EIN: 581869105
UEI: GSA_MIGRATION
Data as of August 25, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on May 14, 2021. 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 November 14, 2021 (1745 days ago).
What is a management decision? →Documentation of verification of low-income status, signed tenant application and signed lease could not be located for two tenants selected and documentation of recertification of income could not be located for one tenant selected. The total number of tenants residing at Reynoldstown Commons apartments in 2019 was twenty-eight and 4 tenants were selected for testing. Cause: Due to turnover in the property manager position in 2019 and 2020, tenant documentation was not filed correctly. Effect: Failure to properly maintain tenant documentation could result in noncompliance with HOME regulation. Recommendation: Management should verify the eligibility of the tenants whose documentation could not be located. We recommend procedures are implemented to ensure tenant documentation is properly filed and maintained.
Show full finding ▾Hide full finding ▴2019-001 ? HOME CFDA 14.239 ? Maintenance of Tenant Documentation ? Internal Control (Material Weakness) HOME loans passed through City of Atlanta and passed through Georgia Housing and Finance Authority Grant Period: Year Ended December 31, 2019 Criteria: HOME program serves low-income families. Eligibility for the HOME program requires family income below the area median income. Verification of income level is completed at onset of occupancy and recertification of income is required annually. All tenant records must be maintained in accordance with HOME regulations for proper audit by the grantee and other parties. Condition: Documentation of verification of low-income status, signed tenant application and signed lease could not be located for two tenants selected and documentation of recertification of income could not be located for one tenant selected. The total number of tenants residing at Reynoldstown Commons apartments in 2019 was twenty-eight and 4 tenants were selected for testing. Cause: Due to turnover in the property manager position in 2019 and 2020, tenant documentation was not filed correctly. Effect: Failure to properly maintain tenant documentation could result in noncompliance with HOME regulation. Recommendation: Management should verify the eligibility of the tenants whose documentation could not be located. We recommend procedures are implemented to ensure tenant documentation is properly filed and maintained.
Corrective Action Plan: Management implemented the tenant (re)certification standard operating procedures as follows. Description This process is followed when tenant certifications or recertifications are processed. Responsible Resources for Residents and Communities ED ? Executive Director RD ? Real Estate Director Property Management OPM ? On-site Property Manager CO ? Compliance Officer Other CT ? Compliance Team (ED/RD, OPM, CO) PT ? Prospective Tenant T ? Tenant Records Tenant Files (Application, Submitted Documents, Communications Records, Lease, etc.) Eligibility Requirements: Land Use Restriction Agreement Land Use Restrictive Covenants Rent Increase Approvals Applicant Certification 1. PT submits rental application to OPM along with application fee. 2. OPM initiates hard and electronic files for PT. All items submitted by PT are added to the file and electronic records are updated to indicate receipt. 3. OPM reviews rental application along with submitted supplemental documentation. a. If any required documents were not received, PT is asked to provide required items. b. If all required documents were received, OPM determines whether PT is eligible according to the Eligibility Requirements. 4. OPM informs PT of eligibility status. a. If PT is eligible, payment of deposit is requested, and timeline related to unit availability is provided to PT. b. If PT is ineligible PT is informed, and file is closed. 5. Upon receipt of deposit and availability of unit OPM executes lease and reviews property rules with T, including annual re-certificate requirement. Tenant Recertification 1. On an annual basis, OPM notifies T when recertification is required and requests all necessary documentation to be provided within a set timeframe. a. If the requested documentation is not received within the set timeframe, T is reminded of the responsibility for re-certification. b. If multiple requests for documentation required for recertification are not fulfilled, T will be evaluated for a month-to-month lease. 2. Upon receipt of all required documentation for recertification, OPM evaluates whether T currently meets Eligibility Requirements. 3. OPM notifies T of current eligibility status. a. If T is eligible, OPM executes lease and reviews property rules with T. b. If T is ineligible PT is informed, and date for move-out is set. Records Retention and Maintenance 1. OPM maintains tenant files and ensures that documentation of tenant certifications, re-certifications received throughout this process, along with payments, communications, repair requests, violations, etc. are added to the tenant file and electronic records on an on-going basis. 2. OPM maintains recertification calendar based upon the prior certification and/or recertification dates for each unit. 3. CO coordinates periodic internal reviews of tenant records. 4. CO reports results of internal reviews, as well as any necessary corrective actions to CT.
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