ONAP COVID-19 Recovery Programs Implementation Challenges
HUD OIG is auditing HUD’s ONAP COVID 19 Recovery Program, which includes funds provided by the Coronavirus Aid, Relief, and Economic Security (CARES) and American Rescue Plan (ARP) Acts. Congress provided over $1 billion in ONAP CARES and ARP grant formula and competitive funding. Our objective is to determine the challenges that Native American and Hawaiian tribes face in implementing and utilizing the funding provided by the CARES and ARP Acts and how ONAP has helped the tribes navigate the COVID-19 recovery programs available.
External COVID-19 Loss Mitigation
HUD OIG is conducting a review of a nationwide mortgage servicing company that provides servicing and origination for FHA loans. In the summer of 2021, FHA introduced new recovery loss mitigation options for borrowers exiting forbearance, which will provide a path to deep and sustained recovery for borrowers who were significantly impacted by the pandemic by reinstating their loans from a delinquent to current status. Our objective is to determine if the servicer provided all available options to borrowers with FHA insured loans to help them stay in their homes after the COVID-19 forbearance ended.
COVID-19 Loss Mitigation
HUD OIG is conducting an audit of COVID-19 loss mitigation. In the summer of 2021, FHA introduced new recovery loss mitigation options for borrowers exiting forbearance, which will provide a path to deep and sustained recovery for borrowers who were significantly impacted by the pandemic by reinstating their loans from a delinquent to current status. Our audit objective is to determine if delinquent borrowers of FHA-insured loans received all available options to stay in their homes after forbearance ended.
Fraud Risk Management Assessment and Fraud Risk Identification
HUD OIG is conducting an audit to assess HUD’s overall fraud risk management program, and to identify fraud risks for funds that HUD received from the Coronavirus Aid Recovery and Economic Stability Act and American Rescue Plan Act. Our objectives are to 1) assess HUD’s progress in implementing a fraud risk management framework, at the enterprise and program office levels, that encompasses control activities to prevent, detect, and respond to fraud; and 2) develop an inventory of fraud risks that HUD has not already identified for the funds appropriated by the CARES and ARP Acts for the Tenant-Based Rental Assistance, Project-Based Rental Assistance, HOME Investment Partnerships, and Public Housing Operating Fund program.
Evaluation of the Federal Reserve System’s Loan Purchase and Administration for Its Main Street Lending Program (MSLP)
In response to the COVID-19 pandemic, the Federal Reserve System 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 (FRB Boston) purchased 1,830 loans amounting to approximately $17.5 billion from lenders; the majority of these loans were purchased during the last 2 months of the program. Following the purchase of the loans, FRB Boston is now responsible for administering the loans, including assessing overall credit risk and identifying substandard loans. FRB Boston leveraged third-party vendors to support both loan purchases and loan administration. We plan to assess the MSLP’s processes for loan purchases and loan administration, including the design, implementation, and operating effectiveness of internal controls.
Evaluation of the Federal Reserve System’s Vendor Selection and Management Processes Related to the Federal Reserve Bank of New York’s Emergency Lending Programs
As part of its emergency lending program, FRB New York operated six emergency lending facilities, five of which were supported by multiple vendor contracts. FRB New York awarded some of its emergency lending program–related contracts noncompetitively because of the exigent circumstances, and other contracts pose potential conflict-of-interest risks to the System. FRB New York’s reliance on vendors highlights the importance of its monitoring of vendor performance. We plan to assess the Board’s and FRB New York’s processes related to vendor selection and management for FRB New York’s emergency lending programs.
CDBG CARES Act Grantee Challenges
HUD OIG is reviewing HUD’s Office of Community Planning and Development’s (CPD) HUD’s Coronavirus Aid, Relief, and Economic Security (CARES) Act, Community Development Block Grants (CDBG-CV) program. The CARES Act provided $4.9 billion in CCDBG-CV funds to be used to prevent, prepare for, and respond to coronavirus. Our objective is to determine what challenges grantees faced in obligating and spending their allocated CDBG-CV funds for activities that prepare for, prevent, or respond to COVID-19 and its impact.
HUD’s Office of Community Planning and Development’s (CPD) Coronavirus Aid, Relief, and Economic Security Act, Emergency Solutions Grants (ESG-CV) program
HUD OIG is reviewing HUD’s Office of Community Planning and Development’s (CPD) Coronavirus Aid, Relief, and Economic Security Act, Emergency Solutions Grants (ESG-CV) program. The CARES Act provided $4 billion in ESG-CV funds to be used to prevent, prepare for, and respond to coronavirus, among individuals and families who are homeless or receiving homeless assistance. Our objective is to determine what challenges grantees of ESG-CV funds have faced in implementing the program and utilizing grant funds.
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.
Temporary Endorsement Policy Related to COVID-19 Forbearance Activity
HUD OIG is auditing HUD’s administration of its temporary endorsement policy related to COVID-19 forbearance activity. The temporary policy allowed mortgagees to endorse mortgages that were placed into forbearance prior to endorsement as long as they met certain requirements and executed a 2-year partial indemnification agreement. Our objectives are to determine whether the policy was properly followed by mortgagees, review HUD’s plan to monitor and enforce the indemnification agreements, and review HUD’s decision to end the policy.