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Herbert Brooks Housing Development Fund Company, IncNon-Profit

EIN: 133595749

UEI: SBB8GNEVUC89

Audited by: Novogradac & Company LLP

Oversight agency: 14 [Department of Housing and Urban Development]

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Data as of September 3, 2026

Herbert Brooks Housing Development Fund Company, Inc9 audit years11 findings6 repeat
9
Audit Years
11
Total Findings
6
Repeat Findings
$9.3M
Federal Awards Expended (FY 2024)

FY 2024-12-31

GOING CONCERNMATERIAL NONCOMPLIANCE DISCLOSED$9,276,504 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on September 5, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by March 5, 2026 (183 days ago).

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2024-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

Statement of Condition Residual receipts were not properly deposited into an account in accordance with HUD requirements. Criteria Owners must deposit residual receipts into a separate account within 90 days of the end of the fiscal year. Questioned Costs $116,553 Effect or potential effect The Company is in non-compliance with specific requirements of a major federal program. Cause Controls and actions were not taken to ensure that the residual receipts were properly deposited in a separate account. Recommendation We recommend that owners take the specific actions of depositing the residual receipts into a separate account in accordance with HUD requirements. Reporting views of responsible officials Auditee agrees with the auditor. Auditor Noncompliance Code: B – Failure to make required residual receipts deposits.

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Statement of Condition Residual receipts were not properly deposited into an account in accordance with HUD requirements. Criteria Owners must deposit residual receipts into a separate account within 90 days of the end of the fiscal year. Questioned Costs $116,553 Effect or potential effect The Company is in non-compliance with specific requirements of a major federal program. Cause Controls and actions were not taken to ensure that the residual receipts were properly deposited in a separate account. Recommendation We recommend that owners take the specific actions of depositing the residual receipts into a separate account in accordance with HUD requirements. Reporting views of responsible officials Auditee agrees with the auditor. Auditor Noncompliance Code: B – Failure to make required residual receipts deposits.

Corrective Action Plan

Recommendation The Company must deposit $116,553 into the residual receipts reserve. Reporting views of responsible officials Auditee agrees with the auditor and management will be responsible for depositing surplus cash into the residual receipts reserve. Completion date or proposed completion date: December 31, 2025 Action(s) taken or planned on the finding Management will make the required deposit to the residual receipts reserve.

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FY 2023-12-31

GOING CONCERN$9,362,485 federal awards expended

FAC accepted this audit on September 30, 2024 — management decision was due March 30, 2025.

2023-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Finding No. 2023-2 Statement of Condition Residual receipts were not properly deposited into an account in accordance with HUD requirements. Criteria Owners must deposit residual receipts into a separate account within 90 days of the end of the fiscal year. Questioned Costs $13,918 Effect or potential effect The Company is in non-compliance with specific requirements of a major federal program. Cause Controls and actions were not taken to ensure that the residual receipts were properly deposited in a separate account. Recommendation We recommend that owners take the specific actions of depositing the residual receipts into a separate account in accordance with HUD requirements. Reporting views of responsible officials Auditee agrees with the auditor. Auditor Noncompliance Code: B – Failure to make required residual receipts deposits.

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Finding No. 2023-2 Statement of Condition Residual receipts were not properly deposited into an account in accordance with HUD requirements. Criteria Owners must deposit residual receipts into a separate account within 90 days of the end of the fiscal year. Questioned Costs $13,918 Effect or potential effect The Company is in non-compliance with specific requirements of a major federal program. Cause Controls and actions were not taken to ensure that the residual receipts were properly deposited in a separate account. Recommendation We recommend that owners take the specific actions of depositing the residual receipts into a separate account in accordance with HUD requirements. Reporting views of responsible officials Auditee agrees with the auditor. Auditor Noncompliance Code: B – Failure to make required residual receipts deposits.

Corrective Action Plan

Finding Reference Number: 2023-2 Recommendation The Company must deposit $13,918 into the residual receipts reserve. Reporting views of responsible officials Auditee agrees with the auditor and management will be responsible for depositing surplus cash into the residual receipts reserve. Completion date or proposed completion date: December 31, 2024 Action(s) taken or planned on the finding Management will make the required deposit to the residual receipts reserve.

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FY 2022-12-31

GOING CONCERN$9,462,436 federal awards expended

FAC accepted this audit on November 28, 2023 — management decision was due May 28, 2024.

2022-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-002OTHER MATTERS

Section III - Findings and Questioned Costs-Major Federal Award Program Audit Finding No. 2022-1 Statement of Condition The electronic submission of the financial statements is overdue. Criteria The financial statements must be electronically submitted to HUD through FASSUB within 90 days of fiscal year-end. Questioned Costs None Effect or potential effect The Company is in non-compliance with specific requirements of a major federal program. Cause Controls are not in place to ensure that the Company reports financial data on time. Recommendation We recommend that the electronic submission be completed as soon as possible. Reporting views of responsible officials Auditee agrees with the auditor. Auditor Noncompliance Code: K – Electronic submission verification

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Section III - Findings and Questioned Costs-Major Federal Award Program Audit Finding No. 2022-1 Statement of Condition The electronic submission of the financial statements is overdue. Criteria The financial statements must be electronically submitted to HUD through FASSUB within 90 days of fiscal year-end. Questioned Costs None Effect or potential effect The Company is in non-compliance with specific requirements of a major federal program. Cause Controls are not in place to ensure that the Company reports financial data on time. Recommendation We recommend that the electronic submission be completed as soon as possible. Reporting views of responsible officials Auditee agrees with the auditor. Auditor Noncompliance Code: K – Electronic submission verification

Corrective Action Plan

Finding Reference Number: 2022-1 Recommendation We recommend that the electronic submissions be completed as soon as possible. Reporting views of responsible officials Auditee concurs with this finding. Completion date or proposed completion date: June 15, 2023 Action(s) taken or planned on the finding Management will take steps to implement strong internal control to report financial data on time.

Prior Finding References

2021-002

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2022-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2021-003QUESTIONED COSTSOTHER MATTERS

Section III - Findings and Questioned Costs-Major Federal Award Program Audit Finding No. 2022-2 Statement of Condition A security deposits cash account was not established in accordance with HUD regulations in that funds were not segregated from the operating account. Criteria The tenant security deposits cash account must be kept in a separate, interest-bearing account in the name of the Company, per HUD Handbook 4370.2 REV-1. Questioned Costs $17,297 Effect or potential effect The Company is noncompliant with specific requirements of its major federal program. Cause Controls are not in place to ensure tenant security deposits are maintained in accordance with HUD regulations. Recommendation Management should set up a separate bank account in the Company's name for tenant security deposits. Reporting views of responsible officials Auditee agrees with the auditor and management will be responsible for creating a separate bank account in the Company's name for tenant security deposits. Auditor Noncompliance Code: M – Security Deposits

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Section III - Findings and Questioned Costs-Major Federal Award Program Audit Finding No. 2022-2 Statement of Condition A security deposits cash account was not established in accordance with HUD regulations in that funds were not segregated from the operating account. Criteria The tenant security deposits cash account must be kept in a separate, interest-bearing account in the name of the Company, per HUD Handbook 4370.2 REV-1. Questioned Costs $17,297 Effect or potential effect The Company is noncompliant with specific requirements of its major federal program. Cause Controls are not in place to ensure tenant security deposits are maintained in accordance with HUD regulations. Recommendation Management should set up a separate bank account in the Company's name for tenant security deposits. Reporting views of responsible officials Auditee agrees with the auditor and management will be responsible for creating a separate bank account in the Company's name for tenant security deposits. Auditor Noncompliance Code: M – Security Deposits

Corrective Action Plan

Finding Reference Number: 2022-2 Recommendation The Company should set up a separate bank account in the Company’s name for tenant security deposits. Reporting views of responsible officials Auditee agrees with the auditor and management will be responsible for creating a separate bank account in the Company’s name for tenant security deposits. Completion date or proposed completion date: April 2023 Action(s) taken or planned on the finding As of April 2023, management has set up a separate bank account in the Company’s name for tenant security deposits.

Prior Finding References

2021-003

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2022-003
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

Finding No. 2022-3 Statement of Condition Owners were unable to maintain the physical condition of the property. Criteria Owners are obligated to maintain the physical condition of the property as stated in the regulatory agreement. Questioned Costs $0 Effect or potential effect The Company is noncompliant with specific requirements of its major federal program. Cause Controls are not in place to ensure that the owners maintain the physical condition of the property. Recommendation Management should support the continuing physical maintenance of the property. Reporting views of responsible officials Auditee agrees with the auditor and management will be responsible for ensuring that the physical condition of the property is maintained. Auditor Noncompliance Code: I – Failure to Maintain Property

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Finding No. 2022-3 Statement of Condition Owners were unable to maintain the physical condition of the property. Criteria Owners are obligated to maintain the physical condition of the property as stated in the regulatory agreement. Questioned Costs $0 Effect or potential effect The Company is noncompliant with specific requirements of its major federal program. Cause Controls are not in place to ensure that the owners maintain the physical condition of the property. Recommendation Management should support the continuing physical maintenance of the property. Reporting views of responsible officials Auditee agrees with the auditor and management will be responsible for ensuring that the physical condition of the property is maintained. Auditor Noncompliance Code: I – Failure to Maintain Property

Corrective Action Plan

Finding Reference Number: 2022-3 Recommendation We recommend that owners support the continuing physical maintenance of the property. Reporting views of responsible officials Auditee concurs with this finding. Completion date or proposed completion date: July 19, 2023 Action(s) taken or planned on the finding A physical inspection was conducted on July 19, 2023 and no immediate attention or remedy exigent health and safety deficiencies were identified.

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FY 2021-12-31

GOING CONCERN$8,208,413 federal awards expended

FAC accepted this audit on April 11, 2023 — management decision was due October 11, 2023.

2021-002
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

Statement of Condition The electronic submission of the financial statements is overdue. Criteria The financial statements must be electronically submitted to HUD through FASSUB within 90 days of fiscal year-end. The financial statements must also be submitted to the Federal Audit Clearinghouse within 9 months of fiscal year-end. Questioned Costs None Effect or potential effect The Company is in non-compliance with specific requirements of a major HUD-assisted program. Cause Controls are not in place to ensure that the Company records and reports financial data on time. Recommendation We recommend that the electronic submission be completed as soon as possible. Reporting views of responsible officials Auditee agrees with the auditor.

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Full finding narrative

Statement of Condition The electronic submission of the financial statements is overdue. Criteria The financial statements must be electronically submitted to HUD through FASSUB within 90 days of fiscal year-end. The financial statements must also be submitted to the Federal Audit Clearinghouse within 9 months of fiscal year-end. Questioned Costs None Effect or potential effect The Company is in non-compliance with specific requirements of a major HUD-assisted program. Cause Controls are not in place to ensure that the Company records and reports financial data on time. Recommendation We recommend that the electronic submission be completed as soon as possible. Reporting views of responsible officials Auditee agrees with the auditor.

Corrective Action Plan

Herbert Brooks Housing Development Fund Company, Inc. HUD Project No.: 012-HE-699 NY 36-S891-009 Corrective Action Plan December 31, 2021 Current findings on the Schedule of Findings, Questioned Costs, and Recommendations Finding Reference Number: 2021-1 Recommendation The Company should ensure that proper internal controls are in place to prevent significant deficiencies from occurring, including reconciling, reviewing and adjusting significant account balances. Reporting views of responsible officials Auditee concurs with this finding. Auditee agrees with auditor recommendations and management will be responsible for accounting for this in the future. Completion date or proposed completion date: February 15, 2023 Action(s) taken or planned on the finding Management will take steps to implement strong internal control to recognize and correct errors in reporting. Finding Reference Number: 2021-2 Recommendation We recommend that the electronic submissions be completed as soon as possible. Reporting views of responsible officials Auditee concurs with this finding. Completion date or proposed completion date: March 31, 2023 Action(s) taken or planned on the finding Management will take steps to implement strong internal control to report financial data on time.

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2021-003
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

Finding No. 2021-3 Statement of Condition A security deposits cash account was not established in accordance with HUD regulations in that funds were not segregated from the operating account. Criteria The tenant security deposits cash account must be kept in a separate, interest-bearing account in the name of the Company, per HUD Handbook 4370.2 REV-1. Questioned Costs $18,393 Effect or potential effect The Company is noncompliant with specific requirements of their major HUD program. Cause Controls are not in place to ensure tenant security deposits are maintained in accordance with HUD regulations. Recommendation Management should set up a separate bank account in the Company's name for tenant security deposits. Reporting views of responsible officials Auditee agrees with the auditor and management will be responsible for creating a separate bank account in the Company's name for tenant security deposits.

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Full finding narrative

Finding No. 2021-3 Statement of Condition A security deposits cash account was not established in accordance with HUD regulations in that funds were not segregated from the operating account. Criteria The tenant security deposits cash account must be kept in a separate, interest-bearing account in the name of the Company, per HUD Handbook 4370.2 REV-1. Questioned Costs $18,393 Effect or potential effect The Company is noncompliant with specific requirements of their major HUD program. Cause Controls are not in place to ensure tenant security deposits are maintained in accordance with HUD regulations. Recommendation Management should set up a separate bank account in the Company's name for tenant security deposits. Reporting views of responsible officials Auditee agrees with the auditor and management will be responsible for creating a separate bank account in the Company's name for tenant security deposits.

Corrective Action Plan

Herbert Brooks Housing Development Fund Company, Inc. HUD Project No.: 012-HE-699 NY 36-S891-009 Corrective Action Plan December 31, 2021 Finding Reference Number: 2021-3 Recommendation The Company should set up a separate bank account in the Company?s name for tenant security deposits. Reporting views of responsible officials Auditee agrees with the auditor and management will be responsible for creating a separate bank account in the Company?s name for tenant security deposits. Completion date or proposed completion date: September 30, 2022 Action(s) taken or planned on the finding As of September 2022, management has set up a separate bank account in the Company?s name for tenant security deposits. Corrective Action Plan prepared by: Name: Ruby Rodriguez Title: Vice President Telephone: (347)-226-2486 Date: March 31, 2023

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FY 2020-12-31

$8,141,193 federal awards expendedNo findings recorded this year

FAC accepted this audit on August 25, 2021 — management decision was due February 25, 2022.

FY 2019-12-31

MATERIAL NONCOMPLIANCE DISCLOSED$8,103,077 federal awards expended

FAC accepted this audit on July 13, 2020 — management decision was due January 13, 2021.

2019-002
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2018-001

Delinquent deposits to the residual receipts reserve Statement of Condition During the years ended December 31, 2012 through 2015, the Company did not make the required residual receipts reserve deposits in a cumulative amount of $196,522 within 90 days of year-end, as required by HUD. Criteria Residual receipts reserve deposits should be made within 90 days of year-end. Questioned Costs None Effect The Company is not in compliance with the requirements of the regulatory agreement. Cause Controls are not in place to ensure that required residual receipts reserve deposits are made timely. Recommendation Management should establish internal controls and procedures to ensure that required residual receipts deposits are made timely. Auditor Noncompliance Code: B - Failure to make required residual receipts deposits. Finding Resolution Status Unresolved. Reporting Views of Responsible Officials Management is currently in the process of evaluating the costs of necessary repairs to the building and in negotiations with HUD to utilize the required deposits to the residual receipts account to make the repairs. Upon determination of the total costs, management will seek approval from HUD to retain monies to make the necessary repairs.

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Delinquent deposits to the residual receipts reserve Statement of Condition During the years ended December 31, 2012 through 2015, the Company did not make the required residual receipts reserve deposits in a cumulative amount of $196,522 within 90 days of year-end, as required by HUD. Criteria Residual receipts reserve deposits should be made within 90 days of year-end. Questioned Costs None Effect The Company is not in compliance with the requirements of the regulatory agreement. Cause Controls are not in place to ensure that required residual receipts reserve deposits are made timely. Recommendation Management should establish internal controls and procedures to ensure that required residual receipts deposits are made timely. Auditor Noncompliance Code: B - Failure to make required residual receipts deposits. Finding Resolution Status Unresolved. Reporting Views of Responsible Officials Management is currently in the process of evaluating the costs of necessary repairs to the building and in negotiations with HUD to utilize the required deposits to the residual receipts account to make the repairs. Upon determination of the total costs, management will seek approval from HUD to retain monies to make the necessary repairs.

Corrective Action Plan

Status of Corrective Actions on findings reported in the prior audit Schedule of Findings, Questioned Costs, and Recommendations Finding reference number: 19-2 The residual receipts finding has been an ongoing issue with this entity. As owners, we contend that due to the poor cashflow experienced over several years that it was unattainable to both fund the residual receipts and maintain operations. Comments on the Findings and Each Recommendation There has been a multi-faceted approach to resolve this finding. As owners we have been filing for Budget Based Rent Increase which has alleviated some of the financial pressures of the property. In 2020 MBD was granted permission by HUD to use the residual funds for capital work that needed to be done as well as supplementary rental income as HUD did not have the funds on hand to meet the BBRI granted for 2019-2020. MBD will contact HUD in order to reach an agreement on the resolution of this finding.

Prior Finding References

2018-001

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FY 2018-12-31

MATERIAL NONCOMPLIANCE DISCLOSED$8,083,947 federal awards expended

FAC accepted this audit on September 14, 2019 — management decision was due March 14, 2020.

2018-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2017-001

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-001

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FY 2017-12-31

$8,067,519 federal awards expended

FAC accepted this audit on April 23, 2018 — management decision was due October 23, 2018.

2017-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2016-001

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-001

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FY 2016-12-31

MATERIAL NONCOMPLIANCE DISCLOSED$8,076,712 federal awards expended

FAC accepted this audit on June 11, 2017 — management decision was due December 11, 2017.

2016-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2015-001

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2015-001

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