Corrective Action Plans

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The responsible official for the corrective action plan is Valerie Vallee, Vice President. The anticipated completion date is April 9, 2025. Response: Unpaid replacement reserve escrow from August 2024 was paid in April 2025.
The responsible official for the corrective action plan is Valerie Vallee, Vice President. The anticipated completion date is April 9, 2025. Response: Unpaid replacement reserve escrow from August 2024 was paid in April 2025.
Name of auditee: Beverly Normandie Housing Corporation HUD auditee identification number: CA16L000004 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2024 CAP prepared by Name: Noel Sweizter Position: President, HDSI Management, Inc. Telephone n...
Name of auditee: Beverly Normandie Housing Corporation HUD auditee identification number: CA16L000004 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2024 CAP prepared by Name: Noel Sweizter Position: President, HDSI Management, Inc. Telephone number: 323-231-1107 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Finding 2024-004: During the year ended December 31, 2024, management did not maintain tenant files in accordance with HUD Handbook 4350.3 Chapter 7. Comments on the Finding and Each Recommendation: Management should perform a review of all tenant files and complete all recertifications that were not completed timely. Management should also ensure that all requirements of HUD Handbook 4530.3 Chapter 7 are adhered to in future periods. Action(s) taken or planned on the finding: Management has completed the recertifications effective November 1, 2024 and 2025 or adjusted on the HAP voucher for any that were not completed timely.
Name of auditee: Beverly Normandie Housing Corporation HUD auditee identification number: CA16L000004 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2024 CAP prepared by Name: Noel Sweizter Position: President, HDSI Management, Inc. Telephone n...
Name of auditee: Beverly Normandie Housing Corporation HUD auditee identification number: CA16L000004 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2024 CAP prepared by Name: Noel Sweizter Position: President, HDSI Management, Inc. Telephone number: 323-231-1107 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Finding 2024-003: Management did not disburse calculated security deposit refunds to three tenants that moved out during the year ended December 31, 2024 timely. Comments on the Finding and Each Recommendation: Management should calculate and distribute a tenant's security deposit refund within 30 days of the tenant moving out. Action(s) taken or planned on the finding: Management disbursed the tenants' security deposit refunds on October 22, 2025 and will disburse security deposit refunds within 30 days of the tenant moving out moving forward.
Name of auditee: Beverly Normandie Housing Corporation HUD auditee identification number: CA16L000004 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2024 CAP prepared by Name: Noel Sweizter Position: President, HDSI Management, Inc. Telephone n...
Name of auditee: Beverly Normandie Housing Corporation HUD auditee identification number: CA16L000004 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2024 CAP prepared by Name: Noel Sweizter Position: President, HDSI Management, Inc. Telephone number: 323-231-1107 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Finding 2024-002: The Corporation did not maintain a cash account for residents' security deposits in an amount greater than or equal to the outstanding balance of the residents' security deposit liability at all times during the year ended December 31, 2024. At December 31, 2024, the residents' security deposit cash account was underfunded by $11,052. Comments on the Finding and Each Recommendation: Management should establish a security deposit cash account and ensure the residents' security deposits cash account is adequately funded. Management should transfer funds from the Property's operating cash account to adequately fund the residents' security deposits cash accounts. Action(s) taken or planned on the finding: Management transferred operating funds to adequately fund the security deposit cash account on November 13, 2025.
Name of auditee: Beverly Normandie Housing Corporation HUD auditee identification number: CA16L000004 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2024 CAP prepared by Name: Noel Sweizter Position: President, HDSI Management, Inc. Telephone n...
Name of auditee: Beverly Normandie Housing Corporation HUD auditee identification number: CA16L000004 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2024 CAP prepared by Name: Noel Sweizter Position: President, HDSI Management, Inc. Telephone number: 323-231-1107 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Finding 2024-001: The Corporation did not furnish HUD with a complete annual financial report within ninety (90) days following the year ended December 31, 2024. Additionally, Form SF-SAC Single Audit Date Collection Form for the year ended December 31, 2024 was not submitted to the federal audit clearinghouse in the required timeframe. Comments on the Finding and Each Recommendation: The Corporation should ensure the annual financial report to HUD and Form SF-SAC Single Audit Data Collection form are filed within the regulatory timeline. Action(s) taken or planned on the finding: The audited financial statements have been submitted to HUD and the federal clearinghouse. No further action is required.
Action Taken: The Houston Housing Authority agrees with this finding and related recommendations. During this audit, as these issues arose, notes were taken, evaluation of what had happened was made so that we could make the necessary adjustments to our procedures to prevent the continuation of thes...
Action Taken: The Houston Housing Authority agrees with this finding and related recommendations. During this audit, as these issues arose, notes were taken, evaluation of what had happened was made so that we could make the necessary adjustments to our procedures to prevent the continuation of these issues. In addition, in the previous year we hired a firm to come in and undertake a review of the finance department. The purpose of this review was to review our existing staffing levels, workloads, experience, etc., for purposes of proposing a reorganization of the finance department to address any deficiencies. We have reviewed the recommendations from this consultant and are in the process of implementing many of the recommended changes. There have been a number of staffing changes made during the year with the intent of improving the overall performance of the finance department. We are in the process of evaluating if additional staff are needed to expand the capacity of the Finance department. In November of 2024 the Houston Housing authority converted to a new accounting system. The Yardi system was implemented and we began processing all transactions on this new system. Unfortunately, there have been a significant amount of post implementation corrections and modifications that have had to be made and continue to occur. We are still undergoing these implementation and modification processes and as a result of this we continue to have to make adjusting entries to correct errors as they are discovered. To further complicate this system conversion there were a number of changes made to the management companies that we utilize to do our primary property level accounting. They have also been converting portions of their accounting systems to Yardi. Many of the same problems that have been encountered during our system conversion have also been encountered by the management companies. It is anticipated that most of these system conversion related issues will be resolved within the 2025 calendar year. The VP Fiscal and Business Operations as well as the Director of Finance are responsible for implementing the necessary process and procedural changes to eliminate the need for this type of finding for the 2024 audit.
The Houston Housing Authority agrees with this fining and related recommendations. During 2024 the voucher and public housing programs converted to a new software system. Yardi is not the principal operating system for both the voucher and public housing programs. This system conversion has required...
The Houston Housing Authority agrees with this fining and related recommendations. During 2024 the voucher and public housing programs converted to a new software system. Yardi is not the principal operating system for both the voucher and public housing programs. This system conversion has required that work flows had to be modified. This modification and implementation of a new processing system did not allow staff to conduct the necessary reviews of existing files to make sure that the compliance related materials that should be found in each file were to be completed. This issue has been discussed and there will be an internal review conducted on file samples to determine what compliance deficiencies are prevalent. Corrective action steps will be implemented to address these issues designed to correct them. Additional training resources will be devoted to staff in these departments designed to improve quality control with these program areas. The Senior Vice President of Voucher Operations will be focused on improving the quality of our files that support the voucher operations
Action Taken: The Houston Housing Authority agrees with this fining and related recommendations. During 2024 the voucher and public housing programs converted to a new software system. Yardi is not the principal operating system for both the voucher and public housing programs. This system conversio...
Action Taken: The Houston Housing Authority agrees with this fining and related recommendations. During 2024 the voucher and public housing programs converted to a new software system. Yardi is not the principal operating system for both the voucher and public housing programs. This system conversion has required that work flows had to be modified. This modification and implementation of a new processing system did not allow staff to conduct the necessary reviews of existing files to make sure that the compliance related materials that should be found in each file were to be completed. This issue has been discussed and there will be an internal review conducted on file samples to determine what compliance deficiencies are prevalent. Corrective action steps will be implemented to address these issues designed to correct them. Additional training resources will be devoted to staff in these departments designed to improve quality control with these program areas. The Senior Vice President of Voucher Operations will be focused on improving the quality of our files that support the voucher operations.
Action Taken: The Houston Housing Authority agrees with this fining and related recommendations. During 2024 the voucher and public housing programs converted to a new software system. Yardi is not the principal operating system for both the voucher and public housing programs. This system conversio...
Action Taken: The Houston Housing Authority agrees with this fining and related recommendations. During 2024 the voucher and public housing programs converted to a new software system. Yardi is not the principal operating system for both the voucher and public housing programs. This system conversion has required that work flows had to be modified. This modification and implementation of a new processing system did not allow staff to conduct the necessary reviews of existing files to make sure that the compliance related materials that should be found in each file were to be completed. This issue has been discussed and there will be an internal review conducted on file samples to determine what compliance deficiencies are prevalent. Corrective action steps will be implemented to address these issues designed to correct them. Additional training resources will be devoted to staff in these departments designed to improve quality control with these program areas. The Senior Vice President of Voucher Operations and the Senior Vice President of Asset Management will be focused on improving the quality of our files that support the voucher and public housing operations
Management concurs with the finding. The Organization revised its tenant monitoring procedures to ensure timely annual recertification of income and compliance with HUD rent adjustment requirements. Training is being provided to all property management staff, and management has implemented procedure...
Management concurs with the finding. The Organization revised its tenant monitoring procedures to ensure timely annual recertification of income and compliance with HUD rent adjustment requirements. Training is being provided to all property management staff, and management has implemented procedures to ensure all required actions are taken when a tenant becomes over-income. As of December 14, 2024 lease agreements have been updated to include language that states once a tenant is over the income limit, they are considered ineligible and their rent will immediately be adjusted to the HUD market rent.
Effective January 1, 2026, management will implement measures such as recurring automated email reminders and scheduled check-in meetings to ensure the REAC report is filed on time going forward.
Effective January 1, 2026, management will implement measures such as recurring automated email reminders and scheduled check-in meetings to ensure the REAC report is filed on time going forward.
Effective January 1, 2026, management will implement measures such as recurring automated email reminders and scheduled check-in meetings to ensure the REAC report is filed on time going forward.
Effective January 1, 2026, management will implement measures such as recurring automated email reminders and scheduled check-in meetings to ensure the REAC report is filed on time going forward.
FINDING# 2024-002 LATE CENSUS BUREAU FILING Condition: The property did not file its annual data collection form with the Federal Audit Clearing House Census Bureau within the required time frame. Recommendation: We recommend that the property comply with all continuing compliance requirements and e...
FINDING# 2024-002 LATE CENSUS BUREAU FILING Condition: The property did not file its annual data collection form with the Federal Audit Clearing House Census Bureau within the required time frame. Recommendation: We recommend that the property comply with all continuing compliance requirements and ensure that the data collection form is submitted by the required deadline in the future. Views of Responsible Officials and Planned Corrective Action: Management will comply with this recommendation in the future.
FINDING# 2024-001 LATE AUDIT SUBMISSION Condition: The project did not file its annual audit within the required time frame. Recommendation: We recommend that the property comply with HUD’s audit requirements and ensure that the audit is submitted by the required deadline in the future. Views of Res...
FINDING# 2024-001 LATE AUDIT SUBMISSION Condition: The project did not file its annual audit within the required time frame. Recommendation: We recommend that the property comply with HUD’s audit requirements and ensure that the audit is submitted by the required deadline in the future. Views of Responsible Officials and Planned Corrective Action: Management is aware and will comply with this recommendation in the future.
Management concurs with the finding. The Authority has developed a Compliance Reporting Schedule listing all required federal reporting submissions, their due dates, and the responsible staff. Calendar reminders and verification checkpoints have been implemented to ensure timely submissions. In addi...
Management concurs with the finding. The Authority has developed a Compliance Reporting Schedule listing all required federal reporting submissions, their due dates, and the responsible staff. Calendar reminders and verification checkpoints have been implemented to ensure timely submissions. In addition, the Authority will conduct quarterly internal audits to confirm adherence to HUD reporting requirements. Management anticipates full corrective action by December 2025.
Management concurs with the finding. The Authority has developed a Compliance Reporting Schedule listing all required HUD submissions, their due dates, and the responsible staff. Calendar reminders and verification checkpoints have been implemented to ensure timely submissions. In addition, the Auth...
Management concurs with the finding. The Authority has developed a Compliance Reporting Schedule listing all required HUD submissions, their due dates, and the responsible staff. Calendar reminders and verification checkpoints have been implemented to ensure timely submissions. In addition, the Authority will conduct quarterly internal audits to confirm adherence to HUD reporting requirements. Management anticipates full corrective action by December 2025.
Management Response: To enhance compliance and operational efficiency, OLYCAP engaged a contract manager to support timely fulfillment of reporting obligations and contractual requirements. This role also includes onboarding new management personnel by ensuring they are informed of all relevant cont...
Management Response: To enhance compliance and operational efficiency, OLYCAP engaged a contract manager to support timely fulfillment of reporting obligations and contractual requirements. This role also includes onboarding new management personnel by ensuring they are informed of all relevant contracts and associated reporting protocols. Anticipated Completion Date: April, 2025 and ongoing. Responsible officials: Erin Smith Holly Morgan
Management Response: To ensure ongoing compliance with HUD guidelines and regulations, Olycap has implemented automatic and recurring monthly transfers of $575.17 from the South 7 operating account to the Replacement Reserves account, in accordance with HUD requirements. This measure is designed to ...
Management Response: To ensure ongoing compliance with HUD guidelines and regulations, Olycap has implemented automatic and recurring monthly transfers of $575.17 from the South 7 operating account to the Replacement Reserves account, in accordance with HUD requirements. This measure is designed to prevent missing deposits and maintain financial integrity. Regarding prior withdrawals, these were discussed with Olycap’s HUD representative, who verbally acknowledged and approved the expenditures post-factum. The withdrawals were made to fund critical repairs, including sidewalk restoration and roof replacements across the property. Moving forward, Olycap will obtain formal HUD approval prior to initiating any future Reserve account withdrawals. Additionally, Olycap has reinforced its internal control framework and conducted targeted training for new personnel to support compliance and operational consistency. Anticipated Completion Date: Ongoing and complete. Responsible officials: Karen Bondurant Holly Morgan
In accordance with HUD requirements, the Authority plans to begin drawing down operating-subsidy funds on a monthly basis. The Executive Director and Board will continue to review monthly financial statements prepared by the accountants and will research and evaluate potential investment options to ...
In accordance with HUD requirements, the Authority plans to begin drawing down operating-subsidy funds on a monthly basis. The Executive Director and Board will continue to review monthly financial statements prepared by the accountants and will research and evaluate potential investment options to increase the return on available funds. The Authority intends to develop and adopt formal written procedures for cash management and investment monitoring during the next fiscal year.
Action Taken: Management acknowledges the findings and the significant deficiency in internal control. We accept responsibility for the deficiencies in internal control over payroll reporting and are committed to implementing corrective actions as follows to ensure a robust control environment that ...
Action Taken: Management acknowledges the findings and the significant deficiency in internal control. We accept responsibility for the deficiencies in internal control over payroll reporting and are committed to implementing corrective actions as follows to ensure a robust control environment that ensures payroll transactions are verified against authorized documentation. • Comprehensive File Reviews: We have immediately begun reviewing all current employee payroll files to confirm that they are complete. • Verify Documentation: We have immediately begun ensuring each employee file contains proper documentation for initial pay rates, compensation changes, and job descriptions and offer letters, where applicable. The Authority has implemented a checks and balances review process to ensure that time is entered accurately, reviewed and signed on by the employee and the employee's supervisor, and then Authority leadership also conducts a pre-payroll audit. • Internal Controls: The Authority currently uses a third-party, Paycom, to manage its payroll functions and for recordkeeping purposes. Timesheets are entered and approved electronically in the system. Pre-payroll audits are conducted by the CEO and COO, prior to payroll being approved for payment. With the current electronic record keeping system, payroll documents are securely stored, easily searchable, and traceable. • Ongoing Compliance: The HR Directorwill conduct semi-annual internal audits of a sample of employee files to confirm and document ongoing compliance. In addition, staff who input and review payroll will receive ongoing compliance training and file documentation. Name of Responsible Person: Catherine Lamberg, CEO and Jackie Otto COO, and Natalie Hawks. HR Director Projected Completion Date: Some of the corrective activities are underway. We anticipate completing these activities by March 1, 2026.
Action Taken: Management acknowledges the findings and the material weakness in internal control and material noncompliance in procurement. We accept responsibility for the deficiencies in internal control over procurement and are committed to implementing corrective actions that address missing doc...
Action Taken: Management acknowledges the findings and the material weakness in internal control and material noncompliance in procurement. We accept responsibility for the deficiencies in internal control over procurement and are committed to implementing corrective actions that address missing documentation and lack of verifiable procurement procedures to ensure compliance. • Implement Standardized Procurement Procedures: Update and implement a forma', written procurement policy that clearly outlines the procedures for sealed bids, proposals, and small purchases. • Mandatory Documentation Checklist: Create a procurement file checklist for every contract to ensure all required documents—such as the independent cost estimate, advertisement, bidder list, evaluations, and justification for award—are included in the procurement file. • Supervisory Review Process: A supervisor will review and sign off on the procurement file checklist before a contract is executed. • Staff Training: Provide comprehensive training to all staff involved in procurement to ensure they understand H U D's procurement standards, including requirements forf ull and open competition and proper record-keeping. • Maintain Records: Ensure that all documentation for the full procurement cycle is maintained, including evidence that contractors are not debarred or suspended. Name of Responsible Person: Catherine Lamberg, CEO and Jackie Otto, COO, and Natalie Hawks, Procurement Director Projected Completion Date: Some of the corrective activities are underway. We anticipate completing these activities by May 1, 2026.
Action Taken: Management acknowledges the findings and the material weakness in internal control and material noncompliance in SEMAP reporting. We accept responsibility for the deficiencies in internal control over SEMAP reporting and are committed to implementing corrective actions that address mis...
Action Taken: Management acknowledges the findings and the material weakness in internal control and material noncompliance in SEMAP reporting. We accept responsibility for the deficiencies in internal control over SEMAP reporting and are committed to implementing corrective actions that address missing self-certification documentalion to ensure compliance. The Authority must take immediate steps to remediate these deficiencies by establishing a robust, auditable documentation process: • Strengthen Internal Controls: Develop procedures to ensure complete and accurate documentation is maintained for all 14 SEMAP indicators, including detailed sampling methodologies. • Pre-Certification Review: Implement a mandatory management review process for all SEMAP documentation before final certification is submitted to HUD. • Ensure Proper Retention: Enforce document retention policies that align with HUD regulations, ensuring records are accessible for audit purposes. • Staff Training: Provide training to staff regarding SEMAP indicator requirements and the necessity of maintaining supporting evidence. • Utilize PIG Reports: Ensure all tenant data is properly reported in PlC, as this is the basis for several indicators. Name of Responsible Person: Catherine Lamberg, CEO, and Jackie Otto, COO, and Daporsha Abernathy, HCVP Director Projected Completion Date: Most of the corrective activities are completed. We anticipate completing the balance of activities by May 1, 2026.
Action Taken: Management acknowledges the findings and the material weakness in internal control and material noncompliance in its waiting list management. We accept responsibility for the deficiencies in internal control over the waiting list and are committed to implementing corrective actions tha...
Action Taken: Management acknowledges the findings and the material weakness in internal control and material noncompliance in its waiting list management. We accept responsibility for the deficiencies in internal control over the waiting list and are committed to implementing corrective actions that address missing documentation and lack of transparency in following the Authority's Administrative Plan and HUD guidelines when selecting applicants from its waiting list. Immediate corrective actions include: • Only using the electronic records of applicants from the Authority's housing software and not creating external waiting lists. • Reconcile and Reconstruct: Immediately reconcile the waiting list and reconstruct missing documentation for voucher issuance. • Cleanup Waiting List: The Authority's waiting list is closed, and staff are currently working to purge it. • Update Procedures: Ensure staff know and are trained on waiting list procedures to ensure compliance with HUD regulations and the Authority's Administrative Plan. • Implement Controls: Establish a periodic supervisory review to verify document completeness during the voucher issuance process. • Training: Provide staff with ongoing training on proper, consistent, and compliant wailing list administration. • Retention: Ensure all records are maintained according to federal retention requirements. Name of Responsible Person: Catherine Lamberg, CEO, and Jackie Otto, COO, and Daporsha Abernathy, HCVP Director Projected Completion Date: Some of the corrective activities are underway. We anticipate completing these activities by June 1, 2026.
Action Taken: Management acknowledges the findings and the material weakness in internal control and material noncompliance in allowability and eligibility. We accept responsibility for the deficiencies in internal control over allowability and eligibility and are committed to implementing correctiv...
Action Taken: Management acknowledges the findings and the material weakness in internal control and material noncompliance in allowability and eligibility. We accept responsibility for the deficiencies in internal control over allowability and eligibility and are committed to implementing corrective actions that address missing documentation and lack of verifiable procurement procedures to ensure compliance. • Immediate File Correction & Review: Correct all identified deficiencies in the sampled files. Furthermore, a 100% review of the remaining -335 files must be conducted to identify if these errors are systematic [1.1]. • Repayment and Re-calculation: For files with incorrect income, utility allowance, or payment standards, the Authority must recalculate the Housing Assistance Payments (HAP) and determine if repayments to HUD are necessary. • Strengthen Internal Controls: • Implement a File Checklist: Require a mandatory, signed checklist for all new admissions and annual recertifications to ensure all 214 forms, 9886 forms, income verifications, and ID documentation are present. • Supervisory Review: Implement a mandatory, independent supervisory review of a percentage of files before HAP payments are authorized. • Inspection Tracking System: Utilize automated tools to track HQS inspection dates to prevent late or missed inspections. • Training: Provide staff training on HUD eligibility, income verification, and rent calculation procedures, specifically focusing on the requirements in 24 CFR Part 5. Name of Responsible Person: Catherine Lamberg, CEO, and Jackie Otto, COO, and Daporsha Abernathy, HCVP Director Projected Completion Date: Some of the corrective activities are underway. We anticipate completing these activities by June 1, 2026.
Concord’s Compliance Dept has implemented procedures to ensure the tenant security deposits are correctly recorded, tenant eligibility is correctly determined and that the tenant lease files are properly maintained in accordance with HUD’s requirements.
Concord’s Compliance Dept has implemented procedures to ensure the tenant security deposits are correctly recorded, tenant eligibility is correctly determined and that the tenant lease files are properly maintained in accordance with HUD’s requirements.
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