EIN: 222619892
UEI: GDYLFF9XJNP7
Audited by: Daniel Dennis and Company LLP
Oversight agency: 14 [Department of Housing and Urban Development]
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Data as of September 7, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on May 21, 2026. 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 November 21, 2026 (74 days from today).
What is a management decision? →Condition During audit testing of tenant eligibility documentation, the auditor was unable to locate one out of eight tenant files selected for testing. In addition, management disclosed that nine out of forty tenant files for the program could not currently be located. As a result, required documentation supporting tenant eligibility and compliance with federal program requirements was not available for review. Criteria The Uniform Guidance requires that federal awards be administered in compliance with the terms and conditions of the federal award and that auditees maintain sufficient records to support compliance and amounts charged to federal programs, with such documentation being accessible for audit and oversight purposes. Cause The missing tenant files appear to be attributable to deficiencies in record retention and file management controls, including inadequate procedures to ensure that tenant records are properly maintained, safeguarded, and retrievable for monitoring and audit purposes. Effect or Potential Effect The absence of tenant files may limit the auditee’s ability to demonstrate compliance with federal award requirements. Without supporting documentation, the allowability of costs charged to the program for affected tenants may not be able to be verified, increasing the risk that federal funds may have been expended for tenants who did not meet eligibility requirements. Context One out of eight original tenant files selected for testing were not able to be located. In addition, management disclosed that nine out of population of forty tenant files for the program could not currently be located. Questioned Costs None Repeat Finding No Recommendation The auditor recommends that management strengthen record retention and file management controls to ensure that all tenant eligibility documentation is properly maintained and readily available. Improved procedures should include monitoring, periodic reconciliation of tenant files to program records, and safeguards to prevent loss or misplacement of documentation required to support compliance with federal award requirements. Management Response Management agrees with the finding and has prepared an attached corrective action plan to address the issue.
Show full finding ▾Hide full finding ▴Condition During audit testing of tenant eligibility documentation, the auditor was unable to locate one out of eight tenant files selected for testing. In addition, management disclosed that nine out of forty tenant files for the program could not currently be located. As a result, required documentation supporting tenant eligibility and compliance with federal program requirements was not available for review. Criteria The Uniform Guidance requires that federal awards be administered in compliance with the terms and conditions of the federal award and that auditees maintain sufficient records to support compliance and amounts charged to federal programs, with such documentation being accessible for audit and oversight purposes. Cause The missing tenant files appear to be attributable to deficiencies in record retention and file management controls, including inadequate procedures to ensure that tenant records are properly maintained, safeguarded, and retrievable for monitoring and audit purposes. Effect or Potential Effect The absence of tenant files may limit the auditee’s ability to demonstrate compliance with federal award requirements. Without supporting documentation, the allowability of costs charged to the program for affected tenants may not be able to be verified, increasing the risk that federal funds may have been expended for tenants who did not meet eligibility requirements. Context One out of eight original tenant files selected for testing were not able to be located. In addition, management disclosed that nine out of population of forty tenant files for the program could not currently be located. Questioned Costs None Repeat Finding No Recommendation The auditor recommends that management strengthen record retention and file management controls to ensure that all tenant eligibility documentation is properly maintained and readily available. Improved procedures should include monitoring, periodic reconciliation of tenant files to program records, and safeguards to prevent loss or misplacement of documentation required to support compliance with federal award requirements. Management Response Management agrees with the finding and has prepared an attached corrective action plan to address the issue.
Responsible Official Nichelle Brown, Senior Vice President of Property and Asset Management Plan Detail Management concurs with the audit finding related to the inability to locate certain tenant files. Management acknowledges that one of the eight tenant files selected for audit testing was not available and concurs with the disclosure that nine of the forty tenant files for the program could not currently be located. Management has evaluated the circumstances contributing to the missing files and determined that existing record retention and file management procedures did not sufficiently ensure that all tenant documentation was safeguarded and readily retrievable. Management recognizes that the absence of tenant files limits the ability to demonstrate compliance with federal award requirements and to support costs charged to the program. To address this issue, management has initiated corrective actions to strengthen document retention and file management controls. These actions include implementing enhanced tracking and reconciliation processes for tenant files, improving secure storage and retention practices, and reinforcing staff responsibilities for maintaining complete and accessible tenant records. Management also plans to conduct periodic internal reviews to confirm that tenant files are properly maintained and available for monitoring and audit purposes. Specifically we plan to: 1. All physical resident files are stored in locked cabinets or secured file rooms with access limited to authorized personnel, including Property Managers, Assistant Property Managers, Compliance Specialists, and designated corporate staff. 2. Access to records will be restricted based on job function and necessity 3. There will be a formal file transfer and chain-of-custody process with required signatures 4. File transfers between properties will be by locked file transport boxes marked as confidential. 5. Employees will be required to maintain direct control of files during transport. 6. All files will be maintained during required retention periods. Management believes that these corrective actions will improve compliance with record retention requirements and reduce the risk of missing documentation in the future. Anticipated Completion Date The corrective action is in the process of being implemented and expected to be completed in fiscal year 2026.
Condition During audit testing, the auditor identified four instances in which tenants’ annual HUD‑50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures (tenant recertification), were not completed in a timely manner. Specifically, recertifications were completed three to twelve months after the required annual effective date, resulting in significant delays between the effective date and execution of the certification. In addition, one tenant recertification file lacked adequate income support documentation to substantiate tenant eligibility and the calculation of the tenant portion of rent. Criteria The terms and conditions of the federal award require the auditee to determine tenant eligibility and calculate the tenant portion of rent based on supported and documented income information on at least an annual basis. Cause The condition occurred because management had insufficient internal controls and monitoring procedures to ensure that tenant recertifications were completed within required timeframes and that income documentation was consistently obtained, reviewed, and retained prior to determining eligibility and calculating tenant rent. Effect or Potential Effect Untimely tenant recertifications increase the risk that tenants may occupy assisted units without documented eligibility for the applicable period. As a result, subsidy rents charged during uncertified periods may not be allowable under the terms and conditions of the federal award. Additionally, because income support documentation was not maintained for one tenant, the auditee was unable to demonstrate that eligibility requirements were met or that the tenant’s portion of rent was calculated correctly, which could result in unallowable subsidy payments. Context Testing was performed on 16 tenant files selected from a population of 40 tenant files for the program. Questioned Costs $13,560 Repeat Finding No Recommendation The auditor recommends that management strengthen internal controls and monitoring procedures to ensure tenant recertifications are completed timely, including periodic supervisory review. In addition, management should implement procedures to ensure that income documentation is obtained, reviewed, and retained prior to determining tenant eligibility and calculating rent amounts. Management Response Management agrees with the finding and has prepared an attached corrective action plan to address the issue.
Show full finding ▾Hide full finding ▴Condition During audit testing, the auditor identified four instances in which tenants’ annual HUD‑50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures (tenant recertification), were not completed in a timely manner. Specifically, recertifications were completed three to twelve months after the required annual effective date, resulting in significant delays between the effective date and execution of the certification. In addition, one tenant recertification file lacked adequate income support documentation to substantiate tenant eligibility and the calculation of the tenant portion of rent. Criteria The terms and conditions of the federal award require the auditee to determine tenant eligibility and calculate the tenant portion of rent based on supported and documented income information on at least an annual basis. Cause The condition occurred because management had insufficient internal controls and monitoring procedures to ensure that tenant recertifications were completed within required timeframes and that income documentation was consistently obtained, reviewed, and retained prior to determining eligibility and calculating tenant rent. Effect or Potential Effect Untimely tenant recertifications increase the risk that tenants may occupy assisted units without documented eligibility for the applicable period. As a result, subsidy rents charged during uncertified periods may not be allowable under the terms and conditions of the federal award. Additionally, because income support documentation was not maintained for one tenant, the auditee was unable to demonstrate that eligibility requirements were met or that the tenant’s portion of rent was calculated correctly, which could result in unallowable subsidy payments. Context Testing was performed on 16 tenant files selected from a population of 40 tenant files for the program. Questioned Costs $13,560 Repeat Finding No Recommendation The auditor recommends that management strengthen internal controls and monitoring procedures to ensure tenant recertifications are completed timely, including periodic supervisory review. In addition, management should implement procedures to ensure that income documentation is obtained, reviewed, and retained prior to determining tenant eligibility and calculating rent amounts. Management Response Management agrees with the finding and has prepared an attached corrective action plan to address the issue.
Responsible Official Nichelle Brown, Senior Vice President of Property and Asset Management Plan Detail Management concurs with the audit finding related to untimely tenant recertifications and missing income documentation. Management reviewed the circumstances that contributed to the delayed completion of tenant recertifications and incomplete documentation and determined that existing internal monitoring procedures did not consistently ensure tenant recertifications were completed within required timeframes. To address these issues, management has implemented corrective actions designed to strengthen oversight and improve the timeliness and completeness of tenant recertifications. These actions include reinforcing internal tracking procedures for recertification due dates, enhancing supervisory review of tenant eligibility files, and providing additional training to staff responsible for tenant eligibility determinations and income verification. Management expects these corrective actions to be fully implemented and operating effectively for all tenant recertifications going forward, thereby improving compliance with federal award requirements and reducing the risk of future untimely tenant recertifications or missing documentation. Anticipated Completion Date The corrective action is in the process of being implemented and expected to be completed in fiscal year 2026.
FAC accepted this audit on October 18, 2024 — management decision was due April 18, 2025.
FAC accepted this audit on October 24, 2023 — management decision was due April 24, 2024.
FAC accepted this audit on November 12, 2022 — management decision was due May 12, 2023.
FAC accepted this audit on October 3, 2021 — management decision was due April 3, 2022.
FAC accepted this audit on October 1, 2020 — management decision was due April 1, 2021.
FAC accepted this audit on September 25, 2019 — management decision was due March 25, 2020.
FAC accepted this audit on September 20, 2018 — management decision was due March 20, 2019.
FAC accepted this audit on October 25, 2017 — management decision was due April 25, 2018.
GSA_MIGRATION
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GSA_MIGRATION
2016-001
FAC accepted this audit on October 20, 2016 — management decision was due April 20, 2017.
GSA_MIGRATION
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GSA_MIGRATION
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