Internal control over compliance / compliance Finding number 2022-001 Section 207 pursuant to Section 223(f) loan Condition and criteria: As required by the Section 207 pursuant to Section 223(f) HUD insured loan, the Corporation is required to prepare and submit monthly reports of excess income (Form HUD-93094) in accordance with HUD instructions and in a timely manner. The contracted management company, on behalf of the Corporation, had failed to timely submit one of the monthly reports of excess income for the fiscal year ended October 31, 2022. Cause: For the fiscal year ended October 31, 2022, the Corporation did not have adequate internal controls over compliance in place for the area of reporting to ensure all required financial reporting was filed timely. Effect: As a result of failing to properly submit required financial reporting in a timely manner, the Corporation and management company was not in compliance with the reporting compliance requirement, and could have been restricted from entering into any new business with HUD. Recommendation: The Corporation, along with the contracted management company, should develop effective internal control procedures to ensure all required financial reporting is filed timely. The Corporation?s and contracted management company?s response: The contracted management company took the appropriate steps to set up automatic reporting for property managers each month.
Internal control over compliance / compliance Finding number 2022-002 Section 207 pursuant to Section 223(f) loan Condition and criteria: As required by the Section 207 pursuant to Section 223(f) HUD insured loan, the Corporation is required to keep funds collected as a security deposit in the name of the project, in an account separate and apart from all other funds of the project, with the amount of this account at all times equal to or exceeding the aggregate of all outstanding security deposits. All disbursements from the security deposit account must be only for refunds to tenants and for payment of expenses incurred by or on behalf of the tenant. The contracted management company had transferred funds out of the security deposit account to the operating account to cover operations during the fiscal year ended October 31, 2022, leaving insufficient funds in the security deposit account to cover outstanding security deposits. Cause: For the fiscal year ended October 31, 2022, the Corporation did not have adequate internal controls over compliance in place for the area of special tests and provisions to ensure that the security deposit account funds were properly always separated from other funds of the Corporation. Effect: As a result of unallowable disbursements from the security deposit account, the Corporation and management company was not in compliance with the special tests and provisions compliance requirement, may not have sufficient funds to cover the security deposit liability and could be restricted from entering into any new business with HUD. Recommendation: The Corporation, along with the contracted management company, should develop effective internal control procedures to ensure that the security deposit account always have sufficient funds to cover the security deposit liability and that no unallowable disbursements from the account occur. The Corporation?s and contracted management company?s response: The contracted management company took the appropriate steps to set up controls over the security deposit account to ensure only allowable disbursements occur, and that the account funds are always sufficiently separated to cover the security deposit liability.
Internal control over compliance / compliance Finding number 2022-001 Section 207 pursuant to Section 223(f) loan Condition and criteria: As required by the Section 207 pursuant to Section 223(f) HUD insured loan, the Corporation is required to prepare and submit monthly reports of excess income (Form HUD-93094) in accordance with HUD instructions and in a timely manner. The contracted management company, on behalf of the Corporation, had failed to timely submit one of the monthly reports of excess income for the fiscal year ended October 31, 2022. Cause: For the fiscal year ended October 31, 2022, the Corporation did not have adequate internal controls over compliance in place for the area of reporting to ensure all required financial reporting was filed timely. Effect: As a result of failing to properly submit required financial reporting in a timely manner, the Corporation and management company was not in compliance with the reporting compliance requirement, and could have been restricted from entering into any new business with HUD. Recommendation: The Corporation, along with the contracted management company, should develop effective internal control procedures to ensure all required financial reporting is filed timely. The Corporation?s and contracted management company?s response: The contracted management company took the appropriate steps to set up automatic reporting for property managers each month.
Internal control over compliance / compliance Finding number 2022-002 Section 207 pursuant to Section 223(f) loan Condition and criteria: As required by the Section 207 pursuant to Section 223(f) HUD insured loan, the Corporation is required to keep funds collected as a security deposit in the name of the project, in an account separate and apart from all other funds of the project, with the amount of this account at all times equal to or exceeding the aggregate of all outstanding security deposits. All disbursements from the security deposit account must be only for refunds to tenants and for payment of expenses incurred by or on behalf of the tenant. The contracted management company had transferred funds out of the security deposit account to the operating account to cover operations during the fiscal year ended October 31, 2022, leaving insufficient funds in the security deposit account to cover outstanding security deposits. Cause: For the fiscal year ended October 31, 2022, the Corporation did not have adequate internal controls over compliance in place for the area of special tests and provisions to ensure that the security deposit account funds were properly always separated from other funds of the Corporation. Effect: As a result of unallowable disbursements from the security deposit account, the Corporation and management company was not in compliance with the special tests and provisions compliance requirement, may not have sufficient funds to cover the security deposit liability and could be restricted from entering into any new business with HUD. Recommendation: The Corporation, along with the contracted management company, should develop effective internal control procedures to ensure that the security deposit account always have sufficient funds to cover the security deposit liability and that no unallowable disbursements from the account occur. The Corporation?s and contracted management company?s response: The contracted management company took the appropriate steps to set up controls over the security deposit account to ensure only allowable disbursements occur, and that the account funds are always sufficiently separated to cover the security deposit liability.