EIN: 943306836
UEI: Z5EMYX73CCJ7
Audited by: CohnReznick LLP
Oversight agency: 14 [Department of Housing and Urban Development]
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Data as of August 31, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on April 9, 2025. 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 9, 2025 (327 days ago).
What is a management decision? →Department of Housing and Urban Development Finding No. 2024-001; Section 8, Assistance Listing 14.195 Criteria Loans are not permitted to be made from project cash without prior authorization from HUD. Condition During the year ended December 31, 2024, the project paid expenses in the amount of $14,215 on behalf of an affiliate from project cash without HUD approval. The amount due to the project as of December 31, 2024 is $14,215. Cause Procedures were not in place to ensure that cash disbursements of project funds were limited to project operating costs. Effect or Potential Effect The payments of $14,215 were unauthorized loans and therefore considered to be questioned costs. Questioned Costs Questioned costs totaled $14,215. Context In connection with the procedures applied to a sample of 25 disbursements, there were 3 instances, totaling $4,307, where management did not detect disbursements made on behalf of another EHI managed project. Upon review, management found additional invoices totaling $9,908. Identification as a Repeat Finding Not a repeat finding. Recommendation Management should immediately reimburse the amount due to the project and establish procedures to ensure payments of this nature are not made in the future. Auditor Noncompliance Code: G - Unauthorized loans from project assets Finding Resolution Status: Resolved. The Project was reimbursed via check in the amount of $14,215 for the funds disbursed on behalf of a different EHI managed project on February 3, 2025.
Show full finding ▾Hide full finding ▴Department of Housing and Urban Development Finding No. 2024-001; Section 8, Assistance Listing 14.195 Criteria Loans are not permitted to be made from project cash without prior authorization from HUD. Condition During the year ended December 31, 2024, the project paid expenses in the amount of $14,215 on behalf of an affiliate from project cash without HUD approval. The amount due to the project as of December 31, 2024 is $14,215. Cause Procedures were not in place to ensure that cash disbursements of project funds were limited to project operating costs. Effect or Potential Effect The payments of $14,215 were unauthorized loans and therefore considered to be questioned costs. Questioned Costs Questioned costs totaled $14,215. Context In connection with the procedures applied to a sample of 25 disbursements, there were 3 instances, totaling $4,307, where management did not detect disbursements made on behalf of another EHI managed project. Upon review, management found additional invoices totaling $9,908. Identification as a Repeat Finding Not a repeat finding. Recommendation Management should immediately reimburse the amount due to the project and establish procedures to ensure payments of this nature are not made in the future. Auditor Noncompliance Code: G - Unauthorized loans from project assets Finding Resolution Status: Resolved. The Project was reimbursed via check in the amount of $14,215 for the funds disbursed on behalf of a different EHI managed project on February 3, 2025.
A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Finding 2024-001 a. Comments on the Finding and Each Recommendation Management concurs that the Project paid expenses in the amount of $14,215 on behalf of an affiliate from project cash without HUD approval. b. Action(s) Taken or Planned on the Finding Management has retrained staff, reaffirmed the review and approval processes to ensure accuracy and existence of each transaction to ensure no cash disbursements are made on behalf of affiliates without HUD approval. Management will continue to reinforce its internal processes to prevent and detect unauthorized cash disbursements from project assets. It has requested reimbursement from the affiliated project, and the funds have been reimbursed.
FAC accepted this audit on April 10, 2024 — management decision was due October 10, 2024.
FAC accepted this audit on May 29, 2023 — management decision was due November 29, 2023.
Finding No. 2022-001; Section 8 Housing Assistance Payments Program, Assistance Listing 14.195 Criteria Loans are not permitted to be made from project cash without prior authorization from HUD. Condition During the year ended December 31, 2022, the Project paid expenses in the amount of $1,455 on behalf of an affiliate from project cash without HUD approval. The amount due to the Project as of December 31, 2022 is $1,455. Cause Procedures were not in place to ensure that cash disbursements of project funds were limited to project operating costs. Effect or Potential Effect The payments of $1,455 were unauthorized loans and are therefore considered to be questioned costs. Questioned Costs Questioned costs totaled $1,455. Context In connection with the procedures applied to a sample of 25 disbursements, there were two instances, totaling $1,455, where management did not detect and timely correct disbursements made on behalf of another EHI managed project with a similar project name. Identification as a Repeat Finding Not a repeat finding. Recommendation Management should immediately reimburse the amount due to the Project and establish procedures to ensure payments of this nature are not made in the future. Auditor Noncompliance Code: G ? Unauthorized loans from project assets. Finding Resolution Status: Resolved. The Project was reimbursed via check in the amount of $1,455 for the funds disbursed on behalf of a different EHI managed project on February 27, 2023. Views of Responsible Officials Management concurs that the Project paid expenses in the amount of $1,455 on behalf of an affiliate from project cash without HUD approval. Management further notes that they have retrained staff, reaffirmed the review and approval process to ensure accuracy and existence of each transaction to ensure no cash disbursements are made on behalf of affiliates without HUD approval. Management has made changes to internal controls to prevent and detect unauthorized cash disbursements from project assets. It has also been reimbursed from the affiliate project.
Show full finding ▾Hide full finding ▴Finding No. 2022-001; Section 8 Housing Assistance Payments Program, Assistance Listing 14.195 Criteria Loans are not permitted to be made from project cash without prior authorization from HUD. Condition During the year ended December 31, 2022, the Project paid expenses in the amount of $1,455 on behalf of an affiliate from project cash without HUD approval. The amount due to the Project as of December 31, 2022 is $1,455. Cause Procedures were not in place to ensure that cash disbursements of project funds were limited to project operating costs. Effect or Potential Effect The payments of $1,455 were unauthorized loans and are therefore considered to be questioned costs. Questioned Costs Questioned costs totaled $1,455. Context In connection with the procedures applied to a sample of 25 disbursements, there were two instances, totaling $1,455, where management did not detect and timely correct disbursements made on behalf of another EHI managed project with a similar project name. Identification as a Repeat Finding Not a repeat finding. Recommendation Management should immediately reimburse the amount due to the Project and establish procedures to ensure payments of this nature are not made in the future. Auditor Noncompliance Code: G ? Unauthorized loans from project assets. Finding Resolution Status: Resolved. The Project was reimbursed via check in the amount of $1,455 for the funds disbursed on behalf of a different EHI managed project on February 27, 2023. Views of Responsible Officials Management concurs that the Project paid expenses in the amount of $1,455 on behalf of an affiliate from project cash without HUD approval. Management further notes that they have retrained staff, reaffirmed the review and approval process to ensure accuracy and existence of each transaction to ensure no cash disbursements are made on behalf of affiliates without HUD approval. Management has made changes to internal controls to prevent and detect unauthorized cash disbursements from project assets. It has also been reimbursed from the affiliate project.
CORRECTIVE ACTION PLAN Project Legal Name: Sycamore Square Housing Corporation. HUD Project No.: CA390079004 Audit Firm: CohnReznick, LLP Period covered by the audit: 1/1/22-12/31/22 Corrective Action Plan prepared by: Name: Julia Fromme Position: Associate Director of Property Operations Telephone Number: 510-305-4800 The following is a recommended format to be followed by the auditee for preparing a corrective action plan: A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Finding 2022-001 a. Comments on the Finding and Each Recommendation The auditee is to provide a statement of concurrence or nonconcurrence with each finding. The auditee is also to provide a statement of agreement or disagreement with each recommendation in the finding. Management concurs that the Project paid expenses in the amount of $1,455 on behalf of an affiliate from project cash without HUD approval. Management further notes that they have re-trained staff, reaffirmed the review and approval process to ensure accuracy and existence of each transaction to ensure no cash disbursements are made on behalf of affiliates without HUD approval. b. Action(s) Taken or Planned on the Finding The auditee should detail actions taken or planned to correct each finding identified in the report. Appropriate documentation should be submitted for actions taken. For planned actions, the auditee should provide the projected date for completion of all required action. The auditee should provide information on the task(s), subtask(s) and projected completion date(s) for the correction of the deficient condition and repayment of funds if appropriate. Officials responsible for completing the proposed task(s) and subtask(s) should also be identified. If the auditee believes a corrective action is not required, a statement describing the reasons should be included. Management has made changes to internal controls to prevent and detect unauthorized cash disbursements from project assets. It has also received reimbursement from the affiliate project.
Finding No. 2022-002; Section 8 Housing Assistance Payments Program, Assistance Listing 14.195 Criteria Tenant lease files are required to be maintained and tenant eligibility determined in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Condition In connection with our lease file review we noted 1 out of 1 new tenants tested did not have documentation in their lease file that the move-in EIV was run within 90 days of move-in. Cause Management?s policies with respect to the determination of tenant eligibility and the maintenance of tenant lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs were not consistently followed. Effect or Potential Effect The procedures for determining tenant eligibility and maintaining tenant lease files were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Questioned Costs No questioned costs identified. Context In connection with the procedures applied to a sample of 1 tenant, there was one instance where management did not run the EIV within the 90 day window. Identification as a Repeat Finding Not a repeat finding. Recommendation Management should establish procedures and monitor compliance with those procedures to insure that tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Auditor Noncompliance Code: R ? Section 8 program administration. Finding Resolution Status: Resolved. The Project ran the EIV on January 13, 2023. Views of Responsible Officials Management concurs that the move-in EIV was not run within 90 days of move in and that this is not in compliance with the requirement to maintain HUD tenant lease files per the HUD Handbook 4350.3. Management staff have been trained on the requirements to run EIV reports in accordance with the HUD Handbook. Staff have included a note to file explaining the deficiency in the tenant file and will ensure that EIV reports are ran as required moving forward.
Show full finding ▾Hide full finding ▴Finding No. 2022-002; Section 8 Housing Assistance Payments Program, Assistance Listing 14.195 Criteria Tenant lease files are required to be maintained and tenant eligibility determined in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Condition In connection with our lease file review we noted 1 out of 1 new tenants tested did not have documentation in their lease file that the move-in EIV was run within 90 days of move-in. Cause Management?s policies with respect to the determination of tenant eligibility and the maintenance of tenant lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs were not consistently followed. Effect or Potential Effect The procedures for determining tenant eligibility and maintaining tenant lease files were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Questioned Costs No questioned costs identified. Context In connection with the procedures applied to a sample of 1 tenant, there was one instance where management did not run the EIV within the 90 day window. Identification as a Repeat Finding Not a repeat finding. Recommendation Management should establish procedures and monitor compliance with those procedures to insure that tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Auditor Noncompliance Code: R ? Section 8 program administration. Finding Resolution Status: Resolved. The Project ran the EIV on January 13, 2023. Views of Responsible Officials Management concurs that the move-in EIV was not run within 90 days of move in and that this is not in compliance with the requirement to maintain HUD tenant lease files per the HUD Handbook 4350.3. Management staff have been trained on the requirements to run EIV reports in accordance with the HUD Handbook. Staff have included a note to file explaining the deficiency in the tenant file and will ensure that EIV reports are ran as required moving forward.
2. Finding 2022-002 a. Comments on the Finding and Each Recommendation The auditee is to provide a statement of concurrence or nonconcurrence with each finding. The auditee is also to provide a statement of agreement or disagreement with each recommendation in the finding. Management concurs that the move-in EIV was not run within 90 days of move in and that this is no in compliance with the requirement to maintain HUD tenant lease files per the HUD Handbook 4350.3. b. Action(s) Taken or Planned on the Finding The auditee should detail actions taken or planned to correct each finding identified in the report. Appropriate documentation should be submitted for actions taken. For planned actions, the auditee should provide the projected date for completion of all required action. The auditee should provide information on the task(s), subtask(s) and projected completion date(s) for the correction of the deficient condition and repayment of funds if appropriate. Officials responsible for completing the proposed task(s) and subtask(s) should also be identified. If the auditee believes a corrective action is not required, a statement describing the reasons should be included. Management staff have been trained on the requirements to run EIV reports in accordance with the HUD Handbook. Staff have included a note to file explaining the deficiency in the tenant file and will ensure that EIV reports are ran as required moving forward.
FAC accepted this audit on April 27, 2022 — management decision was due October 27, 2022.
FAC accepted this audit on April 5, 2021 — management decision was due October 5, 2021.
FAC accepted this audit on June 25, 2020 — management decision was due December 25, 2020.
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