Audit 371944

FY End
2024-12-31
Total Expended
$8.02M
Findings
2
Programs
1
Year: 2024 Accepted: 2025-11-10
Auditor: COHNREZNICK LLP

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
1162153 2024-001 Material Weakness Yes E
1162154 2024-002 Material Weakness Yes B

Programs

ALN Program Spent Major Findings
14.195 PROJECT-BASED RENTAL ASSISTANCE (PBRA) $8.02M Yes 2

Contacts

Name Title Type
DWRFSR1JTTF5 Lukeman Ogunyinka Auditee
2122439090 Jason Rocker Auditor
No contacts on file

Notes to SEFA

The accompanying schedule of expenditures of federal awards (the "Schedule") includes the federal award activity of Boston Tremont Housing Development Fund Corporation (the "Corporation") under a program 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 ("CFR") 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 Corporation, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the Corporation.
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.
The Corporation has elected not to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance.

Finding Details

Finding No. 2024-001- Tenants are not recertified timely 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 review of 25 lease files we noted the following deficiency: 1 file did not have timely recertification of tenants and income verification documentation was performed later than the required recertification date. Cause Management's policies with respect to the determination of 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 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 Identification as a Repeat Finding Repeat finding 2023-001 Recommendation Management should establish procedures and monitor compliance with those procedures to ensure that 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. HUD Auditor Noncompliance Code R- Section 8 program administration Uniform Guidance Auditor Noncompliance Code E- Eligibility Finding Resolution Status: In process Reporting Views of Responsible Officials Management has addressed the issue by recertifying the tenants and does not expect late recertifications to occur again.
Finding No. 2024-002- Unauthorized loans from project assets Criteria The terms of the regulatory agreement/HAP contract require payments/repayments of related party fees/loans to be limited to available surplus cash computed on a semi-annual or annual basis unless approved by HUD. Condition During the year ended December 31, 2024, the project paid expenses in the amount of $83,761 on behalf of an affiliate from project cash without HUD approval. Cause Procedures were not in place to ensure that distributions of cash were limited to available surplus cash computed in accordance with HUD regulations. Effect or Potential Effect The payments/repayments of $83,761 were unauthorized distributions and therefore considered to be questioned costs. Questioned Costs $83,761 Identification as a Repeat Finding N/A Recommendations Management should implement procedures to limit distributions of project cash to the annual surplus cash calculation amount required by the regulatory agreement/HAP contract. Management should immediately reimburse the project's cash account for the unauthorized distribution. HUD Auditor Noncompliance Code G- Unauthorized loans from project assets Uniform Guidance Auditor Noncompliance Code B- Allowable Costs/Cost Principles Finding Resolution Status: Resolved. Reporting Views of Responsible Officials The Corporation agrees with the finding and the auditor's recommendations have been adopted. As of the report date and subsequent to the statement of financial position date, the $83,761 was repaid back to the Corporation.