EIN: 522075470
UEI: LQZEWHNXDUB3
Audited by: CohnReznick LLP
Oversight agency: 14 [Department of Housing and Urban Development]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 18, 2026. 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 August 18, 2026 (13 days ago).
What is a management decision? →Criteria Tenant lease files are required to be maintained and tenant eligibility determined in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Condition In connection with our lease file review, we noted the following deficiencies: Two out of two lease files for new tenants tested had EIV reports generated outside of the 90 day period; Three out of ten lease files for existing tenants tested had EIV reports generated outside of the 120 day period or no EIV ran; One out of ten lease files for existing tenant tested had different rent amounts on the rent roll and the 50059 form. Cause Management’s policies with respect to the maintenance of tenant leases files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs were not consistently followed. Effect or Potential Effect The procedures for eligibility and maintaining tenant lease files were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Questioned Costs N/A Identification as a Repeat Finding This is a repeat finding. Recommendations Management should establish procedures and monitor compliance with those procedures to ensure that tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Auditor Noncompliance Code: Z. Other. View of Responsible Officials Management agrees with the findings and has implemented the policies below and will continue to train and connect our team members with the in-house HUD Compliance Specialist for support. 1. Move in EIV’s – All move in files will be sent to our in-house compliance department and Franklin Group have an EIV specialist how follows and tracks all moves for accuracy for all move files and the EIV specialist also sends out the 90-day reminders for all move in. 2. Existing Tenant EIV – It is the policy that all existing tenant EIV & 120-day reports are run per the 4350 guidelines. The Community Manager for Renaissance Gardens has been provided the HUD Trainings and have noted on her daily task reminder from One Site to pull all reports as required. The Regional Manager is required during monthly visits to spot check at least 5 existing tenants. Finding Resolutions Status: Resolved
Show full finding ▾Hide full finding ▴Criteria Tenant lease files are required to be maintained and tenant eligibility determined in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Condition In connection with our lease file review, we noted the following deficiencies: Two out of two lease files for new tenants tested had EIV reports generated outside of the 90 day period; Three out of ten lease files for existing tenants tested had EIV reports generated outside of the 120 day period or no EIV ran; One out of ten lease files for existing tenant tested had different rent amounts on the rent roll and the 50059 form. Cause Management’s policies with respect to the maintenance of tenant leases files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs were not consistently followed. Effect or Potential Effect The procedures for eligibility and maintaining tenant lease files were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Questioned Costs N/A Identification as a Repeat Finding This is a repeat finding. Recommendations Management should establish procedures and monitor compliance with those procedures to ensure that tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Auditor Noncompliance Code: Z. Other. View of Responsible Officials Management agrees with the findings and has implemented the policies below and will continue to train and connect our team members with the in-house HUD Compliance Specialist for support. 1. Move in EIV’s – All move in files will be sent to our in-house compliance department and Franklin Group have an EIV specialist how follows and tracks all moves for accuracy for all move files and the EIV specialist also sends out the 90-day reminders for all move in. 2. Existing Tenant EIV – It is the policy that all existing tenant EIV & 120-day reports are run per the 4350 guidelines. The Community Manager for Renaissance Gardens has been provided the HUD Trainings and have noted on her daily task reminder from One Site to pull all reports as required. The Regional Manager is required during monthly visits to spot check at least 5 existing tenants. Finding Resolutions Status: Resolved
Management agrees with the findings and has implemented the policies below and will continue to train and connect our team members with the in-house HUD Compliance Specialist for support. 1. Move in EIV’s – All move in files will be sent to our in-house compliance department and Franklin Group have an EIV specialist how follows and tracks all moves for accuracy for all move files and the EIV specialist also sends out the 90-day reminders for all move in. 2. Existing Tenant EIV – It is the policy that all existing tenant EIV & 120-day reports are run per the 4350 guidelines. The Community Manager for Renaissance Gardens has been provided the HUD Trainings and have noted on her daily task reminder from One Site to pull all reports as required. The Regional Manager is required during monthly visits to spot check at least 5 existing tenants.
2024-001
The regulatory agreement requires that the project make monthly deposits to its replacement reserve. Condition During the year ended June 30 2025, the project did not make the required monthly deposits to the replacement reserve in the amount of $66,540. The project is required to make monthly deposits to the reserve in the amount of $5,545. Cause The project does not generate sufficient cash flow to make the required monthly deposits. Effect or Potential Effect Failure to make monthly payments resulted in an underfunding of the replacement reserve and a violation of the regulatory agreement. Questioned Costs $11,090 Identification as a Repeat Finding This is a repeat finding. Recommendations Management should review the project budget to determine if nonessential costs can be cut to ensure that the replacement reserve is funded in accordance with the terms of the regulatory agreement. Auditor Noncompliance Code: N. Reserve for replacements deposits View of Responsible Officials Management agrees with the findings and recommendations, will transfer the replacement reserve funds. Monthly deposits will be completed in accordance with HUD going forward to ensure all terms and conditions are met. Finding Resolutions Status: Unresolved
Show full finding ▾Hide full finding ▴The regulatory agreement requires that the project make monthly deposits to its replacement reserve. Condition During the year ended June 30 2025, the project did not make the required monthly deposits to the replacement reserve in the amount of $66,540. The project is required to make monthly deposits to the reserve in the amount of $5,545. Cause The project does not generate sufficient cash flow to make the required monthly deposits. Effect or Potential Effect Failure to make monthly payments resulted in an underfunding of the replacement reserve and a violation of the regulatory agreement. Questioned Costs $11,090 Identification as a Repeat Finding This is a repeat finding. Recommendations Management should review the project budget to determine if nonessential costs can be cut to ensure that the replacement reserve is funded in accordance with the terms of the regulatory agreement. Auditor Noncompliance Code: N. Reserve for replacements deposits View of Responsible Officials Management agrees with the findings and recommendations, will transfer the replacement reserve funds. Monthly deposits will be completed in accordance with HUD going forward to ensure all terms and conditions are met. Finding Resolutions Status: Unresolved
Management agrees with the findings and recommendations, will transfer the replacement reserve funds. Monthly deposits will be completed in accordance with HUD going forward to ensure all terms and conditions are met.
2024-004
FAC accepted this audit on October 28, 2024 — management decision was due April 28, 2025.
Criteria Tenant lease files are required to be maintained and tenant eligibility determined in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Condition In connection with our lease file review, we noted the following deficiencies: - 2 out of 6 lease files for existing tenants did not follow EIV guidelines, EIV reports were generated outside of the allowed 120-day period. - 2 out of 6 lease files for existing tenants did not contain necessary documentation, files were missing gross rent change forms and latest executed versions of HUD-50059 form. - 2 out of 6 lease files for existing tenants were not certified before required recertification date, one file was 60 days late, second file was 116 days late. - 1 out of 2 lease files for former tenants had late security deposit refund. Cause Management's policies with respect to the determination of eligibility and the maintenance of tenant lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs were not consistently followed. Effect or Potential Effect The procedures for eligibility and maintaining tenant lease files were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Recommendations Management should establish procedures and monitor compliance with those procedures to ensure that tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Auditor Noncompliance Code: Z. Other. View of Responsible Officials Management agrees with the finding. Management’s plan of action for non-compliance of the HUD Guidelines includes the immediate steps below: 1. Provide additional training and resources to ensure that the staff has a clear understanding of HUD requirements that will include the importance of adhering to procedures and guidelines with a specific focus on the EIV requirements and reporting, along with the timely processing of annual recertifications. 2. Implement increased monitoring and oversight mechanisms to detect and correct compliance issues. 3. Establish clear accountability measures for not following procedures through appropriate corrective actions. 4. Effectively communicate the importance of following procedures to all staff, emphasizing the impact on organizational efficiency and compliance. 5. Encourage a culture of continuous improvement where procedures are regularly reviewed, communicated with the staff and provide regular training of changing circumstances or best practices. Finding Resolutions Status: Resolved
Show full finding ▾Hide full finding ▴Criteria Tenant lease files are required to be maintained and tenant eligibility determined in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Condition In connection with our lease file review, we noted the following deficiencies: - 2 out of 6 lease files for existing tenants did not follow EIV guidelines, EIV reports were generated outside of the allowed 120-day period. - 2 out of 6 lease files for existing tenants did not contain necessary documentation, files were missing gross rent change forms and latest executed versions of HUD-50059 form. - 2 out of 6 lease files for existing tenants were not certified before required recertification date, one file was 60 days late, second file was 116 days late. - 1 out of 2 lease files for former tenants had late security deposit refund. Cause Management's policies with respect to the determination of eligibility and the maintenance of tenant lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs were not consistently followed. Effect or Potential Effect The procedures for eligibility and maintaining tenant lease files were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Recommendations Management should establish procedures and monitor compliance with those procedures to ensure that tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Auditor Noncompliance Code: Z. Other. View of Responsible Officials Management agrees with the finding. Management’s plan of action for non-compliance of the HUD Guidelines includes the immediate steps below: 1. Provide additional training and resources to ensure that the staff has a clear understanding of HUD requirements that will include the importance of adhering to procedures and guidelines with a specific focus on the EIV requirements and reporting, along with the timely processing of annual recertifications. 2. Implement increased monitoring and oversight mechanisms to detect and correct compliance issues. 3. Establish clear accountability measures for not following procedures through appropriate corrective actions. 4. Effectively communicate the importance of following procedures to all staff, emphasizing the impact on organizational efficiency and compliance. 5. Encourage a culture of continuous improvement where procedures are regularly reviewed, communicated with the staff and provide regular training of changing circumstances or best practices. Finding Resolutions Status: Resolved
Management agrees with the finding. Managements Plan of Action for Non- Compliance of the HUD Guidelines includes the immediate steps below: 1. Provide additional training and resources to ensure that the staff has a clear understanding of HUD requirements that will include the importance of adhering to procedures and guidelines with a specific focus on the EIV requirements and reporting, along with the timely processing of annual recertifications. 2. Implement increased monitoring and oversight mechanisms to detect and correct compliance issues. 3. Establish clear accountability measures for not following procedures through appropriate corrective actions. 4. Effectively communicate the importance of following procedures to all staff, emphasizing the impact on organizational efficiency and compliance. 5. Encourage a culture of continuous improvement where procedures are regularly reviewed, communicated with the staff and provide regular training of changing circumstances or best practices.
2023-001
Criteria 1. Management is responsible for the design, implementation, and maintenance of internal controls relevant to the preparation and fair presentation of financial statements that are free from material misstatement, whether due to fraud or error. 2. Management is responsible for timely submission of audited financial statements to Federal Audit Clearinghouse ("FAC"). Submission of June 30, 2023 financial statements was not completed within specified time frame. Condition 1. The accounting records required numerous material adjustments to be proposed and recorded in order for the financial statements to be fairly presented in accordance with generally accepted accounting principles in the United States of America. 2. Single Audit reports are required to be submitted to the FAC pursuant to the audit requirement of Title 2 U.S. Code of Federal Regulations Part 200. Cause Management did not have sufficient controls over financial reporting. Effect or Potential Effect Condition 1 may lead to inaccurate financial reporting and potential misstatement of the financial statements such that they are not in accordance with accounting principles generally accepted in the United States of America. Condition 2 results in auditee being designated as a not low-risk auditee, which may have an effect on future federal grants and program eligibility. Recommendations 1. Management should undertake a review of internal controls over financial reporting and ensure that financial data is properly recorded in the books and records of the project to prevent misstatements from occurring in the future. 2. Management should implement procedures to ensure that required filing is completed as required. Auditor Noncompliance Code: S. Internal control deficiencies. View of Responsible Officials 1. Management agrees with the finding and recommendation and has implemented reviews of the financial statements by senior management prior to closing books to ensure accuracy of information. 2. Management agrees with the finding and recommendation and will ensure required filing is completed timely. Finding Resolution Status: Resolved
Show full finding ▾Hide full finding ▴Criteria 1. Management is responsible for the design, implementation, and maintenance of internal controls relevant to the preparation and fair presentation of financial statements that are free from material misstatement, whether due to fraud or error. 2. Management is responsible for timely submission of audited financial statements to Federal Audit Clearinghouse ("FAC"). Submission of June 30, 2023 financial statements was not completed within specified time frame. Condition 1. The accounting records required numerous material adjustments to be proposed and recorded in order for the financial statements to be fairly presented in accordance with generally accepted accounting principles in the United States of America. 2. Single Audit reports are required to be submitted to the FAC pursuant to the audit requirement of Title 2 U.S. Code of Federal Regulations Part 200. Cause Management did not have sufficient controls over financial reporting. Effect or Potential Effect Condition 1 may lead to inaccurate financial reporting and potential misstatement of the financial statements such that they are not in accordance with accounting principles generally accepted in the United States of America. Condition 2 results in auditee being designated as a not low-risk auditee, which may have an effect on future federal grants and program eligibility. Recommendations 1. Management should undertake a review of internal controls over financial reporting and ensure that financial data is properly recorded in the books and records of the project to prevent misstatements from occurring in the future. 2. Management should implement procedures to ensure that required filing is completed as required. Auditor Noncompliance Code: S. Internal control deficiencies. View of Responsible Officials 1. Management agrees with the finding and recommendation and has implemented reviews of the financial statements by senior management prior to closing books to ensure accuracy of information. 2. Management agrees with the finding and recommendation and will ensure required filing is completed timely. Finding Resolution Status: Resolved
1. Management agrees with the finding and recommendation and has implemented reviews of the financial statements by senior management prior to closing books to ensure accuracy of information. 2. Management agrees with the finding and recommendation and will ensure required filing is completed timely.
Criteria Loans are not permitted to be made from project cash without prior authorization from HUD. Condition During the year ended July 30, 2024, the Project transferred funds in the amount of $12,812 to an affiliate from project cash without HUD approval. The funds have since been transferred back. Cause Procedures were not in place to ensure that cash disbursements of project funds were limited to project operating costs. Effect or Potential Effect The payments of $12,812 were unauthorized loans and therefore considered to be questioned costs. Questioned Costs $12,812 Identification as a Repeat Finding This is not a repeat finding. Recommendations Management should establish procedures to ensure payments of this nature are not made in the future. Auditor Noncompliance Code: G. Unauthorized loans from project assets. View of Responsible Officials Management agrees with the finding and recommendation and has reviewed the HUD requirement for funding. Funds have been transferred and will maintain HUD policy of no unauthorized loans between affiliates. Finding Resolutions Status: Resolved
Show full finding ▾Hide full finding ▴Criteria Loans are not permitted to be made from project cash without prior authorization from HUD. Condition During the year ended July 30, 2024, the Project transferred funds in the amount of $12,812 to an affiliate from project cash without HUD approval. The funds have since been transferred back. Cause Procedures were not in place to ensure that cash disbursements of project funds were limited to project operating costs. Effect or Potential Effect The payments of $12,812 were unauthorized loans and therefore considered to be questioned costs. Questioned Costs $12,812 Identification as a Repeat Finding This is not a repeat finding. Recommendations Management should establish procedures to ensure payments of this nature are not made in the future. Auditor Noncompliance Code: G. Unauthorized loans from project assets. View of Responsible Officials Management agrees with the finding and recommendation and has reviewed the HUD requirement for funding. Funds have been transferred and will maintain HUD policy of no unauthorized loans between affiliates. Finding Resolutions Status: Resolved
Management agrees with the finding and recommendation and has reviewed the HUD requirement for funding. Funds have been transferred and will maintain HUD policy of no unauthorized loans between affiliates.
Criteria During the year ended June 30, 2024, the project did not make the required monthly deposits to the replacement reserve. A catch-up deposit was made for 6 months of at once, however the deposit was short by $13,378. Condition The regulatory agreement requires that the project make monthly deposits. Cause The project did make the required monthly deposits during the initial management company change. Effect or Potential Effect Failure to make monthly payments resulted in an underfunding of the replacement reserve and a violation of the regulatory agreement. Questioned Costs $13,378 Identification as a Repeat Finding This is not a repeat finding. Recommendations Management should ensure that the replacement reserve is funded in accordance with the terms of the regulatory agreement. Auditor Noncompliance Code: N. Reserve for replacement deposits. View of Responsible Officials Management agrees with the finding and recommendation and has reviewed the HUD requirement for replacement reserve funding. Funds have been transferred and will maintain HUD policy of monthly deposits to the replacement reserve. Finding Resolution Status: Resolved
Show full finding ▾Hide full finding ▴Criteria During the year ended June 30, 2024, the project did not make the required monthly deposits to the replacement reserve. A catch-up deposit was made for 6 months of at once, however the deposit was short by $13,378. Condition The regulatory agreement requires that the project make monthly deposits. Cause The project did make the required monthly deposits during the initial management company change. Effect or Potential Effect Failure to make monthly payments resulted in an underfunding of the replacement reserve and a violation of the regulatory agreement. Questioned Costs $13,378 Identification as a Repeat Finding This is not a repeat finding. Recommendations Management should ensure that the replacement reserve is funded in accordance with the terms of the regulatory agreement. Auditor Noncompliance Code: N. Reserve for replacement deposits. View of Responsible Officials Management agrees with the finding and recommendation and has reviewed the HUD requirement for replacement reserve funding. Funds have been transferred and will maintain HUD policy of monthly deposits to the replacement reserve. Finding Resolution Status: Resolved
Management agrees with the finding and recommendation and has reviewed the HUD requirement for replacement reserve funding. Funds have been transferred and will maintain HUD policy of monthly deposits to the replacement reserve.
Criteria Management fee payments are limited to amounts determined in accordance with the terms of the HUD approved management agreement. Condition During the year ended June 30, 2024, the project paid management fees of $4,884 in excess of the amount approved by HUD. Cause There were 2 different management agreements and management did not follow the HUD approved management agreement when paying management fees from operations. Effect or Potential Effect The overpaid amount is an unauthorized distribution and therefore considered to be questioned costs. Questioned Costs $4,884 Identification as a Repeat Finding This is not a repeat finding. Recommendation The management company should reimburse the project for overpaid management fee in the amount of $4,884 and implement procedures to ensure that the management fee paid does not exceed the amount determined in accordance with the HUD approved management agreement. Auditor Noncompliance Code: J. Unauthorized management fees Views of Responsible Officials Management agrees with the finding and is working with ownership on reimbursements to the property. Management will collect in accordance with HUD going forward. Finding Resolution Status: In process
Show full finding ▾Hide full finding ▴Criteria Management fee payments are limited to amounts determined in accordance with the terms of the HUD approved management agreement. Condition During the year ended June 30, 2024, the project paid management fees of $4,884 in excess of the amount approved by HUD. Cause There were 2 different management agreements and management did not follow the HUD approved management agreement when paying management fees from operations. Effect or Potential Effect The overpaid amount is an unauthorized distribution and therefore considered to be questioned costs. Questioned Costs $4,884 Identification as a Repeat Finding This is not a repeat finding. Recommendation The management company should reimburse the project for overpaid management fee in the amount of $4,884 and implement procedures to ensure that the management fee paid does not exceed the amount determined in accordance with the HUD approved management agreement. Auditor Noncompliance Code: J. Unauthorized management fees Views of Responsible Officials Management agrees with the finding and is working with ownership on reimbursements to the property. Management will collect in accordance with HUD going forward. Finding Resolution Status: In process
Management agrees with the finding and is working with ownership on reimbursements to the property. Management will collect in accordance with HUD going forward.
FAC accepted this audit on May 15, 2024 — management decision was due November 15, 2024.
Finding No. 2023-001; Section 202 Supportive Housing for the Elderly, Assistance Listing 14.157 Criteria Tenant lease files are required to be maintained and tenant eligibility determined in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Condition In connection with our lease file review we noted the following deficiencies: Two out of seven existing tenants tested had EIVs that were performed outside of 120-day EIV window. One out of one new tenants tested had an initial EIV certification that was performed outside of the 90-day EIV window. Cause Management's policies with respect to the maintenance of tenant lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs were not consistently followed. Effect or Potential Effect The procedures for determining eligibility and maintaining tenant lease files were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Questioned Costs There are no questioned costs. Identification as a Repeat Finding This is a repeat finding. Recommendation Management should establish procedures and monitor compliance with those procedures to ensure that tenant security deposits are correctly recorded, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Auditor Noncompliance Code: Section 202 Supportive Housing for the Elderly program administration. Finding Resolution Status: Resolved. Views of Responsible Officials The Franklin Johnston group has strict EIV policies and procedures in place. Although HUD requires quarterly reports, we require monthly reports for our Master Binder. Site teams are only permitted to pull the "By Head of Household Report" at the time of the recertification appointment. They do not pull 120 ,90 , 60 or 30 days in advance. The report is pulled at the time the recertification packet is completed. The site teams pull this report 90 days after a MI is submitted to TRACS. We pull this report 90 days that a resident receives a utility check as well. There are other EIV reports as it relates to specific tasks. All site teams members have been trained as it relates to this policy. In addition to this training all site teams are required to attend monthly EIV training.
Show full finding ▾Hide full finding ▴Finding No. 2023-001; Section 202 Supportive Housing for the Elderly, Assistance Listing 14.157 Criteria Tenant lease files are required to be maintained and tenant eligibility determined in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Condition In connection with our lease file review we noted the following deficiencies: Two out of seven existing tenants tested had EIVs that were performed outside of 120-day EIV window. One out of one new tenants tested had an initial EIV certification that was performed outside of the 90-day EIV window. Cause Management's policies with respect to the maintenance of tenant lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs were not consistently followed. Effect or Potential Effect The procedures for determining eligibility and maintaining tenant lease files were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Questioned Costs There are no questioned costs. Identification as a Repeat Finding This is a repeat finding. Recommendation Management should establish procedures and monitor compliance with those procedures to ensure that tenant security deposits are correctly recorded, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Auditor Noncompliance Code: Section 202 Supportive Housing for the Elderly program administration. Finding Resolution Status: Resolved. Views of Responsible Officials The Franklin Johnston group has strict EIV policies and procedures in place. Although HUD requires quarterly reports, we require monthly reports for our Master Binder. Site teams are only permitted to pull the "By Head of Household Report" at the time of the recertification appointment. They do not pull 120 ,90 , 60 or 30 days in advance. The report is pulled at the time the recertification packet is completed. The site teams pull this report 90 days after a MI is submitted to TRACS. We pull this report 90 days that a resident receives a utility check as well. There are other EIV reports as it relates to specific tasks. All site teams members have been trained as it relates to this policy. In addition to this training all site teams are required to attend monthly EIV training.
RESPONSE: The Franklin Johnston group has strict EIV policies and procedures in place. Although HUD requires quarterly reports, we require monthly reports for our Master Binder. Site teams are only permitted to pull the “By Head of Household Report” at the time of the recertification appointment. They do not pull 120 ,90 , 60 or 30 days in advance. The report is pulled at the time the recertification packet is completed. The site teams pull this report 90 days after a MI is submitted to TRACS. We pull this report 90 days that a resident receives a utility check as well. There are other EIV reports as it relates to specific tasks. All site teams members have been trained as it relates to this policy. In addition to this training all site teams are required to attend monthly EIV training.
2022-001
FAC accepted this audit on January 8, 2023 — management decision was due July 8, 2023.
Finding No. 2022-001; Section 202 Supportive Housing for the Elderly, Assistance Listing 14.157 Criteria Tenant lease files are required to be maintained and tenant eligibility determined in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Condition In connection with our lease file review we noted the following deficiencies: ? Four out of seven existing tenants tested had EIVs that were performed outside of 120-day EIV window. ? Management provided the auditors the EIV forms electronically within the tenant reporting packages for 1 out of 8 existing and new tenants tested. ? One out of one new tenants tested had an initial EIV certification that was performed outside of the 90-day EIV window. ? One out of seven existing tenants had incorrectly calculated income. Cause Management's policies with respect to the maintenance of tenant lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs were not consistently followed. Effect or Potential Effect The procedures for determining eligibility and maintaining tenant lease files were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Questioned Costs There are no questioned costs. Identification as a Repeat Finding This is not a repeat finding. Recommendation Management should establish procedures and monitor compliance with those procedures to ensure that tenant security deposits are correctly recorded, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Auditor Noncompliance Code: Section 202 Supportive Housing for the Elderly program Administration Finding Resolution Status: Resolved. Views of Responsible Officials Management hired additional oversight staff at the corporate level and changed the procedure for reviewing and approving annual certifications as well as monitoring EIV reporting. Management implemented new EIV procedures to ensure timely EIV reporting. All HUD staff has been trained on the new procedures.
Show full finding ▾Hide full finding ▴Finding No. 2022-001; Section 202 Supportive Housing for the Elderly, Assistance Listing 14.157 Criteria Tenant lease files are required to be maintained and tenant eligibility determined in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Condition In connection with our lease file review we noted the following deficiencies: ? Four out of seven existing tenants tested had EIVs that were performed outside of 120-day EIV window. ? Management provided the auditors the EIV forms electronically within the tenant reporting packages for 1 out of 8 existing and new tenants tested. ? One out of one new tenants tested had an initial EIV certification that was performed outside of the 90-day EIV window. ? One out of seven existing tenants had incorrectly calculated income. Cause Management's policies with respect to the maintenance of tenant lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs were not consistently followed. Effect or Potential Effect The procedures for determining eligibility and maintaining tenant lease files were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Questioned Costs There are no questioned costs. Identification as a Repeat Finding This is not a repeat finding. Recommendation Management should establish procedures and monitor compliance with those procedures to ensure that tenant security deposits are correctly recorded, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Auditor Noncompliance Code: Section 202 Supportive Housing for the Elderly program Administration Finding Resolution Status: Resolved. Views of Responsible Officials Management hired additional oversight staff at the corporate level and changed the procedure for reviewing and approving annual certifications as well as monitoring EIV reporting. Management implemented new EIV procedures to ensure timely EIV reporting. All HUD staff has been trained on the new procedures.
Finding 2022-1 a. Comments on the Finding and Each Recommendation Management agrees with the finding. b. Action(s) Taken or Planned on the Finding In 2022 we hired additional oversight staff at the corporate level and changed the procedure for reviewing and approving annual certifications as well as monitoring EIV reporting. We have implanted new EIV procedures to ensure timely EIV reporting. All HUD staff has been trained on the new procedures.
FAC accepted this audit on October 19, 2021 — management decision was due April 19, 2022.
Finding No. 2021-001; Section 202 Supportive Housing for the Elderly, CFDA 14.157 Statement of Condition As of June 30, 2021, management has not fully funded the tenant security deposits cash account. The tenant security deposits cash account was underfunded by $2,685.Criteria In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs, HUD projects are required to establish and maintain at all times a fully funded separate bank account for tenant security deposits collected. Questioned Costs $2,685 Effect Management inadvertently transferred too much cash from the security deposit because they did not take into account the liability recorded for interest on security deposits. Cause The tenant security deposits liability exceeds the tenant security deposits cash account by $2,685 as of June 30, 2021. Recommendation Management should transfer $2,685 from the operating account in order to fully fund the tenant security deposits account and ensure that they include the security deposit liability when checking if the security cash account is appropriately funded. Auditor Noncompliance Code: D - Comingling of funds Finding Resolution Status: Resolved. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and the auditor's recommendation have been implemented. Transfer of cash to fully cover the liability, including accrued interest, was made into the security deposit account on July 28, 2021.
Show full finding ▾Hide full finding ▴Finding No. 2021-001; Section 202 Supportive Housing for the Elderly, CFDA 14.157 Statement of Condition As of June 30, 2021, management has not fully funded the tenant security deposits cash account. The tenant security deposits cash account was underfunded by $2,685.Criteria In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs, HUD projects are required to establish and maintain at all times a fully funded separate bank account for tenant security deposits collected. Questioned Costs $2,685 Effect Management inadvertently transferred too much cash from the security deposit because they did not take into account the liability recorded for interest on security deposits. Cause The tenant security deposits liability exceeds the tenant security deposits cash account by $2,685 as of June 30, 2021. Recommendation Management should transfer $2,685 from the operating account in order to fully fund the tenant security deposits account and ensure that they include the security deposit liability when checking if the security cash account is appropriately funded. Auditor Noncompliance Code: D - Comingling of funds Finding Resolution Status: Resolved. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and the auditor's recommendation have been implemented. Transfer of cash to fully cover the liability, including accrued interest, was made into the security deposit account on July 28, 2021.
1. Finding 2021-1 a. Comments on the Finding and Each Recommendation We agree with the finding and recommendations b. Action(s) Taken or Planned on the Finding Due to a change in accounting staff, interest on Security Deposits held was not taken into consideration in determining the amount of funds that should be in the Security Deposit Bank Account. The funds have been transferred and the staff has been trained on this procedure.
Finding No. 2021-002; Section 202 Supportive Housing for the Elderly, CFDA 14.157 Statement of Condition In connection with our lease file review we noted the following deficiencies: 1. 2 out of 9 tenants tested did not have documentation in their lease that their income was verified using EIV. 2. 1 out of 9 tenants tested did not have annual recertification completed by the required due date. Criteria Tenant lease files are required to be maintained and tenant eligibility determined in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Questioned Costs N/AEffect The procedures for determining tenant eligibility and maintaining tenant lease files were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Cause Management's policies with respect to the determination of tenant eligibility and the maintenance of tenant lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs were not consistently followed. Recommendation Management should establish procedures and monitor compliance with those procedures to insure that tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Auditor Noncompliance Code: R - Section 8 administration Finding Resolution Status: Resolved. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and the auditor's recommendation have been implemented.
Show full finding ▾Hide full finding ▴Finding No. 2021-002; Section 202 Supportive Housing for the Elderly, CFDA 14.157 Statement of Condition In connection with our lease file review we noted the following deficiencies: 1. 2 out of 9 tenants tested did not have documentation in their lease that their income was verified using EIV. 2. 1 out of 9 tenants tested did not have annual recertification completed by the required due date. Criteria Tenant lease files are required to be maintained and tenant eligibility determined in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Questioned Costs N/AEffect The procedures for determining tenant eligibility and maintaining tenant lease files were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Cause Management's policies with respect to the determination of tenant eligibility and the maintenance of tenant lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs were not consistently followed. Recommendation Management should establish procedures and monitor compliance with those procedures to insure that tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Auditor Noncompliance Code: R - Section 8 administration Finding Resolution Status: Resolved. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and the auditor's recommendation have been implemented.
2. Finding 2021-2 c. Comments on the Finding and Each Recommendation We agree with the finding and recommendations d. Action(s) Taken or Planned on the Finding Weinberg Woods had a turnover in office personnel and the late certifications were addressed by the new staff. The new office staff have been trained in the correct policy and procedures and are being monitored by our Compliance Department to ensure compliance with HUD regulations. The Management Agent has hired a new Director of Compliance and created an EIV Quality Assurance Plan. With this plan management is training a new procedure to ensure compliance with EIV requirements which includes the Compliance Specialists being required to monitor the printing of the move-in and 60 day EIV reports.
Finding No. 2021-003; Section 202 Supportive Housing for the Elderly, CFDA 14.157 Statement of Condition During the year ended June 30, 2021, the project paid expenses in the amount of $13,221 on behalf of an affiliate from project cash without HUD approval. The amount due to the project as of June 30, 2021 is $13,221. Criteria The terms of regulatory agreement prohibit loans from project assets without HUD approval. Questioned Costs $13,221 Effect The payments of $13,221 were unauthorized loans and therefore considered to be questioned costs. Cause An administrative oversight resulted in project funds to be used to pay payroll on behalf of an affiliated project. Recommendation The project's operating cash account should be reimbursed for this amount. Management should establish procedures to ensure payments of this nature are not made in the future.Auditor Noncompliance Code: G - Unauthorized loans from project funds Finding Resolution Status: Resolved. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and the auditor's recommendation has been implemented. Transfer of cash of $13,221 was made into the operating cash account on August 27, 2021.
Show full finding ▾Hide full finding ▴Finding No. 2021-003; Section 202 Supportive Housing for the Elderly, CFDA 14.157 Statement of Condition During the year ended June 30, 2021, the project paid expenses in the amount of $13,221 on behalf of an affiliate from project cash without HUD approval. The amount due to the project as of June 30, 2021 is $13,221. Criteria The terms of regulatory agreement prohibit loans from project assets without HUD approval. Questioned Costs $13,221 Effect The payments of $13,221 were unauthorized loans and therefore considered to be questioned costs. Cause An administrative oversight resulted in project funds to be used to pay payroll on behalf of an affiliated project. Recommendation The project's operating cash account should be reimbursed for this amount. Management should establish procedures to ensure payments of this nature are not made in the future.Auditor Noncompliance Code: G - Unauthorized loans from project funds Finding Resolution Status: Resolved. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and the auditor's recommendation has been implemented. Transfer of cash of $13,221 was made into the operating cash account on August 27, 2021.
3. Finding 2021-3 e. Comments on the Finding and Each Recommendation We agree with the finding and recommendations f. Action(s) Taken or Planned on the Finding An employee was transferred to a new community from Weinberg Woods, but the payroll system was not updated with the change. Once discovered Weinberg Woods was immediately reimbursed by the other community and the payroll system was updated to prevent future issues.
FAC accepted this audit on October 20, 2020 — management decision was due April 20, 2021.
FAC accepted this audit on October 15, 2019 — management decision was due April 15, 2020.
Finding No. 2019-001 Statement of Condition During the procedures applied to a sample of nine tenant lease files, one tenant lease file did not have the required income verification. Criteria Management is responsible for determining tenant eligibility and maintaining lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Effect Noncompliance with HUD guidelines could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Cause The project failed to follow the policies and procedures which have been established for proper tenant file maintenance and determining tenant eligibility in accordance with HUD guidelines. Recommendation Management should ensure procedures in place are followed and monitor compliance with those procedures to ensure that the determination of tenant eligibility and the maintenance of lease files are in accordance with guidelines specified by HUD. Auditor Noncompliance Code Z - Other Finding Resolution Status: Resolved on July 30, 2019. Management performed the income verification for the tenant lease file that did not have the required income verification and submitted corrections to HUD. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and will perform additional income verifications for tenants as required by HUD.
Show full finding ▾Hide full finding ▴Finding No. 2019-001 Statement of Condition During the procedures applied to a sample of nine tenant lease files, one tenant lease file did not have the required income verification. Criteria Management is responsible for determining tenant eligibility and maintaining lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Effect Noncompliance with HUD guidelines could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Cause The project failed to follow the policies and procedures which have been established for proper tenant file maintenance and determining tenant eligibility in accordance with HUD guidelines. Recommendation Management should ensure procedures in place are followed and monitor compliance with those procedures to ensure that the determination of tenant eligibility and the maintenance of lease files are in accordance with guidelines specified by HUD. Auditor Noncompliance Code Z - Other Finding Resolution Status: Resolved on July 30, 2019. Management performed the income verification for the tenant lease file that did not have the required income verification and submitted corrections to HUD. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and will perform additional income verifications for tenants as required by HUD.
Corrective Action Plan Project Legal Name: The Harry and Jeanette Weinberg Woods, Inc. HUD Project No.: 052-EE021 Audit Firm: CohnReznick LLP Period covered by the audit: July 1, 2018 to June30,2019 Corrective Action Plan prepared by: Name: Mark Jones Position: CFO of Edgewood Management Corp. Telephone Number: (301) 628-4310 The following is a recommended format to be followed by the auditee for preparing a corrective action plan: A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Finding 2019-1 a. Comments on the Finding and Each Recommendation During the procedures applied to a sample of nine tenant lease files, one tenant lease file did not have the required income verification. Management agrees with the finding and performed additional income verifications for tenants as required by HUD. b. Action(s) Taken or Planned on the Finding Resolved on July 30, 2019. Management performed the income verification for the tenant lease file that did not have the required income verification and submitted corrections to HUD. Management has established procedures and monitor compliance with those procedures to ensure that the determination of tenant eligibility and the maintenance of lease files are in accordance with guidelines specified by HUD. Management continues with annual and monthly training and monitoring to improve our performance.
FAC accepted this audit on October 15, 2018 — management decision was due April 15, 2019.
FAC accepted this audit on October 17, 2017 — management decision was due April 17, 2018.
FAC accepted this audit on October 17, 2016 — management decision was due April 17, 2017.
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