EIN: 593437427
UEI: KCLRUD1D6XD7
Audited by: CohnReznick LLP
Oversight agency: 14 [Department of Housing and Urban Development]
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Data as of August 31, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 24, 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 December 24, 2026 (113 days from today).
What is a management decision? →During the year ended September 30, 2025, the project did not make the required monthly deposits to the replacement reserve in the amount of $37,242. The project is required to make monthly deposits to the reserve in the amount of $6,198 per month, or $74,376 for the year. Cause: The project does not generate sufficient cash flow to make the required monthly deposits, due to significant delays in receipt of PRAC funds for over a year. This is related to the issues noted in finding 2025-001. Effect or Potential Effect: Failure to make monthly payments resulted in an underfunding of the replacement reserve and a violation of the PRAC subsidy contract. Questioned Costs: $37,242 Context: Due to significant delays in receipt of PRAC funds for over a year, management suspended making the monthly deposits to the reserve in 2024 until PRAC funding was replenished. Management also borrowed funds from the replacement reserve which funds were repaid during the year ended September 30, 2024 once a portion of past-due PRAC funds were received. Management continues to work on obtaining the remaining PRAC funds receivable, which has led to additional delays in deposits to the reserve for replacements until the cash flows are replenished. Identification as a Repeat Finding: Yes Recommendation: Management should review the project budget to determine if nonessential costs can be cut (or request a loan from the owner) to ensure that the replacement reserve is funded in accordance with the terms of the regulatory agreement. Management should obtain from HUD a waiver for the missing replacement reserve deposits if possible. If not granted, management should fund the missing deposits. Auditor Noncompliance Code: N - Replacement reserve deposits Finding Resolution Status: In process Views of Responsible Officials: Due to significant delays in receipt of PRAC funds for over a year, management suspended making the deposits to the reserve until PRAC funding was replenished. Management also borrowed funds from the replacement reserve in 2024 which funds were repaid during the year ended September 30, 2024 once past-due PRAC funds were received. Due to ongoing issues with PRAC funding, management continues to be behind on making the monthly deposits during the year ended September 30, 2025.
Show full finding ▾Hide full finding ▴Finding No. 2025-002 - Special Tests and Provisions U.S. Department of Housing and Urban Development Federal Program Name: Section 202 Supportive Housing for the Elderly Assistance Listing Number: 14.157 Criteria: The Section 202 Project Rental Assistance Contract (PRAC contract) requires that the project make monthly deposits to its replacement reserve. Condition: During the year ended September 30, 2025, the project did not make the required monthly deposits to the replacement reserve in the amount of $37,242. The project is required to make monthly deposits to the reserve in the amount of $6,198 per month, or $74,376 for the year. Cause: The project does not generate sufficient cash flow to make the required monthly deposits, due to significant delays in receipt of PRAC funds for over a year. This is related to the issues noted in finding 2025-001. Effect or Potential Effect: Failure to make monthly payments resulted in an underfunding of the replacement reserve and a violation of the PRAC subsidy contract. Questioned Costs: $37,242 Context: Due to significant delays in receipt of PRAC funds for over a year, management suspended making the monthly deposits to the reserve in 2024 until PRAC funding was replenished. Management also borrowed funds from the replacement reserve which funds were repaid during the year ended September 30, 2024 once a portion of past-due PRAC funds were received. Management continues to work on obtaining the remaining PRAC funds receivable, which has led to additional delays in deposits to the reserve for replacements until the cash flows are replenished. Identification as a Repeat Finding: Yes Recommendation: Management should review the project budget to determine if nonessential costs can be cut (or request a loan from the owner) to ensure that the replacement reserve is funded in accordance with the terms of the regulatory agreement. Management should obtain from HUD a waiver for the missing replacement reserve deposits if possible. If not granted, management should fund the missing deposits. Auditor Noncompliance Code: N - Replacement reserve deposits Finding Resolution Status: In process Views of Responsible Officials: Due to significant delays in receipt of PRAC funds for over a year, management suspended making the deposits to the reserve until PRAC funding was replenished. Management also borrowed funds from the replacement reserve in 2024 which funds were repaid during the year ended September 30, 2024 once past-due PRAC funds were received. Due to ongoing issues with PRAC funding, management continues to be behind on making the monthly deposits during the year ended September 30, 2025.
Project Legal Name: Evangeline Booth Residence, Inc., A Florida Corporation HUD Project No.: 063-EE011-WAH Audit Firm: CohnReznick LLP Period covered by the audit: 10/1/24-9/30/25 Corrective Action Plan prepared by: Name: Philip Gesner Position: Financial Project Manager, USA Southern Territory Finance Department Telephone Number: 470-816-5977 2. Finding 2025-002 a. Comments on the Finding and Each Recommendation The auditee agrees with the finding. The auditee agrees with the recommendation to review the project budget to determine if nonessential costs can be cut (or request a loan from the owner) to ensure that the replacement reserve is funded in accordance with the terms of the regulatory agreement and the recommendation to obtain from HUD a waiver for the missing replacement reserve deposits if possible, or fund the missing deposits. b. Action(s) Taken or Planned on the Finding Due to significant delays in receipt of PRAC funds for over a year, management suspended making the deposits to the reserve until PRAC funding was replenished. Management also borrowed funds from the replacement reserve in 2024 which funds were repaid during the year ended September 30, 2024 once past-due PRAC funds were received. Due to ongoing issues with PRAC funding, management continues to be behind on making the monthly deposits during the year ended September 30, 2025.
2024-003
During the year ended September 30, 2025, management processed a withdrawal of $3,970 from the replacement reserve account to the operating account. Management did not provide a HUD-approved Form HUD-9250 supporting this withdrawal. A correcting transaction to return the $3,970 to the replacement reserve account was dated September 30, 2025, but the repayment did not clear the bank until October 2025, which is subsequent to the audit period. Additionally, management has still not repaid or obtained HUD approval of the prior year withdrawals missing HUD approval of $39,292. Cause: Management initiated the withdrawal without securing or retaining HUD-approved Form HUD-9250 documentation. The error in the original transfer was identified after the fact, resulting in a correcting entry dated at year-end. However, the repayment of the $3,970 occurred after the close of the fiscal year. The prior year withdrawal without HUD approval remains unaddressed. Effect or Potential Effect: Without evidence of HUD approval, the withdrawal is considered unauthorized under HUD requirements. Additionally, because the return of funds occurred after the fiscal year-end, the project remained out of compliance with HUD reserve withdrawal procedures during the audit period. Questioned Costs: $3,970 Context: Management reported that the $3,970 replacement reserve withdrawal was initiated at the direction of the EBGA Director. Upon further review, management determined the transfer amount was incorrect and processed a reversal dated September 30, 2025. However, the repayment cleared the bank in October 2025, outside the audit period. Documentation supporting HUD approval for the original withdrawal was not available for audit. The prior year withdrawal of $39,282 remains unaddressed. Identification as a Repeat Finding: Yes Recommendation: Management should implement procedures to ensure all replacement reserve withdrawals are supported with a HUD-signed Form HUD-9250 prior to releasing funds. Management should repay the $3,970 withdrawal. Management should obtain HUD approval for the 2024 unauthorized withdrawals of $39,282 or pay the amounts back to the reserve. Auditor Noncompliance Code: A - Unauthorized withdrawals from the replacement reserve account Finding Resolution Status: Unresolved Views of Responsible Officials: Management stated that a correction was processed to return the $3,970 to the replacement reserve account, with the repayment clearing in October 2025. The prior year unauthorized withdrawal remains unresolved, as management does not have the funds to repay the $39,282. Management will also strengthen internal controls to ensure all future withdrawals are fully supported with HUD-signed Form HUD-9250 approvals.
Show full finding ▾Hide full finding ▴Finding No. 2025-003 - Special Tests and Provisions U.S. Department of Housing and Urban Development Federal Program Name: Section 202 Supportive Housing for the Elderly Assistance Listing Number: 14.157 Criteria: Any withdrawal from the replacement reserve account requires evidence of HUD approval, generally documented through a HUD-signed Form 9250 authorizing the release of funds. Condition: During the year ended September 30, 2025, management processed a withdrawal of $3,970 from the replacement reserve account to the operating account. Management did not provide a HUD-approved Form HUD-9250 supporting this withdrawal. A correcting transaction to return the $3,970 to the replacement reserve account was dated September 30, 2025, but the repayment did not clear the bank until October 2025, which is subsequent to the audit period. Additionally, management has still not repaid or obtained HUD approval of the prior year withdrawals missing HUD approval of $39,292. Cause: Management initiated the withdrawal without securing or retaining HUD-approved Form HUD-9250 documentation. The error in the original transfer was identified after the fact, resulting in a correcting entry dated at year-end. However, the repayment of the $3,970 occurred after the close of the fiscal year. The prior year withdrawal without HUD approval remains unaddressed. Effect or Potential Effect: Without evidence of HUD approval, the withdrawal is considered unauthorized under HUD requirements. Additionally, because the return of funds occurred after the fiscal year-end, the project remained out of compliance with HUD reserve withdrawal procedures during the audit period. Questioned Costs: $3,970 Context: Management reported that the $3,970 replacement reserve withdrawal was initiated at the direction of the EBGA Director. Upon further review, management determined the transfer amount was incorrect and processed a reversal dated September 30, 2025. However, the repayment cleared the bank in October 2025, outside the audit period. Documentation supporting HUD approval for the original withdrawal was not available for audit. The prior year withdrawal of $39,282 remains unaddressed. Identification as a Repeat Finding: Yes Recommendation: Management should implement procedures to ensure all replacement reserve withdrawals are supported with a HUD-signed Form HUD-9250 prior to releasing funds. Management should repay the $3,970 withdrawal. Management should obtain HUD approval for the 2024 unauthorized withdrawals of $39,282 or pay the amounts back to the reserve. Auditor Noncompliance Code: A - Unauthorized withdrawals from the replacement reserve account Finding Resolution Status: Unresolved Views of Responsible Officials: Management stated that a correction was processed to return the $3,970 to the replacement reserve account, with the repayment clearing in October 2025. The prior year unauthorized withdrawal remains unresolved, as management does not have the funds to repay the $39,282. Management will also strengthen internal controls to ensure all future withdrawals are fully supported with HUD-signed Form HUD-9250 approvals.
3. Finding 2025-003 a. Comments on the Finding and Each Recommendation The auditee agrees with the finding. The auditee agrees with the recommendation to implement procedures to ensure all replacement reserve withdrawals are supported with a HUD-signed Form HUD-9250 prior to releasing funds, the recommendation to repay the $3,970 withdrawal, and the recommendation to obtain HUD approval for the 2024 unauthorized withdrawals of $39,282 or pay the amounts back to the reserve. b. Action(s) Taken or Planned on the Finding Management stated that a correction was processed to return the $3,970 to the replacement reserve account, with the repayment clearing in October 2025. The prior year unauthorized withdrawal remains unresolved, as management does not have the funds to repay the $39,282. Management will also strengthen internal controls to ensure all future withdrawals are fully supported with HUD-signed Form HUD-9250 approvals.
2024-004
During the procedures applied to a sample of 6 tenant files, we noted that management was unable to provide information from the required EIV reports. Based on communication received from management, the current property manager's access to the HUD EIV system has not been activated by HUD despite the site manager completing the required training and requesting access and assurances from HUD to grant access to EIV. As a result, the property was unable to retrieve and furnish the EIV income reports and discrepancy reports requested during the audit. Cause: The site manager completed the required EIV training and followed HUD's procedures to request EIV access; however, HUD did not activate the property's site manager's EIV system access. This prevented management from retrieving the necessary EIV reports for inclusion in the tenant files. Effect or Potential Effect: Without active access to the EIV system, management is unable to obtain required income verification reports in accordance with HUD Handbook 4350.3, resulting in noncompliance with HUD reporting guidelines. This could increase the risk of undetected discrepancies in tenant-reported income and may impact the accuracy of rent subsidies paid by HUD. Questioned Costs: None Context: Management has reported ongoing issues with obtaining EIV system activation from HUD. Despite completing the required training and submitting access requests, HUD has not granted access to the EIV portal. As a result, management was unable to obtain required EIV documentation for certain tenant lease files during the audit period. Identification as a Repeat Finding: No Recommendation: Management should continue to follow up with HUD to complete activation of their EIV system access. Once access is established, management should implement procedures to ensure all required EIV reports are generated, retained, and reviewed in accordance with HUD guidelines. Auditor Noncompliance Code: Z - Other Finding Resolution Status: In process Views of Responsible Officials: Management acknowledged the challenges experienced in obtaining EIV access from HUD and stated that follow-up efforts are ongoing. Once access is granted by HUD as already approved, management will generate and maintain all required EIV reports and strengthen controls to ensure compliance with HUD requirements.
Show full finding ▾Hide full finding ▴Finding No. 2025-004 - Eligibility U.S. Department of Housing and Urban Development Federal Program Name: Section 202 Supportive Housing for the Elderly Assistance Listing Number: 14.157 Criteria: In accordance with HUD Handbook 4350.3, REV-1, and the EIV Multifamily Program User Manual, Section 4.1.1, management is required to obtain and maintain active access to the EIV system and generate the applicable EIV reports for all tenants at required intervals. Condition: During the procedures applied to a sample of 6 tenant files, we noted that management was unable to provide information from the required EIV reports. Based on communication received from management, the current property manager's access to the HUD EIV system has not been activated by HUD despite the site manager completing the required training and requesting access and assurances from HUD to grant access to EIV. As a result, the property was unable to retrieve and furnish the EIV income reports and discrepancy reports requested during the audit. Cause: The site manager completed the required EIV training and followed HUD's procedures to request EIV access; however, HUD did not activate the property's site manager's EIV system access. This prevented management from retrieving the necessary EIV reports for inclusion in the tenant files. Effect or Potential Effect: Without active access to the EIV system, management is unable to obtain required income verification reports in accordance with HUD Handbook 4350.3, resulting in noncompliance with HUD reporting guidelines. This could increase the risk of undetected discrepancies in tenant-reported income and may impact the accuracy of rent subsidies paid by HUD. Questioned Costs: None Context: Management has reported ongoing issues with obtaining EIV system activation from HUD. Despite completing the required training and submitting access requests, HUD has not granted access to the EIV portal. As a result, management was unable to obtain required EIV documentation for certain tenant lease files during the audit period. Identification as a Repeat Finding: No Recommendation: Management should continue to follow up with HUD to complete activation of their EIV system access. Once access is established, management should implement procedures to ensure all required EIV reports are generated, retained, and reviewed in accordance with HUD guidelines. Auditor Noncompliance Code: Z - Other Finding Resolution Status: In process Views of Responsible Officials: Management acknowledged the challenges experienced in obtaining EIV access from HUD and stated that follow-up efforts are ongoing. Once access is granted by HUD as already approved, management will generate and maintain all required EIV reports and strengthen controls to ensure compliance with HUD requirements.
4. Finding 2025-004 a. Comments on the Finding and Each Recommendation The auditee agrees with the finding. The auditee agrees with the recommendation to continue to follow up with HUD to complete activation of their EIV system access. Once access is established, management should implement procedures to ensure all required EIV reports are generated, retained, and reviewed in accordance with HUD guidelines. b. Action(s) Taken or Planned on the Finding Management acknowledged the challenges experienced in obtaining EIV access from HUD and stated that follow-up efforts are ongoing. Once access is granted by HUD as already approved, management will generate and maintain all required EIV reports and strengthen controls to ensure compliance with HUD requirements.
The Single Audit was not submitted to the Federal Audit Clearinghouse (FAC) within nine months after the fiscal year end of the Company for the year ended September 30, 2024. Cause: Management does not have controls in place to timely file its financial statements with the FAC. Effect or Potential Effect: Management is not in compliance with the requirement to timely submit the Single Audit to the FAC. Questioned Costs: None Context: Management does not have a process in place to ensure that all audits are submitted to the FAC timely. Identification as a Repeat Finding: No Recommendation: Management should implement procedures to ensure that the financial statements are submitted to the FAC in accordance with the FAC filing requirements. Auditor Noncompliance Code: Z - Other Finding Resolution Status: Resolved Views of Responsible Officials: Management agrees with the finding and is taking steps to address the issue that caused it.
Show full finding ▾Hide full finding ▴Finding No. 2025-005 - Reporting U.S. Department of Housing and Urban Development Federal Program Name: Section 202 Supportive Housing for the Elderly Assistance Listing Number: 14.157 Criteria: The FAC requires that the annual financial statements be submitted the earlier of 30 days after the report date or nine months after the fiscal year end. Condition: The Single Audit was not submitted to the Federal Audit Clearinghouse (FAC) within nine months after the fiscal year end of the Company for the year ended September 30, 2024. Cause: Management does not have controls in place to timely file its financial statements with the FAC. Effect or Potential Effect: Management is not in compliance with the requirement to timely submit the Single Audit to the FAC. Questioned Costs: None Context: Management does not have a process in place to ensure that all audits are submitted to the FAC timely. Identification as a Repeat Finding: No Recommendation: Management should implement procedures to ensure that the financial statements are submitted to the FAC in accordance with the FAC filing requirements. Auditor Noncompliance Code: Z - Other Finding Resolution Status: Resolved Views of Responsible Officials: Management agrees with the finding and is taking steps to address the issue that caused it.
5. Finding 2025-005 a. Comments on the Finding and Each Recommendation The auditee agrees with the finding. The auditee agrees with the recommendation to implement procedures to ensure that the financial statements are submitted to the FAC in accordance with the FAC filing requirements. b. Action(s) Taken or Planned on the Finding Management agrees with the finding and is taking steps to address the issue that caused it. Management was able to implement procedures to submit the 2025 audit within the 9-month period.
In connection with the procedures applied to a sample of 2 tenants that moved out of the project during the year, we noted 1 instance where management failed to refund the tenant security deposit and/or provide the tenant with an itemized list of charges deducted from the deposit within thirty days after the move-out date. Cause: Management did not have procedures in place regarding timely refunding of tenant security deposits which require refunds or notice to occur within the 30-day requirement established by HUD. Effect or Potential Effect: Management failed to comply with the HUD occupancy requirement to timely refund the tenant security deposits or to provide the tenant with a list of charges. Questioned Costs: $322 Context: Management did not have monitoring procedures in place to ensure timely refunding of tenant security deposits to the tenant or to their estate. Due to errors with the software input an incorrect report was provided to accounting showing no amounts owed to the tenant at move out. Identification as a Repeat Finding: Yes Recommendation: Management should change its policies and procedures related to refunding of tenant security deposits to comply with the thirty-day timeline required by HUD regulations. Auditor Noncompliance Code: M - Security Deposits Finding Resolution Status: In Process Views of Responsible Officials: Management is still reviewing and updating the processes and procedures with site personnel to strengthen controls over the refunding of tenant security deposits.
Show full finding ▾Hide full finding ▴Finding No. 2025-006 - Special Tests and Provisions U.S. Department of Housing and Urban Development Federal Program Name: Section 202 Supportive Housing for the Elderly Assistance Listing Number: 14.157 Criteria: In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs, within 30 days after the move-out date (or shorter time if required by state and/or local laws), management must either: refund the full security deposit plus accrued interest to a tenant that does not owe any amounts under the lease; or provide the tenant with an itemized list of any unpaid rent, damages to the unit, and an estimated cost for repair, along with a statement of the tenant’s rights under state and local laws. Condition: In connection with the procedures applied to a sample of 2 tenants that moved out of the project during the year, we noted 1 instance where management failed to refund the tenant security deposit and/or provide the tenant with an itemized list of charges deducted from the deposit within thirty days after the move-out date. Cause: Management did not have procedures in place regarding timely refunding of tenant security deposits which require refunds or notice to occur within the 30-day requirement established by HUD. Effect or Potential Effect: Management failed to comply with the HUD occupancy requirement to timely refund the tenant security deposits or to provide the tenant with a list of charges. Questioned Costs: $322 Context: Management did not have monitoring procedures in place to ensure timely refunding of tenant security deposits to the tenant or to their estate. Due to errors with the software input an incorrect report was provided to accounting showing no amounts owed to the tenant at move out. Identification as a Repeat Finding: Yes Recommendation: Management should change its policies and procedures related to refunding of tenant security deposits to comply with the thirty-day timeline required by HUD regulations. Auditor Noncompliance Code: M - Security Deposits Finding Resolution Status: In Process Views of Responsible Officials: Management is still reviewing and updating the processes and procedures with site personnel to strengthen controls over the refunding of tenant security deposits.
6. Finding 2025-006 a. Comments on the Finding and Each Recommendation The auditee agrees with the finding. The auditee agrees with the recommendation to change its policies and procedures related to refunding of tenant security deposits to comply with the thirty-day timeline required by HUD regulations. b. Action(s) Taken or Planned on the Finding Management agrees with the finding and is taking steps to address the issue that caused it. Management is still reviewing and updating the processes and procedures with site personnel to strengthen controls over the refunding of tenant security deposits.
2024-006
FAC accepted this audit on September 23, 2025 — management decision was due March 23, 2026.
During the year ended September 30, 2024, the project did not make the required monthly deposits to the replacement reserve in the amount of $74,376. The project is required to make monthly deposits to the reserve in the amount of $6,198 per month, or $74,376 for the year. Cause: The project does not generate sufficient cash flow to make the required monthly deposits, due to significant delays in receipt of PRAC funds for over a year. Effect or Potential Effect: Failure to make monthly payments resulted in an underfunding the replacement reserve and a violation of the PRAC subsidy contract. Questioned Costs: Twelve months of missing replacement reserve deposits of $6,198 per month - $74,376 Context: Due to significant delays in receipt of PRAC funds for over a year, management suspended making the deposits to the reserve until PRAC funding was replenished. Management also borrowed funds from the replacement reserve which funds were repaid during the year ended September 30, 2024 once past-due PRAC funds were received. Identification as a Repeat Finding: No Recommendation: Management should review the project budget to determine if nonessential costs can be cut (or request a loan from the owner) to ensure that the replacement reserve is funded in accordance with the terms of the regulatory agreement. Management should obtain from HUD a waiver for the missing replacement reserve deposits if possible. If not granted, management should fund the missing deposits. Auditor Noncompliance Code: N – Replacement reserve deposits Finding Resolution Status: In process Views of Responsible Officials: Due to significant delays in receipt of PRAC funds for over a year, management suspended making the deposits to the reserve until PRAC funding was replenished. Management also borrowed funds from the replacement reserve which funds were repaid during the year ended September 30, 2024 once past-due PRAC funds were received.
Show full finding ▾Hide full finding ▴Finding No. 2024-003 – Special Tests and Provisions U.S. Department of Housing and Urban Development Federal Program Name: Section 202 Supportive Housing for the Elderly Assistance Listing Number: 14.157 Criteria: The Section 202 Project Rental Assistance Contract (PRAC contract) requires that the project make monthly deposits to its replacement reserve. Condition: During the year ended September 30, 2024, the project did not make the required monthly deposits to the replacement reserve in the amount of $74,376. The project is required to make monthly deposits to the reserve in the amount of $6,198 per month, or $74,376 for the year. Cause: The project does not generate sufficient cash flow to make the required monthly deposits, due to significant delays in receipt of PRAC funds for over a year. Effect or Potential Effect: Failure to make monthly payments resulted in an underfunding the replacement reserve and a violation of the PRAC subsidy contract. Questioned Costs: Twelve months of missing replacement reserve deposits of $6,198 per month - $74,376 Context: Due to significant delays in receipt of PRAC funds for over a year, management suspended making the deposits to the reserve until PRAC funding was replenished. Management also borrowed funds from the replacement reserve which funds were repaid during the year ended September 30, 2024 once past-due PRAC funds were received. Identification as a Repeat Finding: No Recommendation: Management should review the project budget to determine if nonessential costs can be cut (or request a loan from the owner) to ensure that the replacement reserve is funded in accordance with the terms of the regulatory agreement. Management should obtain from HUD a waiver for the missing replacement reserve deposits if possible. If not granted, management should fund the missing deposits. Auditor Noncompliance Code: N – Replacement reserve deposits Finding Resolution Status: In process Views of Responsible Officials: Due to significant delays in receipt of PRAC funds for over a year, management suspended making the deposits to the reserve until PRAC funding was replenished. Management also borrowed funds from the replacement reserve which funds were repaid during the year ended September 30, 2024 once past-due PRAC funds were received.
Project Legal Name: Evangeline Booth Residence, Inc., A Florida Corporation HUD Project No.: 063-EE011-WAH Audit Firm: CohnReznick LLP Period covered by the audit: 10/1/2023 – 9/30/2024 Corrective Action Plan prepared by: Name: Lee Auvenshine Position: Territorial Legal Director-General Counsel (THQ legal) Telephone Number: 404-728-6700 Finding 2024-003 Comments on the Finding and Each Recommendation The auditee agrees that replacement reserve deposits were not made. This was a result of significant delays in PRAC funding that severely affected cash flows. Action(s) Taken or Planned on the Finding Once the PRAC issues were corrected our cash flows have improved to allow us to make past due deposits. We will also reach out to our HUD account executive to discuss possible waiving of past due deposits.
During the year ended September 30, 2024, management withdrew $189,293 from the replacement reserve, for which $139,292 was not supported with a form 9250 signed by the HUD account executive. Cause: The project did not obtain or retain HUD-signed copies of the form HUD-9250 for all replacement reserve withdrawals and was therefore unable to provide evidence of HUD approval to the auditor. Effect or Potential Effect: Failure to retain documentation of HUD approval results in the conclusion the withdrawal was an unauthorized withdrawal from the replacement reserve account. Questioned Costs: Three withdrawals totaling $139,292 were missing HUD’s signature on the Form HUD-9250 Context: Due to significant delays in receipt of PRAC funds for over a year, management borrowed funds from the replacement reserve, which funds were repaid during the year ended September 30, 2024 once past-due PRAC funds were received. Management received an email from their HUD Account Executive explaining how to request the withdrawals, however, management did not retain signed copies of the form 9250 signed by HUD for their records. Identification as a Repeat Finding: No Recommendation: Management should implement procedures to ensure every request for a replacement reserve withdrawal is supported with a HUD-signed form 9250, or management should repay the remaining unsupported $39,292. Auditor Noncompliance Code: A – Unauthorized withdrawals from the replacement reserve account Finding Resolution Status: In process Views of Responsible Officials: Management repaid $250,000 of PRAC loans during the year ended September 30, 2024, including repayment of $100,000 of 2024 PRAC loans that did not have signed HUD-9250 support. The remaining replacement reserve withdrawal without evidence of HUD approval of $39,292 should either be repaid or management should obtain from the HUD Account Executive documentation they approved the withdrawal.
Show full finding ▾Hide full finding ▴Finding No. 2024-004 – Special Tests and Provisions U.S. Department of Housing and Urban Development Federal Program Name: Section 202 Supportive Housing for the Elderly Assistance Listing Number: 14.157 Criteria: Any withdrawal from the replacement reserve account requires evidence of HUD approval. Condition: During the year ended September 30, 2024, management withdrew $189,293 from the replacement reserve, for which $139,292 was not supported with a form 9250 signed by the HUD account executive. Cause: The project did not obtain or retain HUD-signed copies of the form HUD-9250 for all replacement reserve withdrawals and was therefore unable to provide evidence of HUD approval to the auditor. Effect or Potential Effect: Failure to retain documentation of HUD approval results in the conclusion the withdrawal was an unauthorized withdrawal from the replacement reserve account. Questioned Costs: Three withdrawals totaling $139,292 were missing HUD’s signature on the Form HUD-9250 Context: Due to significant delays in receipt of PRAC funds for over a year, management borrowed funds from the replacement reserve, which funds were repaid during the year ended September 30, 2024 once past-due PRAC funds were received. Management received an email from their HUD Account Executive explaining how to request the withdrawals, however, management did not retain signed copies of the form 9250 signed by HUD for their records. Identification as a Repeat Finding: No Recommendation: Management should implement procedures to ensure every request for a replacement reserve withdrawal is supported with a HUD-signed form 9250, or management should repay the remaining unsupported $39,292. Auditor Noncompliance Code: A – Unauthorized withdrawals from the replacement reserve account Finding Resolution Status: In process Views of Responsible Officials: Management repaid $250,000 of PRAC loans during the year ended September 30, 2024, including repayment of $100,000 of 2024 PRAC loans that did not have signed HUD-9250 support. The remaining replacement reserve withdrawal without evidence of HUD approval of $39,292 should either be repaid or management should obtain from the HUD Account Executive documentation they approved the withdrawal.
Finding 2024-004 Comments on the Finding and Each Recommendation The auditee agrees that retained replacement reserve withdrawal forms did not include HUD signature, though HUD did approve the withdrawals. Action(s) Taken or Planned on the Finding Management will reach out to HUD to obtain evidence of approval of the specific withdrawal in question. Management will implement procedures to request from HUD and retain a copy of each signed 9250 going forward.
During the procedures applied to a sample of 8 tenant lease files, we noted the following instances of noncompliance with HUD regulations regarding tenant eligibility and the maintenance of lease files. 1. 2 instances where the project did not maintain the move in/ move out inspection forms in the lease files. 2. 1 instance where the project was unable to provide evidence of the 50059 for the tenant file. 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 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: None Context: Management has had some issues with accessing HUD’s systems, as well as issues with the set up of the third party vendor software used to interact with HUD’s systems. This has resulted in their inability to obtain required documentation for certain tenant lease files. Additionally, not all tenants return move in / move out forms. Identification as a Repeat Finding: No Recommendation: Management should establish procedures and monitor compliance with those procedures to ensure that tenant eligibility is correctly determined and fully documented, 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 program administration Finding Resolution Status: In process Views of Responsible Officials: Management will review the processes and procedures with site personnel to strengthen controls over the maintenance of tenant lease files.
Show full finding ▾Hide full finding ▴Finding No. 2024-005 – Eligibility U.S. Department of Housing and Urban Development Federal Program Name: Section 202 Supportive Housing for the Elderly Assistance Listing Number: 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: During the procedures applied to a sample of 8 tenant lease files, we noted the following instances of noncompliance with HUD regulations regarding tenant eligibility and the maintenance of lease files. 1. 2 instances where the project did not maintain the move in/ move out inspection forms in the lease files. 2. 1 instance where the project was unable to provide evidence of the 50059 for the tenant file. 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 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: None Context: Management has had some issues with accessing HUD’s systems, as well as issues with the set up of the third party vendor software used to interact with HUD’s systems. This has resulted in their inability to obtain required documentation for certain tenant lease files. Additionally, not all tenants return move in / move out forms. Identification as a Repeat Finding: No Recommendation: Management should establish procedures and monitor compliance with those procedures to ensure that tenant eligibility is correctly determined and fully documented, 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 program administration Finding Resolution Status: In process Views of Responsible Officials: Management will review the processes and procedures with site personnel to strengthen controls over the maintenance of tenant lease files.
Finding 2024-005 Comments on the Finding and Each Recommendation We agree tenant files were missing some required information. This is due in part to staffing issues onsite as well as HUD EIV site access issues that our HUD Account Executive has been made aware of and is working with us on resolving. Action(s) Taken or Planned on the Finding Management will review the processes and procedures with site personnel to strengthen controls over the maintenance of tenant lease files. We have communicated to and with our HUD Account Executive regarding the issues, and we have been told they will work to help us resolve these issues on their end.
In connection with the procedures applied to a sample of 7 tenants that moved out of the project during the year, we noted 2 instances where management failed to refund the tenant security deposit and/or provide the tenant with an itemized list of charges deducted from the deposit within thirty days after the move-out date. Cause: Management did not have procedures in place regarding timely refunding of tenant security deposits which require refunds or notice to occur within the 30-day requirement established by HUD. Effect or Potential Effect: Management failed to comply with the HUD occupancy requirement to timely refund the tenant security deposits or to provide the tenant with a list of charges. Questioned Costs: None Context: Management did not have monitoring procedures in place to ensure timely refunding of tenant security deposits to the tenant or to their estate. Identification as a Repeat Finding: No Recommendation: Management should change its policies and procedures related to refunding of tenant security deposits to comply with the thirty-day timeline required by HUD regulations. Auditor Noncompliance Code: M – Security Deposits Finding Resolution Status: In process Views of Responsible Officials: Management will review the processes and procedures with site personnel to strengthen controls over the refunding of tenant security deposits.
Show full finding ▾Hide full finding ▴Finding No. 2024-006 – Special Tests and Provisions U.S. Department of Housing and Urban Development Federal Program Name: Section 202 Supportive Housing for the Elderly Assistance Listing Number: 14.157 Criteria: In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs, within 30 days after the move-out date (or shorter time if required by state and/or local laws), management must either: refund the full security deposit plus accrued interest to a tenant that does not owe any amounts under the lease; or provide the tenant with an itemized list of any unpaid rent, damages to the unit, and an estimated cost for repair, along with a statement of the tenant’s rights under state and local laws. Condition: In connection with the procedures applied to a sample of 7 tenants that moved out of the project during the year, we noted 2 instances where management failed to refund the tenant security deposit and/or provide the tenant with an itemized list of charges deducted from the deposit within thirty days after the move-out date. Cause: Management did not have procedures in place regarding timely refunding of tenant security deposits which require refunds or notice to occur within the 30-day requirement established by HUD. Effect or Potential Effect: Management failed to comply with the HUD occupancy requirement to timely refund the tenant security deposits or to provide the tenant with a list of charges. Questioned Costs: None Context: Management did not have monitoring procedures in place to ensure timely refunding of tenant security deposits to the tenant or to their estate. Identification as a Repeat Finding: No Recommendation: Management should change its policies and procedures related to refunding of tenant security deposits to comply with the thirty-day timeline required by HUD regulations. Auditor Noncompliance Code: M – Security Deposits Finding Resolution Status: In process Views of Responsible Officials: Management will review the processes and procedures with site personnel to strengthen controls over the refunding of tenant security deposits.
Finding 2024-006 Comments on the Finding and Each Recommendation We agree two tenants were not reimbursed their security deposits timely. This is due in part to staffing issues onsite as well as not having an address to forward the security deposits to upon the former tenant’s demise. Action(s) Taken or Planned on the Finding Management will review the processes and procedures with site personnel to strengthen controls over the refund of tenant security deposits. If we are late due to missing appropriate forwarding addresses, we will add documentation in the tenant files of those efforts to support our compliance with HUD procedures.
FAC accepted this audit on June 27, 2024 — management decision was due December 27, 2024.
Department of Housing and Urban Development Finding 2023-002 Section 202 Supportive Housing for the Elderly, AL 14.157 Statement of Condition In connection with our lease file review we noted the following deficiencies: 1 out of 1 move-in tenants and 2 out of 6 existing tenants tested did not have documentation in their lease file that their income was verified using HUD's Enterprise Income Verification (EIV). Criteria Management is required to use EIV as a third party source to verify tenant employment and income information during mandatory recertifications of family composition and income, in accordance with 24 CFR 5.233 and administrative guidance issued by HUD. 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. Cause Access to the EIV system [the system used to access Social Security information and Health and Human Services information] was not available due to the incorrect tax ID being identified to The Salvation Army personnel who had transitioned from another The Salvation Army HUD Project location. It took considerable efforts to get this corrected with HUD. The appropriate access to the system has now been given to the new personnel of the Ocala HUD Project. This lack of access impacted FY 2022 and the early part of FY 2023. Recommendation 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: R - Section 8 program administration (REAC); E – Eligibility (UG) Finding Resolution Status: Resolved. Access to the Enterprise Income Verification (EIV) system [the system used to access Social Security information and Health and Human Services information] was not available due to the incorrect tax ID being identified to The Salvation Army personnel who had transitioned from another The Salvation Army HUD Project location. It took considerable efforts to get this corrected with HUD. The appropriate access to the system has now been given to the new personnel of this Ocala HUD Project. This lack of access impacted the early part of FY 2023. Reporting Views of Responsible Officials See comments under Finding Resolution Status.
Show full finding ▾Hide full finding ▴Department of Housing and Urban Development Finding 2023-002 Section 202 Supportive Housing for the Elderly, AL 14.157 Statement of Condition In connection with our lease file review we noted the following deficiencies: 1 out of 1 move-in tenants and 2 out of 6 existing tenants tested did not have documentation in their lease file that their income was verified using HUD's Enterprise Income Verification (EIV). Criteria Management is required to use EIV as a third party source to verify tenant employment and income information during mandatory recertifications of family composition and income, in accordance with 24 CFR 5.233 and administrative guidance issued by HUD. 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. Cause Access to the EIV system [the system used to access Social Security information and Health and Human Services information] was not available due to the incorrect tax ID being identified to The Salvation Army personnel who had transitioned from another The Salvation Army HUD Project location. It took considerable efforts to get this corrected with HUD. The appropriate access to the system has now been given to the new personnel of the Ocala HUD Project. This lack of access impacted FY 2022 and the early part of FY 2023. Recommendation 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: R - Section 8 program administration (REAC); E – Eligibility (UG) Finding Resolution Status: Resolved. Access to the Enterprise Income Verification (EIV) system [the system used to access Social Security information and Health and Human Services information] was not available due to the incorrect tax ID being identified to The Salvation Army personnel who had transitioned from another The Salvation Army HUD Project location. It took considerable efforts to get this corrected with HUD. The appropriate access to the system has now been given to the new personnel of this Ocala HUD Project. This lack of access impacted the early part of FY 2023. Reporting Views of Responsible Officials See comments under Finding Resolution Status.
Project Legal Name: Evangeline Booth Residence, Inc., a Florida Corporation HUD Project No.: 063-EE011-WAH Audit Firm: CohnReznick LLP Period covered by the audit: 10/1/2022-9/30/2023 Corrective Action Plan prepared by: Name: Sriparna Mitra Position: HUD Specialist, THQ (Legal) Telephone Number: 404-728-6700 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 2023-002 a. Comments on the Finding and Each Recommendation Management agrees with the finding and is taking steps to address the issue that caused it. b. Action(s) Taken or Planned on the Finding Procedures for accruing revenue, as appropriate, will be put in place as the accruing of expenses is already done. 2. Finding 2023-002 c. Comments on the Finding and Each Recommendation Management agrees with the finding and is taking steps to address the issue that caused it. d. Action(s) Taken or Planned on the Finding Access to the Enterprise Income Verification (EIV) system [the system used to access Social Security information and Health and Human Services information] was not available due to the incorrect tax ID being identified to The Salvation Army personnel who had transitioned from another The Salvation Army HUD Project location. It took considerable efforts to get this corrected with HUD. The appropriate access to the system has now been given to the new personnel of this Ocala HUD Project. This lack of access impacted the early part of FY 2023 B. Status of Corrective Actions on Findings Reported in the Schedule of the Status of Prior Audit Findings, Questioned Costs and Recommendations 1. Finding 2022-001 In Process. See finding 2023-001 2. Finding 2021-001 In Process. See finding 2023-001
2022-001
FAC accepted this audit on February 27, 2023 — management decision was due August 27, 2023.
Department of Housing and Urban Development Finding 2022-001 Section 202 Supportive Housing for the Elderly, AL 14.157 Statement of Condition In connection with our lease file review we noted the following deficiencies: 1 out of 1 move-in tenants tested did not have documentation in their lease file that their income was timely verified. 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. 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. 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. Recommendation 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: R - Section 8 program administration (REAC); E - Eligibility (UG) Finding Resolution Status: In process. Access to the Enterprise Income Verification (EIV) system [the system used to access Social Security information and Health and Human Services information] was not available due to the incorrect tax ID being identified to The Salvation Army personnel who had transitioned from another The Salvation Army HUD Project location. It took considerable efforts to get this corrected with HUD. The appropriate access to the system has now been given to the new personnel of this Ocala HUD Project. This lack of access may have impacted the early part of FY 2023. Reporting Views of Responsible Officials Management agrees with the finding and is taking steps to address the issue that caused it.
Show full finding ▾Hide full finding ▴Department of Housing and Urban Development Finding 2022-001 Section 202 Supportive Housing for the Elderly, AL 14.157 Statement of Condition In connection with our lease file review we noted the following deficiencies: 1 out of 1 move-in tenants tested did not have documentation in their lease file that their income was timely verified. 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. 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. 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. Recommendation 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: R - Section 8 program administration (REAC); E - Eligibility (UG) Finding Resolution Status: In process. Access to the Enterprise Income Verification (EIV) system [the system used to access Social Security information and Health and Human Services information] was not available due to the incorrect tax ID being identified to The Salvation Army personnel who had transitioned from another The Salvation Army HUD Project location. It took considerable efforts to get this corrected with HUD. The appropriate access to the system has now been given to the new personnel of this Ocala HUD Project. This lack of access may have impacted the early part of FY 2023. Reporting Views of Responsible Officials Management agrees with the finding and is taking steps to address the issue that caused it.
CORRECTIVE ACTION PLAN Project Legal Name: Evangeline Booth Garden Apartments Ocala, FL (A Project of Evangeline Booth Residence, Inc., a Florida Corporation) HUD Project No.: 063-EE011-WAH Audit Firm: CohnReznick LLP Period covered by the audit: 10/1/2021-9/30/2022 Corrective Action Plan prepared by: Name: Sriparna Mitra Position: HUD Specialist, THQ (Legal) Telephone Number: 404-728-6700 A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Finding 2022-001 a. Comments on the Finding and Each Recommendation Management agrees with the finding and is taking steps to address the issue that caused it. b. Action(s) Taken or Planned on the Finding Access to the Enterprise Income Verification (EIV) system [the system used to access Social Security information and Health and Human Services information] was not available due to the incorrect tax ID being identified to The Salvation Army personnel who had transitioned from another The Salvation Army HUD Project location. It took considerable efforts to get this corrected with HUD. The appropriate access to the system has now been given to the new personnel of this Ocala HUD Project. This lack of access may have impacted the early part of FY 2023. B. Status of Corrective Actions on Findings Reported in the Schedule of the Status of Prior Year Findings, Questioned Costs and Recommendations 1. Finding 2021-001 In Process. See finding 2022-001 2. Finding 2021-002 Cleared. 3. Finding 2021-003 Cleared.
2021-001
FAC accepted this audit on June 27, 2022 — management decision was due December 27, 2022.
Department of Housing and Urban Development Finding 2021-001 Section 202 Capital Advance, CFDA 14.157 Statement of Condition In connection with our lease file review we noted the following deficiencies: 1 out of 2 move-in tenants tested did not have documentation in their lease file that their income was timely verified. 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. 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. 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. 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 program administration Finding Resolution Status: Resolved Reporting Views of Responsible Officials Management agrees with the finding and is taking steps to address the issue that caused it.
Show full finding ▾Hide full finding ▴Department of Housing and Urban Development Finding 2021-001 Section 202 Capital Advance, CFDA 14.157 Statement of Condition In connection with our lease file review we noted the following deficiencies: 1 out of 2 move-in tenants tested did not have documentation in their lease file that their income was timely verified. 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. 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. 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. 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 program administration Finding Resolution Status: Resolved Reporting Views of Responsible Officials Management agrees with the finding and is taking steps to address the issue that caused it.
1. Finding 2021-001 a. Comments on the Finding and Each Recommendation The auditee agrees with the finding. The auditee agrees with the 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. b. Action(s) Taken or Planned on the Finding Management agrees with the finding and is taking steps to address the issue that caused it.
Department of Housing and Urban Development Finding 2021-002 Section 202 Capital Advance, CFDA 14.157 Statement of Condition In connection with the procedures applied to a sample of 1 tenant that moved out of the Project during the year, we noted 1 instance where management failed to refund the tenant security deposit and/or provide the tenant with an itemized list of charges deducted from the deposit within thirty days after the move-out date. Criteria In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs, within 30 days after the move-out date, management must either: refund the full security deposit plus accrued interest to a tenant that does not owe any amounts under the lease; or provide the tenant with an itemized list of any unpaid rent, damages to the unit, and an estimated cost for repair, along with a statement of the tenant's rights under state and local laws. Effect Management failed to comply with the HUD occupancy requirement to timely refund the tenant security deposits or to provide the tenant with a list of charges. Cause Management did not follow both local laws and requirements established by HUD regarding timely refunding of tenant security deposits. HUD requires tenant security deposit refunds to occur within 30 days after the move-out date. Local laws require tenant security deposit refunds to occur within 60 days after the move-out date, however, a notice must be provided within 30 days of move-out. Recommendation Management should change its policies and procedures related to refunding of tenant security deposits to comply with the thirty-day timeline required by HUD regulations. Auditor Noncompliance Code: M - Security deposits Finding Resolution Status: Resolved Reporting Views of Responsible Officials Management agrees with the finding and is taking steps to address the issue that caused it.
Show full finding ▾Hide full finding ▴Department of Housing and Urban Development Finding 2021-002 Section 202 Capital Advance, CFDA 14.157 Statement of Condition In connection with the procedures applied to a sample of 1 tenant that moved out of the Project during the year, we noted 1 instance where management failed to refund the tenant security deposit and/or provide the tenant with an itemized list of charges deducted from the deposit within thirty days after the move-out date. Criteria In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs, within 30 days after the move-out date, management must either: refund the full security deposit plus accrued interest to a tenant that does not owe any amounts under the lease; or provide the tenant with an itemized list of any unpaid rent, damages to the unit, and an estimated cost for repair, along with a statement of the tenant's rights under state and local laws. Effect Management failed to comply with the HUD occupancy requirement to timely refund the tenant security deposits or to provide the tenant with a list of charges. Cause Management did not follow both local laws and requirements established by HUD regarding timely refunding of tenant security deposits. HUD requires tenant security deposit refunds to occur within 30 days after the move-out date. Local laws require tenant security deposit refunds to occur within 60 days after the move-out date, however, a notice must be provided within 30 days of move-out. Recommendation Management should change its policies and procedures related to refunding of tenant security deposits to comply with the thirty-day timeline required by HUD regulations. Auditor Noncompliance Code: M - Security deposits Finding Resolution Status: Resolved Reporting Views of Responsible Officials Management agrees with the finding and is taking steps to address the issue that caused it.
Finding 2021-002 a. Comments on the Finding and Each Recommendation The auditee agrees with the finding. The auditee agrees with the recommendation management should change its policies and procedures related to refunding of tenant security deposits to comply with the thirty-day timeline required by HUD regulations. b. Action(s) Taken or Planned on the Finding Management agrees with the finding and is taking steps to address the issue that caused it.
Department of Housing and Urban Development Finding 2021-003 Section 202 Capital Advance, CFDA 14.157 Statement of Condition The Single Audit was not submitted to the Federal Audit Clearinghouse (FAC) within nine months after the fiscal year end of the Company for the year ended September 30, 2020. Criteria The FAC requires that the annual financial statements be submitted the earlier of 30 days after the report date or nine months after the fiscal year end. Effect Management is not in compliance with the requirement to timely submit the Single Audit to the FAC. Cause Management does not have controls in place to timely file its financial statements with the FAC. Recommendation Management should implement procedures to ensure that the financial statements are submitted to the FAC in accordance with the FAC filing requirements. Auditor Noncompliance Code: L - Reporting (FAC) , Z - Other (REAC) Finding Resolution Status: Resolved Reporting Views of Responsible Officials Management agrees with the finding and is taking steps to address the issue that caused it.
Show full finding ▾Hide full finding ▴Department of Housing and Urban Development Finding 2021-003 Section 202 Capital Advance, CFDA 14.157 Statement of Condition The Single Audit was not submitted to the Federal Audit Clearinghouse (FAC) within nine months after the fiscal year end of the Company for the year ended September 30, 2020. Criteria The FAC requires that the annual financial statements be submitted the earlier of 30 days after the report date or nine months after the fiscal year end. Effect Management is not in compliance with the requirement to timely submit the Single Audit to the FAC. Cause Management does not have controls in place to timely file its financial statements with the FAC. Recommendation Management should implement procedures to ensure that the financial statements are submitted to the FAC in accordance with the FAC filing requirements. Auditor Noncompliance Code: L - Reporting (FAC) , Z - Other (REAC) Finding Resolution Status: Resolved Reporting Views of Responsible Officials Management agrees with the finding and is taking steps to address the issue that caused it.
Finding 2021-003 c. Comments on the Finding and Each Recommendation The auditee agrees with the finding. The auditee agrees with the recommendation to implement procedures to ensure that the financial statements are submitted to the FAC in accordance with the FAC filing requirements. d. Action(s) Taken or Planned on the Finding The filing was submitted and management has implemented procedures to ensure the 2021 audit was filed timely with the FAC.
FAC accepted this audit on May 3, 2022 — management decision was due November 3, 2022.
FAC accepted this audit on June 7, 2020 — management decision was due December 7, 2020.
FAC accepted this audit on June 23, 2019 — management decision was due December 23, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on July 17, 2018 — management decision was due January 17, 2019.
FAC accepted this audit on May 15, 2017 — management decision was due November 15, 2017.
GSA_MIGRATION
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GSA_MIGRATION
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