EIN: 455085747
UEI: VA29X49MNKJ7
Data as of August 27, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 11, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by June 11, 2026 (77 days ago).
What is a management decision? →Finding 2024-002 Program U.S. Department of Housing and Urban Development (HUD) – Supportive Housing for the Elderly (Section 202) and Project Rental Assistance, Assistance Listing No. 14.157. This finding was partially reported as finding 2023-001 in the prior year. Condition/Context A haphazard sample of two tenant files out of twenty (not a statistically valid sample) were selected for testing and for both the required documentation to determine eligibility, as required by the HUD regulations, could not be located as follows: Form HUD-50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures was not updated before the tenant’s anniversary date. There was no verification of income by a third party provided. There was no signed move-in/move-out inspection form provided. There was no signed lease provided. Additionally, our testing indicated that the required deposits to the replacement reserve account had not been made for the last quarter of the Corporation’s fiscal year for any tenants.
Show full finding ▾Hide full finding ▴Finding 2024-002 Program U.S. Department of Housing and Urban Development (HUD) – Supportive Housing for the Elderly (Section 202) and Project Rental Assistance, Assistance Listing No. 14.157. This finding was partially reported as finding 2023-001 in the prior year. Condition/Context A haphazard sample of two tenant files out of twenty (not a statistically valid sample) were selected for testing and for both the required documentation to determine eligibility, as required by the HUD regulations, could not be located as follows: Form HUD-50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures was not updated before the tenant’s anniversary date. There was no verification of income by a third party provided. There was no signed move-in/move-out inspection form provided. There was no signed lease provided. Additionally, our testing indicated that the required deposits to the replacement reserve account had not been made for the last quarter of the Corporation’s fiscal year for any tenants.
2024-002: Section 202, Assistance Listing No. 14.157 Two tenant files were selected for testing and for both the required documentation to determine eligibility, as required by the HUD regulations, could not be located as follows: • Form HUD-50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures was not updated before the tenant’s anniversary date. • There was no verification of income by a third party provided. • There was no signed move-in/move-out inspection form provided. • There was no signed lease provided. Additionally, our testing indicated that the required deposits to the replacement reserve account had not been made for the last quarter of the Corporation’s fiscal year for any tenants. Recommendation: We recommend the Corporation establish procedures and internal controls to ensure that all required documentation is maintained, and all required reserve deposits are made timely, in accordance with HUD requirements. Action Taken: Management concurs with this recommendation. Since assuming property management on June 1, 2025, ULREDC has conducted a tenant file audit. All property management staff have been properly trained to ensure compliance with certification, documentation, and inspection requirements. Missing documentation, including Form HUD-50059, income verifications, and leasing inspections, is being corrected. Replacement reserve deposits were delayed because properties were not cash flowing. As leasing stabilizes, deposits will resume and be verified once RealPage is fully active. RealPage will serve as the compliance and record-retention platform. Quarterly internal compliance reviews will be instituted to confirm file accuracy and documentation completeness.
2023-001
FAC accepted this audit on December 7, 2023 — management decision was due June 7, 2024.
Finding 2023-001 Program U.S. Department of Housing and Urban Development (HUD) – Supportive Housing for the Elderly (Section 202) and Project Rental Assistance, Assistance Listing No. 14.157. Condition We determined a sample selection size of two selections for tenant testing. The Corporation did not complete Form HUD-50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures, before the tenant’s anniversary date, as required by HUD, for one of the two tenants selected for testing. Criteria Tenant recertifications should be completed and maintained as required by HUD requirements. Cause There were no procedures in place to ensure that all annual recertifications were properly completed and maintained. Effect Failure to comply with the annual recertification process is an instance of noncompliance with the Regulatory Agreement. Recommendation We recommend the Corporation establish procedures to ensure that the annual recertifications are completed on a timely basis in accordance with HUD requirements. Reporting Views of Responsible Officials Management agrees with the recommendation and the Corporation’s Board of Directors has made the decision to change property managing agents effective January 1, 2024. It is anticipated that the change to a new property managing agent will allow the Corporation to establish procedures to ensure all recertifications are performed and maintained in accordance with the regulatory agreement.
Show full finding ▾Hide full finding ▴Finding 2023-001 Program U.S. Department of Housing and Urban Development (HUD) – Supportive Housing for the Elderly (Section 202) and Project Rental Assistance, Assistance Listing No. 14.157. Condition We determined a sample selection size of two selections for tenant testing. The Corporation did not complete Form HUD-50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures, before the tenant’s anniversary date, as required by HUD, for one of the two tenants selected for testing. Criteria Tenant recertifications should be completed and maintained as required by HUD requirements. Cause There were no procedures in place to ensure that all annual recertifications were properly completed and maintained. Effect Failure to comply with the annual recertification process is an instance of noncompliance with the Regulatory Agreement. Recommendation We recommend the Corporation establish procedures to ensure that the annual recertifications are completed on a timely basis in accordance with HUD requirements. Reporting Views of Responsible Officials Management agrees with the recommendation and the Corporation’s Board of Directors has made the decision to change property managing agents effective January 1, 2024. It is anticipated that the change to a new property managing agent will allow the Corporation to establish procedures to ensure all recertifications are performed and maintained in accordance with the regulatory agreement.
2023-001: Section 202, Assistance Listing No. 14.157 Two tenant files were selected for testing and the required documentation to determine eligibility, as required by the HUD Regulatory Agreement, could not be located as follows: • One file was missing Form HUD-50059, Owner’s Certification of Compliance Recommendation: We recommend the Corporation establish procedures for maintaining tenant files to comply with HUD requirements for verification of tenant information, as required. Action Taken: Management agrees with the recommendation and the Corporation’s Board of Directors has made the decision to change property managing agents effective January 1, 2024. It is anticipated that the change to a new property managing agent will allow the Corporation to establish procedures to ensure all recertifications are performed and maintained in accordance with the regulatory agreement. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Seanelle Hawkins at 585-325-6530.
2022-001
FAC accepted this audit on December 28, 2022 — management decision was due June 28, 2023.
Finding 2022-001 Program U.S. Department of Housing and Urban Development (HUD) ? Supportive Housing for the Elderly (Section 202) and Project Rental Assistance, Assistance Listing No. 14.157. Condition Two tenant files were selected for testing and the required documentation to determine eligibility, as required by the HUD Regulatory Agreement, could not be located as follows: ? 2 files were missing Form HUD-50059, Owner?s Certification of Compliance ? 2 files were missing the move-in and move-out inspection forms Criteria Tenant files and all required documentation should be maintained as established by HUD requirements. Cause There were no procedures in place to ensure that all tenant files were properly maintained. Effect Inadequate tenant file documentation has resulted in the Corporation?s inability to comply with HUD regulations. Recommendation We recommend the Corporation establish procedures for maintaining tenant files to comply with HUD requirements for verification of tenant information, as required. Reporting Views of Responsible Officials Management agrees with the recommendation and will establish procedures with the managing agent to ensure all tenant files are maintained in accordance with HUD regulations.
Show full finding ▾Hide full finding ▴Finding 2022-001 Program U.S. Department of Housing and Urban Development (HUD) ? Supportive Housing for the Elderly (Section 202) and Project Rental Assistance, Assistance Listing No. 14.157. Condition Two tenant files were selected for testing and the required documentation to determine eligibility, as required by the HUD Regulatory Agreement, could not be located as follows: ? 2 files were missing Form HUD-50059, Owner?s Certification of Compliance ? 2 files were missing the move-in and move-out inspection forms Criteria Tenant files and all required documentation should be maintained as established by HUD requirements. Cause There were no procedures in place to ensure that all tenant files were properly maintained. Effect Inadequate tenant file documentation has resulted in the Corporation?s inability to comply with HUD regulations. Recommendation We recommend the Corporation establish procedures for maintaining tenant files to comply with HUD requirements for verification of tenant information, as required. Reporting Views of Responsible Officials Management agrees with the recommendation and will establish procedures with the managing agent to ensure all tenant files are maintained in accordance with HUD regulations.
2022-001: Section 202, Assistance Listing No. 14.157 Two tenant files were selected for testing and the required documentation to determine eligibility, as required by the HUD Regulatory Agreement, could not be located as follows: ? 2 files were missing Form HUD-50059, Owner?s Certification of Compliance ? 2 files were missing the move-in and move-out inspection forms Recommendation: We recommend the Corporation establish procedures for maintaining tenant files to comply with HUD requirements for verification of tenant information, as required. Action Taken: Management agrees with the recommendation and will establish procedures with the managing agent to ensure all tenant files are maintained in accordance with HUD regulations.
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