Corrective Action Plans

Finding 1208235 (2025-003)

Material Weakness 2025

Palo Duro II Inc.

OK

Special Tests & Provisions HUD Housing Programs Significant Deficiency

Views of Responsible Officials and Planned Corrective Actions: Management Response: Management concurs with the finding. The hazard insurance policy for the project property was in force; however, due to an administrative oversight during policy renewal, the required standard mortgagee clause identi...

Views of Responsible Officials and Planned Corrective Actions: Management Response: Management concurs with the finding. The hazard insurance policy for the project property was in force; however, due to an administrative oversight during policy renewal, the required standard mortgagee clause identifying the U.S. Department of Housing and Urban Development (HUD) as mortgagee/loss payee was not reflected in the insurance documentation maintained on file. Corrective Action Plan: Management will work with the insurance broker to obtain the required endorsement naming the U.S. Department of Housing and Urban Development (HUD) as mortgagee/loss payee and will implement a review process to ensure required endorsements are verified upon future policy renewals. Responsible Official: Stacey Ninness, President/CEO Anticipated Completion Date: Management anticipates the policy endorsement will be completed within 60 days of the audit report date.

View Audit 399180

Finding 1208234 (2025-002)

Material Weakness 2025

Palo Duro II Inc.

OK

HUD Housing Programs Special Tests & Provisions

Views of Responsible Officials and Planned Corrective Actions: Management Response: Management concurs with the finding. Management determined that the noncompliance resulted from insufficient internal controls and monitoring procedures related to HUD-specific banking and cash management requirement...

Views of Responsible Officials and Planned Corrective Actions: Management Response: Management concurs with the finding. Management determined that the noncompliance resulted from insufficient internal controls and monitoring procedures related to HUD-specific banking and cash management requirements. Specifically, formal controls were not in place to ensure required account characteristics were reviewed and confirmed at account setup. Corrective Action Plan: Management will transition the project funds account to a compliant, interest-bearing account in accordance with HUD requirements. Management will also implement procedures to ensure that Section 811 revenues are deposited only into compliant accounts going forward. Responsible Official: Kimberly Burt, Chief Financial Officer Anticipated Completion Date: Management anticipates the bank account transition will be completed within 60 days of the audit report date.

View Audit 399180

Finding 1208233 (2025-001)

Material Weakness 2025

Palo Duro II Inc.

OK

HUD Housing Programs Internal Control / Segregation of Duties Material Weakness § 200.512

Views of Responsible Officials and Planned Corrective Actions: Management Response: Management concurs with the finding. In prior years, the Single Audit Reporting Package was not submitted to the Federal Audit Clearinghouse due to an internal misunderstanding of management’s responsibility for subm...

Views of Responsible Officials and Planned Corrective Actions: Management Response: Management concurs with the finding. In prior years, the Single Audit Reporting Package was not submitted to the Federal Audit Clearinghouse due to an internal misunderstanding of management’s responsibility for submission. With the engagement of a new audit firm, management has clarified these responsibilities. Corrective Action Plan: Management will formally designate responsibility for the timely submission of the Single Audit Reporting Package to a specific member of the finance department. In addition, management will implement a review process to confirm submission and receipt acknowledgment from the Federal Audit Clearinghouse. Responsible Official: Kimberly Burt, Chief Financial Officer Anticipated Completion Date: Management anticipates the filing will be completed within 30 days of the audit report date.

View Audit 399180

Finding 1208228 (2025-001)

Material Weakness 2025

Robertsville Apartments, Inc.

TN

HUD Housing Programs

Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.

View Audit 399172

Finding 1208227 (2025-001)

Material Weakness 2025

Clinch River Apartments, Inc.

TN

HUD Housing Programs

Corrective Action Plan: Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.

View Audit 399170

Finding 1208215 (2025-001)

Material Weakness 2025

Valentine Good Samaritan Hsg Dba Prairie Estates 103-Ee015

CA

HUD Housing Programs

Management will make the delinquent deposit to the replacement reserve of $1,800 and establish transfers for the monthly deposit amount.

View Audit 399147

Finding 1208213 (2025-001)

Material Weakness 2025

Sioux Falls Good Samaritan Hsg Dba Crescent Villa Apts 091-Ee002

CA

HUD Housing Programs

Management will deposit the $5,139 shortfall and ensure future deposits are made in a timely manner.

View Audit 399146

Finding 1208212 (2025-001)

Material Weakness 2025

New Brittany Housing Foundation

CA

Cash Management HUD Housing Programs

The delay in the deposit was an oversight. The deposit has been made. Management will review the surplus cash calculation and ensure any required deposits are made within 90 days of year end.

View Audit 399143

Finding 1208211 (2025-001)

Material Weakness 2025

Casa Community Association

CA

HUD Housing Programs

Management will deposit the $15,800 shortfall and ensure future deposits are made in a timely manner.

View Audit 399129

Finding 1208197 (2025-001)

Material Weakness 2025

City of East Peoria, Illinois

IL

HUD Housing Programs

Finding 2025-001 - Housing Choice Voucher Tenant Files, Eligibility - Noncompliance & Significant Deficiency - Housing Choice Voucher Program - ALN 14.871 Corrective Action Plan: The audit identified that in 3 out of 12 Housing Choice Voucher (HCV) tenant files (25% of the sample), income verificati...

Finding 2025-001 - Housing Choice Voucher Tenant Files, Eligibility - Noncompliance & Significant Deficiency - Housing Choice Voucher Program - ALN 14.871 Corrective Action Plan: The audit identified that in 3 out of 12 Housing Choice Voucher (HCV) tenant files (25% of the sample), income verification requirements were not met. The files contained tenant self-certification only, with no documented attempts to obtain third-party verification as required by HUD regulations and the Agency's Administrative Plan. Corrective Action Steps: 1. Immediate File Review & Correction: Conduct a full review of all active HCV tenant files to identify any additional instances of missing third-party verification. For any file where verification is missing, take corrective action (e.g., obtain required third-party documentation or document attempts if unavailable). Ensure the verification tracking log is being utilized for all verification attempts going forward. 2. Implementation of Stronger Monitoring Controls: Develop a standardized Income Verification Checklist. Executive Director will increase monthly quality-control checks. 3. Staff Training: Provide mandatory training on HUD verification requirements, documentation standards and correct procedures for obtaining and recording third-party verification. 4. Policy Updates: Ensure SOP outlines required verification steps and documentation standards. Anticipated Completion Date: June 30, 2026 Person Responsible: LaToya Brown, Executive Director

View Audit 399078

Finding 1207117 (2025-001)

Material Weakness 2025

The Pelham II Corporation

MA

HUD Housing Programs Internal Control / Segregation of Duties Procurement, Suspension & Debarment § 200.512

A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Finding 2025-001 a. Comments on Finding and Each Recommendation Management agrees with the finding and the transition of responsibilities to the new President has been further identified and understood since ste...

A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Finding 2025-001 a. Comments on Finding and Each Recommendation Management agrees with the finding and the transition of responsibilities to the new President has been further identified and understood since stepping into the role in November 2024. b. Action(s) Taken or Planned on the Finding Identification and understanding of the reporting deadlines, along with the necessary access to facilitate the transmission of data. Going forward the Data Collection Form will be prepared by the management company and reviewed and approved by the President of the Pelham Corporation prior to submission. This action has been completed during 2025. This will allow the timely submission going forward B. Status of Corrective Actions on Findings Reported in the Prior Audit Schedule of Findings, Questions Costs and Recommendations There were no open findings on the prior audit report.

View Audit 398940

Finding 1207113 (2025-001)

Material Weakness 2025

Wesley Jackson Highlands, Inc. 081-Ee022

TN

Subrecipient Monitoring HUD Housing Programs

Finding #2025-001: Comments on the Finding and Each Recommendation: During the year ended December 31, 2025, the Corporation did not make the HUD required total amount of deposits to the reserve for replacements. Management should transfer $19,826 from the operating account to the reserve for replac...

Finding #2025-001: Comments on the Finding and Each Recommendation: During the year ended December 31, 2025, the Corporation did not make the HUD required total amount of deposits to the reserve for replacements. Management should transfer $19,826 from the operating account to the reserve for replacements account. Action(s) taken or planned on the finding: Management concurs with the finding and recommendation. On February 3, 2026, management transferred $20,258 from the operating account to the reserve for replacements. 35

View Audit 398917

Finding 1206884 (2025-001)

Material Weakness 2025

Stand Down Housing, Inc.

RI

HUD Housing Programs

FINDING 2025-001: Section 811 Capital Advance Program and Project Rental Assistance Contract ALN# 14.181 Recommendation: Management will address the shortfall in the replacement reserve by making up the missed deposits in the subsequent period alongside the normal required contributions. Action Take...

FINDING 2025-001: Section 811 Capital Advance Program and Project Rental Assistance Contract ALN# 14.181 Recommendation: Management will address the shortfall in the replacement reserve by making up the missed deposits in the subsequent period alongside the normal required contributions. Action Taken: The Organization will make the necessary required deposits to bring the balance of the reserve for replacement in alignment with requirements of Section 811 Capital Advance Program Regulatory Agreement.

View Audit 398888

Finding 1206883 (2025-001)

Material Weakness 2025

Silent Cooperative Apartments

IL

HUD Housing Programs

Recommendation: We recommend that management and those charge with governance to improve internal controls to ensure that all required lease agreements are included in tenant files. Response: As of March 2026, to prevent recurrence, management has implemented the following procedural changes: 1. The...

Recommendation: We recommend that management and those charge with governance to improve internal controls to ensure that all required lease agreements are included in tenant files. Response: As of March 2026, to prevent recurrence, management has implemented the following procedural changes: 1. The move in checklist will add a line requiring staff sign-off confirming that all executed lease documents are placed in the tenant file prior to move-in or lease renewal. 2. Property management staff will conduct monthly file reviews to verify that all move in’s required documentation, including signed lease agreements, is present and current in each tenant file. 3. The Regional Manager will conduct quarterly file audits to ensure ongoing compliance and will report findings to management.

View Audit 398883

Finding 1206856 (2025-002)

Material Weakness 2025

Casa Otonal Housing Corporation

CT

HUD Housing Programs Eligibility

Project Legal Name: Casa Otonal Housing Corporation HUD Project No.: 017-EH073 Audit Firm: CohnReznick LLP Period covered by the audit: 06/30/2025 Corrective Action Plan prepared by: Name: Sabine Cox Position: Comptroller/Director of Finance Telephone Number: (203) 230-4809 The following is a recomm...

Project Legal Name: Casa Otonal Housing Corporation HUD Project No.: 017-EH073 Audit Firm: CohnReznick LLP Period covered by the audit: 06/30/2025 Corrective Action Plan prepared by: Name: Sabine Cox Position: Comptroller/Director of Finance Telephone Number: (203) 230-4809 The following is a recommended format to be followed by the auditee for preparing a correction action plan: A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendation Finding 2025-002 a. Comments on the Finding and Each Recommendation In connection with our lease file review, we noted the following deficiencies: For one out of one new tenant tested, the Project did not maintain evidence in the lease file that the Enterprise Income Verification ("EIV") system was utilized within 90 days of the tenant's initial certification date of April 1, 2025. For two out of ten existing tenants tested, the Project did not maintain evidence in the lease files that the EIV system was utilized within 120 days of the tenant's annual certification dates of August 1, 2024. For one out of one new tenant tested, the Project did not maintain evidence in the lease file that a move-in inspection was performed. b. Action(s) Taken or Planned on the Finding During the transition of a new site from a prior management company, the Property Manager, Regional Manager, and Director of Compliance must collaborate closely to conduct a thorough review of all tenant files. This coordinated effort helps ensure accuracy, identify any discrepancies early, and supports more effective and efficient use of the EIV system for tenant file testing.

View Audit 398860

Finding 1206654 (2025-001)

Material Weakness 2025

Blue Earth County

MN

HUD Housing Programs Eligibility

HQS Enforcement CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: To address the issues identified and prevent recurrence, the EDA has implemented the following corrective actions: 1....

HQS Enforcement CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: To address the issues identified and prevent recurrence, the EDA has implemented the following corrective actions: 1. StaffingA new rental housing inspector has been hired. The position has been converted from part-time to full-time, allowingadequate time for the inspector to monitor inspection timelines, complete required inspections and reinspections, andensure timely reporting and compliance with program requirements. 2. Training and CertificationStaff completed training on new inspection guidelines and protocols in March 2024. Certification in both HQS andNSPIRE inspection standards are currently underway for the new inspector. This training will ensure the inspector isfully knowledgeable of federal inspection requirements, documentation standards, and required compliancetimelines. 3. Improved Inspection Monitoring and DocumentationThe EDA has strengthen internal procedures for scheduling and tracking inspections and reinspections within theinspection software to ensure all failed inspections are documented and scheduled for reinspection within therequired timeframe. 4. Transition to Electronic Inspection ReportingThe EDA requires the use of iPad-based electronic inspections rather than paper inspection forms. This changeprovides real-time documentation, ensure inspections are entered directly into the tracking system, and reduce therisk of inspections being completed but not logged. 5.Compliance Notification and Payment ControlsA formal procedure has been established to notify appropriate staff in the event of inspection non-compliance. Underthis procedure, Housing Assistance Payments (HAP) will be held until compliance is achieved or the tenant has movedfrom the unit, consistent with program regulations. Management believes these corrective actions will strengthen internal controls over the inspection process, improve documentation and tracking, and ensure compliance with HUD Housing Quality Standards requirements moving forward. The EDA will continue to monitor inspection activities to maintain safe and habitable housing conditions for program participants. Official Responsible for Ensuring CAP: Nicole Cunningham, Housing Coordinator, is the official responsible for ensuring corrective action.

View Audit 398782

Finding 1206653 (2025-001)

Material Weakness 2025

Mankato Economic Development Authority

MN

HUD Housing Programs Eligibility

2025-001 HQS Enforcement CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: To address the issues identified and prevent recurrence, the EDA has implemented the following corrective ac...

2025-001 HQS Enforcement CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: To address the issues identified and prevent recurrence, the EDA has implemented the following corrective actions: 1. Staffing A new rental housing inspector has been hired. The position has been converted from part-time to full-time, allowing adequate time for the inspector to monitor inspection timelines, complete required inspections and reinspections, and ensure timely reporting and compliance with program requirements. 2. Training and Certification Staff completed training on new inspection guidelines and protocols in March 2024. Certification in both HQS and NSPIRE inspection standards are currently underway for the new inspector. This training will ensure the inspector is fully knowledgeable of federal inspection requirements, documentation standards, and required compliance timelines. 3. Improved Inspection Monitoring and Documentation The EDA has strengthened internal procedures for scheduling and tracking inspections and reinspections within the inspection software to ensure all failed inspections are documented and scheduled for reinspection within the required timeframe. 4. Transition to Electronic Inspection Reporting The EDA requires the use of iPad-based electronic inspections rather than paper inspection forms. This change provides real-time documentation, ensures inspections are entered directly into the tracking system, and reduce the risk of inspections being completed but not logged. 5. Compliance Notification and Payment Controls A formal procedure has been established to notify appropriate staff in the event of inspection non-compliance. Under this procedure, Housing Assistance Payments (HAP) will be held until compliance is achieved or the tenant has moved from the unit, consistent with program regulations. Management believes these corrective actions will strengthen internal controls over the inspection process, improve documentation and tracking, and ensure compliance with HUD Housing Quality Standards requirements moving forward. The EDA will continue to monitor inspection activities to maintain safe and habitable housing conditions for program participants. Official Responsible for Ensuring CAP: Nicole Cunningham, Housing Coordinator, is the official responsible for ensuring corrective action. Planned Completion Date for CAP: The planned completion date is December 31, 2026. Plan to Monitor Completion of CAP: The Board will be monitoring this corrective action plan and believes the Executive Director will remedy this finding. Nicole Cunningham Housing Coordinator

View Audit 398779

Finding 1206649 (2025-001)

Material Weakness 2025

Las Bougainvilleas Senior Housing, Inc.

CA

HUD Housing Programs

Management’s response and corrective action plan (unaudited): Property Manager has reviewed the Course Presentation Handbook on Enterprise Income Verification Specialist (EIVS) and will ensure EIV Income reports are run on time. In addition, management at Casitas of Hayward, Inc. ("Casitas") will im...

Management’s response and corrective action plan (unaudited): Property Manager has reviewed the Course Presentation Handbook on Enterprise Income Verification Specialist (EIVS) and will ensure EIV Income reports are run on time. In addition, management at Casitas of Hayward, Inc. ("Casitas") will implement a review process to ensure that all required EIV reports are run timely and maintained in the tenant lease file as required by HUD Handbook 4350.3, Chapter 9, Section 1, 9-58.

View Audit 398748

Finding 1206646 (2025-003)

Material Weakness 2025

Keppel Union School District

CA

Cash Management HUD Housing Programs

Corrective Actions Implemented: 1. Monthly Reconciliation Process: A reconciliation procedure has been implemented requiring cafeteria site managers to compare meal production records, point-of-sale (POS) reports, and student attendance records (including Saturday School attendance, when applicable)...

Corrective Actions Implemented: 1. Monthly Reconciliation Process: A reconciliation procedure has been implemented requiring cafeteria site managers to compare meal production records, point-of-sale (POS) reports, and student attendance records (including Saturday School attendance, when applicable) prior to submission of CNIPS claims. Any discrepancies are investigated and corrected. 2. Verification of Meal Counts: Site managers are now required to review production records and POS data to ensure that only meals actually served to eligible students are included in reimbursement claims. 3. Staff Training: Training has been provided to cafeteria staff and site managers on proper meal counting and claiming procedures to ensure compliance with federal requirements. 4. Supervisory Review: All monthly CNIPS claims are now subject to review and approval by the Child Nutrition Director prior to submission to ensure accuracy and completeness. 5. Ongoing Monitoring: The Director will conduct periodic internal reviews of meal counting and claiming procedures to ensure continued compliance and prevent recurrence of this issue. The District believes these corrective actions address the cause of the finding and will ensure accurate reporting of meals served going forward.

View Audit 398746

Finding 1206631 (2025-003)

Material Weakness 2025

Sunnycrest Village Project LLC

SD

HUD Housing Programs Significant Deficiency

Finding 2025-003 Federal Agency Name: U.S. Department of Housing and Urban Development Federal Financial Assistance Listing Number: #14.134 Program Name: Mortgage Insurance Rental Housing Finding Summary: The Project made twelve monthly deposits into the replacement reserve account; however, the dep...

Finding 2025-003 Federal Agency Name: U.S. Department of Housing and Urban Development Federal Financial Assistance Listing Number: #14.134 Program Name: Mortgage Insurance Rental Housing Finding Summary: The Project made twelve monthly deposits into the replacement reserve account; however, the deposits were not at the amount identified and required by HUD. Corrective Action Plan: Management is working with our mortgagor to appropriately fund the replacement reserve account for the underfunding and will deposit into the replacement reserve account $4,962. Responsible Individuals: Mary Morgan, Executive Director Anticipated Completion Date: April 2026

View Audit 398716

Finding 1206630 (2025-002)

Material Weakness 2025

Sunnycrest Village Project LLC

SD

HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring

Finding 2025-002 Federal Agency Name: U.S. Department of Housing and Urban Development Federal Financial Assistance Listing Number: #14.134 Program Name: Mortgage Insurance Rental Housing Finding Summary: The testing of property, operations, and distributions detected one instance of underpayment of...

Finding 2025-002 Federal Agency Name: U.S. Department of Housing and Urban Development Federal Financial Assistance Listing Number: #14.134 Program Name: Mortgage Insurance Rental Housing Finding Summary: The testing of property, operations, and distributions detected one instance of underpayment of an expense based upon review of supporting invoices and the allocation of the expense. Corrective Action Plan: The invoice approval form will include a note stating that, before completing a disbursement of funds, the request must include supporting documents including allocation calculations and approvals. Accounts Payable staff retraining on allocation calculations has been completed, and the calculation formulas have been updated. Responsible Individuals: Mary Morgan, Executive Director Anticipated Completion Date: April 2026

View Audit 398716

Finding 1206536 (2025-001)

Material Weakness 2025

Orford Village Commons, Inc.

CT

Cash Management HUD Housing Programs

Management agrees with the finding. The residual receipts account deficiency will be funded in the amount of $7,949. Management will ensure that the residual receipts account is properly funded in the future.

View Audit 398623

Finding 1206533 (2025-002)

Material Weakness 2025

City of Corpus Christi, Texas

TX

Allowable Costs / Cost Principles HUD Housing Programs Significant Deficiency

Finding 2025-002 Information on Federal Program: Federal Program: CDBG Entitlement Grants Cluster Federal Agency: U.S. Department of Housing and Urban Development (HUD) Assistance Listing: 14.218 Compliance Requirements: Allowable Costs/Cost Principles Corrective Action Plan The City will submit pay...

Finding 2025-002 Information on Federal Program: Federal Program: CDBG Entitlement Grants Cluster Federal Agency: U.S. Department of Housing and Urban Development (HUD) Assistance Listing: 14.218 Compliance Requirements: Allowable Costs/Cost Principles Corrective Action Plan The City will submit payment to HUD for the $249,565 of questioned costs. Additionally, the City will update its written program and financial policies and procedures per 24 CFR 570.200(g) which should outline how the City of Corpus Christi will monitor compliance with both of the Administrative and Planning expenditure tests and will provide HUD with a certification stating Planning and Community Development staff received training regarding the limitation on planning and administration costs for origin year grants. Person(s) Responsible Jennifer Buxton, Interim Director of Planning and Economic Development Anticipated Completion Date The City has completed all corrective actions.

View Audit 398608

Finding 1206525 (2025-001)

Material Weakness 2025

Guadalupe County Hsg Development Inc. (sunrise Villa Apts)

TX

Cash Management HUD Housing Programs

Management agrees with the finding. The residual receipts account deficiency was funded on January 15, 2026 in the amount of $34,482. Management will ensure that the residual receipts account is properly funded in the future.

View Audit 398589

Finding 1206476 (2025-001)

Material Weakness 2025

Senior Citizens Housing Development Corporation of Montgomery County

FL

HUD Housing Programs

Oversight Agency for Audit, Senior Citizens Housing Development Corporation of Montgomery County, operating as Council House, respectfully submits the following corrective action plan for the year ended September 30, 2025. Name and address of independent public accounting firm: Bellows Associates, P...

Oversight Agency for Audit, Senior Citizens Housing Development Corporation of Montgomery County, operating as Council House, respectfully submits the following corrective action plan for the year ended September 30, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit period: October 1, 2024 through September 30, 2025 The finding from the September 30, 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. SECTION III – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2025-001: Section 227/223(f) Mortgage Insurance for the Refinance of Existing Multifamily Housing Projects, ALN 14.155 Recommendation:The Project should implement procedures to ensure that proper initial eligibility procedures are conducted for potential tenants and that tenant files are accurately maintained. Action Taken: Staff training has been provided with additional HUD training inclusive of EIV reporting and tenant file maintenance and included in monthly reporting procedures. If the audit Oversight Agency has questions regarding these plans, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips CFO

View Audit 398489

Corrective Action Plans

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