Audit 410177

Finding 2025-001 – Special Tests and Provisions – RAD Replacement Reserve – Significant Deficiency ALN 14.195 Criteria: Code of Federal Regulations Title 24 Part 880 provides grantees the requirements of accounting for the reserve for replacement account. This language is incorporated into both the RAD HAP agreement and the RAD Conversion Commitment. Grantees are required to contribute regular deposits into the reserve for replacement account to aid in funding extraordinary maintenance and repair and replacement of capital items. These costs should be paid from the replacement reserve at a higher priority than project level funds. Condition: During our review of the RAD reserve for replacement account we noted that the client was not making regular monthly deposits. The HUD Funds Authorization form required monthly deposits of $15,162 for eleven months and $15,726 for the final month. This totals the annual required contribution of $182,544 that was not made. We also noted that during the audit period the client withdrew $80,449 from the reserve for replacement account without prior HUD authorization. Withdrawals without prior HUD approval are not permissible from this account. Finally, we noted that the client did have authorization to withdraw $20,781 from the account with supported expenditures but failed to transfer the funds out. The replacement for reserve account at December 31, 2025 maintained a cash balance of $246,546. We have recalculated the reserve balance at December 31, 2025 to be $488,758 which management agrees with. Due to this we believe there is a deficit in the reserve for replacement account of $242,212 at year end. Effect: Inadequate contributions to the reserve account can lead to future funding deficits for required capital improvements, modernization, and extraordinary repairs. Recommendation: We recommend that the client continue to deposit into the reserve account pursuant to the signed RCC and RAD HAP contract. We also recommend that the client monitor withdrawals from the account and ensure they are supported by eligible costs. Questioned Costs: None Repeat Finding: No Was sampling statistically valid? Yes Views of responsible officials: The PHA agrees with the results of the audit and recommendations.