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OVER THE RAINBOW ASS'N & SUBSIDIARIESNon-Profit

EIN: 510174945

UEI: J5ZXT2W8K7S7

Audit also covers 6 related EINs: 201768398, 202584736, 204635666, 363296450, 474443135, 822633828 · unlinked EINs have no separate FAC filing

Audited by: BAKER MEINZ & ASSOCIATES, LTD

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

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Showing data from September 2, 2026 — the Federal Audit Clearinghouse is under high demand right now, so this couldn't be refreshed. This is the most recent data on record, not necessarily today's.

OVER THE RAINBOW ASS'N & SUBSIDIARIES9 audit years38 findings6 repeat
9
Audit Years
38
Total Findings
6
Repeat Findings
$17.7M
Federal Awards Expended (FY 2024)

FY 2024-12-31

$17,691,185 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on September 30, 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 March 30, 2026 (157 days ago).

What is a management decision? →
2024-001
Special Tests & Provisions
REPEAT OF 2023-001QUESTIONED COSTSOTHER MATTERS

The Project repaid a portion of the sponsor loan payable (Due to Related Party) without obtaining HUD approval. The total amount of the unauthorized sponsor loan payment was $130,019. Criteria: HUD approval should be obtained prior to making a sponsor loan repayment. Effect: The Project's cash balance is $130,019 less than it should be. Context: The Sponsor loan payable at December 31, 2024 was tested. The test determined that a portion of the sponsor loan was repaid without obtaining HUD approval. Questioned Costs - $130,019. Cause: The Project repaid a portion of the sponsor loan without obtaining HUD approval. Recommendation: The Sponsor should contact HUD to obtain permission to retain the unauthorized sponsor loan payments. Views of Responsible Officials and Planned Corrective Actions: The Sponsor will work with HUD to detemine if the $130,019 needs to be paid back to the Project. Total - Department of Housing and Urban Development $130,019, Non-compliance code - R

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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Hill Housing Facility - FINDING 2024-001: SECTION 8, ASSISTANCE LISTING NUMBER 14.195 Condition: The Project repaid a portion of the sponsor loan payable (Due to Related Party) without obtaining HUD approval. The total amount of the unauthorized sponsor loan payment was $130,019. Criteria: HUD approval should be obtained prior to making a sponsor loan repayment. Effect: The Project's cash balance is $130,019 less than it should be. Context: The Sponsor loan payable at December 31, 2024 was tested. The test determined that a portion of the sponsor loan was repaid without obtaining HUD approval. Questioned Costs - $130,019. Cause: The Project repaid a portion of the sponsor loan without obtaining HUD approval. Recommendation: The Sponsor should contact HUD to obtain permission to retain the unauthorized sponsor loan payments. Views of Responsible Officials and Planned Corrective Actions: The Sponsor will work with HUD to detemine if the $130,019 needs to be paid back to the Project. Total - Department of Housing and Urban Development $130,019, Non-compliance code - R

Corrective Action Plan

Over the Rainbow Association and Subsidiaries respectfully submits the following corrective action plans for the year ended December 31, 2024. Name and address of independent public accounting firm: Baker Meinz & Associates, Ltd. 1000 Shelard Parkway, Suite 110 Minneapolis, MN 55426 Audit period: December 31, 2024. The findings from the December 31, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section A of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS - FINANCIAL STATEMENT AUDIT - NONE; FINDINGS - FEDERAL AWARD PROGRAMS AUDIT - DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT; For the Hill Housing Facility - FINDING 2024-001: SECTION 8, ASSISTANCE LISTING NUMBER 14.195 SPONSOR LOAN PAYMENT WITHOUT HUD APPROVAL Recommendation: The Sponsor should obtain HUD approval for the repayment of the sponsor loan. Action Taken: The Sponsor will contact HUD to obtain HUD permission to retain the unauthorized sponsor loan payments.

Prior Finding References

2023-001

About Special Tests and Provisions →
2024-002
Special Tests & Provisions
QUESTIONED COSTSOTHER MATTERS

One of the tenant files tested contained a mathematical error in computing household income in the process of computing the tenant share of monthly rent. Criteria: Household income should be computed accurately based on information provided by the tenant. Effect: There is no financial effect. Context: A sample of tenant files was selected for testing household income in the process of computing the tenant share of monthly rent. The test found a calculation that was not in compliance. The non-compliance did not have a financial effect. The details and results of the sample are as follows: Population - 20, Dollars - N/A; Sample - 2, Dollars N/A; Not in Compliance - 1, $99; Questioned Costs - $99. Cause: There was an error in interpreting some information provided by the tenant during the certification process. Recommendation: The Project should recompute the HUD subsidy and tenant rent for this tenant. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Tenant rent will be recomputed and management will adjust a future monthly HUD billing. Questioned Costs - Department of Housing and Urban Development - $99; Non-compliance code - R

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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Rockford Supportive Housing Facility - FINDING 2024-002: SECTION 811, ASSISTANCE LISTING NUMBER 14.181 Condition: One of the tenant files tested contained a mathematical error in computing household income in the process of computing the tenant share of monthly rent. Criteria: Household income should be computed accurately based on information provided by the tenant. Effect: There is no financial effect. Context: A sample of tenant files was selected for testing household income in the process of computing the tenant share of monthly rent. The test found a calculation that was not in compliance. The non-compliance did not have a financial effect. The details and results of the sample are as follows: Population - 20, Dollars - N/A; Sample - 2, Dollars N/A; Not in Compliance - 1, $99; Questioned Costs - $99. Cause: There was an error in interpreting some information provided by the tenant during the certification process. Recommendation: The Project should recompute the HUD subsidy and tenant rent for this tenant. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Tenant rent will be recomputed and management will adjust a future monthly HUD billing. Questioned Costs - Department of Housing and Urban Development - $99; Non-compliance code - R

Corrective Action Plan

For the Rockford Supportive Housing Facility - FINDING 2024-002: SECTION 811, ASSISTANCE LISTING NUMBER 14.181 TENANT FILE CONTAINED MATHEMATICAL ERROR IN COMPUTING HOUSEHOLD INCOME Recommendation: The Project should recompute the HUD subsidy and tenant rent for this tenant and adjust a future monthly billing. Project managers should be aware of the importance of computing the tenant's household income correctly. Action Taken: The Project agrees with the finding. Tenant rent was recomputed in January 2025 and will be corrected on a future HAP voucher.

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2024-003
Cost Allowability
QUESTIONED COSTSOTHER MATTERS

The Project paid the expense of another project under common management. Criteria: The Project should not pay the expenses of another project. Effect: The amount of the expense incorrectly paid was $3,500. Context: The Accounts Receivable - Operations account was tested at December 31, 2024. No sample was tested. Questioned Costs - $3,500, Cause: The Project mistakenly paid the invoice of another project under common management. Recommendation: The Project should carefully review invoices before payment to make sure it only pays the proper amount. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. The accounts payable staff will be reminded to be careful when entering invoices for payment. Total-Department of Housing and Urban Development $3,500, Non-compliance code - R

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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Waukegan Supportive Housing Facility FINDING 2024-003: SECTION 811, ASSISTANCE LISTING NUMBER 14.181 Condition: The Project paid the expense of another project under common management. Criteria: The Project should not pay the expenses of another project. Effect: The amount of the expense incorrectly paid was $3,500. Context: The Accounts Receivable - Operations account was tested at December 31, 2024. No sample was tested. Questioned Costs - $3,500, Cause: The Project mistakenly paid the invoice of another project under common management. Recommendation: The Project should carefully review invoices before payment to make sure it only pays the proper amount. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. The accounts payable staff will be reminded to be careful when entering invoices for payment. Total-Department of Housing and Urban Development $3,500, Non-compliance code - R

Corrective Action Plan

For the Waukegan Supportive Housing Facility - FINDING 2024-003: SECTION 811, ASSISTANCE LISTING NUMBER 14.181 PAID THE EXPENSE OF ANOTHER PROJECT UNDER COMMON MANAGEMENT Recommendation: The Project should carefully review invoices before payment to make sure it pays the correct amount. Action Taken: The Project agrees with the finding. The accounts payable staff will be reminded to be careful when entering invoices for payment.

About Allowable Costs / Cost Principles →
2024-004
Cost Allowability
QUESTIONED COSTSOTHER MATTERS

The Project paid the expense of another project under common management. Criteria: The Project should not pay the expenses of another project. Effect: The amount of the expense incorrectly paid was $1,250. Context: The Accounts and Notes Receivable account was tested at December 31, 2024. No sample was tested. Questioned Costs - $1,250, Cause: The Project mistakenly paid the invoice of another project under common management. Recommendation: The Project should carefully review invoices before payment to make sure it only pays the proper amount. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. The accounts payable staff will be reminded to be careful when entering invoices for payment. Total-Department of Housing and Urban Development - $1,250; Non-compliance code - R.

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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the OTR - Arboretum West Apartments Facility FINDING 2024-004: SECTION 223(f), ASSISTANCE LISTING NUMBER 14.155 Condition: The Project paid the expense of another project under common management. Criteria: The Project should not pay the expenses of another project. Effect: The amount of the expense incorrectly paid was $1,250. Context: The Accounts and Notes Receivable account was tested at December 31, 2024. No sample was tested. Questioned Costs - $1,250, Cause: The Project mistakenly paid the invoice of another project under common management. Recommendation: The Project should carefully review invoices before payment to make sure it only pays the proper amount. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. The accounts payable staff will be reminded to be careful when entering invoices for payment. Total-Department of Housing and Urban Development - $1,250; Non-compliance code - R.

Corrective Action Plan

For the OTR - Arboretum West Apartments Facility FINDING 2024-004: SECTION 223(f), ASSISTANCE LISTING NUMBER 14.155 PAID THE EXPENSE OF ANOTHER PROJECT UNDER COMMON MANAGEMENT Recommendation: The Project should carefully review invoices before payment to make sure it pays the correct amount. Action Taken: The Project agrees with the finding. The accounts payable staff will be reminded to be careful when entering invoices for payment.

About Allowable Costs / Cost Principles →

FY 2023-12-31

$17,658,047 federal awards expended

FAC accepted this audit on September 25, 2024 — management decision was due March 25, 2025.

2023-001
Special Tests & Provisions
REPEAT OF 2022-001QUESTIONED COSTSOTHER MATTERS

The Project did not deposit surplus cash at December 31, 2021 into a residual receipts account. The amount that should have been deposited was $14,079. Criteria: The Project should have deposited surplus cash at December 31, 2021 into a residual receipts account. Effect: The residual receipts account balance was $14,079 less than it should be at December 31, 2023. Context: Activity in the residual receipts account for the year ended December 31, 2023 was tested. No sample was tested. Questioned Costs - $14,079, Cause: The Project did not make the necessary deposit of surplus cash into a residual receipts account. Recommendation: The Project should deposit surplus cash as of December 31, 2021 into a residual receipt account as soon as possible. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Management will deposit $14,079 into a residual receipts account as soon as possible. Total - Department of Housing and Urban Development - $14,079, Non-compliance code - B

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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Hill Housing Facility FINDING 2023-001: SECTION 8, ASSISTANCE LISTING NUMBER 14.195 Condition: The Project did not deposit surplus cash at December 31, 2021 into a residual receipts account. The amount that should have been deposited was $14,079. Criteria: The Project should have deposited surplus cash at December 31, 2021 into a residual receipts account. Effect: The residual receipts account balance was $14,079 less than it should be at December 31, 2023. Context: Activity in the residual receipts account for the year ended December 31, 2023 was tested. No sample was tested. Questioned Costs - $14,079, Cause: The Project did not make the necessary deposit of surplus cash into a residual receipts account. Recommendation: The Project should deposit surplus cash as of December 31, 2021 into a residual receipt account as soon as possible. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Management will deposit $14,079 into a residual receipts account as soon as possible. Total - Department of Housing and Urban Development - $14,079, Non-compliance code - B

Corrective Action Plan

For the Hill Housing Facility - FINDING 2023-001: SECTION 8, ASSISTANCE LISTING NUMBER 14.195 - SURPLUS CASH NOT DEPOSITED INTO RESIDUAL RECEIPTS ACCOUNT - Recommendation: The Project should deposit surplus cash as of December 31, 2021 into a residual receipts account as soon as possible. Action Taken: The Project agrees with the finding. Management will deposit $14,079 in a residual receipts account as soon as possible.

Prior Finding References

2022-001

About Special Tests and Provisions →
2023-002
Special Tests & Provisions
REPEAT OF 2022-002QUESTIONED COSTSOTHER MATTERS

The Project repaid a portion of the sponsor loan payable (Due to Related Party) without obtaining HUD approval. The total amount of the unauthorized sponsor loan payment was $130,019. Criteria: HUD approval should be obtained prior to making a sponsor loan repayment. Effect: The Project's cash balance is $130,019 less than it should be. Context: The Sponsor loan payable at December 31, 2023 was tested. The test determined that a portion of the sponsor loan was repaid without obtaining HUD approval. Questioned Costs - $130,019, Cause: The Project repaid a portion of the sponsor loan without obtaining HUD approval. Recommendation: The Sponsor should work with HUD to determine if the $130,019 needs to be paid back to the Project. Views of Responsible Officials and Planned Corrective Actions: The Sponsor will work with HUD to detemine if the $130,019 needs to be paid back to the Project. Total - Department of Housing and Urban Development - $130,019, Non-compliance code - R

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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Hill Housing Facility - FINDING 2023-002: SECTION 8, ASSISTANCE LISTING NUMBER 14.195 Condition: The Project repaid a portion of the sponsor loan payable (Due to Related Party) without obtaining HUD approval. The total amount of the unauthorized sponsor loan payment was $130,019. Criteria: HUD approval should be obtained prior to making a sponsor loan repayment. Effect: The Project's cash balance is $130,019 less than it should be. Context: The Sponsor loan payable at December 31, 2023 was tested. The test determined that a portion of the sponsor loan was repaid without obtaining HUD approval. Questioned Costs - $130,019, Cause: The Project repaid a portion of the sponsor loan without obtaining HUD approval. Recommendation: The Sponsor should work with HUD to determine if the $130,019 needs to be paid back to the Project. Views of Responsible Officials and Planned Corrective Actions: The Sponsor will work with HUD to detemine if the $130,019 needs to be paid back to the Project. Total - Department of Housing and Urban Development - $130,019, Non-compliance code - R

Corrective Action Plan

For the Hill Housing Facility - FINDING 2023-002: SECTION 8, ASSISTANCE LISTING NUMBER 14.195 - SPONSOR LOAN PAYMENT WITHOUT HUD APPROVAL - Recommendation: The Sponsor should work with HUD to determine if the $130,019 needs to be paid back to the Project. Action Taken: The Sponsor will work with HUD to determine if the $130,019 needs to be paid back to the Project.

Prior Finding References

2022-002

About Special Tests and Provisions →
2023-003
Special Tests & Provisions
OTHER MATTERS

One of the tenant files tested did not have evidence of verification of disability and/or handicapped status that would make the tenant eligible for the program. Criteria: Tenant files should contain documentation of disability/handicapped status. Effect: The Project received HUD subsidy that it may not be entitled to. Context: A sample of tenant files was selected for testing for evidence of verification of disability and/or handicapped status. The test found one file not in compliance. The non-compliance did not have a financial effect. The details and results of the sample are as follows: Population - 29, $ - N/A; Sample - 3, $ - N/A; Not in Compliance - 1, $ - N/A; Questioned Costs - None; Cause: The Project manager overlooked the requirement for verification of disability/handicapped status. Recommendation: The Project manager should attempt to obtain proper verification of disability/handicapped status on this tenant. If verification cannot be obtained, the Project should reimburse HUD for all rent subsidy on this tenant. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. The project managers were reminded to obtain documentation to verify disability/handicapped status. Total - Department of Housing and Urban Development - Questioned Costs = None; Non-compliance code - R

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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Hill Housing Facility - FINDING 2023-003: SECTION 8, ASSISTANCE LISTING NUMBER 14.195 Condition: One of the tenant files tested did not have evidence of verification of disability and/or handicapped status that would make the tenant eligible for the program. Criteria: Tenant files should contain documentation of disability/handicapped status. Effect: The Project received HUD subsidy that it may not be entitled to. Context: A sample of tenant files was selected for testing for evidence of verification of disability and/or handicapped status. The test found one file not in compliance. The non-compliance did not have a financial effect. The details and results of the sample are as follows: Population - 29, $ - N/A; Sample - 3, $ - N/A; Not in Compliance - 1, $ - N/A; Questioned Costs - None; Cause: The Project manager overlooked the requirement for verification of disability/handicapped status. Recommendation: The Project manager should attempt to obtain proper verification of disability/handicapped status on this tenant. If verification cannot be obtained, the Project should reimburse HUD for all rent subsidy on this tenant. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. The project managers were reminded to obtain documentation to verify disability/handicapped status. Total - Department of Housing and Urban Development - Questioned Costs = None; Non-compliance code - R

Corrective Action Plan

For the Hill Housing Facility - FINDING 2023-003: SECTION 8, ASSISTANCE LISTING NUMBER 14.195 - TENANT FILE MISSING DISABILITY AND/OR HANDICAPPED VERIFICATION - Recommendation: The Project manager should attempt to obtain proper verification of disability/handicapped status on this tenant. If verification cannot be obtained, the Project should reimburse HUD for all rent subsidy on this tenant. Action Taken: The Project agrees with the finding. The project managers were reminded to obtain documentation to verify disability/handicapped status.

About Special Tests and Provisions →
2023-004
Cost Allowability
QUESTIONED COSTSOTHER MATTERS

The Project overpaid management fees to the management company. Criteria: The management company should calculate management fees using the correct formula. Effect: The Project's management fee expense is overstated. Context: The management fee for the year was tested for accuracy. Through testing, it was determined that the total cash receipts number used to calculate management fee was overstated. The details and results of the sample are as follows: Population - $31,166; Sample - $31,166; Not in Compliance - $31,166; Questioned Costs - $653; Cause: The management company did not compute the management fee correctly. Recommendation: The management company should repay the $653 to the Project. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. The management company will repay the management fee overpayment as soon as possible. Total - Department of Housing and Urban Development - $653; Non-compliance code - J

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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Hill Housing Facility - FINDING 2023-004: SECTION 8, ASSISTANCE LISTING NUMBER 14.195 Condition: The Project overpaid management fees to the management company. Criteria: The management company should calculate management fees using the correct formula. Effect: The Project's management fee expense is overstated. Context: The management fee for the year was tested for accuracy. Through testing, it was determined that the total cash receipts number used to calculate management fee was overstated. The details and results of the sample are as follows: Population - $31,166; Sample - $31,166; Not in Compliance - $31,166; Questioned Costs - $653; Cause: The management company did not compute the management fee correctly. Recommendation: The management company should repay the $653 to the Project. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. The management company will repay the management fee overpayment as soon as possible. Total - Department of Housing and Urban Development - $653; Non-compliance code - J

Corrective Action Plan

For the Hill Housing Facility - FINDING 2023-004: SECTION 8, ASSISTANCE LISTING NUMBER 14.195 - OVERPAYMENT OF MANAGEMENT FEES - Recommendation: The management company should repay the $653 to the Project. Action Taken: The Project agrees with the finding. The management company will repay the management fee overpayment as soon as possible.

About Allowable Costs / Cost Principles →
2023-005
Special Tests & Provisions
REPEAT OF 2022-003QUESTIONED COSTSOTHER MATTERS

The Project took a HUD subsidy loan from replacement reserves of $15,000 and failed to repay the loan based upon the terms of the agreement with HUD. Criteria: The Project should have repaid the required amount to replacement reserves. Effect: The replacement reserve balance was underfunded by $15,000 at December 31, 2023. Context: All elements of the replacement reserve account were tested at December 31, 2023. No sample was selected. Questioned costs - $15,000; Cause: The Project neglected to repay the HUD subsidy loan based upon the terms of the agreement. Recommendation: The Project should repay the HUD subsidy loan as soon as funds are available. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. A $15,000 transfer will be made once funds are available. Management will be reminded to carefully review HUD correspondence to make sure HUD subsidy loan terms are being followed. Questioned Costs - Department of Housing and Urban Development - $15,000; Non-compliance code - N

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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Rockford Supportive Housing Facility - FINDING 2023-005: SECTION 811, ASSISTANCE LISTING NUMBER 14.181 Condition: The Project took a HUD subsidy loan from replacement reserves of $15,000 and failed to repay the loan based upon the terms of the agreement with HUD. Criteria: The Project should have repaid the required amount to replacement reserves. Effect: The replacement reserve balance was underfunded by $15,000 at December 31, 2023. Context: All elements of the replacement reserve account were tested at December 31, 2023. No sample was selected. Questioned costs - $15,000; Cause: The Project neglected to repay the HUD subsidy loan based upon the terms of the agreement. Recommendation: The Project should repay the HUD subsidy loan as soon as funds are available. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. A $15,000 transfer will be made once funds are available. Management will be reminded to carefully review HUD correspondence to make sure HUD subsidy loan terms are being followed. Questioned Costs - Department of Housing and Urban Development - $15,000; Non-compliance code - N

Corrective Action Plan

For the Rockford Supportive Housing Facility - FINDING 2023-005: SECTION 811, ASSISTANCE LISTING NUMBER 14.181 - HUD SUBSIDY LOAN FROM REPLACEMENT REERVES NOT REPAID - Recommendation: The Project should repay the HUD subsidy loan as soon as funds are available. Action Taken: The Project agrees with the finding. A $15,000 transfer will be made once funds are available. Management will be reminded to carefully review HUD correspondence to make sure HUD subsidy loan terms are being followed.

Prior Finding References

2022-003

About Special Tests and Provisions →
2023-006
Special Tests & Provisions
OTHER MATTERS

One of the tenant files tested did not have evidence of verification of disability and/or handicapped status that would make the tenant eligible for the program. Criteria: Tenant files should contain documentation of disability/handicapped status. Effect: The Project received HUD subsidy that it may not be entitled to. Context: A sample of tenant files was selected for testing for evidence of verification of disability and/or handicapped status. The test found one file not in compliance. The non-compliance did not have a financial effect. The details and results of the sample are as follows: Population - 23, $ - N/A; Sample - 3, $ - N/A; Not in Compliance - 1, $ - N/A; Questioned Costs - None; Cause: The Project manager overlooked the requirement for verification of disability/handicapped status. Recommendation: The Project manager should attempt to obtain proper verification of disability/handicapped status on this tenant. If verification cannot be obtained, the Project should reimburse HUD for all rent subsidy on this tenant. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. The project managers were reminded to obtain documentation to verify disability/handicapped status. Questioned Costs - Department of Housing and Urban Development - None; Non-compliance code - R

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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT - For the Waukegan Supportive Housing Facility - FINDING 2023-006: SECTION 811, ASSISTANCE LISTING NUMBER 14.181, Condition: One of the tenant files tested did not have evidence of verification of disability and/or handicapped status that would make the tenant eligible for the program. Criteria: Tenant files should contain documentation of disability/handicapped status. Effect: The Project received HUD subsidy that it may not be entitled to. Context: A sample of tenant files was selected for testing for evidence of verification of disability and/or handicapped status. The test found one file not in compliance. The non-compliance did not have a financial effect. The details and results of the sample are as follows: Population - 23, $ - N/A; Sample - 3, $ - N/A; Not in Compliance - 1, $ - N/A; Questioned Costs - None; Cause: The Project manager overlooked the requirement for verification of disability/handicapped status. Recommendation: The Project manager should attempt to obtain proper verification of disability/handicapped status on this tenant. If verification cannot be obtained, the Project should reimburse HUD for all rent subsidy on this tenant. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. The project managers were reminded to obtain documentation to verify disability/handicapped status. Questioned Costs - Department of Housing and Urban Development - None; Non-compliance code - R

Corrective Action Plan

For the Waukegan Supportive Housing Facility - FINDING 2023-006: SECTION 811, ASSISTANCE LISTING NUMBER 14.181 - TENANT FILE MISSING DISABILITY AND/OR HANDICAPPED VERIFICATION - Recommendation: The Project manager should attempt to obtain proper verification of disability/handicapped status on this tenant. If verification cannot be obtained, the Project should reimburse HUD for all rent subsidy on this tenant. Action Taken: The Project agrees with the finding. The project managers were reminded to obtain documentation to verify disability/handicapped status.

About Special Tests and Provisions →
2023-007
Special Tests & Provisions
QUESTIONED COSTSOTHER MATTERS

The Project's replacement reserve cash balance was underfunded at December 31, 2023. Criteria: The Project should have made the required monthly deposits. Effect: The replacement reserve cash balance was $488 less than it should be at December 31, 2023. Context: All activity in the replacement reserve account for the year ended December 31, 2023 was tested. No sample was selected. Questioned Costs - $488; Cause: The Project neglected to make one of the required monthly deposits. Recommendation: The Project should deposit the correct amount monthly to the reserve. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Management will be reminded to deposit the correct amount monthly to the reserve. The Project will also deposit $488 into the reserve as soon as possible. Questioned Costs - Department of Housing and Urban Development - $488; Non-compliance code - N

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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT - For the OTR - Arboretum West Apartments Facility - FINDING 2023-007: SECTION 223(f), ASSISTANCE LISTING NUMBER 14.155; Condition: The Project's replacement reserve cash balance was underfunded at December 31, 2023. Criteria: The Project should have made the required monthly deposits. Effect: The replacement reserve cash balance was $488 less than it should be at December 31, 2023. Context: All activity in the replacement reserve account for the year ended December 31, 2023 was tested. No sample was selected. Questioned Costs - $488; Cause: The Project neglected to make one of the required monthly deposits. Recommendation: The Project should deposit the correct amount monthly to the reserve. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Management will be reminded to deposit the correct amount monthly to the reserve. The Project will also deposit $488 into the reserve as soon as possible. Questioned Costs - Department of Housing and Urban Development - $488; Non-compliance code - N

Corrective Action Plan

For the OTR - Arboretum West Apartments Facility - FINDING 2023-007: SECTION 223(f), ASSISTANCE LISTING NUMBER 14.155 - REPLACEMENT RESERVE BALANCE UNDERFUNDED - Recommendation: The Project should deposit the correct amount monthly to the reserve. Action Taken: The Project agrees with the finding. Management will be reminded to deposit the correct amount monthly to the reserve. The Project deposited $488 into the reserve account in January 2024.

About Special Tests and Provisions →

FY 2022-12-31

$17,729,718 federal awards expended

FAC accepted this audit on September 24, 2023 — management decision was due March 24, 2024.

2022-001
Special Tests & Provisions
QUESTIONED COSTSOTHER MATTERS

The Project did not deposit surplus cash at December 31, 2021 into a residual receipts account. The amount that should have been deposited was $14,079. Criteria: The Project should have deposited surplus cash at December 31, 2021 into a residual receipts account. Effect: The residual receipts account balance was $14,079 less than it should be at December 31, 2022. Context: Activity in the residual receipts account for the year ended December 31, 2022 was tested. No sample was tested. Questioned Costs $14,079 Cause: The Project did not make the necessary deposit of surplus cash into a residual receipts account. Recommendation: The Project should deposit surplus cash as of December 31, 2021 into a residual receipt account as soon as possible. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Management will deposit $14,079 into a residual receipts account as soon as possible. Total - Department of Housing and Urban Development $14,079 Non-compliance code - B

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Over the Rainbow Association and Subsidiaries SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) YEAR ENDED DECEMBER 31, 2022 C. Findings and Questioned Costs - Major Federal Award Programs Audit Questioned Costs DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Hill Housing Facility FINDING 2022-001: SECTION 8, ASSISTANCE LISITNG NUMBER 14.195 Condition: The Project did not deposit surplus cash at December 31, 2021 into a residual receipts account. The amount that should have been deposited was $14,079. Criteria: The Project should have deposited surplus cash at December 31, 2021 into a residual receipts account. Effect: The residual receipts account balance was $14,079 less than it should be at December 31, 2022. Context: Activity in the residual receipts account for the year ended December 31, 2022 was tested. No sample was tested. Questioned Costs $14,079 Cause: The Project did not make the necessary deposit of surplus cash into a residual receipts account. Recommendation: The Project should deposit surplus cash as of December 31, 2021 into a residual receipt account as soon as possible. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Management will deposit $14,079 into a residual receipts account as soon as possible. Total - Department of Housing and Urban Development $14,079 Non-compliance code - B

Corrective Action Plan

Over the Rainbow Association and Subsidiaries CORRECTIVE ACTION PLANS YEAR ENDED DECEMBER 31, 2022 Over the Rainbow Association and Subsidiaries respectfully submits the following corrective action plans for the year ended December 31, 2022. Name and address of independent public accounting firm: Hinrichs & Associates, Ltd. 1000 Shelard Parkway, Suite 110 Minneapolis, MN 55426 Audit period: December 31, 2022 The findings from the December 31, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section A of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS - FINANCIAL STATEMENT AUDIT NONE FINDINGS - FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Hill Housing Facility FINDING 2022-001: SECTION 8, ASSISTANCE LISTING NUMBER 14.195 SURPLUS CASH NOT DEPOSITED INTO RESIDUAL RECEIPT ACCOUNT Recommendation: The Project should deposit surplus cash as of December 31, 2021 into a residual receipts account as soon as possible. Action Taken: The Project agrees with the finding. Management will deposit $14,079 into a residual receipts account as soon as possible.

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2022-002
Special Tests & Provisions
QUESTIONED COSTSOTHER MATTERS

The Project repaid a portion of the sponsor loan payable (Due to Related Party) without obtaining HUD approval. The total amount of the unauthorized sponsor loan payment was $130,019. Criteria: HUD approval should be obtained prior to making a sponsor loan repayment. Effect: The Project's cash balance is $130,019 less than it should be. Context: The Sponsor loan payable at December 31, 2022 was tested. The test determined that a portion of the sponsor loan was repaid without obtaining HUD approval. Questioned Costs $130,019 Cause: The Project repaid a portion of the sponsor loan without obtaining HUD approval. Recommendation: The Sponsor should work with HUD to determine if the $130,019 needs to be paid back to the Project. Views of Responsible Officials and Planned Corrective Actions: The Sponsor will work with HUD to detemine if the $130,019 needs to be paid back to the Project. Total - Department of Housing and Urban Development $130,019 Non-compliance code - R

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Over the Rainbow Association and Subsidiaries SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) YEAR ENDED DECEMBER 31, 2022 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Hill Housing Facility Questioned Costs FINDING 2022-002: SECTION 8, ASSISTANCE LISITNG NUMBER 14.195 Condition: The Project repaid a portion of the sponsor loan payable (Due to Related Party) without obtaining HUD approval. The total amount of the unauthorized sponsor loan payment was $130,019. Criteria: HUD approval should be obtained prior to making a sponsor loan repayment. Effect: The Project's cash balance is $130,019 less than it should be. Context: The Sponsor loan payable at December 31, 2022 was tested. The test determined that a portion of the sponsor loan was repaid without obtaining HUD approval. Questioned Costs $130,019 Cause: The Project repaid a portion of the sponsor loan without obtaining HUD approval. Recommendation: The Sponsor should work with HUD to determine if the $130,019 needs to be paid back to the Project. Views of Responsible Officials and Planned Corrective Actions: The Sponsor will work with HUD to detemine if the $130,019 needs to be paid back to the Project. Total - Department of Housing and Urban Development $130,019 Non-compliance code - R

Corrective Action Plan

Over the Rainbow Association and Subsidiaries CORRECTIVE ACTION PLANS (CONTINUED) YEAR ENDED DECEMBER 31, 2022 FINDING 2022-002: SECTION 8, ASSISTANCE LISTING NUMBER 14.195 SPONSOR LOAN PAYMENT WITHOUT HUD APPROVAL Recommendation: The Sponsor should work with HUD to determine if the $130,019 needs to be paid back to the Project. Action Taken: The Sponsor will work with HUD to determine if the $130,019 needs to be paid back to the Project.

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2022-003
Special Tests & Provisions
QUESTIONED COSTSOTHER MATTERS

The Project took a HUD subsidy loan from replacement reserves of $15,000 and failed to repay the loan based upon the terms of the agreement with HUD. Criteria: The Project should have repaid the required amount to replacement reserves. Effect: The replacement reserve balance was underfunded by $15,000 at December 31, 2022. Context: All elements of the replacement reserve account were tested at December 31, 2022. No sample was selected. Questioned Costs $15,000 Cause: The Project neglected to repay the HUD subsidy loan based upon the terms of the agreement. Recommendation: The Project should repay the HUD subsidy loan as soon as funds are available. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. A $15,000 transfer will be made once funds are available. Management will be reminded to carefully review HUD correspondence to make sure HUD subsidy loan terms are being followed. Total - Department of Housing and Urban Development $15,000 Non-compliance code - N

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Over the Rainbow Association and Subsidiaries SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) YEAR ENDED DECEMBER 31, 2022 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Rockford Supportive Housing Facility Questioned Costs FINDING 2022-003: SECTION 811, ASSISTANCE LISITNG NUMBER 14.181 Condition: The Project took a HUD subsidy loan from replacement reserves of $15,000 and failed to repay the loan based upon the terms of the agreement with HUD. Criteria: The Project should have repaid the required amount to replacement reserves. Effect: The replacement reserve balance was underfunded by $15,000 at December 31, 2022. Context: All elements of the replacement reserve account were tested at December 31, 2022. No sample was selected. Questioned Costs $15,000 Cause: The Project neglected to repay the HUD subsidy loan based upon the terms of the agreement. Recommendation: The Project should repay the HUD subsidy loan as soon as funds are available. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. A $15,000 transfer will be made once funds are available. Management will be reminded to carefully review HUD correspondence to make sure HUD subsidy loan terms are being followed. Total - Department of Housing and Urban Development $15,000 Non-compliance code - N

Corrective Action Plan

For the Rockford Supportive Housing Facility FINDING 2022-003: SECTION 811, ASSISTANCE LISTING NUMBER 14.181 HUD SUBSIDY LOAN FROM REPLACEMENT RESERVES NOT REPAID Recommendation: The Project should repay the HUD subsidy loan as soon as funds are available. Action Taken: The Project agrees with the finding. A $15,000 transfer will be made once funds are available. Management will be reminded to carefully review HUD correspondence to make sure HUD subsidy loan terms are being followed. If the Department of Housing and Urban Development has questions regarding this plan, please call Les Russo at 847-424-5601.

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FY 2021-12-31

$17,728,039 federal awards expended

FAC accepted this audit on September 26, 2022 — management decision was due March 26, 2023.

2021-001
Special Tests & Provisions
QUESTIONED COSTSOTHER MATTERS

The Project made withdrawals from the replacement reserve account twice for the same invoice. The amount improperly withdrawn was $14,945. Criteria: The Project should not withdraw funds twice for the same invoice. Effect: The replacement reserve account balance is $14,945 less than it should be. Context: Activity in the replacement reserve account for the year ended December 31, 2021 was tested. No sample was tested. Questioned Costs $14,945 Cause: The Project made a mistake and withdrew funds from the replacement reserve account twice for the same invoice. Recommendation: The Project should repay the amount improperly withdrawn from the replacement reserve account. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Management will deposit $14,945 into the replacement reserve account in August 2022. Total - Department of Housing and Urban Development $14,945 Non-compliance code - A

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Over the Rainbow Association and Subsidiaries SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) YEAR ENDED DECEMBER 31, 2021 C. Findings and Questioned Costs - Major Federal Award Programs Audit Questioned Costs DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Hill Housing Facility FINDING 2021-001: SECTION 8, CFDA 14.195 Condition: The Project made withdrawals from the replacement reserve account twice for the same invoice. The amount improperly withdrawn was $14,945. Criteria: The Project should not withdraw funds twice for the same invoice. Effect: The replacement reserve account balance is $14,945 less than it should be. Context: Activity in the replacement reserve account for the year ended December 31, 2021 was tested. No sample was tested. Questioned Costs $14,945 Cause: The Project made a mistake and withdrew funds from the replacement reserve account twice for the same invoice. Recommendation: The Project should repay the amount improperly withdrawn from the replacement reserve account. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Management will deposit $14,945 into the replacement reserve account in August 2022. Total - Department of Housing and Urban Development $14,945 Non-compliance code - A

Corrective Action Plan

Over the Rainbow Association and Subsidiaries CORRECTIVE ACTION PLANS YEAR ENDED DECEMBER 31, 2021 Over the Rainbow Association and Subsidiaries respectfully submits the following corrective action plans for the year ended December 31, 2021. Name and address of independent public accounting firm: Hinrichs & Associates, Ltd. 1000 Shelard Parkway, Suite 110 Minneapolis, MN 55426 Audit period: December 31, 2021 The findings from the December 31, 2021 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section A of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS - FINANCIAL STATEMENT AUDIT NONE FINDINGS - FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Hill Housing Facility FINDING 2021-001: SECTION 8, CFDA 14.195 IMPROPER WITHDRAWAL FROM REPLACEMENT RESERVE ACCOUNT Recommendation: The Project should repay the amount improperly withdrawn from the replacement reserve account. Action Taken: The Project agrees with the finding. Management will deposit $14,945 into the replacement reserve account as funds become available.

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2021-002
Special Tests & Provisions
QUESTIONED COSTSOTHER MATTERS

The Project repaid a portion of the sponsor loan without obtaining HUD approval. The amount of the unauthorized sponsor loan payment was $49,496. Criteria: HUD approval should be obtained prior to making a sponsor loan repayment. Effect: The Project's cash balance is $49,496 less than it should be. Context: The sponsor loan payable at December 31, 2021 was tested. The test determined that a portion of the sponsor loan was repaid without obtaining HUD approval. Questioned Costs $49,496 Cause: The Project repaid a portion of the sponsor loan without obtaining HUD approval. Recommendation: The Sponsor should work with HUD to determine if the $49,496 needs to be paid back to the Project. Views of Responsible Officials and Planned Corrective Actions: The Sponsor will work with HUD to determine if the $49,496 needs to be paid back to the Sponsor. Total - Department of Housing and Urban Development $49,496 Non-compliance code - R

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Over the Rainbow Association and Subsidiaries SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) YEAR ENDED DECEMBER 31, 2021 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Hill Housing Facility Questioned Costs FINDING 2021-002: SECTION 8, CFDA 14.195 Condition: The Project repaid a portion of the sponsor loan without obtaining HUD approval. The amount of the unauthorized sponsor loan payment was $49,496. Criteria: HUD approval should be obtained prior to making a sponsor loan repayment. Effect: The Project's cash balance is $49,496 less than it should be. Context: The sponsor loan payable at December 31, 2021 was tested. The test determined that a portion of the sponsor loan was repaid without obtaining HUD approval. Questioned Costs $49,496 Cause: The Project repaid a portion of the sponsor loan without obtaining HUD approval. Recommendation: The Sponsor should work with HUD to determine if the $49,496 needs to be paid back to the Project. Views of Responsible Officials and Planned Corrective Actions: The Sponsor will work with HUD to determine if the $49,496 needs to be paid back to the Sponsor. Total - Department of Housing and Urban Development $49,496 Non-compliance code - R

Corrective Action Plan

Over the Rainbow Association and Subsidiaries CORRECTIVE ACTION PLANS (CONTINUED) YEAR ENDED DECEMBER 31, 2021 FINDING 2021-002: SECTION 8, CFDA 14.195 SPONSOR LOAN PAYMENT WITHOUT HUD APPROVAL Recommendation: The Sponsor should work with HUD to determine if the $49,496 needs to be paid back to the Project. Action Taken: The Project agrees with the finding. The Sponsor will work with HUD to determine if the $49,496 needs to be paid back to the Sponsor.

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2021-003
Special Tests & Provisions
OTHER MATTERS

One of the tenant files tested did not contain a copy of the signed lease. Criteria: The tenant file should contain a copy of the signed lease. Effect: There is no financial effect. Context: A sample of tenant files were selected to ensure that proper move-in documentation was included. The test found one file that didn't include a copy of the signed lease. The non compliance did not have a financial effect. The details and results of the sample are as follows: Number Dollars Population 30 N/A Sample 3 N/A Not in Compliance 1 N/A Questioned Costs None Cause: A copy of the signed lease was not included in the tenant's file. Recommendation: Project personnel should be reminded that a copy of the signed lease should be included in the tenant's file. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Management obtained a copy of the signed lease after fieldwork was complete and included it in the tenant's file. Total-Department of Housing and Urban Development $- Non-compliance code: R

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Over the Rainbow Association and Subsidiaries SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) YEAR ENDED DECEMBER 31, 2021 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Matteson Supportive Housing Facility Questioned Costs FINDING 2021-003: SECTION 811, CFDA 14.181 Condition: One of the tenant files tested did not contain a copy of the signed lease. Criteria: The tenant file should contain a copy of the signed lease. Effect: There is no financial effect. Context: A sample of tenant files were selected to ensure that proper move-in documentation was included. The test found one file that didn't include a copy of the signed lease. The non compliance did not have a financial effect. The details and results of the sample are as follows: Number Dollars Population 30 N/A Sample 3 N/A Not in Compliance 1 N/A Questioned Costs None Cause: A copy of the signed lease was not included in the tenant's file. Recommendation: Project personnel should be reminded that a copy of the signed lease should be included in the tenant's file. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Management obtained a copy of the signed lease after fieldwork was complete and included it in the tenant's file. Total-Department of Housing and Urban Development $- Non-compliance code: R

Corrective Action Plan

Over the Rainbow Association and Subsidiaries CORRECTIVE ACTION PLANS (CONTINUED) YEAR ENDED DECEMBER 31, 2021 FINDING 2021-003: SECTION 811, CFDA 14.181 TENANT FILE MISSING COPY OF SIGNED LEASE Recommendation: Project personnel should be reminded that a copy of the signed lease should be included in the tenant's file. Action Taken: The Project agrees with the finding. Management obtained a copy of the singed lease in March, 2022 and included it in the tenant's file. If the department of Housing and Urban Development has questions regarding these plans, please call Les Russo at 847-209-3909.

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FY 2020-12-31

$17,819,109 federal awards expended

FAC accepted this audit on October 18, 2021 — management decision was due April 18, 2022.

2020-001
Special Tests & Provisions
OTHER MATTERS

One of the tenant files tested was missing the certification of handicap status. Criteria: A certification of handicap status should be obtained for all tenants living in the Project. Effect: There is no financial effect. Context: The tenant file was reviewed for compliance with the occupancy rules. It was determined that the file did not contain a certification of handicap status. The details and results of the sample are as follows: Number Dollars Population 8 N/A Sample 1 N/A Not in Compliance 1 N/A Questioned Costs $- Cause: The Project failed to obtain a certification of handicap status from the tenant's health care provider. Recommendation: The Project should obtain a certification of handicap status for this tenant from their health care provider. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. They will obtain a certification of handicap status from the tenant's health care provider. Total - Department of Housing and Urban Development $- Non-compliance code - R

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Over the Rainbow Association and Subsidiaries SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) YEAR ENDED DECEMBER 31, 2020 Questioned C. Findings and Questioned Costs - Major Federal Award Programs Audit Costs DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Belden Housing Facility FINDING 2020-001: SECTION 8, CFDA 14.195 Condition: One of the tenant files tested was missing the certification of handicap status. Criteria: A certification of handicap status should be obtained for all tenants living in the Project. Effect: There is no financial effect. Context: The tenant file was reviewed for compliance with the occupancy rules. It was determined that the file did not contain a certification of handicap status. The details and results of the sample are as follows: Number Dollars Population 8 N/A Sample 1 N/A Not in Compliance 1 N/A Questioned Costs $- Cause: The Project failed to obtain a certification of handicap status from the tenant's health care provider. Recommendation: The Project should obtain a certification of handicap status for this tenant from their health care provider. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. They will obtain a certification of handicap status from the tenant's health care provider. Total - Department of Housing and Urban Development $- Non-compliance code - R

Corrective Action Plan

Over the Rainbow Association and Subsidiaries CORRECTIVE ACTION PLANS YEAR ENDED DECEMBER 31, 2020 Over the Rainbow Association and Subsidiaries respectfully submits the following corrective action plans for the year ended December 31, 2020. Name and address of independent public accounting firm: Hinrichs & Associates, Ltd. 1000 Shelard Parkway, Suite 110 Minneapolis, MN 55426 Audit period: December 31, 2020 The findings from the December 31, 2020 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section A of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS - FINANCIAL STATEMENT AUDIT NONE FINDINGS - FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Belden Housing Facility FINDING 2020-001: SECTION 8, CFDA 14.195 TENANT FILE MISSING CERTIFICATION OF HANDICAP STATUS Recommendation: The Project should obtain a certification of handicap status for this tenant from their health care provider. Action Taken: The Project agrees with the finding. Management obtained the certification of handicap status in March 2021.

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2020-002
Special Tests & Provisions
OTHER MATTERS

One of the tenant files tested was missing the tenant's certification of handicap status. Criteria: A certification of handicap status should be obtained for all tenants living in the Project. Effect: There is no financial effect. Context: The tenant file was reviewed for compliance with the occupancy rules. It was determined that the file did not contain a certification of handicap status. The details and results of the sample are as follows: Number Dollars Population 33 N/A Sample 4 N/A Not in Compliance 1 N/A Questioned Costs $- Cause: The Project failed to obtain a certification of handicap status from the tenant's health care provider. Recommendation: The Project should obtain a certification of handicap status for this tenant from their health care provider. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. They will obtain a certification of handicap status from the tenant's health care provider. Total - Department of Housing and Urban Development $- Non-compliance code - R

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Over the Rainbow Association and Subsidiaries SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) YEAR ENDED DECEMBER 31, 2020 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Hill Housing Facility Questioned Costs FINDING 2020-002: SECTION 8, CFDA 14.195 Condition: One of the tenant files tested was missing the tenant's certification of handicap status. Criteria: A certification of handicap status should be obtained for all tenants living in the Project. Effect: There is no financial effect. Context: The tenant file was reviewed for compliance with the occupancy rules. It was determined that the file did not contain a certification of handicap status. The details and results of the sample are as follows: Number Dollars Population 33 N/A Sample 4 N/A Not in Compliance 1 N/A Questioned Costs $- Cause: The Project failed to obtain a certification of handicap status from the tenant's health care provider. Recommendation: The Project should obtain a certification of handicap status for this tenant from their health care provider. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. They will obtain a certification of handicap status from the tenant's health care provider. Total - Department of Housing and Urban Development $- Non-compliance code - R

Corrective Action Plan

Over the Rainbow Association and Subsidiaries CORRECTIVE ACTION PLANS (CONTINUED) YEAR ENDED DECEMBER 31, 2020 For the Hill Housing Facility FINDING 2020-002: SECTION 8, CFDA 14.195 TENANT FILE MISSING CERTIFICATION OF HANDICAP STATUS Recommendation: The Project should obtain a certification of handicap status for this tenant from their health care provider. Action Taken: The Project agrees with the finding. Management obtained the certification of handicap status in March 2021.

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2020-003
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

During 2020, the Project transferred $50,581 to the Project's Sponsor without HUD approval. Criteria: The Sponsor should not withdraw funds from the Project without HUD approval. Effect: The Project's cash balance at December 31, 2020 was $50,581 less than it should be. Context: 100% of the accounts receivable - sponsor account was tested at December 31, 2020. Questioned Costs $50,581 Cause: Management failed to recognize that they should not take money out of the Project without HUD approval. Recommendation: The Project should work with HUD to determine if the money needs to be paid back to the Project. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Management will work with HUD to determine if the money needs to be paid back to the Project. Questioned Costs - Department of Housing and Urban Development $50,581 Non-compliance code - G

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Over the Rainbow Association and Subsidiaries SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) YEAR ENDED DECEMBER 31, 2020 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Arboretum West Apartment Facility Questioned Costs FINDING 2020-003: SECTION 223(f), CFDA 14.155 Condition: During 2020, the Project transferred $50,581 to the Project's Sponsor without HUD approval. Criteria: The Sponsor should not withdraw funds from the Project without HUD approval. Effect: The Project's cash balance at December 31, 2020 was $50,581 less than it should be. Context: 100% of the accounts receivable - sponsor account was tested at December 31, 2020. Questioned Costs $50,581 Cause: Management failed to recognize that they should not take money out of the Project without HUD approval. Recommendation: The Project should work with HUD to determine if the money needs to be paid back to the Project. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Management will work with HUD to determine if the money needs to be paid back to the Project. Questioned Costs - Department of Housing and Urban Development $50,581 Non-compliance code - G

Corrective Action Plan

For the Arboretum West Apartment Facility FINDING 2020-003: SECTION 223(f), CFDA 14.155 PROJECT TRANSFERRED FUNDS WITHOUT HUD APPROVAL Recommendation: The Project should work with HUD to determine if the money needs to be paid back to the Project. Action Taken: Management will work with HUD to determine if the money needs to be paid back to the Project.

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2020-004
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

During 2020, the Project did not make all of the required monthly mortgage payments ($64,279) and the related replacement reserve deposits ($5,600). Criteria: The Project should make all of the required monthly mortgage payments and related deposits to the replacement reserve account. Effect: The Project is delinquent on the HUD mortgage and the replacement reserve account balance is $5,600 less than it should be. Context: 100% of the debt accounts and replacement reserve account was tested at December 31, 2020. Questioned Costs $69,879 Cause: The Project was not communicating with the mortgage servicer to determine the monthly debt and replacement reserve requirements. Recommendation: The Project should work with HUD to determine the process for satisfaction of monthly mortgage and replacement reserve payments that were missed. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Management will work with HUD to correct the mortgage status and replacement reserve condition. Questioned Costs - Department of Housing and Urban Development $69,879 Non-compliance code - Q

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Over the Rainbow Association and Subsidiaries SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) YEAR ENDED DECEMBER 31, 2020 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Arboretum West Apartment Facility Questioned Costs FINDING 2020-004: SECTION 223(f), CFDA 14.155 Condition: During 2020, the Project did not make all of the required monthly mortgage payments ($64,279) and the related replacement reserve deposits ($5,600). Criteria: The Project should make all of the required monthly mortgage payments and related deposits to the replacement reserve account. Effect: The Project is delinquent on the HUD mortgage and the replacement reserve account balance is $5,600 less than it should be. Context: 100% of the debt accounts and replacement reserve account was tested at December 31, 2020. Questioned Costs $69,879 Cause: The Project was not communicating with the mortgage servicer to determine the monthly debt and replacement reserve requirements. Recommendation: The Project should work with HUD to determine the process for satisfaction of monthly mortgage and replacement reserve payments that were missed. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Management will work with HUD to correct the mortgage status and replacement reserve condition. Questioned Costs - Department of Housing and Urban Development $69,879 Non-compliance code - Q

Corrective Action Plan

For the Arboretum West Apartment Facility FINDING 2020-004: SECTION 223(f), CFDA 14.155 MISSING MORTGAGE PAYMENTS AND REPLACEMENT RESERVE DEPOSITS Recommendation: The Project should work with HUD to determine the process for satisfaction of monthly mortgage and replacement reserve payments that were missed. Action Taken: Management will work with HUD to correct the mortgage status. The replacement reserve account condition was corrected in March 2021.

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FY 2019-12-31

$17,829,367 federal awards expended

FAC accepted this audit on September 27, 2020 — management decision was due March 27, 2021.

2019-001
Special Tests & Provisions
OTHER MATTERS

The Project's replacement reserve account was underfunded at December 31, 2019. Criteria: The Project failed to increase the monthly deposit amount to the replacement reserve account in August 2019, as required by HUD. Effect: The replacement reserve cash balance was $61 less than it should be at December 31, 2019. Context: Activity in the replacement reserve account for the year ended December 31, 2019 was tested. No sample was tested. Questioned costs $61 Cause: The Project forgot to increase the monthly deposit amount to the replacement reserve account in August 2019, as required by HUD. Recommendation: The Project should deposit $61 into the replacement reserve account. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Management will deposit $61 to the replacement reserve account as soon as possible. Total - Department of Housing and Urban Development Non-compliance code - A

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Over the Rainbow Association and Subsidiaries SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) YEAR ENDED DECEMBER 31, 2019 C. Findings and Questioned Costs - Major Federal Award Programs Audit DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Belden Housing Facility FINDING 2019-001: SECTION 8, CFDA 14.195 Condition: The Project's replacement reserve account was underfunded at December 31, 2019. Criteria: The Project failed to increase the monthly deposit amount to the replacement reserve account in August 2019, as required by HUD. Effect: The replacement reserve cash balance was $61 less than it should be at December 31, 2019. Context: Activity in the replacement reserve account for the year ended December 31, 2019 was tested. No sample was tested. Questioned costs $61 Cause: The Project forgot to increase the monthly deposit amount to the replacement reserve account in August 2019, as required by HUD. Recommendation: The Project should deposit $61 into the replacement reserve account. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Management will deposit $61 to the replacement reserve account as soon as possible. Total - Department of Housing and Urban Development Non-compliance code - A

Corrective Action Plan

Over the Rainbow Association and Subsidiaries CORRECTIVE ACTION PLANS YEAR ENDED DECEMBER 31, 2019 Over the Rainbow Association and Subsidiaries respectfully submits the following corrective action plans for the year ended December 31, 2019. Name and address of independent public accounting firm: Hinrichs & Associates, Ltd. 1000 Shelard Parkway, Suite 110 Minneapolis, MN 55426 Audit period: December 31, 2019 The findings from the December 31, 2019 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section A of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS - FINANCIAL STATEMENT AUDIT NONE FINDINGS - FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Belden Housing Facility FINDING 2019-001: SECTION 8, CFDA 14.195 REPLACEMENT RESERVE ACCOUNT UNDERFUNDED Recommendation: The Project should deposit $61 into the replacement reserve account. Action Taken: The Project agrees with the finding. Management transferred $61 to the replacement reserve account on February 19, 2020.

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2019-002
Special Tests & Provisions
OTHER MATTERS

One of the tenant files tested was missing the tenant's certification of handicapped status. Criteria: A certification of handicap status should be obtained for all tenants living in the Project. Effect: There is no financial effect. Context: The tenant file was reviewed for compliance with the occupancy rules. It was determined that the file did not contain a certification of handicap status. The details and results of the sample are as follows: Number Dollars Population 33 N/A Sample 4 N/A Not in Compliance 1 N/A Questioned Costs none Cause: The Project failed to obtain a certification of handicap status from the tenant's health care provider. Recommendation: The Project should obtain a certification of handicap status for this tenant from their health care provider. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. They will obtain a certification of handicap status from the tenant's health care provider. Total - Department of Housing and Urban Development $- Non-compliance code - R

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Over the Rainbow Association and Subsidiaries SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) YEAR ENDED DECEMBER 31, 2019 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Hill Housing Facility FINDING 2019-002: SECTION 8, CFDA 14.195 Condition: One of the tenant files tested was missing the tenant's certification of handicapped status. Criteria: A certification of handicap status should be obtained for all tenants living in the Project. Effect: There is no financial effect. Context: The tenant file was reviewed for compliance with the occupancy rules. It was determined that the file did not contain a certification of handicap status. The details and results of the sample are as follows: Number Dollars Population 33 N/A Sample 4 N/A Not in Compliance 1 N/A Questioned Costs none Cause: The Project failed to obtain a certification of handicap status from the tenant's health care provider. Recommendation: The Project should obtain a certification of handicap status for this tenant from their health care provider. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. They will obtain a certification of handicap status from the tenant's health care provider. Total - Department of Housing and Urban Development $- Non-compliance code - R

Corrective Action Plan

FINDINGS - FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Hill Housing Facility FINDING 2019-002: SECTION 8, CFDA 14.195 TENANT FILE MISSING CERTIFICATION OF HANDICAPPED STATUS Recommendation: The Project should obtain a certification of handicap status for this tenant from their health care provider. Action Taken: The Project agrees with the finding. Management obtained the certification of handicap status on February 20, 2020.

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2019-003
Cost Allowability
QUESTIONED COSTSOTHER MATTERS

In 1 of 15 cash disbursements tested, the Project paid the expense of another project under common management. Criteria: The Project should not pay the expenses of another project. Effect: The amount of expenses incorrectly paid was $166 out of a total sample of disbursements of $10,036. Context: A sample of disbursements was selected for testing of compliance. The test found one disbursement that was not in compliance. The non-compliance had a financial effect outlined below. The details and results of the sample are as follows: Number Dollars Population 147 $220,677 Sample 15 $10,036 Not in Compliance 1 $166 Questioned Costs $166 Cause: The Project mistakenly paid part of an invoice of another project under common management. Recommendation: The Project should carefully review invoices before payment to make sure it only pays the proper amount. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. The accounts payable staff will be reminded to be careful when entering invoices for payment. Total - Department of Housing and Urban Development $166 Non-compliance code - R

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Over the Rainbow Association and Subsidiaries SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) YEAR ENDED DECEMBER 31, 2019 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For Matteson Supportive Housing Facility FINDING 2019-003: SECTION 811, CFDA 14.181 Condition: In 1 of 15 cash disbursements tested, the Project paid the expense of another project under common management. Criteria: The Project should not pay the expenses of another project. Effect: The amount of expenses incorrectly paid was $166 out of a total sample of disbursements of $10,036. Context: A sample of disbursements was selected for testing of compliance. The test found one disbursement that was not in compliance. The non-compliance had a financial effect outlined below. The details and results of the sample are as follows: Number Dollars Population 147 $220,677 Sample 15 $10,036 Not in Compliance 1 $166 Questioned Costs $166 Cause: The Project mistakenly paid part of an invoice of another project under common management. Recommendation: The Project should carefully review invoices before payment to make sure it only pays the proper amount. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. The accounts payable staff will be reminded to be careful when entering invoices for payment. Total - Department of Housing and Urban Development $166 Non-compliance code - R

Corrective Action Plan

FINDINGS - FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Matteson Supportive Housing Facility FINDING 2019-003: SECTION 811, CFDA 14.181 PROJECT PAID THE EXPENSE OF ANOTHER PROJECT UNDER COMMON MANAGEMENT Recommendation: The Project should carefully review invoices before payment to make sure it only pays the proper amount. Action Taken: The Project agrees with the finding. The accounts payable staff will be reminded to be careful when entering invoices for payment. The finding was corrected by management on February 20, 2020.

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2019-004
Special Tests & Provisions
OTHER MATTERS

For three of the tenant files tested, the Project was late with the tenant recertification. Criteria: The Project should recertify tenants on a timely basis. Effect: There is no financial effect on rent subsidies. Subsidy rent is adjusted in subsequent months to reflect the correct HUD subsidy. Context: A sample of tenant files was selected for testing tenant recertification. The test located three recertifications that were not in compliance. The non-compliance did not have a financial effect. The details and results of the sample are as follows: Number Dollars Population 25 N/A Sample 3 N/A Not in Compliance 3 N/A Questioned Costs none Cause: Project personnel was busy responding to issues related to a water damage and was not able to complete recertifications in a timely manner. Recommendation: Project personnel should be reminded that timely recertification is an important step in tenant management. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Recertification staff will be reminded to be aware of deadlines to ensure recertifications are completed in a timely manner. Total - Department of Housing and Urban Development $- Non-compliance code - R

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Over the Rainbow Association and Subsidiaries SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) YEAR ENDED DECEMBER 31, 2019 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For Matteson Supportive Housing Facility FINDING 2019-004: SECTION 811, CFDA 14.181 Condition: For three of the tenant files tested, the Project was late with the tenant recertification. Criteria: The Project should recertify tenants on a timely basis. Effect: There is no financial effect on rent subsidies. Subsidy rent is adjusted in subsequent months to reflect the correct HUD subsidy. Context: A sample of tenant files was selected for testing tenant recertification. The test located three recertifications that were not in compliance. The non-compliance did not have a financial effect. The details and results of the sample are as follows: Number Dollars Population 25 N/A Sample 3 N/A Not in Compliance 3 N/A Questioned Costs none Cause: Project personnel was busy responding to issues related to a water damage and was not able to complete recertifications in a timely manner. Recommendation: Project personnel should be reminded that timely recertification is an important step in tenant management. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Recertification staff will be reminded to be aware of deadlines to ensure recertifications are completed in a timely manner. Total - Department of Housing and Urban Development $- Non-compliance code - R

Corrective Action Plan

FINDINGS - FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Matteson Supportive Housing Facility FINDING 2019-004: SECTION 811, CFDA 14.181 TENANT RECERTIFICATIONS COMPLETED LATE Recommendation: Project personnel should be reminded that timely recertification is an important step in tenant management. Action Taken: The Project agrees with the finding. Recertification staff have been reminded to be aware of deadlines and perform recertification procedures in a timely manner. The recertifications were completed by June 15, 2020.

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2019-005
Special Tests & Provisions
OTHER MATTERS

The Project's security deposit liability account was underfunded at December 31, 2019. Criteria: The Project should have a security deposit cash balance in excess of the security deposit liability balance. Effect: The security deposit account was underfunded by $666. Context: The security deposit account was tested at December 31, 2019. No sample was tested. Questioned Costs none Cause: Management failed to recognize that the security deposit liability account was underfunded at December 31, 2019. Recommendation: The Project should carefully review the statement of financial position to make sure the security deposit liability account is funded. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Management will be reminded to review the tenant security deposit cash balance versus the security deposit liabilty balance on a monthly basis. Total - Department of Housing and Urban Development $- Non-compliance code - M

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Over the Rainbow Association and Subsidiaries SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) YEAR ENDED DECEMBER 31, 2019 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For Waukegan Supportive Housing Facility FINDING 2019-005: SECTION 811, CFDA 14.181 Condition: The Project's security deposit liability account was underfunded at December 31, 2019. Criteria: The Project should have a security deposit cash balance in excess of the security deposit liability balance. Effect: The security deposit account was underfunded by $666. Context: The security deposit account was tested at December 31, 2019. No sample was tested. Questioned Costs none Cause: Management failed to recognize that the security deposit liability account was underfunded at December 31, 2019. Recommendation: The Project should carefully review the statement of financial position to make sure the security deposit liability account is funded. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Management will be reminded to review the tenant security deposit cash balance versus the security deposit liabilty balance on a monthly basis. Total - Department of Housing and Urban Development $- Non-compliance code - M

Corrective Action Plan

FINDINGS - FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Waukegan Supportive Housing Facility FINDING 2019-005: SECTION 811, CFDA 14.181 SECURITY DEPOSIT LIABILITY ACCOUNT UNDERFUNDED Recommendation: The Project should carefully review the statement of financial position to make sure the security deposit liability account is funded. Action Taken: The Project agrees with the finding. Management will be reminded to review the tenant security deposit cash balance versus the security deposit liability balance on a monthly basis. This finding was corrected by management on February 20, 2020.

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2019-006
Special Tests & Provisions
OTHER MATTERS

As of December 31, 2019, the Project had not set up a security deposit bank account. Criteria: The Project should have a security deposit bank account and that balance should be greater than the security deposit liability. Effect: The security deposit account was underfunded by $3,204. Context: The security deposit account was tested at December 31, 2019. No sample was tested. Questioned Costs none Cause: Mangement failed to recognize that a security deposit bank account had not been opened up by December 31, 2019. Recommendation: The Project should open a security deposit bank account and fund it immediately. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Management will open and fund a security deposit bank account as soon as possible. Questioned Costs - Department of Housing and Urban Development $- Non-compliance code - M

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Over the Rainbow Association and Subsidiaries SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) YEAR ENDED DECEMBER 31, 2019 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For Arboretum West Apartment Facility FINDING 2019-006: SECTION 223(f), CFDA 14.155 Condition: As of December 31, 2019, the Project had not set up a security deposit bank account. Criteria: The Project should have a security deposit bank account and that balance should be greater than the security deposit liability. Effect: The security deposit account was underfunded by $3,204. Context: The security deposit account was tested at December 31, 2019. No sample was tested. Questioned Costs none Cause: Mangement failed to recognize that a security deposit bank account had not been opened up by December 31, 2019. Recommendation: The Project should open a security deposit bank account and fund it immediately. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Management will open and fund a security deposit bank account as soon as possible. Questioned Costs - Department of Housing and Urban Development $- Non-compliance code - M

Corrective Action Plan

FINDINGS - FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Arboretum West Apartment Facility FINDING 2019-006: SECTION 223(f), CFDA 14.155 NO SECURITY DEPOSIT BANK ACCOUNT Recommendation: The Project should open a security deposit bank account and fund it immediately. Action Taken: The Project agrees with the finding. Management opened and funded a security deposit bank account on July 22, 2020.

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2019-007
Special Tests & Provisions
OTHER MATTERS

The Project's replacement reserve cash balance was underfunded by $55,608 at December 31, 2019. Criteria: The Project withdrew $50,008 from the replacement reserve account that was not authorized by HUD. In addition, the Project did not make it's required monthly deposits during 2019 (totaling $5,600). Effect: The replacement reserve cash balance was $55,608 less than it should be at December 31, 2019. Context: Activity in the replacement reserve account for the year ended December 31, 2019 was tested. No sample was tested. Questioned Costs $55,608 Cause: The Project withdrew funds from the replacement reserve account without HUD approval. The Project also forgot to make the required monthly deposits during 2019. Recommendation: The Project should deposit $55,608 into the replacement reserve account. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Management will deposit $55,608 to the replacement reserve account as soon as possible. Total - Department of Housing and Urban Development $55,608 Non-compliance code - A

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Over the Rainbow Association and Subsidiaries SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) YEAR ENDED DECEMBER 31, 2019 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For Arboretum West Apartment Facility FINDING 2019-007: SECTION 223(f), CFDA 14.155 Condition: The Project's replacement reserve cash balance was underfunded by $55,608 at December 31, 2019. Criteria: The Project withdrew $50,008 from the replacement reserve account that was not authorized by HUD. In addition, the Project did not make it's required monthly deposits during 2019 (totaling $5,600). Effect: The replacement reserve cash balance was $55,608 less than it should be at December 31, 2019. Context: Activity in the replacement reserve account for the year ended December 31, 2019 was tested. No sample was tested. Questioned Costs $55,608 Cause: The Project withdrew funds from the replacement reserve account without HUD approval. The Project also forgot to make the required monthly deposits during 2019. Recommendation: The Project should deposit $55,608 into the replacement reserve account. Views of Responsible Officials and Planned Corrective Actions: The Project agrees with the finding. Management will deposit $55,608 to the replacement reserve account as soon as possible. Total - Department of Housing and Urban Development $55,608 Non-compliance code - A

Corrective Action Plan

FINDINGS - FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT For the Arboretum West Apartment Facility FINDING 2019-007: SECTION 223(f), CFDA 14.155 REPLACEMENT RESERVE ACCOUNT UNDERFUNDED Recommendation: The Project should deposit $55,608 into the replacement reserve account. Action Taken: The Project agrees with the finding. As of July 31, 2020 management is currently working with HUD to resolve this finding. If the Department of Housing and Urban Development has questions regarding these plans, please call Les Russo at 847-424-5601.

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FY 2018-12-31

$12,573,118 federal awards expended

FAC accepted this audit on September 24, 2019 — management decision was due March 24, 2020.

2018-001
Special Tests & Provisions
REPEAT OF 2017-001OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

Prior Finding References

2017-001

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2018-002
Cost Allowability
REPEAT OF 2017-003QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2017-003

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FY 2017-12-31

$12,644,548 federal awards expended

FAC accepted this audit on September 23, 2018 — management decision was due March 23, 2019.

2017-001
Special Tests & Provisions
OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2017-002
Special Tests & Provisions
OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2017-003
Cost Allowability
QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2017-004
Cost Allowability
QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2017-005
Special Tests & Provisions
OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2017-006
Special Tests & Provisions
OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2017-007
Special Tests & Provisions
OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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FY 2016-12-31

$12,635,547 federal awards expended

FAC accepted this audit on September 17, 2017 — management decision was due March 17, 2018.

2016-001
Special Tests & Provisions
OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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