Audit of the CFPB’s Consumer Response Operations
Pursuant to the Dodd-Frank Act, the CFPB’s Office of Consumer Response collects, monitors, and responds to consumer complaints on financial services and products. The CFPB uses these consumer complaints to help inform the agency’s supervision activities, enforce federal consumer financial laws, and write rules and regulations. With an increase in consumer complaints as a result of the COVID-19 pandemic, Consumer Response faces an operational risk with respect to the timeliness in which it can respond to consumer complaints. We plan to assess the effectiveness of the CFPB’s processes for reviewing and responding to consumer complaints.
Evaluation of the Paycheck Protection Program Liquidity Facility’s (PPPLF) Credit Extension Repayment and At-Risk Loan Monitoring Efforts
In response to the COVID-19 pandemic, the Board established the PPPLF to extend credit to financial institutions that originate loans through the U.S. Small Business Administration’s guaranteed Paycheck Protection Program (PPP), taking the PPP loans as collateral. The PPPLF, managed by the Federal Reserve Bank of Minneapolis and operated out of the 12 Federal Reserve Banks, distributed billions of dollars to eligible lenders. We will assess the effectiveness of internal controls to (1) determine lender eligibility, extend credit, and process repayments and (2) identify at-risk advances, handle instances of nonpayment, and detect and mitigate fraud. We also plan to assess the extent to which the Federal Reserve System coordinates with the U.S. Small Business Administration to determine lender eligibility, recover losses due to nonpayment, and detect and mitigate fraud.
Evaluation of the Federal Reserve System’s Loan Administration Processes for Its Main Street Lending Program (MSLP)
In response to the COVID-19 pandemic, the Board established the MSLP—composed of five different lending facilities—to facilitate lending to small and medium-sized for-profit and nonprofit organizations. Through the MSLP, the Federal Reserve Bank of Boston is responsible for administering the loans, including assessing overall credit risk and identifying substandard loans. We plan to assess the MSLP’s processes for loan administration, including the design and operating effectiveness of internal controls.
Disaster Preparedness of Federal Agencies
HUD OIG will summarize the conclusions/findings and recommendations reported by seven participating OIGs and the General Accountability Office related to natural disaster preparedness. Our objective is to inform Federal agencies and the OIG community of the reported conclusions/findings and recommendations regarding preparing for and responding to natural disasters.
Public and Indian Housing Supplemental Operating Funds
HUD OIG is conducting a limited review of HUD's administration of supplemental operating funds under the CARES Act. The CARES Act authorized an additional $685 million in public housing operating funds to prevent, prepare for, and respond to COVID-19. The review objective is to assess Public Housing Agencies' (PHA) experiences and challenges and HUD's efforts in providing guidance related to the administration of supplemental operating funds under the CARES Act.
Monitoring of the Federal Reserve’s Lending Programs
In response to the economic effects of the coronavirus pandemic, the Federal Reserve recently announced that it would create new lending facilities to provide loans to employers, certain businesses, and communities across the country to support the U.S. economy. Specifically, the following programs have been created or are in development: the Main Street Lending Program, the Paycheck Protection Program Liquidity Facility, the Municipal Liquidity Facility, the Primary Market Corporate Credit Facility, and the Secondary Market Corporate Credit Facility. We are initiating an active monitoring effort of these programs to gain an understanding of operational, governance, reputational, and financial matters associated with them. Through this monitoring effort, we will refine our focus on the programs and identify areas for future audits or evaluations. Some of the topics we are considering include the design, operation, governance, and oversight of the lending programs; data collection and reporting associated with the programs; and the effect of the programs on the Board’s supervision and regulation activities.
FHA Default Reporting
The purpose of this memorandum is to notify you that we are researching prior audits of HUD’s Single Family Default Monitoring System to provide HUD information regarding lessons learned and risks identified in these prior audits that HUD should act on now to ensure program integrity and mitigate the risk of financial loss for COVID-19 related forbearance assistance and foreclosure moratorium related to single family loans.
FHA Partial Claims
The purpose of this memorandum is to notify you that we are researching prior audits of HUD’s partial claims loss mitigation option to provide HUD information regarding lessons learned and risks identified in these prior audits that HUD should act on now to ensure program integrity and mitigate the risk of financial loss for COVID-19 related partial claims.
Public and Indian Housing and Multifamily Vacancies During a Disaster Declaration
HUD OIG is researching Public and Indian Housing and Multifamily use of vacant units during previously Presidentially Declared Disasters and the COVID-19 declared Disaster, as well as PIH and Multifamily’s ability to place a waitlist preference for the homeless and how many homeless individuals had a 50058 or 50059 new move-in during the COVID pandemic. Since the introduction of the CARES act, there has been an emphasis to review how HUD has reacted to the COVID-19 disaster. HUD allocated $1 billion to keep America's homeless population safe. The purpose of this research is to issue memorandums for both PIH and Multifamily addressing the research topics.
Key Considerations and Lessons Learned From Prior Audits of FHA Partial Claims
HUD OIG is researching prior audits of HUD’s partial claims loss mitigation option. On July 8, 2020, FHA issued Mortgagee Letter 2020-22 informing mortgagees the full suite of loss mitigations available to single family borrowers affected by the COVID-19 pandemic. The purpose of this research is to provide HUD information regarding lessons learned and risks identified in these prior audits that HUD should act on now to ensure program integrity and mitigate the risk of financial loss for COVID-19 related partial claims.