ACCESSIBLE RESIDENCES, INC.

Special Tests and Provisions – Material Weakness in Internal Controls over Compliance (Replacement Reserve Disbursement – HUD Approval Requirement) Management Response Management acknowledges that a disbursement of $15,000 was made from the replacement reserve account without obtaining prior written approval from HUD, as required under the Capital Advance Regulatory Agreement. Management recognizes that appropriate controls were not in place to prevent disbursement of restricted reserve funds without required approval, resulting in noncompliance. Management has initiated communication with HUD to disclose the transaction and request guidance on the appropriate resolution. The organization will comply with all directives issued by HUD and will continue to follow up as necessary to ensure timely resolution. Corrective Actions Implemented / To Be Implemented • A formal control will be implemented requiring documented written HUD approval prior to any disbursement from the replacement reserve account. • All reserve disbursements will require documented HUD approval prior to processing and will be subject to Controller review to ensure compliance with HUD requirements. • Replacement reserve accounts will be formally designated as restricted funds within internal financial procedures. • A formal policy governing replacement reserve disbursements will be established. • Alternative funding sources will be used when HUD approval is not available. • Training will be provided to relevant staff on HUD requirements and reserve controls.Training Training on reserve account procedures will be conducted by May 1, 2026, with refresher training annually. Responsible Staff: Controller – Oversight of compliance Chief Executive Officer (CEO) – Final accountability Implementation Date: Corrective actions related to implementation of review controls will be implemented immediately. Resolution will follow HUD guidance.

Special Tests – Significant Deficiency in Internal Controls over Compliance (Utility Allocation – Section 811 Program) Management Response Management acknowledges that utility allocation errors occurred in a limited number of instances due to a miscalculation in the allocation spreadsheet. Specifically, utility expenses were allocated among four tenants instead of five occupied tenants, resulting in an overallocation of utility costs to certain residents. The error was due to an input/calculation issue within the allocation spreadsheet and not a deficiency in the underlying allocation methodology. The organization’s documented utility allocation policy requires that total utility costs be allocated equally among occupied tenants, which is consistent with HUD requirements. Management has evaluated the exceptions identified and determined that the issue was isolated to specific instances of spreadsheet error rather than a systemic failure of the allocation methodology. Corrective Actions Implemented / To Be Implemented • The utility allocation spreadsheet will be corrected to ensure that the total number of occupied tenants is accurately reflected in the allocation calculation. • A two-level review control will be implemented over utility allocations. The Leasing Assistant/Clerk will prepare the allocation, and the Leasing Manager will independently verify accuracy prior to finalization. • Verification will include tenant count validation to the rent roll or occupancy report, recalculation of the per-tenant allocation, and confirmation that total allocations agree to the original utility invoice. • Allocation schedules will be supported by rent roll or occupancy documentation. • A standardized checklist will be implemented for monthly allocation procedures. • Any identified allocation errors will be promptly corrected to ensure tenants are not overcharged. Training Training on utility allocation procedures will be conducted by May 1, 2026, for leasing staff and management, with annual refresher training. Responsible Staff: Leasing Assistant/Clerk – Preparation Leasing Manager – Review and verification Controller – Oversight Chief Executive Officer (CEO) – Final accountability Implementation Date: Corrective actions are being implemented immediately upon identification of the finding. Ongoing monitoring will occur monthly.

GSA_MIGRATION