KEYSTONE PLACE HOUSING CORPNon-Profit

S3800-010: Finding Reference Number 2025-001 (Significant Deficiency) S3800-011: Program Information Federal Program: Supportive Housing for Persons with Disabilities – Section 811 Federal Agency: Department of Housing and Urban Development Assistance Listing #: 14.181 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N – Special Tests and Provisions S3800-015: Type of Finding Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size 122 S3800-018: Sample Size Information 15 S3800-019: Identification of Repeat Finding and Finding Reference Number 2024-001 and 2023-001 S3800-020: Criteria The HUD Management Agent Handbook (4381.5) requires owners of multifamily housing to follow specific guidelines and determine requirements are being met for residents requesting maintenance of property in compliance with management’s procedures. S3800-030: Statement of Condition During our audit of the Organization’s fiscal year ended December 31, 2025 federal award program, we noted concerns regarding adherence to compliance requirements with management procedures for work orders and tenant complaints for timely follow-up. Six of the fifteen samples were not completed in a timely manner. S3800-032: Cause The Organization did not follow HUD required procedures for housing quality standards. S3800-033: Effect or Potential Effect The Organization was not in compliance with ensuring HUD requirements are being met for residents requesting maintenance of property via management’s procedures. S3800-035: Auditor Non-Compliance Code: I – Failure to maintain property / open physical inspection(s) S3800-040: Questioned Costs N/A S3800-045: Reporting Views of Responsible Officials The Organization will ensure tenants requesting maintenance of property via work orders are being maintained properly and in a timely manner and review the accuracy / completeness of the documentation being processed in the work order system on a quarterly basis. Also, for the three of the work orders without signatures, we didn’t talk with our Maintenance man about signing off on work orders until after April 2025’s board meeting. This was completed before the forms were changed so that Chad could sign and add more details. We amended the work order form to accommodate the findings from the 2024 audit. S3800-050: Context The Organization is required to be in compliance with provisions in HUD Handbook 4381.5 related to work orders and tenant complaints for timely follow-up. S3800-080: Recommendation The Organization should ensure tenants requesting maintenance of property via work orders are being maintained properly and in a timely manner and review the accuracy / completeness of the documentation being processed in the work order system on a quarterly basis. S3800-090: Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date July 31, 2026 S3800-150: Response See Corrective Action Plan

S3800-010: Finding Reference Number 2024-001 (Significant Deficiency) S3800-011: Program Information Federal Program: Supportive Housing for Persons with Disabilities – Section 811 Federal Agency: Department of Housing and Urban Development Assistance Listing #: 14.181 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N – Special Tests and Provisions S3800-015: Type of Finding Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size 64 S3800-018: Sample Size Information 7 S3800-019: Identification of Repeat Finding and Finding Reference Number 2023-001 S3800-020: Criteria The HUD Management Agent Handbook (4381.5) requires owners of multifamily housing to follow specific guidelines and determine requirements are being met for residents requesting maintenance of property in compliance with management’s procedures. S3800-030: Statement of Condition During our audit of the Organization’s fiscal year ended December 31, 2024 federal award program, we noted concerns regarding adherence to compliance requirements with management procedures for work orders and tenant complaints for timely follow-up. Two of the seven samples were not completed in a timely manner. S3800-032: Cause The Organization did not follow HUD required procedures for housing quality standards. S3800-033: Effect or Potential Effect The Organization was not in compliance with ensuring HUD requirements are being met for residents requesting maintenance of property via management’s procedures. S3800-035: Auditor Non-Compliance Code: I – Failure to maintain property / open physical inspection(s) S3800-040: Questioned Costs N/A S3800-045: Reporting Views of Responsible Officials The Organization will ensure tenants requesting maintenance of property via work orders are being maintained properly and in a timely manner and review the accuracy / completeness of the documentation being processed in the work order system on a quarterly basis. Our Maintenance personnel was off work due to health issues at various times in 2024. One period was for about 6 weeks and the other was for 4 weeks. During this period, April Douglas-Bowers (our Property Manager) would review work orders for urgency and would use a vendor to perform work. Otherwise, our Maintenance personnel worked on open items upon returning to work. S3800-050: Context The Organization is required to be in compliance with provisions in HUD Handbook 4381.5 related to work orders and tenant complaints for timely follow-up. S3800-080: Recommendation The Organization should ensure tenants requesting maintenance of property via work orders are being maintained properly and in a timely manner and review the accuracy / completeness of the documentation being processed in the work order system on a quarterly basis. S3800-090: Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date July 31, 2025 S3800-150: Response See Corrective Action Plan

S3800-010: Finding Reference Number 2024-002 (Significant Deficiency) S3800-011: Program Information Federal Program: Supportive Housing for Persons with Disabilities – Section 811 Federal Agency: Department of Housing and Urban Development Assistance Listing #: 14.181 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N – Special Tests and Provisions S3800-015: Type of Finding Federal Awards 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 2023-002 and 2022-002 S3800-020: Criteria Per HUD Handbook 4381.5, REV-2, CHG-2, Management Agents of insured and assisted multifamily housing projects are required by HUD administrative guidelines to have a HUD approved Project Owner's / Management Agent’s Certification for Multifamily Housing Projects for very low-income persons with disabilities (Form 9839-B). S3800-030: Statement of Condition During our audit of the Organization’s fiscal year ended December 31, 2024 federal award program, we noted that the Organization did not have a HUD approved Form 9839-B; the last effective date was August 31, 2014. S3800-032: Cause Form 9839-B expired in 2014 and the Organization failed to obtain an approved HUD Form 9839-B since then. The Organization submitted a request for approval of Form 9839-B to HUD in March 2023, however HUD requested additional documentation from the Organization regarding the operation and management of the property before granting approval. The additional documentation (a Management Agreement) and an updated HUD Form 9839-B request was submitted to HUD in October 2024; however, approval has not been granted by HUD as of the audit report date. S3800-033: Effect or Potential Effect Charges for management fees for the fiscal year were not authorized. S3800-035: Auditor Non-Compliance Code: J – Unauthorized management fee S3800-040: Questioned Costs $10,918 S3800-045: Reporting Views of Responsible Officials The Organization agreed with this finding. S3800-050: Context The Organization is required to have all of its necessary forms and licenses current and up to date. S3800-080: Recommendation The Organization should establish a process to ensure they have obtained all required HUD approved forms. Additionally, the Organization should ask HUD to retrospectively approve Form 9839-B effective September 1, 2014. In March 2023, the Organization submitted a request for approval of Form 9839-B to HUD, however HUD requested additional documentation from the Organization regarding the operation and management of the property before granting approval. The additional documentation (a Management Agreement) and an updated Form 9839-B request was submitted to HUD in October 2024; however, approval has not been granted by HUD to-date. S3800-090: Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date July 31, 2025 S3800-150: Response See Corrective Action Plan

S3800-010: Finding Reference Number 2023-001 (Significant Deficiency) S3800-011: Program Information Federal Program: Supportive Housing for Persons with Disabilities – Section 811 Federal Agency: Department of Housing and Urban Development Assistance Listing #: 14.181 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N – Special Tests and Provisions S3800-015: Type of Finding Federal Awards S3800-016: Finding Resolution Status Unresolved S3800-017: Information on Universe Population Size 66 S3800-018: Sample Size Information 7 S3800-019: Identification of Repeat Finding and Finding Reference Number 2022-001 S3800-020: Criteria Per HUD Handbook 4381.5, REV-2, CHG-2, requires owners of multifamily housing to follow specific guidelines and determine requirements are being met for residents requesting maintenance of property via a work order system in compliance with management’s procedures. S3800-030: Statement of Condition During our audit of the Organization’s fiscal year ended December 31, 2023 financial statements, we noted that HUD requirements related to housing quality standards were not properly followed. We tested a sample of seven work orders and noted that a proper and efficient work order system was not in place; as the Organization has tenants submit paper maintenance work order request forms, however the maintenance personnel does not on sign / initial each work order as completed, provide the date of their completion, and /or list the work performed to resolve the tenant request on the work order. Someone places a checkmark on the work order request form with no additional information. S3800-032: Cause The Organization did not follow HUD required procedures for housing quality standards. S3800-033: Effect or Potential Effect The Organization was not in compliance with the requirements of HUD related to ensuring a properly functioning work order system is in place. S3800-035: Auditor Non-Compliance Code: S – Internal control deficiencies S3800-040: Questioned Costs None S3800-045: Reporting Views of Responsible Officials The Organization will adopt a policy to ensure tenants requesting maintenance of property via work orders is being maintained properly and efficiently in the work order system and we will review the accuracy / completeness of the documentation being processed in the work order system on a quarterly basis. S3800-050: Context The Organization is required to maintain a properly functioning work order system that demonstrates resolution of tenants requesting maintenance. S3800-080: Recommendation The Organization should adopt a policy to ensure tenants requesting maintenance of property via work orders is being maintained properly and efficiently in the work order system and management is reviewing the accuracy / completeness of the documentation being processed in the work order system on a quarterly basis. S3800-090: Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date July 31, 2024 S3800-150: Response See Corrective Action Plan

S3800-010: Finding Reference Number 2023-002 (Significant Deficiency) S3800-011: Program Information Federal Program: Supportive Housing for Persons with Disabilities – Section 811 Federal Agency: Department of Housing and Urban Development Assistance Listing #: 14.181 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N – Special Tests and Provisions S3800-015: Type of Finding Financial Statements and Federal Awards 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 2022-002 S3800-020: Criteria Per HUD Handbook 4381.5, REV-2, CHG-2, Management Agents of insured and assisted multifamily housing projects are required by HUD administrative guidelines to have a HUD approved Project Owner's / Management Agent’s Certification for Multifamily Housing Projects for very low-income persons with disabilities (Form 9839-B). S3800-030: Statement of Condition During our audit of the Organization’s fiscal year ended December 31, 2023 federal award program, we noted that the Organization did not have a HUD approved Form 9839-B; the last effective date was August 31, 2014. S3800-032: Cause Form 9839-B expired in 2014 and the Organization failed to obtain an approved HUD Form 9839-B since then. However, as of March 22, 2023, the Organization submitted a request for approval of Form 9839-B to HUD, however HUD requested additional documentation from the Organization regarding the operation and management of the property before granting approval. S3800-033: Effect or Potential Effect Charges for management fees for the fiscal year were not authorized. S3800-035: Auditor Non-Compliance Code: J – Unauthorized management fee S3800-040: Questioned Costs $9,478 S3800-045: Reporting Views of Responsible Officials The Organization agreed with this finding. S3800-050: Context The Organization is required to have all of its necessary forms and licenses current and up to date. S3800-080: Recommendation The Organization should establish a process to ensure they have obtained all required HUD approved forms. Additionally, the Organization should ask HUD to retrospectively approve Form 9839-B effective September 1, 2014. As of March 22, 2023, the Organization submitted a request for approval of Form 9839-B to HUD, however HUD requested additional documentation from the Organization regarding the operation and management of the property before granting approval, in which we recommend the Organization submit. S3800-090: Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date July 31, 2024 S3800-150: Response See Corrective Action Plan

S3800-010: Finding Reference Number 2022-001 (Significant Deficiency) S3800-011: Program Information Federal Program: Supportive Housing for Persons with Disabilities ? Section 811 Federal Agency: Department of Housing and Urban Development Assistance Listing #: 14.181 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N ? Special Tests and Provisions S3800-015: Type of Finding Federal Awards Finding S3800-016: Finding Resolution Status In-progress S3800-017: Information on Universe Population Size 81 S3800-018: Sample Size Information 9 S3800-019: Identification of Repeat Finding and Finding Reference Number N/A S3800-020: Criteria The Management Agent Handbook (4381.5) requires owners of multifamily housing to follow specific guidelines and determine requirements are being met for residents requesting maintenance of property via a work order system in compliance with management?s procedures. S3800-030: Statement of Condition During our audit of the Organization?s fiscal year ended December 31, 2022 financial statements, we noted that HUD requirements related to housing quality standards were not properly followed. We tested a sample of nine work orders and noted that a work order system was not in place, as the Organization doesn?t keep a log, but paper maintenance work order request forms. S3800-032: Cause The Organization did not follow HUD required procedures for housing quality standards. S3800-033: Effect or Potential Effect The Organization was not in compliance with the requirements of HUD related to ensuring a properly functioning work order system is in place. S3800-035: Auditor Non-Compliance Code: S ? Internal control deficiencies S3800-040: Questioned Costs None S3800-045: Reporting Views of Responsible Officials The Organization will adopt a policy to ensure tenants requesting maintenance of property via work orders is being maintained properly in the work order system and we will review the accuracy of the documentation being processed in the work order system on a quarterly basis. S3800-050: Context The Organization is required to maintain a work order system. S3800-080: Recommendation The Organization should adopt a policy to ensure tenants requesting maintenance of property via work orders is being maintained properly in the work order system and management is reviewing the accuracy of the documentation being processed in the work order system on a quarterly basis. S3800-090: Auditor?s Summary of the Auditee?s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date June 30, 2023 S3800-150: Response See Corrective Action Plan

S3800-010: Finding Reference Number 2022-002 (Significant Deficiency) S3800-011: Program Information Federal Program: Supportive Housing for Persons with Disabilities ? Section 811 Federal Agency: Department of Housing and Urban Development Assistance Listing #: 14.181 Pass-through Entity: None Federal Award Identification Number and Year: N/A Type of Compliance Finding: N ? Special Tests and Provisions S3800-015: Type of Finding Federal Awards Finding S3800-016: Finding Resolution Status In-progress 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 Per the HUD Handbook 4381.5, REV-2, CHG-2, Management Agents of insured and assisted multifamily housing projects are required by HUD administrative guidelines to have a HUD approved Project Owner's / Management Agent?s Certification for Multifamily Housing Projects for very low-income persons with disabilities (Form 9839-B). S3800-030: Statement of Condition During our audit of the Organization?s fiscal year ended December 31, 2022 federal award program, we noted that the Organization did not have a HUD approved Form 9839-B; the last effective date was August 31, 2014. S3800-032: Cause Form 9839-B was expired in 2014 and the Organization failed to obtain an approved HUD Form 9839-B since then. S3800-033: Effect or Potential Effect Charges for management fees for the fiscal year were not authorized. S3800-035: Auditor Non-Compliance Code: J ? Unauthorized management fee S3800-040: Questioned Costs $8,991 S3800-045: Reporting Views of Responsible Officials The Organization agreed with this finding. S3800-050: Context The Organization is required to have all of its necessary forms and licenses current and up to date. S3800-080: Recommendation The Organization should establish a process to ensure they have obtained all required HUD approved forms. Additionally, the Organization should ask HUD to retrospectively approve Form 9839-B effective September 1, 2014. S2700-090: Auditor?s Summary of the Auditee?s Comments on the Findings and Recommendations Auditee agreed with our recommendation. S3800-130: Response Indicator Agree S3800-140: Completion Date or Proposed Completion Date June 30, 2023 S3800-150: Response See Corrective Action Plan