EIN: 161452557
UEI: NWF8UQF88D23
Data as of August 21, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 11, 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 June 11, 2026 (71 days ago).
What is a management decision? →Program U.S. Department of Housing and Urban Development (HUD) – Supportive Housing for Persons with Disabilities (Section 811) and Project Rental Assistance, Assistance Listing No. 14.181. This finding was partially reported as finding 2023-001 in the prior year. Condition/Context A haphazard sample of three tenant files out of twenty-four (not a statistically valid sample) were selected for testing and the required documentation to determine eligibility, as required by the HUD regulations, could not be located as follows: For one of the files, Form HUD-50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures was not provided. For one of the files, there was no verification of income by a third party provided. For all of the files, there was no signed move-in/move-out inspection form provided. Additionally, our testing indicated that the required deposits to the replacement reserve account had not been made for the last quarter of the Corporation’s fiscal year for any tenants. Criteria Tenant files and all required documents should be completed and maintained as required by HUD requirements and replacement reserve deposits need to be made timely. Cause There were no procedures in place to ensure that all tenant files were properly completed and maintained or ensure that replacement reserve deposits were made. Effect Inadequate tenant file documentation and lack of timely replacement reserve deposits has resulted in the Corporation’s inability to comply with the HUD Regulatory Agreement. Recommendation We recommend the Corporation establish procedures and internal controls to ensure that all required documentation is maintained, and all required reserve deposits are made timely, in accordance with HUD requirements. Finding 2024-002 Program U.S. Department of Housing and Urban Development (HUD) – Supportive Housing for Persons with Disabilities (Section 811) and Project Rental Assistance, Assistance Listing No. 14.181. This finding was partially reported as finding 2023-001 in the prior year. Condition/Context A haphazard sample of three tenant files out of twenty-four (not a statistically valid sample) were selected for testing and the required documentation to determine eligibility, as required by the HUD regulations, could not be located as follows: For one of the files, Form HUD-50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures was not provided. For one of the files, there was no verification of income by a third party provided. For all of the files, there was no signed move-in/move-out inspection form provided. Additionally, our testing indicated that the required deposits to the replacement reserve account had not been made for the last quarter of the Corporation’s fiscal year for any tenants. Criteria Tenant files and all required documents should be completed and maintained as required by HUD requirements and replacement reserve deposits need to be made timely. Cause There were no procedures in place to ensure that all tenant files were properly completed and maintained or ensure that replacement reserve deposits were made. Effect Inadequate tenant file documentation and lack of timely replacement reserve deposits has resulted in the Corporation’s inability to comply with the HUD Regulatory Agreement.
Show full finding ▾Hide full finding ▴Program U.S. Department of Housing and Urban Development (HUD) – Supportive Housing for Persons with Disabilities (Section 811) and Project Rental Assistance, Assistance Listing No. 14.181. This finding was partially reported as finding 2023-001 in the prior year. Condition/Context A haphazard sample of three tenant files out of twenty-four (not a statistically valid sample) were selected for testing and the required documentation to determine eligibility, as required by the HUD regulations, could not be located as follows: For one of the files, Form HUD-50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures was not provided. For one of the files, there was no verification of income by a third party provided. For all of the files, there was no signed move-in/move-out inspection form provided. Additionally, our testing indicated that the required deposits to the replacement reserve account had not been made for the last quarter of the Corporation’s fiscal year for any tenants. Criteria Tenant files and all required documents should be completed and maintained as required by HUD requirements and replacement reserve deposits need to be made timely. Cause There were no procedures in place to ensure that all tenant files were properly completed and maintained or ensure that replacement reserve deposits were made. Effect Inadequate tenant file documentation and lack of timely replacement reserve deposits has resulted in the Corporation’s inability to comply with the HUD Regulatory Agreement. Recommendation We recommend the Corporation establish procedures and internal controls to ensure that all required documentation is maintained, and all required reserve deposits are made timely, in accordance with HUD requirements. Finding 2024-002 Program U.S. Department of Housing and Urban Development (HUD) – Supportive Housing for Persons with Disabilities (Section 811) and Project Rental Assistance, Assistance Listing No. 14.181. This finding was partially reported as finding 2023-001 in the prior year. Condition/Context A haphazard sample of three tenant files out of twenty-four (not a statistically valid sample) were selected for testing and the required documentation to determine eligibility, as required by the HUD regulations, could not be located as follows: For one of the files, Form HUD-50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures was not provided. For one of the files, there was no verification of income by a third party provided. For all of the files, there was no signed move-in/move-out inspection form provided. Additionally, our testing indicated that the required deposits to the replacement reserve account had not been made for the last quarter of the Corporation’s fiscal year for any tenants. Criteria Tenant files and all required documents should be completed and maintained as required by HUD requirements and replacement reserve deposits need to be made timely. Cause There were no procedures in place to ensure that all tenant files were properly completed and maintained or ensure that replacement reserve deposits were made. Effect Inadequate tenant file documentation and lack of timely replacement reserve deposits has resulted in the Corporation’s inability to comply with the HUD Regulatory Agreement.
2024-002: Section 811, Assistance Listing No. 14.181 Three tenant files were selected for testing and the required documentation to determine eligibility, as required by the HUD regulations, could not be located as follows: • One of the files was missing Form HUD-50059, Owner’s Certification of Compliance. • One of the files was missing verification of income by a third party. • All three of the files were missing signed move-in/move-out inspection forms. Additionally, our testing indicated that the required deposits to the replacement reserve account had not been made for the last quarter of the Corporation’s fiscal year for any tenants. Recommendation: We recommend the Corporation establish procedures and internal controls to ensure that all required documentation is maintained, and all required reserve deposits are made timely, in accordance with HUD requirements. Action Taken: Management concurs with this recommendation. Since assuming property management on June 1, 2025, ULREDC has conducted a tenant file audit. All property management staff have been properly trained to ensure compliance with certification, documentation, and inspection requirements. Missing documentation, including Form HUD-50059, income verifications, and leasing inspections, is being corrected. Replacement reserve deposits were delayed because properties were not cash flowing. As leasing stabilizes, deposits will resume and be verified once RealPage is fully active. RealPage will serve as the compliance and record-retention platform. Quarterly internal compliance reviews will be instituted to confirm file accuracy and documentation completeness. We are committed to compliance and accuracy as required by the U.S. Department of Housing and Urban Development. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please contact Dr. Hawkins at shawkins@ulr.org.
2023-001
FAC accepted this audit on December 7, 2023 — management decision was due June 7, 2024.
Finding 2023-001 Program U.S. Department of Housing and Urban Development (HUD) – Supportive Housing for Persons with Disabilities (Section 811) and Project Rental Assistance, Assistance Listing No. 14.181. Condition Three tenant files were selected for testing and the required documentation to determine eligibility, as required by the HUD regulations, could not be located as follows: For two of the files, Form HUD-50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures had not been completed before the tenant’s anniversary date as required by HUD. Criteria Tenant recertifications should be completed and maintained as required by HUD requirements. Cause There were no procedures in place to ensure that all annual recertifications were properly completed and maintained. Effect Failure to comply with the annual recertification process is an instance of noncompliance with the Regulatory Agreement. Recommendation We recommend the Corporation establish procedures to ensure that the annual recertifications are completed on a timely basis in accordance with HUD requirements. Reporting Views of Responsible Officials Management agrees with the recommendation and the Corporation’s Board of Directors has made the decision to change property managing agents effective January 1, 2024. It is anticipated that the change to a new property managing agent will allow the Corporation to establish procedures to ensure all recertifications are performed and maintained in accordance with the regulatory agreement.
Show full finding ▾Hide full finding ▴Finding 2023-001 Program U.S. Department of Housing and Urban Development (HUD) – Supportive Housing for Persons with Disabilities (Section 811) and Project Rental Assistance, Assistance Listing No. 14.181. Condition Three tenant files were selected for testing and the required documentation to determine eligibility, as required by the HUD regulations, could not be located as follows: For two of the files, Form HUD-50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures had not been completed before the tenant’s anniversary date as required by HUD. Criteria Tenant recertifications should be completed and maintained as required by HUD requirements. Cause There were no procedures in place to ensure that all annual recertifications were properly completed and maintained. Effect Failure to comply with the annual recertification process is an instance of noncompliance with the Regulatory Agreement. Recommendation We recommend the Corporation establish procedures to ensure that the annual recertifications are completed on a timely basis in accordance with HUD requirements. Reporting Views of Responsible Officials Management agrees with the recommendation and the Corporation’s Board of Directors has made the decision to change property managing agents effective January 1, 2024. It is anticipated that the change to a new property managing agent will allow the Corporation to establish procedures to ensure all recertifications are performed and maintained in accordance with the regulatory agreement.
2023-001: Section 811, Assistance Listing No. 14.181 Three tenant files were selected for testing and the required documentation to determine eligibility, as required by the HUD regulations, could not be located as follows: • Two of the files were missing Form HUD-50059, Owner’s Certification of Compliance. Recommendation: We recommend the Corporation establish procedures to ensure that the annual recertifications are completed on a timely basis in accordance with HUD requirements. Action Taken: Management agrees with the recommendation and the Corporation’s Board of Directors has made the decision to change property managing agents effective January 1, 2024. It is anticipated that the change to a new property managing agent will allow the Corporation to establish procedures to ensure all recertifications are performed and maintained in accordance with the regulatory agreement. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Dr. Seanelle Hawkins at (585) 325-6530.
2022-001
FAC accepted this audit on December 28, 2022 — management decision was due June 28, 2023.
Finding 2022-001 Program U.S. Department of Housing and Urban Development (HUD) ? Supportive Housing for Persons with Disabilities (Section 811) and Project Rental Assistance, Assistance Listing No. 14.181. Condition Three tenant files were selected for testing and the required documentation to determine eligibility, as required by the HUD regulations, could not be located as follows: ? 2 files were missing Form HUD-50059, Owner?s Certification of Compliance ? 2 files were missing the move-in and move-out inspection forms Criteria Tenant files and all required documents should be maintained as established by HUD requirements. Cause There were no procedures in place to ensure that all tenant files were properly maintained. Effect Inadequate tenant file documentation has resulted in the Corporation?s inability to comply with HUD regulations. Recommendation We recommend the Corporation establish procedures for maintaining tenant files to comply with HUD requirements for verification of tenant information, as required. Reporting Views of Responsible Officials Management agrees with the recommendation and will establish procedures with the managing agent to ensure all tenant files are maintained in accordance with HUD regulations.
Show full finding ▾Hide full finding ▴Finding 2022-001 Program U.S. Department of Housing and Urban Development (HUD) ? Supportive Housing for Persons with Disabilities (Section 811) and Project Rental Assistance, Assistance Listing No. 14.181. Condition Three tenant files were selected for testing and the required documentation to determine eligibility, as required by the HUD regulations, could not be located as follows: ? 2 files were missing Form HUD-50059, Owner?s Certification of Compliance ? 2 files were missing the move-in and move-out inspection forms Criteria Tenant files and all required documents should be maintained as established by HUD requirements. Cause There were no procedures in place to ensure that all tenant files were properly maintained. Effect Inadequate tenant file documentation has resulted in the Corporation?s inability to comply with HUD regulations. Recommendation We recommend the Corporation establish procedures for maintaining tenant files to comply with HUD requirements for verification of tenant information, as required. Reporting Views of Responsible Officials Management agrees with the recommendation and will establish procedures with the managing agent to ensure all tenant files are maintained in accordance with HUD regulations.
2022-001: Section 811, Assistance Listing No. 14.181 Three tenant files were selected for testing and the required documentation to determine eligibility, as required by the HUD regulations, could not be located as follows: ? 2 files were missing Form HUD-50059, Owner?s Certification of Compliance ? 2 files were missing the move-in and move-out inspection forms Recommendation: We recommend the Corporation establish procedures for maintaining tenant files to comply with HUD requirements for verification of tenant information, as required. Action Taken: Management agrees with the recommendation and will establish procedures with the managing agent to ensure all tenant files are maintained in accordance with HUD regulations.
2021-001
FAC accepted this audit on September 13, 2021 — management decision was due March 13, 2022.
Finding 2021-001 Program U.S. Department of Housing and Urban Development (HUD) ? Supportive Housing for Persons with Disabilities (Section 811) and Project Rental Assistance, CFDA No. 14.181. Condition The March 31, 2021 surplus cash available was not deposited to the residual receipts account for the Corporation within 60 days after year-end. Criteria The HUD regulatory agreement states all surplus cash available at the end of an annual fiscal period must be deposited in the residual receipts account within 60 days after the end of the annual fiscal period in which the receipts were generated. Effect Failure to comply with the required residual receipt deposit timeline is an instance of noncompliance with the regulatory agreement. Recommendation We recommend the Corporation establish procedures to ensure surplus cash is deposited to the residual receipts account on a timely basis. Reporting Views of Responsible Officials Management agrees with the condition and will establish procedures to ensure surplus cash is deposited on a timely basis in accordance with the regulatory agreement. Dr. Seanelle Hawkins, CEO, will assume responsibility for implementation by March 31, 2022.
Show full finding ▾Hide full finding ▴Finding 2021-001 Program U.S. Department of Housing and Urban Development (HUD) ? Supportive Housing for Persons with Disabilities (Section 811) and Project Rental Assistance, CFDA No. 14.181. Condition The March 31, 2021 surplus cash available was not deposited to the residual receipts account for the Corporation within 60 days after year-end. Criteria The HUD regulatory agreement states all surplus cash available at the end of an annual fiscal period must be deposited in the residual receipts account within 60 days after the end of the annual fiscal period in which the receipts were generated. Effect Failure to comply with the required residual receipt deposit timeline is an instance of noncompliance with the regulatory agreement. Recommendation We recommend the Corporation establish procedures to ensure surplus cash is deposited to the residual receipts account on a timely basis. Reporting Views of Responsible Officials Management agrees with the condition and will establish procedures to ensure surplus cash is deposited on a timely basis in accordance with the regulatory agreement. Dr. Seanelle Hawkins, CEO, will assume responsibility for implementation by March 31, 2022.
2021-001: Section 811, CFDA 14.181 The March 31, 2021 surplus cash available was not deposited to the residual receipts account for the Corporation within 60 days after year-end. Recommendation: We recommend the Corporation establish procedures to ensure surplus cash is deposited to the residual receipts account timely. Action Taken: Management agrees with the condition and will establish procedures to ensure surplus cash is deposited on a timely basis in accordance with the regulatory agreement.
Finding 2021-002 Program U.S. Department of Housing and Urban Development (HUD) ? Supportive Housing for Persons with Disabilities (Section 811) and Project Rental Assistance, CFDA No. 14.181. Condition For one of three tenants selected for tenant testing, the tenant?s lease agreement could not be located, as required by the HUD Regulatory Agreement. Criteria Tenant lease agreements should be maintained as established by HUD requirements. Effect Failure to comply with maintenance of tenant lease agreements is an instance of noncompliance with the regulatory agreement. Recommendation We recommend the Corporation establish procedures for maintaining the tenant lease agreement, as required. Reporting Views of Responsible Officials Management agrees with the condition and will establish procedures to ensure all tenant lease agreements are maintained in accordance with the regulatory agreement. Dr. Seanelle Hawkins, CEO, will assume responsibility for implementation by March 31, 2022.
Show full finding ▾Hide full finding ▴Finding 2021-002 Program U.S. Department of Housing and Urban Development (HUD) ? Supportive Housing for Persons with Disabilities (Section 811) and Project Rental Assistance, CFDA No. 14.181. Condition For one of three tenants selected for tenant testing, the tenant?s lease agreement could not be located, as required by the HUD Regulatory Agreement. Criteria Tenant lease agreements should be maintained as established by HUD requirements. Effect Failure to comply with maintenance of tenant lease agreements is an instance of noncompliance with the regulatory agreement. Recommendation We recommend the Corporation establish procedures for maintaining the tenant lease agreement, as required. Reporting Views of Responsible Officials Management agrees with the condition and will establish procedures to ensure all tenant lease agreements are maintained in accordance with the regulatory agreement. Dr. Seanelle Hawkins, CEO, will assume responsibility for implementation by March 31, 2022.
2021-002: Section 811, CFDA 14.181 For one of three tenants selected for tenant testing, the tenant?s lease agreement could not be located, as required by the HUD Regulatory Agreement. Recommendation: We recommend the Corporation establish procedures for maintaining the original lease as required. We recommend the Corporation review these procedures with staff to ensure understanding of compliance with HUD requirements. Action Taken: Management agrees with the condition and will establish procedures to ensure all tenant lease agreements are maintained in accordance with the regulatory agreement.
Finding 2021-003 Program U.S. Department of Housing and Urban Development (HUD) ? Supportive Housing for Persons with Disabilities (Section 811) and Project Rental Assistance, CFDA No. 14.181. Condition We determined a sample selection size of three selections for tenant testing. The Corporation did not prepare a HUD-50059, Owner?s Certification of Compliance with HUD?s Tenant Eligibility and Rent Procedures, before the tenant?s anniversary date, as required by HUD, for all three selections. Criteria Tenant recertifications should be completed and maintained as required by HUD requirements. Effect Failure to comply with the annual recertification process is an instance of noncompliance with the regulatory agreement. Recommendation We recommend the Corporation establish procedures to ensure that the annual recertifications are performed on a timely basis in accordance with HUD requirements. Reporting Views of Responsible Officials Management agrees with the condition and will establish procedures to ensure all recertifications are performed and maintained in accordance with the regulatory agreement. Dr. Seanelle Hawkins, CEO, will assume responsibility for implementation by March 31, 2022.
Show full finding ▾Hide full finding ▴Finding 2021-003 Program U.S. Department of Housing and Urban Development (HUD) ? Supportive Housing for Persons with Disabilities (Section 811) and Project Rental Assistance, CFDA No. 14.181. Condition We determined a sample selection size of three selections for tenant testing. The Corporation did not prepare a HUD-50059, Owner?s Certification of Compliance with HUD?s Tenant Eligibility and Rent Procedures, before the tenant?s anniversary date, as required by HUD, for all three selections. Criteria Tenant recertifications should be completed and maintained as required by HUD requirements. Effect Failure to comply with the annual recertification process is an instance of noncompliance with the regulatory agreement. Recommendation We recommend the Corporation establish procedures to ensure that the annual recertifications are performed on a timely basis in accordance with HUD requirements. Reporting Views of Responsible Officials Management agrees with the condition and will establish procedures to ensure all recertifications are performed and maintained in accordance with the regulatory agreement. Dr. Seanelle Hawkins, CEO, will assume responsibility for implementation by March 31, 2022.
2021-003: Section 811, CFDA 14.181 We determined a sample selection size of three selections for tenant testing. The Corporation did not prepare a HUD-50059, Owner?s Certification of Compliance with HUD?s Tenant Eligibility and Rent Procedures, before the tenant?s anniversary date, as required by HUD, for all three selections. Recommendation: We recommend the Corporation establish procedure to ensure a review is conducted of recertifications to ensure their accuracy and timely completion in accordance with HUD requirements. Action Taken: Management agrees with the condition and will establish procedures to ensure all recertifications are performed and maintained in accordance with the regulatory agreement.
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