring, specifically for slow-spending CDBG-DR grantees. 

OIG identified opportunities for CPD to enhance its (1) monthly 

CDBG-DR grant financial report, (2) use of Disaster Recovery Grant 

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

(4) documentation for quarterly performance report reviews, and (5) 

documentation for monitoring reviews and updating the related exhibit 

(questionnaire). Enhancing these tools may allow CPD to provide more 

to the Assistant Secretary for Public and Indian Housing. However, 

OIG did not reach agreement with the Assistant Secretary on the 

corrective actions identified in the report. Therefore, OIG referred the 

recommendation to the official serving as Deputy Secretary on March 

31, 2020, for his final decision as the Departmental Audit Resolution 

Official. HUD began scheduling regular meetings with OIG during 2021 

to attempt to reach a resolution. As of September 30, 2022, OIG had 

not received a decision from the Deputy Secretary. 

(Audit Report: 2019-KC-0002)

Independent Public Accountant’s Audit Report on the U.S. 

Department of Housing and Urban Development’s Fiscal Years 

2021 and 2022 Consolidated Financial Statements | Issue Date: 

December 09, 2021

OIG contracted with CliftonLarsonAllen LLP (CLA) to audit the financial 

statements of HUD as of and for the fiscal years ended September 30, 

2021 and 2020,1 and to provide reports on HUD’s 1) internal control over 

financial reporting; and 2) compliance with laws, regulations, contracts, 

and grant agreements and other matters. During the audit, CLA found 

that HUD did not comply with the Single Audit Act and the implementing 

guidance issued by OMB in CFR Title 2 Grants and Agreements, Part 

200 – Uniform Administrative Requirements, Cost Principles, and Audit 

Requirements for Federal Awards (2 CRF 200). 

CLA recommended that HUD establish controls to fulfill the 

responsibilities outlined for federal agencies in 2 CFR 200. However, 

OIG has not been able to reach management decision on two of the five 

recommendations. OIG referred these recommendations to the CFO on 

August 15, 2022. Since then, the OCFO has provided a second version 

of proposed management decisions, but OIG still does not agree. Based 

on conversations with HUD, it seems that HUD is trying to implement a 
Report Resolution | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 51

access and compromise. Of particular concern was the discovery of 

multiple operating web applications unknown to the Office of the Chief 

Information Officer (OCIO). 

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

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

concurred to close five recommendations based on HUD OCIO closure 

requests and associated evidence during the previous semiannual 

reporting period, leaving four open recommendations. OIG had not 

received management decisions for these four recommendations. OIG 

obtained a recommendation status update on August 30, 2022, and 

one of the open recommendations has been identified by HUD OIG as a 

priority recommendation.

(Evaluation Report: 2016-OE-0002)

HUD IT System Management and Oversight of the Section 184 

Program | Issue Date: August 13, 2018

OIG evaluated the IT systems supporting the Office of Native American 

Programs (ONAP), Indian Home Loan Guarantee Program (Section 

184 program), following concerns that HUD did not use its resources 

to address shortcomings in internal controls and lacked the ability to 

deploy a reliable IT system. OIG observed that (1) a newly developed 

IT system, called the Loan Origination System (LOS), had significant 

limitations, requiring lenders and program officials to continue to use 

a HUD legacy IT system and manual processes for maintaining files, 

servicing loans, and managing claims; (2) only 1 of 38 lenders was able 

to access and use LOS due to HUD’s inability to resolve and implement a 

user access solution; (3) LOS had no capability to conduct loan servicing 

and claims, which were still conducted using Excel spreadsheets; and 

(4) LOS lacked critical management reporting capabilities. Despite 

HUD’s investing $4 million into the development of LOS, the system did 

effective oversight of grant expenditures, better assist its grantees with 

the progress of their spending, and assist in preventing the recapture of 

funds from communities with needs that can benefit from these funds. 

OIG recommended that CPD update its policies and procedures (1B) for 

tracking expenditures related to slow-spending grantees, including steps 

for assisting the grantees to expedite spending; identifying the reasons 

for the delays with the grant; documenting the outcome of its efforts; 

and (1F) requiring grantees to identify the reason for variances between 

the actual and projected expenditures to enhance CPD’s oversight.

The Deputy Assistant Secretary proposed a management decision on March 

16, 2022, which OIG rejected. On April 14, 2022, OIG held a meeting with 

CPD to discuss the disagreements but was unable to reach a resolution. OIG 

will continue to work with CPD to reach an agreeable decision.

(Audit Report: 2022-AT-0001)

Evaluation Reports Issued Before Start of 

Period with No Managment Decision as of 

September 30, 2022

HUD Web Application Security Evaluation | Issue Date: June 6, 

2018

OIG completed a targeted web application security evaluation of HUD in 

support of a Counsel of the Inspectors General on Integrity and Efficiency 

(CIGIE) Federal cross-cutting project, making nine recommendations 

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

and mitigate critical IT vulnerabilities in its publicly accessible web 

applications. OIG identified key deficiencies in HUD’s practices that 

put HUD’s extensive collection of sensitive data, including personal 

information of private citizens, at increased risk of unauthorized 
Report Resolution | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 52

identification of questioned costs and the City’s not executing loan 

agreements and repayment schedules for loans issued to the Agency. 

OIG, therefore, recommended that HUD require the City to support 

or repay almost $13 million in questioned costs and execute loan 

agreements with the Agency for more than $139 million in principal and 

interest, including terms of repayment.

HUD’s March 2009 management decisions required the City to support 

or repay the questioned costs and execute loan agreements with specific 

loan terms for repayment. HUD reached an agreement with the City 

in 2010 to have the Agency repay the CDBG program more than $78.7 

million under a 10-year repayment plan. Final action on this decision was 

delayed by the State of California’s 2012 dissolution of redevelopment 

agencies and the subsequent establishment of the City of San Diego’s 

Successor Agency, to manage and complete the contractual obligations of 

the City’s former Redevelopment Agency. Effective September 28, 2022, 

HUD revised the open management decision to recognize additional 

returns to the CDBG program, thereby increasing the amounts recovered 

to more than $145.4 million. 

(Audit Report: 2009-LA-1005)

HUD Did Not Have Effective Controls To Ensure That Lenders 

Reported Defaults Accurately and in a Timely Manner | Issue 

Date: September 10, 2013 

OIG audited HUD’s Office of Single Family Housing to determine whether 

it had effective controls in place to ensure that lenders reported default 

information on FHA-insured loans accurately and in a timely manner. 

Lenders report default information to HUD’s Single Family Default 

Monitoring System (SFDMS). This system collects and tracks the key 

significant events that occur during a default episode. 

not satisfy all management and oversight objectives.

OIG made five recommendations. HUD and ONAP concurred with all 

five recommendations in August 2018 with a suspense of November 

26, 2018, to provide OIG with management decisions. In addition, 

two recommendations were closed during the previous semiannual 

reporting period due to the progress of OCIO’s implementing electronic 

document capabilities and resolving the lender access issue using the 

FHA Catalyst IT system. Three recommendations remained open, with 

HUD providing closure requests for all three. As of September 21, 2021, 

three recommendations remain open and HUD had closure requests for 

those. Despite the closure requests, OIG determined additional evidence 

was needed to support the closure.

(Evaluation Report: 2018-OE-0004)

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 three significantly revised 

management decisions.

The City of San Diego, California, Did Not Administer Its 

Community Development Block Grant Program in Accordance 

with HUD Requirements When Funding the City’s Redevelopment 

Agency Projects | Issue Date: December 30, 2008

OIG audited the City of San Diego’s CDBG program to determine whether 

the City administered CDBG loans issued to the City’s Redevelopment 

Agency in accordance with HUD rules and regulations. OIG found that 

the City did not properly administer its CDBG funds, including the 
Report Resolution | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 53

Fiscal Year 2019 Review of Information Systems Controls in Support 

of the Financial Statements Audit | Issue Date: December 17, 2020

OIG audited the information systems controls over HUD’s computing 

environment as part of its audit of HUD’s financial statements for fiscal year 

2019 under the Chief Financial Officer’s Act of 1990. OIG’s objective was to 

assess general controls over HUD’s computing environment for compliance 

with departmental IT policies and Federal information system security and 

financial management requirements. OIG focused its assessment on the 

general controls over HUD’s IBM mainframe general support system. 

OIG reported 4 findings and 11 recommendations. One of the findings was 

that OCIO allowed the use of two outdated software products on the IBM 

mainframe. OIG recommended that the Chief Information Officer establish 

and implement a policy specific to upgrading software that requires OCIO 

to (1) establish a timeframe for completion of upgrades, (2) document the 

specific reasons why fully upgrading software or upgrading software in a 

timely manner is not feasible, and (3) require that a waiver be obtained 

accepting the risks associated with using the outdated software. OIG 

specified that the policy should require that the waiver be approved by the 

Chief Information Officer or his or her designee.

In its original management decision, OCIO planned to provide an updated 

Software Configuration Management Policy Handbook to include 

enterprise software configuration management requirements, defined 

roles and responsibilities, and a formal waiver process. On July 18, 2022, 

OCIO submitted a revised management decision with additional actions, 

to include (1) issuing a memorandum to the program offices on the new 

policy, waiver template, and process; (2) providing training to the program 

offices on the new requirements; and (3) initiating meetings with the 

appropriate program offices. On July 20, 2022, OIG concurred with the 

revised management decision. 

Audit Report: 2021-DP-0001

OIG determined that HUD did not have effective controls to ensure that 

lenders reported default information accurately and in a timely manner. 

HUD’s controls included only minimal system error codes; basic monitoring 

of error code rates, nonreporting, and underreporting; and lender servicing 

reviews examining a sample of default information at selected lenders. 

HUD also did not have an adequate penalty process to deter future issues. 

As a result, the default data were not always accurate and timely. 

OIG recommended that HUD develop and implement a data 

management policy; resume reviews of SFDMS reporting; and implement 

a progressive penalty process for pursuing administrative action 

against lenders that fail to report, underreport, and submit inaccurate 

or unsupported data. HUD agreed with these recommendations and 

completed the corresponding actions in July 2014 and July 2015. 

OIG also recommended that HUD implement additional system error 

checks to identify potential reporting issues. In its original management 

decision, HUD agreed to modify SFDMS to create additional system error 

checks, subject to budgetary constraints. In August 2018, HUD submitted 

a revised management decision, stating that due to funding constraints, 

it had not been able to enhance the system. Instead, HUD planned to 

implement its 4-year roadmap plan, which included retiring SFDMS 

and replacing it with a more modern and robust system. HUD planned 

to submit a subsequent revised management decision upon budget 

approval. Accordingly, in May 2022, HUD submitted the subsequent 

revised management decision, which showed that FHA had moved to 

the new default reporting system in FHA Catalyst in March 2022 and 

expanded the list of fatal error codes.

On May 25, 2022, OIG agreed with the significantly revised management 

decision. 

(Audit Report: 2013-KC-0003)
Report Resolution | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 54

Significant Management Decision With 

Which OIG Disagrees

Section 5(a)(12) of the Inspector General Act, as amended, requires that 

OIG report information concerning any significant management decision 

with which OIG disagrees. 

During the reporting period, there were no reports in which OIG 

disagreed with the significant management decisions.

Federal Financial Management Improvement Act of 1996

Section 803(a) of FFMIA requires that each agency establish and maintain 

financial management systems that comply with (1) Federal financial 

management system requirements, (2) Federal accounting standards, and 

(3) the United States Standard General Ledger at the transaction level. 

Section 803(c) of FFMIA requires an agency to establish a remediation 

plan if it is determined that the agency’s financial management systems 

do not comply with the requirements of section 803(a). Section 804(b) 

of FFMIA requires OIG to report in its semiannual reports to Congress 

instances and reasons when an agency has not met the intermediate 

target dates established in its remediation plans.

As of September 30, 2022, OIG and HUD had identified noncompliance 

with the three section 803(a) elements of FFMIA. Specifically, there 

was one financial system, the Tenant Rental Assistance Certification 

System (TRACS), that was noncompliant with the three section 803(a) 

requirements. While the Office of Housing expected to complete TRACS 

remediation activities in fiscal year 2022 (March 21, 2021), the timeline 

to address TRACS’ FFMIA noncompliance was pushed back to fiscal year 

2023 (first December 31, 2022, and most recently July 2023). This delay 

is because the new TRACS release needs to address the Office of Asset 

Management and Portfolio Oversight’s Housing Opportunity Through 

Modernization Act of 2016 Final Rule and Requirements, and there have 

been delays in this process.
Whistleblower Protection Coordinator | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 55

WHISTLEBLOWER 

PROTECTION 

COORDINATOR

Whistleblowers play a critical role in keeping Government programs honest, efficient, and 

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

Inspector General (OIG), continues to ensure that HUD and OIG employees are aware of their 

rights to disclose misconduct, waste, or abuse in HUD programs without reprisal and to assist 

HUD and OIG employees in seeking redress when employees believe that they have been subject 

to retaliation for whistleblowing. OIG also investigates complaints of whistleblower retaliation by 

HUD contractors and grantees.

OIG’s Whistleblower Protection Coordinator works with HUD and OIG 

employees to provide information on

• options for disclosing misconduct, waste, or abuse in HUD 

programs; 

• statutory protections for Federal employees who make such 

disclosures; and

• how to file a complaint when an employee believes he or she has 

been retaliated against for making protected disclosures.

The OIG Whistleblower Protection Coordinator may meet with HUD 

employees individually, upon request. Generally, OIG will refer HUD 

employees with whistleblower retaliation complaints to the U.S. Office of 

Special Counsel. 

The Whistleblower Protection Coordinator also provides training to OIG 

personnel on whistleblower-related issues. OIG’s mandatory whistleblower 

training for OIG personnel is an interactive, virtual training experience 

about whistleblower rights and protections, making protected disclosures, 

and making disclosures about investigative agencies, such as OIGs. 

OIG received several complaints filed under 41 U.S.C. (United States Code) 

4712, which 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, which will 

review the complaint and, if necessary, investigate the matter and provide 

a report of findings to the HUD Secretary for a determination as to whether 

unlawful reprisal occurred.
Whistleblower Protection Coordinator | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 56

The chart below provides further information on whistleblower retaliation 

complaints received by OIG.

Number of complainants alleging 

whistleblower retaliation 54

Complaints meeting threshold requirements 

for investigation 3

Reports of finding transmitted to HUD for 

determination (pertaining to matters opened 

during previous reporting periods)

2
Peer Review | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 57

PEER REVIEW

The Dodd-Frank Wall Street Reform and Consumer Protection Act (Public Law No. 111-203), section 

989C, requires inspectors general to report the latest peer review results in their semiannual reports 

to Congress. The purpose in doing so is to enhance transparency within the Government. Both the 

Office of Audit and Office of Investigation are required to undergo a peer review of their individual 

organizations every 3 years. The purpose of the review is to ensure that the work completed by 

the respective organizations meets the applicable requirements and standards. The following is a 

summary of the status of the latest round of peer reviews: 

Table 1. Peer Reviews Conducted of HUD OIG

Type of Review Date of Peer Review Reviewing OIG Rating Outstanding Recommendations

Audits December 17, 2021 USAID OIG Pass None 

Evaluation May 12, 2020 CIGIE In Compliance None 

Investigation July 3, 20179 DHS OIG Pass None 

Table 2. Peer Reviews Conducted by HUD OIG 

Type of Review Date of Peer Review OIG Reviewed Rating Outstanding Recommendations

Audits June 24, 2022 DOE OIG Pass None 

Evaluation September 10, 2019 FHFA OIG In Compliance None 

Investigation June 5, 2020 DHS OIG Pass None 

9 The scheduled peer review for the Office of Investigation was delayed due to the pandemic. SSA OIG began a peer review during this semiannual period and the results will be reported 

out in the next semiannual report.
Appendixes | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 58

APPENDIXES

APPENDIX 1: Reports Issued

APPENDIX 2: Tables

APPENDIX 3: Inspector General Empowerment Act

APPENDIX 4: Reporting Requirements

APPENDIX 5: Acronyms and Abbreviations

APPENDIX 6: OIG Directory
Appendix 1: reports Issued | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 59

Appendix 1 - Reports Issued

Internal Audit Reports Issued

Chief Financial Officer

2022-FO-0005 HUD Did Not Comply With the Payment Integrity Information Act of 2019, 06/27/2022.

Chief Procurement Officer

2022-FO-0006 Corrective Action Verification Government Purchase Card Program and Government Travel Card Program Audit 

Recommendations, 08/24/2022.

Community Planning and Development

2022-FO-0007 Potential Fraud Schemes That Could Affect Tenant- and Project-Based Rental Assistance, HOME, and Operating Fund Programs’ 

CARES and ARP Act Funds, 09/29/2022.

2022-LA-0002 Emergency Solutions Grants CARES Act Implementation Challenges, 08/17/2022.

2022-LA-0003 Community Planning and Development, Washington, DC, Community Development Block Grant CARES Act Grantees Faced 

Challenges Using Program Funds, 09/28/2022.

Policy Development and Research

2022-LA-0004 Office of Policy Development and Research, Washington, DC, HUD Met 11 of 13 Responsibilities Stated in the Geospatial Data Act 

of 2018 for Fiscal Year 2022, 09/30/2022.
Appendix 1: reports Issued | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 60

External Audit Reports

Community Planning and Development

2022-AT-1002 The State of North Carolina Generally Had Capacity and Mostly Followed Disbursement Requirements, but Its Procurement 

Process Needs Improvement, 09/16/2022. Questioned: $2,588,362. Unsupported: $2,588,362.

Public and Indian Housing

2022-NY-1003 Long Branch Housing Authority, Long Branch, NJ, Did Not Properly Handle Income and Expenses Related to Agreements With 

Other Housing Agencies, 08/24/2022. Questioned: $2,598,312. Unsupported: $2,598,312. Better use: $697,912.

Internal Evaluation Reports Issued

Information Technology

2022-OE-0001 Fiscal Year 2022 Federal Information Security Modernization Act (FISMA) Evaluation, 09/30/2022.

Public and Indian Housing

2021-OE-0011a Risk Indicators of Lead-Based Paint Hazards in Public Housing Agencies, 09/28/2022.
Appendix 1: reports Issued | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 61

Appendix 2 - Tables

Table A

Audit Reports Issued Before Start of Period With No Management Decision as of 09/30/2022

*Significant Audit Reports Described in Previous Semiannual Reports

Report number Report title Issue date

* 2016-PH-0001 HUD Did Not Always Provide Adequate Oversight of Property Acquisition and Disposition 

Activities 06/30/2016

* 2016-PH-0005 HUD Did Not Always Provide Accurate and Supported Certifications of State Disaster Grantee 

Procurement Processes 09/29/2016

2017-CF-0801 HUD Needs To Clarify Whether Illegal-Undocumented Aliens Are Eligible for Assistance Under 

the Housing Opportunities for Persons With AIDS Program 08/21/2017

* 2017-PH-0002 HUD Did Not Provide Sufficient Guidance and Oversight To Ensure That State Disaster Grantees 

Followed Proficient Procurement Processes 09/22/2017

* 2017-NY-0002 HUD Could Improve Its Controls Over the Disposition of Real Properties Assisted With 

Community Development Block Grant Funds 09/29/2017

* 2018-FW-0002 HUD’s Office of Block Grant Assistance Had Not Codified the Community Development Block 

Grant Disaster Recovery Program 07/23/2018

* 2019-NY-1001 The State of New York Did Not Ensure That Properties Purchased Under the Acquisition 

Component of Its Program Were Eligible 03/29/2019
Appendix 1: reports Issued | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 62

Report number Report title Issue date

* 2019-NY-1002 The State of New York Did Not Ensure That Appraised Values Used by Its Program Were 

Supported and Appraisal Costs and Services Complied With Requirements 05/29/2019

* 2019-KC-0002 HUD Paid Rental Subsidies To Benefit Public Housing and Voucher Tenants Reported as 

Excluded From Federal Programs or Deceased 06/25/2019

* 2022-FO-0004 Independent Public Accountant’s Audit Report on the U.S. Department of Housing and Urban 

Development’s Fiscal Years 2021 and 2020 Consolidated Financial Statements 12/09/2021

* 2022-AT-0001 Opportunities Exist To Improve CPD’s Oversight of and Monitoring Tools for Slow-Spending 

Grantees 01/05/2022

Evaluation Reports Issued Before Start of Period With No Management Decision as of 09/30/2022

Report number Report title Issue date

2016-OE-0002 HUD Web Application Security Evaluation 06/06/2018

2018-OE-0004 HUD IT System Management and Oversight of the Section 184 Program 08/13/2018
Appendix 1: reports Issued | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 63

Table B 

Significant Audit Reports for Which Final Action Had Not Been Completed Within 12 Months After the Date of 

the Inspector General’s Report

Report number Report title Issue date Decision 

date 

Final action 

target date

2005-AT-1013

Corporacion para el Fomento Economico de la Ciudad Capital, San Juan, 

Puerto Rico, Did Not Administer Its Independent Capital Fund in Accordance 

with HUD Requirements

09/15/2005 01/11/2006 Note 2

2006-CH-1021 Housing Authority of the County of Cook, Chicago, Illinois, Had Weak Controls 

over Its Section 8 Housing Choice Voucher Program 09/30/2006 01/26/2007 09/30/2037

2010-AT-1003 The Housing Authority of Whitesburg Mismanaged Its Operations, 

Whitesburg, KY 04/28/2010 08/26/2010 11/29/2035

2011-PH-1005 The District of Columbia Did Not Administer Its HOME Program in Accordance 

With Federal Requirements, Washington, DC 12/23/2010 04/22/2011 Note 2

2011-NY-1010 The City of Buffalo Did Not Always Administer Its CDBG Program in 

Accordance With HUD Requirements, Buffalo, NY 04/15/2011 01/25/2012 Note 2

2011-AT-1018 The Municipality of San Juan, PR, Did Not Properly Manage Its HOME 

Investment Partnerships Program 09/28/2011 01/12/2012 Note 2

2012-NY-1002 The City of New York Charged Questionable Expenditures to Its HPRP, New 

York, NY 10/18/2011 02/16/2012 Note 2
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 64

Report number Report title Issue date Decision 

date 

Final action 

target date

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 Note 2

2013-PH-1001 Luzerne County Did Not Properly Evaluate, Underwrite, and Monitor a HighRisk Loan, Wilkes-Barre, PA 10/31/2012 01/31/2013 Note 1

2013-PH-0002 HUD Policies Did Not Always Ensure That Borrowers Complied With Program 

Residency Requirements 12/20/2012 04/19/2013 02/28/2023

2013-NY-1006 Nassau County Did Not Administer Its HOME Investment Partnerships 

Program in Accordance With HUD Requirements, Nassau County, NY 05/13/2013 09/06/2013 Note 2

2013-LA-1009 The City of Hawthorne Inappropriately Used Nearly $1.6 Million in HOME 

Funds for Section 8 Tenants, Hawthorne, CA 09/13/2013 01/06/2014 Note 1

2013-LA-1010 The City of Hawthorne Did Not Administer Its CDBG Program Cost Allocations 

in Accordance With HUD Rules and Requirements, Hawthorne, CA 09/20/2013 01/06/2014 Note 1

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 Note 2

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 02/23/2023

2014-AT-1001 The Municipality of Arecibo Did Not Properly Administer Its HOME Program 12/03/2013 01/24/2014 Note 2
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 65

Report number Report title Issue date Decision 

date 

Final action 

target date

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 Note 2

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 Note 2

2014-NY-0001 HUD Did Not Provide Effective Oversight of Section 202 Multifamily Project 

Refinances 02/19/2014 06/10/2014 Note 2

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 Note 2

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 Note 2

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-PH-0001 HUD Policies Did Not Always Ensure That HECM Borrowers Complied With 

Residency Requirements 09/30/2014 01/28/2015 02/28/2023
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 66

Report number Report title Issue date Decision 

date 

Final action 

target date

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 Note 2

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 Note 2

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 Note 2

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 Note 2

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 Note 2

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
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 67

Report number Report title Issue date Decision 

date 

Final action 

target date

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 Note 2

2015-PH-0004 HUD Policies Did Not Always Ensure That HECM Borrowers Complied With 

Residency Requirements 08/21/2015 12/18/2015 02/28/2023

2015-NY-1010 New York State Did Not Always Administer Its Rising Home Enhanced Buyout 

Program in Accordance With Federal and State Regulations 09/17/2015 03/01/2016 Note 2

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 Note 2

2015-LA-1009 loanDepot’s FHA-Insured Loans With Downpayment Assistance Funds Did Not 

Always Meet HUD Requirements 09/30/2015 01/12/2016 Note 1

2015-LA-1010 loanDepot’s FHA-Insured Loans With Golden State Finance Authority 

Downpayment Assistance Gifts Did Not Always Meet HUD Requirements 09/30/2015 01/12/2016 Note 1

2016-FO-0001 Audit of Fiscal Years 2015 and 2014 (Restated) Financial Statements 11/13/2015 03/24/2016 Note 2

2016-FO-0003

Additional Details To Supplement Our Fiscal Years 2015 and 2014 (Restated) 

U.S. Department of Housing and Urban Development Financial Statement 

Audit

11/18/2015 03/22/2016 Note 2

2016-DP-0801 Review of Information System Controls Over the Government National 

Mortgage Association 11/30/2015 03/30/2016 Note 2

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 Note 2
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 68

Report number Report title Issue date Decision 

date 

Final action 

target date

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 Note 2

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 Note 2

2016-PH-0001 HUD Did Not Always Provide Adequate Oversight of Property Acquisition and 

Disposition Activities 06/30/2016 02/16/2017 Note 3

2016-NY-0001 Operating Fund Calculations Were Not Always Adequately Verified 09/12/2016 12/22/2016 04/01/2025

2016-FW-1010

The State of Oklahoma Did Not Obligate and Spend Its Community 

Development Block Grant Disaster Recovery Funds in Accordance With 

Requirements

09/30/2016 01/17/2017 Note 2

2016-PH-1009 The State of New Jersey Did Not Disburse Disaster Funds to Its Contractor in 

Accordance With HUD, Federal, and Other Applicable Requirements 09/30/2016 01/27/2017 Note 1

2017-KC-0001 FHA Paid Claims for an Estimated 239,000 Properties That Servicers Did Not 

Foreclose Upon or Convey on Time 10/14/2016 02/28/2017 Note 2

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 2
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 69

Report number Report title Issue date Decision 

date 

Final action 

target date

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 Note 2

2017-LA-0002 HUD Failed To Follow Departmental Clearance Protocols for FHA Programs, 

Policies, and Operations 01/25/2017 09/22/2017 Note 2

2017-KC-1801 Final Action Memorandum: Purchaser of HUD-Insured Single-Family Property 

Settled Allegations of Causing the Submission of a False Claim 02/23/2017 02/23/2017 Note 2

2017-LA-0003 HUD Failed To Adequately Oversee FHA-Insured Loans With BorrowerFinanced Downpayment Assistance 03/03/2017 06/22/2017 Note 1

2017-PH-1001 The City of Pittsburgh, PA, Did Not Always Administer Its CDBG Program in 

Accordance With HUD and Federal Requirements 03/22/2017 07/19/2017 Note 2

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 Note 2

2017-NY-0001 HUD PIH's Required Conversion Program Was Not Adequately Implemented 05/18/2017 09/15/2017 12/31/2023

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 Note 2

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 Note 2
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 70

Report number Report title Issue date Decision 

date 

Final action 

target date

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 Note 2

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 Note 2

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 11/18/2022

2017-LA-0004 HUD Did Not Have Adequate Controls To Ensure That Servicers Properly 

Engaged in Loss Mitigation 09/14/2017 01/11/2018 Note 2

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 Note 2

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

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 Note 2

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
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 71

Report number Report title Issue date Decision 

date 

Final action 

target date

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 Note 2

2018-FW-1001 Jefferson Parish, Jefferson, LA, Did Not Always Properly Administer Its 

Rehabilitation Program 01/29/2018 05/22/2018 12/31/2022

2018-NY-1003 The Housing Authority of the City of Asbury Park, NJ, Did Not Always 

Administer Its Operating and Capital Funds in Accordance With Requirements 02/08/2018 06/07/2018 01/28/2050

2018-CF-1801

MetLife Home Loans, LLC, and a Borrower’s Son Settled Allegations of 

Failing To Comply With HUD’s Federal Housing Administration HECM Loan 

Requirements

03/23/2018 08/09/2018 Note 2

2018-KC-0001 FHA Insured $1.9 Billion in Loans to Borrowers Barred by Federal 

Requirements 03/26/2018 07/11/2018 Note 2

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 Note 2

2018-LA-0801 The Office of Native American Programs Section 184 Program Continues To 

Operate Without Adequate Oversight 3 Years After the Prior OIG Audit 08/27/2018 12/21/2018 Note 2

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 Note 2

2018-KC-0004 HUD Did Not Always Identify and Collect Partial Claims Out of Surplus 

Foreclosure Proceeds 09/20/2018 04/18/2019 Note 2

2018-LA-0005 HUD Did Not Have Adequate Controls To Ensure That Partial Claim Notes for 

FHA Loans Were Properly Tracked for Future Collection 09/21/2018 03/08/2019 Note 2
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 72

Report number Report title Issue date Decision 

date 

Final action 

target date

2018-NY-0001 HUD Did Not Adequately Administer Its Housing Counseling Program 09/24/2018 02/26/2019 04/01/2023

2018-PH-1007 The Crisfield Housing Authority, Crisfield, MD, Did Not Properly Administer Its 

Public Housing Program Operating and Capital Funds 09/25/2018 03/01/2019 03/31/2023

2018-PH-1008

The City of Erie, PA, Did Not Always Administer Its Code Enforcement 

and Community Policing Activities in Accordance With HUD and Federal 

Requirements

09/26/2018 03/07/2019 Note 2

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 Note 2

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 Note 2

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 Note 2

2019-FO-0002 Audit of the Federal Housing Administration’s Financial Statements for Fiscal 

Years 2018 and 2017 (Restated) 11/14/2018 05/30/2019 Note 1

2019-FO-0003

Additional Details To Supplement Our Fiscal Years 2018 and 2017 (Restated) 

U.S. Department of Housing and Urban Development Financial Statement 

Audit

11/15/2018 07/11/2019 Note 1

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 Note 2

2019-KC-0001 FHA Improperly Paid Partial Claims That Did Not Reinstate Their Related Loans 04/11/2019 08/02/2019 Note 2
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 73

Report number Report title Issue date Decision 

date 

Final action 

target date

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 10/05/2022

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-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-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 01/31/2023

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 Note 2

2020-KC-0001 HUD’s Purchase Card Program Had Inaccurate Records, Untimely Training, and 

Improper Purchases 01/31/2020 05/18/2020 10/24/2022

2020-KC-0002 HUD’s Travel Cards Were Used for Illegal, Improper, or Erroneous Purchases 

and Were Not Always Used When Required 01/31/2020 05/29/2020 10/24/2022

2020-AT-0801 HUD Had Not Established Deadlines for Reporting FHA-HAMP Nonincentivized 

Loan Modifications and Filing Nonincentivized Partial Claims 02/04/2020 06/01/2020 Note 2

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 Note 2
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 74

Report number Report title Issue date Decision 

date 

Final action 

target date

2020-AT-1002 The Puerto Rico Department of Housing, San Juan, PR, Should Strengthen Its 

Capacity To Administer Its Disaster Grants 03/16/2020 07/13/2020 12/30/2022

2020-CH-0003 HUD Lacked Adequate Oversight of Public Housing Agencies’ Compliance 

With the Lead Safe Housing Rule 03/18/2020 09/03/2020 04/15/2022

2020-CH-0005 HUD Needs To Improve Its Oversight of Lead in the Water of Multifamily 

Housing Units 08/21/2020 01/26/2021 Note 2

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 12/31/2022

2020-LA-0002 HUD Had Implemented Most of the Required Responsibilities Stated in the 

Geospatial Data Act of 2018 09/24/2020 01/11/2021 11/29/2022

2021-LA-1001 The City of Compton, Compton, CA, Did Not Always Administer Neighborhood 

Stabilization Program Funds in Compliance With Procedures and Regulations 10/27/2020 01/26/2021 Note 2

2021-LA-1002 Neighborhood Housing Services of Los Angeles County, Los Angeles, CA, Did 

Not Always Follow Program Requirements in Administering Its NSP2 01/05/2021 04/29/2021 Note 2

2021-PH-0002 HUD Improperly Accounted for and Managed Reimbursements It Received 

Through Rent Credits From the General Services Administration 03/29/2021 05/28/2021 05/26/2022

2021-AT-0002 HUD Did Not Fully Comply With the Payment Integrity Information Act of 

2019 05/17/2021 06/17/2021 Note 2

2021-FW-1001 Harris County Community Services Department, Houston, TX, Was Inefficient 

and Ineffective in Operating Its Hurricane Harvey Program 06/02/2021 09/14/2021 Note 2
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 75

Report number Report title Issue date Decision 

date 

Final action 

target date

2021-FW-1002

The City of Houston’s Housing and Community Development Department, 

Houston, TX, Did Not Always Ensure That Its Program Followed Procurement 

Requirements

06/21/2021 10/06/2021 10/05/2022

2021-KC-0003 HUD’s Major Program Offices Can Improve Their Preparedness To Respond to 

Upcoming Natural Disasters 07/26/2021 11/05/2021 12/31/2022

2021-KC-0004 HUD’s Office of Multifamily Housing Programs’ Complaint Process Did Not 

Ensure That Health and Safety Complaints Were Resolved in a Timely Manner 07/28/2021 09/28/2021 10/01/2024

2021-CH-0001 HUD Remains Challenged To Serve the Maximum Number of Eligible Families 

Due to Decreasing Utilization in the Housing Choice Voucher Program 09/15/2021 01/14/2022 01/13/2023

2021-FW-1003 The Bay City Housing Authority, Bay City, TX, Did Not Follow Requirements for 

Its Legal Services Contract, Administrative Costs, and Board Meetings 09/29/2021 01/26/2022 12/31/2022
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 76

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 09/30/2022

Report number Report title Issue date Decision date Final action

2022-FO-0801 Fraud Risk Inventory for the CDBG and ESG CARES Act Funds 10/12/2021 08/02/2022 09/01/2024

2022-FO-0004

Independent Public Accountant’s Audit Report on the U.S. Department of 

Housing and Urban Development’s Fiscal Years 2021 and 2020 Consolidated 

Financial Statements

12/09/2021 09/13/2022 Note 3

2022-PH-0801 HUD Did Not Always Implement Corrective Actions To Further Ensure That 

HECM Borrowers Complied With Principal Residency Requirements 12/10/2021 02/22/2022 02/28/2023

2022-KC-0001 FHA Borrowers Did Not Always Properly Receive COVID-19 Forbearances 

From Their Loan Servicers 12/15/2021 04/01/2022 03/15/2023

2022-FW-1001 The City of Houston, Houston, TX, Faced Challenges in Administering Its 

Hurricane Harvey Program and Risked Losing Its Funding 01/04/2022 04/19/2022 12/31/2022

2022-AT-0001 Opportunities Exist To Improve CPD’s Oversight of and Monitoring Tools for 

Slow-Spending Grantees 01/05/2022 04/22/2022 Note 3

2022-LA-0001 HUD Did Not Have Adequate Controls in Place To Track, Monitor, and Issue 

FHA Refunds Owed to Homeowners 01/07/2022 04/26/2022 04/26/2023

2022-NY-1001

The Buffalo Municipal Housing Authority, Buffalo, NY, Needs To Improve Its 

Management of the Commodore Perry Homes Development To Address 

Longstanding Concerns

01/11/2022 05/11/2022 10/01/2023
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 77

2022-LA-1001

The Los Angeles Homeless Services Authority, Los Angeles, CA, Did Not 

Always Administer Its Continuum of Care Program in Accordance With HUD 

Requirements

01/20/2022 04/28/2022 04/27/2023

2022-BO-0001

HUD Did Not Have Adequate Policies and Procedures for Ensuring That 

Public Housing Agencies Properly Processed Requests for Reasonable 

Accommodation

02/07/2022 05/26/2022 05/15/2023

2022-NY-0001 HUD Did Not Implement Adequate Grant Closeout and Reporting Processes 

To Ensure Consistent Application of GONE Act Requirements 03/09/2022 07/07/2022 12/30/2023

2022-KC-0002 Approximately 31,500 FHA-Insured Loans Did Not Maintain the Required 

Flood Insurance Coverage in 2020 03/22/2022 06/29/2022 06/20/2023

2022-AT-1001

The State of Florida Administered Its Housing Repair and Replacement 

Program Effectively but Not Always in a Cost-Efficient and Prudent Manner 

for the Projects and Activity Delivery Costs Reviewed

03/30/2022 09/14/2022 03/31/2023

2022-NY-1002 The Housing Authority of Plainfield, NJ, Did Not Always Comply With 

Requirements When Administering Its Public Housing Programs 03/30/2022 07/28/2022 10/31/2023

Audits Excluded: 

70 audits under repayment plans

30 audits under debt claims collection processing, formal judicial review, investigation, 

or legislative solution

Notes: 

1 Management did not meet the target date. Target date is more than 1 year old. 

2 Management did not meet the target date. Target date is less than 1 year old. 

3 No management decision
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 78

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

2014-ITED-0001 HUD Privacy Program Evaluation Report 04/30/2014 04/30/2014 Note 1

2015-OE-0001 Federal Information Security Modernization Act (FISMA) Fiscal Year 

2015 Evaluation Report 11/15/2015 11/15/2015 Note 1

2015-OE-0001 Federal Information Security Modernization Act (FISMA) Fiscal Year 

2015 Evaluation Report 11/15/2015 11/15/2015 Note 1

2015-OE-0002 HUD IT Modernization Evaluation Report 09/29/2015 09/29/2015 Note 1

2016-OE-0002 HUD Web Application Security Evaluation Report 06/07/2017 n/a Note 2

2017-OE-0007 HUD Fiscal Year 2017 Federal Information Security Modernization Act 

of 2014 (FISMA) Evaluation Report 10/31/2017 08/16/2018 Note 1

2018-OE-0001 HUD Privacy Program Evaluation Report 09/13/2018 11/27/2019 Note 1

2018-OE-0003 HUD Fiscal Year 2018 Federal Information Security Modernization Act 

of 2014 (FISMA) Evaluation Report 10/31/2018 05/27/2019 Note 1

2018-OE-0004 HUD IT System Management and Oversight of the Section 184 Program 08/13/2018 n/a Note 2

2019-OE-0002 HUD Fiscal Year 2019 Federal Information Security Modernization Act 

of 2014 (FISMA) Evaluation Report 06/24/2020 01/19/2021 Note 1
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 79

Report number Report title Issue date Decision date Final action

2019-OE-0002a HUD Personally Identifiable Information (PII) Records Protection and 

Management 06/25/2020 12/21/2020 Note 1

2020-OE-0001 HUD Fiscal Year 2020 Federal Information Security Modernization Act 

of 2014 (FISMA) Evaluation Report 11/30/2020 03/30/2021 Note 1

2021-OE-0003 HUD IT Modernization Roadmap Evaluation Report 06/29/2021 09/28/2021 Note 1
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 80

Significant Evaluation Reports Issued Within the Past 12 Months That Were Described in Previous 

Semiannual Reports for Which Final Action Had Not Been Completed as of 09/30/2022

Report number Report title Issue date Decision date Final action

2020-OE-0004 HUD's Processes for Managing IT Acquisitions 11/17/2021 05/17/2022 Note 3

2021-OE-0001 Fiscal Year 2021 Federal Information Security Modernization Act (FISMA) 

Evaluation Report 02/15/2022 09/20/2022 Note 3

Notes:

1 Management did not meet the target date. Target date is more than 1 year old.

2 No management decision (for one or more recommendations)

3 Management is working to meet the target date. Target date is less than 1 year old.
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 81

Table C

Inspector General-Issued Reports With Questioned and Unsupported Costs as of 09/30/2022 (Dollars in 

Thousands)

Audit reports Number of audit 

reports

Questioned 

costs

Unsupported 

costs

A1 For which no management decision had been made by the beginning of the reporting period 7 $397,477 $393,911

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 - 357 86

A4 For which costs were added to noncost reports 0 0 0

B1 Which were issued during the reporting period 2 5,187 5,187

B2 Which were reopened during the reporting period 0 0 0

Subtotals (A+B) 9 403,021 399,184

C For which a management decision was made during the reporting period 310 4,215 3,944

 (1)Dollar value of disallowed costs:

Due HUD 

Due program participants 

0 

3

87

4,128

87

3,857

 (2)Dollar value of costs not disallowed 0 0 0

D For which a management decision had been made not to determine costs until 

completion of litigation, legislation, or investigation 0 0 0

E For which no management decision had been made by the end of the reporting period 6

<15>11

398,806

<385,535>9

395,240

<381,973>9

10 Two audit reports also contain recommendations with funds to be put to better use.

11 The figures in brackets represent data at the recommendation level as compared to the report level. See Explanations of Tables C and D.
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 82

Table D

Inspector General-Issued Reports With Recommendations That Funds Be Put to Better Use as of 

09/30/2022 (Dollars in Thousands)

Audit reports Number of 

audit reports Dollar value

A1 For which no management decision had been made by the beginning of the reporting period 7 $11,929,164

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 - 130,698

A4 For which costs were added to noncost reports 0 0

B1 Which were issued during the reporting period 1 698

B2 Which were reopened during the reporting period 0 0

Subtotals (A+B) 8 12,060,560

C  For which a management decision was made during the reporting period 412 7,074,692

 (1) Dollar value of recommendations that were agreed to by management:

 Due HUD

 Due program participants 

2

2

6,937,979

136,713

 (2) Dollar value of recommendations that were not agreed to by management 0 0

D  For which a management decision had been made not to determine costs until completion of litigation, 

legislation, or investigation 0 0

E For which no management decision had made by the end of the reporting period 4

<4>13

4,985,868

<4,979,774>11

12 Two audit reports also contain recommendations with questioned costs. 

13 The figures in brackets represent data at the recommendation level as compared to the report level. See Explanations of Tables C and D.
Appendix 2: Tables | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 83

Explanations of Tables C and D

The Inspector General Act Amendments of 1988 require inspectors general and agency heads to report cost data on management decisions and final 

actions on audit reports. The current method of reporting at the “report” level rather than at the individual audit “recommendation” level results in 

misleading reporting of cost data. Under the Act, an audit “report” does not have a management decision or final action until all questioned cost items 

or other recommendations have a management decision or final action. Under these circumstances, the use of the “report” based rather than the 

“recommendation” based method of reporting distorts the actual agency efforts to resolve and complete action on audit recommendations. For example, 

certain cost items or recommendations could have a management decision and repayment (final action) in a short period of time. Other cost items or 

nonmonetary recommendation issues in the same audit report may be more complex, requiring a longer period of time for management’s decision or 

final action. Although management may have taken timely action on all but one of many recommendations in an audit report, the current “all or nothing” 

reporting format does not recognize its efforts.

The closing inventory for items with no management decision in tables C and D (line E) reflects figures at the report level as well as the recommendation 

level.
Appendix 3 - Inspector General Empowerment Act | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 84

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 879 outstanding (open) unimplemented 

recommendations with a combined potential cost savings of nearly 

$20 billion. The following table and charts reflect the reasons why they 

remain unimplemented:

1. 819 recommendations have active corrective action plans 

in place or valid repayment plans, but HUD has not finished 

implementing the recommendation. 

2. 60 recommendations are currently without management 

decisions (agreement between the Department and OIG), 37 

of which are beyond the 180-day statutory requirement due 

to disagreement and were reported in table A of OIG’s SAR. 

The remainder are within the 180-day limit, during which time 

management and OIG can arrive at an agreed-upon corrective 

action plan.

3. 324 open recommendations have management decisions 

in place but are currently under investigative, legislative, 

or judicial action or under a valid repayment plan and are, 

therefore, suspended pending resolution

Appendix 3 - Inspector 

General Empowerment Act

The Inspector General Empowerment Act (Public Law 114-317) (IGEA),

enacted in December 2016, contains several reporting requirements

regarding offices of inspectors general’s (OIG) semiannual reports

to Congress (SAR). Below are the U.S. Department of Housing and

Urban Development, Office of Inspector General’s (HUD OIG) statutory

requirements as stated in the IGEA, with hyperlinks to the detailed

information located on its website at www.hudoig.gov.

Summary of Reports With No Establishment 

Comment

IGEA requires OIG to report on each audit and evaluation report for 

which HUD did not return comments within 60 days of OIG’s providing 

the report to the Department.

There are no instances of reports with no establishment comment this 

semiannual reporting period. 
Appendix 3 - Inspector General Empowerment Act | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 85

Calendar 

year

Number of open 

recommendations

Cumulative estimated 

cost savings from open 

recommendations

2012 12 10,318,051

2013 42 51,846,583

2014 65 240,556,432

2015 66 318,755,612

2016 102 7,271,889,327

2017 126 629,189,007

2018 86 2,834,220,235

2019 63 6,660,743,216

2020 35 1,296,315

2021 52 18,720,503

202214 86 1,523,734,945

Total 879 19,712,853,489

14 Data as of 9/30/2022 for the calendar year.

Office of Audit Summary

Calendar 

year

Number of open 

recommendations

Cumulative estimated 

cost savings from open 

recommendations

Pre-2001 2 $1,688,555

2001 1 120,000

2002 3 83,604

2003 12 1,746,990

2004 6 8,044,077

2005 5 2,999,361

2006 12 8,829,704

2007 14 4,899,125

2008 26 7,001,295

2009 18 4,822,283

2010 13 15,796,445

2011 32 95,551,824
Appendix 3 - Inspector General Empowerment Act | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 86

Office of Evaluation

OE conducts evaluations focused on improving departmental operations and programs. OE’s recommendations do not focus on direct cost savings but, 

rather, on improving program effectiveness, reducing the likelihood of negative outcomes, and addressing HUD’s top management challenges.

Calendar year Number of open recommendations

2013 0

2014 3

2015 3

2016 0

2017 5

2018 19

2019 0

2020 29

2021 15

2022 27

Total 101
Appendix 3 - Inspector General Empowerment Act | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 87

Statistical Table Showing Investigative Report Metrics

The data used in this statistical table were extracted from OIG’s Case Management System. The Case Management System and its underlying 

infrastructure allow for data input and maintain data integrity during the complete investigative case cycle, while ensuring data privacy and 

confidentiality. The system was developed in .Net 4.7.2, and the database is SQL 2017. OIG develops queries to extract data from the Case Management 

System to meet business requirements, such as the information used to create this statistical table. The footnotes provide additional guidance pertaining 

to each requested category of information. 

Reporting Period: Fiscal Year (FY) 2022, Period 2 (SAR 88), April 2021 Through September 30, 2022

Measure Total

A. Total number of investigative reports issued during the reporting period15 89

B. Total number of persons referred to the U.S. Department of Justice for 

criminal prosecution during the reporting period 104

C. Total number of persons referred to State and local prosecuting authorities 

for criminal prosecution during the reporting period 31

D. Total number of indictments and criminal informations during the reporting 

period that resulted from any prior referral to prosecuting authorities16 45

15 Includes approved reports of investigation

16 Includes all charging documents reported: criminal complaints, indictments, informations, and superseding indictments
Appendix 3: Inspector General Empowerement Act | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 88

Investigations of Senior Government 

Employees

The IGEA requires OIG to summarize in the SAR each investigation 

involving a senior government employee when allegations of misconduct 

were substantiated. Listed below are the cases for this reporting period.

• HUD OIG initiated an investigation based on allegations that a GS-15 

program analyst formerly employed within HUD’s Office of the Chief 

Information Officer may have provided nonpublic HUD information 

to representatives of a private firm. The investigation found that the 

employee provided a HUD budget portfolio document not authorized 

for public release to a senior official of a private firm in violation 

of 5 CFR (Code of Federal Regulations) 2635.702 and 2635.703, 

which prohibit the use of public office and nonpublic information for 

private gain. HUD OIG referred these findings to the appropriate U.S. 

Attorney’s Office for prosecutorial consideration and no prosecution 

resulted. HUD OIG also referred its findings in this matter to HUD for 

any administrative action it deems appropriate.

• HUD OIG initiated an investigation based on allegations that Lynne 

Patton, then HUD Regional Administrator, may have violated various 

Federal ethics laws by participating in the production of a video 

that aired at a national political convention. The investigation found 

that Patton used or allowed the use of her government position to 

solicit participation in the video by tenants from a housing authority 

she oversaw and created the appearance that she was participating 

in the production of the video on behalf of HUD in violation of 5 

CFR 2635.702 and 2635.101(b)(14), which prohibit the use of public 

office for private gain and creating the appearance of unlawful 

conduct. The investigation found further that Patton used the 

official time of her subordinates in a questionable manner, used 

her personal phone to conduct official HUD business, and did not 

meet her obligation to cooperate fully with HUD OIG’s investigation. 

HUD OIG referred these findings to the appropriate U.S. Attorney’s 

Office for prosecutorial consideration, and no prosecution resulted. 

HUD OIG also referred its findings in this matter to HUD for any 

administrative action it deems appropriate.
Appendix 3: Inspector General Empowerement Act | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 89

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, evaluation, and investigation conducted by the office that is 

closed during the reporting period and was not disclosed to the public.

Office of Investigation

• HUD OIG conducted an investigation relating to another OIG at that 

OIG’s request.

• HUD OIG conducted an investigation relating to another OIG in 

support of the Council of the Inspectors General on Integrity and 

Efficiency’s Integrity Committee.

• HUD OIG initiated an investigation based on allegations that a 

former senior HUD official published a book containing nonpublic 

HUD information in violation of regulations regarding the use of 

departmental records. The investigation did not substantiate the 

allegations, and the matter was neither presented for prosecution 

nor referred to HUD.

• HUD OIG initiated an investigation based on allegations referred 

from the Office of Special Counsel that (1) a senior official’s former 

ownership of a HUD subcontractor created the appearance of 

a conflict of interest and (2) three other senior officials may 

have engaged in gross mismanagement by underfunding and 

mishandling certain HUD contracts or activities. The HUD OIG 

investigation did not substantiate either allegation, and HUD OIG 

provided its findings in this matter to HUD for transmittal to the 

Office of Special Counsel.

Instances of Whistleblower Retaliation

The IGEA requires OIG to include in the SAR a detailed description of 

any instance of whistleblower retaliation, including information about 

the official found to have engaged in retaliation and what, if any, 

consequences the establishment imposed to hold that official accountable. 

• HUD OIG has no instances of whistleblower retaliation to report for 

this period. OSI made two referrals to the Department during this 

reporting period finding that complainants had established a prima 

facie case of retaliation under Section 4712 but, consistent with HUD 

OIG’s practice during the last reporting period, OSI is not including 

summaries of those referrals because Section 4712 requires the 

Department to determine whether retaliation took place and the 

Department has made no such determination in these matters.

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.
Appendix 3: Inspector General Empowerement Act | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 90

Office of Evaluation

Fiscal Year 2022 Federal Information Security Modernization Act 

(FISMA) Evaluation Report: September 30, 2022

OIG assessed HUD’s information security (IS) program for effectiveness 

in accordance with FISMA, which directs OIGs to conduct an evaluation 

using the OIG FISMA metrics. The metrics consist 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 continued to take positive steps to improve its information technology 

(IT) security posture. However, OMB modified the FISMA evaluation 

methodology in FY 2022, asking IG’s to evaluate 20 core metrics instead of 

approximately 60 FISMA metric that had been assessed in previous years. 

Based on the FY 2022 FISMA Core IG [Inspector General] Metrics issued by 

the Office of Management and Budget, HUD’s IS program was evaluated 

as not effective. Significant limitations and challenges continue to impact 

the Office of the Chief Information Officer’s ability to establish an effective 

IS program. The longstanding inability to modernize key IT systems and 

consistently implement enterprise efforts, as well as budget and resource 

constraints in FY 2022, affected HUD’s ability to mature. This outcome is 

despite HUD’s increasing maturity in 3 of the 20 core metrics, remaining 

at the same maturity level for 16 of the 20 core metrics, and dropping in 

maturity for 1 core metric. 

HUD continued to make significant progress in addressing OIG’s 

prior years’ recommendations. During FY 2022, HUD closed 21 

prior FISMA recommendations. In this report, OIG issued five new 

recommendations and offered opportunities for improvement for the 

enterprise and the program offices. 

(Agencywide, Evaluation Report: 2022-OE-0001)
Appendix 4 - Reporting Requirements | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 91

Appendix 4 - Reporting Requirements

The specific reporting requirements as prescribed by the Inspector General Act of 1978, as amended by the Inspector General Act of 1988, are listed 

below.

Source requirement Pages

Section 4(a)(2) - review of existing and proposed legislation and regulations. 26-43

Section 5(a)(1) – description of significant problems, abuses, and deficiencies relating to the 

administration of programs and operations of the Department. 13-22, 55-56

Section 5(a)(2) – description of recommendations for corrective action with respect to significant 

problems, abuses, and deficiencies. 44-54

Section 5(a)(3) – identification of each significant recommendation described in previous 

Semiannual Reports on which corrective action has not been completed.

Appendix 2, 

Table B, 63

Section 5(a)(4) – summary of matters referred to prosecutive authorities and the prosecutions 

and convictions that have resulted. 13-22

Section 5(a)(5) – summary of reports made on instances where information or assistance was 

unreasonably refused or not provided, as required by Section 6(b)(2) of the Act. no instances

Section 5(a)(6) – listing of each audit report completed during the reporting period, and for each 

report, where applicable, the total dollar value of questioned and unsupported costs and dollar 

value of recommendations that funds be put to better use.

Appendix 1, 

59

Section 5(a)(7) – summary of each particularly significant report. 13-22
Appendix 4 - Reporting Requirements | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 92

Source requirement Pages

Section 5(a)(8) – statistical tables showing the total number of adult reports and the total dollar 

value of questioned and unsupported costs.

Appendix 2, 

Table C, 81

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, 82

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 

Table A, 59

Section 5(a)(11) – a description and explanation of the reasons for any significant revised 

management decisions made during the reporting period. 52-53

Section 5(a)(12) – information concerning any significant management decision with which the 

Inspector General is in disagreement. No instances

Section 5(a)(13) – the information described under section 05(b) of the Federal Financial 

Management Improvement Act of 1996. 54
Appendix 5 - Acronyms and Abbreviations | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 93

Appendix 5 - Acronyms and 

Abbreviations

BAP Buy America Domestic Content Procurement Preference

CARES Act Coronavirus Aid, Relief, and Economic Security Act

CAV corrective action verification

CDBG Community Development Block Grant

CDBG-DR Community Development Block Grant Disaster Recovery

CFR Code of Federal Regulations

CLA CliftonLarsonAllen LLP

CIGIE Council of the Inspectors General on Integrity and 

Efficiency

CPD Office of Community Planning and Development

DHS U.S. Department of Homeland Security

DOE U.S. Department of Energy

DOJ U.S. Department of Justice

ESG Emergency Solutions Grant

ESG-CV Emergency Solutions Grant CARES Act

ESS Environmental Shared Services office

FFMIA Federal Financial Management Improvement Act

FHA Federal Housing Administration

FHFA Federal Housing Finance Agency

FISMA Federal Information Security Modernization Act of 2014

FMR fair market rent

FR Federal Register

FSS Family Self-Sufficiency

FY fiscal year

HCV Housing Choice Voucher

HOPWA Housing Opportunities for Persons With AIDS

HOTMA Housing Opportunity Through Modernization Act of 2016

HTF Housing Trust Fund

HUD U.S. Department of Housing and Urban Development

HUD-VASH HUD-Veterans Affairs Supportive Housing

IDIS Integrated Disbursement and Information System

IG Inspector General

IGEA Inspector General Empowerment Act

ICDBG Indian Community Development Block Grant

IHBG Indian Housing Block Grant

IHBG-ARP Indian Housing Block Grant American Rescue Plan Act

IS information security

IT information technology

LOS Loan Origination System

MAP multifamily accelerated processing

MIP mortgage insurance premium

NAHASDA Native American Housing Assistance and SelfDetermination Act of 1996

OBGA Office of Block Grant Assistance

OCIO Office of the Chief Information Officer

OE Office of Evaluation

OIG Office of Inspector General

OLHCHH Office of Lead Hazard Control and Healthy Homes

OMB Office of Management and Budget

ONAP Office of Native American Programs

ORCF Office of Residential Care Facilities

PBRA project-based rental assistance

PHA public housing agency

PIH Office of Public and Indian Housing

PIH-TBRA Office of Public and Indian Housing, Tenant-Based Rental 

 Assistance

PIIA Payment Integrity Information Act of 2019

PRWORA Personal Responsibility and Work Opportunity 

Reconciliation Act
Appendix 5 - Acronyms and Abbreviations | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 94

PSH Permanent Supportive Housing

RFIF renewal funding inflation factor

RVI remote video inspection

SAM System for Award Management

SAR Semiannual Report to Congress

SFDMS Single Family Default Monitoring System

TBRA tenant-based rental assistance

TDHE tribally designated housing entity

TRACS Tenant Rental Assistance Certification System

UEI unique entity identifier

USAID U.S. Agency for International Development

U.S.C. United States Code

VASH Veterans Affairs Supportive Housing

 
APPENDIX 6: OIG DIRECTORY | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 95 

Appendix 6 - OIG Directory

Office of Audit

Headquarters Washington, DC 202-708-0364

Fair Housing Audit 

Division 

Boston, MA

Hartford, CT

Philadelphia, PA

Baltimore, MD

Pittsburgh, PA

Richmond, VA

617-994-8380

860-240-9739

215-656-0500

410-962-2520

412-644-6428

800-842-2610

Single Family Housing 

(Originations)-Multifamily 

Insurance Audit Division 

New York, NY

Buffalo, NY

Newark, NJ

212-264-4174

716-551-5755

973-622-7900

Disaster Recovery Audit 

Division (East)

Atlanta, GA

Greensboro, NC

Miami, FL

San Juan, PR

404-331-3369

336-547-4001

305-536-5387

787-766-5540

Rental Assistance-Safe 

and Affordable Housing 

Audit Division 

Chicago, IL

Columbus, OH

Detroit, MI

312-913-8499

614-280-6138

313-226-6190

Disaster Recovery Audit 

Division (West)

Fort Worth, TX

Baton Rouge, LA

Houston, TX 

New Orleans, LA

Oklahoma City, OK

San Antonio, TX 

817-978-9309

225-448-3975

713-718-3199

504-671-3000

405-609-8606

210-475-6800

Ginnie Mae-Single 

Family Housing 

(Servicing) Audit Division

Kansas City, KS

Denver, CO

913-551-5870

303-672-5471

Grants Management Los Angeles, CA

Phoenix, AZ

San Francisco, CA

213-894-8016

602-379-7250

415-489-6400

Office of Evaluation

Headquarters Washington, DC evaluations@hudoig.gov
APPENDIX 6: OIG DIRECTORY | HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 96 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Office of Investigation

Headquarters Washington, DC (202)708-0390

Northeast Region Boston, MA (617) 994-8450

Buffalo, NY (716) 646-7105

Hartford, CT (860) 240-4800

Newark, NJ (973) 776-7342

New York, NY (212) 542-7294

MidAtlantic Region Alexandria, VA 

Baltimore, MD 

Cleveland, OH

Columbus, OH 

Indianapolis, IN 

Philadelphia, PA 

Pittsburgh, PA

Richmond, VA

Southeast Region Atlanta, GA

Birmingham, AL

Greensboro, NC

Miami, FL

San Juan, PR

Tampa, FL

(206) 498-6461

(410) 962-2520

(216) 357-7800

(614) 280-6137

(317) 226-6303

(215) 430-6758

(412) 644-6598

(804) 771-2100

(404) 331-5001

(205) 731-2630

(336) 547-4000

(305) 536-3087

(787) 766-5872

(813) 596-5764

Midwest Region Chicago, IL (312) 353-4196

Detroit, MI (313) 226-7900

Kansas City, KS (913) 551-5866

St. Louis, MO (314) 539-6278

South Central Region Baton Rouge, LA (225) 448-3941

Fort Worth, TX (817) 978-5440

Houston, TX (713) 718-3097

New Orleans, LA (504) 671-3700

Western Region Denver, CO

Los Angeles, CA

Phoenix, AZ

San Francisco, CA

(303) 672-5350

(213) 894-8000

(602) 379-7251

(415) 489-6400
HUD OIG Semiannual Report to Congress BACK TO TABLE OF CONTENTS | PAGE 97

WWW.HUDOIG.GOV

Report fraud, waste, and mismanagement

in HUD programs and operations by

Calling the HUD OIG hotline: 

1-800-347-3735

Visiting online at

https://www.hudoig.gov/hotline

Report #88 Scan to report fraud