Recommendation: The Secretary of Housing and Urban Development should direct the Chief Information Officer, Senior Agency Official for Privacy, and Chief Privacy Officer to review and revise department-level security and privacy policies to ensure that they require the implementation of risk-based security and privacy controls for external entities that process, store, or share sensitive information with HUD. (Recommendation 1)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Housing and Urban Development should direct the Chief Information Officer, Senior Agency Official for Privacy, and Chief Privacy Officer to review and revise department-level security and privacy policies to ensure that they require independent assessments of external entities that process, store, or share sensitive information with HUD to ensure controls are implemented. (Recommendation 2)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Housing and Urban Development should direct the Chief Information Officer, Senior Agency Official for Privacy, and Chief Privacy Officer to review and revise department-level security and privacy policies to ensure that they require identifying and tracking corrective action needed by external entities that process, store, or share sensitive information with HUD. (Recommendation 3)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Housing and Urban Development should direct the Chief Information Officer, Senior Agency Official for Privacy, and Chief Privacy Officer to review and revise department-level security and privacy policies to ensure that they require monitoring of progress in implementing controls/corrective actions by external entities that process, store, or share sensitive information with HUD. (Recommendation 4)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Housing and Urban Development should direct the Chief Information Officer, Senior Agency Official for Privacy, and Chief Privacy Officer to develop and maintain a comprehensive systems inventory that incorporates sufficient, reliable information about the external entities with which HUD program information is shared and the extent to which each external entity has access to PII and other sensitive information. (Recommendation 5)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The FHA Commissioner should take steps to improve the quality and accuracy of HECM termination data. These steps may include updating the termination reasons in the HERMIT system or updating the HERMIT User Guide to more clearly instruct servicers how to record termination reasons. (Recommendation 1)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The FHA Commissioner should establish, periodically review, and report on performance indicators for the HECM program—such as the percentage of terminations due to borrower defaults, the proportion of active HECMs with delinquent property charges, the amount of servicer advances, and the percentage of distressed borrowers who have received foreclosure prevention options—and examine the impact of foreclosure prevention options in the forthcoming HECM program evaluation. (Recommendation 2)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The FHA Commissioner should develop analytic tools, such as dashboards or watch lists, to better monitor outcomes for the HECM portfolio, such as reasons for HECM terminations, defaults, use of foreclosure prevention options, or advances paid by servicers on behalf of HECM borrowers. (Recommendation 3)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The FHA Commissioner should evaluate FHA's foreclosure prioritization process for FHA-assigned loans. Such an analysis should include the implications that the process may have for HECM borrowers, neighborhoods, and FHA's insurance fund. (Recommendation 4)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The FHA Commissioner should develop and implement procedures for conducting on-site reviews of HECM servicers, including a risk-rating system for prioritizing and determining the frequency of reviews. (Recommendation 5)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

Comments: As of February 2020, FHA had taken steps to implement this recommendation--including developing a HECM Servicing Review Guide and scheduling reviews of the three largest HECM servicers--but had not finalized a risk-rating system for prioritizing and determining the frequency of additional HECM servicing reviews. We will update the status of the recommendation when FHA provides documentation of a risk-rating system for prioritizing and determining the frequency of reviews and has completed the three reviews scheduled for fiscal year 2020.

Recommendation: The FHA Commissioner should work with CFPB to complete an agreement for sharing the results of CFPB examinations of HECM servicers with FHA. (Recommendation 6)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The CFPB Director should work with FHA to complete an agreement for sharing the results of CFPB examinations of HECM servicers with FHA. (Recommendation 7)

Agency: Consumer Financial Protection Bureau
Status: Open

Comments: As of April 2020, CFPB has begun to take steps to complete an information sharing agreement to facilitate the process of sharing confidential information with FHA, including the results of HECM examinations. However, work on the agreement remains ongoing and CFPB noted it looks forward to finalizing the agreement as soon as practicable.

Recommendation: The FHA Commissioner should periodically analyze available internal and external consumer complaint data about reverse mortgages to help inform management and oversight of the HECM program. (Recommendation 9)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

Comments: As of March 2020, FHA had taken steps to implement this recommendation, including using a different system to collect and record consumer complaints about HECMs and generating monthly reports on the information for FHA senior management. We will update the status of the recommendation when FHA provides documentation showing that it also periodically analyzes external consumer complaint data on HECMs.

Recommendation: The Commissioner of FHA should clearly define DASP objectives and develop measurable targets for all program objectives. (Recommendation 3)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

Comments: HUD issued Standard Operating Procedures for these sales on October 17, 2019. We will continue to follow up with the agency on how it defines the DASP objectives and its development of measurable targets for the program objectives.

Recommendation: The Commissioner of FHA should use performance data to develop criteria for when to hold DASP sales. (Recommendation 4)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

Comments: HUD issued a Standard Operating Procedure for these sales on October 17, 2019. However, HUD has not yet developed criteria for when to hold a DASP sale based on performance criteria.

Recommendation: The Commissioner of FHA should monitor individual purchasers' compliance with FHA's modification requirements and ensure the purchasers submit the data needed to evaluate the sustainability of modifications. (Recommendation 6)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

Comments: HUD issued s Standard Operating Procedure for these sales on October 17, 2019. However, HUD has not yet addressed purchasers' compliance with FHA's modification requirements to ensure that purchasers submit the data needed to evaluate the sustainability of modifications. We will continue to follow up on the agency's response to this recommendation.

Recommendation: The Commissioner of FHA should develop a methodology to assess the range of possible outcomes for loans when setting DASP reserve prices. (Recommendation 8)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

Comments: HUD issued a Standard Operating Procedure for these sales on October, 17, 2019. The procedures address reserve pricing but we will continue to follow up with the agency on any plans to develop a methodology to assess the range of possible outcomes when setting the reserve prices.

Recommendation: Congress should consider requiring Ginnie Mae to evaluate the adequacy of its current guaranty fee for single-family mortgage-backed securities and report to Congress with recommendations, if any, on revising the fee, such as by adopting standards under which the fee should be determined. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: As of September 2020, Congress had not enacted legislation to require Ginnie Mae to evaluate the adequacy of its current guaranty fee for single-family mortgage-backed securities and report to Congress with recommendations.

Recommendation: Congress should consider requiring Ginnie Mae to evaluate its reliance on contractors and report to Congress on how it would use fee revenue available to hire contractors to also hire in-house staff. (Matter for Consideration 2)

Agency: Congress
Status: Open

Comments: As of September 2020, Congress had not enacted legislation to require Ginnie Mae to evaluate its reliance on contractors and report to Congress on its findings.

Recommendation: Congress should consider requiring Ginnie Mae to provide a report on how it would use greater flexibility or broader authority to set the compensation of its in-house staff. (Matter for Consideration 3)

Agency: Congress
Status: Open

Comments: As of September 2020, Congress has not enacted legislation to require Ginnie Mae to report on how it would use greater flexibility or broader authority to set the compensation of its in-house staff.

Recommendation: Congress should consider reforms to Ginnie Mae's oversight structure that can help address its increasing risks. (Matter for Consideration 4)

Agency: Congress
Status: Open

Comments: As of September 2020, Congress has not enacted legislation that considers reforms to Ginnie Mae's oversight structure that can help address its increasing risks.

Recommendation: The Chief Risk Officer of Ginnie Mae should periodically conduct an actuarial or similar analysis that includes a stress test to evaluate the extent to which the current level of the guaranty fee for single-family MBS provides Ginnie Mae with sufficient reserves to cover potential losses under different economic scenarios. (Recommendation 1)

Agency: Department of Housing and Urban Development: Government National Mortgage Association (Ginnie Mae)
Status: Open
Priority recommendation

Comments: Ginnie Mae (HUD) agreed with this recommendation. As of September 2020, Ginnie Mae took steps to address this recommendation. First, according to its 2020 budget justification, Ginnie Mae has concluded that it would be advantageous to have the authority to administratively adjust its guarantee fee and requested that the permissible guarantee fee be established within a range. Upon receipt of this authority, Ginnie Mae would then establish an administrative process through which an adjustment could be made. Second, Ginnie Mae has developed a stress test framework and solicited public comment. According to officials, by early 2021, Ginnie Mae plans to have its contractor develop an economic model to explore the current level of the guaranty fee under different economic scenarios including variations in issuer types and across Ginnie Mae programs. To fully implement this recommendation, Ginnie Mae needs to follow through on this effort and provide additional detail on changes to the existing models and its plan to periodically conduct this analysis. We will continue to monitor Ginnie Mae's progress in implementing our recommendation.

Recommendation: The Senior Vice President of Ginnie Mae's Office of Management Operations should analyze the costs of using contractors for its operations and develop a plan to determine the optimal mix of contractor or in-house staff for operations. (Recommendation 2)

Agency: Department of Housing and Urban Development: Government National Mortgage Association (Ginnie Mae)
Status: Open
Priority recommendation

Comments: Ginnie Mae (HUD) agreed with this recommendation. As of September 2020, Ginnie Mae said it procured a contractor to do this analysis on their behalf at the end of fiscal year 2020. Officials expected the cost analysis to commence in early 2021. To fully implement this recommendation, Ginnie Mae should ensure the analysis and plan are completed. We will continue to monitor Ginnie Mae's progress in implementing our recommendation.

Recommendation: The Senior Vice President of Ginnie Mae's Office of Management Operations should assess its contract administration options to determine the most efficient and effective use of funds. (Recommendation 3)

Agency: Department of Housing and Urban Development: Government National Mortgage Association (Ginnie Mae)
Status: Open
Priority recommendation

Comments: Ginnie Mae (HUD) agreed with this recommendation. As of October 2020, Ginnie Mae stated it assesses procurement approaches on a per contract basis on whether to administer a contract within HUD or outsource the contract administration. However, GAO recommends Ginnie Mae comprehensively evaluate whether the outsourcing of its contract administration has met its intended purposes and is the most efficient and effective use of funds. In order to implement this recommendation, Ginnie Mae should reevaluate its decision to use an external provider.

Recommendation: The Chief Financial Officer of Ginnie Mae and Senior Vice President of Ginnie Mae's Office of Management Operations should finalize efforts to assess the costs and benefits of options to revise its compensation structure within current authority and submit proposals, if warranted, to HUD for review and consideration. (Recommendation 4)

Agency: Department of Housing and Urban Development: Government National Mortgage Association (Ginnie Mae)
Status: Open
Priority recommendation

Comments: Ginnie Mae (HUD) agreed with this recommendation. As of September 2020, Ginnie Mae has taken steps to assess options to revise its compensation structure. More specifically, according to Ginnie Mae, in the development of its fiscal year 2020 budget request, Ginnie requested authority to develop alternative pay options, such as premium pay, pay bands and critical pay. In August 2020, Ginnie Mae was given authority to proceed with implementing critical pay by the Office of Personnel Management. Critical Pay authority permits an agency to set a higher rate of basic pay than would otherwise be payable for a position that requires expertise of an extremely high level in a scientific, technical, professional, or administrative field and is critical to the successful accomplishment of an important mission. As of September 2020, Ginnie Mae is working with HUD on developing an implementation plan to implement critical pay within its Office of Enterprise Risk. In addition, Ginne Mae is working with OMB to ensure program execution and outcomes are aligned between the agencies. We will continue to monitor Ginnie Mae's progress in implementing our recommendation.

Recommendation: To improve compliance with OMB Circular A-129 standards and strengthen management and oversight of the guarantee program, and to enhance screening of loan guarantee applicants, the Secretary of Agriculture should direct the Undersecretary for Rural Development to complete steps to obtain access to Treasury's Do Not Pay portal and establish policies and procedures to deny loan guarantees to applicants who are subject to administrative offsets for delinquent child support payments.

Agency: Department of Agriculture
Status: Open

Comments: In August 2020, Rural Development said that implementing the recommendation would require a rule change and that it anticipated publishing a proposed rule by December 31, 2020.

Recommendation: To improve compliance with OMB Circular A-129 standards and strengthen management and oversight of the guarantee program, and to strengthen oversight of lenders and servicers, the Secretary of Agriculture should direct the Undersecretary for Rural Development to develop and publish in the Federal Register qualification requirements for the principal officers of lenders and servicers seeking initial or continued approval to participate in the guarantee program.

Agency: Department of Agriculture
Status: Open

Comments: In August 2020, Rural Development said it anticipated publishing a proposed rule to implement this recommendation by December 31, 2020.

Recommendation: To improve compliance with OMB Circular A-129 standards and strengthen management and oversight of the guarantee program, and to strengthen oversight of lenders and servicers, the Secretary of Agriculture should direct the Undersecretary for Rural Development to develop and publish in the Federal Register capital and financial requirements for guarantee program lenders that are not regulated by a federal financial institution regulatory agency.

Agency: Department of Agriculture
Status: Open

Comments: In August 2020, Rural Development said it anticipated publishing a proposed rule to implement this recommendation by December 31, 2020.

Recommendation: To improve compliance with OMB Circular A-129 standards and strengthen management and oversight of the guarantee program, and to strengthen risk assessment and reporting, the Secretary of Agriculture should direct the Undersecretary for Rural Development to improve performance measures comparing RHS and the Federal Housing Administration loan performance, potentially by making comparisons on a cohort basis and limiting comparisons to loans made in similar geographic areas.

Agency: Department of Agriculture
Status: Open

Comments: In August 2020, Rural Development said it was working with a contractor to establish more meaningful performance measures and estimated a completion date of December 31, 2020.

Recommendation: To improve compliance with OMB Circular A-129 standards and strengthen management and oversight of the guarantee program, and to strengthen risk assessment and reporting, the Secretary of Agriculture should direct the Undersecretary for Rural Development to develop risk thresholds for the guarantee program, potentially in the form of maximum portfolio- or loan-level loss tolerances.

Agency: Department of Agriculture
Status: Open

Comments: Rural Development hired a contractor to help establish risk thresholds for the guarantee program. The contractor's October 2016 report developed and recommended portfolio-level and loan-level risk thresholds (values that trigger consideration of policy adjustments) and also recommended that program officials conduct stress tests to validate that each recommended risk threshold was appropriate for the program's overall risk appetite. As of August 2020, Rural Development said it was continuing to work with the contractor to stress test the risk thresholds and estimated a completion date of December 31, 2020.

Recommendation: To improve compliance with OMB Circular A-129 standards and strengthen management and oversight of the guarantee program, and to more effectively fulfill the requirements for conducting program reviews described in OMB Circular A-129, the Secretary of Agriculture should direct the Undersecretary for Rural Development to develop procedures for selecting RD credit programs for review based on risk and establish a prioritized schedule for conducting the reviews.

Agency: Department of Agriculture
Status: Open

Comments: In August 2020, Rural Development said that its Chief Risk Officer was working with the agency on establishing procedures for selecting Rural Development credit programs for review based on risk, including a prioritized schedule. Rural Development estimated a completion date of June 30, 2021.

Recommendation: To ensure that FHFA has adequate authority to ensure the safety and soundness of the enterprises and to clarify its supervisory role, Congress should consider granting FHFA explicit authority to examine third parties that do business with and play a critical role in the operations of the enterprises.

Agency: Congress
Status: Open

Comments: As of March 2020, Congress has not taken action on this matter.

Recommendation: To better ensure that taxpayer funds are being used effectively, Congress should consider permanently rescinding any Treasury-deobligated excess MHA balances that Treasury does not move into the Hardest Hit Fund.

Agency: Congress
Status: Open

Comments: No legislative action identified, as of July 22, 2020. Congress has not yet taken any action to rescind excess MHA balances, as recommended in GAO's March 2016 report. According to Treasury, it took action on July 27, 2018, to deobligate $4.0 billion MHA program funds beyond the $2 billion that it had previously deobligated and transferred to the Troubled Asset Relief Program-funded Hardest Hit Fund in February 2016. As a result of Treasury's deobligated action, Congress now has the opportunity to rescind and use the funds for other priorities.

Recommendation: To enhance the effectiveness of its preparations for conducting a retrospective review of its QM regulations, HUD should develop a plan that identifies the metrics, baselines, and analytical methods to be used. Furthermore, to account for and help mitigate the limitations of existing data and the uncertain availability of enhanced datasets, HUD should include in its plan alternate metrics, baselines, and analytical methods that could be used data were to remain unavailable.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2017, HUD noted that it does not currently collect data on the annual percentage rate (APR) for each loan that would allow for a perfect comparison to the average prime offer rate. According to HUD, its Office of Housing has on its long-term list of systems priorities to collect specific information from the Uniform Closing Data that could be used to conduct such a comparison. However, HUD stated that it has not received adequate funding to meet these systems enhancements. According to HUD, it is considering the feasibility and potential utility of alternative data sources or the use of a proxy in an appropriate methodology. For instance, whether it may be possible to approximate the APR based upon the note rate and information on closing costs that is collected in the current data system, or alternatively, whether the APR could be obtained or approximated through matching Home Mortgage Disclosure Act data for FHA loans. In a September 2020 email, HUD officials stated that HUD has certain unique considerations for review of its own QM rule as compared to the other federal agencies covered in the GAO report. HUD officials explained that HUD's QM rule implemented certain changes intended to conform with the Consumer Financial Protection Bureau's (CFPB) rule and constituted only a small subset of FHA's overall requirements related to underwriting and loan characteristics. According to HUD officials, HUD's QM rule was intended to make conforming changes to FHA's requirements, as statutorily required, in order to bring them into greater alignment with the new CFPB-promulgated QM rule requirements. They stated that HUD assesses FHA loan performance on an ongoing basis through a variety of mechanisms including the annual audit requirement and monitoring of the overall market and mortgage portfolio. According to the HUD officials, these mechanisms are used to assess the need for adjustments in underwriting criteria and mortgage insurance premiums as well as to assess the health and risks to safety and soundness of the MMIF Fund. HUD officials said that given these considerations, there is no specific stand-alone full evaluation of the HUD QM rule planned at this time.

Recommendation: To better ensure the viability and safety of manufactured housing produced in accordance with the HUD Code, the Secretary of the Department of Housing and Urban Development should develop a plan to assess how FHA financing might further promote the affordability of manufactured homes and identify the potential for better securitization of manufactured housing financing.

Agency: Department of Housing and Urban Development
Status: Open

Comments: According to HUD officials, Ginnie Mae and FHA met to discuss their manufactured housing programs and produced a white paper. Once we receive a copy of the white paper, we will determine if it addresses our recommendation.

Recommendation: To better ensure that Congress, stakeholders, and agencies have complete information about changing costs and whether a fee needs to be changed, HUD should assess the feasibility, including an analysis of the benefits and costs, of putting in place user fees for its dispute resolution and installation programs.

Agency: Department of Housing and Urban Development
Status: Open

Comments: As of March 2018, HUD stated that the Office of Manufactured Housing Programs continues to work toward fully implementing both the installation and dispute resolution programs in the default states using two new contractors for these purposes. As the implementation of these programs continues to mature, HUD stated that its Office of Manufactured Housing Programs will be monitoring program requirements and service delivery and gathering data that it can use in assessing the feasibility of putting in place user fees for these programs. We will continue to monitor HUD's progress in implementing our recommendation.

Recommendation: To better ensure that Congress, stakeholders, and agencies have complete information about changing costs and whether a fee needs to be changed, HUD should establish the goals for use of reserves of the Manufactured Housing Fees Trust Fund, and the minimum and maximum thresholds for the reserves appropriate for meeting these goals.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In response to this recommendation, as of March 2018, HUD plans to consider user fee reserve best practices in evaluating any carryover balances and developing future operating budgets for its manufactured housing programs. The Office of Manufactured Housing Programs plans on reviewing best practices and determining next steps ideally by the end of Fiscal Year 2019. We continue to believe that setting clear goals for the reserve and clarifying how those reserves will be used helps ensure accountability and transparency both to Congress and users of fee-based programs. We will continue to monitor HUD's progress in implementing our recommendation.

Recommendation: To strengthen FHA accountability for complying with the Fund's statutory capital requirement, Congress should consider requiring that FHA submit a capital restoration plan and regular updates on plan implementation whenever the capital ratio falls below 2 percent as calculated in the annual actuarial review of the Fund, or the Fund's financial condition does not meet other congressionally-defined requirements.

Agency: Congress
Status: Open

Comments: As of October 2019, Congress had not yet acted on this matter for consideration.

Recommendation: To provide additional perspective on the Fund's financial status, FHA should disclose estimates of the individual cash flows associated with the liability for loan guarantees (premiums, claims, and recoveries), including their value for each year of the 30-year estimation period.

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

Comments: As of October 2019, HUD had not yet acted on this recommendation.

Recommendation: While creating control systems at the same time that the emergency programs were being designed and implemented posed unique challenges, the recent crisis provided invaluable experience that the Federal Reserve System can apply in the future should the use of these authorities again become warranted. Going forward, to further strengthen policies for selecting vendors, ensuring the transparency and consistency of decision making involving the implementation of any future emergency programs, and managing risks related to these programs, the Chairman of the Federal Reserve Board should direct Federal Reserve Board and Reserve Bank staff to strengthen procedures in place to guide Reserve Banks' efforts to manage emergency program access for higher-risk borrowers by providing more specific guidance on how Reserve Bank staff should exercise discretion and document decisions to restrict or deny program access for depository institutions and primary dealers that would otherwise be eligible for emergency assistance.

Agency: Federal Reserve System: Board of Governors
Status: Open

Comments: We most recently sought information from the Board of Governors of the Federal Reserve System in July 2018 regarding the status of the recommendation but did not receive any new information. Therefore, the recommendation remains open.

Recommendation: While creating control systems at the same time that the emergency programs were being designed and implemented posed unique challenges, the recent crisis provided invaluable experience that the Federal Reserve System can apply in the future should the use of these authorities again become warranted. Going forward, to further strengthen policies for selecting vendors, ensuring the transparency and consistency of decision making involving the implementation of any future emergency programs, and managing risks related to these programs, the Chairman of the Federal Reserve Board should direct Federal Reserve Board and Reserve Bank staff to document a plan for estimating and tracking losses that could occur under more adverse economic conditions within and across all emergency lending activities and for using this information to inform policy decisions, such as decisions to limit risk exposures through program design or restrictions applied to eligible borrowing institutions.

Agency: Federal Reserve System: Board of Governors
Status: Open

Comments: We most recently sought information from the Board of Governors of the Federal Reserve System in July 2018 regarding the status of the recommendation but did not receive any new information. Therefore, the recommendation remains open.

Recommendation: While creating control systems at the same time that the emergency programs were being designed and implemented posed unique challenges, the recent crisis provided invaluable experience that the Federal Reserve System can apply in the future should the use of these authorities again become warranted. Going forward, to further strengthen policies for selecting vendors, ensuring the transparency and consistency of decision making involving the implementation of any future emergency programs, and managing risks related to these programs, the Chairman of the Federal Reserve Board should direct Federal Reserve Board and Reserve Bank staff to document the Federal Reserve Board's guidance to Reserve Banks on types of emergency program decisions and risk events that require approval by or consultation with the Board of Governors, the Federal Open Market Committee, or other designated groups or officials at the Federal Reserve Board.

Agency: Federal Reserve System: Board of Governors
Status: Open

Comments: We most recently sought information from the Board of Governors of the Federal Reserve System in July 2018 regarding the status of the recommendation but did not receive any new information. Therefore, the recommendation remains open.

Recommendation: To strengthen accountability and transparency in FHA's management of the Fund, Congress may wish to consider clarifying (1) the definition of the Fund's capital ratio--specifically, whether the denominator of the ratio was intended to be the amortized insurance-in-force; (2) the definition of the phrase "established target subsidy rate" used in HERA; and (3) the nature and extent of information that FHA should be reporting on subsidy rates pursuant to HERA, recognizing that subsidy rates are generally only reestimated once a year under current budget processes.

Agency: Congress
Status: Open

Comments: As of October 2019, Congress had not acted on this matter for consideration.