Corrective Action Plans

CORRECTIVE ACTION PLAN Breakthrough Phase III, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2022. Purkey, Carter, Compton, Swann, & Carter, PLLC PO. Box 727 Morristown, Tennessee 37815 Audit period: July 1, 2021 ?June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section A of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS ? FINANCIAL STATEMENT AUDIT None FINDINGS ? FEDERAL AWARD PROGRAMS AUDITS FINDING N0. 2022-001: Ineffective operation of internal controls by management Management did not conduct recertifications of the Project?s tenants during the ?scal year under audit. Criteria: According to the HUD Handbook 4350.3, owners must conduct a recertification of family income and composition at least annually by the tenant?s recertification anniversary date. Owners must then recompute the tenants? rents and assistance payments, if applicable, based on the information gathered. If a new recertification is not submitted within 15 months of the previous year?s recertification anniversary date, HUD will terminate assistance payments. Cause of Condition: Management had difficulties setting up the OneSite Leasing software in order to conduct the recertifications in a timely manner. Recommendation: Auditor recommends management review HUD Handbook 4350.3 and put proper internal controls in place to ensure recertifications are completed as required by HUD. Action Taken: Personnel at Breakthrough Corporation that are handling the operations of the Project have gone through HUD?related training. The Board is working closely with Breakthrough Corporation to ensure the Project is complying with HUD requirements and completing training annually to stay up to date with HUD compliance. The difficulties with the leasing software has been resolved and recertifications have been completed after year end.

CORRECTIVE ACTION PLAN Finding No. 2022-01: Surplus Cash existing at December 31, 2021 was not deposited into a separate residual receipts account. Recommendation: Management should deposit the amount or request HUD's approval for a waiver. Action Taken or Planned: Due to pending cash requirements, we requested HUD's approval to waive the deposit requirement, however an answer was not obtained. We will again seek w waiver for the current year and, if not approved, we will follow the HUD Account Executive?s instructions on how to resolve the matter. Responsible Person: James Watt, Senior Vice President, Management Company Completion Date: July 31, 2023

Finding Reference Number: 2022-002 Concur or Do Not Concur: Concur Agree or Disagree with Auditor Recommendations: Agree Actions Taken or Planned on the Finding: Management agrees with the finding. The residual receipts account deficiency will be funded in the amount of $25,122. Management will ensure that the residual receipts account is properly funded in the future. Completion Date: August 31, 2022

Corrective Action Plan Haven Towers Development Corporation For the Year Ended June 30, 2022 Haven Towers Development Corporation respectfully submits the following Corrective Action Plan for the year ended June 30, 2022. Name and address of the independent public accounting firm who conducted the related audit: Comer, Nowling And Associates, P.C. 10475 Crosspoint Boulevard, Suite 200 Indianapolis, Indiana 46256 Finding 2022-001 Corrective Action Planned ? Management will provide the auditors with all audit documentation in a matter timely enough to complete the audit fieldwork and file the audit in the REAC system within 90 days of year-end. Contact Person(s) Responsible ? Jim Beemster, Controller Anticipated Completion Date ? January 17, 2023 Auditee Disagreements ? Management maintains the request for documentation was not received with enough time to turn around the documents. This corrective action plan was prepared by Evergreen Real Estate Services, the management company, on behalf of Haven Towers Development Corporation. __________________________ _____________________ Jim Beemster, Controller Date Evergreen Real Estate Services 566 West Lake Street, Suite 400 Chicago, IL 60661 312-234-9400

Condition: The audited financial statements, reports and supplemental information for the year ended December 31, 2021 were not submitted to the REAC within 90 days of the Corporation?s fiscal year end, and was not submitted to the Federal Audit Clearinghouse within nine months of the fiscal year end. Recommendation: Gethsemane Manor Apartments should implement controls to ensure necessary information is available for timely completion of the audit and submission of the audited financial statements to the REAC and the Federal Audit Clearinghouse within the required timeframe. Action Taken: Management of Gethsemane Manor Apartments will make every effort going forward to ensure timely submission to the REAC and Federal Audit Clearinghouse within the required timeframe.

Statement of Condition 2022-001 (Assistance Listing No. 14.155): The Corporation did not make the required surplus cash deposit computed at March 31, 2021, in the amount of $12,264 within 90 days of fiscal year end. Recommendation: Management should implement a system to ensure the required deposit to the residual receipts is made within 90 days of fiscal year end. Action(s) taken or planned on the finding: Agreed. Management concurs with the finding and the auditor's recommendation. The Corporation made the required surplus cash deposit on August 3, 2022.

Views of Responsible Officials: RFE/RL Management fully agrees on the need to ensure our policies and procedures demonstrate adherence to the requirements of the Patriot Act. The process for new employee screening will be reviewed and modified to ensure documented compliance. New vendor and contractor screening is conducted and now fully documented during the initial procurement/contracting process in our Prague office. Additionally, RFE/RL has implemented a process for regular, automated Office of Foreign Asset Control (OFAC) screening of all vendors in FY23. A similar process for regular, automated System Award Management (SAM) screening is in process. Once implemented, these systems will ensure that all vendors on RFE/RL?s supplier list will be reviewed annually.

2022-004 Project Rental Assistance Payment Adjustments Not Made Timely Recommendation Develop policies to identify changes in tenant vacancies and make timely adjustments. Action Taken We concur with the recommendation and will implement the recommendation immediately.

2022-003 Required Deposit Into a Replacement Reserve Account Not Made Recommendation We recommend that a deposit of $2,958 be made into the replacement reserve account in order for South Fulton Homes, Inc. to be in compliance with HUD regulations. Action Taken We concur with the recommendation. The Organization made a $2,958 deposit in October 2022 to the replacement reserve account to correct this deficiency.

2022-002 Internal Controls Over Financial Reporting Recommendation We recommend documents are signed via mail or electronically if in person contact is not available. Action Taken We concur with the finding and will implement the recommendation immediately.

Trinity Manor Senior Non-Profit Corporation respectfully submits the following corrective action plan for the year ended December 31, 2022. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit Period: Year ended December 31, 2022 Corporation Contact Person: Shannon Hilbrecht, Accounting Manager at the Management Agent The findings from the December 31, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding ? Federal Award Findings and Questioned Costs Finding 2022-001: Considered a significant deficiency in internal control over compliance. Recommendation: The Corporation should pay back the $18,000 with a deposit to the replacement reserve account. Action to be Taken: The Corporation concurs with the facts of this finding, has already paid back the $18,000 to the replacement reserve account during 2023, and is implementing procedures to prevent this in the future.

Corrective Action Plan For the year ended March 31, 2022 U.S. Department of Housing and Urban Development: The Housing Authority of the City of Paterson respectfully submits the following corrective action plan for the year ended March 31, 2022. Auditor: Novogradac and Company, LLP Certified Public Accountants 1144 Hooper Avenue Suite 203 Toms River, New Jersey 08753 The findings from the March 31, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Financial Statement Findings Reference 2022-001: Criteria: In accordance with N.J.S.A. 46:30B and the Uniform Unclaimed Property Act of the State of New Jersey, all property, including any income or increment derived there from, less any lawful charges, whether located in this state or another state, that is held, issued, owing in the ordinary course of a holder's business and has remained unclaimed by the owner for more than three years after it became payable or distributable is presumed abandoned, and is subject to custody of the state as unclaimed property. Additionally, HUD requires PHA?s to conform to state escheatment laws related to unclaimed tenant utility reimbursements. Condition: The Authority has unclaimed property in stale dated checks that meet that State?s definition. Reference 2022-001 (continued) Context: During our audit, we noted several checks that were either outstanding for greater than a three-year period or determined to be stale dated by management. These checks were made up of housing assistance payments and utility reimbursements, and were recorded as a liability in the Section 8 Housing Choice Vouchers Program. HUD?s regulations require the Authority to follow the State?s escheat laws, which would require the Authority to ultimately consider these checks as unclaimed property, and turn them over to the State Treasurer. Known Questioned Costs: N/A Cause: The Authority did not properly consider state and federal regulations related to unclaimed property. Effect: Due to the stale dated checks being outstanding for greater than a three-year period, they are to be considered unclaimed property in the State of New Jersey. The Authority did not properly identify these outstanding checks as unclaimed property, or follow the proper reporting requirements of the State of New Jersey. Additionally, no stale dated checks were escheated to the State. Recommendation: The Authority should draft and adopt a method of complying with reporting requirements related to unclaimed property in accordance with the State of New Jersey Statutes. Authority Response: The Authority accepts the recommendation of the auditor and has made arrangements to comply with the State of New Jersey Statutes. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor and has made arrangements to comply with the State of New Jersey Statutes. Irma Gorham is responsible to remedy the deficiency by March 31, 2023. Federal Award Findings and Questioned Costs Finding 2022-002: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Catalog Numbers: 14.871 Noncompliance ? E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: No Significant deficiency in Internal Control over Compliance for Eligibility 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). Finding 2022-002 (continued): Condition: Based upon inspection of the Authority?s files and on discussions with management there were documents that were unavailable for examination at the time of audit. Context: Of a sample size of thirty-six (36) tenant files, the following information was unavailable for examination at the time of audit: ? Verification of income and assets was missing in one (1) file Our sample size is statistically valid. Known Questioned Costs: $11,054 Cause: There is a significant deficiency in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered and designed a system of internal controls that reasonably assures the program is in compliance. 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. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Authority Response: We agree with the Auditor?s observations on the inspection of the tenant files and will implement internal control procedures that will assure tenant file compliance. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor on the inspection of tenant files and has made arrangements to comply with the Section 8 Housing Choice Vouchers Program. Irma Gorham is responsible to remedy the deficiency by March 31, 2023. Schedule of Prior Year Audit Findings Reference 2021-001: Observation: During our audit, we noted several checks that were either outstanding for greater than a three-year period or determined to be stale dated by management. These checks were made up of housing assistance payments and utility reimbursements, and were recorded as a liability in the Section 8 Housing Choice Vouchers Program. HUD?s regulations require the Authority to follow the State?s escheat laws, which would require the Authority to ultimately consider these checks as unclaimed property and turn them over to the State Treasurer. Reference 2021-001 (continued): Status: The finding remains open. See Finding 2022-001 above. Sincerely yours, Irma Gorham Executive Director

U.S Department of Housing and Urban Development 2022-003 Housing Choice Voucher Program ? Assistance Listing No. 14.871 Recommendation: We recommend the Authority review their process for maintaining 3rd party verification of income, for uploading data to PIC, and for generating HAP amendment letters. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Create a third party verification policy and procedure SOP. Name(s) of the contact person(s) responsible for corrective action: Doryan Campo Planned completion date for corrective action plan: April 2023

U.S Department of Housing and Urban Development 2022-002 Housing Choice Voucher Program ? Assistance Listing No. 14.871 Recommendation: We recommend the Authority review their processes for maintaining documentation for tenant selection from the waiting list. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Create a waiting list management SOP. Name(s) of the contact person(s) responsible for corrective action: Aida Nu?ez Planned completion date for corrective action plan: April 2023

U.S Department of Housing and Urban Development 2022-001 Housing Choice Voucher Program ? Assistance Listing No. 14.871 Recommendation: We recommend the Authority review their procedures for performing QC inspections in a timely manner. Explanation of disagreement with audit finding: The Housing Authority disagrees with the finding. We employ a third party vendor to conduct QC inspections. Due to the Pandemic we were unable to secure a vendor without a backlog. Additionally, the HA had a waiver. Action taken in response to finding: To avoid future backlogs secure vendor several month in advance. Name(s) of the contact person(s) responsible for corrective action: Aida Nu?ez Planned completion date for corrective action plan: September, 2023

U.S. Department of Housing and Urban Development 2022-001: Section 8 Housing Assistance Payments Program ? Assistance Listing No. 14.195 Recommendation: Management should review its internal control procedures to ensure proper oversight over the payroll disbursement process surrounding earned time payouts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Upon realization of the overpayment, Human Resource (HR) and Payroll have developed a new process where the hourly rates are to be verified and validated prior to the processing of an earned time payout. This process is for all employees that remain employed but are no longer eligible to accrue earned time, thus requiring their earned time to be paid out. On the bi-weekly HR changes worksheet, HR will denote what the hourly rate should be upon pay out of the earned time. Payroll will then cross-check the hourly rate and the earned time hours prior to processing payroll. Name(s) of the contact person(s) responsible for corrective action: Jonathan Allia, Vice President of Finance Planned completion date for corrective action plan: August 1, 2022 If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Jonathan Allia, Vice President of Finance at 617-971-5762.

2022-001- Noncompliance regarding Reporting ALN #93.498 Provider Relief Funds U.S. Department of Health & Human Services As soon as I was aware of the mistake that was made for the Single Federal Audit for Phase @ & 3 of the CARES Act funding, it was evident that I used amounts that was in a FY instead of CY financials. The program we use, Share Point for billing and receipts automatically defaults to FY which again, was incorrect. This went through 4 different hands and did not get noticed before reporting. I immediately contacted HRSA Provider Relief Support to report the incorrect information and to see if I could revise my reporting. Unfortunately, that can't be done. One the deadline for reporting takes place, it is then locked and cannot be retrieved. I asked if there was anything I could do and her reply was to keep the corrections with what I reported in case I was to be audited. Ongoing reporting will be confirmed for the correct time frames as required.

Finding No. 2022-003: Eligibility (Significant Deficiency - Internal Control Over Compliance) Audit Recommendation: We recommend the City be more diligent in following its policies and procedures for tracking, documenting and performing HQS inspections and taking appropriate action timely when an owner fails to correct HQS deficiencies identified. Administration?s Comments: The City will follow policies and procedures to ensure tracking, documenting and performing HQS inspections and timely appropriate actions are taken when owner fails to correct HQS deficiencies. Anticipated Completion Date: Effective immediately (March 2023)

Finding No. 2022-002: Subrecipient Monitoring (Significant Deficiency - Internal Control Over Compliance) Audit Recommendation: Management should create policies and procedures to ensure required monitoring procedures are performed and completed timely. Administration?s Comment: The City will adhere to policies and procedures for the timely performance of required monitoring, including the review and issuance of monitoring reports. The City will prepare a schedule for targeted monitoring and comprehensively track these projects. The City acknowledges that the finding was caused in part by the aforementioned staffing-related issues which the City has attempted to address and will continue to attempt to address by filling the vacant positions responsible for monitoring. Anticipated Completion Date: June 2023 (for the monitoring related issues including issuance of reports). Ongoing (until the Post Development Monitoring Section is fully staffed)

Finding 2022-003 ? Lack of Data Available to Audit the Federal Compliance Requirements Applicable to the Section 8 Housing Choice Program (Material Weakness, Potential Material Noncompliance) Section 8 Housing Choice Voucher Program ? Assistance Listing No. 14.871; Grant period ? fiscal year ended March 31, 2022 Corrective Action The Commission will maintain, and make available for audit, data applicable to the Section 8 Housing Choice Voucher Program compliance requirements. Laurie Ingram, Executive Director, has assumed the responsibility of maintaining and making available for audit, data applicable to the Section 8 Housing Choice Voucher Program compliance requirements and expects the deficiencies which led to this Finding to be resolved by February 28, 2023.

Finding 2022-002 ? Lack of Data Available to Audit the Federal Compliance Requirements Applicable to the Public Housing Program (Material Weakness, Potential Material Noncompliance) Public Housing Program ? Assistance Listing No. 14.850a; Grant period ? fiscal year ended March 31, 2022 Corrective action The Commission will maintain, and make available for audit, data applicable to the Public Housing Program compliance requirements. Laurie Ingram, Executive Director, has assumed the responsibility of maintaining and making available for audit, data applicable to the Public Housing Program compliance requirements and expects the deficiencies which led to this Finding to be resolved by February 28, 2023.

The Housing Authority's Executive Director will start randomly pulling files to double check the calculations and make sure EIV reports/Income match.

Finding 2022-001- Housing Choice Voucher Tenant Files - Eligibility- Internal Control over Tenant Files - Noncompliance and Significant Deficiency Housing Choice Voucher Program CFDA #14.871 Corrective Action Plan: 1) SCCHA will arrange for a thorough tenant file audit of existing HCVP files to determine whether there is a significant Incident of incorrect income projections and/or tenant rent calculations. The Initial audit will entail 230 HCVP files randomly sampled (approximately 10% of the program.) The file audit process will continue to include more randomly selected files as Indicated by the results of the initial audit. 2) SCCHA will Increase monitoring and review of HCVP files to increase accuracy and ensure compliance with regulatory and statutory requirements related to income projection and rent determinations. 3) Any staff members with rent calculation certifications older than ten years will be required to attend HCVP rent calculation training and pass the corresponding certification exam. Anticipated Completion Date: 1) Within six months; 2) Initiated within 60 days and on-going thereafter; 3) Within twelve months depending on third-party trainer availability Persons Responsible: Larry McLean, Executive Director; Pam Jackson, HCV Program Director; and Shanae Golliday, Program Integrity & Compliance Coordinator

St. Peter's Housing, Inc. Winston-Salem, NC CORRECTIVE ACTION PLAN February 16, 2023 U.S. Department of Housing and Urban Development Atlanta Regional Office Five Points Plaza Building 40 Marietta Street Atlanta, GA 30303 St. Peter's Housing, Inc. respectfully submits the following Corrective Action Plan for the year ended December 31, 2022. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Post Office Box 19608 Greensboro, North Carolina 27419-9608 Audit period: Year Ended December 31, 2022 The finding for the year ended December 31, 2022 Schedule of Findings and Questioned Costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Findings and Questioned Costs: Finding 2022-001: U.S. Department of Housing and Urban Development, Supportive Housing for the Elderly, Assistance Listing #14.157 Recommendation: We recommend that management should continuously monitor cash balances to ensure that funds are always covered by FDIC insurance limits, collateral agreements are obtained, or funds are invested in government securities. Action Taken: We agree with Finding 2022-001 described in the accompanying schedule of findings and questioned costs. Management will transfer funds to provide adequate FDIC insurance coverage for all funds. Additionally, management will re-evaluate its policies and procedures to determine any necessary changes. If HUD has questions regarding this corrective action plan, please call (336) 765-0424. Sincerely yours, Laura Grimes Accounting Manager Community Management Corporation Managing Agent

Recommendation: In conjunction with The Shire, Inc. and their local HUD field office, it was determined that the related party should invoice the Organization for project expenses on a monthly basis. In turn,The Shire, Inc. should pay the invoice amount on a monthly basis. Action Taken: The auditors have worked with the auditee in conjunction with their local HUD field office to determine a course of action. All parties agreed with the recommendation to avoid unauthorized distributions.