Corrective Action Plans

Finding 498190 (2023-003)

None 2023

IL

HUD Housing Programs

For the Hill Housing Facility - FINDING 2023-003: SECTION 8, ASSISTANCE LISTING NUMBER 14.195 - TENANT FILE MISSING DISABILITY AND/OR HANDICAPPED VERIFICATION - Recommendation: The Project manager should attempt to obtain proper verification of disability/handicapped status on this tenant. If verifi...

For the Hill Housing Facility - FINDING 2023-003: SECTION 8, ASSISTANCE LISTING NUMBER 14.195 - TENANT FILE MISSING DISABILITY AND/OR HANDICAPPED VERIFICATION - Recommendation: The Project manager should attempt to obtain proper verification of disability/handicapped status on this tenant. If verification cannot be obtained, the Project should reimburse HUD for all rent subsidy on this tenant. Action Taken: The Project agrees with the finding. The project managers were reminded to obtain documentation to verify disability/handicapped status.

View Audit 320943

Finding 498189 (2023-002)

None 2023

Over the Rainbow Ass'n & Subsidiaries

IL

Questioned Costs HUD Housing Programs Matching / Level of Effort / Earmarking

For the Hill Housing Facility - FINDING 2023-002: SECTION 8, ASSISTANCE LISTING NUMBER 14.195 - SPONSOR LOAN PAYMENT WITHOUT HUD APPROVAL - Recommendation: The Sponsor should work with HUD to determine if the $130,019 needs to be paid back to the Project. Action Taken: The Sponsor will work with HUD...

For the Hill Housing Facility - FINDING 2023-002: SECTION 8, ASSISTANCE LISTING NUMBER 14.195 - SPONSOR LOAN PAYMENT WITHOUT HUD APPROVAL - Recommendation: The Sponsor should work with HUD to determine if the $130,019 needs to be paid back to the Project. Action Taken: The Sponsor will work with HUD to determine if the $130,019 needs to be paid back to the Project.

View Audit 320943 Questioned Costs: $1

Finding 498188 (2023-001)

None 2023

Over the Rainbow Ass'n & Subsidiaries

IL

Questioned Costs HUD Housing Programs Cash Management

For the Hill Housing Facility - FINDING 2023-001: SECTION 8, ASSISTANCE LISTING NUMBER 14.195 - SURPLUS CASH NOT DEPOSITED INTO RESIDUAL RECEIPTS ACCOUNT - Recommendation: The Project should deposit surplus cash as of December 31, 2021 into a residual receipts account as soon as possible. Action Tak...

For the Hill Housing Facility - FINDING 2023-001: SECTION 8, ASSISTANCE LISTING NUMBER 14.195 - SURPLUS CASH NOT DEPOSITED INTO RESIDUAL RECEIPTS ACCOUNT - Recommendation: The Project should deposit surplus cash as of December 31, 2021 into a residual receipts account as soon as possible. Action Taken: The Project agrees with the finding. Management will deposit $14,079 in a residual receipts account as soon as possible.

View Audit 320943 Questioned Costs: $1

Finding 498186 (2023-003)

Material Weakness 2023

Mobile County Housing Authority

AL

HUD Housing Programs Subrecipient Monitoring Internal Control / Segregation of Duties

2023-003 ALN 14.871 – Housing Voucher Cluster – Waiting List Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Ms. Tyronnda Bethune, Executive Director Projected ...

2023-003 ALN 14.871 – Housing Voucher Cluster – Waiting List Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Ms. Tyronnda Bethune, Executive Director Projected Completion Date: December 31, 2024

View Audit 320939

Finding 498185 (2023-001)

Material Weakness 2023

Mobile County Housing Authority

AL

HUD Housing Programs Subrecipient Monitoring Eligibility

2023-001 ALN 14.871 – Housing Voucher Cluster – Eligibility Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Ms. Tyronnda Bethune, Executive Director Projected C...

2023-001 ALN 14.871 – Housing Voucher Cluster – Eligibility Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Ms. Tyronnda Bethune, Executive Director Projected Completion Date: December 31, 2024

View Audit 320939

Finding 498128 (2023-004)

Significant Deficiency 2023

Save the Michael's of the World

NY

HUD Housing Programs

(a) Comments with the Finding and Recommendation – The Organization agrees with the finding as well as the recommendation. Please see below for action taken. (b) Corrective Action Taken – Beginning in 2024, the Organization has switched their time tracking system to use QuickBooks Time, a solution...

(a) Comments with the Finding and Recommendation – The Organization agrees with the finding as well as the recommendation. Please see below for action taken. (b) Corrective Action Taken – Beginning in 2024, the Organization has switched their time tracking system to use QuickBooks Time, a solution directly integrated into their accounting software. This integration will assist with accurate and automated transfer of information from time entry into payroll systems. Supervisors will still be required to review and validate all time entered to the system. Additionally, procedures will be put in place to ensure the total hours worked are agreed to corresponding payroll reports for each pay period.

View Audit 320810

Finding 498127 (2023-003)

Significant Deficiency 2023

Little Earth of United Tribes Housing Corporation

MN

HUD Housing Programs Subrecipient Monitoring Eligibility

Management will implement a system to monitor and review tenant file gross rent changes occurring during the year.

View Audit 320806

Finding 498126 (2023-002)

Significant Deficiency 2023

Little Earth of United Tribes Housing Corporation

MN

HUD Housing Programs Reporting Significant Deficiency § 200.512

Management filed the 2022 Single Audit Reporting Package in July 2024.

View Audit 320806

Finding 498125 (2023-001)

Significant Deficiency 2023

Little Earth of United Tribes Housing Corporation

MN

HUD Housing Programs Significant Deficiency Special Tests & Provisions

Management made an additional deposit to the replacement reserve of $17,617 in June 2024.

View Audit 320806

Finding 498077 (2023-003)

Significant Deficiency 2023

Housing and Redevelopment Authority of Morrison County, Minnesota

MN

HUD Housing Programs

Corrective Action Planned: The Authority will obtain depository agreements with all of their banks. Completion Date: December 31, 2024

View Audit 320738

Finding 498076 (2023-002)

Significant Deficiency 2023

Housing and Redevelopment Authority of Morrison County, Minnesota

MN

HUD Housing Programs Reporting

Corrective Action Planned: The Authority will work on getting the Authority’s information in timely and working with their fee accountant to make sure the submission is in timely. Completion Date: December 31, 2024

View Audit 320738

Finding 498071 (2023-006)

Significant Deficiency 2023

North Central Housing Authority

ND

HUD Housing Programs

Corrective Action Planned: The Authority will obtain depository agreements with of their banks. Completion Date: June 30, 2025

View Audit 320731

Finding 498068 (2023-002)

Significant Deficiency 2023

North Central Housing Authority

ND

HUD Housing Programs

Corrective Action Planned: The Authority will start to prepare budgets every year for the Housing Choice Voucher program. Completion Date: June 30, 2025

View Audit 320731

Finding 498000 (2023-001)

Material Weakness 2023

Klamath Housing Authority

OR

Questioned Costs HUD Housing Programs Material Weakness

Federal Award Findings and Questioned Costs Finding 2023-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers and Mainstream Vouchers Programs Federal Assistance Listing Numbers: 14.871 and 14.879 Noncompliance – N. Special T...

Federal Award Findings and Questioned Costs Finding 2023-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers and Mainstream Vouchers Programs Federal Assistance Listing Numbers: 14.871 and 14.879 Noncompliance – N. Special Tests and Provisions – HQS Enforcement Non Compliance Material to the Financial Statements: Yes Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions for the Section 8 Housing Choice Vouchers Program Material Weakness in Internal Control over Compliance for Special Tests and Provisions for the Mainstream Vouchers Program. Criteria: HQS Enforcement. For units under HAP contract that fail to meet HQS, the PHA must require the owner to correct all life threatening HQS deficiencies within 24 hours after the inspections and all other deficiencies within 30 days or within a specified PHA-approved extension. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were failed inspections that did not pass reinspection within 30 days without penalty. Context: There were approximately one hundred and thirty-eight (138) Section 8 Housing Choice Vouchers' units and seven (7) Mainstream Vouchers' units with failed inspections. Of a sample size of fourteen (14) Section 8 Housing Choice Vouchers' and one (1) Mainstream Vouchers' failed inspections, two (2) and one (1) failed inspections, respectively, did not pass reinspection within 30 days. Housing assistance payments were not abated nor was the tenant relocated. Known Questioned Costs: Section 8 Housing Choice Vouchers $814 Mainstream Vouchers $1,608 Cause: There is a significant deficiency for the Section 8 Housing Choice Vouchers Program and a material weakness for the Mainstream Vouchers Program in internal controls over the compliance for the special tests and provisions type of compliance related to HQS inspections. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers Program is in non-compliance and the Mainstream Vouchers Program is in material non-compliance with the special tests and provisions type of compliance related to HQS enforcement. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers and Mainstream Vouchers Programs to ensure that established internal control policies related to HQS inspections are being followed on a timely basis. Ann Malfavon, Executive Director, is responsible for implementing this corrective action by December 31, 2024.

View Audit 320673 Questioned Costs: $1

Finding 497999 (2023-003)

Material Weakness 2023

Klamath Housing Authority

OR

Questioned Costs HUD Housing Programs Material Weakness

Finding 2023-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Assistance Listing Numbers: 14.871 Noncompliance – N. Special Tests and Provisions - Reasonable Rent Non Compliance Material to the Financial S...

Finding 2023-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Assistance Listing Numbers: 14.871 Noncompliance – N. Special Tests and Provisions - Reasonable Rent Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions. Criteria: Reasonable Rent. The PHA must do the following: The PHA must determine that the rent to owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 5 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: There were approximately one hundred and sixty-three (163) newly leased units. Of a sample size of sixteen (16) newly leased units, three (3) unit's documentation of reasonable rent did not include the minimum required number of comparable units of three (3), as stated in the Authority's Section 8 Administrative Policy. Known Questioned Costs: $21,531 Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to reasonable rent. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that reasonably assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers Program is in material non-compliance with the special tests and provisions type of compliance related to reasonable rent. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. Ann Malfavon, Executive Director, is responsible for implementing this corrective action by December 31, 2024.

View Audit 320673 Questioned Costs: $1

Finding 497998 (2023-002)

Material Weakness 2023

Klamath Housing Authority

OR

Questioned Costs HUD Housing Programs Eligibility

Finding 2023-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Federal Assistance Listing Numbers: 14.871 Noncompliance – N. Special Tests and Provisions – Selections from the Waiting List Non Compliance Material to the Fi...

Finding 2023-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Federal Assistance Listing Numbers: 14.871 Noncompliance – N. Special Tests and Provisions – Selections from the Waiting List Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions. Criteria: Selections from the Waiting List. The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants from the waiting list. Except for as provided in 24 CFR section 982.203(Special admission (non-waiting list)), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: Based upon inspection of the waiting list provided to us during the time of audit, the new move-in list and discussions with management, it could not be determined with any certainty that new move-ins were selected from the wait list in an order that is in accordance with the Authority’s policy. Context: Of a sample size of fifteen (15) Section 8 Housing Choice Vouchers' new move-ins, one (1) could not be traced to the Authority's waiting list. Known Questioned Costs: $4,336 Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to selections from the waiting list. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers Program is in material non-compliance with the special tests and provisions type of compliance related to selections from the waiting list. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority agrees with the finding and will increase oversight on the maintenance of the waiting list and process of housing applicants to better monitor adequacy with compliance requirements. Ann Malfavon, Executive Director, is responsible for implementing this corrective action by December 31, 2024.

View Audit 320673 Questioned Costs: $1

Finding 497991 (2023-001)

Significant Deficiency 2023

Brown County Housing Authority

WI

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

U.S. Department of Housing and Urban Development 2023-001 Housing Choice Voucher Program – Assistance Listing No. 14.871 Recommendation: We recommend that the Authority implement a process for ensuring that the GDA is updated with the financial institution when bank accounts are created or closed. E...

U.S. Department of Housing and Urban Development 2023-001 Housing Choice Voucher Program – Assistance Listing No. 14.871 Recommendation: We recommend that the Authority implement a process for ensuring that the GDA is updated with the financial institution when bank accounts are created or closed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority completed the process for updating the General Depository Agreement to include all required accounts. Name of the contact person responsible for corrective action: Patrick Leifker, Executive Director Planned completion date for corrective action plan: September 30, 2024

View Audit 320670

Finding 497988 (2023-002)

None 2023

Town of Plattsburgh Housing Development Fund Company, Inc.

NY

HUD Housing Programs Cash Management

Name of auditee: Town of Plattsburgh Housing Development Fund Company, Inc. TIN: 014-EE068 Name of Audit Firm: EFPR Group, CPAs, PLLC Period covered by audit: December 31, 2023 CAP prepared by: David Kimmel President Two Plus Four Property Management Co,. Inc. (315) 437-2178 Current Finding on the S...

Name of auditee: Town of Plattsburgh Housing Development Fund Company, Inc. TIN: 014-EE068 Name of Audit Firm: EFPR Group, CPAs, PLLC Period covered by audit: December 31, 2023 CAP prepared by: David Kimmel President Two Plus Four Property Management Co,. Inc. (315) 437-2178 Current Finding on the Schedule of Findings and Questioned Costs and Recommendations Finding 2023-002 (a) Comments on the finding and recommendation: Management agrees with the finding. Management also agrees with the recommendation, please see below for action taken. (b) Action taken: Management will deposit the surplus cash in the amount of $11,218 into the residual receipts account during August 2024.

View Audit 320668

Finding 497987 (2023-001)

None 2023

Town of Plattsburgh Housing Development Fund Company, Inc.

NY

Special Tests & Provisions HUD Housing Programs

Name of auditee: Town of Plattsburgh Housing Development Fund Company, Inc. TIN: 014-EE068 Name of Audit Firm: EFPR Group, CPAs, PLLC Period covered by audit: December 31, 2023 CAP prepared by: David Kimmel President Two Plus Four Property Management Co,. Inc. (315) 437-2178 Current Finding on the S...

Name of auditee: Town of Plattsburgh Housing Development Fund Company, Inc. TIN: 014-EE068 Name of Audit Firm: EFPR Group, CPAs, PLLC Period covered by audit: December 31, 2023 CAP prepared by: David Kimmel President Two Plus Four Property Management Co,. Inc. (315) 437-2178 Current Finding on the Schedule of Findings and Questioned Costs and Recommendations Finding 2023-001 (a) Comments on the finding and recommendation: Management agrees with the finding. Management also agrees with the recommendation, please see below for action taken. (b) Action taken: Management will deposit the underfunded amount of $6,000 into the reserve for replacements account during August 2024.

View Audit 320668

Finding 497980 (2023-003)

Significant Deficiency 2023

Maine Sate Housing Authority

ME

HUD Housing Programs Eligibility

2023-003: Housing Voucher Cluster – Eligibility – Document Retention Name of Contact Person(s): Allison Gallagher, Director of Housing Choice Vouchers Management’s Views and Corrective Action Plan: Signed HAP contracts and lease agreements are required for every new lease up and MaineHousing will...

2023-003: Housing Voucher Cluster – Eligibility – Document Retention Name of Contact Person(s): Allison Gallagher, Director of Housing Choice Vouchers Management’s Views and Corrective Action Plan: Signed HAP contracts and lease agreements are required for every new lease up and MaineHousing will not release payment to the owner until those signed documents are received. These agreements state the contract rent and subsidy amounts at the time of the initial lease. Annually, each tenant is recertified and a contract amendment is generated with the current contract rent and subsidy amounts listed. These amendments are filed with the original documents. Management is certain that proper rent and subsidy payments were made based on annual and interim recertification documents on file. A new electronic file retention process was implemented in 2022, which involved organizing and converting volumes of physical files to electronic files. Since implementation of the new process, we have determined that some unit information for certain tenants was inadvertently discarded during conversion. Program staff are identifying missing unit information as they process annual recertification or when an outside party requests it and reaching out to the owner to obtain a copy of the signed original documents. The two HAP and lease contracts identified in this finding have been obtained. Management believes that the electronic file retention process currently in place is working well and this was isolated to the period of time when files were being organized and scanned from physical files to electronic files. Proposed Completion Date: Completed

View Audit 320643

Finding 497965 (2023-002)

Material Weakness 2023

Housing Authority of the City of New Britain

CT

HUD Housing Programs Material Weakness Special Tests & Provisions

HQS Enforcement Description of Findging: Reinspection, follow up and/or abatement documentation was missing for 5 out of 25 initial failed inspections. Statement of Concurrence or NonConcurrence: Procedures were not in place to properly document the corrections of deficiencies and abate the housin...

HQS Enforcement Description of Findging: Reinspection, follow up and/or abatement documentation was missing for 5 out of 25 initial failed inspections. Statement of Concurrence or NonConcurrence: Procedures were not in place to properly document the corrections of deficiencies and abate the housing assistance payments when necessary. EFFECT The Authority may have made housing assistance payments to landlords for units that failed to meet housing quality standards. Corrective Action: Interviews are underway to hire an internal inspector which will allow for better follow through and communication as opposed to a contracted inspector. The HCV Director will monitor inspections completed for proper disposition and also run reports on units due in the upcoming month to make sure they are executed and updated in Pha Web. Procedures be strengthened to ensure that documentation is maintained for all inspections and enforcements. Maribel Aguliar

View Audit 320625

Finding 497954 (2023-001)

Significant Deficiency 2023

Housing Authority of Monroe County

PA

HUD Housing Programs Special Tests & Provisions Significant Deficiency

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority has updated the practice to follow the HUD compliance supplement. Linda Kaufman, Executive Director, is responsible for implementing this corrective action by Decembe...

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority has updated the practice to follow the HUD compliance supplement. Linda Kaufman, Executive Director, is responsible for implementing this corrective action by December 31, 2024.

View Audit 320577

Finding 497921 (2023-001)

Material Weakness 2023

Housing Authority of the City of Easton

PA

Questioned Costs HUD Housing Programs Special Tests & Provisions

Authority Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. Tyler Martin, ...

Authority Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. Tyler Martin, Executive Director, is responsible for implementing this corrective action by December 31, 2024.

View Audit 320526 Questioned Costs: $1

Finding 497920 (2023-004)

Significant Deficiency 2023

New Brighton Borough

PA

Internal Control / Segregation of Duties HUD Housing Programs

Recommendation: Ideally, the Borough would hire the number of staff necessary to segregate all duties. However, we realize segregation of duties is not practical, if not impossible. Because of this internal control situation, the responsibility of the Business Manager is greatly increased because th...

Recommendation: Ideally, the Borough would hire the number of staff necessary to segregate all duties. However, we realize segregation of duties is not practical, if not impossible. Because of this internal control situation, the responsibility of the Business Manager is greatly increased because the Board must rely on his knowledge of the everyday operations to discover any material changes in the Borough’s financial position. Management’s Response: The Borough recognizes that the limited number of staff adds to the risk associated with the daily operations. To mitigate this risk, the Assistant Borough Manager has to take an active role in the day-to-day operations of the Business Unit. She actively reviews all reconciliations and receipts to ensure they are posted to the accounting system properly. In addition, Borough Council approves all disbursements.

View Audit 320523

Finding 497910 (2023-001)

Significant Deficiency 2023

St John's Health Care Corporation

NY

HUD Housing Programs Matching / Level of Effort / Earmarking

CORRECTIVE ACTION PLAN August 29, 2024 U.S. Department of Housing and Urban Development St. John’s Health Care Corporation respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: Bonadio & Co., LLP 171...

CORRECTIVE ACTION PLAN August 29, 2024 U.S. Department of Housing and Urban Development St. John’s Health Care Corporation respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: Bonadio & Co., LLP 171 Sully’s Trail Pittsford, NY 14534 Audit Period: January 1, 2023 – December 31, 2023 The findings from the December 31, 2023, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS – FEDERAL AWARD PROGRAMS AUDIT FINDING 2023-001: Section 232, CFDA 14.129 Recommendation: Adhere to the HUD regulatory agreement in relation to obtaining prior written approval from HUD before encumbering the Project. Action Taken: The Home obtained the related-party loan as a prudent business decision to meet operating expenses. The Home has implemented procedures to ensure that prior written approval is obtained from HUD before encumbering the Project in the future. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Robert Earl at (585)-760-1473. Sincerely yours, Robert Earl Chief Financial Officer

View Audit 320493

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