EASTER SEALS UNITED CEREBRAL PALSY NC HOUSING, INC.Non-Profit

HUD insured mortgage program Section 223(f), ALN 14.155 Criteria: Under HUD regulations, recipients are required to maintain and make available all records necessary to demonstrate compliance with program requirements. HUD requires documentation of tenant eligibility, income verification, and rent determination. The Uniform Guidance requires recipients to maintain records that adequately identify the source and application of funds. Statement of Condition: We reviewed 10% of the total population of tenant files. During our review, we noted that documentation to support tenant eligibility determination was missing or incomplete. We consider this condition to be a significant deficiency. Cause: The deficiencies occurred due to inconsistent file management practices and ineffective internal review procedures to ensure that all required eligibility documentation is obtained and retained. Effect: Missing or incomplete files increase the risk of improper eligibility determinations, inaccurate rent calculations, questioned costs, and HUD noncompliance. Recommendation: We recommend that management strengthen internal controls over tenant file documentation by conducting periodic supervisory reviews of files to ensure that all required documentation is present and complete and by providing staff training on HUD eligibility and documentation requirements. Views of Responsible Officials: We agree with the auditor’s finding. The audited files exist in the same timeframe as other issues noted in the previous audit, and therefore findings will be similar. Those files and documents were not properly managed or maintained and some cannot be located. Prior management did not implement established and required processes and failed to oversee the work to ensure accuracy. In the second quarter of 2025, we began exploring the issues that existed at that time and correcting procedures, changing software systems, establishing supervisors, training staff, and establishing tracking and monitoring systems and processes. Staff have made substantial progress and continue to do so.

HUD insured mortgage program Section 223(f), ALN 14.155 Criteria: The Project’s occupancy rate should be adequate to maintain Project operations. Statement of Condition: The Project’s vacancy expense was 28% of rental revenue for the year ended September 30, 2025. Cause: Of the Project’s seventy-two units, eighteen were vacant the entire year, and one was vacant several months during the year. Effect: Decreased revenue may result in excessive future usage of replacement reserve and debt service savings reserve funds. Decreased revenue may also negatively impact the Project’s ability to fund future Project operations. Recommendation: The Project should continue its efforts to obtain tenants and decrease vacancies. Views of Responsible Officials: We agree with the finding. The Project will continue its attempts to decrease vacancies.

HUD insured mortgage program - Section 223(f), Assistance Listing Number 14.155 Criteria: The Project’s occupancy rate should be adequate to maintain Project operations. Statement of Condition: The Project’s vacancy expense was 29% of rental revenue for the year ended September 30, 2024. Cause: Of the Project’s seventy-two units, eighteen were vacant the entire year, and eight others were vacant several months during the year. Effect: Decreased revenue may result in excessive future usage of replacement reserve funds. Decreased revenue may also negatively impact the Project’s ability to fund future Project operations. Recommendation: The Project should continue its efforts to obtain tenants and decrease vacancies. Views of Responsible Officials: We agree with the finding. The Project will continue its attempts to decrease vacancies.

HUD insured mortgage program - Section 223(f), Assistance Listing Number 14.155 Criteria: The Project’s occupancy rate should be adequate to maintain Project operations. Statement of Condition: The Project’s vacancy expense was 26% of rental revenue for the year ended September 30, 2023. Cause: Of the Project’s seventy-two units, seven were vacant the entire year, and three others were vacant several months during the year. Effect: Decreased revenue may result in excessive future usage of replacement reserve funds. Decreased revenue may also negatively impact the Project’s ability to fund future Project operations. Recommendation: The Project should continue its efforts to obtain tenants and decrease vacancies. Views of Responsible Officials: We agree with the finding. The Project will continue its attempts to decrease vacancies.

Criteria: Paragraph 5.(a) of the Regulatory Agreement with HUD states that annual transfers of $28,836 should be deposited into the reserve for replacement account. Condition: For the year ended September 30, 2019, the Organization did not make the full amount of the required annual deposits into the reserve for replacement account, per the Organization?s Regulatory Agreement with HUD. Cause: Management oversight. Effect: At September 30, 2019, the reserve for replacement account was underfunded by $456, based on the requirements in the Regulatory Agreement. Recommendation: We recommend that Management institute procedures to ensure that the required deposits are made into the reserve for replacement account on a timely basis and to fund the reserve for replacement account fully. Views of Responsible Officials: Management agrees with the finding and the recommendation.

GSA_MIGRATION