Audit 303161

2023-002 Eligibility Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must determine HAP assistance based on a calculation from the eligible tenant’s annual income, deductions and third party verification in accordance with HUD Section 8 Housing Voucher Program compliance requirements. 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). Condition During our review of tenant files, one tenant did not have income verified with a third party during the annual recertification as well as not having their family income and composition reexamined every 12 months. We also noted two instances where utility allowances were calculated incorrectly resulting in incorrect HAP payments that were not caught. Questioned Costs None Context We reviewed a sample of 40 tenant files for eligibility requirements. Effect Tenants may not be provided the proper housing assistance in accordance with their income and eligibility factors. Cause Lack of controls and oversight during the year. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all necessary procedures have been performed and appropriate documents are included. The review would also ensure that procedures are being performed correctly and calculations are accurate. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-002 Eligibility Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must determine HAP assistance based on a calculation from the eligible tenant’s annual income, deductions and third party verification in accordance with HUD Section 8 Housing Voucher Program compliance requirements. 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). Condition During our review of tenant files, one tenant did not have income verified with a third party during the annual recertification as well as not having their family income and composition reexamined every 12 months. We also noted two instances where utility allowances were calculated incorrectly resulting in incorrect HAP payments that were not caught. Questioned Costs None Context We reviewed a sample of 40 tenant files for eligibility requirements. Effect Tenants may not be provided the proper housing assistance in accordance with their income and eligibility factors. Cause Lack of controls and oversight during the year. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all necessary procedures have been performed and appropriate documents are included. The review would also ensure that procedures are being performed correctly and calculations are accurate. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-002 Eligibility Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must determine HAP assistance based on a calculation from the eligible tenant’s annual income, deductions and third party verification in accordance with HUD Section 8 Housing Voucher Program compliance requirements. 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). Condition During our review of tenant files, one tenant did not have income verified with a third party during the annual recertification as well as not having their family income and composition reexamined every 12 months. We also noted two instances where utility allowances were calculated incorrectly resulting in incorrect HAP payments that were not caught. Questioned Costs None Context We reviewed a sample of 40 tenant files for eligibility requirements. Effect Tenants may not be provided the proper housing assistance in accordance with their income and eligibility factors. Cause Lack of controls and oversight during the year. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all necessary procedures have been performed and appropriate documents are included. The review would also ensure that procedures are being performed correctly and calculations are accurate. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-002 Eligibility Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must determine HAP assistance based on a calculation from the eligible tenant’s annual income, deductions and third party verification in accordance with HUD Section 8 Housing Voucher Program compliance requirements. 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). Condition During our review of tenant files, one tenant did not have income verified with a third party during the annual recertification as well as not having their family income and composition reexamined every 12 months. We also noted two instances where utility allowances were calculated incorrectly resulting in incorrect HAP payments that were not caught. Questioned Costs None Context We reviewed a sample of 40 tenant files for eligibility requirements. Effect Tenants may not be provided the proper housing assistance in accordance with their income and eligibility factors. Cause Lack of controls and oversight during the year. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all necessary procedures have been performed and appropriate documents are included. The review would also ensure that procedures are being performed correctly and calculations are accurate. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-002 Eligibility Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must determine HAP assistance based on a calculation from the eligible tenant’s annual income, deductions and third party verification in accordance with HUD Section 8 Housing Voucher Program compliance requirements. 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). Condition During our review of tenant files, one tenant did not have income verified with a third party during the annual recertification as well as not having their family income and composition reexamined every 12 months. We also noted two instances where utility allowances were calculated incorrectly resulting in incorrect HAP payments that were not caught. Questioned Costs None Context We reviewed a sample of 40 tenant files for eligibility requirements. Effect Tenants may not be provided the proper housing assistance in accordance with their income and eligibility factors. Cause Lack of controls and oversight during the year. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all necessary procedures have been performed and appropriate documents are included. The review would also ensure that procedures are being performed correctly and calculations are accurate. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-002 Eligibility Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must determine HAP assistance based on a calculation from the eligible tenant’s annual income, deductions and third party verification in accordance with HUD Section 8 Housing Voucher Program compliance requirements. 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). Condition During our review of tenant files, one tenant did not have income verified with a third party during the annual recertification as well as not having their family income and composition reexamined every 12 months. We also noted two instances where utility allowances were calculated incorrectly resulting in incorrect HAP payments that were not caught. Questioned Costs None Context We reviewed a sample of 40 tenant files for eligibility requirements. Effect Tenants may not be provided the proper housing assistance in accordance with their income and eligibility factors. Cause Lack of controls and oversight during the year. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all necessary procedures have been performed and appropriate documents are included. The review would also ensure that procedures are being performed correctly and calculations are accurate. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-002 Eligibility Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must determine HAP assistance based on a calculation from the eligible tenant’s annual income, deductions and third party verification in accordance with HUD Section 8 Housing Voucher Program compliance requirements. 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). Condition During our review of tenant files, one tenant did not have income verified with a third party during the annual recertification as well as not having their family income and composition reexamined every 12 months. We also noted two instances where utility allowances were calculated incorrectly resulting in incorrect HAP payments that were not caught. Questioned Costs None Context We reviewed a sample of 40 tenant files for eligibility requirements. Effect Tenants may not be provided the proper housing assistance in accordance with their income and eligibility factors. Cause Lack of controls and oversight during the year. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all necessary procedures have been performed and appropriate documents are included. The review would also ensure that procedures are being performed correctly and calculations are accurate. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-003 Special Tests and Provisions: Rent Reasonableness Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition We tested compliance with the Authority’s rent reasonableness forms in 40 tenant files and found that one tenant did not have a rent reasonableness form for an increase in rent. The rent was deemed reasonable by the Authority once noted by the auditors. We also noted two tenants whose rent was not within 110% of the rent reasonableness comparables. Questioned Costs None Context We reviewed a sample of 40 tenant files for rent reasonableness requirements. Effect HAP payments could have been paid to a tenant where rent was not considered reasonable. Cause Upon change in rent during the term of the HAP contract, the tenant file did not contain forms comparing the rent of like-kind units and the rent comparison was not reviewed to ensure that it was within the required percentage. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all appropriate documents are included. Views of Responsible Officials The Authority will have a checklist on annual certifications to ensure all appropriate documents are included in the file.

2023-003 Special Tests and Provisions: Rent Reasonableness Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition We tested compliance with the Authority’s rent reasonableness forms in 40 tenant files and found that one tenant did not have a rent reasonableness form for an increase in rent. The rent was deemed reasonable by the Authority once noted by the auditors. We also noted two tenants whose rent was not within 110% of the rent reasonableness comparables. Questioned Costs None Context We reviewed a sample of 40 tenant files for rent reasonableness requirements. Effect HAP payments could have been paid to a tenant where rent was not considered reasonable. Cause Upon change in rent during the term of the HAP contract, the tenant file did not contain forms comparing the rent of like-kind units and the rent comparison was not reviewed to ensure that it was within the required percentage. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all appropriate documents are included. Views of Responsible Officials The Authority will have a checklist on annual certifications to ensure all appropriate documents are included in the file.

2023-003 Special Tests and Provisions: Rent Reasonableness Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition We tested compliance with the Authority’s rent reasonableness forms in 40 tenant files and found that one tenant did not have a rent reasonableness form for an increase in rent. The rent was deemed reasonable by the Authority once noted by the auditors. We also noted two tenants whose rent was not within 110% of the rent reasonableness comparables. Questioned Costs None Context We reviewed a sample of 40 tenant files for rent reasonableness requirements. Effect HAP payments could have been paid to a tenant where rent was not considered reasonable. Cause Upon change in rent during the term of the HAP contract, the tenant file did not contain forms comparing the rent of like-kind units and the rent comparison was not reviewed to ensure that it was within the required percentage. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all appropriate documents are included. Views of Responsible Officials The Authority will have a checklist on annual certifications to ensure all appropriate documents are included in the file.

2023-003 Special Tests and Provisions: Rent Reasonableness Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition We tested compliance with the Authority’s rent reasonableness forms in 40 tenant files and found that one tenant did not have a rent reasonableness form for an increase in rent. The rent was deemed reasonable by the Authority once noted by the auditors. We also noted two tenants whose rent was not within 110% of the rent reasonableness comparables. Questioned Costs None Context We reviewed a sample of 40 tenant files for rent reasonableness requirements. Effect HAP payments could have been paid to a tenant where rent was not considered reasonable. Cause Upon change in rent during the term of the HAP contract, the tenant file did not contain forms comparing the rent of like-kind units and the rent comparison was not reviewed to ensure that it was within the required percentage. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all appropriate documents are included. Views of Responsible Officials The Authority will have a checklist on annual certifications to ensure all appropriate documents are included in the file.

2023-003 Special Tests and Provisions: Rent Reasonableness Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition We tested compliance with the Authority’s rent reasonableness forms in 40 tenant files and found that one tenant did not have a rent reasonableness form for an increase in rent. The rent was deemed reasonable by the Authority once noted by the auditors. We also noted two tenants whose rent was not within 110% of the rent reasonableness comparables. Questioned Costs None Context We reviewed a sample of 40 tenant files for rent reasonableness requirements. Effect HAP payments could have been paid to a tenant where rent was not considered reasonable. Cause Upon change in rent during the term of the HAP contract, the tenant file did not contain forms comparing the rent of like-kind units and the rent comparison was not reviewed to ensure that it was within the required percentage. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all appropriate documents are included. Views of Responsible Officials The Authority will have a checklist on annual certifications to ensure all appropriate documents are included in the file.

2023-003 Special Tests and Provisions: Rent Reasonableness Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition We tested compliance with the Authority’s rent reasonableness forms in 40 tenant files and found that one tenant did not have a rent reasonableness form for an increase in rent. The rent was deemed reasonable by the Authority once noted by the auditors. We also noted two tenants whose rent was not within 110% of the rent reasonableness comparables. Questioned Costs None Context We reviewed a sample of 40 tenant files for rent reasonableness requirements. Effect HAP payments could have been paid to a tenant where rent was not considered reasonable. Cause Upon change in rent during the term of the HAP contract, the tenant file did not contain forms comparing the rent of like-kind units and the rent comparison was not reviewed to ensure that it was within the required percentage. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all appropriate documents are included. Views of Responsible Officials The Authority will have a checklist on annual certifications to ensure all appropriate documents are included in the file.

2023-003 Special Tests and Provisions: Rent Reasonableness Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition We tested compliance with the Authority’s rent reasonableness forms in 40 tenant files and found that one tenant did not have a rent reasonableness form for an increase in rent. The rent was deemed reasonable by the Authority once noted by the auditors. We also noted two tenants whose rent was not within 110% of the rent reasonableness comparables. Questioned Costs None Context We reviewed a sample of 40 tenant files for rent reasonableness requirements. Effect HAP payments could have been paid to a tenant where rent was not considered reasonable. Cause Upon change in rent during the term of the HAP contract, the tenant file did not contain forms comparing the rent of like-kind units and the rent comparison was not reviewed to ensure that it was within the required percentage. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all appropriate documents are included. Views of Responsible Officials The Authority will have a checklist on annual certifications to ensure all appropriate documents are included in the file.

004 Special Tests and Provisions: HQS Enforcement Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspection and all other HQS deficiencies within 30 calendar days. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). Condition We tested compliance with the Authority’s HQS Enforcement on 40 failed inspections and found that one failed inspection was not cleared timely and HAP payments were not abated. Questioned Costs None Context We reviewed a sample of 40 of the Authority’s 508 failed inspections to note a re-inspection and subsequent pass. Effect The tenant could be living in a unit that is not fit for living, or not up to standard with the lease agreement terms. Cause The failed inspection was not followed up on within a reasonable time to ensure that the failed items were corrected. Repeat Finding Not a repeat finding. Recommendation We recommend implementing a review process that occurs within the required timeframe for inspections to be followed up in order to ensure the failed inspections are appropriately taken care of. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

004 Special Tests and Provisions: HQS Enforcement Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspection and all other HQS deficiencies within 30 calendar days. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). Condition We tested compliance with the Authority’s HQS Enforcement on 40 failed inspections and found that one failed inspection was not cleared timely and HAP payments were not abated. Questioned Costs None Context We reviewed a sample of 40 of the Authority’s 508 failed inspections to note a re-inspection and subsequent pass. Effect The tenant could be living in a unit that is not fit for living, or not up to standard with the lease agreement terms. Cause The failed inspection was not followed up on within a reasonable time to ensure that the failed items were corrected. Repeat Finding Not a repeat finding. Recommendation We recommend implementing a review process that occurs within the required timeframe for inspections to be followed up in order to ensure the failed inspections are appropriately taken care of. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

004 Special Tests and Provisions: HQS Enforcement Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspection and all other HQS deficiencies within 30 calendar days. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). Condition We tested compliance with the Authority’s HQS Enforcement on 40 failed inspections and found that one failed inspection was not cleared timely and HAP payments were not abated. Questioned Costs None Context We reviewed a sample of 40 of the Authority’s 508 failed inspections to note a re-inspection and subsequent pass. Effect The tenant could be living in a unit that is not fit for living, or not up to standard with the lease agreement terms. Cause The failed inspection was not followed up on within a reasonable time to ensure that the failed items were corrected. Repeat Finding Not a repeat finding. Recommendation We recommend implementing a review process that occurs within the required timeframe for inspections to be followed up in order to ensure the failed inspections are appropriately taken care of. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

004 Special Tests and Provisions: HQS Enforcement Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspection and all other HQS deficiencies within 30 calendar days. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). Condition We tested compliance with the Authority’s HQS Enforcement on 40 failed inspections and found that one failed inspection was not cleared timely and HAP payments were not abated. Questioned Costs None Context We reviewed a sample of 40 of the Authority’s 508 failed inspections to note a re-inspection and subsequent pass. Effect The tenant could be living in a unit that is not fit for living, or not up to standard with the lease agreement terms. Cause The failed inspection was not followed up on within a reasonable time to ensure that the failed items were corrected. Repeat Finding Not a repeat finding. Recommendation We recommend implementing a review process that occurs within the required timeframe for inspections to be followed up in order to ensure the failed inspections are appropriately taken care of. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

004 Special Tests and Provisions: HQS Enforcement Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspection and all other HQS deficiencies within 30 calendar days. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). Condition We tested compliance with the Authority’s HQS Enforcement on 40 failed inspections and found that one failed inspection was not cleared timely and HAP payments were not abated. Questioned Costs None Context We reviewed a sample of 40 of the Authority’s 508 failed inspections to note a re-inspection and subsequent pass. Effect The tenant could be living in a unit that is not fit for living, or not up to standard with the lease agreement terms. Cause The failed inspection was not followed up on within a reasonable time to ensure that the failed items were corrected. Repeat Finding Not a repeat finding. Recommendation We recommend implementing a review process that occurs within the required timeframe for inspections to be followed up in order to ensure the failed inspections are appropriately taken care of. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

004 Special Tests and Provisions: HQS Enforcement Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspection and all other HQS deficiencies within 30 calendar days. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). Condition We tested compliance with the Authority’s HQS Enforcement on 40 failed inspections and found that one failed inspection was not cleared timely and HAP payments were not abated. Questioned Costs None Context We reviewed a sample of 40 of the Authority’s 508 failed inspections to note a re-inspection and subsequent pass. Effect The tenant could be living in a unit that is not fit for living, or not up to standard with the lease agreement terms. Cause The failed inspection was not followed up on within a reasonable time to ensure that the failed items were corrected. Repeat Finding Not a repeat finding. Recommendation We recommend implementing a review process that occurs within the required timeframe for inspections to be followed up in order to ensure the failed inspections are appropriately taken care of. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

004 Special Tests and Provisions: HQS Enforcement Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspection and all other HQS deficiencies within 30 calendar days. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). Condition We tested compliance with the Authority’s HQS Enforcement on 40 failed inspections and found that one failed inspection was not cleared timely and HAP payments were not abated. Questioned Costs None Context We reviewed a sample of 40 of the Authority’s 508 failed inspections to note a re-inspection and subsequent pass. Effect The tenant could be living in a unit that is not fit for living, or not up to standard with the lease agreement terms. Cause The failed inspection was not followed up on within a reasonable time to ensure that the failed items were corrected. Repeat Finding Not a repeat finding. Recommendation We recommend implementing a review process that occurs within the required timeframe for inspections to be followed up in order to ensure the failed inspections are appropriately taken care of. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-005 Special Tests and Provisions: Depository Agreements Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria PHAs are required to enter into depository agreements with their financial institutions in the form required by HUD (24 CFR section 982.156). The Authority is required to meet the terms of the agreements. Condition The Authority did not meet all the terms set forth by the depository agreements. It was noted that one account was not properly collateralized. Questioned Costs None Context We reviewed the depository agreements required by HUD for bank accounts holding HCV funds. Effect The Authority’s deposits are not covered by collateral and If the bank fails, deposits would be at risk of being lost. Cause The pledged collateral did not exceed deposits over FDIC coverage at the point in time in which deposits were highest. Repeat Finding Not a repeat finding. Recommendation We recommend the Authority reviews pledged collateral balances and deposits on a monthly basis to ensure proper coverage is maintained. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-005 Special Tests and Provisions: Depository Agreements Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria PHAs are required to enter into depository agreements with their financial institutions in the form required by HUD (24 CFR section 982.156). The Authority is required to meet the terms of the agreements. Condition The Authority did not meet all the terms set forth by the depository agreements. It was noted that one account was not properly collateralized. Questioned Costs None Context We reviewed the depository agreements required by HUD for bank accounts holding HCV funds. Effect The Authority’s deposits are not covered by collateral and If the bank fails, deposits would be at risk of being lost. Cause The pledged collateral did not exceed deposits over FDIC coverage at the point in time in which deposits were highest. Repeat Finding Not a repeat finding. Recommendation We recommend the Authority reviews pledged collateral balances and deposits on a monthly basis to ensure proper coverage is maintained. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-005 Special Tests and Provisions: Depository Agreements Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria PHAs are required to enter into depository agreements with their financial institutions in the form required by HUD (24 CFR section 982.156). The Authority is required to meet the terms of the agreements. Condition The Authority did not meet all the terms set forth by the depository agreements. It was noted that one account was not properly collateralized. Questioned Costs None Context We reviewed the depository agreements required by HUD for bank accounts holding HCV funds. Effect The Authority’s deposits are not covered by collateral and If the bank fails, deposits would be at risk of being lost. Cause The pledged collateral did not exceed deposits over FDIC coverage at the point in time in which deposits were highest. Repeat Finding Not a repeat finding. Recommendation We recommend the Authority reviews pledged collateral balances and deposits on a monthly basis to ensure proper coverage is maintained. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-005 Special Tests and Provisions: Depository Agreements Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria PHAs are required to enter into depository agreements with their financial institutions in the form required by HUD (24 CFR section 982.156). The Authority is required to meet the terms of the agreements. Condition The Authority did not meet all the terms set forth by the depository agreements. It was noted that one account was not properly collateralized. Questioned Costs None Context We reviewed the depository agreements required by HUD for bank accounts holding HCV funds. Effect The Authority’s deposits are not covered by collateral and If the bank fails, deposits would be at risk of being lost. Cause The pledged collateral did not exceed deposits over FDIC coverage at the point in time in which deposits were highest. Repeat Finding Not a repeat finding. Recommendation We recommend the Authority reviews pledged collateral balances and deposits on a monthly basis to ensure proper coverage is maintained. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-005 Special Tests and Provisions: Depository Agreements Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria PHAs are required to enter into depository agreements with their financial institutions in the form required by HUD (24 CFR section 982.156). The Authority is required to meet the terms of the agreements. Condition The Authority did not meet all the terms set forth by the depository agreements. It was noted that one account was not properly collateralized. Questioned Costs None Context We reviewed the depository agreements required by HUD for bank accounts holding HCV funds. Effect The Authority’s deposits are not covered by collateral and If the bank fails, deposits would be at risk of being lost. Cause The pledged collateral did not exceed deposits over FDIC coverage at the point in time in which deposits were highest. Repeat Finding Not a repeat finding. Recommendation We recommend the Authority reviews pledged collateral balances and deposits on a monthly basis to ensure proper coverage is maintained. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-005 Special Tests and Provisions: Depository Agreements Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria PHAs are required to enter into depository agreements with their financial institutions in the form required by HUD (24 CFR section 982.156). The Authority is required to meet the terms of the agreements. Condition The Authority did not meet all the terms set forth by the depository agreements. It was noted that one account was not properly collateralized. Questioned Costs None Context We reviewed the depository agreements required by HUD for bank accounts holding HCV funds. Effect The Authority’s deposits are not covered by collateral and If the bank fails, deposits would be at risk of being lost. Cause The pledged collateral did not exceed deposits over FDIC coverage at the point in time in which deposits were highest. Repeat Finding Not a repeat finding. Recommendation We recommend the Authority reviews pledged collateral balances and deposits on a monthly basis to ensure proper coverage is maintained. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-005 Special Tests and Provisions: Depository Agreements Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria PHAs are required to enter into depository agreements with their financial institutions in the form required by HUD (24 CFR section 982.156). The Authority is required to meet the terms of the agreements. Condition The Authority did not meet all the terms set forth by the depository agreements. It was noted that one account was not properly collateralized. Questioned Costs None Context We reviewed the depository agreements required by HUD for bank accounts holding HCV funds. Effect The Authority’s deposits are not covered by collateral and If the bank fails, deposits would be at risk of being lost. Cause The pledged collateral did not exceed deposits over FDIC coverage at the point in time in which deposits were highest. Repeat Finding Not a repeat finding. Recommendation We recommend the Authority reviews pledged collateral balances and deposits on a monthly basis to ensure proper coverage is maintained. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-002 Eligibility Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must determine HAP assistance based on a calculation from the eligible tenant’s annual income, deductions and third party verification in accordance with HUD Section 8 Housing Voucher Program compliance requirements. 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). Condition During our review of tenant files, one tenant did not have income verified with a third party during the annual recertification as well as not having their family income and composition reexamined every 12 months. We also noted two instances where utility allowances were calculated incorrectly resulting in incorrect HAP payments that were not caught. Questioned Costs None Context We reviewed a sample of 40 tenant files for eligibility requirements. Effect Tenants may not be provided the proper housing assistance in accordance with their income and eligibility factors. Cause Lack of controls and oversight during the year. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all necessary procedures have been performed and appropriate documents are included. The review would also ensure that procedures are being performed correctly and calculations are accurate. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-002 Eligibility Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must determine HAP assistance based on a calculation from the eligible tenant’s annual income, deductions and third party verification in accordance with HUD Section 8 Housing Voucher Program compliance requirements. 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). Condition During our review of tenant files, one tenant did not have income verified with a third party during the annual recertification as well as not having their family income and composition reexamined every 12 months. We also noted two instances where utility allowances were calculated incorrectly resulting in incorrect HAP payments that were not caught. Questioned Costs None Context We reviewed a sample of 40 tenant files for eligibility requirements. Effect Tenants may not be provided the proper housing assistance in accordance with their income and eligibility factors. Cause Lack of controls and oversight during the year. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all necessary procedures have been performed and appropriate documents are included. The review would also ensure that procedures are being performed correctly and calculations are accurate. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-002 Eligibility Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must determine HAP assistance based on a calculation from the eligible tenant’s annual income, deductions and third party verification in accordance with HUD Section 8 Housing Voucher Program compliance requirements. 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). Condition During our review of tenant files, one tenant did not have income verified with a third party during the annual recertification as well as not having their family income and composition reexamined every 12 months. We also noted two instances where utility allowances were calculated incorrectly resulting in incorrect HAP payments that were not caught. Questioned Costs None Context We reviewed a sample of 40 tenant files for eligibility requirements. Effect Tenants may not be provided the proper housing assistance in accordance with their income and eligibility factors. Cause Lack of controls and oversight during the year. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all necessary procedures have been performed and appropriate documents are included. The review would also ensure that procedures are being performed correctly and calculations are accurate. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-002 Eligibility Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must determine HAP assistance based on a calculation from the eligible tenant’s annual income, deductions and third party verification in accordance with HUD Section 8 Housing Voucher Program compliance requirements. 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). Condition During our review of tenant files, one tenant did not have income verified with a third party during the annual recertification as well as not having their family income and composition reexamined every 12 months. We also noted two instances where utility allowances were calculated incorrectly resulting in incorrect HAP payments that were not caught. Questioned Costs None Context We reviewed a sample of 40 tenant files for eligibility requirements. Effect Tenants may not be provided the proper housing assistance in accordance with their income and eligibility factors. Cause Lack of controls and oversight during the year. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all necessary procedures have been performed and appropriate documents are included. The review would also ensure that procedures are being performed correctly and calculations are accurate. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-002 Eligibility Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must determine HAP assistance based on a calculation from the eligible tenant’s annual income, deductions and third party verification in accordance with HUD Section 8 Housing Voucher Program compliance requirements. 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). Condition During our review of tenant files, one tenant did not have income verified with a third party during the annual recertification as well as not having their family income and composition reexamined every 12 months. We also noted two instances where utility allowances were calculated incorrectly resulting in incorrect HAP payments that were not caught. Questioned Costs None Context We reviewed a sample of 40 tenant files for eligibility requirements. Effect Tenants may not be provided the proper housing assistance in accordance with their income and eligibility factors. Cause Lack of controls and oversight during the year. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all necessary procedures have been performed and appropriate documents are included. The review would also ensure that procedures are being performed correctly and calculations are accurate. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-002 Eligibility Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must determine HAP assistance based on a calculation from the eligible tenant’s annual income, deductions and third party verification in accordance with HUD Section 8 Housing Voucher Program compliance requirements. 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). Condition During our review of tenant files, one tenant did not have income verified with a third party during the annual recertification as well as not having their family income and composition reexamined every 12 months. We also noted two instances where utility allowances were calculated incorrectly resulting in incorrect HAP payments that were not caught. Questioned Costs None Context We reviewed a sample of 40 tenant files for eligibility requirements. Effect Tenants may not be provided the proper housing assistance in accordance with their income and eligibility factors. Cause Lack of controls and oversight during the year. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all necessary procedures have been performed and appropriate documents are included. The review would also ensure that procedures are being performed correctly and calculations are accurate. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-002 Eligibility Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must determine HAP assistance based on a calculation from the eligible tenant’s annual income, deductions and third party verification in accordance with HUD Section 8 Housing Voucher Program compliance requirements. 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). Condition During our review of tenant files, one tenant did not have income verified with a third party during the annual recertification as well as not having their family income and composition reexamined every 12 months. We also noted two instances where utility allowances were calculated incorrectly resulting in incorrect HAP payments that were not caught. Questioned Costs None Context We reviewed a sample of 40 tenant files for eligibility requirements. Effect Tenants may not be provided the proper housing assistance in accordance with their income and eligibility factors. Cause Lack of controls and oversight during the year. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all necessary procedures have been performed and appropriate documents are included. The review would also ensure that procedures are being performed correctly and calculations are accurate. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-003 Special Tests and Provisions: Rent Reasonableness Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition We tested compliance with the Authority’s rent reasonableness forms in 40 tenant files and found that one tenant did not have a rent reasonableness form for an increase in rent. The rent was deemed reasonable by the Authority once noted by the auditors. We also noted two tenants whose rent was not within 110% of the rent reasonableness comparables. Questioned Costs None Context We reviewed a sample of 40 tenant files for rent reasonableness requirements. Effect HAP payments could have been paid to a tenant where rent was not considered reasonable. Cause Upon change in rent during the term of the HAP contract, the tenant file did not contain forms comparing the rent of like-kind units and the rent comparison was not reviewed to ensure that it was within the required percentage. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all appropriate documents are included. Views of Responsible Officials The Authority will have a checklist on annual certifications to ensure all appropriate documents are included in the file.

2023-003 Special Tests and Provisions: Rent Reasonableness Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition We tested compliance with the Authority’s rent reasonableness forms in 40 tenant files and found that one tenant did not have a rent reasonableness form for an increase in rent. The rent was deemed reasonable by the Authority once noted by the auditors. We also noted two tenants whose rent was not within 110% of the rent reasonableness comparables. Questioned Costs None Context We reviewed a sample of 40 tenant files for rent reasonableness requirements. Effect HAP payments could have been paid to a tenant where rent was not considered reasonable. Cause Upon change in rent during the term of the HAP contract, the tenant file did not contain forms comparing the rent of like-kind units and the rent comparison was not reviewed to ensure that it was within the required percentage. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all appropriate documents are included. Views of Responsible Officials The Authority will have a checklist on annual certifications to ensure all appropriate documents are included in the file.

2023-003 Special Tests and Provisions: Rent Reasonableness Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition We tested compliance with the Authority’s rent reasonableness forms in 40 tenant files and found that one tenant did not have a rent reasonableness form for an increase in rent. The rent was deemed reasonable by the Authority once noted by the auditors. We also noted two tenants whose rent was not within 110% of the rent reasonableness comparables. Questioned Costs None Context We reviewed a sample of 40 tenant files for rent reasonableness requirements. Effect HAP payments could have been paid to a tenant where rent was not considered reasonable. Cause Upon change in rent during the term of the HAP contract, the tenant file did not contain forms comparing the rent of like-kind units and the rent comparison was not reviewed to ensure that it was within the required percentage. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all appropriate documents are included. Views of Responsible Officials The Authority will have a checklist on annual certifications to ensure all appropriate documents are included in the file.

2023-003 Special Tests and Provisions: Rent Reasonableness Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition We tested compliance with the Authority’s rent reasonableness forms in 40 tenant files and found that one tenant did not have a rent reasonableness form for an increase in rent. The rent was deemed reasonable by the Authority once noted by the auditors. We also noted two tenants whose rent was not within 110% of the rent reasonableness comparables. Questioned Costs None Context We reviewed a sample of 40 tenant files for rent reasonableness requirements. Effect HAP payments could have been paid to a tenant where rent was not considered reasonable. Cause Upon change in rent during the term of the HAP contract, the tenant file did not contain forms comparing the rent of like-kind units and the rent comparison was not reviewed to ensure that it was within the required percentage. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all appropriate documents are included. Views of Responsible Officials The Authority will have a checklist on annual certifications to ensure all appropriate documents are included in the file.

2023-003 Special Tests and Provisions: Rent Reasonableness Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition We tested compliance with the Authority’s rent reasonableness forms in 40 tenant files and found that one tenant did not have a rent reasonableness form for an increase in rent. The rent was deemed reasonable by the Authority once noted by the auditors. We also noted two tenants whose rent was not within 110% of the rent reasonableness comparables. Questioned Costs None Context We reviewed a sample of 40 tenant files for rent reasonableness requirements. Effect HAP payments could have been paid to a tenant where rent was not considered reasonable. Cause Upon change in rent during the term of the HAP contract, the tenant file did not contain forms comparing the rent of like-kind units and the rent comparison was not reviewed to ensure that it was within the required percentage. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all appropriate documents are included. Views of Responsible Officials The Authority will have a checklist on annual certifications to ensure all appropriate documents are included in the file.

2023-003 Special Tests and Provisions: Rent Reasonableness Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition We tested compliance with the Authority’s rent reasonableness forms in 40 tenant files and found that one tenant did not have a rent reasonableness form for an increase in rent. The rent was deemed reasonable by the Authority once noted by the auditors. We also noted two tenants whose rent was not within 110% of the rent reasonableness comparables. Questioned Costs None Context We reviewed a sample of 40 tenant files for rent reasonableness requirements. Effect HAP payments could have been paid to a tenant where rent was not considered reasonable. Cause Upon change in rent during the term of the HAP contract, the tenant file did not contain forms comparing the rent of like-kind units and the rent comparison was not reviewed to ensure that it was within the required percentage. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all appropriate documents are included. Views of Responsible Officials The Authority will have a checklist on annual certifications to ensure all appropriate documents are included in the file.

2023-003 Special Tests and Provisions: Rent Reasonableness Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition We tested compliance with the Authority’s rent reasonableness forms in 40 tenant files and found that one tenant did not have a rent reasonableness form for an increase in rent. The rent was deemed reasonable by the Authority once noted by the auditors. We also noted two tenants whose rent was not within 110% of the rent reasonableness comparables. Questioned Costs None Context We reviewed a sample of 40 tenant files for rent reasonableness requirements. Effect HAP payments could have been paid to a tenant where rent was not considered reasonable. Cause Upon change in rent during the term of the HAP contract, the tenant file did not contain forms comparing the rent of like-kind units and the rent comparison was not reviewed to ensure that it was within the required percentage. Repeat Finding Not a repeat finding. Recommendation We recommend there be a second party review of the file to ensure all appropriate documents are included. Views of Responsible Officials The Authority will have a checklist on annual certifications to ensure all appropriate documents are included in the file.

004 Special Tests and Provisions: HQS Enforcement Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspection and all other HQS deficiencies within 30 calendar days. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). Condition We tested compliance with the Authority’s HQS Enforcement on 40 failed inspections and found that one failed inspection was not cleared timely and HAP payments were not abated. Questioned Costs None Context We reviewed a sample of 40 of the Authority’s 508 failed inspections to note a re-inspection and subsequent pass. Effect The tenant could be living in a unit that is not fit for living, or not up to standard with the lease agreement terms. Cause The failed inspection was not followed up on within a reasonable time to ensure that the failed items were corrected. Repeat Finding Not a repeat finding. Recommendation We recommend implementing a review process that occurs within the required timeframe for inspections to be followed up in order to ensure the failed inspections are appropriately taken care of. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

004 Special Tests and Provisions: HQS Enforcement Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspection and all other HQS deficiencies within 30 calendar days. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). Condition We tested compliance with the Authority’s HQS Enforcement on 40 failed inspections and found that one failed inspection was not cleared timely and HAP payments were not abated. Questioned Costs None Context We reviewed a sample of 40 of the Authority’s 508 failed inspections to note a re-inspection and subsequent pass. Effect The tenant could be living in a unit that is not fit for living, or not up to standard with the lease agreement terms. Cause The failed inspection was not followed up on within a reasonable time to ensure that the failed items were corrected. Repeat Finding Not a repeat finding. Recommendation We recommend implementing a review process that occurs within the required timeframe for inspections to be followed up in order to ensure the failed inspections are appropriately taken care of. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

004 Special Tests and Provisions: HQS Enforcement Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspection and all other HQS deficiencies within 30 calendar days. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). Condition We tested compliance with the Authority’s HQS Enforcement on 40 failed inspections and found that one failed inspection was not cleared timely and HAP payments were not abated. Questioned Costs None Context We reviewed a sample of 40 of the Authority’s 508 failed inspections to note a re-inspection and subsequent pass. Effect The tenant could be living in a unit that is not fit for living, or not up to standard with the lease agreement terms. Cause The failed inspection was not followed up on within a reasonable time to ensure that the failed items were corrected. Repeat Finding Not a repeat finding. Recommendation We recommend implementing a review process that occurs within the required timeframe for inspections to be followed up in order to ensure the failed inspections are appropriately taken care of. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

004 Special Tests and Provisions: HQS Enforcement Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspection and all other HQS deficiencies within 30 calendar days. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). Condition We tested compliance with the Authority’s HQS Enforcement on 40 failed inspections and found that one failed inspection was not cleared timely and HAP payments were not abated. Questioned Costs None Context We reviewed a sample of 40 of the Authority’s 508 failed inspections to note a re-inspection and subsequent pass. Effect The tenant could be living in a unit that is not fit for living, or not up to standard with the lease agreement terms. Cause The failed inspection was not followed up on within a reasonable time to ensure that the failed items were corrected. Repeat Finding Not a repeat finding. Recommendation We recommend implementing a review process that occurs within the required timeframe for inspections to be followed up in order to ensure the failed inspections are appropriately taken care of. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

004 Special Tests and Provisions: HQS Enforcement Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspection and all other HQS deficiencies within 30 calendar days. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). Condition We tested compliance with the Authority’s HQS Enforcement on 40 failed inspections and found that one failed inspection was not cleared timely and HAP payments were not abated. Questioned Costs None Context We reviewed a sample of 40 of the Authority’s 508 failed inspections to note a re-inspection and subsequent pass. Effect The tenant could be living in a unit that is not fit for living, or not up to standard with the lease agreement terms. Cause The failed inspection was not followed up on within a reasonable time to ensure that the failed items were corrected. Repeat Finding Not a repeat finding. Recommendation We recommend implementing a review process that occurs within the required timeframe for inspections to be followed up in order to ensure the failed inspections are appropriately taken care of. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

004 Special Tests and Provisions: HQS Enforcement Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspection and all other HQS deficiencies within 30 calendar days. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). Condition We tested compliance with the Authority’s HQS Enforcement on 40 failed inspections and found that one failed inspection was not cleared timely and HAP payments were not abated. Questioned Costs None Context We reviewed a sample of 40 of the Authority’s 508 failed inspections to note a re-inspection and subsequent pass. Effect The tenant could be living in a unit that is not fit for living, or not up to standard with the lease agreement terms. Cause The failed inspection was not followed up on within a reasonable time to ensure that the failed items were corrected. Repeat Finding Not a repeat finding. Recommendation We recommend implementing a review process that occurs within the required timeframe for inspections to be followed up in order to ensure the failed inspections are appropriately taken care of. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

004 Special Tests and Provisions: HQS Enforcement Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria The Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspection and all other HQS deficiencies within 30 calendar days. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). Condition We tested compliance with the Authority’s HQS Enforcement on 40 failed inspections and found that one failed inspection was not cleared timely and HAP payments were not abated. Questioned Costs None Context We reviewed a sample of 40 of the Authority’s 508 failed inspections to note a re-inspection and subsequent pass. Effect The tenant could be living in a unit that is not fit for living, or not up to standard with the lease agreement terms. Cause The failed inspection was not followed up on within a reasonable time to ensure that the failed items were corrected. Repeat Finding Not a repeat finding. Recommendation We recommend implementing a review process that occurs within the required timeframe for inspections to be followed up in order to ensure the failed inspections are appropriately taken care of. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-005 Special Tests and Provisions: Depository Agreements Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria PHAs are required to enter into depository agreements with their financial institutions in the form required by HUD (24 CFR section 982.156). The Authority is required to meet the terms of the agreements. Condition The Authority did not meet all the terms set forth by the depository agreements. It was noted that one account was not properly collateralized. Questioned Costs None Context We reviewed the depository agreements required by HUD for bank accounts holding HCV funds. Effect The Authority’s deposits are not covered by collateral and If the bank fails, deposits would be at risk of being lost. Cause The pledged collateral did not exceed deposits over FDIC coverage at the point in time in which deposits were highest. Repeat Finding Not a repeat finding. Recommendation We recommend the Authority reviews pledged collateral balances and deposits on a monthly basis to ensure proper coverage is maintained. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-005 Special Tests and Provisions: Depository Agreements Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria PHAs are required to enter into depository agreements with their financial institutions in the form required by HUD (24 CFR section 982.156). The Authority is required to meet the terms of the agreements. Condition The Authority did not meet all the terms set forth by the depository agreements. It was noted that one account was not properly collateralized. Questioned Costs None Context We reviewed the depository agreements required by HUD for bank accounts holding HCV funds. Effect The Authority’s deposits are not covered by collateral and If the bank fails, deposits would be at risk of being lost. Cause The pledged collateral did not exceed deposits over FDIC coverage at the point in time in which deposits were highest. Repeat Finding Not a repeat finding. Recommendation We recommend the Authority reviews pledged collateral balances and deposits on a monthly basis to ensure proper coverage is maintained. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-005 Special Tests and Provisions: Depository Agreements Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria PHAs are required to enter into depository agreements with their financial institutions in the form required by HUD (24 CFR section 982.156). The Authority is required to meet the terms of the agreements. Condition The Authority did not meet all the terms set forth by the depository agreements. It was noted that one account was not properly collateralized. Questioned Costs None Context We reviewed the depository agreements required by HUD for bank accounts holding HCV funds. Effect The Authority’s deposits are not covered by collateral and If the bank fails, deposits would be at risk of being lost. Cause The pledged collateral did not exceed deposits over FDIC coverage at the point in time in which deposits were highest. Repeat Finding Not a repeat finding. Recommendation We recommend the Authority reviews pledged collateral balances and deposits on a monthly basis to ensure proper coverage is maintained. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-005 Special Tests and Provisions: Depository Agreements Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria PHAs are required to enter into depository agreements with their financial institutions in the form required by HUD (24 CFR section 982.156). The Authority is required to meet the terms of the agreements. Condition The Authority did not meet all the terms set forth by the depository agreements. It was noted that one account was not properly collateralized. Questioned Costs None Context We reviewed the depository agreements required by HUD for bank accounts holding HCV funds. Effect The Authority’s deposits are not covered by collateral and If the bank fails, deposits would be at risk of being lost. Cause The pledged collateral did not exceed deposits over FDIC coverage at the point in time in which deposits were highest. Repeat Finding Not a repeat finding. Recommendation We recommend the Authority reviews pledged collateral balances and deposits on a monthly basis to ensure proper coverage is maintained. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-005 Special Tests and Provisions: Depository Agreements Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria PHAs are required to enter into depository agreements with their financial institutions in the form required by HUD (24 CFR section 982.156). The Authority is required to meet the terms of the agreements. Condition The Authority did not meet all the terms set forth by the depository agreements. It was noted that one account was not properly collateralized. Questioned Costs None Context We reviewed the depository agreements required by HUD for bank accounts holding HCV funds. Effect The Authority’s deposits are not covered by collateral and If the bank fails, deposits would be at risk of being lost. Cause The pledged collateral did not exceed deposits over FDIC coverage at the point in time in which deposits were highest. Repeat Finding Not a repeat finding. Recommendation We recommend the Authority reviews pledged collateral balances and deposits on a monthly basis to ensure proper coverage is maintained. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-005 Special Tests and Provisions: Depository Agreements Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria PHAs are required to enter into depository agreements with their financial institutions in the form required by HUD (24 CFR section 982.156). The Authority is required to meet the terms of the agreements. Condition The Authority did not meet all the terms set forth by the depository agreements. It was noted that one account was not properly collateralized. Questioned Costs None Context We reviewed the depository agreements required by HUD for bank accounts holding HCV funds. Effect The Authority’s deposits are not covered by collateral and If the bank fails, deposits would be at risk of being lost. Cause The pledged collateral did not exceed deposits over FDIC coverage at the point in time in which deposits were highest. Repeat Finding Not a repeat finding. Recommendation We recommend the Authority reviews pledged collateral balances and deposits on a monthly basis to ensure proper coverage is maintained. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.

2023-005 Special Tests and Provisions: Depository Agreements Federal Program U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency Grant Award No. ND014-Housing Choice Voucher Federal Award Year 2023 Criteria PHAs are required to enter into depository agreements with their financial institutions in the form required by HUD (24 CFR section 982.156). The Authority is required to meet the terms of the agreements. Condition The Authority did not meet all the terms set forth by the depository agreements. It was noted that one account was not properly collateralized. Questioned Costs None Context We reviewed the depository agreements required by HUD for bank accounts holding HCV funds. Effect The Authority’s deposits are not covered by collateral and If the bank fails, deposits would be at risk of being lost. Cause The pledged collateral did not exceed deposits over FDIC coverage at the point in time in which deposits were highest. Repeat Finding Not a repeat finding. Recommendation We recommend the Authority reviews pledged collateral balances and deposits on a monthly basis to ensure proper coverage is maintained. Views of Responsible Officials Management recognizes the deficiency and plans to implement the auditor’s recommendation.