Audit 363099

Criteria Management is responsible for adhering to the EIV Rules of Behavior in accordance with Section 4.1.1 of the EIV Multifamily Program User Manual and HUD Notice H 2020-10. Condition During the procedures applied to a sample of three tenant lease files, we noted the following instances of noncompliance with HUD regulations regarding dissemination of Electronic Income Verification (EIV) information. Cause Management company employees failed to follow the policies and procedures which have been established for proper dissemination of EIV information in accordance with HUD guidelines and management policies. Effect or Potential Effect Noncompliance with HUD guidelines could result in tenant personal information being disseminated to unauthorized individuals. Questioned Costs None Context Two instances where EIV information was provided in electronic format to the independent public accountant were noted. These instances were not part of a statistical sample. Identification as a Repeat Finding This finding is not a repeat finding

Criteria In accordance with HUD program guidelines under which the Project operates, the tenant income verification is required to be completed in the EIV system within 90 days of the tenant being entered into the HUD TRACS system. Condition Income verification was not performed within the required 90 days of the tenant being entered into the HUD TRACS system. Cause Management's policies with respect to timing of income verifications were not consistently followed and personnel responsible for tenant certifications failed to complete the required certifications within 90 days of the tenant being entered into the HUD TRACS system. Effect or Potential Effect Noncompliance with HUD guidelines could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Questioned Costs None Context In connection with lease file testing, we noted one instance where the income verification was not performed within the required 90 days of the tenant being entered into the HUD TRACS system. Identification as a Repeat Finding This finding is not a repeat finding.

Criteria Management is responsible for adhering to the EIV Rules of Behavior in accordance with Section 4.1.1 of the EIV Multifamily Program User Manual and HUD Notice H 2020-10. Condition During the procedures applied to a sample of three tenant lease files, we noted the following instances of noncompliance with HUD regulations regarding dissemination of Electronic Income Verification (EIV) information. Cause Management company employees failed to follow the policies and procedures which have been established for proper dissemination of EIV information in accordance with HUD guidelines and management policies. Effect or Potential Effect Noncompliance with HUD guidelines could result in tenant personal information being disseminated to unauthorized individuals. Questioned Costs None Context Two instances where EIV information was provided in electronic format to the independent public accountant were noted. These instances were not part of a statistical sample. Identification as a Repeat Finding This finding is not a repeat finding

Criteria In accordance with HUD program guidelines under which the Project operates, the tenant income verification is required to be completed in the EIV system within 90 days of the tenant being entered into the HUD TRACS system. Condition Income verification was not performed within the required 90 days of the tenant being entered into the HUD TRACS system. Cause Management's policies with respect to timing of income verifications were not consistently followed and personnel responsible for tenant certifications failed to complete the required certifications within 90 days of the tenant being entered into the HUD TRACS system. Effect or Potential Effect Noncompliance with HUD guidelines could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Questioned Costs None Context In connection with lease file testing, we noted one instance where the income verification was not performed within the required 90 days of the tenant being entered into the HUD TRACS system. Identification as a Repeat Finding This finding is not a repeat finding.