EIN: 141869907
UEI: PMHJDK326KS7
Audited by: CohnReznick LLP
Oversight agency: 14 [Department of Housing and Urban Development]
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Data as of August 31, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 4, 2024. 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 4, 2025 (546 days ago).
What is a management decision? →Criteria - Special Tests and Provisions Effective January 1, 2023, Victory Heights changed from a fiscal year end of June 30 to December 31. The prior period audit report, dated October 31, 2023, represents a six-month fiscal transition period from July 1, 2022 through December 31, 2022. Any required residual receipts reserve deposits should be made on or before October 31, 2023. Condition During the year ended December 31, 2023, management did not make the required residual receipts reserve deposit in the amount of $19,656, as required by HUD. Cause Controls are not in place to ensure that required residual receipts reserve deposits are made timely. In addition, operating cash was insufficient to fund the reserve as of October 31, 2023. Effect or Potential Effect Victory Heights is not in compliance with the requirements of the regulatory agreement. Questioned Costs None Context Isolated instance Identification as a Repeat Finding Not a repeat finding. Recommendation Management should establish internal controls and procedures to ensure that required residual receipts reserve deposits are made timely. In addition, management should withdrawal $19,656 from operating cash and immediately deposit this amount into the residual receipts account. Auditor Noncompliance Code: B - Failure to make required residual receipts deposits Finding Resolution Status: In-Process Views of Responsible Officials Going forward, management will ensure that any shortage is funded on time even if operating funds are short and we have to request funds from ownership.
Show full finding ▾Hide full finding ▴Criteria - Special Tests and Provisions Effective January 1, 2023, Victory Heights changed from a fiscal year end of June 30 to December 31. The prior period audit report, dated October 31, 2023, represents a six-month fiscal transition period from July 1, 2022 through December 31, 2022. Any required residual receipts reserve deposits should be made on or before October 31, 2023. Condition During the year ended December 31, 2023, management did not make the required residual receipts reserve deposit in the amount of $19,656, as required by HUD. Cause Controls are not in place to ensure that required residual receipts reserve deposits are made timely. In addition, operating cash was insufficient to fund the reserve as of October 31, 2023. Effect or Potential Effect Victory Heights is not in compliance with the requirements of the regulatory agreement. Questioned Costs None Context Isolated instance Identification as a Repeat Finding Not a repeat finding. Recommendation Management should establish internal controls and procedures to ensure that required residual receipts reserve deposits are made timely. In addition, management should withdrawal $19,656 from operating cash and immediately deposit this amount into the residual receipts account. Auditor Noncompliance Code: B - Failure to make required residual receipts deposits Finding Resolution Status: In-Process Views of Responsible Officials Going forward, management will ensure that any shortage is funded on time even if operating funds are short and we have to request funds from ownership.
We have processes in place to account for these requirements, but in this case the year end changed, and a stub period audit was conducted. We could not make a deposit by 10/31/23 since we did not have the final audit by then and there were not sufficient funds in the operating account to cover the funding. Going forward, management will ensure that any shortage is funded on time even if operating funds are short and we have to request funds from ownership.
Criteria - Eligibility Management is responsible for determining tenant eligibility and maintaining lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Condition In connection with our lease file review, we noted the following deficiencies: 1 out of 9 tenants tested did not have the accurate amount of adjusted annual income reported on HUD Form 50059 and did not utilized the Enterprise Income Verification system timely. 7 out of 9 tenants tested did not utilize the Enterprise Income Verification system timely. Cause The Project failed to follow the policies and procedures which have been established for proper tenant file maintenance and determining tenant eligibility in accordance with HUD guidelines. Effect or Potential Effect The procedures for determining tenant eligibility and maintaining tenant lease files were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Context A sample of 9 tenant files from a population of 82 were selected. We identified exceptions in 8 out of the 9 files tested. The sample in not a statistically valid sample. Identification as a Repeat Finding Repeat finding of Finding No. 2022-001 Questioned Costs None Recommendation Management should establish procedures and monitor compliance with those procedures to ensure that the determination of tenant eligibility and the maintenance of lease files are in accordance with guidelines specified by HUD. Auditor Noncompliance Code: R - Section 8 program administration Finding Resolution Status: In-Process Views of Responsible Officials Going forward, management will ensure that the EIV system is utilized correctly and timely. Tenant files have been noted on the late EIV reports. Management is now running EIV reports from corporate to eliminate the pate processing or missing EIV reports.
Show full finding ▾Hide full finding ▴Criteria - Eligibility Management is responsible for determining tenant eligibility and maintaining lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Condition In connection with our lease file review, we noted the following deficiencies: 1 out of 9 tenants tested did not have the accurate amount of adjusted annual income reported on HUD Form 50059 and did not utilized the Enterprise Income Verification system timely. 7 out of 9 tenants tested did not utilize the Enterprise Income Verification system timely. Cause The Project failed to follow the policies and procedures which have been established for proper tenant file maintenance and determining tenant eligibility in accordance with HUD guidelines. Effect or Potential Effect The procedures for determining tenant eligibility and maintaining tenant lease files were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Context A sample of 9 tenant files from a population of 82 were selected. We identified exceptions in 8 out of the 9 files tested. The sample in not a statistically valid sample. Identification as a Repeat Finding Repeat finding of Finding No. 2022-001 Questioned Costs None Recommendation Management should establish procedures and monitor compliance with those procedures to ensure that the determination of tenant eligibility and the maintenance of lease files are in accordance with guidelines specified by HUD. Auditor Noncompliance Code: R - Section 8 program administration Finding Resolution Status: In-Process Views of Responsible Officials Going forward, management will ensure that the EIV system is utilized correctly and timely. Tenant files have been noted on the late EIV reports. Management is now running EIV reports from corporate to eliminate the pate processing or missing EIV reports.
Each resident’s information is processed before moving in to ensure they don’t have tenancy elsewhere. Going forward, we will ensure that things are processed timely within the 90-day period. Going forward, management will ensure that the EIV system is utilized correctly and timely. Tenant files have been noted on the late EIV reports. Management is now running EIV reports from corporate to eliminate the pate processing or missing EIV reports.
2022-001
FAC accepted this audit on November 20, 2023 — management decision was due May 20, 2024.
Criteria - Eligibility Tenant lease files are required to be maintained and tenant eligibility determined in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Condition In connection with our lease file review we noted the following deficiencies: 1 out of 8 tenants tested did not have the accurate amount of adjusted annual income reported on HUD Form 50059 and did not have documentation in their lease file that certain income was verified. 6 out of 8 tenants tested did not utilize the Enterprise Income Verification system timely. 1 out of 8 tenants tested did not perform recertifications on HUD Form 50059 timely. Cause Management's policies with respect to the determination of tenant eligibility and the maintenance of tenant lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs were not consistently followed. Effect or Potential Effect The procedures for determining tenant eligibility and maintaining tenant lease files were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Questioned Costs: N/A Context The sample is not considered a statistically valid sample. Identification as a Repeat Finding Not a repeat finding. Recommendation Management should establish procedures and monitor compliance with those procedures to insure that tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Auditor Noncompliance Code: R - Section 8 program administration Finding Resolution Status: In-process Views of Responsible Officials The incorrect adjusted annual income was corrected on the HUD Form 50059. The full-time manager that was authorized to run the EIV reports was out for a portion of the year. When a staff member is out or a position is vacant, someone at another site who is authorized to run EIVs will help cover until a replacement is found. The EIV paperwork has since been placed in the correct files. A full EIV Policy and Procedure manual is located on site and the new employee was trained on these policies by their supervisor and compliance manager. The tenant signed her recertification paperwork 20 days late due a transition in the office. New employee was trained on HUD policies by their supervisor and compliance manager.
Show full finding ▾Hide full finding ▴Criteria - Eligibility Tenant lease files are required to be maintained and tenant eligibility determined in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Condition In connection with our lease file review we noted the following deficiencies: 1 out of 8 tenants tested did not have the accurate amount of adjusted annual income reported on HUD Form 50059 and did not have documentation in their lease file that certain income was verified. 6 out of 8 tenants tested did not utilize the Enterprise Income Verification system timely. 1 out of 8 tenants tested did not perform recertifications on HUD Form 50059 timely. Cause Management's policies with respect to the determination of tenant eligibility and the maintenance of tenant lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs were not consistently followed. Effect or Potential Effect The procedures for determining tenant eligibility and maintaining tenant lease files were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Questioned Costs: N/A Context The sample is not considered a statistically valid sample. Identification as a Repeat Finding Not a repeat finding. Recommendation Management should establish procedures and monitor compliance with those procedures to insure that tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Auditor Noncompliance Code: R - Section 8 program administration Finding Resolution Status: In-process Views of Responsible Officials The incorrect adjusted annual income was corrected on the HUD Form 50059. The full-time manager that was authorized to run the EIV reports was out for a portion of the year. When a staff member is out or a position is vacant, someone at another site who is authorized to run EIVs will help cover until a replacement is found. The EIV paperwork has since been placed in the correct files. A full EIV Policy and Procedure manual is located on site and the new employee was trained on these policies by their supervisor and compliance manager. The tenant signed her recertification paperwork 20 days late due a transition in the office. New employee was trained on HUD policies by their supervisor and compliance manager.
Our back up plan for when a staff member is out or a position vacant is to have someone who is authorized to run EIV at another location/site to help cover until a replacement is found. In this case the EIV paperwork was held at a separate location and has since been placed in all the correct files. A full EIV Policy and Procedure manual is located on site and the new employee is trained on these policies by their supervisor and compliance manager. Both items were addressed in the follow up to the audit. The adjusted income was dealing with a lump sum of income which is not included in income. Correction was made to the 50059. The tenant signed her recertification paperwork 20 days late due a transition in the office. This was documented and file has been corrected. Additional training is provided to all managers on Section 8 Policies and Procedures on a regular basis. Policies and Procedures are also located on our direct intra network for individuals to refer to specific calculations, income issues, asset issues, forms and policies. This training is ongoing.
FAC accepted this audit on October 24, 2022 — management decision was due April 24, 2023.
FAC accepted this audit on October 27, 2021 — management decision was due April 27, 2022.
Statement of Condition During 2020, due to the COVID-19 pandemic, HUD authorized Victory Heights to transfer the projects operating surplus cash as of June 30, 2020, to Victory Heights' replacement reserve account to protect the funds for the use of delayed capital improvements. During the year ended June 30, 2021, the Victory Heights did not make the required prior year surplus cash deposit to the replacement reserve in the amount of $9,927. Criteria - Special tests and provisions The HUD letter received during 2020 requires that Victory Heights deposits any operating surplus cash as of June 30, 2020, to the replacement reserve. Effect Failure to make the required surplus cash payment results in a violation of the HUD letter and HAP contract. Cause Victory Heights did not make the required surplus cash deposit in error. Recommendation Management should deposit $9,927 from the operating account to the replacement reserve account to ensure that the replacement reserve is funded in accordance with the terms of the HUD letter and HAP contract. Auditor Noncompliance Code: N - Reserve for replacements deposits Finding Resolution Status: Resolved Views of Responsible Officials and Planned Corrective Actions The $9,927 was deposited to the replacement reserve on September 15, 2021. For the fiscal year ended June 30, 2020, management submitted requests for multiple properties to retain operating surplus cash because of project and scheduling delays due to COVID-19. As this was the first time these kinds of requests were made, there was not a uniform format for how the requests were submitted or for the terms of the approvals received. After the June 30, 2020 audits were finalized in September 2020, Management should have reviewed the HUD approval letters to see if further action was needed to move funds between accounts. Management does not anticipate this being an issue in the future as requests to retain operating surplus cash were not made for the fiscal year ending June 30, 2021 and does not expect to make these requests again. However, Management will be more diligent in the future when circumstances warrant atypical requests to ensure they are addressed in accordance with the terms in the HUD approval.
Show full finding ▾Hide full finding ▴Statement of Condition During 2020, due to the COVID-19 pandemic, HUD authorized Victory Heights to transfer the projects operating surplus cash as of June 30, 2020, to Victory Heights' replacement reserve account to protect the funds for the use of delayed capital improvements. During the year ended June 30, 2021, the Victory Heights did not make the required prior year surplus cash deposit to the replacement reserve in the amount of $9,927. Criteria - Special tests and provisions The HUD letter received during 2020 requires that Victory Heights deposits any operating surplus cash as of June 30, 2020, to the replacement reserve. Effect Failure to make the required surplus cash payment results in a violation of the HUD letter and HAP contract. Cause Victory Heights did not make the required surplus cash deposit in error. Recommendation Management should deposit $9,927 from the operating account to the replacement reserve account to ensure that the replacement reserve is funded in accordance with the terms of the HUD letter and HAP contract. Auditor Noncompliance Code: N - Reserve for replacements deposits Finding Resolution Status: Resolved Views of Responsible Officials and Planned Corrective Actions The $9,927 was deposited to the replacement reserve on September 15, 2021. For the fiscal year ended June 30, 2020, management submitted requests for multiple properties to retain operating surplus cash because of project and scheduling delays due to COVID-19. As this was the first time these kinds of requests were made, there was not a uniform format for how the requests were submitted or for the terms of the approvals received. After the June 30, 2020 audits were finalized in September 2020, Management should have reviewed the HUD approval letters to see if further action was needed to move funds between accounts. Management does not anticipate this being an issue in the future as requests to retain operating surplus cash were not made for the fiscal year ending June 30, 2021 and does not expect to make these requests again. However, Management will be more diligent in the future when circumstances warrant atypical requests to ensure they are addressed in accordance with the terms in the HUD approval.
Comments on the Finding and Each Recommendation Management acknowledges that the $9,927 of operating surplus cash as of June 30, 2020, was not deposited into the replacement reserve in accordance with the HUD approval letter. Management agrees that the funds need to be deposited to the replacement reserve. Action(s) Taken or Planned on the Finding The $9,927 was deposited to the replacement reserve on September 15, 2021. For the fiscal year ended June 30, 2020, management submitted requests for multiple properties to retain operating surplus cash because of project and scheduling delays due to COVID. As this was the first time these kinds of requests were made, there was not a uniform format for how the requests were submitted or for the terms of the approvals received. After the June 30, 2020 audits were finalized in September 2020, Management should have reviewed the HUD approval letters to see if further action was needed to move funds between accounts. Management does not anticipate this being an issue in the future as requests to retain operating surplus cash were not made for the fiscal year ending June 30, 2021, and does not expect to make these requests again. However, Management will be more diligent in the future when circumstances warrant atypical requests to ensure they are addressed in accordance with the terms in the HUD approval.
FAC accepted this audit on October 25, 2020 — management decision was due April 25, 2021.
FAC accepted this audit on October 22, 2019 — management decision was due April 22, 2020.
FAC accepted this audit on October 18, 2018 — management decision was due April 18, 2019.
FAC accepted this audit on October 10, 2017 — management decision was due April 10, 2018.
FAC accepted this audit on January 12, 2017 — management decision was due July 12, 2017.
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