EIN: 463323500
UEI: YZ5QMDM1UK16
Audited by: CBIZ CPAs, P.C.
Oversight agency: 14 [Department of Housing and Urban Development]
Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on October 1, 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 April 1, 2026 (149 days ago).
What is a management decision? →Identification of the federal program AL #14.181, Department of Housing and Urban Development, Section 811 Capital Advance 2015 • Criteria The compliance supplement states that "Owners shall establish and maintain a replacement reserve to aid in funding extraordinary maintenance and repair and replacement of capital items. The replacement reserve funds must be deposited in a federally insured depository in an interestbearing account. All earnings including interest on the reserve must be added to the reserve. An amount as required by HUD will be deposited monthly in the reserve fund (Regulatory Agreement, item 5 (a)). All disbursements from the reserve must be approved by HUD (24 CFR section 891.405)." • Condition As of December 31, 2024 the account maintained at a federally insured depository is not interest bearing. • Cause The Project did not verify that the account was interest bearing at the time it was opened and has not corrected this error. • Effect or potential effect The Project is not in compliance with the requirements set forth by HUD related to its reserve for replacement account. • Questioned costs None • Identification as a repeat finding This is a repeat finding. • Recommendation The Project should transfer its reserve for replacement balance to a new account within a federally insured financial institution which is interest bearing. • Views of responsible officials The Organization’s agrees with this finding and has implemented additional accounting policies and procedures, as well as staffing changes, in order to correct these issues. See the response included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴Identification of the federal program AL #14.181, Department of Housing and Urban Development, Section 811 Capital Advance 2015 • Criteria The compliance supplement states that "Owners shall establish and maintain a replacement reserve to aid in funding extraordinary maintenance and repair and replacement of capital items. The replacement reserve funds must be deposited in a federally insured depository in an interestbearing account. All earnings including interest on the reserve must be added to the reserve. An amount as required by HUD will be deposited monthly in the reserve fund (Regulatory Agreement, item 5 (a)). All disbursements from the reserve must be approved by HUD (24 CFR section 891.405)." • Condition As of December 31, 2024 the account maintained at a federally insured depository is not interest bearing. • Cause The Project did not verify that the account was interest bearing at the time it was opened and has not corrected this error. • Effect or potential effect The Project is not in compliance with the requirements set forth by HUD related to its reserve for replacement account. • Questioned costs None • Identification as a repeat finding This is a repeat finding. • Recommendation The Project should transfer its reserve for replacement balance to a new account within a federally insured financial institution which is interest bearing. • Views of responsible officials The Organization’s agrees with this finding and has implemented additional accounting policies and procedures, as well as staffing changes, in order to correct these issues. See the response included in the Corrective Action Plan.
Management concurs with the findings and is working to ensure all employees adhere to control procedures and compliance requirements set by HUD. For finding 2024-002, the Organization has transferred the funds into an interest-bearing account.
2023-002
FAC accepted this audit on October 1, 2024 — management decision was due April 1, 2025.
• Identification of the federal program AL #14.181, Department of Housing and Urban Development, Section 811 Capital Advance 2015 • Criteria The compliance supplement states that "Owners shall establish and maintain a replacement reserve to aid in funding extraordinary maintenance and repair and replacement of capital items. The replacement reserve funds must be deposited in a federally insured depository in an interestbearing account. All earnings including interest on the reserve must be added to the reserve. An amount as required by HUD will be deposited monthly in the reserve fund (Regulatory Agreement, item 5 (a)). All disbursements from the reserve must be approved by HUD (24 CFR section 891.405)." • Condition As of December 31, 2023 the account maintained at a federally insured depository is not interest bearing. • Cause The Project did not verify that the account was interest bearing at the time it was opened and has not corrected this error. • Effect or potential effect The Project is not in compliance with the requirements set forth by HUD related to its reserve for replacement account. • Questioned costs None • Identification as a repeat finding This is not a repeat finding. • Recommendation The Project should transfer its reserve for replacement balance to a new account within a federally insured financial institution which is interest bearing. • Views of responsible officials The Organization’s agrees with this finding and has implemented additional accounting policies and procedures, as well as staffing changes, in order to correct these issues. See the response included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴• Identification of the federal program AL #14.181, Department of Housing and Urban Development, Section 811 Capital Advance 2015 • Criteria The compliance supplement states that "Owners shall establish and maintain a replacement reserve to aid in funding extraordinary maintenance and repair and replacement of capital items. The replacement reserve funds must be deposited in a federally insured depository in an interestbearing account. All earnings including interest on the reserve must be added to the reserve. An amount as required by HUD will be deposited monthly in the reserve fund (Regulatory Agreement, item 5 (a)). All disbursements from the reserve must be approved by HUD (24 CFR section 891.405)." • Condition As of December 31, 2023 the account maintained at a federally insured depository is not interest bearing. • Cause The Project did not verify that the account was interest bearing at the time it was opened and has not corrected this error. • Effect or potential effect The Project is not in compliance with the requirements set forth by HUD related to its reserve for replacement account. • Questioned costs None • Identification as a repeat finding This is not a repeat finding. • Recommendation The Project should transfer its reserve for replacement balance to a new account within a federally insured financial institution which is interest bearing. • Views of responsible officials The Organization’s agrees with this finding and has implemented additional accounting policies and procedures, as well as staffing changes, in order to correct these issues. See the response included in the Corrective Action Plan.
Management concurs with the findings and is working to ensure all employees adhere to control procedures and compliance requirements set by HUD. For finding 2023-002, the Organization is working to transfer the funds into an interest-bearing account.
• Identification of the federal program AL #14.181, Department of Housing and Urban Development, Section 811 Capital Advance 2015 • Criteria The compliance supplement states that "Surplus cash available at the end of the annual reporting period is to be deposited into a Residual Receipts account within sixty (60) days. Surplus cash is determined by completion of a Computation of Surplus Cash. (Chapter 2 of HUD Handbook 4370.2, Financial Operations and Accounting Procedures for Insured Multifamily Projects.) Withdrawals from this account require HUD approval." • Condition As of the audit issuance date, the December 31, 2023 the computed surplus cash amount has not been deposited into a residual receipts reserve. • Cause The Project did not calculate the surplus cash timely in order to determine the amount which should have been deposited into a residual receipts account. • Effect or potential effect The Project is not in compliance with the requirements set forth by HUD related to its cash surplus. • Questioned costs None • Identification as a repeat finding This is not a repeat finding. • Recommendation The Project should deposit the cash surplus amount into the residual receipts account. • Views of responsible officials The Organization’s agrees with this finding and has implemented additional accounting policies and procedures, as well as staffing changes, in order to correct these issues. See the response included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴• Identification of the federal program AL #14.181, Department of Housing and Urban Development, Section 811 Capital Advance 2015 • Criteria The compliance supplement states that "Surplus cash available at the end of the annual reporting period is to be deposited into a Residual Receipts account within sixty (60) days. Surplus cash is determined by completion of a Computation of Surplus Cash. (Chapter 2 of HUD Handbook 4370.2, Financial Operations and Accounting Procedures for Insured Multifamily Projects.) Withdrawals from this account require HUD approval." • Condition As of the audit issuance date, the December 31, 2023 the computed surplus cash amount has not been deposited into a residual receipts reserve. • Cause The Project did not calculate the surplus cash timely in order to determine the amount which should have been deposited into a residual receipts account. • Effect or potential effect The Project is not in compliance with the requirements set forth by HUD related to its cash surplus. • Questioned costs None • Identification as a repeat finding This is not a repeat finding. • Recommendation The Project should deposit the cash surplus amount into the residual receipts account. • Views of responsible officials The Organization’s agrees with this finding and has implemented additional accounting policies and procedures, as well as staffing changes, in order to correct these issues. See the response included in the Corrective Action Plan.
Management concurs with the findings and is working to ensure all employees adhere to control procedures and compliance requirements set by HUD. For finding 2023-003, the Organization is working to deposit surplus cash into a residual receipts account.
FAC accepted this audit on April 3, 2021 — management decision was due October 3, 2021.
FINDING 2020-001 ? Replacement Reserve Deposits Federal Agency: U.S. Department of Housing and Urban Development Pass through Entity: Not applicable Program Name: Section 811 Capital Advance Program Section 811 Project Rental Assistance Payments CFDA# and Program Expenditures: 14.181 ($2,147,500) 14.181 ($ 41,683) Award Number: N/A Federal Award Year: January 1, 2020 to December 31, 2020 Questioned Costs: None Condition Found: The reserve for replacement was not funded for the year ended December 31, 2020. Monthly deposits totaling $8,165 for the year should have been deposited in the account. In addition, replacement reserve deposits totaling $23,787 were not made for the years ending December 31, 2019, 2018, and 2017. A total of $31,952 is due to the replacement reserve account. Criteria: The regulatory agreement requires that $680.41 be deposited in the replacement reserve account each month from January 2020 through December 2020. Cause: The required deposits were not transferred from the operating account to the replacement reserve account. Possible Asserted Effect: The replacement reserve was underfunded by $8,165 for the year ended December 31, 2020. The replacement reserve was also underfunded by a combined total of $23,787 for the year ended December 31, 2019, 2018, and 2017. The cumulative total due to the replacement reserve fund is $31,952. Repeat Finding: This finding was reported in the immediately prior audit as Finding 2019-002. Recommendation: The overall reserve shortage of $31,952 should be funded as soon as possible. Management should consider requesting a replacement reserve deposit waiver or a rent increase from HUD. Management Response: Project management will follow-up with HUD on a request for a replacement reserve deposit waiver. In the absence of an approved waiver, management will transfer $31,952 from operating to reserve after evaluating available cash. Management hopes to have this completed by December 31, 2021.
Show full finding ▾Hide full finding ▴FINDING 2020-001 ? Replacement Reserve Deposits Federal Agency: U.S. Department of Housing and Urban Development Pass through Entity: Not applicable Program Name: Section 811 Capital Advance Program Section 811 Project Rental Assistance Payments CFDA# and Program Expenditures: 14.181 ($2,147,500) 14.181 ($ 41,683) Award Number: N/A Federal Award Year: January 1, 2020 to December 31, 2020 Questioned Costs: None Condition Found: The reserve for replacement was not funded for the year ended December 31, 2020. Monthly deposits totaling $8,165 for the year should have been deposited in the account. In addition, replacement reserve deposits totaling $23,787 were not made for the years ending December 31, 2019, 2018, and 2017. A total of $31,952 is due to the replacement reserve account. Criteria: The regulatory agreement requires that $680.41 be deposited in the replacement reserve account each month from January 2020 through December 2020. Cause: The required deposits were not transferred from the operating account to the replacement reserve account. Possible Asserted Effect: The replacement reserve was underfunded by $8,165 for the year ended December 31, 2020. The replacement reserve was also underfunded by a combined total of $23,787 for the year ended December 31, 2019, 2018, and 2017. The cumulative total due to the replacement reserve fund is $31,952. Repeat Finding: This finding was reported in the immediately prior audit as Finding 2019-002. Recommendation: The overall reserve shortage of $31,952 should be funded as soon as possible. Management should consider requesting a replacement reserve deposit waiver or a rent increase from HUD. Management Response: Project management will follow-up with HUD on a request for a replacement reserve deposit waiver. In the absence of an approved waiver, management will transfer $31,952 from operating to reserve after evaluating available cash. Management hopes to have this completed by December 31, 2021.
CORRECTIVE ACTION PLAN Year Ended December 31, 2020 FINDING 2020-001 ? Replacement Reserve Deposits CFDA# and Program Expenditures: 14.181 ($2,147,500) 14.181 ($ 41,683) Award Number: N/A Federal Award Year: January 1, 2020 to December 31, 2020 Questioned Costs: None Condition Found: The reserve for replacement was not funded for the year ended December 31, 2020. Monthly deposits totaling $8,165 for the year should have been deposited in the account. In addition, replacement reserve deposits totaling $23,787 were not made for the years ending December 31, 2019, 2018, and 2017. A total of $31,952 is due to the replacement reserve account. Corrective Action Plan: Project management will follow-up with HUD on a request for a replacement reserve deposit waiver. In the absence of an approved waiver, management will transfer $31,952 from operating to reserve after evaluating available cash. Fred Gibbs is the contact person for this finding. Management anticipates completing this task by December 31, 2021.
2019-002
FAC accepted this audit on July 20, 2020 — management decision was due January 20, 2021.
FINDING 2019-001 ? Residual Receipt Deposits Federal Agency: U.S. Department of Housing and Urban Development Pass through Entity: Not applicable Program Name: Section 811 Capital Advance Program CFDA# and Program Expenditures: 14.181 ($2,147,500) Award Number: N/A Federal Award Year: January 1, 2019 to December 31, 2019 Questioned Costs: None Condition Found: The $4,762 of surplus cash at December 31, 2018 was not deposited into the residual receipts account within ninety days. In addition, $11,123 and $22,783 of surplus cash was not deposited for the years ending December 31, 2017 and 2016, respectively. Criteria: According to HUD?s guidelines, a Project must deposit surplus cash due to residual receipts within ninety days after the fiscal period ends (REAC submission due date). Cause: Project management did not transfer the surplus cash of $4,762 from the operating account to the residual receipts account. There was a shortage of cash arising from HAP voucher funds not being received timely. The Project received the 2017 HAP funds shortage in January 2018 and the 2016 HAP funds shortage in November 2018. Possible Asserted Effect: The Project held excess cash and did not make the required residual receipts deposit. $4,762 was due for the year ended December 31, 2018.Repeat Finding: See Finding 2018-004 for a similar finding in the prior year. Recommendation: Surplus cash was recalculated at December 31, 2019. The Project did not have surplus cash at December 31, 2019. The Project should wait for further instructions from HUD for the residual deposits that were due December 31, 2018, 2017, and 2016. In addition, procedures should be improved to ensure that surplus cash is calculated and transferred to residual receipts timely. Management Response: Project management is discussing waiving the prior period residual receipt with the HUD account executive. The Project will wait for further instructions from HUD for the residual deposits that were due December 31, 2018, 2017, and 2016. In addition, procedures will be improved to ensure that surplus cash is calculated and transferred to residual receipts timely.
Show full finding ▾Hide full finding ▴FINDING 2019-001 ? Residual Receipt Deposits Federal Agency: U.S. Department of Housing and Urban Development Pass through Entity: Not applicable Program Name: Section 811 Capital Advance Program CFDA# and Program Expenditures: 14.181 ($2,147,500) Award Number: N/A Federal Award Year: January 1, 2019 to December 31, 2019 Questioned Costs: None Condition Found: The $4,762 of surplus cash at December 31, 2018 was not deposited into the residual receipts account within ninety days. In addition, $11,123 and $22,783 of surplus cash was not deposited for the years ending December 31, 2017 and 2016, respectively. Criteria: According to HUD?s guidelines, a Project must deposit surplus cash due to residual receipts within ninety days after the fiscal period ends (REAC submission due date). Cause: Project management did not transfer the surplus cash of $4,762 from the operating account to the residual receipts account. There was a shortage of cash arising from HAP voucher funds not being received timely. The Project received the 2017 HAP funds shortage in January 2018 and the 2016 HAP funds shortage in November 2018. Possible Asserted Effect: The Project held excess cash and did not make the required residual receipts deposit. $4,762 was due for the year ended December 31, 2018.Repeat Finding: See Finding 2018-004 for a similar finding in the prior year. Recommendation: Surplus cash was recalculated at December 31, 2019. The Project did not have surplus cash at December 31, 2019. The Project should wait for further instructions from HUD for the residual deposits that were due December 31, 2018, 2017, and 2016. In addition, procedures should be improved to ensure that surplus cash is calculated and transferred to residual receipts timely. Management Response: Project management is discussing waiving the prior period residual receipt with the HUD account executive. The Project will wait for further instructions from HUD for the residual deposits that were due December 31, 2018, 2017, and 2016. In addition, procedures will be improved to ensure that surplus cash is calculated and transferred to residual receipts timely.
FINDING 2019-001 ? Residual Receipt Deposits CFDA# and Program Expenditures: 14.181 ($2,147,500) Award Number: N/A Federal Award Year: January 1, 2019 ? December 31, 2019 Questioned Costs: None Condition Found: The $4,762 of surplus cash at December 31, 2018 was not deposited into the residual receipts account within ninety days. Corrective Action Plan: There was not a surplus cash balance at December 31, 2019. Project management is contacting the Project?s HUD account executive to see if a waiver can be obtained. The Project will wait for further instructions from HUD for the residual deposits that were due December 31, 2018, 2017, and 2016. In addition, procedures will be improved to ensure that surplus cash is calculated and transferred to residual receipts timely. Fred Gibbs is the contact person for this finding. Management anticipates completing this task by September 30, 2020.
2018-004
FINDING 2019-002 ? Replacement Reserve Deposits Federal Agency: U.S. Department of Housing and Urban Development Pass through Entity: Not applicable Program Name: Section 811 Capital Advance Program CFDA# and Program Expenditures: 14.181 ($2,147,500) Award Number: N/A Federal Award Year: January 1, 2019 to December 31, 2019 Questioned Costs: None Condition Found: The reserve for replacement was not funded for the year ended December 31, 2019. Monthly deposits totaling $8,165 for the year should have been deposited in the account. In addition, replacement reserve deposits totaling $15,622 were not made for the years ending December 31, 2018 and 2017. A total of $23,787 is due to the replacement reserve account. Criteria: The regulatory agreement requires that $680.41 be deposited in the replacement reserve account each month from January 2019 through December 2019. Cause: The required deposits were not transferred from the operating account to the replacement reserve account. Possible Asserted Effect: The replacement reserve was underfunded by $8,165 for the year ended December 31, 2019. The replacement reserve was also underfunded by a combined total of $15,622 for the year ended December 31, 2018 and 2017. The cumulative total due to the replacement reserve fund is $23,787. Repeat Finding: This finding was reported in the immediately prior audit as Finding 2018-001. Recommendation: The overall reserve shortage of $23,787 should be funded as soon as possible. Management should consider requesting a replacement reserve deposit waiver or a rent increase from HUD. Management Response: Project management will follow-up with HUD on a request for a replacement reserve deposit waiver. In the absence of an approved waiver, management will transfer $23,787 from operating to reserve after evaluating available cash. Management hopes to have this completed by September 30, 2020.
Show full finding ▾Hide full finding ▴FINDING 2019-002 ? Replacement Reserve Deposits Federal Agency: U.S. Department of Housing and Urban Development Pass through Entity: Not applicable Program Name: Section 811 Capital Advance Program CFDA# and Program Expenditures: 14.181 ($2,147,500) Award Number: N/A Federal Award Year: January 1, 2019 to December 31, 2019 Questioned Costs: None Condition Found: The reserve for replacement was not funded for the year ended December 31, 2019. Monthly deposits totaling $8,165 for the year should have been deposited in the account. In addition, replacement reserve deposits totaling $15,622 were not made for the years ending December 31, 2018 and 2017. A total of $23,787 is due to the replacement reserve account. Criteria: The regulatory agreement requires that $680.41 be deposited in the replacement reserve account each month from January 2019 through December 2019. Cause: The required deposits were not transferred from the operating account to the replacement reserve account. Possible Asserted Effect: The replacement reserve was underfunded by $8,165 for the year ended December 31, 2019. The replacement reserve was also underfunded by a combined total of $15,622 for the year ended December 31, 2018 and 2017. The cumulative total due to the replacement reserve fund is $23,787. Repeat Finding: This finding was reported in the immediately prior audit as Finding 2018-001. Recommendation: The overall reserve shortage of $23,787 should be funded as soon as possible. Management should consider requesting a replacement reserve deposit waiver or a rent increase from HUD. Management Response: Project management will follow-up with HUD on a request for a replacement reserve deposit waiver. In the absence of an approved waiver, management will transfer $23,787 from operating to reserve after evaluating available cash. Management hopes to have this completed by September 30, 2020.
FINDING 2019-002 ? Replacement Reserve Deposits CFDA# and Program Expenditures: 14.181 ($2,147,500) Award Number: N/A Federal Award Year: January 1, 2019 to December 31, 2019 Questioned Costs: None Condition Found: The reserve for replacement was not funded for the year ended December 31, 2019. Monthly deposits totaling $8,165 for the year should have been deposited in the account. In addition, replacement reserve deposits totaling $15,622 were not made for the years ending December 31, 2018 and 2017. A total of $23,787 is due to the replacement reserve account. Corrective Action Plan: Project management will contact the Project?s HUD account executive to request a payment waiver. In the absence of a waiver, project management will transfer $23,787 from operating to reserve after evaluating available cash. Fred Gibbs is the contact person for this finding. Management anticipates completing this task by September 30, 2020.
2018-001
FAC accepted this audit on July 22, 2019 — management decision was due January 22, 2020.
GSA_MIGRATION
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2017-001
FAC accepted this audit on April 10, 2018 — management decision was due October 10, 2018.
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GSA_MIGRATION
FAC accepted this audit on May 21, 2017 — management decision was due November 21, 2017.
GSA_MIGRATION
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