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METRO TOWERS, INCNon-Profit

EIN: 431425399

UEI: N1J4FLDAGJQ1

Audited by: WELCH & ASSOCIATES, LLC

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

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Data as of August 28, 2026

METRO TOWERS, INC10 audit years24 findings8 repeat
10
Audit Years
24
Total Findings
8
Repeat Findings
$3M
Federal Awards Expended (FY 2025)

FY 2025-12-31

$2,991,826 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on May 15, 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 15, 2026 (76 days from today).

What is a management decision? →
2025-001
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2024-001, 2023-001

S3800-010: Finding Reference Number 2025-001 (Material Weakness) S3800-011: Program Information Federal Program: Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Federal Agency: Department of Housing and Urban Development (HUD) Assistance Listing #: 14.155 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N – Special Tests and Provisions S3800-015: Type of Finding Financial Statement and Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size N/A S3800-018: Sample Size Information N/A S3800-019: Identification of Repeat Finding and Finding Reference Number 2024-001 and 2023-001 S3800-020: Criteria The regulatory agreement requires that the Organization’s books and records are maintained in accordance with HUD guidelines and generally accepted accounting principles. S3800-030: Statement of Condition Several misstatements were identified by the auditor in the unaudited financial statements and accounts of the Organization. S3800-032: Cause The Organization lacks adequate internal controls to ensure that books and records are kept accurately and completely. S3800-033: Effect or Potential Effect The Organization was not in compliance with the regulatory agreement requirement to maintain accurate and complete books and accounts. S3800-035: Auditor Non-Compliance Code S – Internal Control Deficiencies S3800-040: Questioned Costs None S3800-045: Reporting Views of Responsible Officials Management agrees with the finding. S3800-050: Context On the general ledger, various accounts such as rent, vacancies, and escrow accounts did not tie to supporting documentation. The Organization did not capitalize the fixed assets as per the capitalization policy. The unadjusted net assets did not roll forward correctly from the prior year. S3800-080: Recommendation The Auditor recommends the Organization follows their policies and procedures to ensure that accounting records are kept accurate and complete, and a responsible official should review and sign off on the monthly financial statements. S3800-090: Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date July 31, 2026 S3800-150: Response See Corrective Action Plan

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S3800-010: Finding Reference Number 2025-001 (Material Weakness) S3800-011: Program Information Federal Program: Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Federal Agency: Department of Housing and Urban Development (HUD) Assistance Listing #: 14.155 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N – Special Tests and Provisions S3800-015: Type of Finding Financial Statement and Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size N/A S3800-018: Sample Size Information N/A S3800-019: Identification of Repeat Finding and Finding Reference Number 2024-001 and 2023-001 S3800-020: Criteria The regulatory agreement requires that the Organization’s books and records are maintained in accordance with HUD guidelines and generally accepted accounting principles. S3800-030: Statement of Condition Several misstatements were identified by the auditor in the unaudited financial statements and accounts of the Organization. S3800-032: Cause The Organization lacks adequate internal controls to ensure that books and records are kept accurately and completely. S3800-033: Effect or Potential Effect The Organization was not in compliance with the regulatory agreement requirement to maintain accurate and complete books and accounts. S3800-035: Auditor Non-Compliance Code S – Internal Control Deficiencies S3800-040: Questioned Costs None S3800-045: Reporting Views of Responsible Officials Management agrees with the finding. S3800-050: Context On the general ledger, various accounts such as rent, vacancies, and escrow accounts did not tie to supporting documentation. The Organization did not capitalize the fixed assets as per the capitalization policy. The unadjusted net assets did not roll forward correctly from the prior year. S3800-080: Recommendation The Auditor recommends the Organization follows their policies and procedures to ensure that accounting records are kept accurate and complete, and a responsible official should review and sign off on the monthly financial statements. S3800-090: Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date July 31, 2026 S3800-150: Response See Corrective Action Plan

Corrective Action Plan

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2025 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended December 31, 2025. Finding 2025-001 Responsible Party Name: Fred Gibbs Position: President – Management Agent Telephone Number: 913-709-1811 Federal Agency U.S. Department of Housing and Urban Development Federal Program Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Compliance Requirements N – Special Tests and Provisions Finding Type Financial Statement and Federal Awards Auditee’s Comment on Finding We agree with the auditor’s finding. Corrective Action We will follow our policies and procedures to ensure that accounting records are kept accurate and complete, and a responsible official will review and sign off on the monthly financial statements. Anticipated Completion Date July 31, 2026

Prior Finding References

2024-001, 2023-001

About Special Tests and Provisions →
2025-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

S3800-010: Finding Reference Number 2025-002 (Significant Deficiency) S3800-011: Program Information Federal Program: Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Federal Agency: Department of Housing and Urban Development (HUD) Assistance Listing #: 14.155 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N – Special Tests and Provisions S3800-015: Type of Finding Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size 110 S3800-018: Sample Size Information 15 S3800-019: Identification of Repeat Finding and Finding Reference Number N/A S3800-020: Criteria The HUD Management Agent Handbook (4381.5) requires owners of multifamily housing to follow specific guidelines and determine requirements are being met for residents requesting maintenance of property in compliance with management’s procedures. S3800-030: Statement of Condition During our audit of the Organization’s fiscal year ended December 31, 2025 federal award program, we noted concerns regarding adherence to compliance requirements with management procedures for work orders and tenant complaints for timely follow-up. Five of the fifteen samples were not completed in a timely manner. S3800-032: Cause The Organization did not follow HUD required procedures for housing quality standards. S3800-033: Effect or Potential Effect The Organization was not in compliance with ensuring HUD requirements are being met forresidents requesting maintenance of property via management’s procedures. S3800-035: Auditor Non-Compliance Code: I – Failure to maintain property / open physical inspection(s) S3800-040: Questioned Costs None S3800-045: Reporting Views of Responsible Officials Management agrees with the finding. S3800-050: Context The Organization is required to be in compliance with provisions in HUD Handbook 4381.5 related to work orders and tenant complaints for timely follow-up. S3800-080: Recommendation The Organization should ensure tenants requesting maintenance of property via work orders are being maintained properly and in a timely manner and review the accuracy / completeness of the documentation being processed in the work order system on a quarterly basis. S3800-090: Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date July 31, 2026 S3800-150: Response See Corrective Action Plan

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S3800-010: Finding Reference Number 2025-002 (Significant Deficiency) S3800-011: Program Information Federal Program: Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Federal Agency: Department of Housing and Urban Development (HUD) Assistance Listing #: 14.155 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N – Special Tests and Provisions S3800-015: Type of Finding Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size 110 S3800-018: Sample Size Information 15 S3800-019: Identification of Repeat Finding and Finding Reference Number N/A S3800-020: Criteria The HUD Management Agent Handbook (4381.5) requires owners of multifamily housing to follow specific guidelines and determine requirements are being met for residents requesting maintenance of property in compliance with management’s procedures. S3800-030: Statement of Condition During our audit of the Organization’s fiscal year ended December 31, 2025 federal award program, we noted concerns regarding adherence to compliance requirements with management procedures for work orders and tenant complaints for timely follow-up. Five of the fifteen samples were not completed in a timely manner. S3800-032: Cause The Organization did not follow HUD required procedures for housing quality standards. S3800-033: Effect or Potential Effect The Organization was not in compliance with ensuring HUD requirements are being met forresidents requesting maintenance of property via management’s procedures. S3800-035: Auditor Non-Compliance Code: I – Failure to maintain property / open physical inspection(s) S3800-040: Questioned Costs None S3800-045: Reporting Views of Responsible Officials Management agrees with the finding. S3800-050: Context The Organization is required to be in compliance with provisions in HUD Handbook 4381.5 related to work orders and tenant complaints for timely follow-up. S3800-080: Recommendation The Organization should ensure tenants requesting maintenance of property via work orders are being maintained properly and in a timely manner and review the accuracy / completeness of the documentation being processed in the work order system on a quarterly basis. S3800-090: Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date July 31, 2026 S3800-150: Response See Corrective Action Plan

Corrective Action Plan

Finding 2025-002 Federal Agency U.S. Department of Housing and Urban Development Federal Program Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Compliance Requirements N – Special Tests and Provisions Finding Type Federal Awards Auditee’s Comment on Finding We agree with the auditor’s finding. Corrective Action We ensure tenants requesting maintenance of property via work orders are being maintained properly and in a timely manner and review the accuracy / completeness of the documentation being processed in the work order system on a quarterly basis. This finding was due to the review if inspection work orders generated by staff, not tenant requests. Anticipated Completion Date July 31, 2026

About Special Tests and Provisions →
2025-003
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINION

S3800-010: Finding Reference Number 2025-003 (Material Weakness) S3800-011: Program Information Federal Program: Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Federal Agency: Department of Housing and Urban Development (HUD) Assistance Listing #: 14.155 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N – Special Tests and Provisions S3800-015: Type of Finding Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size N/A S3800-018: Sample Size Information N/A S3800-019: Identification of Repeat Finding and Finding Reference Number N/A S3800-020: Criteria The HUD Handbook 4381.5, REV-2, CHG-2, The Management Agent Handbook requires owners of multifamily housing with supportive services for very low-income elderly persons to maintain the mortgaged premises in decent, safe, sanitary conditions. S3800-030: Statement of Condition During our audit of the Organization’s fiscal year ended December 31, 2025 federal award program, we noted that the Organization did not have a current elevator operating certificate issued by the City of Kansas City, Missouri after March 1, 2026. S3800-032: Cause An elevator inspection was performed on December 30, 2025 which identified various safety concerns and failed items, in which the Organization has to repair. Therefore, the Organization is unable to obtain a current elevator certification until these services are restored. During this period the elevator was still in use. S3800-033: Effect or Potential Effect Safety of all persons on premises and elevators may not be safe to use. S3800-035: Auditor Non-Compliance Code: I – Failure to maintain property / open physical inspection(s) S3800-040: Questioned Costs None S3800-045: Reporting Views of Responsible Officials Management agrees with the finding. S3800-050: Context The Organization is required to have all of its necessary forms, licenses, and certifications current and up to date. S3800-080: Recommendation In general, the Organization should establish a process to ensure that they keep all necessary forms, licenses, and certifications current and up to date. S3800-090: Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date July 31, 2026 S3800-150: Response See Corrective Action Plan

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S3800-010: Finding Reference Number 2025-003 (Material Weakness) S3800-011: Program Information Federal Program: Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Federal Agency: Department of Housing and Urban Development (HUD) Assistance Listing #: 14.155 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N – Special Tests and Provisions S3800-015: Type of Finding Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size N/A S3800-018: Sample Size Information N/A S3800-019: Identification of Repeat Finding and Finding Reference Number N/A S3800-020: Criteria The HUD Handbook 4381.5, REV-2, CHG-2, The Management Agent Handbook requires owners of multifamily housing with supportive services for very low-income elderly persons to maintain the mortgaged premises in decent, safe, sanitary conditions. S3800-030: Statement of Condition During our audit of the Organization’s fiscal year ended December 31, 2025 federal award program, we noted that the Organization did not have a current elevator operating certificate issued by the City of Kansas City, Missouri after March 1, 2026. S3800-032: Cause An elevator inspection was performed on December 30, 2025 which identified various safety concerns and failed items, in which the Organization has to repair. Therefore, the Organization is unable to obtain a current elevator certification until these services are restored. During this period the elevator was still in use. S3800-033: Effect or Potential Effect Safety of all persons on premises and elevators may not be safe to use. S3800-035: Auditor Non-Compliance Code: I – Failure to maintain property / open physical inspection(s) S3800-040: Questioned Costs None S3800-045: Reporting Views of Responsible Officials Management agrees with the finding. S3800-050: Context The Organization is required to have all of its necessary forms, licenses, and certifications current and up to date. S3800-080: Recommendation In general, the Organization should establish a process to ensure that they keep all necessary forms, licenses, and certifications current and up to date. S3800-090: Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date July 31, 2026 S3800-150: Response See Corrective Action Plan

Corrective Action Plan

Finding 2025-003 Federal Agency U.S. Department of Housing and Urban Development Federal Program Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Compliance Requirements N – Special Tests and Provisions Finding Type Federal Awards Auditee’s Comment on Finding We agree with the auditor’s finding. Corrective Action We have a process to ensure that we keep all necessary forms, licenses, and certifications current and they are up to date. The current condition is due to an open elevator modernization project by EMI Elevator. Once completed, they will schedule the final inspection and the certificate will be obtained. Anticipated Completion Date July 31, 2026

About Special Tests and Provisions →

FY 2024-12-31

$3,026,483 federal awards expended

FAC accepted this audit on June 9, 2025 — management decision was due December 9, 2025.

2024-001
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2023-001

S3800-010: Finding Reference Number 2024-001 (Material Weakness) S3800-011: Program Information Federal Program: Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Federal Agency: Department of Housing and Urban Development (HUD) Assistance Listing #: 14.155 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N – Special Tests and Provisions S3800-015: Type of Finding Financial Statement and Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size N/A S3800-018: Sample Size Information N/A S3800-019: Identification of Repeat Finding and Finding Reference Number 2023-001 S3800-020: Criteria The regulatory agreement requires that the Organization’s books and records are maintained in accordance with HUD guidelines and generally accepted accounting principles. S3800-030: Statement of Condition Several misstatements were identified by the auditor in the unaudited financial statements and accounts of the Organization. S3800-032: Cause The Organization lacks adequate internal controls to ensure that books and records are kept accurately and completely. S3800-033: Effect or Potential Effect The Organization was not in compliance with the regulatory agreement requirement to maintain accurate and complete books and accounts. S3800-035: Auditor Non-Compliance Code S – Internal Control Deficiencies S3800-040: Questioned Costs None S3800-045: Reporting Views of Responsible Officials Management agrees with the finding. S3800-050: Context On the general ledger, various accounts such as rent, vacancies, and escrow accounts did not tie to supporting documentation. The Organization did not capitalize the fixed assets as per the capitalization policy. The cash balance in general ledger did not tie the bank reconciliation statement. S3800-080: Recommendation The Auditor recommends the Organization follows their policies and procedures to ensure that accounting records are kept accurate and complete, and a responsible official should review and sign off on the monthly financial statements. S3800-090: Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date June 30, 2025 S3800-150: Response See Corrective Action Plan

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S3800-010: Finding Reference Number 2024-001 (Material Weakness) S3800-011: Program Information Federal Program: Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Federal Agency: Department of Housing and Urban Development (HUD) Assistance Listing #: 14.155 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N – Special Tests and Provisions S3800-015: Type of Finding Financial Statement and Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size N/A S3800-018: Sample Size Information N/A S3800-019: Identification of Repeat Finding and Finding Reference Number 2023-001 S3800-020: Criteria The regulatory agreement requires that the Organization’s books and records are maintained in accordance with HUD guidelines and generally accepted accounting principles. S3800-030: Statement of Condition Several misstatements were identified by the auditor in the unaudited financial statements and accounts of the Organization. S3800-032: Cause The Organization lacks adequate internal controls to ensure that books and records are kept accurately and completely. S3800-033: Effect or Potential Effect The Organization was not in compliance with the regulatory agreement requirement to maintain accurate and complete books and accounts. S3800-035: Auditor Non-Compliance Code S – Internal Control Deficiencies S3800-040: Questioned Costs None S3800-045: Reporting Views of Responsible Officials Management agrees with the finding. S3800-050: Context On the general ledger, various accounts such as rent, vacancies, and escrow accounts did not tie to supporting documentation. The Organization did not capitalize the fixed assets as per the capitalization policy. The cash balance in general ledger did not tie the bank reconciliation statement. S3800-080: Recommendation The Auditor recommends the Organization follows their policies and procedures to ensure that accounting records are kept accurate and complete, and a responsible official should review and sign off on the monthly financial statements. S3800-090: Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date June 30, 2025 S3800-150: Response See Corrective Action Plan

Corrective Action Plan

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2024 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended December 31, 2024. Finding 2024-001 Responsible Party Name: Fred Gibbs Position: President – Management Agent Telephone Number: 913-709-1811 Federal Agency U.S. Department of Housing and Urban Development Federal Program Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Compliance Requirements N – Special Tests and Provisions Finding Type Financial Statement and Federal Awards Auditee’s Comment on Finding We agree with the auditor’s finding. Corrective Action We will follow our policies and procedures to ensure that accounting records are kept accurate and complete, and a responsible official will review and sign off on the monthly financial statements. Anticipated Completion Date June 30, 2025

Prior Finding References

2023-001

About Special Tests and Provisions →

FY 2023-12-31

$3,070,032 federal awards expended

FAC accepted this audit on May 23, 2024 — management decision was due November 23, 2024.

2023-001
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINION

S3800-010: Finding Reference Number 2023-001 (Material Weakness) S3800-011: Program Information Federal Program: Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Federal Agency: Department of Housing and Urban Development (HUD) Assistance Listing #: 14.155 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N – Special Tests and Provisions S3800-015: Type of Finding Financial Statement and Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size N/A S3800-018: Sample Size Information N/A S3800-019: Identification of Repeat Finding and Finding Reference Number N/A S3800-020: Criteria The regulatory agreement requires that the Organization’s books and records are maintained in accordance with HUD guidelines and generally accepted accounting principles. S3800-030: Statement of Condition Several misstatements were identified by the auditor in the unaudited financial statements and accounts of the Organization. S3800-032: Cause The Organization lacks adequate internal controls to ensure that books and records are kept accurately and completely. S3800-033: Effect or Potential Effect The Organization was not in compliance with the regulatory agreement requirement to maintain accurate and complete books and accounts. S3800-035: Auditor Non-Compliance Code S – Internal Control Deficiencies S3800-040: Questioned Costs None S3800-045: Reporting Views of Responsible Officials Management agrees with the finding. S3800-050: Context On the general ledger, various accounts such as rent, vacancies, and escrow accounts did not tie to supporting documentation. The Organization did not capitalize the fixed assets as per the capitalization policy. The cash balance in general ledger did not tie the bank reconciliation statement. S3800-080: Recommendation The Auditor recommends the Organization follows their policies and procedures to ensure that accounting records are kept accurate and complete, and a responsible official should review and sign off on the monthly financial statements. S3800-090: Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date June 30, 2024 S3800-150: Response See Corrective Action Plan

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S3800-010: Finding Reference Number 2023-001 (Material Weakness) S3800-011: Program Information Federal Program: Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Federal Agency: Department of Housing and Urban Development (HUD) Assistance Listing #: 14.155 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N – Special Tests and Provisions S3800-015: Type of Finding Financial Statement and Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size N/A S3800-018: Sample Size Information N/A S3800-019: Identification of Repeat Finding and Finding Reference Number N/A S3800-020: Criteria The regulatory agreement requires that the Organization’s books and records are maintained in accordance with HUD guidelines and generally accepted accounting principles. S3800-030: Statement of Condition Several misstatements were identified by the auditor in the unaudited financial statements and accounts of the Organization. S3800-032: Cause The Organization lacks adequate internal controls to ensure that books and records are kept accurately and completely. S3800-033: Effect or Potential Effect The Organization was not in compliance with the regulatory agreement requirement to maintain accurate and complete books and accounts. S3800-035: Auditor Non-Compliance Code S – Internal Control Deficiencies S3800-040: Questioned Costs None S3800-045: Reporting Views of Responsible Officials Management agrees with the finding. S3800-050: Context On the general ledger, various accounts such as rent, vacancies, and escrow accounts did not tie to supporting documentation. The Organization did not capitalize the fixed assets as per the capitalization policy. The cash balance in general ledger did not tie the bank reconciliation statement. S3800-080: Recommendation The Auditor recommends the Organization follows their policies and procedures to ensure that accounting records are kept accurate and complete, and a responsible official should review and sign off on the monthly financial statements. S3800-090: Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date June 30, 2024 S3800-150: Response See Corrective Action Plan

Corrective Action Plan

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended December 31, 2023. Finding 2023-001 Responsible Party Name: Fred Gibbs Position: President – Management Agent Telephone Number: 913-709-1811 Federal Agency U.S. Department of Housing and Urban Development Federal Program Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Compliance Requirements N – Special Tests and Provisions Finding Type Financial Statement and Federal Awards Auditee’s Comment on Finding We agree with the auditor’s finding. Corrective Action We will follow our policies and procedures to ensure that accounting records are kept accurate and complete, and a responsible official will review and sign off on the monthly financial statements. Anticipated Completion Date June 30, 2024

About Special Tests and Provisions →
2023-002
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

S3800-010: Finding Reference Number 2023-002 (Material Weakness) S3800-011: Program Information Federal Program: Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Federal Agency: Department of Housing and Urban Development (HUD) Assistance Listing #: 14.155 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N – Special Tests and Provisions S3800-015: Type of Finding Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size N/A S3800-018: Sample Size Information N/A S3800-019: Identification of Repeat Finding and Finding Reference Number 2022-002 S3800-020: Criteria HUD Form-9250, Funds Authorizations, requires the Organization to deposit $1,842 into the replacement reserve account on a monthly basis. S3800-030: Statement of Condition During our audit of the Organization’s fiscal year ended December 31, 2023 federal award program, we noted the Organization failed to make the required monthly deposits into the reserve for replacement account for all twelve months. The Organization deposited monthly $1,796 as opposed to the approved $1,842. S3800-032: Cause The Organization deposited the prior required monthly amount into the reserve for replacement account. S3800-033: Effect or Potential Effect The Organization was not in compliance with the regulatory agreement to make required monthly deposits into the reserve for replacement account. S3800-035: Auditor Non-Compliance Code: N – Reserve for replacements deposits S3800-040: Questioned Costs $544 S3800-045: Reporting Views of Responsible Officials Management agrees with the finding. S3800-050: Context The Organization deposited $21,560 onto the reserve for replacement account during the year ended December 31, 2023. The Organization was required to deposit $22,104 for the year. Per Missouri Housing Development Commission (HUD’s designee), the Organization was required to increase the monthly deposit to the reserve for replacement account from $1,796 to $1,842 effective June 1, 2019. The $544 questioned costs only accounts for the current fiscal year underfunding. S3800-080: Recommendation The Organization should deposit the shortfall of $544 into the reserve for replacement account, as well as the shortfall for 2019, 2020, 2021 and 2022, as soon as possible and ensure the process is being followed to deposit and reconcile the reserve for replacement account on a monthly basis. S3800-090: Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date June 30, 2024 S3800-150: Response See Corrective Action Plan

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S3800-010: Finding Reference Number 2023-002 (Material Weakness) S3800-011: Program Information Federal Program: Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Federal Agency: Department of Housing and Urban Development (HUD) Assistance Listing #: 14.155 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N – Special Tests and Provisions S3800-015: Type of Finding Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size N/A S3800-018: Sample Size Information N/A S3800-019: Identification of Repeat Finding and Finding Reference Number 2022-002 S3800-020: Criteria HUD Form-9250, Funds Authorizations, requires the Organization to deposit $1,842 into the replacement reserve account on a monthly basis. S3800-030: Statement of Condition During our audit of the Organization’s fiscal year ended December 31, 2023 federal award program, we noted the Organization failed to make the required monthly deposits into the reserve for replacement account for all twelve months. The Organization deposited monthly $1,796 as opposed to the approved $1,842. S3800-032: Cause The Organization deposited the prior required monthly amount into the reserve for replacement account. S3800-033: Effect or Potential Effect The Organization was not in compliance with the regulatory agreement to make required monthly deposits into the reserve for replacement account. S3800-035: Auditor Non-Compliance Code: N – Reserve for replacements deposits S3800-040: Questioned Costs $544 S3800-045: Reporting Views of Responsible Officials Management agrees with the finding. S3800-050: Context The Organization deposited $21,560 onto the reserve for replacement account during the year ended December 31, 2023. The Organization was required to deposit $22,104 for the year. Per Missouri Housing Development Commission (HUD’s designee), the Organization was required to increase the monthly deposit to the reserve for replacement account from $1,796 to $1,842 effective June 1, 2019. The $544 questioned costs only accounts for the current fiscal year underfunding. S3800-080: Recommendation The Organization should deposit the shortfall of $544 into the reserve for replacement account, as well as the shortfall for 2019, 2020, 2021 and 2022, as soon as possible and ensure the process is being followed to deposit and reconcile the reserve for replacement account on a monthly basis. S3800-090: Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date June 30, 2024 S3800-150: Response See Corrective Action Plan

Corrective Action Plan

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended December 31, 2023. Finding 2023-002 Responsible Party Name: Fred Gibbs Position: President – Management Agent Telephone Number: 913-709-1811 Federal Agency U.S. Department of Housing and Urban Development Federal Program Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Compliance Requirements N – Special Tests and Provisions Finding Type Federal Awards Auditee’s Comment on Finding We agree with the auditor’s finding. Corrective Action We will deposit the shortfall of $544 into the reserve for replacement account, as well as the shortfalls for 2019, 2020, 2021 and 2022, as soon as possible and ensure the process is being followed to deposit and reconcile the reserve for replacement account on a monthly basis. Anticipated Completion Date June 30, 2024

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2023-003
Special Tests & Provisions
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

S3800-010: Finding Reference Number 2023-003 (Significant Deficiency) S3800-011: Program Information Federal Program: Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Federal Agency: Department of Housing and Urban Development (HUD) Assistance Listing #: 14.155 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N – Special Tests and Provisions S3800-015: Type of Finding Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size N/A S3800-018: Sample Size Information N/A S3800-019: Identification of Repeat Finding and Finding Reference Number N/A S3800-020: Criteria Owners of insured and assisted multifamily housing projects are required by HUD administrative guidelines to have a HUD approved Project Owner’s/Management Agent’s Certification for housing projects managed by Administrators for extremely or very low-income persons (Form 9839-B). S3800-030: Statement of Condition During our audit of the Organization’s fiscal year ended December 31, 2023 federal award program, we noted the Organization did not have a HUD approved Form 9839-B from March 1, 2023 through December 31, 2023. S3800-032: Cause The Organization did not submit a request for approval. S3800-033: Effect or Potential Effect Management has not been approved to manage the Project for this period. S3800-035: Auditor Non-Compliance Code: J – Unauthorized management fees S3800-040: Questioned Costs $20,106 S3800-045: Reporting Views of Responsible Officials Management agrees with the finding. S3800-050: Context The Organization is required to have all of its necessary forms and licenses current and up to date. S3800-080: Recommendation The Organization should file HUD Form 9839-B immediately. Additionally, the Organization should ask HUD to retrospectively approve Form 9839-B effective March 1, 2023. S3800-090: Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date June 30, 2024 S3800-150: Response See Corrective Action Plan

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S3800-010: Finding Reference Number 2023-003 (Significant Deficiency) S3800-011: Program Information Federal Program: Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Federal Agency: Department of Housing and Urban Development (HUD) Assistance Listing #: 14.155 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N – Special Tests and Provisions S3800-015: Type of Finding Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size N/A S3800-018: Sample Size Information N/A S3800-019: Identification of Repeat Finding and Finding Reference Number N/A S3800-020: Criteria Owners of insured and assisted multifamily housing projects are required by HUD administrative guidelines to have a HUD approved Project Owner’s/Management Agent’s Certification for housing projects managed by Administrators for extremely or very low-income persons (Form 9839-B). S3800-030: Statement of Condition During our audit of the Organization’s fiscal year ended December 31, 2023 federal award program, we noted the Organization did not have a HUD approved Form 9839-B from March 1, 2023 through December 31, 2023. S3800-032: Cause The Organization did not submit a request for approval. S3800-033: Effect or Potential Effect Management has not been approved to manage the Project for this period. S3800-035: Auditor Non-Compliance Code: J – Unauthorized management fees S3800-040: Questioned Costs $20,106 S3800-045: Reporting Views of Responsible Officials Management agrees with the finding. S3800-050: Context The Organization is required to have all of its necessary forms and licenses current and up to date. S3800-080: Recommendation The Organization should file HUD Form 9839-B immediately. Additionally, the Organization should ask HUD to retrospectively approve Form 9839-B effective March 1, 2023. S3800-090: Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date June 30, 2024 S3800-150: Response See Corrective Action Plan

Corrective Action Plan

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended December 31, 2023. Finding 2023-003 Responsible Party Name: Fred Gibbs Position: President – Management Agent Telephone Number: 913-709-1811 Federal Agency U.S. Department of Housing and Urban Development Federal Program Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Compliance Requirements N – Special Tests and Provisions Finding Type Federal Awards Auditee’s Comment on Finding We agree with the auditor’s finding. Corrective Action We will file HUD Form 9839-B with HUD and ask them to retrospectively approve this form effective February 28, 2023. Anticipated Completion Date June 30, 2024

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2023-004
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINION

S3800-010: Finding Reference Number 2023-004 (Material Weakness) S3800-011: Program Information Federal Program: Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Federal Agency: Department of Housing and Urban Development (HUD) Assistance Listing #: 14.155 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N – Special Tests and Provisions S3800-015: Type of Finding Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size N/A S3800-018: Sample Size Information N/A S3800-019: Identification of Repeat Finding and Finding Reference Number N/A S3800-020: Criteria Per the Consolidated Audit Guide for Audits of HUD Programs (Handbook 2000.4 REV-2; the HUD audit guide), the amount of tenant security deposits shall at all times equal or exceed the aggregate of all outstanding obligations under the security deposit account. S3800-030: Statement of Condition During our audit of the Organization’s fiscal year ended December 31, 2023 federal award program, we noted the Organization failed to maintain an amount equal to or greater of the tenant security deposit account compared to all obligations under that account. S3800-032: Cause The Organization failed to review and ensure the amount on deposit was at least equal to the outstanding obligations under the security deposit account throughout the reporting period. S3800-033: Effect or Potential Effect The Organization was not in compliance with requirements in the HUD audit guide related to tenant security deposits. S3800-035: Auditor Non-Compliance Code: M – Security deposits S3800-040: Questioned Costs None S3800-045: Reporting Views of Responsible Officials Management agrees with the finding. S3800-050: Context The Organization did not reconcile the security deposit account throughout the reporting period to ensure the amount on deposit was at least equal to the outstanding obligations under the security deposit account. At all times, the liability account was greater than the asset account. S3800-080: Recommendation The Organization should implement policies and procedures to ensure that accounting records are kept accurate and complete as per the requirement of the HUD audit guide related to tenant security deposits and a responsible official should ensure the process is being followed on a monthly basis. S3800-090: Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date June 30, 2024 S3800-150: Response See Corrective Action Plan

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S3800-010: Finding Reference Number 2023-004 (Material Weakness) S3800-011: Program Information Federal Program: Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Federal Agency: Department of Housing and Urban Development (HUD) Assistance Listing #: 14.155 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N – Special Tests and Provisions S3800-015: Type of Finding Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size N/A S3800-018: Sample Size Information N/A S3800-019: Identification of Repeat Finding and Finding Reference Number N/A S3800-020: Criteria Per the Consolidated Audit Guide for Audits of HUD Programs (Handbook 2000.4 REV-2; the HUD audit guide), the amount of tenant security deposits shall at all times equal or exceed the aggregate of all outstanding obligations under the security deposit account. S3800-030: Statement of Condition During our audit of the Organization’s fiscal year ended December 31, 2023 federal award program, we noted the Organization failed to maintain an amount equal to or greater of the tenant security deposit account compared to all obligations under that account. S3800-032: Cause The Organization failed to review and ensure the amount on deposit was at least equal to the outstanding obligations under the security deposit account throughout the reporting period. S3800-033: Effect or Potential Effect The Organization was not in compliance with requirements in the HUD audit guide related to tenant security deposits. S3800-035: Auditor Non-Compliance Code: M – Security deposits S3800-040: Questioned Costs None S3800-045: Reporting Views of Responsible Officials Management agrees with the finding. S3800-050: Context The Organization did not reconcile the security deposit account throughout the reporting period to ensure the amount on deposit was at least equal to the outstanding obligations under the security deposit account. At all times, the liability account was greater than the asset account. S3800-080: Recommendation The Organization should implement policies and procedures to ensure that accounting records are kept accurate and complete as per the requirement of the HUD audit guide related to tenant security deposits and a responsible official should ensure the process is being followed on a monthly basis. S3800-090: Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date June 30, 2024 S3800-150: Response See Corrective Action Plan

Corrective Action Plan

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended December 31, 2023. Finding 2023-004 Responsible Party Name: Fred Gibbs Position: President – Management Agent Telephone Number: 913-709-1811 Federal Agency U.S. Department of Housing and Urban Development Federal Program Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Compliance Requirements N – Special Tests and Provisions Finding Type Federal Awards Auditee’s Comment on Finding We agree with the auditor’s finding. Corrective Action We will follow our policies and procedures to ensure that accounting records are kept accurate and complete as per the requirement of the HUD audit guide related to tenant security deposits and a responsible official will ensure the process is being followed on a monthly basis. Anticipated Completion Date June 30, 2024

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FY 2022-12-31

$3,132,807 federal awards expended

FAC accepted this audit on June 25, 2023 — management decision was due December 25, 2023.

2022-001
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINION

S3800-010: Finding Reference Number 2022-001 (Material Weakness) S3800-011: Program Information Federal Program: Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Federal Agency: Department of Housing and Urban Development (HUD) Assistance Listing #: 14.155 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N ? Special Tests and Provisions S3800-015: Type of Finding Financial Statement and Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size N/A S3800-018: Sample Size Information N/A S3800-019: Identification of Repeat Finding and Finding Reference Number N/A S3800-020: Criteria The regulatory agreement requires that the Organization?s books and records are maintained in accordance with HUD guidelines and generally accepted accounting principles. S3800-030: Statement of Condition Several misstatements were identified by the auditor in the unaudited financial statements and accounts of the Organization. S3800-032: Cause The Organization lacks adequate internal controls to ensure that books and records are kept accurately and completely. S3800-033: Effect or Potential Effect The Organization was not in compliance with the regulatory agreement requirement to maintain accurate and complete books and accounts. S3800-035: Auditor Non-Compliance Code S ? Internal Control Deficiencies S3800-040: Questioned Costs None S3800-045: Reporting Views of Responsible Officials Management agrees with the finding. S3800-050: Context On the general ledger, various accounts such as rent, vacancies, and escrow accounts did not tie to supporting documentation. The Organization did not record the prior year audit adjusting entries as well due to which the unadjusted net assets did not roll forward correctly from prior year. S3800-080: Recommendation The Auditor recommends the Organization follows their policies and procedures to ensure that accounting records are kept accurate and complete, and a responsible official should review and sign off on the monthly financial statements. S3800-090: Auditor?s Summary of the Auditee?s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date June 30, 2023 S3800-150: Response See Corrective Action Plan

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S3800-010: Finding Reference Number 2022-001 (Material Weakness) S3800-011: Program Information Federal Program: Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Federal Agency: Department of Housing and Urban Development (HUD) Assistance Listing #: 14.155 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N ? Special Tests and Provisions S3800-015: Type of Finding Financial Statement and Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size N/A S3800-018: Sample Size Information N/A S3800-019: Identification of Repeat Finding and Finding Reference Number N/A S3800-020: Criteria The regulatory agreement requires that the Organization?s books and records are maintained in accordance with HUD guidelines and generally accepted accounting principles. S3800-030: Statement of Condition Several misstatements were identified by the auditor in the unaudited financial statements and accounts of the Organization. S3800-032: Cause The Organization lacks adequate internal controls to ensure that books and records are kept accurately and completely. S3800-033: Effect or Potential Effect The Organization was not in compliance with the regulatory agreement requirement to maintain accurate and complete books and accounts. S3800-035: Auditor Non-Compliance Code S ? Internal Control Deficiencies S3800-040: Questioned Costs None S3800-045: Reporting Views of Responsible Officials Management agrees with the finding. S3800-050: Context On the general ledger, various accounts such as rent, vacancies, and escrow accounts did not tie to supporting documentation. The Organization did not record the prior year audit adjusting entries as well due to which the unadjusted net assets did not roll forward correctly from prior year. S3800-080: Recommendation The Auditor recommends the Organization follows their policies and procedures to ensure that accounting records are kept accurate and complete, and a responsible official should review and sign off on the monthly financial statements. S3800-090: Auditor?s Summary of the Auditee?s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date June 30, 2023 S3800-150: Response See Corrective Action Plan

Corrective Action Plan

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2022 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 ? Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor?s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended December 31, 2022. Finding 2022-001 Responsible Party Name: Fred Gibbs Position: President ? Management Agent Telephone Number: 913-709-1811 Federal Agency U.S. Department of Housing and Urban Development Federal Program Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Compliance Requirements N ? Special Tests and Provisions Finding Type Financial Statement and Federal Awards Auditee?s Comment on Finding We agree with the auditor?s finding. Corrective Action We will follow our policies and procedures to ensure that our accounting records are kept accurate and complete, and a responsible official will review and sign off on the monthly financial statements. Anticipated Completion Date June 30, 2023

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2022-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

S3800-010: Finding Reference Number 2022-002 (Significant Deficiency) S3800-011: Program Information Federal Program: Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Federal Agency: Department of Housing and Urban Development (HUD) Assistance Listing #: 14.155 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N ? Special Tests and Provisions S3800-015: Type of Finding Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size N/A S3800-018: Sample Size Information N/A S3800-019: Identification of Repeat Finding and Finding Reference Number N/A S3800-020: Criteria HUD Form-9250, Funds Authorizations, requires the Organization to deposit $1,842 into the replacement reserve account on a monthly basis. S3800-030: Statement of Condition During our audit of the Organization?s fiscal year ended December 31, 2022 federal award program, we noted the Organization failed to make the required monthly deposits into the reserve for replacement account for all twelve months. The Organization deposited monthly $1,796 as opposed to the approved $1,842. S3800-032: Cause The Organization deposited the prior required monthly amount into the reserve for replacement account. S3800-033: Effect or Potential Effect The Organization was not in compliance with the regulatory agreement to make required monthly deposits into the reserve for replacement account. S3800-035: Auditor Non-Compliance Code: N ? Reserve for replacements deposits S3800-040: Questioned Costs $868 S3800-045: Reporting Views of Responsible Officials Management agrees with the finding. S3800-050: Context The Organization deposited $21,236 onto the reserve for replacement account during the year ended December 31, 2022. The Organization was required to deposit $22,104 for the year. Per Missouri Housing Development Commission (HUD?s designee), the Organization was required to increase the monthly deposit to the reserve for replacement account from $1,796 to $1,842 effective June 1, 2019. The $868 questioned costs only accounts for the current fiscal year underfunding. S3800-080: Recommendation The Organization should deposit the shortfall of $868 into the reserve for replacement account, as well as the shortfall for 2019, 2020, and 2021, as soon as possible and ensure the process is being followed to deposit and reconcile the reserve for replacement account on a monthly basis. S3800-090: Auditor?s Summary of the Auditee?s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date June 30, 2023 S3800-150: Response See Corrective Action Plan

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S3800-010: Finding Reference Number 2022-002 (Significant Deficiency) S3800-011: Program Information Federal Program: Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Federal Agency: Department of Housing and Urban Development (HUD) Assistance Listing #: 14.155 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N ? Special Tests and Provisions S3800-015: Type of Finding Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size N/A S3800-018: Sample Size Information N/A S3800-019: Identification of Repeat Finding and Finding Reference Number N/A S3800-020: Criteria HUD Form-9250, Funds Authorizations, requires the Organization to deposit $1,842 into the replacement reserve account on a monthly basis. S3800-030: Statement of Condition During our audit of the Organization?s fiscal year ended December 31, 2022 federal award program, we noted the Organization failed to make the required monthly deposits into the reserve for replacement account for all twelve months. The Organization deposited monthly $1,796 as opposed to the approved $1,842. S3800-032: Cause The Organization deposited the prior required monthly amount into the reserve for replacement account. S3800-033: Effect or Potential Effect The Organization was not in compliance with the regulatory agreement to make required monthly deposits into the reserve for replacement account. S3800-035: Auditor Non-Compliance Code: N ? Reserve for replacements deposits S3800-040: Questioned Costs $868 S3800-045: Reporting Views of Responsible Officials Management agrees with the finding. S3800-050: Context The Organization deposited $21,236 onto the reserve for replacement account during the year ended December 31, 2022. The Organization was required to deposit $22,104 for the year. Per Missouri Housing Development Commission (HUD?s designee), the Organization was required to increase the monthly deposit to the reserve for replacement account from $1,796 to $1,842 effective June 1, 2019. The $868 questioned costs only accounts for the current fiscal year underfunding. S3800-080: Recommendation The Organization should deposit the shortfall of $868 into the reserve for replacement account, as well as the shortfall for 2019, 2020, and 2021, as soon as possible and ensure the process is being followed to deposit and reconcile the reserve for replacement account on a monthly basis. S3800-090: Auditor?s Summary of the Auditee?s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date June 30, 2023 S3800-150: Response See Corrective Action Plan

Corrective Action Plan

Finding 2022-002 Responsible Party Name: Fred Gibbs Position: President ? Management Agent Telephone Number: 913-709-1811 Federal Agency U.S. Department of Housing and Urban Development Federal Program Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Compliance Requirements N ? Special Tests and Provisions Finding Type Federal Awards Auditee?s Comment on Finding We agree with the auditor?s finding. Corrective Action We will deposit the shortfall of $868 into the reserve for replacement account, as soon as possible. We will also deposit the shortfall for 2019, 2020, and 2021 once funds become available. We will follow our process to deposit and reconcile the reserve for replacement account on a monthly basis. Anticipated Completion Date June 30, 2023

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FY 2021-12-31

$3,117,617 federal awards expendedNo findings recorded this year

FAC accepted this audit on July 13, 2022 — management decision was due January 13, 2023.

FY 2020-12-31

GOING CONCERN$3,089,117 federal awards expendedNo findings recorded this year

FAC accepted this audit on August 15, 2021 — management decision was due February 15, 2022.

FY 2019-12-31

GOING CONCERNMATERIAL NONCOMPLIANCE DISCLOSED$3,181,414 federal awards expended

FAC accepted this audit on September 7, 2020 — management decision was due March 7, 2021.

2019-001
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2018-003QUESTIONED COSTS

S3800-010: Finding Reference Number 2019-001 Program Information S3800-011: Major Federal Program Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing ? Section 207/223(F) (CFDA 14.155) Federal Agency: U.S. Department of Housing and Urban Development Pass-through Entity: None Type of Compliance Finding: N - Special Tests and Provisions S3800-015: Type of Finding Federal Awards Finding S3800-016: Finding Resolution Status In-process S3800-017: Information on Universe Population Size N/A S3800-018: Sample Size Information N/A S3800-019: Repeat Finding Number 2018-003 S3800-020: Criteria The regulatory agreement required that the Organization deposit any surplus cash into the residual receipts account within sixty days after the fiscal year end. S3800-030: Statement of Condition During our audit of the Organization?s fiscal year ended December 31, 2019 federal award program, we noted that the Organization failed to deposit the fiscal year 2018 surplus cash into the residual receipts account. S3800-032: Cause The Organization overlooked depositing the fiscal year 2018 surplus cash into the residual receipts account. S3800-033: Effect or Potential Effect The Organization was not in compliance with the regulatory agreement requirement related to deposit of surplus cash into the residual receipts account. S3800-035: Auditor Non-Compliance Code B ? Failure to Make Required Residual Receipts Deposits S3800-040: Questioned Costs $42,166 S3800-045: Reporting Views of Responsible Officials The Organization agreed with our finding. S3800-050: Context The Organization was required to deposit surplus cash into the residual receipts account within sixty days after the fiscal year-end. S3800-080: Recommendation The Organization should deposit delinquent surplus cash into the residual receipts account as soon as possible and establish a process to ensure timely deposit of surplus cash into residual receipts account after the fiscal year end. S3800-090: Auditor?s Summary of the Auditee?s Comments on the Findings and Recommendations Concur S3800-130: Response Indicator Agree S3800-140: Completion Date December 31, 2021 S3800-150: Response See Corrective Action Plan

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Full finding narrative

S3800-010: Finding Reference Number 2019-001 Program Information S3800-011: Major Federal Program Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing ? Section 207/223(F) (CFDA 14.155) Federal Agency: U.S. Department of Housing and Urban Development Pass-through Entity: None Type of Compliance Finding: N - Special Tests and Provisions S3800-015: Type of Finding Federal Awards Finding S3800-016: Finding Resolution Status In-process S3800-017: Information on Universe Population Size N/A S3800-018: Sample Size Information N/A S3800-019: Repeat Finding Number 2018-003 S3800-020: Criteria The regulatory agreement required that the Organization deposit any surplus cash into the residual receipts account within sixty days after the fiscal year end. S3800-030: Statement of Condition During our audit of the Organization?s fiscal year ended December 31, 2019 federal award program, we noted that the Organization failed to deposit the fiscal year 2018 surplus cash into the residual receipts account. S3800-032: Cause The Organization overlooked depositing the fiscal year 2018 surplus cash into the residual receipts account. S3800-033: Effect or Potential Effect The Organization was not in compliance with the regulatory agreement requirement related to deposit of surplus cash into the residual receipts account. S3800-035: Auditor Non-Compliance Code B ? Failure to Make Required Residual Receipts Deposits S3800-040: Questioned Costs $42,166 S3800-045: Reporting Views of Responsible Officials The Organization agreed with our finding. S3800-050: Context The Organization was required to deposit surplus cash into the residual receipts account within sixty days after the fiscal year-end. S3800-080: Recommendation The Organization should deposit delinquent surplus cash into the residual receipts account as soon as possible and establish a process to ensure timely deposit of surplus cash into residual receipts account after the fiscal year end. S3800-090: Auditor?s Summary of the Auditee?s Comments on the Findings and Recommendations Concur S3800-130: Response Indicator Agree S3800-140: Completion Date December 31, 2021 S3800-150: Response See Corrective Action Plan

Corrective Action Plan

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2019 Name of Audit: Metro Towers, Inc. HUD Project Number: 084-11131 Name of Audit Firm: Welch & Associates, LLC Period Covered by Audit: Year Ending December 31, 2019 Corrective Action Plan Prepared by: Name: Fred Gibbs Position: Managing Agent Telephone Number: (913) 709-1811 Findings-Financial Statement Audit None Findings-Federal Award Programs Audit Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing ? Section 207/223(F) CFDA Number: 14.155 Finding 2019-001 Comments on Findings and Each Recommendation The Organization agrees with the auditors? finding and recommendation. Action(s) Taken or Planned on the Finding The Organization will deposit the delinquent surplus cash amount of $42,166 into the residual receipts account as soon as possible and establish a process to ensure timely deposit of surplus cash into residual receipts account after the fiscal year end. The Organization expects to deposit the delinquent surplus cash by December 31, 2021.

Prior Finding References

2018-003

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2019-002
Procurement & Suspension/Debarment
MATERIAL WEAKNESSREPEAT OF 2018-004OTHER MATTERS

S3800-010 ? Finding Reference Number: 2019-002 Program Information S3800-011: Major Federal Programs Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing ? Section 207/223(F) (CFDA 14.155) Federal Agency: U.S. Department of Housing and Urban Development Pass-through Entity: None Type of Compliance Finding: I ? Procurement, Suspension, and Debarment S3800-015: Type of Finding Federal Award Finding S3800-016: Finding Resolution Status In-process S3800-017: Information on Universe Population Size N/A S3800-018: Sample Size Information N/A S3800-019: Repeat Finding Number 2018-004 S3800-020: Criteria Uniform Guidance requires the Organization to have a written procurement policy in accordance with applicable federal requirements. S3800-030: Statement of Condition During our audit of the Organization?s fiscal year ended December 31, 2019 financial statements, we noted that the procurement policy does not comply with the federal requirements. S3800-032: Cause The Organization?s procurement policy lacks all the required elements. The procurement policy requirements changed significantly under Uniform Guidance. S3800-033: Effect or Potential Effect The Organization was not in compliance with the federal requirements in relation to the procurement policy. S3800-035: Auditor Noncompliance Code Z ? Other S3800-040: Questioned Costs None S3800-045: Reporting Views of Responsible Officials The Organization will adopt a policy which complies with all applicable federal requirements. The Procurement requirements changed significantly under Uniform Guidance. S3800-050: Context The Organization?s Procurement policy does not include all applicable federal requirements. S3800-080: Recommendation The Organization should adopt a policy which complies with all applicable federal requirements. S3800-090: Auditor?s Summary of the Auditee?s Comments on the Findings and Recommendations Concur S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date December 31, 2020 S3800-150: Response See Corrective Action Plan

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S3800-010 ? Finding Reference Number: 2019-002 Program Information S3800-011: Major Federal Programs Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing ? Section 207/223(F) (CFDA 14.155) Federal Agency: U.S. Department of Housing and Urban Development Pass-through Entity: None Type of Compliance Finding: I ? Procurement, Suspension, and Debarment S3800-015: Type of Finding Federal Award Finding S3800-016: Finding Resolution Status In-process S3800-017: Information on Universe Population Size N/A S3800-018: Sample Size Information N/A S3800-019: Repeat Finding Number 2018-004 S3800-020: Criteria Uniform Guidance requires the Organization to have a written procurement policy in accordance with applicable federal requirements. S3800-030: Statement of Condition During our audit of the Organization?s fiscal year ended December 31, 2019 financial statements, we noted that the procurement policy does not comply with the federal requirements. S3800-032: Cause The Organization?s procurement policy lacks all the required elements. The procurement policy requirements changed significantly under Uniform Guidance. S3800-033: Effect or Potential Effect The Organization was not in compliance with the federal requirements in relation to the procurement policy. S3800-035: Auditor Noncompliance Code Z ? Other S3800-040: Questioned Costs None S3800-045: Reporting Views of Responsible Officials The Organization will adopt a policy which complies with all applicable federal requirements. The Procurement requirements changed significantly under Uniform Guidance. S3800-050: Context The Organization?s Procurement policy does not include all applicable federal requirements. S3800-080: Recommendation The Organization should adopt a policy which complies with all applicable federal requirements. S3800-090: Auditor?s Summary of the Auditee?s Comments on the Findings and Recommendations Concur S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date December 31, 2020 S3800-150: Response See Corrective Action Plan

Corrective Action Plan

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2019 Name of Audit: Metro Towers, Inc. HUD Project Number: 084-11131 Name of Audit Firm: Welch & Associates, LLC Period Covered by Audit: Year Ending December 31, 2019 Corrective Action Plan Prepared by: Name: Fred Gibbs Position: Managing Agent Telephone Number: (913) 709-1811 Findings-Financial Statement Audit None Findings-Federal Award Programs Audit Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing ? Section 207/223(F) CFDA Number: 14.155 Finding 2019-002 Comments on Findings and Each Recommendation The Organization agrees with the auditors? finding and recommendation. Action(s) Taken or Planned on the Finding The Organization will adopt a procurement policy which complies with all applicable federal requirements. The Organization expects to establish the process by December 31, 2020.

Prior Finding References

2018-004

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FY 2018-12-31

$4,210,289 federal awards expended

FAC accepted this audit on June 6, 2019 — management decision was due December 6, 2019.

2018-001
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2016-001, 2017-001

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-001, 2017-001

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2018-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2017-002QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-002

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2018-003
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2018-004
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2018-005
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINION

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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FY 2017-12-31

$1,413,115 federal awards expended

FAC accepted this audit on May 15, 2018 — management decision was due November 15, 2018.

2017-001
Special Tests & Provisions
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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2017-002
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2016-003QUESTIONED COSTS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-003

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2017-003
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Special Tests and Provisions →
2017-004
Special Tests & Provisions
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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FY 2016-12-31

MATERIAL NONCOMPLIANCE DISCLOSEDLOW-RISK AUDITEE$1,413,778 federal awards expended

FAC accepted this audit on June 15, 2017 — management decision was due December 15, 2017.

2016-001
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINION

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2016-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Special Tests and Provisions →
2016-003
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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