Audit 364442

FY End
2024-12-31
Total Expended
$3.16M
Findings
2
Programs
5
Organization: Pilgrim Towers, Inc. (CT)
Year: 2024 Accepted: 2025-08-18
Auditor: Whittlesey PC

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
573777 2024-001 Significant Deficiency Yes P
1150219 2024-001 Significant Deficiency Yes P

Contacts

Name Title Type
HS2NGCSLY253 Patricia Thatcher Auditee
2036536538 Niko Yanouzas Auditor
No contacts on file

Notes to SEFA

Title: NOTE 1 – BASIS OF PRESENTATION Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The ten percent de minimis indirect cost rate is not applicable to the HUD funded loan and housing assistance program. The accompanying Schedule of expenditures of federal awards (the “Schedule”) includes the federal award activity of Pilgrim Towers, Inc. (the “Corporation”) under programs of the federal government for the year ended December 31, 2024. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the Agency, it is not intended to and does not present the financial position, changes in net assets or cash flows of the Agency.
Title: NOTE 2 – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The ten percent de minimis indirect cost rate is not applicable to the HUD funded loan and housing assistance program. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement.
Title: NOTE 3 – FEDERALLY FUNDED LOANS Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The ten percent de minimis indirect cost rate is not applicable to the HUD funded loan and housing assistance program. Federally funded loans reported on the Schedule include the amount of new loans funded during the year ended December 31, 2024, the beginning balances of loans from the previous year that have continuing compliance imposed by HUD and subsidized interest that has been accrued in accordance with the promissory notes, as applicable. The ending principal balances of federally funded loans as of December 31, 2024 are as follows: Flexible Subsidy Loan (Section 201) January 1, 2024 - 489,563 Accrued interest for 2024 - 3,734 Flexible Subsidy Loan (Section 201) December 31, 2024 - 493,297 Community Development Block Grants/ Entitlement Grants - 1,630,446 Home Investment Partnerships Program - 800,000
Title: NOTE 4 – INDIRECT COST RATE Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The ten percent de minimis indirect cost rate is not applicable to the HUD funded loan and housing assistance program. The ten percent de minimis indirect cost rate is not applicable to the HUD funded loan and housing assistance program.

Finding Details

S3800-010 Finding reference number: 2024-001 S3800-011 Title and CFDA Flexible Subsidy Loan: 14.164 S3800-015 Type of Finding: FA S3800-016 Finding resolution status: In process S3800-019 Identification of repeat finding: 2023-001 S3800-020 Criteria: The Flexible Subsidy Loan "Residual Receipts Note" clause 3(a) cites that the entire principal together with interest is immediately due and payable when the HUD Section 202 mortgage is paid off. S3800-030 Statement of Condition: During our audit for the year ended December 31, 2021, we inquired and requested documentation regarding the repayment status of the Flexible Subsidy Loan from the Agency's officers and from its management company. The Agency did not have documentation regarding the mortgage status of the Flexible Subsidy Loan available since the HUD Section 202 mortgage was paid off in November 2016. S3800-032 Cause: The Agency is waiting for a response from HUD as to their inquiry regarding the repayment of the Flexible Subsidy Loan. S3800-033 Effect of Potential Effect: Based on the literal terms of the Flexible Subsidy Loan, the Agency appears to be in default as it has not established repayment with HUD. S3800-035 Auditor non-compliance code: S S3800-040 Amount of questioned costs: $0 S3800-045 Reporting Views of Responsible Officials: We continue to follow up, as we diligently have over many recent months, starting in 2008. Most recently, via an attorney, who, like Pilgrim Towers, has not been able to elicit any response from HUD to resolve this matter. S3800-037 FHA/Contract number: CT26M000251 S3800-038 Questioned Costs: $0 S3800-050 Context: It has been brought to the Agency's attention that the repayment of the HUD Section 202 mortgage that they would need to contact their HUD field representative regarding repayment of the Flexible Subsidy Loan. S3800-080 Recommendation: We recommend that the Agency follow up with its HUD field representative to determine the next steps regarding the repayment terms of the Flexible Subsidy Loan. S3800-090 Auditor's Summary of the Auditee's Comments on the Findings and Recommendations: We recommend that the Agency follow up with its HUD field representative to determine the next steps regarding the repayment terms of the Flexible Subsidy Loan. S3800-130 Response Indicator: A S3800-140 Completion date of proposed recommendation: December 31, 2025 S3800-150 Response: We have submitted a Flexible Subsidy Deferal Request package to HUD's Boston Multifamily Asset management division in October 2024, and have sent follow up requests in December 2024 and Febraury 2025. We are currently awaiting final approval of this request from HUD.
S3800-010 Finding reference number: 2024-001 S3800-011 Title and CFDA Flexible Subsidy Loan: 14.164 S3800-015 Type of Finding: FA S3800-016 Finding resolution status: In process S3800-019 Identification of repeat finding: 2023-001 S3800-020 Criteria: The Flexible Subsidy Loan "Residual Receipts Note" clause 3(a) cites that the entire principal together with interest is immediately due and payable when the HUD Section 202 mortgage is paid off. S3800-030 Statement of Condition: During our audit for the year ended December 31, 2021, we inquired and requested documentation regarding the repayment status of the Flexible Subsidy Loan from the Agency's officers and from its management company. The Agency did not have documentation regarding the mortgage status of the Flexible Subsidy Loan available since the HUD Section 202 mortgage was paid off in November 2016. S3800-032 Cause: The Agency is waiting for a response from HUD as to their inquiry regarding the repayment of the Flexible Subsidy Loan. S3800-033 Effect of Potential Effect: Based on the literal terms of the Flexible Subsidy Loan, the Agency appears to be in default as it has not established repayment with HUD. S3800-035 Auditor non-compliance code: S S3800-040 Amount of questioned costs: $0 S3800-045 Reporting Views of Responsible Officials: We continue to follow up, as we diligently have over many recent months, starting in 2008. Most recently, via an attorney, who, like Pilgrim Towers, has not been able to elicit any response from HUD to resolve this matter. S3800-037 FHA/Contract number: CT26M000251 S3800-038 Questioned Costs: $0 S3800-050 Context: It has been brought to the Agency's attention that the repayment of the HUD Section 202 mortgage that they would need to contact their HUD field representative regarding repayment of the Flexible Subsidy Loan. S3800-080 Recommendation: We recommend that the Agency follow up with its HUD field representative to determine the next steps regarding the repayment terms of the Flexible Subsidy Loan. S3800-090 Auditor's Summary of the Auditee's Comments on the Findings and Recommendations: We recommend that the Agency follow up with its HUD field representative to determine the next steps regarding the repayment terms of the Flexible Subsidy Loan. S3800-130 Response Indicator: A S3800-140 Completion date of proposed recommendation: December 31, 2025 S3800-150 Response: We have submitted a Flexible Subsidy Deferal Request package to HUD's Boston Multifamily Asset management division in October 2024, and have sent follow up requests in December 2024 and Febraury 2025. We are currently awaiting final approval of this request from HUD.