EIN: 311595534
UEI: J1LQVU9M4N83
Audited by: Wharton CPA, LLC
Oversight agency: 14 [Department of Housing and Urban Development]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 20, 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 20, 2025 (528 days ago).
What is a management decision? →The Project did not prepare a HUD 9250 to remit excess residual receipts, nor did it mail a check or transmit a wire of those funds. Criteria: According to the Consolidated Appropriations Act, 2017, owners subject to a Section 202 or 811 Project Rental Assistance Contract (PRAC) are required to remit any excess balance in a Residual Receipts account, greater than $250 per unit, to HUD’s Accounting Center upon termination or renewal of the PRAC contract. Cause: The cause is undeterminable. Effect: Residual receipts balance is $17,507 as of December 31, 2023. The allowable balance is $5,250 ($250 X 21 units), resulting in excess residual receipts of $12,257. Recommendation: I recommend the Property prepare the HUD 9250 requesting to remit excess funds to HUD.
Show full finding ▾Hide full finding ▴2023-1 Excess Residual Receipts Condition: The Project did not prepare a HUD 9250 to remit excess residual receipts, nor did it mail a check or transmit a wire of those funds. Criteria: According to the Consolidated Appropriations Act, 2017, owners subject to a Section 202 or 811 Project Rental Assistance Contract (PRAC) are required to remit any excess balance in a Residual Receipts account, greater than $250 per unit, to HUD’s Accounting Center upon termination or renewal of the PRAC contract. Cause: The cause is undeterminable. Effect: Residual receipts balance is $17,507 as of December 31, 2023. The allowable balance is $5,250 ($250 X 21 units), resulting in excess residual receipts of $12,257. Recommendation: I recommend the Property prepare the HUD 9250 requesting to remit excess funds to HUD.
Residual Receipts in the amount of $12,257 was not incurred in the fiscal year of 2023. This surplus cash was incurred in prior years. Excess residual receipts have not been remitted for two reasons 1) funds are needed for improvements which we are pursuing to 3 bids for as required and 2) HUD has not notified management of the method to remit.
The Project did not make the required deposits into the bank account on a monthly basis. There were 11 deposits made during the 2023 year. Criteria: According to the Regulatory Agreement, “mortgagor will establish and maintain a reserve fund for replacements in a separate account in a bank…Concurrently with the effective commencement of rental assistance payments under the Project Rental Assistance Contract, the Mortgagor will deposit an amount…per month unless a different date or amount is approved in writing by HUD”. Cause: The cause is undeterminable. Effect: The Project is not in compliance with the Regulatory Agreement. The cash balance was overstated by $1,076 related to deposits that were never made to this account. The balance was corrected during the audit. Recommendation: I recommend the Property make required monthly deposits according to the Regulatory Agreement.
Show full finding ▾Hide full finding ▴2023-2 Reserve for Replacement Deposits Not Made or Not Made Timely 2023-2 Reserve for Replacement Deposits Not Made Timely or Not At All Condition: The Project did not make the required deposits into the bank account on a monthly basis. There were 11 deposits made during the 2023 year. Criteria: According to the Regulatory Agreement, “mortgagor will establish and maintain a reserve fund for replacements in a separate account in a bank…Concurrently with the effective commencement of rental assistance payments under the Project Rental Assistance Contract, the Mortgagor will deposit an amount…per month unless a different date or amount is approved in writing by HUD”. Cause: The cause is undeterminable. Effect: The Project is not in compliance with the Regulatory Agreement. The cash balance was overstated by $1,076 related to deposits that were never made to this account. The balance was corrected during the audit. Recommendation: I recommend the Property make required monthly deposits according to the Regulatory Agreement.
The required annual deposit was made into the property’s reserve for replacement account. However, in October 2023, management was notified by the banking institution of fraudulent activities that had taken place with some of the Reserve for Replacement accounts held at their institution. The banking institution closed all accounts and restricted all routine depository activity. The banking institution established new accounts in January 2024 at which time management could resume making deposits. Management’s records reflect that 12 checks were drafted and in 2023.
2022-001, 2021-004
The owner did not meet the HUD financial reporting requirement. Criteria: According to HUD’s Uniform Financial Reporting Standards rule, annually, an owner is required to submit a financial statement, prepared in accordance with generally accepted accounting principles (GAAP), in the electronic format specified by HUD. The unaudited financial statement is due three months after the owner’s fiscal year end and the audited financial statement is due nine months after its fiscal year-end (24 CFR section 5.801). The financial statement must include the financial activities of this program. Cause: The cause is undeterminable. Effect: The Project is not compliant with HUD program requirements. Recommendation: I recommend the owner meet HUD program requirements.
Show full finding ▾Hide full finding ▴2023-3 Late HUD Financial Reporting Condition: The owner did not meet the HUD financial reporting requirement. Criteria: According to HUD’s Uniform Financial Reporting Standards rule, annually, an owner is required to submit a financial statement, prepared in accordance with generally accepted accounting principles (GAAP), in the electronic format specified by HUD. The unaudited financial statement is due three months after the owner’s fiscal year end and the audited financial statement is due nine months after its fiscal year-end (24 CFR section 5.801). The financial statement must include the financial activities of this program. Cause: The cause is undeterminable. Effect: The Project is not compliant with HUD program requirements. Recommendation: I recommend the owner meet HUD program requirements.
We will ensure that going forward, processes are in place to allow for the timely submission of the financial reporting requirements. Further, we request that this finding be removed as the late filing occurred in 2024 and should be given in 2024 pursuant to AU-C 935.
FAC accepted this audit on September 6, 2023 — management decision was due March 6, 2024.
The Project did not prepare a HUD 9250 to remit excess residual receipts, nor did it mail a check or transmit a wire of those funds. Criteria: According to the Consolidated Appropriations Act, 2017, owners subject to a Section 202 or 811 Project Rental Assistance Contract (PRAC) are required to remit any excess balance in a Residual Receipts account, greater than $250 per unit, to HUD?s Accounting Center upon termination or renewal of the PRAC contract. Cause: The cause is undeterminable. Effect: Residual receipts balance is $17,459 as of December 31, 2022. The allowable balance is $5,250 ($250 X 21 units), resulting in excess residual receipts of $12,209. Recommendation: I recommend the Property prepare the HUD 9250 requesting to remit excess funds to HUD.
Show full finding ▾Hide full finding ▴2022-1 Excess Residual Receipts Condition: The Project did not prepare a HUD 9250 to remit excess residual receipts, nor did it mail a check or transmit a wire of those funds. Criteria: According to the Consolidated Appropriations Act, 2017, owners subject to a Section 202 or 811 Project Rental Assistance Contract (PRAC) are required to remit any excess balance in a Residual Receipts account, greater than $250 per unit, to HUD?s Accounting Center upon termination or renewal of the PRAC contract. Cause: The cause is undeterminable. Effect: Residual receipts balance is $17,459 as of December 31, 2022. The allowable balance is $5,250 ($250 X 21 units), resulting in excess residual receipts of $12,209. Recommendation: I recommend the Property prepare the HUD 9250 requesting to remit excess funds to HUD.
2022-1 ? Excess Residual Receipts Condition: The Project did not prepare a HUD 9250 to remit excess residual receipts, nor did it mail a check or transmit a wire of those funds. Response: Residual Receipts in the amount of $12,209 was not incurred in the fiscal year of 2022. This surplus cash was incurred some years ago. Excess residual receipts have not been remitted for two reasons 1) the property is in need of the funds to pay for necessary improvements in which we are pursuing to obtain 3 bids as required and 2) HUD has not notified management of the method to remit.
2021-004
FAC accepted this audit on April 30, 2022 — management decision was due October 30, 2022.
Management failed to properly reconcile prepaid insurance expenses to the general ledger. Criteria: Management is required to prepare financial statements in accordance with generally accepted accounting principles. Cause: The cause is undeterminable. Effect: Misrepresentation of prepaid expenses could have an impact on both the balance sheet and the income statements. Recommendation: I recommend management properly record prepaid insurance expenses.
Show full finding ▾Hide full finding ▴2021-1 Prepaid Insurance Not Properly Recorded Condition: Management failed to properly reconcile prepaid insurance expenses to the general ledger. Criteria: Management is required to prepare financial statements in accordance with generally accepted accounting principles. Cause: The cause is undeterminable. Effect: Misrepresentation of prepaid expenses could have an impact on both the balance sheet and the income statements. Recommendation: I recommend management properly record prepaid insurance expenses.
In 2021 we were recording prepaid expenses monthly as required and reconciling based on the policy renewal date of 3/15/2021. Going forward, we will adjust the general ledger to match that of the prepaid expense schedule at fiscal year-end in reconciliation of the same.
Management did not record utility accruals in the accounting records. Criteria: The accrual accounting method ensures transactions are recognized in the accounting period incurred, rather than paid; which follows the matching principle. Cause: The cause is undeterminable. Effect: Not recording accruals could have a material impact on both the balance sheet and the income statements. Recommendation: I recommend management post all accruals to properly reflect the financial position of the Project.
Show full finding ▾Hide full finding ▴2021-2 Accruals Not Properly Posted Condition: Management did not record utility accruals in the accounting records. Criteria: The accrual accounting method ensures transactions are recognized in the accounting period incurred, rather than paid; which follows the matching principle. Cause: The cause is undeterminable. Effect: Not recording accruals could have a material impact on both the balance sheet and the income statements. Recommendation: I recommend management post all accruals to properly reflect the financial position of the Project.
We will ensure that going forward, all required utility accrual entries will be done timely.
The Project did not make the required deposit into the bank account on a monthly basis. Criteria: According to the Regulatory Agreement, ?mortgagor will establish and maintain a reserve fund for replacements in a separate account in a bank?Concurrently with the effective commencement of rental assistance payments under the Project Rental Assistance Contract, the Mortgagor will deposit an amount?per month unless a different date or amount is approved in writing by HUD?. Cause: The cause is undeterminable. Effect: The Project is not in compliance with the Regulatory Agreement. Recommendation: I recommend the Property make required monthly deposits according to the Regulatory Agreement.
Show full finding ▾Hide full finding ▴2021?3 Reserve for Replacement Monthly Deposits Not Made Timely Condition: The Project did not make the required deposit into the bank account on a monthly basis. Criteria: According to the Regulatory Agreement, ?mortgagor will establish and maintain a reserve fund for replacements in a separate account in a bank?Concurrently with the effective commencement of rental assistance payments under the Project Rental Assistance Contract, the Mortgagor will deposit an amount?per month unless a different date or amount is approved in writing by HUD?. Cause: The cause is undeterminable. Effect: The Project is not in compliance with the Regulatory Agreement. Recommendation: I recommend the Property make required monthly deposits according to the Regulatory Agreement.
The required remittances were made on a monthly basis, however delivery delays into the bank account were outside of our control. To correct this going forward, we will explore utilizing a financial institution that will allow for external wire transfers into the reserve for replacement bank account to avoid postal or other delivery methods delay.
The Project did not prepare a HUD 9250 to remit excess residual receipts, nor did it mail a check or transmit a wire of those funds. Criteria: According to the Consolidated Appropriations Act, 2017, owners subject to a Section 202 or 811 Project Rental Assistance Contract (PRAC) are required to remit any excess balance in a Residual Receipts account, greater than $250 per unit, to HUD?s Accounting Center upon termination or renewal of the PRAC contract. Cause: The cause is undeterminable. Effect: Residual receipts balance is $17,433 as of December 31, 2021. The allowable balance is $5,250 ($250 X 21 units), resulting in excess residual receipts of $12,183. Recommendation: I recommend the Property prepare the HUD 9250 requesting to remit excess funds to HUD.
Show full finding ▾Hide full finding ▴2021-4 Excess Residual Receipts Condition: The Project did not prepare a HUD 9250 to remit excess residual receipts, nor did it mail a check or transmit a wire of those funds. Criteria: According to the Consolidated Appropriations Act, 2017, owners subject to a Section 202 or 811 Project Rental Assistance Contract (PRAC) are required to remit any excess balance in a Residual Receipts account, greater than $250 per unit, to HUD?s Accounting Center upon termination or renewal of the PRAC contract. Cause: The cause is undeterminable. Effect: Residual receipts balance is $17,433 as of December 31, 2021. The allowable balance is $5,250 ($250 X 21 units), resulting in excess residual receipts of $12,183. Recommendation: I recommend the Property prepare the HUD 9250 requesting to remit excess funds to HUD.
No formal response provided.
FAC accepted this audit on April 29, 2021 — management decision was due October 29, 2021.
Management failed to capitalize expenditures that yield benefits over an extended period of time. Criteria: Management is required to prepare financial statements in accordance with generally accepted accounting principles. Cause: Transactions were expensed in the accounting records. Effect: Misrepresentation of financial position of the Project. Recommendation: I recommend management properly capitalize property and equipment according to their capitalization policy.
Show full finding ▾Hide full finding ▴2020-1 Property and Equipment not Capitalized and Depreciation Not Recorded Condition: Management failed to capitalize expenditures that yield benefits over an extended period of time. Criteria: Management is required to prepare financial statements in accordance with generally accepted accounting principles. Cause: Transactions were expensed in the accounting records. Effect: Misrepresentation of financial position of the Project. Recommendation: I recommend management properly capitalize property and equipment according to their capitalization policy.
We have reviewed this issue with our recently hired accountant who will ensure that going forward eligible expenses are capitalized. This matter was an oversite and not an intentional measure of misrepresentation of the financial position of the property.
FAC accepted this audit on September 17, 2020 — management decision was due March 17, 2021.
Vacancies are not reconciled throughout the calendar year.Criteria: Vacancies should be reconciled at the end of each month.Cause: The cause is undeterminable.Effect: Vacancies had to be reconciled during the audit process.Recommendation: I recommend management reconcile vacancies on a monthly basis.
Show full finding ▾Hide full finding ▴2019?1 Vacancies Not Reconciled TimelyCondition: Vacancies are not reconciled throughout the calendar year.Criteria: Vacancies should be reconciled at the end of each month.Cause: The cause is undeterminable.Effect: Vacancies had to be reconciled during the audit process.Recommendation: I recommend management reconcile vacancies on a monthly basis.
Response: All vacancies in the General Ledger of ARMS agree to the reports of the tenant ledgers in ourLeasing and Rents software. This reconciliation of vacancies is performed on a regular basis.
Gross potential rent is not reconciled throughout the calendar year.Criteria: Gross potential rent should be reconciled at the end of each month.Cause: The cause is undeterminable.Effect: Gross potential rent had to be calculated and reconciled during the audit process.Recommendation: I recommend management calculate and reconcile on gross potential rent on a monthlybasis.
Show full finding ▾Hide full finding ▴2019?2 Gross Potential Rent Not Reconciled TimelyCondition: Gross potential rent is not reconciled throughout the calendar year.Criteria: Gross potential rent should be reconciled at the end of each month.Cause: The cause is undeterminable.Effect: Gross potential rent had to be calculated and reconciled during the audit process.Recommendation: I recommend management calculate and reconcile on gross potential rent on a monthlybasis.
Response: The gross rent potential is reconciled throughout the year. However, interim and annualcertifications of resident income, assets, and household composition may create adjustments to prior closedperiods of rent and subsidy payments which are reflected in the current fiscal year. We will continue to ensurereconciliation of Gross Rent Potential on a monthly basis.
Management failed to collect monthly lease payments resulting in tenants accruing largeamounts of past due rent.Criteria: Monthly tenant lease payments should be collected and payable according to the terms of theHUD model lease.Cause: Site managers did not carry out the terms of the HUD-model lease and collect rent due.Effect: Tenant accounts receivables included significant amounts of unpaid rent for former residents.Recommendation: I recommend management develop and implement a collection policy.
Show full finding ▾Hide full finding ▴2019?3 Collection of Tenant Accounts ReceivableCondition: Management failed to collect monthly lease payments resulting in tenants accruing largeamounts of past due rent.Criteria: Monthly tenant lease payments should be collected and payable according to the terms of theHUD model lease.Cause: Site managers did not carry out the terms of the HUD-model lease and collect rent due.Effect: Tenant accounts receivables included significant amounts of unpaid rent for former residents.Recommendation: I recommend management develop and implement a collection policy.
Response: In the report, the Effect states that there are significant amounts of unpaid rent of formerresidents. A review of former tenant balances as of 12/31/2019 reflect .46% of Net Rent Potential, or$838.00. Therefore, we disagree that there are significant amounts of unpaid rent of former residents.We will ensure monthly reconciliation of Former Tenant Accounts Receivable.
Management Agent Certifications provided during the audit and approved by the Departmentof Housing and Urban Development (HUD) had a term of 2/1/2018 ? 1/31/2019.Criteria: According to HUD Handbook 4381.5, The Management Handbook, Paragraph 2.6, the ownerand agent must complete HUD Form 9839-B Management Agent Certification.Cause: Management failed to obtain a current management agent certification approved by HUD.Effect: The accuracy of the management fee expense is undeterminable.Recommendation: I recommend the management company obtain current management agentcertifications approved by HUD, upon expiration.
Show full finding ▾Hide full finding ▴2019?4 Management Agent Certifications Not CurrentCondition: Management Agent Certifications provided during the audit and approved by the Departmentof Housing and Urban Development (HUD) had a term of 2/1/2018 ? 1/31/2019.Criteria: According to HUD Handbook 4381.5, The Management Handbook, Paragraph 2.6, the ownerand agent must complete HUD Form 9839-B Management Agent Certification.Cause: Management failed to obtain a current management agent certification approved by HUD.Effect: The accuracy of the management fee expense is undeterminable.Recommendation: I recommend the management company obtain current management agentcertifications approved by HUD, upon expiration.
Response: The Management Agent Certification (HUD Form 9839-b) does not have an expirationdate. An updated Management Agent Certification (HUD Form 9839-b) is required under thefollowing conditions: a) Authorizing the agent to collect a fee different from the percentages fees andany special fees specified in Paragraph 1 of the existing Certification: b) Changing the expiration dateof the Management Agreement. c) Renewing the Management Agreement. d) Permitting a new Agentto operate the project e) Permitting a new Agent to collect a fee. f) Undertaking self-management ofthe project. Therefore, we disagree with this finding as the Management Agent Certification providedthat is signed and approved by the Owner, HUD, and the Agent, is valid.
FAC accepted this audit on March 25, 2019 — management decision was due September 25, 2019.
GSA_MIGRATION
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Show full finding ▾Hide full finding ▴FAC accepted this audit on May 27, 2018 — management decision was due November 27, 2018.
GSA_MIGRATION
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Show full finding ▾Hide full finding ▴FAC accepted this audit on April 30, 2017 — management decision was due October 30, 2017.
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