Criteria
In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily
Housing Programs, HUD projects are required to establish and maintain at all times a fully funded
separate bank account for tenant security deposits collected.
Condition
As of June 30, 2024, management has not fully funded the tenant security deposits cash account.
The tenant security deposits cash account was underfunded by $3,370.
Cause
The tenant security deposits liability exceeds the tenant security deposits cash account by $3,370
as of June 30, 2024.
Effect or Potential Effect
Management commingled tenant security deposits with its operating cash and did not have
sufficient cash balance in the tenant security deposits cash account to cover the tenant security
deposits liability as of June 30, 2024.
Questioned Costs
N/A
Identification as a Repeat Finding
This finding is not a repeat finding.
Recommendation
Management should transfer $3,370 from the operating account in order to fully fund the tenant
security deposits account.
Auditor Noncompliance Code:
D - Commingling of funds
View of Responsible Officials
Management agrees with the finding and recommendation and has reviewed the HUD requirement
for security funding. Funds have been transferred and will be maintained based on HUD
requirements in a separate account from operating funds.
Finding Resolution Status: Resolved.
Criteria
In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily
Housing Programs, HUD projects are required to establish and maintain at all times a fully funded
separate bank account for tenant security deposits collected.
Condition
As of June 30, 2024, management has not fully funded the tenant security deposits cash account.
The tenant security deposits cash account was underfunded by $3,370.
Cause
The tenant security deposits liability exceeds the tenant security deposits cash account by $3,370
as of June 30, 2024.
Effect or Potential Effect
Management commingled tenant security deposits with its operating cash and did not have
sufficient cash balance in the tenant security deposits cash account to cover the tenant security
deposits liability as of June 30, 2024.
Questioned Costs
N/A
Identification as a Repeat Finding
This finding is not a repeat finding.
Recommendation
Management should transfer $3,370 from the operating account in order to fully fund the tenant
security deposits account.
Auditor Noncompliance Code:
D - Commingling of funds
View of Responsible Officials
Management agrees with the finding and recommendation and has reviewed the HUD requirement
for security funding. Funds have been transferred and will be maintained based on HUD
requirements in a separate account from operating funds.
Finding Resolution Status: Resolved.
Criteria
Loans are not permitted to be made from project cash without prior authorization from HUD.
Condition
During the year ended June 30, 2024, the Project paid payroll expense in the amount of $9,303 on
behalf of an affiliate from project cash without HUD approval. The amount due to the Project as of
June 30, 2024, is $9,303.
Cause
Procedures were not in place to ensure that cash disbursements of project funds were limited to
project operating costs.
Effect or Potential Effect
Use of project funds for unauthorized loans may result in shortage of cash and default on projects'
own obligations.
Questioned Costs
The payments of $9,303 were unauthorized loans and therefore considered to be questioned costs.
Identification as a Repeat Finding
This finding is not a repeat finding.
Recommendation
Management should immediately reimburse the amount due to the Project and establish
procedures to ensure payments of this nature are not made in the future.
Auditor Noncompliance Code:
G - Unauthorized loans from project assets
Views of Responsible Officials
Management agrees with the finding and will ensure payroll is allocated correctly going forward.
Finding Resolution Status: Unresolved
Criteria
Loans are not permitted to be made from project cash without prior authorization from HUD.
Condition
During the year ended June 30, 2024, the Project paid payroll expense in the amount of $9,303 on
behalf of an affiliate from project cash without HUD approval. The amount due to the Project as of
June 30, 2024, is $9,303.
Cause
Procedures were not in place to ensure that cash disbursements of project funds were limited to
project operating costs.
Effect or Potential Effect
Use of project funds for unauthorized loans may result in shortage of cash and default on projects'
own obligations.
Questioned Costs
The payments of $9,303 were unauthorized loans and therefore considered to be questioned costs.
Identification as a Repeat Finding
This finding is not a repeat finding.
Recommendation
Management should immediately reimburse the amount due to the Project and establish
procedures to ensure payments of this nature are not made in the future.
Auditor Noncompliance Code:
G - Unauthorized loans from project assets
Views of Responsible Officials
Management agrees with the finding and will ensure payroll is allocated correctly going forward.
Finding Resolution Status: Unresolved
Criteria
1. Management is responsible for the design, implementation, and maintenance of internal
controls relevant to the preparation and fair presentation of financial statements that are free
from material misstatement, whether due to fraud or error.
2. Management is responsible for timely submission of audited financial statements to Federal
Audit Clearinghouse ("FAC"). Submission of June 30, 2023 financial statements was not
completed within specified time frame.
Condition
1. The accounting records required numerous material adjustments to be proposed and recorded
in order for the financial statements to be fairly presented in accordance with generally accepted
accounting principles in the United States of America.
2. Single Audit reports are required to be submitted to the FAC pursuant to the audit requirement
of Title 2 U.S. Code of Federal Regulations Part 200.
Cause
Management did not have sufficient controls over financial reporting.
Effect or Potential Effect
Condition 1 may lead to inaccurate financial reporting and potential misstatement of the financial
statements such that they are not in accordance with accounting principles generally accepted in
the United States of America. Condition 2 results in auditee being designated as a not-low risk
auditee, which may have an effect on future federal grants and program eligibility.
Recommendation
1. Management should undertake a review of internal controls over financial reporting and ensure
that financial data is properly recorded in the books and records of the Project to prevent
misstatements from occurring in the future.
2. Management should implement procedures to ensure that required filing is completed as
required.
Views of Responsible Officials
1. Management agrees with the finding and recommendation and has implemented reviews of the
financial statements by senior management prior to releasing them to ensure accuracy of
information.
2. Management agrees with the finding and recommendation and will ensure single audit reports
are submitted to the FAC pursuant to the audit requirement of Title 2 U.S. Code of Federal
Regulations Part 200.
Finding Resolution Status: Resolved
Criteria
1. Management is responsible for the design, implementation, and maintenance of internal
controls relevant to the preparation and fair presentation of financial statements that are free
from material misstatement, whether due to fraud or error.
2. Management is responsible for timely submission of audited financial statements to Federal
Audit Clearinghouse ("FAC"). Submission of June 30, 2023 financial statements was not
completed within specified time frame.
Condition
1. The accounting records required numerous material adjustments to be proposed and recorded
in order for the financial statements to be fairly presented in accordance with generally accepted
accounting principles in the United States of America.
2. Single Audit reports are required to be submitted to the FAC pursuant to the audit requirement
of Title 2 U.S. Code of Federal Regulations Part 200.
Cause
Management did not have sufficient controls over financial reporting.
Effect or Potential Effect
Condition 1 may lead to inaccurate financial reporting and potential misstatement of the financial
statements such that they are not in accordance with accounting principles generally accepted in
the United States of America. Condition 2 results in auditee being designated as a not-low risk
auditee, which may have an effect on future federal grants and program eligibility.
Recommendation
1. Management should undertake a review of internal controls over financial reporting and ensure
that financial data is properly recorded in the books and records of the Project to prevent
misstatements from occurring in the future.
2. Management should implement procedures to ensure that required filing is completed as
required.
Views of Responsible Officials
1. Management agrees with the finding and recommendation and has implemented reviews of the
financial statements by senior management prior to releasing them to ensure accuracy of
information.
2. Management agrees with the finding and recommendation and will ensure single audit reports
are submitted to the FAC pursuant to the audit requirement of Title 2 U.S. Code of Federal
Regulations Part 200.
Finding Resolution Status: Resolved
Criteria
During the year ended June 30, 2024, the Project paid management fees of $1,212 in excess of the
amount approved by HUD.
Condition
Management fee payments are limited to amounts determined in accordance with the terms of the
HUD approved management agreement.
Cause
There were 2 different management agreements and management did not follow the HUD
approved management agreement when paying management fees from operations.
Effect or Potential Effect
The overpaid amount is an unauthorized distribution and therefore considered to be questioned
costs.
Questioned Costs
$1,212
Identification as a Repeat Finding
This finding is not a repeat finding.
Recommendation
The management company should reimburse the Project for overpaid management fee in the
amount of $1,212 and implement procedures to ensure that the management fee paid does not
exceed the amount determined in accordance with the HUD approved management agreement.
Auditor Noncompliance Code:
J - Unauthorized management fees
View of Responsible Officials
Management agrees with the finding and is working with ownership on reimbursements to the
property. Management will collect in accordance with HUD going forward.
Finding Resolution Status: In process
Criteria
During the year ended June 30, 2024, the Project paid management fees of $1,212 in excess of the
amount approved by HUD.
Condition
Management fee payments are limited to amounts determined in accordance with the terms of the
HUD approved management agreement.
Cause
There were 2 different management agreements and management did not follow the HUD
approved management agreement when paying management fees from operations.
Effect or Potential Effect
The overpaid amount is an unauthorized distribution and therefore considered to be questioned
costs.
Questioned Costs
$1,212
Identification as a Repeat Finding
This finding is not a repeat finding.
Recommendation
The management company should reimburse the Project for overpaid management fee in the
amount of $1,212 and implement procedures to ensure that the management fee paid does not
exceed the amount determined in accordance with the HUD approved management agreement.
Auditor Noncompliance Code:
J - Unauthorized management fees
View of Responsible Officials
Management agrees with the finding and is working with ownership on reimbursements to the
property. Management will collect in accordance with HUD going forward.
Finding Resolution Status: In process
Criteria
The property does not have a current Affirmative Fair Housing Marketing Plan.
Condition
In accordance with HUD Handbook 4530.3, Occupancy Requirements of Subsidized Multifamily
Housing Programs, management must review and update the Affirmative Fair Housing Marketing
Plan at least every 5 years.
Cause
Procedures were not in place to ensure proper documentation was maintained upon the change of
management.
Effect or Potential Effect
Absent these written documents, the Project could open itself up to mistakes in marketing and
leasing activity that could put their PRAC contract at risk upon renewal.
Questioned Costs
N/A
Identification as a Repeat Finding
This finding is not a repeat finding.
Recommendation
Management should maintain an Affirmative Fair Housing Marketing Plan and update it every 5
years.
Auditor Noncompliance Code:
Z - Other
View of Responsible Officials
Management agrees with the finding and is working with ownership on reimbursements to the
property. Management has submitted their Affirmative Fair Housing Marketing Plan with an
effective date of September 9, 2024.
Finding Resolution Status: Resolved
Criteria
The property does not have a current Affirmative Fair Housing Marketing Plan.
Condition
In accordance with HUD Handbook 4530.3, Occupancy Requirements of Subsidized Multifamily
Housing Programs, management must review and update the Affirmative Fair Housing Marketing
Plan at least every 5 years.
Cause
Procedures were not in place to ensure proper documentation was maintained upon the change of
management.
Effect or Potential Effect
Absent these written documents, the Project could open itself up to mistakes in marketing and
leasing activity that could put their PRAC contract at risk upon renewal.
Questioned Costs
N/A
Identification as a Repeat Finding
This finding is not a repeat finding.
Recommendation
Management should maintain an Affirmative Fair Housing Marketing Plan and update it every 5
years.
Auditor Noncompliance Code:
Z - Other
View of Responsible Officials
Management agrees with the finding and is working with ownership on reimbursements to the
property. Management has submitted their Affirmative Fair Housing Marketing Plan with an
effective date of September 9, 2024.
Finding Resolution Status: Resolved
Criteria
In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily
Housing Programs, HUD projects are required to establish and maintain at all times a fully funded
separate bank account for tenant security deposits collected.
Condition
As of June 30, 2024, management has not fully funded the tenant security deposits cash account.
The tenant security deposits cash account was underfunded by $3,370.
Cause
The tenant security deposits liability exceeds the tenant security deposits cash account by $3,370
as of June 30, 2024.
Effect or Potential Effect
Management commingled tenant security deposits with its operating cash and did not have
sufficient cash balance in the tenant security deposits cash account to cover the tenant security
deposits liability as of June 30, 2024.
Questioned Costs
N/A
Identification as a Repeat Finding
This finding is not a repeat finding.
Recommendation
Management should transfer $3,370 from the operating account in order to fully fund the tenant
security deposits account.
Auditor Noncompliance Code:
D - Commingling of funds
View of Responsible Officials
Management agrees with the finding and recommendation and has reviewed the HUD requirement
for security funding. Funds have been transferred and will be maintained based on HUD
requirements in a separate account from operating funds.
Finding Resolution Status: Resolved.
Criteria
In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily
Housing Programs, HUD projects are required to establish and maintain at all times a fully funded
separate bank account for tenant security deposits collected.
Condition
As of June 30, 2024, management has not fully funded the tenant security deposits cash account.
The tenant security deposits cash account was underfunded by $3,370.
Cause
The tenant security deposits liability exceeds the tenant security deposits cash account by $3,370
as of June 30, 2024.
Effect or Potential Effect
Management commingled tenant security deposits with its operating cash and did not have
sufficient cash balance in the tenant security deposits cash account to cover the tenant security
deposits liability as of June 30, 2024.
Questioned Costs
N/A
Identification as a Repeat Finding
This finding is not a repeat finding.
Recommendation
Management should transfer $3,370 from the operating account in order to fully fund the tenant
security deposits account.
Auditor Noncompliance Code:
D - Commingling of funds
View of Responsible Officials
Management agrees with the finding and recommendation and has reviewed the HUD requirement
for security funding. Funds have been transferred and will be maintained based on HUD
requirements in a separate account from operating funds.
Finding Resolution Status: Resolved.
Criteria
Loans are not permitted to be made from project cash without prior authorization from HUD.
Condition
During the year ended June 30, 2024, the Project paid payroll expense in the amount of $9,303 on
behalf of an affiliate from project cash without HUD approval. The amount due to the Project as of
June 30, 2024, is $9,303.
Cause
Procedures were not in place to ensure that cash disbursements of project funds were limited to
project operating costs.
Effect or Potential Effect
Use of project funds for unauthorized loans may result in shortage of cash and default on projects'
own obligations.
Questioned Costs
The payments of $9,303 were unauthorized loans and therefore considered to be questioned costs.
Identification as a Repeat Finding
This finding is not a repeat finding.
Recommendation
Management should immediately reimburse the amount due to the Project and establish
procedures to ensure payments of this nature are not made in the future.
Auditor Noncompliance Code:
G - Unauthorized loans from project assets
Views of Responsible Officials
Management agrees with the finding and will ensure payroll is allocated correctly going forward.
Finding Resolution Status: Unresolved
Criteria
Loans are not permitted to be made from project cash without prior authorization from HUD.
Condition
During the year ended June 30, 2024, the Project paid payroll expense in the amount of $9,303 on
behalf of an affiliate from project cash without HUD approval. The amount due to the Project as of
June 30, 2024, is $9,303.
Cause
Procedures were not in place to ensure that cash disbursements of project funds were limited to
project operating costs.
Effect or Potential Effect
Use of project funds for unauthorized loans may result in shortage of cash and default on projects'
own obligations.
Questioned Costs
The payments of $9,303 were unauthorized loans and therefore considered to be questioned costs.
Identification as a Repeat Finding
This finding is not a repeat finding.
Recommendation
Management should immediately reimburse the amount due to the Project and establish
procedures to ensure payments of this nature are not made in the future.
Auditor Noncompliance Code:
G - Unauthorized loans from project assets
Views of Responsible Officials
Management agrees with the finding and will ensure payroll is allocated correctly going forward.
Finding Resolution Status: Unresolved
Criteria
1. Management is responsible for the design, implementation, and maintenance of internal
controls relevant to the preparation and fair presentation of financial statements that are free
from material misstatement, whether due to fraud or error.
2. Management is responsible for timely submission of audited financial statements to Federal
Audit Clearinghouse ("FAC"). Submission of June 30, 2023 financial statements was not
completed within specified time frame.
Condition
1. The accounting records required numerous material adjustments to be proposed and recorded
in order for the financial statements to be fairly presented in accordance with generally accepted
accounting principles in the United States of America.
2. Single Audit reports are required to be submitted to the FAC pursuant to the audit requirement
of Title 2 U.S. Code of Federal Regulations Part 200.
Cause
Management did not have sufficient controls over financial reporting.
Effect or Potential Effect
Condition 1 may lead to inaccurate financial reporting and potential misstatement of the financial
statements such that they are not in accordance with accounting principles generally accepted in
the United States of America. Condition 2 results in auditee being designated as a not-low risk
auditee, which may have an effect on future federal grants and program eligibility.
Recommendation
1. Management should undertake a review of internal controls over financial reporting and ensure
that financial data is properly recorded in the books and records of the Project to prevent
misstatements from occurring in the future.
2. Management should implement procedures to ensure that required filing is completed as
required.
Views of Responsible Officials
1. Management agrees with the finding and recommendation and has implemented reviews of the
financial statements by senior management prior to releasing them to ensure accuracy of
information.
2. Management agrees with the finding and recommendation and will ensure single audit reports
are submitted to the FAC pursuant to the audit requirement of Title 2 U.S. Code of Federal
Regulations Part 200.
Finding Resolution Status: Resolved
Criteria
1. Management is responsible for the design, implementation, and maintenance of internal
controls relevant to the preparation and fair presentation of financial statements that are free
from material misstatement, whether due to fraud or error.
2. Management is responsible for timely submission of audited financial statements to Federal
Audit Clearinghouse ("FAC"). Submission of June 30, 2023 financial statements was not
completed within specified time frame.
Condition
1. The accounting records required numerous material adjustments to be proposed and recorded
in order for the financial statements to be fairly presented in accordance with generally accepted
accounting principles in the United States of America.
2. Single Audit reports are required to be submitted to the FAC pursuant to the audit requirement
of Title 2 U.S. Code of Federal Regulations Part 200.
Cause
Management did not have sufficient controls over financial reporting.
Effect or Potential Effect
Condition 1 may lead to inaccurate financial reporting and potential misstatement of the financial
statements such that they are not in accordance with accounting principles generally accepted in
the United States of America. Condition 2 results in auditee being designated as a not-low risk
auditee, which may have an effect on future federal grants and program eligibility.
Recommendation
1. Management should undertake a review of internal controls over financial reporting and ensure
that financial data is properly recorded in the books and records of the Project to prevent
misstatements from occurring in the future.
2. Management should implement procedures to ensure that required filing is completed as
required.
Views of Responsible Officials
1. Management agrees with the finding and recommendation and has implemented reviews of the
financial statements by senior management prior to releasing them to ensure accuracy of
information.
2. Management agrees with the finding and recommendation and will ensure single audit reports
are submitted to the FAC pursuant to the audit requirement of Title 2 U.S. Code of Federal
Regulations Part 200.
Finding Resolution Status: Resolved
Criteria
During the year ended June 30, 2024, the Project paid management fees of $1,212 in excess of the
amount approved by HUD.
Condition
Management fee payments are limited to amounts determined in accordance with the terms of the
HUD approved management agreement.
Cause
There were 2 different management agreements and management did not follow the HUD
approved management agreement when paying management fees from operations.
Effect or Potential Effect
The overpaid amount is an unauthorized distribution and therefore considered to be questioned
costs.
Questioned Costs
$1,212
Identification as a Repeat Finding
This finding is not a repeat finding.
Recommendation
The management company should reimburse the Project for overpaid management fee in the
amount of $1,212 and implement procedures to ensure that the management fee paid does not
exceed the amount determined in accordance with the HUD approved management agreement.
Auditor Noncompliance Code:
J - Unauthorized management fees
View of Responsible Officials
Management agrees with the finding and is working with ownership on reimbursements to the
property. Management will collect in accordance with HUD going forward.
Finding Resolution Status: In process
Criteria
During the year ended June 30, 2024, the Project paid management fees of $1,212 in excess of the
amount approved by HUD.
Condition
Management fee payments are limited to amounts determined in accordance with the terms of the
HUD approved management agreement.
Cause
There were 2 different management agreements and management did not follow the HUD
approved management agreement when paying management fees from operations.
Effect or Potential Effect
The overpaid amount is an unauthorized distribution and therefore considered to be questioned
costs.
Questioned Costs
$1,212
Identification as a Repeat Finding
This finding is not a repeat finding.
Recommendation
The management company should reimburse the Project for overpaid management fee in the
amount of $1,212 and implement procedures to ensure that the management fee paid does not
exceed the amount determined in accordance with the HUD approved management agreement.
Auditor Noncompliance Code:
J - Unauthorized management fees
View of Responsible Officials
Management agrees with the finding and is working with ownership on reimbursements to the
property. Management will collect in accordance with HUD going forward.
Finding Resolution Status: In process
Criteria
The property does not have a current Affirmative Fair Housing Marketing Plan.
Condition
In accordance with HUD Handbook 4530.3, Occupancy Requirements of Subsidized Multifamily
Housing Programs, management must review and update the Affirmative Fair Housing Marketing
Plan at least every 5 years.
Cause
Procedures were not in place to ensure proper documentation was maintained upon the change of
management.
Effect or Potential Effect
Absent these written documents, the Project could open itself up to mistakes in marketing and
leasing activity that could put their PRAC contract at risk upon renewal.
Questioned Costs
N/A
Identification as a Repeat Finding
This finding is not a repeat finding.
Recommendation
Management should maintain an Affirmative Fair Housing Marketing Plan and update it every 5
years.
Auditor Noncompliance Code:
Z - Other
View of Responsible Officials
Management agrees with the finding and is working with ownership on reimbursements to the
property. Management has submitted their Affirmative Fair Housing Marketing Plan with an
effective date of September 9, 2024.
Finding Resolution Status: Resolved
Criteria
The property does not have a current Affirmative Fair Housing Marketing Plan.
Condition
In accordance with HUD Handbook 4530.3, Occupancy Requirements of Subsidized Multifamily
Housing Programs, management must review and update the Affirmative Fair Housing Marketing
Plan at least every 5 years.
Cause
Procedures were not in place to ensure proper documentation was maintained upon the change of
management.
Effect or Potential Effect
Absent these written documents, the Project could open itself up to mistakes in marketing and
leasing activity that could put their PRAC contract at risk upon renewal.
Questioned Costs
N/A
Identification as a Repeat Finding
This finding is not a repeat finding.
Recommendation
Management should maintain an Affirmative Fair Housing Marketing Plan and update it every 5
years.
Auditor Noncompliance Code:
Z - Other
View of Responsible Officials
Management agrees with the finding and is working with ownership on reimbursements to the
property. Management has submitted their Affirmative Fair Housing Marketing Plan with an
effective date of September 9, 2024.
Finding Resolution Status: Resolved