Finding reference number: 2020-001
Assistance Listing title and number (Federal award identification number and year): Section 8 new construction and substantial rehabilitation Assistance Listing No. 14.182 (NJ39H085044 and 1979)
Auditor non-compliance code: Z - Other
Finding resolution status: In process
Universe population size: The universe population size is not applicable to the finding.
Sample size information: The sample size information is not applicable to the finding.
Statistically valid sample: No
Name of Federal agency: U.S. Department of Housing and Urban Development
Pass-through entity: N/A
Questioned costs: N/A
Statement of Condition 2020-001 (Assistance Listing No. 14.182): The Form SF-SAC Single Audit Data Collection Form for the year ended December 31, 2020 was not submitted to the federal audit clearinghouse in the required timeframe.
Criteria: Pursuant to the Uniform Guidance, the Corporation is required to submit Form SF-SAC Single Audit Data Collection Form within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period.
Effect: The Corporation is not in compliance with Uniform Guidance.
Cause: The Corporation did not file the data collection form for the year ended December 31, 2020 by nine months after the end of the audit period.
Recommendation: The Corporation should submit the Form SF-SAC Single Audit Data Collection Form for the year ended December 31, 2020 as soon as practical.
Completion date: In process
Management Response: Agree. Form SF-SAC Single Audit Data Collection Form for the year ended December 31, 2020 will be submitted to the federal audit clearinghouse as soon as practical.
Finding reference number: 2020-002
Assistance Listing title and number (Federal award identification number and year): Section 8 new construction and substantial rehabilitation Assistance Listing No. 14.182 (NJ39H085044 and 1979)
Auditor non-compliance code: R – Section 8 Program Administration
Finding resolution status: In process
Universe population size: 137 tenant files
Sample size information: 15 tenant files
Statistically valid sample: Yes
Name of Federal agency: U.S. Department of Housing and Urban Development
Pass-through entity: N/A
Questioned costs: N/A
Statement of Condition 2020-002 (Assistance Listing No. 14.182): During the year ended December 31, 2020, 15 of the 15 resident files selected for testing under the HUD Consolidated Audit Guide lacked properly executed and documented resident eligibility forms.
Criteria: In accordance with the Housing Assistance Payments Contract and HUD Handbook 4350.3, the Management Agent must certify and recertify residents and update other applicable forms in accordance with HUD regulations and contractual requirements.
Effect: The Corporation is not in compliance with the terms of the Housing Assistance Payments Contract or HUD Handbook 4350.3. Current, future, and potentially prior funding under the Housing Assistance Payments Contract could be impacted as a result of these resident files.
Cause: Upon taking over management of the property, the Management Agent received incomplete resident files from the previous management agent.
Recommendation: The Management Agent should ensure that all resident files are maintained at the site for each resident of the Property, and the Management Agent should ensure that the resident files include all properly executed and documented resident eligibility forms.
Completion date: In process
Management Response: Agree. Management intends to update all resident files to include all resident eligibility forms during the year ended December 31, 2021.
Finding reference number: 2020-003
Assistance Listing title and number (Federal award identification number and year): Section 8 new construction and substantial rehabilitation Assistance Listing No. 14.182 (NJ39H085044 and 1979)
Auditor non-compliance code: R – Section 8 Program Administration
Finding resolution status: In process
Universe population size: The universe population size is not applicable to the finding.
Sample size information: The sample size information is not applicable to the finding.
Statistically valid sample: No
Name of Federal agency: U.S. Department of Housing and Urban Development
Pass-through entity: N/A
Questioned costs: N/A
Statement of Condition 2020-003 (Assistance Listing No. 14.182): During the year ended December 31, 2020, 7 of the applicants selected for waitlist testing under the HUD Consolidated Audit Guide lacked proper documentation for tenant selection.
Criteria: In accordance with the Housing Assistance Payments Contract and HUD Handbook 4350.3, the Property must select applicants in a systematic fashion from a waitlist for tenant selection.
Effect: The Property is not in compliance with the terms of the Housing Assistance Payments Contract or HUD Handbook 4350.3. Applicants could have selected ineligible applicants for tenant selection over eligible applicants.
Cause: The on-site property manager was not properly maintaining the waitlist per HUD standards.
Recommendation: The Management Agent should ensure that all applicants are properly documented on the waitlist.
Completion date: In process
Management Response: Agree. The Management Agent will review and update, if necessary, its procedures to ensure waitlist is in compliance with HUD Handbook 4530.3.
Finding reference number: 2020-004
Assistance Listing title and number (Federal award identification number and year): Section 8 new construction and substantial rehabilitation Assistance Listing No. 14.182 (NJ39H085044 and 1979)
Auditor non-compliance code: Z - Other
Finding resolution status: In process
Universe population size: The universe population size is not applicable to the finding.
Sample size information: The sample size information is not applicable to the finding.
Statistically valid sample: No
Name of Federal agency: U.S. Department of Housing and Urban Development
Pass-through entity: N/A
Questioned costs: N/A
Statement of Condition 2020-004 (Assistance Listing NO. 14.182): As of December 31, 2020, the owners and management agent did not have written policies and procedures for staff to follow when using the Enterprise Income Verification (EIV) System.
Criteria: Pursuant to HUD housing Notice 2013-06, the owners and management agent must have written policies and procedures for staff to follow when using the EIV System.
Effect: The Corporation is not in compliance with HUD regulations and could allow access to sensitive resident information.
Cause: The Former Agent failed to prepare written EIV policies and procedures in accordance with HUD regulations.
Recommendation: The Management Agent should prepare written EIV policies and procedures in accordance with HUD regulations.
Completion date: In process
Management Response: Agree. The Management Agent will prepare written EIV policies and procedures in accordance with HUD regulations as soon as practical.
Finding reference number: 2020-005
Assistance Listing title and number (Federal award identification number and year): Section 8 new construction and substantial rehabilitation Assistance Listing No. 14.182 (NJ39H085044 and 1979)
Auditor non-compliance code: Z - Other
Finding resolution status: In process
Universe population size: The universe population size is not applicable to the finding.
Sample size information: The sample size information is not applicable to the finding.
Statistically valid sample: No
Name of Federal agency: U.S. Department of Housing and Urban Development
Pass-through entity: N/A
Questioned costs: N/A
Statement of Condition 2020-005 (Assistance Listing No. 14.182): The Corporation's books and records were not maintained in reasonable condition for proper audit as required by HUD.
Criteria: The books and records of the Corporation are required to be kept in accordance with HUD Financial Operations and Accounting Procedures for Insured Handbook (4370.2) Chapter 2: Financial Operations and Accounting (Section 2-3 Maintenance of Books and Records), which requires the records be maintained in reasonable condition for proper audit which includes adequate design and monitoring of controls to safeguard the entity's assets.
Effect: The Corporation is not in compliance with HUD regulations.
Cause: As a result of the change in management agent and the former management agent's inability or refusal to provide access to all relevant finance and accounting materials, we were unable to obtain appropriate audit evidence that the financial statements referred to in the first paragraph were reported in accordance with accounting principles generally accepted in the United States of America, and we were unable to satisfy ourselves by other auditing procedures.
Recommendation: The Board of Directors should ensure the books and records are maintained in reasonable condition for proper audit as required by HUD.
Completion date: December 31, 2020
Management Response: Agree. The management agent will ensure the books and records are maintained in reasonable condition for proper audits as required by HUD going forward.
Finding reference number: 2020-001
Assistance Listing title and number (Federal award identification number and year): Section 8 new construction and substantial rehabilitation Assistance Listing No. 14.182 (NJ39H085044 and 1979)
Auditor non-compliance code: Z - Other
Finding resolution status: In process
Universe population size: The universe population size is not applicable to the finding.
Sample size information: The sample size information is not applicable to the finding.
Statistically valid sample: No
Name of Federal agency: U.S. Department of Housing and Urban Development
Pass-through entity: N/A
Questioned costs: N/A
Statement of Condition 2020-001 (Assistance Listing No. 14.182): The Form SF-SAC Single Audit Data Collection Form for the year ended December 31, 2020 was not submitted to the federal audit clearinghouse in the required timeframe.
Criteria: Pursuant to the Uniform Guidance, the Corporation is required to submit Form SF-SAC Single Audit Data Collection Form within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period.
Effect: The Corporation is not in compliance with Uniform Guidance.
Cause: The Corporation did not file the data collection form for the year ended December 31, 2020 by nine months after the end of the audit period.
Recommendation: The Corporation should submit the Form SF-SAC Single Audit Data Collection Form for the year ended December 31, 2020 as soon as practical.
Completion date: In process
Management Response: Agree. Form SF-SAC Single Audit Data Collection Form for the year ended December 31, 2020 will be submitted to the federal audit clearinghouse as soon as practical.
Finding reference number: 2020-002
Assistance Listing title and number (Federal award identification number and year): Section 8 new construction and substantial rehabilitation Assistance Listing No. 14.182 (NJ39H085044 and 1979)
Auditor non-compliance code: R – Section 8 Program Administration
Finding resolution status: In process
Universe population size: 137 tenant files
Sample size information: 15 tenant files
Statistically valid sample: Yes
Name of Federal agency: U.S. Department of Housing and Urban Development
Pass-through entity: N/A
Questioned costs: N/A
Statement of Condition 2020-002 (Assistance Listing No. 14.182): During the year ended December 31, 2020, 15 of the 15 resident files selected for testing under the HUD Consolidated Audit Guide lacked properly executed and documented resident eligibility forms.
Criteria: In accordance with the Housing Assistance Payments Contract and HUD Handbook 4350.3, the Management Agent must certify and recertify residents and update other applicable forms in accordance with HUD regulations and contractual requirements.
Effect: The Corporation is not in compliance with the terms of the Housing Assistance Payments Contract or HUD Handbook 4350.3. Current, future, and potentially prior funding under the Housing Assistance Payments Contract could be impacted as a result of these resident files.
Cause: Upon taking over management of the property, the Management Agent received incomplete resident files from the previous management agent.
Recommendation: The Management Agent should ensure that all resident files are maintained at the site for each resident of the Property, and the Management Agent should ensure that the resident files include all properly executed and documented resident eligibility forms.
Completion date: In process
Management Response: Agree. Management intends to update all resident files to include all resident eligibility forms during the year ended December 31, 2021.
Finding reference number: 2020-003
Assistance Listing title and number (Federal award identification number and year): Section 8 new construction and substantial rehabilitation Assistance Listing No. 14.182 (NJ39H085044 and 1979)
Auditor non-compliance code: R – Section 8 Program Administration
Finding resolution status: In process
Universe population size: The universe population size is not applicable to the finding.
Sample size information: The sample size information is not applicable to the finding.
Statistically valid sample: No
Name of Federal agency: U.S. Department of Housing and Urban Development
Pass-through entity: N/A
Questioned costs: N/A
Statement of Condition 2020-003 (Assistance Listing No. 14.182): During the year ended December 31, 2020, 7 of the applicants selected for waitlist testing under the HUD Consolidated Audit Guide lacked proper documentation for tenant selection.
Criteria: In accordance with the Housing Assistance Payments Contract and HUD Handbook 4350.3, the Property must select applicants in a systematic fashion from a waitlist for tenant selection.
Effect: The Property is not in compliance with the terms of the Housing Assistance Payments Contract or HUD Handbook 4350.3. Applicants could have selected ineligible applicants for tenant selection over eligible applicants.
Cause: The on-site property manager was not properly maintaining the waitlist per HUD standards.
Recommendation: The Management Agent should ensure that all applicants are properly documented on the waitlist.
Completion date: In process
Management Response: Agree. The Management Agent will review and update, if necessary, its procedures to ensure waitlist is in compliance with HUD Handbook 4530.3.
Finding reference number: 2020-004
Assistance Listing title and number (Federal award identification number and year): Section 8 new construction and substantial rehabilitation Assistance Listing No. 14.182 (NJ39H085044 and 1979)
Auditor non-compliance code: Z - Other
Finding resolution status: In process
Universe population size: The universe population size is not applicable to the finding.
Sample size information: The sample size information is not applicable to the finding.
Statistically valid sample: No
Name of Federal agency: U.S. Department of Housing and Urban Development
Pass-through entity: N/A
Questioned costs: N/A
Statement of Condition 2020-004 (Assistance Listing NO. 14.182): As of December 31, 2020, the owners and management agent did not have written policies and procedures for staff to follow when using the Enterprise Income Verification (EIV) System.
Criteria: Pursuant to HUD housing Notice 2013-06, the owners and management agent must have written policies and procedures for staff to follow when using the EIV System.
Effect: The Corporation is not in compliance with HUD regulations and could allow access to sensitive resident information.
Cause: The Former Agent failed to prepare written EIV policies and procedures in accordance with HUD regulations.
Recommendation: The Management Agent should prepare written EIV policies and procedures in accordance with HUD regulations.
Completion date: In process
Management Response: Agree. The Management Agent will prepare written EIV policies and procedures in accordance with HUD regulations as soon as practical.
Finding reference number: 2020-005
Assistance Listing title and number (Federal award identification number and year): Section 8 new construction and substantial rehabilitation Assistance Listing No. 14.182 (NJ39H085044 and 1979)
Auditor non-compliance code: Z - Other
Finding resolution status: In process
Universe population size: The universe population size is not applicable to the finding.
Sample size information: The sample size information is not applicable to the finding.
Statistically valid sample: No
Name of Federal agency: U.S. Department of Housing and Urban Development
Pass-through entity: N/A
Questioned costs: N/A
Statement of Condition 2020-005 (Assistance Listing No. 14.182): The Corporation's books and records were not maintained in reasonable condition for proper audit as required by HUD.
Criteria: The books and records of the Corporation are required to be kept in accordance with HUD Financial Operations and Accounting Procedures for Insured Handbook (4370.2) Chapter 2: Financial Operations and Accounting (Section 2-3 Maintenance of Books and Records), which requires the records be maintained in reasonable condition for proper audit which includes adequate design and monitoring of controls to safeguard the entity's assets.
Effect: The Corporation is not in compliance with HUD regulations.
Cause: As a result of the change in management agent and the former management agent's inability or refusal to provide access to all relevant finance and accounting materials, we were unable to obtain appropriate audit evidence that the financial statements referred to in the first paragraph were reported in accordance with accounting principles generally accepted in the United States of America, and we were unable to satisfy ourselves by other auditing procedures.
Recommendation: The Board of Directors should ensure the books and records are maintained in reasonable condition for proper audit as required by HUD.
Completion date: December 31, 2020
Management Response: Agree. The management agent will ensure the books and records are maintained in reasonable condition for proper audits as required by HUD going forward.