Fowler Christian Apartments II

Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Section 202 Capital Advance and Project Rental Assistance Contract ALN: 14.157 Award Period: 2024 Type of Finding: Significant Deficiency Criteria or specific requirement: According to the Regulatory Agreement, “mortgagor will establish and maintain a reserve fund for replacements in a separate account in a bank…concurrently with the effective commencement of rental assistance payments under the Project Rental Assistance Contract, the Mortgagor will deposit an amount…per month unless a different date or amount is approved in writing by HUD”. Condition: The Organization did not make all required deposits into the Reserve for Replacements bank account in a timely manner. Questioned costs: $7,162 Cause: A process control to ensure the automatic transfer of deposits from the operating account to the replacements reserve on a monthly basis was not in place. Effect: Deposits for three of the twelve months of the year were not made timely. Therefore, the Organization is not in compliance with the Regulatory Agreement. Recommendation: We recommend management implement a control to ensure the monthly transfer is completed automatically and in accordance with the Regulatory Agreement. Views of responsible officials: The Organization agrees with the finding and the recommendation will be implemented. Controls implemented include scheduling of automatic transfers to our reserve for replacement savings account as well as updating our treasury standard operating procedures to ensure funds are available for the transfer. Condition status: Resolved. Repeat Finding: No.

Replacement Reserve Deposits Recommendation: We recommend management implement a control to ensure the monthly transfer is completed automatically and in accordance with the Regulatory Agreement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization agrees with the finding and the recommendation will be implemented. Controls implemented include scheduling of automatic transfers to our reserve for replacement savings account as well as updating our treasury standard operating procedures to ensure funds are available for the transfer. Monthly bank reconciliation will also confirm that the transfer occurred. Name(s) of the contact person(s) responsible for corrective action: Alex Lueth, VP of Finance Planned completion date for corrective action plan: June 2025

2022 ? 002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Section 202 Capital Advance and Project Rental Assistance Contract ALN: 14.157 Award Period: 2022 Type of Finding: Significant Deficiency Condition: The Organization did not submit a budget related to their project rental assistance contract. Criteria: An annual budget must be submitted to HUD for project rental assistance contracts. Questioned costs: None Context: During reporting testing, it was determined that budgets had not been submitted to HUD as required. Effect: The annual budget was not submitted to HUD as required. Cause: The Organization was not able to submit an annual budget to HUD due to delays in previous audit submissions. Recommendation: We recommend audits are completed timely to ensure the annual budget is submitted to HUD as required. Views of Responsible Officials: Annual budgets will begin being submitted in 2023 now that audits are caught up in the hope we can bring our rental rates and approved budgets closer into alignment with current rental rates and cost to operate in the DFW area. Repeat Finding: No

Views of Responsible Officials: Annual budgets will begin being submitted in 2023 now that audits are caught up in the hope we can bring our rental rates and approved budgets closer into alignment with current rental rates and cost to operate in the DFW area.

2022 ? 003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Section 202 Capital Advance and Project Rental Assistance Contract ALN: 14.157 Award Period: 2022 Type of Finding: Significant Deficiency Criteria or specific requirement: According to the Regulatory Agreement, ?mortgagor will establish and maintain a reserve fund for replacements in a separate account in a bank?concurrently with the effective commencement of rental assistance payments under the Project Rental Assistance Contract, the Mortgagor will deposit an amount?per month unless a different date or amount is approved in writing by HUD?. Condition: The Organization did not make all required deposits into the Reserve for Replacements bank account in a timely manner. Questioned costs: None Cause: A process control to ensure the automatic transfer of deposits from the operating account to the replacements reserve on a monthly basis was not in place. Effect: Deposits for six of the twelve months of the year were not made timely. Therefore, the Organization is not in compliance with the Regulatory Agreement. Recommendation: We recommend management implement a control to ensure the monthly transfer is completed automatically and in accordance with the Regulatory Agreement. Views of responsible officials: The Organization agrees with the finding and the recommendation will be implemented. Controls implemented include scheduling of automatic transfers to our reserve for replacement savings account as well as updating our treasury standard operating procedures to ensure funds are available for the transfer. Condition status: In progress. Repeat Finding: Yes; finding is a repeat from prior audit finding 2021-003.

Views of responsible officials: The Organization agrees with the finding and the recommendation will be implemented. Controls implemented include scheduling of automatic transfers to our reserve for replacement savings account as well as updating our treasury standard operating procedures to ensure funds are available for the transfer.

2021-003

Criteria: The Organization?s regulatory agreement provides that the Organization properly maintain their books and records for sound financial reporting. Additionally, the Organization has reporting objectives under Uniform Guidance. Condition: The Organization lacks sufficient controls surrounding financial reporting and year-end close, performance of timely reconciliations of intercompany transactions and material accounts, and oversight of the Organization?s financial reporting and internal controls by those charged with governance. Cause: The Organization was severely impacted by the COVID-19 pandemic and is considered an essential care facility. Safety protocols, employee illness, and staffing difficulties required accounting and management personnel to share operational duties and provide coverage, including responsibilities outside of the accounting and finance department. Appropriate consideration was not given to the heightened risks posed to the Organization and its internal control environment. In addition, timely performance and review of monthly reconciliations and year-end close was not performed consistently, resulting in controls not functioning properly throughout the year. Effect: The issues discussed above resulted in substantial delay in intercompany reimbursements and the completion of the Organization?s financial statement audit. The matter is considered a finding and a significant deficiency in internal control over financial reporting and compliance in accordance with Government Auditing Standards. Recommendation: We recommend Management (1) complete an updated analysis of the Organization?s internal controls and risks posed by the COVID-19 pandemic; (2) determine what staffing changes are necessary to ensure the Organization has adequate personnel to perform the duties and responsibilities vital to the accounting and finance function, while minimizing the sharing of non-accounting/finance responsibilities; and (3) ensure that reconciliations of all key accounts are reviewed and approved by someone independent of the individual performing the reconciliation, preferable by an individual within senior management. Views of Responsible Officials: Executive Management agrees with the finding?s content described above and intends to implement all of the recommendations. The COVID-19 pandemic was an unforeseen event that put the lives of the Organization?s residents and employees at risk. Management and the Board of Directors were required to make quick decisions in an ever-evolving environment, often with conflicting guidance from government authorities, to prevent a more tragic scenario from coming to fruition. Management?s election to deploy all available resources, both personnel and otherwise, to prevent infection and ensure the livelihood of the Project?s residents did indeed result in certain controls not working as intended, or being overridden for the ultimate collective welfare of the residents and the property. It is Management?s position that its assessment performed in the wake of the audit has allowed the Project to identify areas of weakness, and amend policies to address those weaknesses, and implement changes that will improve the accuracy of financial information and effectiveness of the Organization as a whole. The Organization has made personnel changes starting in 2021, including placement of a Chief Financial Officer and additional hires, to ensure that all prescribed responsibilities within accounting and finance are completed timely and accurately. Management has also changed the policy for intercompany expense allocation and reimbursement, and starting in 2022 is requiring all transactions be performed solely between JFC and FCA II rather than a combination of JFC, FCA, FCA II, and FCA III. Condition Status: In Progress Repeat Finding: Yes; finding is a repeat from prior audit finding 2020-001.

We have or intend to implement policies, procedures, and controls to address all of the recommendations made by our independent auditors. The COVID-19 pandemic was an unforeseen event that put the lives of the Organization?s residents and employees at risk. We were required to make quick decisions in an ever-evolving environment, often with conflicting guidance from government authorities, to prevent a more tragic scenario from coming to fruition. Our election to deploy all available resources, both personnel and otherwise, to prevent infection and ensure the livelihood of our residents did indeed result in certain controls not working as intended or being overridden for the ultimate collective welfare of the residents and the property. The assessment we performed in the wake of the audit has allowed the us to identify areas of weakness, and amend policies to address those weaknesses, and implement changes that will improve the accuracy of financial information and effectiveness of the Organization as a whole. Starting in 2021, we began implementing personnel changes, including placement of a Chief Financial Officer and additional hires, to ensure that all prescribed responsibilities within accounting and finance are completed timely and accurately. Our management team has also changed the policy for intercompany expense allocation and reimbursement, and starting in 2022 is requiring all transactions be performed solely between JFC and FCA II rather than a combination of JFC, FCA, FCA II, and FCA III. We believe this modified reimbursement policy will improve efficiency during month- and year-end close as well as reduce the possibility for errors. We intend to have all actions above completed no later than November 4, 2022.

2020-001

Criteria: Per the Regulatory Agreement, the Organization is required to submit audited financial statements to HUD within 90 days of a Project?s fiscal year end. In addition, Uniform Guidance 2 CFR Subpart F 200.512, the audit must be completed and the data collection form and reporting package submitted within the earlier of 30 days after receipt of the auditor?s report, or nine-months after the end of the audit period. Condition: The Organization did not meet its financial statement filing requirements under both HUD regulations and those under Uniform Guidance for the year ended December 31, 2021. Cause: The Organization has suffered from the ongoing effects of the COVID-19 pandemic, turnover, and other administrative matters. It was unable to dedicate resources to ensure completion of the Organization?s financial statement audit. Effect: The 2021 financial statement audit was not completed and, therefore, no financial statements were submitted to the federal audit clearinghouse. The filing is considered delinquent. HUD does not have the financial information of the project available for review. HUD may request immediate repayment of the capital advance or suspend assistance payments due to non-compliance with the regulatory agreement. Recommendation: We recommend that management submit the audited financial statements to HUD and the federal audit clearinghouse. Views of Management: The Organization agrees with the finding and the recommendation will be completed. Condition Status: In Progress Repeat Finding: Yes; finding is a repeat from prior audit finding 2020-002.

We have or intend to implement policies, procedures, and controls to address all of the recommendations made by our independent auditors. The actions documented above related to Finding No. 2021-001 will prevent a recurrence of Finding No. 2021-002. In addition, we intend on filing the financial reporting package with the FAC no later than November 4, 2022.

2020-002

Criteria: According to the Regulatory Agreement, ?mortgagor will establish and maintain a reserve fund for replacements in a separate account in a bank?concurrently with the effective commencement of rental assistance payments under the Project Rental Assistance Contract, the Mortgagor will deposit an amount?per month unless a different date or amount is approved in writing by HUD?. Condition: The Organization did not make all required deposits into the Reserve for Replacements bank account in a timely manner. Cause: A process control to ensure the automatic transfer of deposits from the operating account to the replacements reserve on a monthly basis was not in place. Effect: One deposit during 2021 was considered delinquent. Therefore, the Organization is not in compliance with the Regulatory Agreement. Recommendation: We recommend management implement a control to ensure the monthly transfer is completed automatically and in accordance with the Regulatory Agreement. Views of Management: The Organization agrees with the finding and the recommendation will be implemented. Condition Status: In Progress Repeat Finding: Yes; finding is a repeat from prior audit finding 2020-003

We have implemented policies, procedures, and controls to address the recommendation made by our independent auditors. Automatic bank drafts are now being implemented to prevent this issue from occurring in the future.

2020-003

Questioned Costs: $36,081 Criteria: HUD?s rules and regulations prohibit the commingling of funds from any other Projects. Condition: Funds from the reserve for replacement of Fowler Christian Apartments III, Inc. (HUD Project No. 113-EE075), a related party, were improperly transferred to the Organization?s operating bank account. Cause: Sufficient controls were not in place at the Managing Agent to ensure that transfers between bank accounts for managed properties were initiated in the correct amount, for the correct entity, between the correct bank account accounts, and only subsequent to HUD?s and Management?s approval. Effect: The Managing Agent transferred funds from the incorrect entity?s to FCA II?s operating bank account related to a release from the reserve for replacement. In addition, the amount transferred was in excess of the amount approved by HUD on Form 9250. The Organization recorded a payable to the related party for the amount deposited improperly. Recommendation: We recommend management implement a control to ensure releases from the Reserve for Replacement are initiated by an individual separate from those approving the transfer. In addition, a review of the transfer should be performed to ensure that the correct bank accounts are being used, and that transfers agree with the amount approved by HUD on Form 9250. Views of Management: The Organization agrees with the finding and the recommendation will be implemented. Condition Status: In Progress Repeat Finding: No

We have implemented additional policies and procedures related to bank transfers. These new policies require that all transfers be requested and initiated by an individual other than the individual approving such transfers. In addition, we will only approve transfers after review of supporting documentation and verification of correct account numbers and entities. We have also ensured our bank will not allow transfers to be requested and approved by the same individual.

Criteria: The Organization?s regulatory agreement provides that the Organization properly maintain their books and records for sound financial reporting. Additionally, the Organization has reporting objectives under Uniform Guidance. Condition: The Organization lacks sufficient controls surrounding financial reporting and year-end close, performance of timely reconciliations of intercompany transactions and material accounts, and oversight of the Organization?s financial reporting and internal controls by those charged with governance. Cause: The Organization was severely impacted by the COVID-19 pandemic and is considered an essential care facility. Safety protocols, employee illness, and staffing difficulties required accounting and management personnel to share operational duties and provide coverage, including responsibilities outside of the accounting and finance department. Appropriate consideration was not given to the heightened risks posed to the Organization and its internal control environment. In addition, timely performance and review of monthly reconciliations and year-end close was not performed consistently, resulting in controls not functioning properly throughout the year. Effect: The issues discussed above resulted in substantial delay in intercompany reimbursements and the completion of the Organization?s financial statement audit. The matter is considered a finding and a significant deficiency in internal control over financial reporting and compliance in accordance with Government Auditing Standards. Recommendation: We recommend Management (1) complete an updated analysis of the Organization?s internal controls and risks posed by the COVID-19 pandemic; (2) determine what staffing changes are necessary to ensure the Organization has adequate personnel to perform the duties and responsibilities vital to the accounting and finance function, while minimizing the sharing of non-accounting/finance responsibilities; and (3) ensure that reconciliations of all key accounts are reviewed and approved by someone independent of the individual performing the reconciliation, preferable by an individual within senior management. Views of Responsible Officials: Executive Management agrees with the finding?s content described above and intends to implement all of the recommendations. The COVID-19 pandemic was an unforeseen event that put the lives of the Organization?s residents and employees at risk. Management and the Board of Directors were required to make quick decisions in an ever-evolving environment, often with conflicting guidance from government authorities, to prevent a more tragic scenario from coming to fruition. Management?s election to deploy all available resources, both personnel and otherwise, to prevent infection and ensure the livelihood of the Project?s residents did indeed result in certain controls not working as intended, or being overridden for the ultimate collective welfare of the residents and the property. It is Management?s position that its assessment performed in the wake of the audit has allowed the Project to identify areas of weakness, and amend policies to address those weaknesses, and implement changes that will improve the accuracy of financial information and effectiveness of the Organization as a whole. The Organization has made personnel changes starting in 2021, including placement of a Chief Financial Officer and additional hires, to ensure that all prescribed responsibilities within accounting and finance are completed timely and accurately. Management has also changed the policy for intercompany expense allocation and reimbursement, and starting in 2022 is requiring all transactions be performed solely between JFC and FCA II rather than a combination of JFC, FCA, FCA II, and FCA III. Condition Status: In Progress Repeat Finding: Yes; finding is a repeat from prior audit finding 2019-001.

Planned Corrective Action We have or intend to implement policies, procedures, and controls to address all of the recommendations made by our independent auditors. The COVID-19 pandemic was an unforeseen event that put the lives of the Organization?s residents and employees at risk. We were required to make quick decisions in an ever-evolving environment, often with conflicting guidance from government authorities, to prevent a more tragic scenario from coming to fruition. Our election to deploy all available resources, both personnel and otherwise, to prevent infection and ensure the livelihood of our residents did indeed result in certain controls not working as intended or being overridden for the ultimate collective welfare of the residents and the property. The assessment we performed in the wake of the audit has allowed the us to identify areas of weakness, and amend policies to address those weaknesses, and implement changes that will improve the accuracy of financial information and effectiveness of the Organization as a whole. Starting in 2021, we began implementing personnel changes, including placement of a Chief Financial Officer and additional hires, to ensure that all prescribed responsibilities within accounting and finance are completed timely and accurately. Our management team has also changed the policy for intercompany expense allocation and reimbursement, and starting in 2022 is requiring all transactions be performed solely between JFC and FCA II rather than a combination of JFC, FCA, FCA II, and FCA III. We believe this modified reimbursement policy will improve efficiency during month- and year-end close as well as reduce the possibility for errors. We intend to have all actions above completed no later than August 31, 2022.

2019-001

Criteria: Per the regulatory agreement, the Organization is required to submit audited financial statements to HUD within 90 days of a Project?s fiscal year end. For 2020, HUD granted an extension through June 30, 2021. In addition, Uniform Guidance 2 CFR Subpart F 200.512, the audit must be completed and the data collection form and reporting package submitted within the earlier of 30 days after receipt of the auditor?s report, or nine-months after the end of the audit period. Condition: The Organization did not meet its financial statement filing requirements under both HUD regulations and those under Uniform Guidance for the year ended December 31, 2020. Cause: The Organization has suffered from the ongoing effects of the COVID-19 pandemic, turnover, and other administrative matters. It was unable to dedicate resources to ensure completion of the Organization?s financial statement audit. Effect: The 2020 financial statement audit was not completed and, therefore, no financial statements were submitted to the federal audit clearinghouse. The filing is considered delinquent. HUD does not have the financial information of the project available for review. HUD may request immediate repayment of the capital advance or suspend assistance payments due to non-compliance with the regulatory agreement. Recommendation: We recommend that management submit the audited financial statements to HUD and the federal audit clearinghouse. Views of Management: The Organization agrees with the finding and the recommendation will be completed. Condition Status: In Progress Repeat Finding: Yes; finding is a repeat from prior audit finding 2019-002.

Planned Corrective Action We have or intend to implement policies, procedures, and controls to address all of the recommendations made by our independent auditors. The actions documented above related to Finding No. 2020-001 will prevent a recurrence of Finding No. 2020-002. In addition, we intend on filing the financial reporting package with the FAC no later than August 31, 2022.

2019-002

Criteria: The regulatory agreement provides that the Organization make monthly deposits into the replacements reserve. Condition: The required deposits for the months of May through August 2020 were not made timely and were remitted in bulk in September 2020. Cause: A process control to ensure the automatic transfer of deposits from the operating account to the replacements reserve on a monthly basis was not in place. Effect: Four deposits during 2020 were considered delinquent. Recommendation: We recommend management implement a control to ensure the monthly transfer is completed automatically. Views of Management: The Organization agrees with the finding and the recommendation will be implemented. Condition Status: In Progress Repeat Finding: No

Planned Corrective Action We have implemented policies, procedures, and controls to address the recommendation made by our independent auditors. Automatic bank drafts are now being implemented to prevent this issue from occurring in the future.

Criteria: The Organization?s regulatory agreement provides that the Organization properly maintain their books and records for sound financial reporting. Additionally, the Organization has reporting objectives under Uniform Guidance. Condition: The Organization lacks sufficient controls surrounding financial reporting and year-end close, performance of timely reconciliations of intercompany transactions and material accounts, and oversight of the Organization?s financial reporting and internal controls by those charged with governance. Cause: The Organization was severely impacted by the COVID-19 pandemic and is considered an essential care facility. Safety protocols, employee illness, and staffing difficulties required accounting and management personnel to share operational duties and provide coverage, including responsibilities outside of the accounting and finance department. Appropriate consideration was not given to the heightened risks posed to the Organization and its internal control environment. In addition, timely performance and review of monthly reconciliations and year-end close was not performed consistently, resulting in controls not functioning properly throughout the year. Effect: The issues discussed above resulted in substantial delay in intercompany reimbursements and the completion of the Organization?s financial statement audit. The matter is considered a finding and a significant deficiency in internal control over financial reporting and compliance in accordance with Government Auditing Standards. Recommendation: We recommend Management (1) complete an updated analysis of the Organization?s internal controls and risks posed by the COVID-19 pandemic; (2) determine what staffing changes are necessary to ensure the Organization has adequate personnel to perform the duties and responsibilities vital to the accounting and finance function, while minimizing the sharing of non-accounting/finance responsibilities; and (3) ensure that reconciliations of all key accounts are reviewed and approved by someone independent of the individual performing the reconciliation, preferable by in individual within senior management. Views of Responsible Officials: Executive Management agrees with the finding?s content described above and intends to implement all of the recommendations. The COVID-19 pandemic was an unforeseen event that put the lives of the Organization?s residents and employees at risk. Management and the Board of Directors were required to make quick decisions in an ever-evolving environment, often with conflicting guidance from government authorities, to prevent a more tragic scenario from coming to fruition. Management?s election to deploy all available resources, both personnel and otherwise, to prevent infection and ensure the livelihood of the Project?s residents did indeed result in certain controls not working as intended, or being overridden for the ultimate collective welfare of the residents and the property. It is Management?s position that its assessment performed in the wake of the audit has allowed the Project to identify areas of weakness, and amend policies to address those weaknesses, and implement changes that will improve the accuracy of financial information and effectiveness of the Organization as a whole. The Organization has made personnel changes starting in 2021, including placement of a Chief Financial Officer and additional hires, to ensure that all prescribed responsibilities within accounting and finance are completed timely and accurately. Management has also changed the policy for intercompany expense allocation and reimbursement, and starting in 2022 is requiring all transactions be performed solely between JFC and FCA II rather than a combination of JFC, FCA, FCA II, and FCA III.

Planned Corrective Action We have or intend to implement policies, procedures, and controls to address all of the recommendations made by our independent accountants. The COVID-19 pandemic was an unforeseen event that put the lives of the Organization?s residents and employees at risk. We were required to make quick decisions in an ever-evolving environment, often with conflicting guidance from government authorities, to prevent a more tragic scenario from coming to fruition. Our election to deploy all available resources, both personnel and otherwise, to prevent infection and ensure the livelihood of our residents did indeed result in certain controls not working as intended or being overridden for the ultimate collective welfare of the residents and the property. The assessment we performed in the wake of the audit has allowed the us to identify areas of weakness, and amend policies to address those weaknesses, and implement changes that will improve the accuracy of financial information and effectiveness of the Organization as a whole. Starting in 2021, we began implementing personnel changes, including placement of a Chief Financial Officer and additional hires, to ensure that all prescribed responsibilities within accounting and finance are completed timely and accurately. Our management team has also changed the policy for intercompany expense allocation and reimbursement, and starting in 2022 is requiring all transactions be performed solely between JFC and FCA II rather than a combination of JFC, FCA, FCA II, and FCA III. We believe this modified reimbursement policy will improve efficiency during month- and year-end close as well as reduce the possibility for errors. We intend to have all actions above completed no later than March 31, 2022.

Criteria: Submission of the audited financial statements to the federal audit clearinghouse is required to be completed no later than nine months after the end of the audit period. Condition: Submission of the audited financial statements to the federal audit clearinghouse for the period ending December 31, 2019 was not completed. Cause: The Organization has suffered from the ongoing effects of the COVID-19 pandemic, turnover, and other administrative matters. It was unable to dedicate resources to ensure completion of the Organization?s financial statement audit. Effect: The 2019 financial statement audit was not completed and, therefore, no financial statements were submitted to the federal audit clearinghouse. The filing is considered delinquent. Recommendation: We recommend that management submit the audited financial statements to the federal audit clearinghouse. Views of Responsible Officials: The Organization agrees with the finding and the recommendation will be completed.

Planned Corrective Action We have or intend to implement policies, procedures, and controls to address all of the recommendations made by our independent accountants. The actions documented above related to Finding No. 2019-1 will prevent a recurrence of Finding No. 2019-2. In addition, we intend on filing the financial reporting package with the FAC no later than March 31, 2022.

Criteria: The regulatory agreement provides that the Organization deposit surplus cash into a separate account no more than 60 days after fiscal year end. Condition: Deposits of $1,621 due to the residual receipts account, for the year end December 31, 2019 were not remitted in the time prescribed by HUD. Cause: The Organization?s existing policy was to wait until all audit adjustments were received from the independent accountant prior to calculating surplus cash in order to make the assessment as to whether a contribution to the residual receipts account was necessary. As the audit of the Organization?s financial statements for the year ended December 31, 2019 was not completed until after the date the residual receipts were due to be deposited, the transfer was not completed timely. Effect: The deposit is considered delinquent and remains outstanding. Recommendation: We recommend that management transfer the funds as soon as administratively feasible. Views of Responsible Officials: The Organization agrees with the finding and the recommendation will be completed.

Planned Corrective Action We have changed the manner in which we calculate excess cash to perform the calculation based on preliminary internal financial statements rather our than final audited financial statements. We believe that our internal financial statements are sufficiently accurate for the calculation of surplus cash and, therefore, sufficient to use to determine whether a deposit into the residual receipts account is necessary. If a deposit is necessary based on preliminary unaudited financial data, we will make the deposit within 30 days of year-end. An additional calculation will be performed when final audited financial data is available to determine if any correction is necessary. We will make the deposit for the excess cash at December 31, 2019 into the residual receipts account no later than March 31, 2022.