Corrective Action Plans

2023-002 Special Tests and Provisions – Income Targeting Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (CFDA 14.871) Type of Finding: Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance This is a repeat finding of 2022-002 from June 30, 2022 (initially reported June 30, 2021) Statement of Condition The Authority did not have adequate controls over income targeting to assure that the Authority is in compliance with this requirement. During our testing, we noted that tenants with incomes that were extremely low accounted for approximately 70% of new admissions during the fiscal year, which is below the minimum required percentage of 75%. Recommendation We recommend the Authority assure that at least 75% of new admissions be in the extremely low-income bracket. This should be monitored throughout the year. The Authority can also select applicants on the waiting list who are extremely low income by bypassing others on the list that don’t meet the requirement and documenting that the person was selected ahead of others to be able to meet the requirement Action Taken: We concur with this finding. We will closely monitor new admissions and focus on applicants on the waiting list who meet the criteria as extremely low income so that the 75% requirement is met. Our lease rate has been decreasing due to a decrease in availability in our area. We have been issuing vouchers every month and have little to no wait on our waiting list. We are also accepting applications every week. We have been unable to exclude persons due to the extremely low-income bracket requirement because we are trying to increase the overall utilization in our voucher program. We have submitted a request to HUD to allow an exception to the income targeting rule and are currently awaiting a response. Effective Date: February 29, 2024 Contact Information Jenny Hammond, Executive Director Housing Authority of the City of York 221 California Street York, SC 29745 (803) 684-7359

Finding No. 2023-001 Eligibility – Tenant Files Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (CFDA 14.871) Type of Finding: Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance This is a repeat finding of 2022-001 from June 30, 2022 (initially reported June 30, 2021) Statement of Condition Out of a total tenant population of approximately 194 vouchers, 20 files were selected for testing. Exceptions were noted as follows: • 1 file where a math error on zero-income calculation resulted in an increase in HAP rent from $709 to $712. • 1 file where a math error on zero-income calculation resulted in a decrease in HAP rent from $961 to $912. • 1 file where social security income was calculated using 2022 amounts despite move-in date in February 2023. As a result, HAP rent decreased from $561 to $546. • 1 file where social security income was calculated using 2022 amounts despite annual re-exam in February 2023. As a result, HAP rent decreased from $709 to $687. In addition to the above, during our new admissions testing (5 tested out of 44 new admissions) we noted the following: • 1 file that did not contain a signed lease agreement. Recommendation The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken We concur with this finding and have implemented various controls. A tenant file and unit quality control procedure has been developed and implemented.

The Downey Adult School concurs with the finding and to prevent future occurrences, the school purchased a new student database management software system (Campus Café) that was implemented on August 1, 2023. The school also partnered with National Student Clearinghouse (NSCH). NSCH articulates with the new student database management software system (Campus Café). The new student database management software system together with National Student Clearinghouse will help to prevent human errors and omissions from occurring when reporting National Student Loan Data System (NSLDS) data. While the district purchased the new system in November of 2022, the school did not begin using the new system(s) until August of 2023 because the switch had to be implemented at the beginning of the fiscal year. Implementation is a several month process and all DAS employees have been receiving extensive training (ongoing) to be proficient and comfortable with the new system(s). We have ongoing weekly training for all DAS staff as we continue to fully implement the new student database management software system.

Finding Number: 2023-001 Planned Corrective Action: Applicable staff will be briefed on the finding and training will be provided on both written policy and procedure. The Housing Authority has a quality assurance program to monitor and ensure the completion and accuracy of the inspection protocol. The Housing Authority will continue to implement its 30-day review system for the HCV Inspection Program. Although the system cannot ensure 100% compliance, its effectiveness is demonstrated in the high percentage of compliance. Anticipated Completion Date: 6/30/2024 Responsible Contact Person: Kristen Runion, HCV Supervisor

Finding Number: 2023-002 Planned Corrective Action: The Housing Authority noted the difference but was unable to resubmit the report. Actions have been taken to build automatic flags in the utility tracking spreadsheet to prevent errors in the future. Anticipated Completion Date: 6/30/2024 Responsible Contact Person: Jen Coy, Fiscal and Budget Officer

The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings – Federal Award Program Audit 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 Catalog Numbers: 14.871 and 14.879 Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Section 8 Housing Choice Vouchers Program - No Mainstream Vouchers Program - Yes Material Weaknesses in Internal Control over Compliance for Eligibility for the Mainstream Vouchers Program Significant Deficiency in Internal Control over Compliance for Eligibility Section 8 Housing Choice Vouchers Program Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 5,295 units. Of a sample size of seventy-one (71) tenant files, the following was noted: • HUD 9886 Form was missing in 1 file • Annual HUD 50058 recertification form and related verification of income and assets was missing in 1 file Our sample size is statistically valid. Known Questioned Costs: • Mainstream Vouchers $19,830 • Section 8 Housing Choice Vouchers Program $1,875 Cause: There is a significant deficiency in compliance for the eligibility type of compliance related to the maintenance of tenant files in the Section 8 Housing Choice Vouchers Program. There is a material weakness in compliance for the eligibility type of compliance related to the maintenance of tenant files in the Mainstream Vouchers Program. The Authority has not properly maintained tenant files in compliance with program requirements following the expiration of HUD waivers. Effect: The Section 8 Housing Choice Vouchers Program is in non-compliance with the eligibility type of compliance related to the maintenance of tenant files. The Mainstream Vouchers Program is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement a corrective action plan that will 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. Following the expiration of the COVID-19 HUD regulatory waivers, the Authority experienced a large backlog of reexaminations along with higher than usual rates of staff turnover and other staff capacity challenges related to the pandemic. Authority management developed and implemented a plan to rapidly work through the backlog, and has made significant progress to bring the program into compliance. The audit resulted in one missing consent form (HUD 9886), and one re-examination (HUD 50058), which is noted as missing. While the consent form had expired and a new consent form was required during the audit period, the income information collected for the household was collected while the consent form was still valid. With regards to the re-examination noted as missing, this re-examination was performed late, having been completed just six days after the end of the audit period. The re-examination was initiated on time, and the delay in completing the re-examination was caused by the program participant’s delay in providing the required documents. Additionally, the Authority has been selected for participation in the Moving to Work program ('MTW'). Alternative re-examination schedules, including biennial re-examinations, are an approved MTW activity allowable through the MTW Operations Notice. The Authority has received HUD approval of a waiver that allows the use of an alternate re-examination schedule effective July 1, 2023. This re-examination schedule is in effect currently and will be in effect for the entire duration of the subsequent audit period. Based on the transition to biennial and triennial re-examinations, the Authority has already come into compliance with timely recertifications. Further, the Authority management is in the process of implementing enhanced Quality Control procedures, with staff to conduct ongoing internal audits over the course of the year. If the U.S. Department of Housing and Urban Development has any questions regarding this plan, please call Aaron Pomeroy, Finance Director at 831-454-5908.

Federal Agency: U.S. Department of Housing and Urban Development Program/Cluster: Section 8 Housing Choice Voucher Cluster Federal Assistance Listing Number: 14.871 Pass‐through: N/A Award No. and Year: CA065‐2023 Compliance Requirement: Utility Allowance Schedule Type of Finding: Instance of Non‐Compliance and Material Weakness in Internal Control over Compliance Views of Responsible Officials: The Housing Authority fully complied with 24CFR 982.517(C)(1) of HUD regulations that states that "A PHA must review its schedule of utility allowances each year and must revise its allowance for a utility category if there has been a change of 10 percent or more in the utility rate since the last time the utility allowance schedule was revised. The PHA must maintain information supporting its annual review of utility allowances and any revisions made in its utility allowance schedule." Each year, the Housing Authority hires a consultant to analyze the Utility allowances for the Fairfield jurisdiction. Once that assessment is completed, Housing Authority staff and Management review it. The Housing Authority staff then meets with the Consultant to discuss any irregularities found or resolve questions emanating from its review. Once staff and Management are satisfied with the information, have clear documentation explaining the Consultant's conclusions, and memorialize any categories that have changed 10% or more, Management will finalize its review of the Utility Allowance Schedule. The Housing Authority will document Management’s approval of the utility allowance adjustments, if any. Responsible Individual(s): Tanya Tran, Housing Division Manager LaTanna Jones, Deputy Executive Director Anticipated Completion Date: June 1, 2024

Finding 2023‐007 Federal Agency: U.S. Department of Housing and Urban Development Program/Cluster: Section 8 Housing Choice Voucher Cluster Federal Assistance Listing Number: 14.871 Pass‐through: N/A Award No. and Year: CA065‐2023 Compliance Requirement: Housing Quality Standards Inspection Type of Finding: Instance of Non‐Compliance and Significant Deficiency in Internal Control over Compliance Views of Responsible Officials: We concur. The Housing Authority will ensure that HQS inspections are completed at least biennially for all units in the program. Each Housing Specialist maintains a tabulation of inspection deadlines for each unit; hence, 98% of the 60‐unit test group was completed on time. However, Management will more frequently monitor the inspection deadlines with the specialist to avoid even a 2% margin of error, as indicated in this audit assessment. Responsible Individual(s): Tanya Tran, Housing Division Manager Anticipated Completion Date: June 1, 2024

Federal Agency: U.S. Department of Housing and Urban Development Program/Cluster: Section 8 Housing Choice Voucher Cluster Federal Assistance Listing Number: 14.871 Pass‐through: N/A Award No. and Year: CA065‐2023 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Views of Responsible Officials: We concur. The Housing Authority addressed this issue when the City was informed in March 2023 there was not enough documentation prior to online grant reporting for the auditors to verify grant reports were reviewed prior to submission on other grants being audited. The Housing Authority has continuously maintained a check and balance approach for preparing and reviewing VMS reports before HUD submission. All reports are prepared by the Housing Authority and finance staff, then reviewed by either the Housing Authority Manager or the Deputy Executive Director before submission to HUD. The reviewer is now documenting their review prior to submitting the VMS reports. Responsible Individual(s): Tanya Tran, Housing Division Manager Anticipated Completion Date: June 30, 2023

Finding 2023-001: Section 202 Supportive Housing for the Elderly, Capital Advance and Project Rental Assistance Contract, ALN 14.157 Anticipated Completion Date: September 30, 2024 Recommendation: It was recommended Sessions Village 202 obtain the missing signed documents if the tenant still resides at the project. In addition, it was recommended Sessions Village 202 review all tenant files to ensure all other records are complete. Also, it was recommended staff involved in the tenant move-in process review the requirements and revise their current process and procedures as needed to ensure the appropriate forms are completed correctly and kept in the tenant files going forward. Additional controls could include completing a checklist of required signed forms obtained during the move-in process. Action Taken: The first tenant listed above no longer resides at the project and a signed HUD model lease cannot be obtained. On November 7, 2023, the Property Manager at Sessions Village 202 obtained the missing signed documents for the second tenant listed above. The Property Manager at Sessions Village 202 will review the process and procedures in place, and implement controls to ensure the appropriate forms are completed correctly and kept in the tenant files going forward.

Finding 2023-003: Section 232 Loan – Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes and Assisted Living Facilities Loan, ALN 14.129 Anticipated Completion Date: December 31, 2023 Recommendation: It was recommended management of Cheney Care Community review their internal controls over the cash and implement a policy to monitor the bank ratings quarterly for the financial institutions the project holds funds at. Action Taken: Cheney Care Community will review and update their policies and procedures to ensure the bank ratings for the financial institutions are monitored on a quarterly basis and the documentation is maintained.

Finding 2023-002: Section 232 Loan – Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes and Assisted Living Facilities Loan, ALN 14.129 Anticipated Completion Date: September 30, 2024 Recommendation: It was recommended management of Cheney Care Community review their internal controls over the cash disbursement process with the necessary individuals involved in the process to ensure the implementation of general ledger account coding on cash disbursements is consistently performed going forward. Action Taken: The Executive Director and A/P Clerk agreed upon using certain general ledger account codes consistently for similar purchases from the same vendor. In Cheney Care Community’s accounting system, these agreed upon general ledger account codes have been pre-set as a default for certain vendors. When invoices are received that should be appropriately coded to this default general ledger account code, errors of not documenting the general ledger account code on the invoice are periodically made. Cheney Care Community will consistently perform the general ledger account coding internal control procedures on invoices going forward.

Finding 2023-001: Section 232 Loan – Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes and Assisted Living Facilities Loan, ALN 14.129 Anticipated Completion Date: September 30, 2024 Recommendation: It was recommended management of Cheney Care Community review their internal controls over the financial reporting and close processes to determine whether additional controls over the preparation of the final trial balances and related schedules can be implemented to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Action Taken: Cheney Care Community will review their internal controls over the financial reporting and close processes to determine whether additional controls need to be implemented going forward.

Corrective Action Plan Finding: Finding 2023-003-Section III Summary Report Not on File-Reporting Condition: Federal regulations require that the Authority update its inventory of equipment and Office Equipment at least every two years. Corrective Action Planned We will comply with the auditor’s recommendation. Person responsible for corrective action: Skipton Evans, Executive Director Telephone: (918) 423-3345 McAlester Housing Authority Fax: (918) 426-3064 520 W. Kiowa McAlester, OK 74501 Anticipated Completion Date- June 30, 2024

January 24, 2024 United States Department of Health and Human Services Community Health and Wellness Center of Greater Torrington, Inc. and Affiliate respectfully submits the following corrective action plan for the year ended September 30, 2023. CohnReznick LLP 350 Church Street Hartford, CT 06103 Audit Period: September 30, 2023 The findings from the September 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS SIGNIFICANT DEFICIENCIES Health Center Program Cluster, Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID - 19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), and Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 2023-001 Recommendation The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated based on family size and income. Action Taken Education was provided to the staff who complete the applications, this included a quiz to measure the staff's knowledge of the process and mathematical calculations. Management developed a tool "How to Calculate Household Income for Processing Financial Assistance Applications" which includes step by step instructions for calculating household income. Prevention strategies have been implemented to prevent future occurrences of adverse events. Monthly audits of the calculation of annual income for a minimum of 10% of the total number of patients who have completed a financial assistance application are being performed. The manager of the population health department will report audit results quarterly at the continuous quality improvement (CQI) committee meeting. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Joanne Borduas, CEO at (860) 387-0425. Sincerely yours,

Finding 2023-006: Voucher Management System Reporting NHA Corrective Action: In process. The fee accountant will now complete the VMS report monthly. The executive director will review these reports monthly. The executive director will conduct an annual review of VMS at the YE closing in June (done in July or August prior to FDS submission) and before HUD pulls VMS data for annual renewal funding (usually done in January). This will ensure that all VMS data is reviewed by both management and the fee accountants, increasing the likelihood that any error will be caught and corrected in a timely manner.

Finding 2023-005: Utility Allowance Review NHA Corrective Action: In process. The Authority hired a firm to complete the annual utility allowance reviews two years ago. Coordinating the review with the firm has yet to produce a review in time to meet the audit deadlines. The annual utility allowance review has been added to the Authority’s annual calendar so that the process will be completed each year by November 1. An annual documentation checklist has been created implementing the finding recommendation to track the annual utility allowance review including: • date of annual utility allowance review • records of rates as of the review date • records of calculations for rate changes • records of increases in utility allowance schedule

Finding 2023-004: Capital Fund Grant Admin NHA Corrective Action: The Authority has all documentation on paper for all payment vouchers, statements that monies were drawn down correctly, invoices, and records of payments. The updated annual online budget forms were not completed in the required Capital Funds timeline regulations. Plans are underway to update the 2023 online budgets within the next month. Ongoing Capital Funds Education continues to be prioritized. Improvements in internal processes will be implemented as knowledge is accumulated. When these online budgets are updated with the information from the paper tracking documentation and submitted for approval to the regional office, it will be clear that the $206,189.50 in Questioned Costs in this finding were accurately distributed. In order to prevent this situation from occurring in the future, the Authority will follow the finding recommendation to provide the following reports at monthly board meetings beginning with the April 2024 board meeting.: • status of grants including grant award • obligation and expenditure deadlines • funds obligated • funds advance, and • funds expended

Finding 2023-003: Allowable Activities NHA Corrective Action: In process. The Authority has initiated a new time study to review its allocation system and document the justification for it. Urlaub will use this information to verify the original 65/35 percentages or to determine more accurate percentages. The new percentages will be used for determining the correct Reallocation of administrative funds. The new percentages will be used to correct the percentages that will be used by Urlaub to redistribute the funding for fiscal year 2024. This information will be used to determine the relevance of the expense being allocated.

CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2023 HANAC, Inc. and Affiliates (HANAC) respectfully submits the following corrective action plan for the year ended June 30, 2023. CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2023 The finding from the June 30, 2023 consolidated and combined schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT None reported. FINDINGS – FEDERAL AWARD PROGRAMS AUDITS Material Weakness FINDING 2023-001 Eligibility U.S. Department of Housing and Urban Development 14.157 Supportive Housing for the Elderly Section 202 Loan Condition: In connection with the audit, it was noted that of the eight lease files tested four files did not have timely recertification of tenants and Enterprise Income Verification system documentation was performed later than the required recertification date. Additionally, one file did not contain the signed application or the background check. Recommendation: Management should establish procedures and monitor compliance with those procedures to insure that tenant security deposits are correctly recorded, 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. Action Taken: Management agrees with recommendation and has begun to implement the following: - A checklist form will be completed for every certification and signed off once file is approved. - An AR form will be created for the move in, transfer and move out process which is to be attached with proof of payment. Once completed it is to be sent to senior staff for review. Under this new management, we already have set in place policies and procedures under the governance of HUD and the tenant selection plan to ensure compliance and due diligence is taking place. Any new staff will be HUD trained. - The file setup format and recertification updates will be monitored on a monthly basis. - EIV are being run according to the frequency provisions related to the type of reports we are annually required to complete as per HUD. Annual inspections are being schedule as per Annual Recertifications are being processed. - Bi-weekly meetings will be in place to discuss the results collected with a tracking log on the progress of the project. - Trainings will be scheduled to keep on top of HUD updates/compliance procedures; Yardi software trainings; and in-house trainings covering compliance with the files and Yardi 50059 module. Expected completion date: January 2024 If any cognizant or oversight agency has questions regarding this plan, please call Lola Maroulis, Chief Financial Officer at 212-840-8005, extension 111. Sincerely yours, Lola Maroulis, Chief Financial Officer

Condition: There was a lack of timely reconciliation performed withdrawals by the Organization to ensure all from the replacement reserve account had proper HUD deposits were approval, all required monthly made, and HUD-approved loans were repaid timely. The Organization from HUD for a $30,848 loan advance received approval to be repaid to the replacement reserve when the November voucher payment was received (November 18, 2022); however, the loan was not repaid until January 18, 2023 Planned Corrective Action: Management acknowledges the significant deficiency in internal control over compliance and has taken measures to improve internal acknowledges control over compliance. Management also that it did not repay the replacement reserve timely received, but with voucher funds subsequently it did repay the $30,848 advance to the replacement reserve account on January 18, 2023. Contact person responsible for corrective action: Bruce Blalock, Sr. VP of Finance and Obligated Group Operations Anticipated Completion Date: January 18, 2023

Condition: During the year ended June 30, 2023, the Organization had 5 withdrawals from the replacement reserve totaling $150,316. Of these withdrawals, $71,998 was properly supported and $78,318 was withdrawn without proper HUD approval. The lack of timely reconciliations resulted in unauthorized amounts transferred out of the replacement reserve and the funds were not returned to the replacement reserve account by June 30, 2023. Planned Corrective Action: Management acknowledges the significant deficiency in internal control over compliance since it did not obtain prior HUD approval for 3 withdrawals totaling $78,318 during the year ended June 30, 2023 and is implementing measures to improve this internal control over compliance. Management returned the $78,318 to the replacement reserve account in August 2023. Contact person responsible for corrective action: Bruce Blalock, Sr. VP of Finance and Obligated Group Operations Anticipated Completion Date: August 2, 2023

Condition: There was a lack of timely reconciliation performed by the Organization to ensure all withdrawals from the replacement reserve account had proper HUD approval, all required monthly deposits were made, and HUD approved loans were repaid timely. The Organization received approval from HUD for a $27,743 loan advance to be repaid to the replacement reserve by January 31, 2023; however, the loan was not repaid until April 17, 2023. Planned Corrective Action: Management acknowledges the significant deficiency in internal control over compliance and has taken measures to improve internal control over compliance Management also acknowledges that it did not repay the replacement reserve timely with voucher funds subsequently received, but it did repay the $27,743 advance to the replacement reserve account on April 17, 2023 Contact person responsible for corrective action: Bruce Blalock, Sr. VP of Finance and Obligated Group Operations Anticipated Completion Date: April 17, 2023

Condition: There was a lack of timely reconciliation performed by the Organization of the replacement reserve account activity. The Organization received approval in 2019 from HUD for a $22,427 loan advance to be repaid to the replacement reserve when the January 2019 voucher payment was received. Of this amount, $6,740 was received and deposited back into the replacement reserve in 2019. The remaining $15,687 was received by the Organization on February 6, 2023, however, this amount was not deposited back to the replacement reserve until after year end, on August 16, 2023. Planned Corrective Action: Management acknowledges the significant deficiency in internal control over compliance that resulted in the late deposit back into the replacement reserve account as required and has taken measures to improve internal control over compliance. Contact person responsible for corrective action: Bruce Blalock, Sr. VP of Finance and Obligated Group Operations Anticipated Completion Date: August 16, 2023

Finding Number: 2023-002 Condition: The Organization failed to refund the security deposit to a tenant within 30 days of their move out date. Planned Corrective Action: Management acknowledges noncompliance in the current fiscal year and returned the security deposit to the resident on December 22, 2022, 41 days after their move out. Contact person responsible for corrective action: Bruce Blalock, Sr. VP of Finance and Obligated Group Operations Anticipated Completion Date: December 22, 2022