Corrective Action Plans

Finding Number 2024-001 SPECIAL TESTS AND PROVISIONS- ENVIRONMENTAL CONTAMINANTS TESTING AND REMEDIATION – MATERIAL WEAKNESS Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.850 – PUBLIC AND INDIAN HOUSING Contract # N/A Criteria Special Tests and Provisions - Environmental Contaminants Testing and Remediation As stated in the May 2024 Compliance Supplement, Public Housing must be decent, safe, sanitary, and in good repair. Public Housing Authority’s (PHA) must maintain such housing in a manner that meets the physical condition standards set forth in 24 CFR section 5.703 in order to be considered decent, safe, sanitary, and in good repair. Those standards address the major areas of the public housing: the site; the building exterior; the building systems; the dwelling units; the common areas; and health and safety considerations. Health and safety considerations require that all areas and components of the housing must be free of health and safety hazards. These areas include, but are not limited to, air quality, electrical hazards, elevators, emergency/fire exits, flammable materials, garbage and debris, handrail hazards, infestation, and lead-based paint. The housing must have no evidence of infestation by rats, mice, or other vermin, or of garbage and debris. The housing must have no evidence of electrical hazards, natural hazards, or fire hazards. The dwelling units and common areas must have proper ventilation and be free of mold, odor (e.g., propane, natural gas, methane gas), or other indoor air hazards such as radon. The housing must comply with all requirements related to the evaluation and reduction of lead-based paint hazards and have available proper certifications of such (see 24 CFR Part 35). For the period under audit, the PHA is required to test for and remediate environmental contaminates including but not limited to lead-based paint, radon gas, and mold to ensure that public housing met the physical condition standards for health and safety considerations set forth in 24 CFR section 5.703. Condition/Context The New York City Housing Authority (the “Authority”) performs environmental contaminates testing and remediation including but not limited to Lead-based paint, Mold, Pest Control, Elevators, Heating and Annual Apartment Inspections. To track compliance with the Agreement executed on January 31, 2019 by and among the Authority, the U.S. Department of Housing and Urban Development (“HUD”) and the U.S. Attorney’s Office for the Southern District of New York (SDNY) and The City Of New York (the “HUD Agreement”), the Authority maintains monthly inspection reports for the various inspections performed and provides that information to HUD, the SDNY and the Federal Monitor appointed under the HUD Agreement. Deloitte obtained the bi-annual lead- based paint compliance reports from the Authority and for the Period from January 1, 2024 through July 31, 2024. we read extermination, heat outage, mold inspections, annual apartment inspections, and elevator outage reports for the months of February 2024; April 2024; July 2024; September 2024 and November 2024. During our audit, we noted that the Authority did not complete all corrective actions in the 2024 audit period and is in the process of addressing these issues. Recommendation We recommend that the Authority continue to ensure that all environmental contaminates are properly remediated during the audit period through the HUD Agreement. Corrective Action Plan In January 2019, the Authority entered into the HUD Agreement to address building conditions, including conditions related to lead-based paint, mold, pests, elevators, and heating. Among other things, the HUD Agreement appointed a federal Monitor and established three new Departments – Compliance, Environmental Health & Safety, and Quality Assurance. It also required the promulgation of action plans around these health and safety issues and other items. These action plans are publicly available https://www1.nyc.gov/site/nycha/about/reports.page, along with other reports on health and safety issues, which detail the Authority’s efforts to inspect for and correct deficiencies associated with environmental contaminants like lead-based paint and mold. The Authority plans to continue to work to address these health and safety issues, and to work towards meeting the multi-year obligations laid out in the HUD agreement in addition to the action plans. NYCHA has recorded $4,930,190,000 of pollution remediation obligations as of December 31, 2024, which relates to costs to inspect for, and correct deficiencies associated with environmental contaminants. Action Date Ongoing milestones through January 31, 2039 Final Implementation The latest in time obligation under the HUD Agreement is the Authority’s obligation to abate 100% of the apartment units that contain lead-based paint, and the interior common areas that contain lead-based paint in the same building as those units, by January 31, 2039 Name And Phone Number Of Person Responsible For Implementation Cassiah (Cassie) M.Ward Chief Compliance Officer +1-212-306-8484

U.S. Department of Housing and Urban Development 2024-005 Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 – Annual HQS Inspections Recommendation: We recommend the Authority implement controls to ensure that all units are inspected annually. We recommend the Authority hire an outside firm to perform inspections if there is not capacity internally. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority will increase oversight in the Section 8 Housing Choice Voucher program to ensure that established internal control policies are being followed. The Authority has identified an error whereby our data system isn’t identifying every unit due for an annual inspection. The Authority is implementing a new procedure to confirm every household due for an annual recertification is also pulling for an annual inspection. Name(s) of the contact person(s) responsible for corrective action: Philisa Smith, HCV Director Planned completion date for corrective action plan: December 31, 2026 If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Ashley Hatheway, CFO at (402) 444-6900.

U.S. Department of Housing and Urban Development 2024-004 Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 – Rent Reasonableness Recommendation: We recommend the Authority implement controls to ensure reasonable rent requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority will increase oversight in the Section 8 Housing Choice Voucher program to ensure that established internal control policies are being followed. Increased effort with quality control and staff training will be focused in this area to ensure the HUD-50058 and rent determinations match and are clear on the comparable units. Name(s) of the contact person(s) responsible for corrective action: Philisa Smith, HCV Director Planned completion date for corrective action plan: December 31, 2026

U.S. Department of Housing and Urban Development 2024-003 Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 – PIC Submissions Recommendation: We recommend the Authority to designate an individual to ensure accurate HUD-50058 information is inputted into the PIC system timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority will increase oversight in the Section 8 Housing Choice Voucher program to ensure that established internal control policies are being followed. HUD-50058s are transmitted monthly. Some transmissions have PIC errors while other files that are submitted late due to annual recertification completion. The Authority has plans in place to ensure quality control and resubmission of any errors and to improve timely annual completion and submission. Name(s) of the contact person(s) responsible for corrective action: Philisa Smith, HCV Director Planned completion date for corrective action plan: December 31, 2026

U.S. Department of Housing and Urban Development 2024-002 Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 - Eligibility Recommendation: We recommend the Authority: - Review and revise its eligibility determination procedures to ensure full compliance with HUD regulations. - Train staff on proper documentation and verification protocols for tenant income, assets, expenses and overall eligibility. - Conduct a file audit to identify and correct any improperly admitted tenants. - Update its Administrative Plan to reflect accurate eligibility screening procedures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority will increase oversight in the Section 8 Housing Choice Voucher program to ensure that established internal control policies are being followed. Additional Quality Control personnel have been added in 2025 to review files and confirm calculations. Electronic workflow processes are also being implemented to track regulatory compliance and flag files when not all required processes are completed. Name(s) of the contact person(s) responsible for corrective action: Philisa Smith, HCV Director Planned completion date for corrective action plan: December 31, 2026

USAID Foreign Assistance for Programs Overseas – Assistance Listing No. 98.001 Recommendation: CLA recommends that additional emphasis of documentary evidence of approvals be made, and such evidence obtained and retained by SFP as proof of oversight of expenditure of federal funds. This could include: signatures on reports, emails indicating review and approval from appropriate individuals, retention of meeting agendas and minutes to corroborate that review occurred during the meetings, etc. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective immediately, the COO (or the Director of Finance, once hired) will conduct a documented review and written approval of all federal draw requests prior to submission to USAID. This review will be evidenced by either1. A signed and dated approval on the draw request form, or 2. A saved electronic record (e.g., email approval) in the grant’s shared compliance folder. SFP will also retain relevant meeting minutes or other supporting documentation demonstrating review in accordance with 2 CFR §200.303(a) requirements for internal controls. Name(s) of the contact person(s) responsible for corrective action: Anna Gabis Planned completion date for corrective action plan: October 31, 2025

Report period: 12/31/2024 Title of result and comment FY24 Audit Corrective Action Plan Contact person Responsible for Sabrina Bollinger Corrective Action: Contact's Phone Number 248-593-4611 Contact's Email Address: sbollinger@fourmidable,com Views of Responsible Official: Management agrees with the auditor's finding and will implement the auditor's recommendations. Description of Corrective Action Plan The Commission should implement internal controls over tenant files to ensure accountability. Allcertifications and the required documentation should be maintained in the tenant's current file. Additionally,in order to ensure certifications are performed timely and tenant information is input correctly, theCommission should have a second party review files in a timely manner. Anticipated Completion Date: The plan is to implement the corrective action within six months of the audit date. If applicable: Document reason issue will NOT be corrected with 6 months: N/A

Management will document its’ review of the utility allowances annually for each category and will adjust its allowance schedule with an effective date of January 1st for each calendar year.

Management will re-emphasize its staff and document on new admissions that rent reasonableness was properly determined prior to lease-up.

Corrective Action:  Housing service leadership staff have developed a HUD‐compliant Rent Reasonableness Policy to ensure that each lease served through NWYS will have documentation supporting compliance with federal reasonable rental rates. NWYS housing service leadership staff will follow this policy and procedure to ensure rental rates fall within federal grant compliance requirements at the time of each lease signing or renewal. Documentation of rent reasonableness certification will be performed by NWYS housing staff, reviewed by NWYS housing service leadership, and maintained in the client’s permanent file, as defined in the NWYS Rent Reasonableness Policy. Name(s) of Responsible Party:  NWYS Housing leadership staff – Luis Reyna, Addison Ausley, Daniel Pry Anticipated Completion Date:  9/5/25

Rent Reasonableness forms for rental payments made with CoC funds were not always completed in a timely fashion. Additionally, there was inadequate evidence of internal review and approval. In late 2024, LifeWire’s Controller began requiring Rent Reasonableness forms to be provided with every rental payment request made with public funds. LifeWire’s AP approval process requires review and approval by members of the Director team before payments can be issued. In 2025, all rental payments made with CoC funds now have documented evidence of internal approval and review. Name of Responsible Individual(s): E. Jeannette Biffle, Controller Anticipated Completion Date: The new process was rolled out in November 2024.

We are planning to close the current policy. We are opening a separate policy for Council Towers II, Council Towers III and Council Towers IV that we covered by that policy.

Department of Housing and Urban Development Homeless No More, Inc., HUD Project No. 122-HD085-WDD-NP, respectfully submits the following Corrective Action Plan for the year ended December 31, 2024. Name and address of independent public accounting firm: Suchan & Associates, An Accountancy Corporation, 8588 Utica Ave. Suite 100, Rancho Cucamonga, California 91730. Audit Period: January 1, 2024 through December 31, 2024 The finding from the 2024 Schedule of Findings and Questioned Costs is discussed below. The finding is numbered consistent with the number assigned in the schedule. Section A of the Schedule, Summary of Audit Results does not include findings and is not addressed. FINDINGS-FINANCIAL STATEMENTS AUDIT None FINDINGS AND QUESTIONED COSTS-MAJOR FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT FINDING NO. 2024-001 Section 811 (Capital Advance Loan), AL No. 14.181 Recommendation: The Project should fund the replacement reserves shortage as soon as possible and make the required monthly deposits in accordance with the regulatory agreement. Action Taken: As of the current date the delinquent deposits have not been brought up to date due to ongoing cash flow issues. The Project is negotiating for a rent increase and is in the process of renewing its contract with HUD. Once both the rent increase and contract renewal are approved the replacement reserve account will be funded as soon as the HUD assistance payments are received. If you have any questions regarding the plan, please call Dan O’Brien, Treasurer (213) 251-3410. Sincerely, Dan O’Brien Treasurer

Recommendation – The Project should ensure the surplus cash calculation is made in a manner that allows for a timely deposit of any required deposit to the residual receipts account. If there are cash flow issues preventing the deposit from taking place, the Project needs to contact HUD and request a waiver if allowed. Views of Responsible Officials and Planned Corrective Actions – Management will calculate an estimated surplus cash calculation amount and deposit them into the residual receipts account within the required time frame. Name and Title of Responsible Official – Sabine Cox, Comptroller Anticipated Completion Date – Once the funds are received.

Recommendation – The reserve account was underfunded as of 12/31/24. We recommend that management discuss this issue with HUD and request approval retroactively to fund the reserve account at a lower amount until the funds due to the Project are paid in full by HUD. Views of Responsible Officials and Planned Corrective Actions – Management will reach out to HUD and request approval retroactively to fund the reserve account at a lower amount. Once the approval has been granted and the remainder of the funds have been received, management will pay the reserve account in full. Name and Title of Responsible Official – Sabine Cox, Comptroller Anticipated Completion Date – unknown

Finding 2024-003 - tenant rent payments not deposited timely a. Issue: During the year ended June 30, 2024, Bay Cove Human Services, an affiliate and sponsor agency for Juliette Corporation, collected rent and other client fees related to its clients who are also tenants in the Projects. Bay Cove Human Services did not timely remit the tenant rent portion of these payments to the Projects which resulted in a total balance owed to the Projects of $161,053 as of June 30, 2024. b. Recommendation: Management should establish or undertake a review of internal controls over monitoring of the tenant rent deposits to ensure deposits are timely made into the Project accounts. c. Action taken: Subsequent to year end, Bay Cove Human Services, Inc. deposited the tenant rent payments of $161,053 with the Projects. In addition, the Assistant Controller has p'rovided proper training to both the Senior Accountant and the Senior Cash Management Accountant regarding the transfers that need to be made from Bay Cove Human Services to the Projects for tenant rent. The Senior Accountant is now preparing these transfers on a monthly basis, with the Assistant Controller reviewing them. In addition, the Senior Cash Management Accountant is now performing a monthly reconciliation of the related balance sheet accounts which show the amounts due to/from the entities for the tenant rents in order to identify any problems with the timeliness of the transfers.

Finding 2024-002 - delinquent deposits to the replacement reserve a. Issue: During the year ended June 30, 2024, the Projects did not make the required monthly deposits to the replacement reserves in the amount of $96,360. The Projects were required to make monthly deposits to the reserves in the amount of $144,539 and only $48,179 was deposited during the year ended June 30, 2024. b. Recommendation: Management should establish or undertake a review of internal controls over monitoring of the replacement reserve requirements to ensure deposits are made as required. c. Action taken: The delinquent deposits of $96,360 were made to the replacement reserves subsequent to year end. In addition, a tracking spreadsheet has been re-implemented which lists the monthly amounts required to be transferred to the reserves and has a column for staff to input the date that the transfers were made. This spreadsheet is now reviewed on a weekly basis by both the Senior Cash Management Accountant and the Assistant Controller as part of the weekly check run to ensure that the monthly transfers to the reserves are made early in the month prior to paying other liabilities.

Finding 2024-001: The Corporation did not make all required reserve for replacements deposits during the year ended December 31, 2024. Comments on the Finding and Each Recommendation: The Corporation should make a deposit of $30,975 to the reserve for replacements fund. Action(s) Taken or Planned on the Finding: The Corporation concurs with the recommendation and will make the deposit to fully fund the reserve for replacements fund.

Contact Person Heidi Johnson, Board President Corrective Action Plan The Housing Authority will be more diligent in completing HQS quality control re-inspections on a sample of tenant units each year, as required. Completion Date Effective immediately.

Contact Person Heidi Johnson, Board President Corrective Action Plan The Housing Authority will be more diligent in obtaining general depository agreements with all our financial institutions, as required. Completion Date Effective immediately.

Contact Person Tom Alexander, Executive Director Corrective Action Plan The Authority will be more diligent in maintain tenant file documentation, as required. Completion Date Effective immediately

Contact Person Tom Alexander, Executive Director Corrective Action Plan The Authority will be more diligent in maintaining a tracking system of failed inspection to verify compliance with required timelines, as required.. Completion Date Effective immediately

Contact Person Tom Alexander, Executive Director Corrective Action Plan The Authority will be more diligent in completing HQS quality control re-inspections on a sample of tenant units each year, as required. Completion Date Effective immediately

Contact Person Tom Alexander, Executive Director Corrective Action Plan The Authority will be more diligent in completing HAP contracts when required, as well as all other required information. Completion Date Effective immediately

The above finding is the result of two missed rent schedules not being processed. It will be corrected with the execution of an approved repayment plan with HUD.