Report 2023-112 Recommendations

When an audit is completed and a report is issued, auditees must provide the State Auditor with information regarding their progress in implementing recommendations from our reports at three intervals from the release of the report: 60 days, six months, and one year. Additionally, Senate Bill 1452 (Chapter 452, Statutes of 2006), requires auditees who have not implemented recommendations after one year, to report to us and to the Legislature why they have not implemented them or to state when they intend to implement them. Below, is a listing of each recommendation the State Auditor made in the report referenced and a link to the most recent response from the auditee addressing their progress in implementing the recommendation and the State Auditor's assessment of auditee's response based on our review of the supporting documentation.

Recommendations in Report 2023-112: Mobilehome Residency Law Protection Program: The California Department of Housing and Community Development Must Improve Its Oversight of the Program (Release Date: December 2023)

Recommendations to Housing and Community Development, Department of
Number Recommendation Status

To ensure that LSPs are providing complainants with timely and effective services, HCD should, by March 2024, begin regular surveys of complainants whom it has referred to LSPs to determine whether the LSPs are in regular communication with the complainants and whether complainants have any concerns about the LSPs' services.


To ensure that LSPs are providing complainants with timely and effective services, HCD should, by March 2024, amend the LSP contracts and require the LSPs to provide complainants copies of invoices specific to their complaints.

Will Not Implement

To ensure that LSPs are providing complainants with timely and effective services, HCD should, by March 2024, monitor the updates that LSPs provide to detect any inappropriate denial of services and immediately respond to correct those denials.


HCD should adopt more effective data management practices by developing, at a minimum, the following CASAS upgrades as soon as is feasible:
-A list of outcomes that HCD staff would select from when changing a complaint's status to closed. That list should include the option to note that closure pertains to an inquiry rather than a complaint.
-The ability to automatically generate a report with the outcome information needed for HCD's annual report to the Legislature.

Recommendations to Legislature
Number Recommendation Status

To ensure that HCD is able to effectively monitor the LSPs with which it contracts, the Legislature should amend state law to require LSPs to permit HCD, in its role as the contract manager overseeing the performance of the LSP contracts, access to confidential information—currently protected by the attorney-client communication and attorney-work product privileges—regarding the status of each case and the services provided to complainants. HCD should be prohibited from disclosing this confidential information to anyone outside of HCD. The Legislature should also specify that the LSPs providing access to HCD does not constitute a waiver of any attorney-related privileges.


To ensure that HCD has enough funding to effectively manage the program without accumulating excessive funds, the Legislature should amend state law to:

-Suspend the program's $10 per lot fee until the program's sunset date of January 1, 2027.
-Provide HCD authority to reinstate the $10 per lot fee for the duration of the program in the event HCD and the Department of Finance agree that the program fund can cover only six months of expenditures.
-Require HCD—in its annual report due on or before December 31, 2025—to report on the program's financial sustainability and justify any further revisions to the program fee.

Print all recommendations and responses.