EIN: 510395729
UEI: LKZ4PAKV8W75
Data as of August 27, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on July 23, 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 January 23, 2026 (216 days ago).
What is a management decision? →The Senior Director of Housing & Facilities is responsible for the custody of assets and for authorizing and recording transactions, with no regular oversight occurring. While an independent contractor assists with annual closing, there is no documented review process during the rest of the year. Effect: Reliance on a single individual for critical functions, without systematic reviews, undermines the reliability of financial reporting. Errors and irregularities may go undetected, thereby increasing the risk of material misstatement and noncompliance with federal requirements. This control environment also contributed to the noncompliance described in Finding 2025-002. Cause: Staffing constraints and an informal approach to internal controls have resulted in one individual performing incompatible functions. Management oversight once documented by weekly meetings between the Senior Director of Housing & Facilities and the CEO are no longer occurring. Recommendations: Management should strongly consider reallocating routine accounting tasks, such as preparing deposits and reconciling bank statements, to different staff members. It is also advisable to reinstate documented, periodic management reviews of both financial and compliance-related data. These regularly scheduled reviews will help detect errors, strengthen accountability, and support adherence to the requirements of the Uniform Guidance. Management Comments: We concur with this finding and recognize the need for a more robust control environment. We plan to reevaluate staff responsibilities, expand the documentation of oversight procedures, and implement structured, recurring reviews of financial transactions and compliance-related data to ensure compliance with Uniform Guidance requirements.
Show full finding ▾Hide full finding ▴Criteria: Accurate financial reporting and compliance with the Uniform Guidance require a strong internal control system, including proper segregation of duties and consistent management oversight. Condition: The Senior Director of Housing & Facilities is responsible for the custody of assets and for authorizing and recording transactions, with no regular oversight occurring. While an independent contractor assists with annual closing, there is no documented review process during the rest of the year. Effect: Reliance on a single individual for critical functions, without systematic reviews, undermines the reliability of financial reporting. Errors and irregularities may go undetected, thereby increasing the risk of material misstatement and noncompliance with federal requirements. This control environment also contributed to the noncompliance described in Finding 2025-002. Cause: Staffing constraints and an informal approach to internal controls have resulted in one individual performing incompatible functions. Management oversight once documented by weekly meetings between the Senior Director of Housing & Facilities and the CEO are no longer occurring. Recommendations: Management should strongly consider reallocating routine accounting tasks, such as preparing deposits and reconciling bank statements, to different staff members. It is also advisable to reinstate documented, periodic management reviews of both financial and compliance-related data. These regularly scheduled reviews will help detect errors, strengthen accountability, and support adherence to the requirements of the Uniform Guidance. Management Comments: We concur with this finding and recognize the need for a more robust control environment. We plan to reevaluate staff responsibilities, expand the documentation of oversight procedures, and implement structured, recurring reviews of financial transactions and compliance-related data to ensure compliance with Uniform Guidance requirements.
1. Implemented Monthly Oversight Meetings: Beginning in January 2025, we instituted monthly meetings to review financial statements, budgets, forecasts, and compliance-related data. These meetings include key stakeholders and team members to ensure timely discussions of financial status, variances, and compliance matters. This structure enhances accountability and provides regular managerial oversight. 2. Hired Key Finance Staff to Support Segregation of Duties: To improve internal controls, we have hired a new Chief Finance Officer with expanded responsibilities over the accounting functions of the housing entities. We have also hired a Senior Accountant who has assumed responsibility for the day-to-day accounting tasks previously performed by the Senior Director of Housing & Facilities. These hires have significantly enhanced our ability to segregate duties. We are currently in the process of formalizing these new roles, along with related internal controls and procedures, to establish a more robust control environment.
During the year, only nine of the twelve required monthly deposits to the replacement reserve were made. As a result, the reserve was underfunded in the amount of $663. Effect: Failure to make the required deposits constitutes noncompliance with HUD requirements. Additionally, in the absence of effective internal controls to monitor and confirm compliance on an ongoing basis, similar issues may go undetected in the future. Cause: The missed deposits appear to have resulted from a lack of monitoring and formal oversight, consistent with the internal control deficiency described in Finding 2025-001. Recommendations: We recommend that management implement a monthly compliance checklist to monitor HUD requirements, including replacement reserve deposits. Responsibility for verifying and documenting compliance should be clearly assigned. Periodic supervisory reviews should be conducted, documented, and retained to ensure programmatic requirements are consistently met. Management Comments: We concur with this finding. The missed deposits were an oversight in part due to employee turnover, and we have since reimbursed the replacement reserve. Moving forward, we will adopt a monthly compliance checklist and assign staff to verify that all regulatory requirements, including reserve deposits, are completed timely and documented.
Show full finding ▾Hide full finding ▴Criteria: The Project is required to make monthly deposits to the replacement reserve in the amount specified by HUD. These deposits must be made timely and consistently to ensure funds are available for future capital needs and to remain in compliance with the Project’s regulatory agreement and other applicable HUD program requirements. Condition: During the year, only nine of the twelve required monthly deposits to the replacement reserve were made. As a result, the reserve was underfunded in the amount of $663. Effect: Failure to make the required deposits constitutes noncompliance with HUD requirements. Additionally, in the absence of effective internal controls to monitor and confirm compliance on an ongoing basis, similar issues may go undetected in the future. Cause: The missed deposits appear to have resulted from a lack of monitoring and formal oversight, consistent with the internal control deficiency described in Finding 2025-001. Recommendations: We recommend that management implement a monthly compliance checklist to monitor HUD requirements, including replacement reserve deposits. Responsibility for verifying and documenting compliance should be clearly assigned. Periodic supervisory reviews should be conducted, documented, and retained to ensure programmatic requirements are consistently met. Management Comments: We concur with this finding. The missed deposits were an oversight in part due to employee turnover, and we have since reimbursed the replacement reserve. Moving forward, we will adopt a monthly compliance checklist and assign staff to verify that all regulatory requirements, including reserve deposits, are completed timely and documented.
1. Reimbursed the Replacement Reserve Account: The missed deposits totaling $663 were reimbursed to the replacement reserve on May 30, 2025. 2. Implemented Monthly Oversight Meetings: Beginning in January 2025, we instituted monthly meetings to review financial statements, budgets, forecasts, and compliance-related data. These meetings include key stakeholders and team members to ensure timely discussions of financial status, variances, and compliance matters. This structure enhances accountability and provides regular managerial oversight.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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