Finding No. 2024-001; Federal Assistance Listing Number 14.157
Criteria
Tenant lease files are required to be maintained and tenant eligibility determined in accordance with
HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs.
Condition
In connection with our lease file review, we noted that three out of three tenants' income verification
was not performed timely with the use of the HUD Enterprise Income Verification ("EIV").
Cause
Management's policies with respect to recertifications and eligibility and the maintenance of tenant
lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized
Multifamily Housing Programs were not consistently followed.
Effect or Potential Effect
The procedures for determining tenant recertification eligibility and maintaining tenant lease files
were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements
of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible
tenants or errors in the rent subsidies paid by HUD.
Questioned Costs
N/A
Context
Three out of three tenants tested did not have an EIV performed timely.
Identification as a Repeat Finding
Yes, 2023-001
Recommendation
Management should establish procedures and monitor compliance with those procedures to insure
that EIVs are performed timely, tenant eligibility is correctly determined and that tenant lease files
are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy
Requirements of Subsidized Multifamily Housing Programs.
Auditor Noncompliance Code: E - Eligibility for Uniform Guidance
Finding Resolution Status: Unresolved
Views of Responsible Officials and Planned Corrective Actions
REACH has policies in place to complete certifications in a timely manner but due to staffing
shortages and tenant noncompliance issues the property continued to have issues with timely
completion of income certifications in 2024. As new staff are brought onboard training is provided
and annual HUD training is completed by all staff. Management will continue to coordinate and
provide assistance to on-site staff to ensure that the properties are in compliance.
Finding No. 2024-002; Federal Assistance Listing Number 14.157
Criteria
In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily
Housing Programs, within 30 days after the move-out date (or shorter time if required by state
and/or local laws), management must either: refund the full security deposit plus accrued interest to
a tenant that does not owe any amounts under the lease; or provide the tenant with an itemized list
of any unpaid rent, damages to the unit, and an estimated cost for repair, along with a statement of
the tenant's rights under state and local laws.
Condition
In connection with the procedures applied to a sample of 1 tenant that moved out of the project
during the year, we noted 1 instance where management failed to refund the tenant security deposit
and/or provide the tenant with an itemized list of charges deducted from the deposit within thirty
days after the move-out date.
Cause
Management's policies with respect to move outs and security deposit refunds were not consistently
followed.
Effect or Potential Effect
Management failed to comply with the HUD occupancy requirement to timely refund the tenant
security deposits or to provide the tenant with a list of charges. The Property owes the tenant
security deposit back to the tenant.
Questioned Costs
N/A
Context
One tenant did not have their security deposit refund returned timely.
Identification as a Repeat Finding
No
Recommendation
Management should establish procedures and monitor compliance with those procedures to insure
that move out inspections are performed timely, security deposits are returned timely and that
tenant lease files are properly maintained in accordance with the requirements of HUD Handbook
4350.3, Occupancy Requirements of Subsidized Multifamily Housing Program.
Auditor Noncompliance Code: M - Security Deposits for REAC
Finding Resolution Status: Unresolved
Views of Responsible Officials and Planned Corrective Actions
REACH has policies in place to ensure security deposits are returned in a timely manner. Staffing
shortages at the property had an impact on the timely return of security deposits. As new staff are
brought onboard training is provided and management will continue to coordinate and provide
assistance to on-site staff to ensure that the security deposits are being returned or an itemized list
of charges is provided and properties are in compliance.
Finding No. 2024-003; Federal Assistance Listing Number 14.157
Criteria
Loans are not permitted to be made from project cash without prior authorization from HUD.
Condition
During the year ended December 31, 2024, the property paid 2 of 25 cash disbursements tested in
the amount of $2,204 on behalf of an affiliate from project cash without HUD approval. The amount
due to the project as of December 31, 2024 is $2,204.
Cause
Procedures were not in place to ensure that cash disbursements of project funds were limited to
project operating costs.
Effect or Potential Effect
The payments of $2,204 were unauthorized loans and therefore considered to be questioned costs.
Questioned Costs
$2,204
Context
The entity paid $2,204 of expenses on behalf of a related party entity.
Identification as a Repeat Finding
No
Recommendation
Management should immediately reimburse the amount due to the property and establish
procedures to ensure payments of this nature are not made in the future.
Auditor Noncompliance Code: G - Unauthorized loans from project assets
Finding Resolution Status: Resolved
Views of Responsible Officials and Planned Corrective Actions
REACH has policies in place to ensure that costs are allocated to the appropriate property. In 2024,
costs from an adjacent property, Community Housing I, were accidentally paid by Community
Housing II. These funds were repaid to the Community Housing II in 2025.
Finding No. 2024-001; Federal Assistance Listing Number 14.157
Criteria
Tenant lease files are required to be maintained and tenant eligibility determined in accordance with
HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs.
Condition
In connection with our lease file review, we noted that three out of three tenants' income verification
was not performed timely with the use of the HUD Enterprise Income Verification ("EIV").
Cause
Management's policies with respect to recertifications and eligibility and the maintenance of tenant
lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized
Multifamily Housing Programs were not consistently followed.
Effect or Potential Effect
The procedures for determining tenant recertification eligibility and maintaining tenant lease files
were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements
of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible
tenants or errors in the rent subsidies paid by HUD.
Questioned Costs
N/A
Context
Three out of three tenants tested did not have an EIV performed timely.
Identification as a Repeat Finding
Yes, 2023-001
Recommendation
Management should establish procedures and monitor compliance with those procedures to insure
that EIVs are performed timely, tenant eligibility is correctly determined and that tenant lease files
are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy
Requirements of Subsidized Multifamily Housing Programs.
Auditor Noncompliance Code: E - Eligibility for Uniform Guidance
Finding Resolution Status: Unresolved
Views of Responsible Officials and Planned Corrective Actions
REACH has policies in place to complete certifications in a timely manner but due to staffing
shortages and tenant noncompliance issues the property continued to have issues with timely
completion of income certifications in 2024. As new staff are brought onboard training is provided
and annual HUD training is completed by all staff. Management will continue to coordinate and
provide assistance to on-site staff to ensure that the properties are in compliance.
Finding No. 2024-002; Federal Assistance Listing Number 14.157
Criteria
In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily
Housing Programs, within 30 days after the move-out date (or shorter time if required by state
and/or local laws), management must either: refund the full security deposit plus accrued interest to
a tenant that does not owe any amounts under the lease; or provide the tenant with an itemized list
of any unpaid rent, damages to the unit, and an estimated cost for repair, along with a statement of
the tenant's rights under state and local laws.
Condition
In connection with the procedures applied to a sample of 1 tenant that moved out of the project
during the year, we noted 1 instance where management failed to refund the tenant security deposit
and/or provide the tenant with an itemized list of charges deducted from the deposit within thirty
days after the move-out date.
Cause
Management's policies with respect to move outs and security deposit refunds were not consistently
followed.
Effect or Potential Effect
Management failed to comply with the HUD occupancy requirement to timely refund the tenant
security deposits or to provide the tenant with a list of charges. The Property owes the tenant
security deposit back to the tenant.
Questioned Costs
N/A
Context
One tenant did not have their security deposit refund returned timely.
Identification as a Repeat Finding
No
Recommendation
Management should establish procedures and monitor compliance with those procedures to insure
that move out inspections are performed timely, security deposits are returned timely and that
tenant lease files are properly maintained in accordance with the requirements of HUD Handbook
4350.3, Occupancy Requirements of Subsidized Multifamily Housing Program.
Auditor Noncompliance Code: M - Security Deposits for REAC
Finding Resolution Status: Unresolved
Views of Responsible Officials and Planned Corrective Actions
REACH has policies in place to ensure security deposits are returned in a timely manner. Staffing
shortages at the property had an impact on the timely return of security deposits. As new staff are
brought onboard training is provided and management will continue to coordinate and provide
assistance to on-site staff to ensure that the security deposits are being returned or an itemized list
of charges is provided and properties are in compliance.
Finding No. 2024-003; Federal Assistance Listing Number 14.157
Criteria
Loans are not permitted to be made from project cash without prior authorization from HUD.
Condition
During the year ended December 31, 2024, the property paid 2 of 25 cash disbursements tested in
the amount of $2,204 on behalf of an affiliate from project cash without HUD approval. The amount
due to the project as of December 31, 2024 is $2,204.
Cause
Procedures were not in place to ensure that cash disbursements of project funds were limited to
project operating costs.
Effect or Potential Effect
The payments of $2,204 were unauthorized loans and therefore considered to be questioned costs.
Questioned Costs
$2,204
Context
The entity paid $2,204 of expenses on behalf of a related party entity.
Identification as a Repeat Finding
No
Recommendation
Management should immediately reimburse the amount due to the property and establish
procedures to ensure payments of this nature are not made in the future.
Auditor Noncompliance Code: G - Unauthorized loans from project assets
Finding Resolution Status: Resolved
Views of Responsible Officials and Planned Corrective Actions
REACH has policies in place to ensure that costs are allocated to the appropriate property. In 2024,
costs from an adjacent property, Community Housing I, were accidentally paid by Community
Housing II. These funds were repaid to the Community Housing II in 2025.
Finding No. 2024-001; Federal Assistance Listing Number 14.157
Criteria
Tenant lease files are required to be maintained and tenant eligibility determined in accordance with
HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs.
Condition
In connection with our lease file review, we noted that three out of three tenants' income verification
was not performed timely with the use of the HUD Enterprise Income Verification ("EIV").
Cause
Management's policies with respect to recertifications and eligibility and the maintenance of tenant
lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized
Multifamily Housing Programs were not consistently followed.
Effect or Potential Effect
The procedures for determining tenant recertification eligibility and maintaining tenant lease files
were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements
of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible
tenants or errors in the rent subsidies paid by HUD.
Questioned Costs
N/A
Context
Three out of three tenants tested did not have an EIV performed timely.
Identification as a Repeat Finding
Yes, 2023-001
Recommendation
Management should establish procedures and monitor compliance with those procedures to insure
that EIVs are performed timely, tenant eligibility is correctly determined and that tenant lease files
are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy
Requirements of Subsidized Multifamily Housing Programs.
Auditor Noncompliance Code: E - Eligibility for Uniform Guidance
Finding Resolution Status: Unresolved
Views of Responsible Officials and Planned Corrective Actions
REACH has policies in place to complete certifications in a timely manner but due to staffing
shortages and tenant noncompliance issues the property continued to have issues with timely
completion of income certifications in 2024. As new staff are brought onboard training is provided
and annual HUD training is completed by all staff. Management will continue to coordinate and
provide assistance to on-site staff to ensure that the properties are in compliance.
Finding No. 2024-002; Federal Assistance Listing Number 14.157
Criteria
In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily
Housing Programs, within 30 days after the move-out date (or shorter time if required by state
and/or local laws), management must either: refund the full security deposit plus accrued interest to
a tenant that does not owe any amounts under the lease; or provide the tenant with an itemized list
of any unpaid rent, damages to the unit, and an estimated cost for repair, along with a statement of
the tenant's rights under state and local laws.
Condition
In connection with the procedures applied to a sample of 1 tenant that moved out of the project
during the year, we noted 1 instance where management failed to refund the tenant security deposit
and/or provide the tenant with an itemized list of charges deducted from the deposit within thirty
days after the move-out date.
Cause
Management's policies with respect to move outs and security deposit refunds were not consistently
followed.
Effect or Potential Effect
Management failed to comply with the HUD occupancy requirement to timely refund the tenant
security deposits or to provide the tenant with a list of charges. The Property owes the tenant
security deposit back to the tenant.
Questioned Costs
N/A
Context
One tenant did not have their security deposit refund returned timely.
Identification as a Repeat Finding
No
Recommendation
Management should establish procedures and monitor compliance with those procedures to insure
that move out inspections are performed timely, security deposits are returned timely and that
tenant lease files are properly maintained in accordance with the requirements of HUD Handbook
4350.3, Occupancy Requirements of Subsidized Multifamily Housing Program.
Auditor Noncompliance Code: M - Security Deposits for REAC
Finding Resolution Status: Unresolved
Views of Responsible Officials and Planned Corrective Actions
REACH has policies in place to ensure security deposits are returned in a timely manner. Staffing
shortages at the property had an impact on the timely return of security deposits. As new staff are
brought onboard training is provided and management will continue to coordinate and provide
assistance to on-site staff to ensure that the security deposits are being returned or an itemized list
of charges is provided and properties are in compliance.
Finding No. 2024-003; Federal Assistance Listing Number 14.157
Criteria
Loans are not permitted to be made from project cash without prior authorization from HUD.
Condition
During the year ended December 31, 2024, the property paid 2 of 25 cash disbursements tested in
the amount of $2,204 on behalf of an affiliate from project cash without HUD approval. The amount
due to the project as of December 31, 2024 is $2,204.
Cause
Procedures were not in place to ensure that cash disbursements of project funds were limited to
project operating costs.
Effect or Potential Effect
The payments of $2,204 were unauthorized loans and therefore considered to be questioned costs.
Questioned Costs
$2,204
Context
The entity paid $2,204 of expenses on behalf of a related party entity.
Identification as a Repeat Finding
No
Recommendation
Management should immediately reimburse the amount due to the property and establish
procedures to ensure payments of this nature are not made in the future.
Auditor Noncompliance Code: G - Unauthorized loans from project assets
Finding Resolution Status: Resolved
Views of Responsible Officials and Planned Corrective Actions
REACH has policies in place to ensure that costs are allocated to the appropriate property. In 2024,
costs from an adjacent property, Community Housing I, were accidentally paid by Community
Housing II. These funds were repaid to the Community Housing II in 2025.
Finding No. 2024-001; Federal Assistance Listing Number 14.157
Criteria
Tenant lease files are required to be maintained and tenant eligibility determined in accordance with
HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs.
Condition
In connection with our lease file review, we noted that three out of three tenants' income verification
was not performed timely with the use of the HUD Enterprise Income Verification ("EIV").
Cause
Management's policies with respect to recertifications and eligibility and the maintenance of tenant
lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized
Multifamily Housing Programs were not consistently followed.
Effect or Potential Effect
The procedures for determining tenant recertification eligibility and maintaining tenant lease files
were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements
of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible
tenants or errors in the rent subsidies paid by HUD.
Questioned Costs
N/A
Context
Three out of three tenants tested did not have an EIV performed timely.
Identification as a Repeat Finding
Yes, 2023-001
Recommendation
Management should establish procedures and monitor compliance with those procedures to insure
that EIVs are performed timely, tenant eligibility is correctly determined and that tenant lease files
are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy
Requirements of Subsidized Multifamily Housing Programs.
Auditor Noncompliance Code: E - Eligibility for Uniform Guidance
Finding Resolution Status: Unresolved
Views of Responsible Officials and Planned Corrective Actions
REACH has policies in place to complete certifications in a timely manner but due to staffing
shortages and tenant noncompliance issues the property continued to have issues with timely
completion of income certifications in 2024. As new staff are brought onboard training is provided
and annual HUD training is completed by all staff. Management will continue to coordinate and
provide assistance to on-site staff to ensure that the properties are in compliance.
Finding No. 2024-002; Federal Assistance Listing Number 14.157
Criteria
In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily
Housing Programs, within 30 days after the move-out date (or shorter time if required by state
and/or local laws), management must either: refund the full security deposit plus accrued interest to
a tenant that does not owe any amounts under the lease; or provide the tenant with an itemized list
of any unpaid rent, damages to the unit, and an estimated cost for repair, along with a statement of
the tenant's rights under state and local laws.
Condition
In connection with the procedures applied to a sample of 1 tenant that moved out of the project
during the year, we noted 1 instance where management failed to refund the tenant security deposit
and/or provide the tenant with an itemized list of charges deducted from the deposit within thirty
days after the move-out date.
Cause
Management's policies with respect to move outs and security deposit refunds were not consistently
followed.
Effect or Potential Effect
Management failed to comply with the HUD occupancy requirement to timely refund the tenant
security deposits or to provide the tenant with a list of charges. The Property owes the tenant
security deposit back to the tenant.
Questioned Costs
N/A
Context
One tenant did not have their security deposit refund returned timely.
Identification as a Repeat Finding
No
Recommendation
Management should establish procedures and monitor compliance with those procedures to insure
that move out inspections are performed timely, security deposits are returned timely and that
tenant lease files are properly maintained in accordance with the requirements of HUD Handbook
4350.3, Occupancy Requirements of Subsidized Multifamily Housing Program.
Auditor Noncompliance Code: M - Security Deposits for REAC
Finding Resolution Status: Unresolved
Views of Responsible Officials and Planned Corrective Actions
REACH has policies in place to ensure security deposits are returned in a timely manner. Staffing
shortages at the property had an impact on the timely return of security deposits. As new staff are
brought onboard training is provided and management will continue to coordinate and provide
assistance to on-site staff to ensure that the security deposits are being returned or an itemized list
of charges is provided and properties are in compliance.
Finding No. 2024-003; Federal Assistance Listing Number 14.157
Criteria
Loans are not permitted to be made from project cash without prior authorization from HUD.
Condition
During the year ended December 31, 2024, the property paid 2 of 25 cash disbursements tested in
the amount of $2,204 on behalf of an affiliate from project cash without HUD approval. The amount
due to the project as of December 31, 2024 is $2,204.
Cause
Procedures were not in place to ensure that cash disbursements of project funds were limited to
project operating costs.
Effect or Potential Effect
The payments of $2,204 were unauthorized loans and therefore considered to be questioned costs.
Questioned Costs
$2,204
Context
The entity paid $2,204 of expenses on behalf of a related party entity.
Identification as a Repeat Finding
No
Recommendation
Management should immediately reimburse the amount due to the property and establish
procedures to ensure payments of this nature are not made in the future.
Auditor Noncompliance Code: G - Unauthorized loans from project assets
Finding Resolution Status: Resolved
Views of Responsible Officials and Planned Corrective Actions
REACH has policies in place to ensure that costs are allocated to the appropriate property. In 2024,
costs from an adjacent property, Community Housing I, were accidentally paid by Community
Housing II. These funds were repaid to the Community Housing II in 2025.