CITADEL GARDENS, INC.Non-Profit

S3800-010: Finding Reference Number 2025-001 (Material Weakness) S3800-011: Program Information Federal Program: Supportive Housing for the Elderly - Section 202 Federal Agency: U.S. Department of Housing and Urban Development Assistance Listing #: 14.157 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, 2023-001, 2022-001 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 auditor’s finding. S3800-050: Context On the general ledger, accounts receivable, accounts payable, prepaid rents, rent revenue, cash and tenant security deposits did not tie to supporting documentation. The expenses were also not capitalized 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 Concur S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date December 31, 2025 S3800-150: Response See Corrective Action Plan

S3800-010: Finding Reference Number 2025-002 (Significant Deficiency) S3800-011: Program Information Federal Program: Supportive Housing for the Elderly - Section 202 Federal Agency: U.S. Department of Housing and Urban Development Assistance Listing #: 14.157 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 Resolved 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 March 31, 2025 federal award program, we noted the Organization did not have a HUD approved Form 9839-B from March 1, 2025 through March 31, 2025. S3800-032: Cause The Organization did not submit a timely request to approve the management agent. S3800-033: Effect or Potential Effect As of March 31, 2025 the management agent had not been approved; however, on August 4, 2025 HUD retroactively approved the management agent effective March 1, 2025. S3800-035: Auditor Non-Compliance Code J – Unauthorized management fees S3800-040: Questioned Costs $0 S3800-045: Reporting Views of Responsible Officials Management agrees with auditor’s 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 timely submit the request to approve the management agent. 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 July 24, 2025 S3800-150: Response See Corrective Action Plan

S3800-010: Finding Reference Number 2025-003 (Material Weakness) S3800-011: Program Information Federal Program: Supportive Housing for the Elderly - Section 202 Federal Agency: U.S. Department of Housing and Urban Development Assistance Listing #: 14.157 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: A/B – Activities Allowed or Unallowed and Allowable Costs / Cost Principles, E – Eligibility, and 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 2024-002, 2024-003, 2023-002, 2023-003 S3800-020: Criteria The Regulatory Agreement, HUD Handbook 4350.3, and HUD Handbook 4381.5 requires that Organizations are compliant with procedures for allowable activities and costs, accepting applicants, managing the waitlist, determining initial eligibility and recertifying tenants annually, determining a tenant’s rent and subsidy, and work orders and tenant complaints. S3800-030: Statement of Condition During our audit of the Organization’s fiscal year ended March 31, 2025 federal award program, we noted the below concerns regarding adherence to compliance requirements: • Supporting documentation to evaluate Activities Allowed or Unallowed and Allowable Costs/Cost Principles was not available. • Supporting documentation to evaluate Eligibility was not available. • Supporting documentation to evaluate Special Tests and Provisions for the following criteria were not available: o Move-outs (security deposits), waitlist applicants, and work-orders / maintenance requests S3800-032: Cause Management did not perform internal control processes and procedures to ensure adherence to HUD compliance requirements. S3800-033: Effect or Potential Effect We have not obtained sufficient audit evidence to express an opinion on the accompanying federal award program due to the inability to perform substantive auditing procedures. S3800-035: Auditor Non-Compliance Code Z - Other S3800-040: Questioned Costs Unknown S3800-045: Reporting Views of Responsible Officials Auditee has not had time to evaluate Auditor’s finding. S3800-050: Context The Organization is required to comply with the Regulatory Agreement and HUD handbooks. S3800-080: Recommendation The management agent should keep all required documentation in tenant files and establish processes and procedures to ensure compliance with the provisions in HUD Handbook 4350.3, HUD Handbook 4381.5, and the Regulatory Agreement. 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, 2025 S3800-150: Response See Corrective Action Plan

S3800-010: Finding Reference Number 2024-001 (Material Weakness) S3800-011: Program Information Federal Program: Supportive Housing for the Elderly - Section 202 Federal Agency: U.S. Department of Housing and Urban Development Assistance Listing #: 14.157 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 auditor’s finding. S3800-050: Context On the general ledger, accounts receivable, prepaid rents, rent revenue and tenant security deposits did not tie to supporting documentation. The expenses were also not capitalized 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 Concur S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date December 31, 2024 S3800-150: Response See Corrective Action Plan

S3800-010: Finding Reference Number 2024-002 (Material Weakness) S3800-011: Program Information Federal Program: Supportive Housing for the Elderly - Section 202 Federal Agency: U.S. Department of Housing and Urban Development Assistance Listing #: 14.157 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: E – Eligibility S3800-015: Type of Finding Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size 61 S3800-018: Sample Size Information 8 S3800-019: Identification of Repeat Finding and Finding Reference Number 2023-002 S3800-020: Criteria HUD-subsidized, multifamily housing properties must follow specific guidelines for determining eligibility and establishing and maintaining security deposits for tenants moving out; to determine whether they are in compliance with provisions in the HUD Handbook (4350.3). S3800-030: Statement of Condition During our audit of the Organization’s fiscal year ended March 31, 2024 federal award program, we noted the below concerns regarding adherence to compliance requirements • The Organization did not have the necessary supporting documentation to evaluate security deposits and criminal and background information for three tenants in their files • The Organization did not have the necessary supporting documentation to evaluate move-outs for two tenants in their files S3800-032: Cause The Organization did not follow HUD required procedures for eligibility and security deposits. S3800-033: Effect or Potential Effect The Organization was not in compliance with the requirements of HUD related to determining initial eligibility and establishing and maintaining security deposits for tenants moving out. S3800-035: Auditor Non-Compliance Code M – Security deposits S3800-040: Questioned Costs Unknown S3800-045: Reporting Views of Responsible Officials Management agrees with the auditor’s finding. S3800-050: Context The Organization is required to be in compliance with provisions relating to tenant eligibility and establishing and maintaining security deposits for tenants moving out. S3800-080: Recommendation The Organization should follow procedures to ensure tenant eligibility and establishing and maintaining security deposits for tenants moving out and the Organization should review the accuracy / completeness of the documentation being processed in the tenant files on a periodic basis. 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, 2024 S3800-150: Response See Corrective Action Plan

S3800-010: Finding Reference Number 2024-003 (Material Weakness) S3800-011: Program Information Federal Program: Supportive Housing for the Elderly - Section 202 Federal Agency: U.S. Department of Housing and Urban Development Assistance Listing #: 14.157 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: A/B – Activities Allowed or Unallowed and Allowable Costs/Cost Principles S3800-015: Type of Finding Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size >250 S3800-018: Sample Size Information 25 S3800-019: Identification of Repeat Finding and Finding Reference Number 2023-003 S3800-020: Criteria Per 24 CFR Part 891, PRAC project funds may be used only for expenses that are reasonable and necessary to the operation of the project as provided for in the Regulatory Agreement between HUD and the project owner. S3800-030: Statement of Condition During our audit of the Organization’s fiscal year ended March 31, 2024 federal award program, we noted that the Organization did not: • Maintain proper documentation to support expenditures for three of the twenty-five samples • Adhere to the HUD approved budget o Manager or Superintendent salaries were greater than approved amount o Payroll expenses were greater than approved amount o Garbage and trash removal expenses were greater than approved amount S3800-032: Cause The Organization did not follow HUD required procedures and the approved budget for activities allowed or unallowed and allowable costs and cost principles and Management is not following processes in place that require supporting documentation to be included with all expenditures. S3800-033: Effect or Potential Effect The Organization was not in compliance with the requirements of HUD related to activities allowed or unallowed and allowable costs and cost principles and expenditures may not be allowed. S3800-035: Auditor Non-Compliance Code S – Internal control deficiencies S3800-040: Questioned Costs $40,295 S3800-045: Reporting Views of Responsible Officials Management agrees with auditor’s finding. S3800-050: Context The Organization is required to be in compliance with provisions relating to activities allowed or unallowed and allowable costs and cost principles. S3800-080: Recommendation The Organization should follow procedures to ensure expenditures are not greater than the HUD approved budget and expenditures include supporting documentation before they are posted to the general ledger. The Organization should also review the accuracy / completeness of all documentation prior to making payment. 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, 2024 S3800-150: Response See Corrective Action Plan

S3800-011: Program Information Federal Program: Supportive Housing for the Elderly - Section 202 Federal Agency: U.S. Department of Housing and Urban Development Assistance Listing #: 14.157 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 2022-001 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 auditor’s finding. S3800-050: Context On the general ledger, accounts receivable, prepaid rents, and tenant security deposits did not tie to supporting documentation. The expenses were also not capitalized as per the capitalization policy. 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 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 Concur S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date December 31, 2023 S3800-150: Response See Corrective Action Plan

S3800-011: Program Information Federal Program: Supportive Housing for the Elderly - Section 202 Federal Agency: U.S. Department of Housing and Urban Development Assistance Listing #: 14.157 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: E - Eligibility S3800-015: Type of Finding Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size 53 S3800-018: Sample Size Information 10 S3800-019: Identification of Repeat Finding and Finding Reference Number N/A S3800-020: Criteria HUD-subsidized, multifamily housing properties must follow specific guidelines for determining eligibility and establishing and maintaining security deposits for tenants moving out; and determine whether they are in compliance with provisions in the HUD Handbook (4350.3). S3800-030: Statement of Condition During our audit of the Organization’s fiscal year ended March 31, 2023 federal award program, we noted that the Organization did not have the necessary documentation related to security deposits for five tenants and move-outs for three tenants in their files. S3800-032: Cause The Organization did not follow HUD required procedures for eligibility and security deposits. S3800-033: Effect or Potential Effect The Organization was not in compliance with the requirements of HUD related to determining initial eligibility and establishing and maintaining security deposits for tenants moving out. S3800-035: Auditor Non-Compliance Code M – Security deposits S3800-040: Questioned Costs Unknown S3800-045: Reporting Views of Responsible Officials Management agrees with the auditor’s finding. S3800-050: Context The Organization is required to be in compliance with provisions relating to tenant eligibility and establishing and maintaining security deposits for tenants moving out. S3800-080: Recommendation The Organization should follow procedures to ensure tenant eligibility and establishing and maintaining security deposits for tenants moving out and the Organization should review the accuracy / completeness of the documentation being processed in the tenant files on a periodic basis. 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, 2023 S3800-150: Response See Corrective Action Plan

S3800-011: Program Information Federal Program: Supportive Housing for the Elderly - Section 202 Federal Agency: U.S. Department of Housing and Urban Development Assistance Listing #: 14.157 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: A/B – Activities Allowed or Unallowed and Allowable Costs/Cost Principles S3800-015: Type of Finding Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size 53 S3800-018: Sample Size Information 250< S3800-019: Identification of Repeat Finding and Finding Reference Number N/A S3800-020: Criteria Per 24 CFR Part 891, PRAC project funds may be used only for expenses that are reasonable and necessary to the operation of the project as provided for in the Regulatory Agreement between HUD and the project owner. S3800-030: Statement of Condition During our audit of the Organization’s fiscal year ended March 31, 2023 federal award program, we noted that the Organization did not maintain proper documentation to support the payments made for six of the twenty-five samples. S3800-032: Cause The Organization did not follow HUD required procedures for activities allowed or unallowed and allowable costs and cost principles and Management is not following processes in place that require supporting documentation to be included with all expenditures. S3800-033: Effect or Potential Effect The Organization was not in compliance with the requirements of HUD related to activities allowed or unallowed and allowable costs and cost principles and payments made may not be allowed. S3800-035: Auditor Non-Compliance Code S – Internal control deficiencies S3800-040: Questioned Costs Unknown S3800-045: Reporting Views of Responsible Officials Management agrees with auditor’s finding. S3800-050: Context The Organization is required to be in compliance with provisions relating to activities allowed or unallowed and allowable costs and cost principles. S3800-080: Recommendation The Organization should follow procedures to ensure expenditures include supporting documentation before they are posted to the general ledger, and the Organization should review the accuracy / completeness of the documentation prior to making payment. 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, 2023 S3800-150: Response See Corrective Action Plan

S3800-010: Finding Reference Number 2022-001 Program Information S3800-011: Federal Program Supportive Housing for the Elderly - Section 202 Federal Agency: U.S. Department of Housing and Urban Development Federal Award Identification Number and Year: COVID-19 Identification: Pass-through Entity: None CFDA #: 14.157 Type of Compliance Finding: N ? Special Tests and Provisions S3800-015: Type of Finding Financial Statement and 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 N/A S3800-020: Criteria HUD Handbook 4370.2 REV-1 ?Financial Operations and Accounting Procedures for Insured Multifamily Projects? Chapter 2-2 states in pertinent part that the books and records should be maintained in accordance with Generally Accepted Accounting Principles (GAAP). Section 9(d) of the Organization?s Regulatory Agreement states the books and records should be maintained in accordance with the requirements of HUD. S3800-030: Statement of Condition During our audit of the Organization?s fiscal year ended March 31, 2022 federal award program, we noted that management had not recorded a material audit entry for depreciation calculated during the prior year audit. As a result, the financial statements were materially misstated and not in compliance with GAAP. S3800-032: Cause The Organization?s engages the audit firm to perform the depreciation calculation at the time of the audit due to not having a fixed asset system in which to easily perform the calculation. The Organization failed to record the prior year entry causing the financials to be materially misstated. The Organization does not have adequate internal controls over financial reporting. S3800-033: Effect or Potential Effect The Organization is not in compliance with requirements to maintain books and records according to GAAP. S3800-035: Auditor Non-Compliance Code S ? Internal Control Deficiencies S3800-040: Questioned Costs None S3800-045: Reporting Views of Responsible Officials Management agreed with auditor?s finding. S3800-050: Context Management did not record prior year depreciation of fixed assets. S3800-080: Recommendation Management should ensure that annual depreciation entry is recorded when it is provided by the audit firm. Management should ensure accounting records agree to audited financial statements. 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, 2022 S3800-150: Response See Corrective Action Plan

S3800-010: Finding Reference Number 2022-002 Program Information S3800-011: Federal Program Supportive Housing for the Elderly - Section 202 Federal Agency: U.S. Department of Housing and Urban Development Federal Award Identification Number and Year: COVID-19 Identification: Pass-through Entity: None CFDA #: 14.157 Type of Compliance Finding: N ? Special Tests and Provisions S3800-015: Type of Finding Federal Award Finding S3800-016: Finding Resolution Status In-progress S3800-017: Information on Universe Population Size NA S3800-018: Sample Size Information NA S3800-019: Repeat Finding Number NA S3800-020: Criteria The Project Rental Assistance Contract (PRAC) with the U.S. Department of Housing and Urban Development (HUD) approved a rent increase effective April 1, 2021. S3800-030: Statement of Condition During our audit of the Organization?s fiscal year ended March 31, 2022 we noted the approved rent increase was not implemented and rents were charged at the prior year?s rates. S3800-032: Cause The Organization does not have adequate internal controls to ensure rents charged are in accordance with most recent PRAC contract. S3800-033: Effect or Potential Effect The Organization was not in compliance with the requirements of HUD related to rental assistance contract. S3800-035: Auditor Non-Compliance Code: Z ? Other S3800-040: Questioned Costs $31,871 S3800-045: Reporting Views of Responsible Officials Management agreed with auditor?s finding S3800-050: Context The Organization did not charge rent in accordance with most recent HUD approved rates. S3800-080: Recommendation The Organization should implement a process to ensure that rent is charged in accordance with the most recent PRAC authorized by HUD. 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 August 31, 2022 S3800-150: Response See Corrective Action Plan

S3800-010: Finding Reference Number 2021-001 Program Information S3800-011: Federal Program Supportive Housing for the Elderly - Section 202 Federal Agency: U.S. Department of Housing and Urban Development Pass-through Entity: None CFDA #: 14.157 Type of Compliance Finding: N ? Special Tests and Provisions S3800-015: Type of Finding Federal Awards Finding S3800-016: Finding Resolution Status In-progress S3800-017: Information on Universe Population Size 7 S3800-018: Sample Size Information 3 S3800-019: Repeat Finding Number 2020-003 S3800-020: Criteria HUD Handbook 4350.3 ?Occupancy Requirements of Subsidized Multifamily Housing Programs? Section 6-18(C) requires that within 30 days after the move-out date, a landlord must either (1) refund the full security deposit or (2) provide the former tenant with an itemized list of any unpaid rent and other charges that includes statement of their rights under state and local laws, where if the amount the owner claims is less than the security deposit, the owner must refund the unused balance to the tenant. S3800-030: Statement of Condition During our audit of the Organization?s fiscal year ended March 31, 2021 financial statements, we noted that the Organization not provide one former tenant with a report explaining the disposition of their security deposit and did not refund the security deposit to that former tenant. S3800-032: Cause The Organization does not have an adequate process to ensure that tenant security deposits for former tenants are administered in accordance with HUD guidelines. S3800-033: Effect or Potential Effect The Organization was not in compliance with the requirements of HUD related to tenant security deposits. S3800-035: Auditor Non-Compliance Code: M ? Security deposits S3800-040: Questioned Costs $215 S3800-045: Reporting Views of Responsible Officials The Organization will implement a process to ensure that former tenant?s security deposits are timely disposed of in accordance with HUD rules. S3800-050: Context The Organization is required to provide a report to former tenant?s within 30 days of move-out explaining the disposition of their security deposit. S3800-080: Recommendation The Organization should implement a process to ensure that former tenant?s security deposits are timely disposed of in accordance with HUD rules. 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 September 30, 2021 S3800-150: Response See Corrective Action Plan

S3800-010: Finding Reference Number 2020-001 Program Information S3800-011: Federal Program Supportive Housing for the Elderly - Section 202 Federal Agency: U.S. Department of Housing and Urban Development Pass-through Entity: None CFDA #: 14.157 Type of Compliance Finding: I ? Procurement, Suspension, and Debarment S3800-015: Type of Finding Federal Award Finding S3800-016: Finding Resolution Status In-progress S3800-017: Information on Universe Population Size N/A S3800-018: Sample Size Information N/A S3800-019: Repeat Finding Number 2019-001 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 March 31, 2020 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

S3800-010: Finding Reference Number 2020-002 Program Information S3800-011: Federal Program Supportive Housing for the Elderly - Section 202 Federal Agency: U.S. Department of Housing and Urban Development Pass-through Entity: None CFDA #: 14.157 Type of Compliance Finding: N ? Special Tests and Provisions S3800-015: Type of Finding Federal Awards Finding S3800-016: Finding Resolution Status In-progress S3800-017: Information on Universe Population Size 209 S3800-018: Sample Size Information 21 S3800-019: Repeat Finding Number N/A S3800-020: Criteria HUD requires owners of multifamily housing to follow specific guidelines and determine requirements are being met for tenants requesting maintenance of property via work orders. S3800-030: Statement of Condition During our audit of the Organization?s fiscal year ended March 31, 2020 financial statements, we noted that HUD requirements related to work orders were not properly followed. We tested a sample of 21 work orders and noted that workorders were not completed timely. S3800-032: Cause The Organization did not follow the HUD approved procedures for work orders. S3800-033: Effect or Potential Effect The Organization was not in compliance with the requirements of HUD related to work orders. S3800-035: Auditor Non-Compliance Code: Z - Other S3800-040: Questioned Costs None S3800-045: Reporting Views of Responsible Officials The Organization will adopt a policy to make sure that work orders are completed in a timely manner and required documentation is retained in their records. S3800-050: Context The Organization is required to have all of its necessary information in the files as required by HUD. S3800-080: Recommendation The Organization should adopt a policy to make sure that work orders are completed in a timely manner and required documentation is retained in their records. 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

S3800-010: Finding Reference Number 2020-003 Program Information S3800-011: Federal Program Supportive Housing for the Elderly - Section 202 Federal Agency: U.S. Department of Housing and Urban Development Pass-through Entity: None CFDA #: 14.157 Type of Compliance Finding: N ? Special Tests and Provisions S3800-015: Type of Finding Federal Awards Finding S3800-016: Finding Resolution Status In-progress S3800-017: Information on Universe Population Size 7 S3800-018: Sample Size Information 5 S3800-019: Repeat Finding Number N/A S3800-020: Criteria HUD Handbook 4350.3 ?Occupancy Requirements of Subsidized Multifamily Housing Programs? Section 6-18(C) requires that within 30 days after the move-out date, a landlord must either (1) refund the full security deposit or (2) provide the former tenant with an itemized list of any unpaid rent and other charges that includes statement of their rights under state and local laws, where if the amount the owner claims is less than the security deposit, the owner must refund the unused balance to the tenant. S3800-030: Statement of Condition During our audit of the Organization?s fiscal year ended March 31, 2020 financial statements, we noted that the Organization did not refund two security deposits within 30-days of move-out. S3800-032: Cause The Organization does not have an adequate process to ensure that tenant security deposits for former tenants are administered in accordance with HUD guidelines. S3800-033: Effect or Potential Effect The Organization was not in compliance with the requirements of HUD related to tenant security deposits. S3800-035: Auditor Non-Compliance Code: M ? Security deposits S3800-040: Questioned Costs $379 S3800-045: Reporting Views of Responsible Officials The Organization will adopt a policy to ensure that former tenant?s security deposits are timely disposed of in accordance with HUD rules. S3800-050: Context The Organization is required to handle all former tenant security deposits as required by HUD. S3800-080: Recommendation The Organization should adopt a policy to timely review the move-out reports and ensure that tenant security deposits are being handled in accordance with HUD guidelines. 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

S3800-010: Finding Reference Number 2019-001 Program Information S3800-011: Major Federal Programs Supportive Housing for the Elderly - Section 202 Federal Agency: U.S. Department of Housing and Urban Development Pass-through Entity: None CFDA #: 14.157 Type of Compliance Finding: I ? Procurement, Suspension, and Debarment S3800-015: Type of Finding Federal Award Finding S3800-016: Finding Resolution Status In-progress S3800-017: Information on Universe Population Size N/A S3800-018: Sample Size Information N/A S3800-019: Repeat Finding Number N/A 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 March 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 September 30, 2019 S3800-150: Response See Corrective Action Plan

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