Villa South (III) d/b/a Villa Madonna III Apartments, Inc.

EIN: 611360816

UEI: PN2NLSJPSJB7

Data as of August 27, 2026

Villa South (III) d/b/a Villa Madonna III Apartments, Inc.9 audit years10 findings2 repeat
9
Audit Years
10
Total Findings
2
Repeat Findings

FY 2022-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on April 26, 2023. 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 October 26, 2023 (1036 days ago).

What is a management decision? →
2022-001
Other
QUESTIONED COSTS

S3800-010 Finding Reference Number ? 2022-001 S3800-011 Title and CFDA Number of Federal Program ? Section 202 Capital Advance 14.157 S3800-015 Type of Finding ? Federal Award S3800-016 Finding Resolution Status ? Unresolved S3800-017 Information on Universe Population Size ? N/A S3800-018 Sample Size Information ? N/A S3800-019 Identification of Repeat Finding and Finding Reference Number ? 2021-001 S3800-020 Criteria ? In accordance with the Regulatory Agreement, surplus cash is required to be deposited into a residual receipts account within 90 days of year-end. S3800-030 Statement of Condition ? Surplus cash was not deposited into a residual receipts account within 90 days of year-end. S3800-032 Cause ? Management was unaware of the requirement for the prior year audit. S3800-033 Effect or Potential Effect ? The Project is in violation of the Regulatory Agreement. S3800-035 Auditor Non-Compliance Code ? B S3800-040 Questioned Costs ? $3,811 S3800-045 Reporting Views of Responsible Officials ? Management will reference the audit in future years to ensure proper deposits are made in a timely manner. S3800-050 Context ? Management will ensure the residual receipts deposits are made in a timely manner. S3800-080 Recommendation ? Management should ensure surplus cash is calculated in a timely matter in order to make any required deposit to the residual receipts account. S3800-090 Auditor?s Summary of the Auditee?s Comments on the Finding and Recommendations ? Management will reference the audit in future years to ensure proper deposits are made in a timely manner. S3800-130 Response Indicator ? Agree S3800-140 Completion Date ? May 2, 2022 S3800-150 Response ? Management will ensure surplus cash is calculated in a timely manner in order to make the required residual receipts deposit.

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Full finding narrative

S3800-010 Finding Reference Number ? 2022-001 S3800-011 Title and CFDA Number of Federal Program ? Section 202 Capital Advance 14.157 S3800-015 Type of Finding ? Federal Award S3800-016 Finding Resolution Status ? Unresolved S3800-017 Information on Universe Population Size ? N/A S3800-018 Sample Size Information ? N/A S3800-019 Identification of Repeat Finding and Finding Reference Number ? 2021-001 S3800-020 Criteria ? In accordance with the Regulatory Agreement, surplus cash is required to be deposited into a residual receipts account within 90 days of year-end. S3800-030 Statement of Condition ? Surplus cash was not deposited into a residual receipts account within 90 days of year-end. S3800-032 Cause ? Management was unaware of the requirement for the prior year audit. S3800-033 Effect or Potential Effect ? The Project is in violation of the Regulatory Agreement. S3800-035 Auditor Non-Compliance Code ? B S3800-040 Questioned Costs ? $3,811 S3800-045 Reporting Views of Responsible Officials ? Management will reference the audit in future years to ensure proper deposits are made in a timely manner. S3800-050 Context ? Management will ensure the residual receipts deposits are made in a timely manner. S3800-080 Recommendation ? Management should ensure surplus cash is calculated in a timely matter in order to make any required deposit to the residual receipts account. S3800-090 Auditor?s Summary of the Auditee?s Comments on the Finding and Recommendations ? Management will reference the audit in future years to ensure proper deposits are made in a timely manner. S3800-130 Response Indicator ? Agree S3800-140 Completion Date ? May 2, 2022 S3800-150 Response ? Management will ensure surplus cash is calculated in a timely manner in order to make the required residual receipts deposit.

Corrective Action Plan

Villa South (III) d/b/a Villa Madonna III Apartments, Inc. respectfully submits the following Corrective Action Plan for the year ended December 31, 2022. Name and address of the independent public accounting firm who conducted the related audit: Comer, Nowling And Associates, P.C. 10475 Crosspoint Boulevard, Suite 200 Indianapolis, Indiana 46256 Finding 2022-001 Corrective Action Planned ? Management will deposit the $3,403 of delinquent deposits into the residual receipts account as soon as possible. Management will implement controls to ensure the proper deposits are made in the future. Contact Person(s) Responsible ? Amy Hobbs, Property Manager Anticipated Completion Date ? 05/31/2023 Auditee Disagreements ? N/A This corrective action plan was prepared by Brookside Development Corporation Management, the management company, on behalf of Villa South (III) d/b/a Villa Madonna III Apartments, Inc.. ?????????_____________________________ _________________ Name, Title Date Brookside Development Corporation Management 312 Brookside Drive Mayfield, KY 42006 (270) 247-6391

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FY 2021-12-31

FAC accepted this audit on June 23, 2022 — management decision was due December 23, 2022.

2021-001
Other
QUESTIONED COSTS

S3800-010 Finding Reference Number ? 2021-001 S3800-011 Title and CFDA Number of Federal Program ? Section 202 Capital Advance 14.157 S3800-015 Type of Finding ? Federal Award S3800-016 Finding Resolution Status ? Unresolved S3800-017 Information on Universe Population Size ? N/A S3800-018 Sample Size Information ? N/A S3800-019 Identification of Repeat Finding and Finding Reference Number ? 2020-001 S3800-020 Criteria ? In accordance with the Regulatory Agreement, surplus cash is required to be deposited into a residual receipts account within 90 days of year-end. S3800-030 Statement of Condition ? Surplus cash was not deposited into a residual receipts account within 90 days of year-end. S3800-032 Cause ? Management was unaware of the requirement for the prior year audit. S3800-033 Effect or Potential Effect ? The Project is in violation of the Regulatory Agreement. S3800-035 Auditor Non-Compliance Code ? B S3800-040 Questioned Costs ? $3,403 S3800-045 Reporting Views of Responsible Officials ? Management will reference the audit in future years to ensure proper deposits are made in a timely manner. S3800-050 Context ? Management will ensure the residual receipts deposits are made in a timely manner. S3800-080 Recommendation ? Management should ensure surplus cash is calculated in a timely matter in order to make any required deposit to the residual receipts account. S3800-090 Auditor?s Summary of the Auditee?s Comments on the Finding and Recommendations ? Management will reference the audit in future years to ensure proper deposits are made in a timely manner. S3800-130 Response Indicator ? Agree S3800-140 Completion Date ? November 18, 2021 S3800-150 Response ? Management will ensure surplus cash is calculated in a timely manner in order to make the required residual receipts deposit.

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Full finding narrative

S3800-010 Finding Reference Number ? 2021-001 S3800-011 Title and CFDA Number of Federal Program ? Section 202 Capital Advance 14.157 S3800-015 Type of Finding ? Federal Award S3800-016 Finding Resolution Status ? Unresolved S3800-017 Information on Universe Population Size ? N/A S3800-018 Sample Size Information ? N/A S3800-019 Identification of Repeat Finding and Finding Reference Number ? 2020-001 S3800-020 Criteria ? In accordance with the Regulatory Agreement, surplus cash is required to be deposited into a residual receipts account within 90 days of year-end. S3800-030 Statement of Condition ? Surplus cash was not deposited into a residual receipts account within 90 days of year-end. S3800-032 Cause ? Management was unaware of the requirement for the prior year audit. S3800-033 Effect or Potential Effect ? The Project is in violation of the Regulatory Agreement. S3800-035 Auditor Non-Compliance Code ? B S3800-040 Questioned Costs ? $3,403 S3800-045 Reporting Views of Responsible Officials ? Management will reference the audit in future years to ensure proper deposits are made in a timely manner. S3800-050 Context ? Management will ensure the residual receipts deposits are made in a timely manner. S3800-080 Recommendation ? Management should ensure surplus cash is calculated in a timely matter in order to make any required deposit to the residual receipts account. S3800-090 Auditor?s Summary of the Auditee?s Comments on the Finding and Recommendations ? Management will reference the audit in future years to ensure proper deposits are made in a timely manner. S3800-130 Response Indicator ? Agree S3800-140 Completion Date ? November 18, 2021 S3800-150 Response ? Management will ensure surplus cash is calculated in a timely manner in order to make the required residual receipts deposit.

Corrective Action Plan

Corrective Action Plan Villa South (III) d/b/a Villa Madonna III Apartments, Inc. For the Year Ended December 31, 2021 Villa South (III) d/b/a Villa Madonna III Apartments, Inc. respectfully submits the following Corrective Action Plan for the year ended December 31, 2021. Name and address of the independent public accounting firm who conducted the related audit: Comer, Nowling And Associates, P.C. 10475 Crosspoint Boulevard, Suite 200 Indianapolis, Indiana 46256 Finding 2020-001 Corrective Action Planned ? Management will ensure residual receipts are deposited with in 90 days of year. Contact Person(s) Responsible ? Amy Hobbs, Property Manager Anticipated Completion Date ? 5/26/2022 Auditee Disagreements ? N/A This corrective action plan was prepared by Brookside Development Corporation Management, the management company, on behalf of Villa South (III) d/b/a Villa Madonna III Apartments, Inc.. Amy Hobbs _5/26/2022_______ Amy Hobbs, Property Manager Date Brookside Development Corporation Management 312 Brookside Drive Mayfield, KY 42006 (270) 247-6391

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FY 2020-12-31

FAC accepted this audit on May 2, 2021 — management decision was due November 2, 2021.

2020-001
Other
REPEAT

S3800-010 Finding Reference Number ? 2020-001 S3800-011 Title and CFDA Number of Federal Program ? Section 202 Capital Advance 14.157 S3800-015 Type of Finding ? Federal Award S3800-016 Finding Resolution Status ? Unresolved S3800-017 Information on Universe Population Size ? N/A S3800-018 Sample Size Information ? N/A S3800-019 Identification of Repeat Finding and Finding Reference Number ? 2019-001 S3800-020 Criteria ? In accordance with the Regulatory Agreement, surplus cash is required to be deposited into a residual receipts account within 90 days of year-end. S3800-030 Statement of Condition ? Surplus cash was not deposited into a residual receipts account within 90 days of year-end. S3800-032 Cause ? Management was unaware of the requirement for the prior year audit. S3800-033 Effect or Potential Effect ? The Project is in violation of the Regulatory Agreement. S3800-035 Auditor Non-Compliance Code ? B S3800-040 Questioned Costs ? $0 S3800-045 Reporting Views of Responsible Officials ? The new management company during the prior year was unable to obtain accounting information from the prior management company in a timely manner to calculate surplus cash and make the residual receipts deposit as required. S3800-050 Context ? The management company changed during the prior year, and the new management company was unable to obtain accounting information from the old management company prior to year-end. S3800-080 Recommendation ? Management should ensure surplus cash is calculated in a timely matter in order to make any required deposit to the residual receipts account. S3800-090 Auditor?s Summary of the Auditee?s Comments on the Finding and Recommendations ? The new management company was unable to obtain accounting information from the prior management company in a timely manner to calculate surplus cash. S3800-130 Response Indicator ? Agree S3800-140 Completion Date ? December 20, 2020 S3800-150 Response ? Management will ensure surplus cash is calculated in a timely manner in order to make the required residual receipts deposit.

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Full finding narrative

S3800-010 Finding Reference Number ? 2020-001 S3800-011 Title and CFDA Number of Federal Program ? Section 202 Capital Advance 14.157 S3800-015 Type of Finding ? Federal Award S3800-016 Finding Resolution Status ? Unresolved S3800-017 Information on Universe Population Size ? N/A S3800-018 Sample Size Information ? N/A S3800-019 Identification of Repeat Finding and Finding Reference Number ? 2019-001 S3800-020 Criteria ? In accordance with the Regulatory Agreement, surplus cash is required to be deposited into a residual receipts account within 90 days of year-end. S3800-030 Statement of Condition ? Surplus cash was not deposited into a residual receipts account within 90 days of year-end. S3800-032 Cause ? Management was unaware of the requirement for the prior year audit. S3800-033 Effect or Potential Effect ? The Project is in violation of the Regulatory Agreement. S3800-035 Auditor Non-Compliance Code ? B S3800-040 Questioned Costs ? $0 S3800-045 Reporting Views of Responsible Officials ? The new management company during the prior year was unable to obtain accounting information from the prior management company in a timely manner to calculate surplus cash and make the residual receipts deposit as required. S3800-050 Context ? The management company changed during the prior year, and the new management company was unable to obtain accounting information from the old management company prior to year-end. S3800-080 Recommendation ? Management should ensure surplus cash is calculated in a timely matter in order to make any required deposit to the residual receipts account. S3800-090 Auditor?s Summary of the Auditee?s Comments on the Finding and Recommendations ? The new management company was unable to obtain accounting information from the prior management company in a timely manner to calculate surplus cash. S3800-130 Response Indicator ? Agree S3800-140 Completion Date ? December 20, 2020 S3800-150 Response ? Management will ensure surplus cash is calculated in a timely manner in order to make the required residual receipts deposit.

Corrective Action Plan

Villa South (III) d/b/a Villa Madonna III Apartments, Inc. respectfully submits the following Corrective Action Plan for the year ended December 31, 2020. Name and address of the independent public accounting firm who conducted the related audit: Comer, Nowling And Associates, P.C. 10475 Crosspoint Boulevard, Suite 200 Indianapolis, Indiana 46256 Finding 2020-001 Corrective Action Planned ? Management will ensure surplus cash is calculated in a timely manner in order to make the required residual receipts deposit. Contact Person(s) Responsible ? Amy Hobbs, Managing Agent Anticipated Completion Date ? 05/01/2021 Auditee Disagreements ? N/A This corrective action plan was prepared by Brookside Development Corporation Management, the management company, on behalf of Villa South (III) d/b/a Villa Madonna III Apartments, Inc.. ?????????_____________________________ _________________ Amy Hobbs, Managing Agent 04/29/2021 Brookside Development Corporation Management 312 Brookside Drive Mayfield, KY 42006 (270) 247-6391

Prior Finding References

2019-001

About Other →

FY 2019-12-31

FAC accepted this audit on October 12, 2020 — management decision was due April 12, 2021.

2019-001
Other
REPEAT

S3800-010 Finding Reference Number ? 2019-001 S3800-011 Title and CFDA Number of Federal Program ? Section 202 Capital Advance 14.157 S3800-015 Type of Finding ? Federal Award S3800-016 Finding Resolution Status ? Unresolved S3800-017 Information on Universe Population Size ? N/A S3800-018 Sample Size Information ? N/A S3800-019 Identification of Repeat Finding and Finding Reference Number ? 2018-003 S3800-020 Criteria ? In accordance with the Regulatory Agreement, surplus cash is required to be deposited into a residual receipts account within 90 days of year-end. S3800-030 Statement of Condition ? Surplus cash was not deposited into a residual receipts account within 90 days of year-end. S3800-032 Cause ? Management was unaware of the requirement for the prior year audit. S3800-033 Effect or Potential Effect ? The Project is in violation of the Regulatory Agreement. S3800-035 Auditor Non-Compliance Code ? B S3800-040 Questioned Costs ? $0 S3800-045 Reporting Views of Responsible Officials ? The new management company was unable to obtain accounting information from the prior management company in a timely manner to calculate surplus cash and make the residual receipts deposit as required. S3800-050 Context ? The management company changed during the prior year, and the new management company was unable to obtain accounting information from the old management company prior to year-end. S3800-080 Recommendation ? Management should ensure surplus cash is calculated in a timely matter in order to make any required deposit to the residual receipts account.S3800-090 Auditor?s Summary of the Auditee?s Comments on the Finding and Recommendations ? The new management company was unable to obtain accounting information from the prior management company in a timely manner to calculate surplus cash. S3800-130 Response Indicator ? Agree S3800-140 Completion Date ? October 23, 2019 S3800-150 Response ? Management will ensure surplus cash is calculated in a timely manner in order to make the required residual receipts deposit.

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Full finding narrative

S3800-010 Finding Reference Number ? 2019-001 S3800-011 Title and CFDA Number of Federal Program ? Section 202 Capital Advance 14.157 S3800-015 Type of Finding ? Federal Award S3800-016 Finding Resolution Status ? Unresolved S3800-017 Information on Universe Population Size ? N/A S3800-018 Sample Size Information ? N/A S3800-019 Identification of Repeat Finding and Finding Reference Number ? 2018-003 S3800-020 Criteria ? In accordance with the Regulatory Agreement, surplus cash is required to be deposited into a residual receipts account within 90 days of year-end. S3800-030 Statement of Condition ? Surplus cash was not deposited into a residual receipts account within 90 days of year-end. S3800-032 Cause ? Management was unaware of the requirement for the prior year audit. S3800-033 Effect or Potential Effect ? The Project is in violation of the Regulatory Agreement. S3800-035 Auditor Non-Compliance Code ? B S3800-040 Questioned Costs ? $0 S3800-045 Reporting Views of Responsible Officials ? The new management company was unable to obtain accounting information from the prior management company in a timely manner to calculate surplus cash and make the residual receipts deposit as required. S3800-050 Context ? The management company changed during the prior year, and the new management company was unable to obtain accounting information from the old management company prior to year-end. S3800-080 Recommendation ? Management should ensure surplus cash is calculated in a timely matter in order to make any required deposit to the residual receipts account.S3800-090 Auditor?s Summary of the Auditee?s Comments on the Finding and Recommendations ? The new management company was unable to obtain accounting information from the prior management company in a timely manner to calculate surplus cash. S3800-130 Response Indicator ? Agree S3800-140 Completion Date ? October 23, 2019 S3800-150 Response ? Management will ensure surplus cash is calculated in a timely manner in order to make the required residual receipts deposit.

Corrective Action Plan

Villa South (III) d/b/a Villa Madonna III Apartments, Inc. respectfully submits the following Corrective Action Plan for the year ended December 31, 2019. Name and address of the independent public accounting firm who conducted the related audit: Comer, Nowling And Associates, P.C. 10475 Crosspoint Boulevard, Suite 200 Indianapolis, Indiana 46256 Finding 2019-001 Corrective Action Planned ? Management will ensure surplus cash is calculated in a timely manner in order to make the required residual receipts deposit. Contact Person(s) Responsible ? Amy Hobbs, Property Manager Anticipated Completion Date ? December 31, 2020 Auditee Disagreements ? None Finding 2019-002 Corrective Action Planned ? Management will transfer the residual receipts funds to an interestbearing account. Contact Person(s) Responsible ? Amy Hobbs, Property Manager Anticipated Completion Date ? December 31, 2020 Auditee Disagreements ? None Finding 2019-003 Corrective Action Planned ? Management will transfer the replacement reserve funds to an interest-bearing account. Contact Person(s) Responsible ? Amy Hobbs, Property Manager Anticipated Completion Date ? December 31, 2020 Auditee Disagreements ? None Finding 2019-004 Corrective Action Planned ? Management will implement policies and procedures to ensure security deposits get refunded in a timely manner. Contact Person(s) Responsible ? Amy Hobbs, Property Manager Anticipated Completion Date ? December 31, 2020 Auditee Disagreements ? None This corrective action plan was prepared by Brookside Development Corporation, the management company, on behalf of Villa South (III) d/b/a Villa Madonna III Apartments, Inc. __________________________ _____________________ Name, Title Date Brookside Development Corporation 312 Brookside Drive Mayfield, KY 42066 (270) 247-6391

Prior Finding References

2018-003

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2019-002
Other

S3800-010 Finding Reference Number ? 2019-002 S3800-011 Title and CFDA Number of Federal Program ? Section 202 Capital Advance 14.157 S3800-015 Type of Finding ? Federal Award S3800-016 Finding Resolution Status ? Unresolved S3800-017 Information on Universe Population Size ? N/A S3800-018 Sample Size Information ? N/A S3800-019 Identification of Repeat Finding and Finding Reference Number ? N/A S3800-020 Criteria ? The residual receipts funds must be held in an interest-bearing account. S3800-030 Statement of Condition ? The residual receipts fund is not an interest-bearing account. S3800-032 Cause ? Management was unaware of the requirement. S3800-033 Effect or Potential Effect ? The Project is in violation with HUD regulations. S3800-035 Auditor Non-Compliance Code ? P S3800-040 Questioned Costs ? $0 S3800-045 Reporting Views of Responsible Officials ? Management was unaware of the requirement and will make the correction. S3800-050 Context ? The residual receipts account was opened during the audit year and is not an interest-bearing account. S3800-080 Recommendation ? Management should transfer the residual receipts funds to an interest-bearing account. S3800-090 Auditor?s Summary of the Auditee?s Comments on the Finding and Recommendations ? Management was unaware of the requirement and will transfer the residual receipts funds to an interest-bearing account. S3800-130 Response Indicator ? Agree S3800-140 Completion Date ? July 2020 S3800-150 Response ? Management will transfer the residual receipts funds to an interestbearing account.

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S3800-010 Finding Reference Number ? 2019-002 S3800-011 Title and CFDA Number of Federal Program ? Section 202 Capital Advance 14.157 S3800-015 Type of Finding ? Federal Award S3800-016 Finding Resolution Status ? Unresolved S3800-017 Information on Universe Population Size ? N/A S3800-018 Sample Size Information ? N/A S3800-019 Identification of Repeat Finding and Finding Reference Number ? N/A S3800-020 Criteria ? The residual receipts funds must be held in an interest-bearing account. S3800-030 Statement of Condition ? The residual receipts fund is not an interest-bearing account. S3800-032 Cause ? Management was unaware of the requirement. S3800-033 Effect or Potential Effect ? The Project is in violation with HUD regulations. S3800-035 Auditor Non-Compliance Code ? P S3800-040 Questioned Costs ? $0 S3800-045 Reporting Views of Responsible Officials ? Management was unaware of the requirement and will make the correction. S3800-050 Context ? The residual receipts account was opened during the audit year and is not an interest-bearing account. S3800-080 Recommendation ? Management should transfer the residual receipts funds to an interest-bearing account. S3800-090 Auditor?s Summary of the Auditee?s Comments on the Finding and Recommendations ? Management was unaware of the requirement and will transfer the residual receipts funds to an interest-bearing account. S3800-130 Response Indicator ? Agree S3800-140 Completion Date ? July 2020 S3800-150 Response ? Management will transfer the residual receipts funds to an interestbearing account.

Corrective Action Plan

Villa South (III) d/b/a Villa Madonna III Apartments, Inc. respectfully submits the following Corrective Action Plan for the year ended December 31, 2019. Name and address of the independent public accounting firm who conducted the related audit: Comer, Nowling And Associates, P.C. 10475 Crosspoint Boulevard, Suite 200 Indianapolis, Indiana 46256 Finding 2019-001 Corrective Action Planned ? Management will ensure surplus cash is calculated in a timely manner in order to make the required residual receipts deposit. Contact Person(s) Responsible ? Amy Hobbs, Property Manager Anticipated Completion Date ? December 31, 2020 Auditee Disagreements ? None Finding 2019-002 Corrective Action Planned ? Management will transfer the residual receipts funds to an interestbearing account. Contact Person(s) Responsible ? Amy Hobbs, Property Manager Anticipated Completion Date ? December 31, 2020 Auditee Disagreements ? None Finding 2019-003 Corrective Action Planned ? Management will transfer the replacement reserve funds to an interest-bearing account. Contact Person(s) Responsible ? Amy Hobbs, Property Manager Anticipated Completion Date ? December 31, 2020 Auditee Disagreements ? None Finding 2019-004 Corrective Action Planned ? Management will implement policies and procedures to ensure security deposits get refunded in a timely manner. Contact Person(s) Responsible ? Amy Hobbs, Property Manager Anticipated Completion Date ? December 31, 2020 Auditee Disagreements ? None This corrective action plan was prepared by Brookside Development Corporation, the management company, on behalf of Villa South (III) d/b/a Villa Madonna III Apartments, Inc. __________________________ _____________________ Name, Title Date Brookside Development Corporation 312 Brookside Drive Mayfield, KY 42066 (270) 247-6391

About Other →
2019-003
Other

S3800-010 Finding Reference Number ? 2019-003 S3800-011 Title and CFDA Number of Federal Program ? Section 202 Capital Advance 14.157 S3800-015 Type of Finding ? Federal Award S3800-016 Finding Resolution Status ? Unresolved S3800-017 Information on Universe Population Size ? N/A S3800-018 Sample Size Information ? N/A S3800-019 Identification of Repeat Finding and Finding Reference Number ? N/A S3800-020 Criteria ? The replacement reserve funds must be held in an interest-bearing account. S3800-030 Statement of Condition ? The replacement reserve fund is not an interest-bearing account. S3800-032 Cause ? Management was unaware of the requirement. S3800-033 Effect or Potential Effect ? The Project is in violation with HUD regulations. S3800-035 Auditor Non-Compliance Code ? O S3800-040 Questioned Costs ? $0 S3800-045 Reporting Views of Responsible Officials ? Management was unaware of the requirement and will make the correction.S3800-050 Context ? The replacement reserve account was opened during the audit year and is not an interest-bearing account. S3800-080 Recommendation ? Management should transfer the replacement reserve funds to an interest-bearing account. S3800-090 Auditor?s Summary of the Auditee?s Comments on the Finding and Recommendations ? Management was unaware of the requirement and will transfer the replacement reserve funds to an interest-bearing account. S3800-130 Response Indicator ? Agree S3800-140 Completion Date ? July 2020 S3800-150 Response ? Management will transfer the replacement reserve funds to an interestbearing account.

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S3800-010 Finding Reference Number ? 2019-003 S3800-011 Title and CFDA Number of Federal Program ? Section 202 Capital Advance 14.157 S3800-015 Type of Finding ? Federal Award S3800-016 Finding Resolution Status ? Unresolved S3800-017 Information on Universe Population Size ? N/A S3800-018 Sample Size Information ? N/A S3800-019 Identification of Repeat Finding and Finding Reference Number ? N/A S3800-020 Criteria ? The replacement reserve funds must be held in an interest-bearing account. S3800-030 Statement of Condition ? The replacement reserve fund is not an interest-bearing account. S3800-032 Cause ? Management was unaware of the requirement. S3800-033 Effect or Potential Effect ? The Project is in violation with HUD regulations. S3800-035 Auditor Non-Compliance Code ? O S3800-040 Questioned Costs ? $0 S3800-045 Reporting Views of Responsible Officials ? Management was unaware of the requirement and will make the correction.S3800-050 Context ? The replacement reserve account was opened during the audit year and is not an interest-bearing account. S3800-080 Recommendation ? Management should transfer the replacement reserve funds to an interest-bearing account. S3800-090 Auditor?s Summary of the Auditee?s Comments on the Finding and Recommendations ? Management was unaware of the requirement and will transfer the replacement reserve funds to an interest-bearing account. S3800-130 Response Indicator ? Agree S3800-140 Completion Date ? July 2020 S3800-150 Response ? Management will transfer the replacement reserve funds to an interestbearing account.

Corrective Action Plan

Villa South (III) d/b/a Villa Madonna III Apartments, Inc. respectfully submits the following Corrective Action Plan for the year ended December 31, 2019. Name and address of the independent public accounting firm who conducted the related audit: Comer, Nowling And Associates, P.C. 10475 Crosspoint Boulevard, Suite 200 Indianapolis, Indiana 46256 Finding 2019-001 Corrective Action Planned ? Management will ensure surplus cash is calculated in a timely manner in order to make the required residual receipts deposit. Contact Person(s) Responsible ? Amy Hobbs, Property Manager Anticipated Completion Date ? December 31, 2020 Auditee Disagreements ? None Finding 2019-002 Corrective Action Planned ? Management will transfer the residual receipts funds to an interestbearing account. Contact Person(s) Responsible ? Amy Hobbs, Property Manager Anticipated Completion Date ? December 31, 2020 Auditee Disagreements ? None Finding 2019-003 Corrective Action Planned ? Management will transfer the replacement reserve funds to an interest-bearing account. Contact Person(s) Responsible ? Amy Hobbs, Property Manager Anticipated Completion Date ? December 31, 2020 Auditee Disagreements ? None Finding 2019-004 Corrective Action Planned ? Management will implement policies and procedures to ensure security deposits get refunded in a timely manner. Contact Person(s) Responsible ? Amy Hobbs, Property Manager Anticipated Completion Date ? December 31, 2020 Auditee Disagreements ? None This corrective action plan was prepared by Brookside Development Corporation, the management company, on behalf of Villa South (III) d/b/a Villa Madonna III Apartments, Inc. __________________________ _____________________ Name, Title Date Brookside Development Corporation 312 Brookside Drive Mayfield, KY 42066 (270) 247-6391

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2019-004
Other

S3800-010 Finding Reference Number ? 2019-004 S3800-011 Title and CFDA Number of Federal Program ? Section 202 Capital Advance 14.157 S3800-015 Type of Finding ? Federal Award S3800-016 Finding Resolution Status ? Resolved S3800-017 Information on Universe Population Size ? 2 tenants S3800-018 Sample Size Information ? 1 tenant S3800-019 Identification of Repeat Finding and Finding Reference Number ? N/A S3800-020 Criteria ? Security deposits paid by tenants must be refunded within 60 days of the date of move out. S3800-030 Statement of Condition ? The security deposit for the sample tenant move-out was not refunded until audit testing was performed and the unrefunded deposit was discovered. S3800-032 Cause ? Unknown S3800-033 Effect or Potential Effect ? The Project is in violation with HUD regulations. S3800-035 Auditor Non-Compliance Code ? M S3800-040 Questioned Costs ? $0 S3800-045 Reporting Views of Responsible Officials ? Management has subsequently refunded the security deposit. S3800-050 Context ? The tenant sampled moved out on September 13, 2019. The security deposit was not refunded until December 12, 2019 after the auditors discovered the unpaid refund during audit fieldwork. S3800-080 Recommendation ? Management should implement policies and procedures to ensure security deposits get refunded in a timely manner. S3800-090 Auditor?s Summary of the Auditee?s Comments on the Finding and Recommendations ? Management will implement policies and procedures to ensure security deposits get refunded in a timely manner. S3800-130 Response Indicator ? Agree S3800-140 Completion Date ? December 12, 2019 S3800-150 Response ? Management will implement policies and procedures to ensure security deposits get refunded in a timely manner.

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Full finding narrative

S3800-010 Finding Reference Number ? 2019-004 S3800-011 Title and CFDA Number of Federal Program ? Section 202 Capital Advance 14.157 S3800-015 Type of Finding ? Federal Award S3800-016 Finding Resolution Status ? Resolved S3800-017 Information on Universe Population Size ? 2 tenants S3800-018 Sample Size Information ? 1 tenant S3800-019 Identification of Repeat Finding and Finding Reference Number ? N/A S3800-020 Criteria ? Security deposits paid by tenants must be refunded within 60 days of the date of move out. S3800-030 Statement of Condition ? The security deposit for the sample tenant move-out was not refunded until audit testing was performed and the unrefunded deposit was discovered. S3800-032 Cause ? Unknown S3800-033 Effect or Potential Effect ? The Project is in violation with HUD regulations. S3800-035 Auditor Non-Compliance Code ? M S3800-040 Questioned Costs ? $0 S3800-045 Reporting Views of Responsible Officials ? Management has subsequently refunded the security deposit. S3800-050 Context ? The tenant sampled moved out on September 13, 2019. The security deposit was not refunded until December 12, 2019 after the auditors discovered the unpaid refund during audit fieldwork. S3800-080 Recommendation ? Management should implement policies and procedures to ensure security deposits get refunded in a timely manner. S3800-090 Auditor?s Summary of the Auditee?s Comments on the Finding and Recommendations ? Management will implement policies and procedures to ensure security deposits get refunded in a timely manner. S3800-130 Response Indicator ? Agree S3800-140 Completion Date ? December 12, 2019 S3800-150 Response ? Management will implement policies and procedures to ensure security deposits get refunded in a timely manner.

Corrective Action Plan

Villa South (III) d/b/a Villa Madonna III Apartments, Inc. respectfully submits the following Corrective Action Plan for the year ended December 31, 2019. Name and address of the independent public accounting firm who conducted the related audit: Comer, Nowling And Associates, P.C. 10475 Crosspoint Boulevard, Suite 200 Indianapolis, Indiana 46256 Finding 2019-001 Corrective Action Planned ? Management will ensure surplus cash is calculated in a timely manner in order to make the required residual receipts deposit. Contact Person(s) Responsible ? Amy Hobbs, Property Manager Anticipated Completion Date ? December 31, 2020 Auditee Disagreements ? None Finding 2019-002 Corrective Action Planned ? Management will transfer the residual receipts funds to an interestbearing account. Contact Person(s) Responsible ? Amy Hobbs, Property Manager Anticipated Completion Date ? December 31, 2020 Auditee Disagreements ? None Finding 2019-003 Corrective Action Planned ? Management will transfer the replacement reserve funds to an interest-bearing account. Contact Person(s) Responsible ? Amy Hobbs, Property Manager Anticipated Completion Date ? December 31, 2020 Auditee Disagreements ? None Finding 2019-004 Corrective Action Planned ? Management will implement policies and procedures to ensure security deposits get refunded in a timely manner. Contact Person(s) Responsible ? Amy Hobbs, Property Manager Anticipated Completion Date ? December 31, 2020 Auditee Disagreements ? None This corrective action plan was prepared by Brookside Development Corporation, the management company, on behalf of Villa South (III) d/b/a Villa Madonna III Apartments, Inc. __________________________ _____________________ Name, Title Date Brookside Development Corporation 312 Brookside Drive Mayfield, KY 42066 (270) 247-6391

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FY 2018-12-31

FAC accepted this audit on June 24, 2019 — management decision was due December 24, 2019.

2018-001
Other

GSA_MIGRATION

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2018-002
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GSA_MIGRATION

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2018-003
Other

GSA_MIGRATION

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