FALCON HOUSING CORPNon-Profit

FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-001: Major Program: Supportive Housing for the Elderly (Section 202 Capital Advance - Accumulated Balance), Federal Assistance Listing Number 14.157 STATEMENT OF CONDITION One tenant file, out of six files reviewed, was for a tenant who moved in during the year and management did not properly generate the Enterprise Income Verification (EIV) report timely. CRITERIA HUD Handbook 4350.3 Revision 1 for HUD Subsidized Multifamily Housing Programs requires owners to review the EIV report within 90 days after transmission of the move in certification to the Tenant Rental Assistance Certification System (TRACS). EFFECT OF CONDITION The EIV report for the tenant moved in was not generated until after the 90-day period specified by HUD. CONTEXT During audit fieldwork, six files from a statistically valid sample were examined for compliance with tenant eligibility criteria. Of the six tenant files examined, one tenant was a new move in. The tenant’s file did not contain the EIV verified in the required 90-day timeframe. CAUSE OF CONDITION The procedures to ensure compliance over HUD tenant compliance, including EIV verification, were not followed timely. RECOMMENDATION The auditor recommends ensuring all current and new staff are trained on tenants’ 90-day EIV reports and ensuring they are generated within the required time period to verify tenant information promptly and help reduce errors in subsidy payments. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The Project will be monitoring use of the EIV system for move ins and recertifications.

FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2023-001: Major Program: Supportive Housing for the Elderly (Section 202 Capital Advance - Accumulated Balance), Federal Assistance Listing Number 14.157 STATEMENT OF CONDITION One tenant file, out of six files reviewed, incorrectly accounted for tenant’s income, which resulted in undercharging the tenant $22 a month in rent. CRITERIA HUD Handbook 4350.3 Revision 1 for HUD Subsidized Multifamily Housing Programs requires owners to properly calculate tenants rent derived from the appropriate documents on file for tenants. EFFECT OF CONDITION The tenant was improperly undercharged $264 of rent for the year ended December 31, 2023. HUD was overcharged $264 of additional rental assistance payments for the year ended December 31, 2023. CONTEXT During audit fieldwork, six tenant files from a statistically valid sample were examined for compliance with tenant eligibility criteria and HUD lease requirements. Of the six tenant files examined, income for one tenant was incorrectly accounted for, resulting in the wrong calculation of tenant rent and HUD tenant assistance payments. CAUSE OF CONDITION Management mistakenly did not ensure the proper income was used to calculate the tenant’s rent. RECOMMENDATION The auditor recommends ensuring all tenants’ paperwork is thoroughly reviewed and accurately used in the calculation of the tenant’s required monthly rent and HUD’s tenant assistance payments. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The Project will be billing the tenant for the $264 and reimbursing HUD for additional tenant assistance payments of $264 due to the Project.

FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT (CONTINUED) Department of Housing and Urban Development Finding, 2023-002: Major Program: Supportive Housing for the Elderly (Section 202 Capital Advance - Accumulated Balance), Federal Assistance Listing Number 14.157 STATEMENT OF CONDITION One tenant file, out of six files reviewed, was for a tenant who moved in during the year and management did not properly generate the Enterprise Income Verification (EIV) report timely. CRITERIA HUD Handbook 4350.3 Revision 1 for HUD Subsidized Multifamily Housing Programs requires owners to review the EIV report within 90 days after transmission of the move in certification to the Tenant Rental Assistance Certification System (TRACS). EFFECT OF CONDITION The EIV report for the tenant moved in was not generated until after the 90-day period specified by HUD. CONTEXT During audit fieldwork, six files from a statistically valid sample were examined for compliance with tenant eligibility criteria. Of the six tenant files examined, one tenant was a new move in. The tenant’s file did not contain the EIV verified in the required 90-day timeframe. CAUSE OF CONDITION The procedures to ensure compliance over HUD tenant compliance, including EIV verification, were not followed timely. RECOMMENDATION The auditor recommends ensuring all current and new staff are trained on tenants’ 90-day EIV reports and ensuring they are generated within the required time period to verify tenant information promptly and help reduce errors in subsidy payments. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The Project will be monitoring use of the EIV system for move ins and recertifications.

FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT (CONTINUED) Department of Housing and Urban Development Finding, 2023-003: Major Program: Supportive Housing for the Elderly (Section 202 Capital Advance - Accumulated Balance), Federal Assistance Listing Number 14.157 STATEMENT OF CONDITION All required deposits were not made to the Reserve for Replacement account for the years ended December 31, 2023 and 2022, totaling $5,727 and $24,287 outstanding as of December 31, 2023. CRITERIA HUD Handbook 4350.1 Revision 1 for HUD Subsidized Multifamily Housing Programs requires owners to make monthly deposits to the Reserve for Replacement account based on the Project’s monthly deposit authorized by HUD. EFFECT OF CONDITION Management did not make all required deposits to the Reserve for Replacement account in 2023. CONTEXT During audit fieldwork, the Reserve for Replacement accounts were tested for compliance with required monthly deposits. Insufficient monthly deposits were noted on the bank statements. CAUSE OF CONDITION Management did not make all monthly deposits to the Reserve for Replacement account due to cash flow issues during 2023. RECOMMENDATION The auditor recommends the Reserve for Replacement be properly funded on a monthly basis. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The Project has suffered dramatically from the results of COVID-19. During all years prior to 2022, the Reserve for Replacement has been in compliance. Although HUD did help with small COVID-19 grants, it was not sufficient to overcome the costs. Properties of 50-units and less suffered far more during COVID-19 than the larger developments due to the economies of scale. It should be noted that in addition to the Reserve for Replacement that was not funded in 2023, the property management firm was also not paid $24,523. Management received a substantial rent increase in June 2023 and plans to make all required deposits in 2024 when they will begin to see the effects of this increase.

FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2022-001: Major Program: Supportive Housing for the Elderly (Section 202 Capital Advance - Accumulated Balance), Federal Assistance Listing Number 14.157 STATEMENT OF CONDITION One tenant file, out of six files reviewed, did not refund a security deposit within thirty days of the tenant moving out. CRITERIA HUD Handbook 4350.3 Revision 1 for HUD Subsidized Multifamily Housing Programs requires owners to refund the tenant?s security deposit within thirty days after the move out date. EFFECT OF CONDITION The tenant was not refunded their security deposit within thirty days of their move out. CONTEXT During audit fieldwork, six tenant files from a statistically valid sample were examined for compliance with tenant eligibility criteria and HUD lease requirements. Of the six tenant files examined, one moved out during 2022. This tenant, who moved out, was not refunded their security deposit within thirty days of the move out date. CAUSE OF CONDITION Management mistakenly did not ensure that the security deposit was refunded within thirty days of the tenant moving out. RECOMMENDATION The auditor recommends implementing greater oversight over HUD tenant compliance and proper employee training. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The Project will monitor tenant move outs to ensure security deposits are refunded within the thirty-day period specified by HUD and review the HUD move out procedures with their employees.

FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2022-002: Major Program: Supportive Housing for the Elderly (Section 202 Capital Advance - Accumulated Balance), Federal Assistance Listing Number 14.157 STATEMENT OF CONDITION One tenant file, out of six files reviewed, was for a tenant who moved in during the year and management did not properly generate the Enterprise Income Verification (EIV) report timely. CRITERIA HUD Handbook 4350.3 Revision 1 for HUD Subsidized Multifamily Housing Programs requires owners to review the EIV report within 90 days after transmission of the move in certification to the Tenant Rental Assistance Certification System (TRACS). EFFECT OF CONDITION The EIV report for the tenant moved in was not generated until after the 90-day period specified by HUD. CONTEXT During audit fieldwork, six files from a statistically valid sample were examined for compliance with tenant eligibility criteria. Of the six tenant files examined, one tenant was a new move in. The tenant?s file did not contain the EIV verified in the required 90-day timeframe. CAUSE OF CONDITION The procedures to ensure compliance over HUD tenant compliance, including EIV verification, were not followed timely. RECOMMENDATION The auditor recommends ensuring all tenants? 90-day EIV reports are generated within the required time period to verify tenant information promptly and help reduce errors in subsidy payments. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The Project will be monitoring use of the EIV system for move ins and recertifications.

FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2022-003: Major Program: Supportive Housing for the Elderly (Section 202 Capital Advance - Accumulated Balance), Federal Assistance Listing Number 14.157 STATEMENT OF CONDITION No required deposits were made to the Reserve for Replacement account. CRITERIA HUD Handbook 4350.3 Revision 1 for HUD Subsidized Multifamily Housing Programs requires owners to make monthly deposits to the Reserve for Replacement account based on the Project?s monthly deposit authorized by HUD. EFFECT OF CONDITION Management did not make any required deposits to the Reserve for Replacement account in 2022. CONTEXT During audit fieldwork, the Reserve for Replacement accounts were tested for compliance with required monthly deposits. No monthly deposits were noted on the bank statements. CAUSE OF CONDITION Management did not make monthly deposits to the Reserve for Replacement account due to cash flow issues during 2022 as a result of the Project not receiving a rent increase since 2019. RECOMMENDATION The auditor recommends the Reserve for Replacement be properly funded on a monthly basis. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The Project has suffered dramatically from the results of COVID-19. During all prior years, the Reserve for Replacement has been in compliance. Although HUD did help with small COVID-19 grants, it was not sufficient to overcome the costs. Properties of 50-units and less suffered far more during COVID-19 than the larger developments due to the economies of scale. It should be noted that in addition to the Reserve for Replacement that was not funded in 2022, the property management firm was also not paid $25,781. Management has requested a substantial rent increase, however, being more than a 4.0% increase triggers a longer review time table, which the Project is awaiting. The Project submitted a rent increase on February 23, 2023 for 14.7% and is awaiting (i) a contract renewal, (ii) approval of the rent increase, and (iii) the approval of a new rent increase schedule so we can bill for the Section 8. Lastly, management will propose to HUD, after a substantial rent increase, to double the outstanding Reserve for Replacement payments to bring this development into compliance over the next two years.

FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2021-001: Major Program: Supportive Housing for the Elderly (Section 202 Capital Advance - Accumulated Balance), Assistance Listing 14.157 STATEMENT OF CONDITION One tenant file, out of six files reviewed, had incorrectly accounted for tenant?s income, which resulted in undercharging the tenant $19 a month in rent. CRITERIA HUD Handbook 4350.3 Revision 1 for HUD Subsidized Multifamily Housing Programs requires owners to properly calculate tenants rent derived from the appropriate documents on file for tenants. EFFECT OF CONDITION The tenant was improperly undercharged $152 of additional rent for the year ended December 31, 2021. HUD was overcharged $152 of rental assistance payments for the year ended December 31, 2021. CONTEXT During audit fieldwork, six tenant files from a statistically valid sample were examined for compliance with tenant eligibility criteria. Of the six tenant files examined, income for one tenant was incorrectly accounted for, therefore resulting in the wrong calculation of tenant rent and HUD tenant assistance payment. CAUSE OF CONDITION Management mistakenly did not ensure that the proper income was used to calculate the tenant?s rent. RECOMMENDATION The auditor recommends ensuring that all tenants? paperwork is thoroughly reviewed and accurately used in the calculation of the tenants? required monthly rent and HUD?s tenant assistance payments. MANAGEMENT?S RESPONSE The Project billed the tenant $152 and reimbursed HUD for the additional tenant assistance of $152 due from the Project.

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