Corrective Action Plans

2024-004 ALN 14.850 – Public Housing Operating Fund – Special Test – Depository Agreements Current management acknowledges the finding and is following the auditor’s recommendations. Person Responsible for Correction of Finding: Froncello Bumpass, Interim Executive Director Anticipated Completion Date: December 31, 2025

2024-003 ALN 14.850 – Public Housing Operating Fund - Eligibility Current management acknowledges the finding and is following the auditor’s recommendations. Person Responsible for Correction of Finding: Froncello Bumpass, Interim Executive Director Anticipated Completion Date: December 31, 2025

Name of Auditee: Amsterdam Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: December 31, 2024 CAP Prepared by: Damaris Carbone, Executive Director Phone: (518) 842-2894 (A) Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (3) Finding 2024-003 (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendation. Please see below for additional comments and action taken. (b) Action taken - The Authority will establish internal tracking and reminder systems to ensure all required reports, including the final P&E and AMCC, are completed and submitted to HUD by the required due dates. Grant reporting responsibilities will be clearly assigned, and submission deadlines will be monitored by the Director of Finance to prevent future delays. These procedures will be implemented immediately. (c) Planned implementation date - The Authority plans to implement procedures during the year ending December 31, 2025 to resolve the reported finding.

Name of Auditee: Amsterdam Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: December 31, 2024 CAP Prepared by: Damaris Carbone, Executive Director Phone: (518) 842-2894 (A) Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (4) Finding 2024-004 (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendation. Please see below for additional comments and action taken. (b) Action taken - The Authority will strengthen procedures to ensure all interfund accounts are reconciled and settled monthly before completing the HUD-52681-B report. Accounting staff will review and verify key line items (including Unrestricted Net Position and Cash in Investments) against the general ledger prior to VMS submission. Supervisory review will be required to confirm accuracy. (c) Planned implementation date - The Authority plans to implement procedures during the year ending December 31, 2025 to resolve the reported finding.

Finding #2024-001- Limited Segregation of Duties Criteria: Segregation of duties is an aspect of internal control intended to prevent or decrease opportunities of intentional and unintentional errors and fraud. Duties and responsibilities are properly segregated if no single individual either has control over all phases of a transaction or can both make and conceal an error, whether such error is intentional or unintentional. Condition: A properly designed system of internal control includes adequate staffing, policies, and procedures to properly segregate duties. All internal control duties can be classified into four broad categories: authorization, custody, recordkeeping, and reconciliation. No one person should have control of two or more of these four categories for any one cycle. There are key controls related to significant transaction cycles that are important in reducing the risk of errors or irregularities. Currently, there are the following overlapping duties: - Both Accounting Specialists have the authority to enter invoices into the system, print checks, and have access to the electronic signatures. Preferably, the check cutting process would separate the entering of payment information into the system and the ability to print signed checks. - One Accounting Specialist creates deposits and makes deposits with the bank. Although not the standard procedure, the Accounting Specialist has the authority to collect cash receipts. Ideally, separate individuals would collect cash and make deposits. - The Housing Authority Executive Director opens the mail, creates deposits and takes deposits to the bank. The Executive Director also enters invoices into the system and prints checks. The Board of Commissioners approves disbursements and all checks require dual signatures. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities because of the lack of segregation of duties. Cause: Limited number of personnel. Recommendation: We recommend that the City consider the benefits of implementing additional policies and procedures to address key controls related to its significant transaction cycles as noted. Response: We agree with this finding but do not believe it is cost effective to increase personnel to bring about a more effective segregation of duties.

2024-002 Condition: Deficiencies Noted in Cash Disbursements Steps to resolve: Management agrees with the audit finding and the auditor’s recommendation. We will review the cash disbursement documentation process in order to ensure that each disbursement is fully documented prior to check issuance. We will further review our internal control procedures and policies over cash disbursements and conduct regular quality control reviews to ensure compliance with HUD regulations. We will implement any needed procedures and changes to ensure that this finding will be cleared by the subsequent fiscal year audit. Individual responsible for correction: Ms. Linda Dillard, Executive Director Timeframe: As of December 31, 2025

Name of auditee: THF San Gabriel Holdings, LLC HUD auditee identification number: 115-11319 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2024 CAP prepared by Name: Allison Milliorn Position: Chief Executive Officer Telephone number: 830-693-8100 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Finding 2024-001: Comments on the Finding and Each Recommendation: For the year ended December 31, 2023, the Company did not submit the Data Collection Form (SF-SAC) to the Federal Audit Clearinghouse in the time period required by Uniform Guidance Section 2 CFR 200.512. Action(s) taken or planned on the finding: The Data Collection Form was submitted to the Federal Audit Clearinghouse on May 10, 2024 and management will submit the Data Collection Form timely going forward.

Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend the Authority implements controls to ensure all files are maintained and available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HAKC will take the necessary steps to ensure files are placed back in the file room and are available upon request with the required documentation placed in the file. HAKC will complete the initial process and complete ongoing compliance reviews. Name(s) of the contact person(s) responsible for corrective action: Lisa Earnest, Director of Housing Choice Voucher Program Planned completion date for corrective action plan: 7/31/2026

Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend the Authority implements controls to ensure the HAP agrees between the HUD-50058, HAP contract, and HAP register. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HAKC will take the necessary steps to ensure the HUD-50058 matches the HAP contract and the HAP register by reviewing the accuracy of HAP amount, coordinate general HAP processing controls, (segregating duties to mitigate the threat of fraud or theft), and monitoring files on a monthly basis. HAKC will complete the initial process and complete ongoing compliance reviews. Name(s) of the contact person(s) responsible for corrective action: Lisa Earnest, Director of Housing Choice Voucher Program Planned completion date for corrective action plan: 3/31/2026

Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend that the Authority implements controls to ensure that documentation is maintained in accordance with rent reasonableness requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HAKC will audit files for the correct methodology used in determining rents and ensure rents are reasonable on a monthly basis. In addition, HAKC has contracted a QC audit to review 100% of the files. HAKC will complete the initial process and complete ongoing compliance reviews. Name(s) of the contact person(s) responsible for corrective action: Lisa Earnest, Director of Housing Choice Voucher Program Planned completion date for corrective action plan: 12/31/2026

Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend that the Authority implements controls to ensure HUD-50058 recertifications are uploaded to PIC. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HAKC will monitor the monthly SEMAP Indicator report and monitor the PIC dashboard to ensure all 50058 errors are corrected and uploaded in a timely manner. HAKC will also pull the ADHOC from PIC to verify the records. HAKC will continue working with the HUD PIC coach monthly to correct all errors. HAKC will complete the initial process and complete ongoing compliance reviews. Name(s) of the contact person(s) responsible for corrective action: Lisa Earnest, Director of Housing Choice Voucher Program Planned completion date for corrective action plan: 4/30/2026

Finding Number 2024-004 SPECIAL PERFORMANCE – DEFICIENCY - COMPLIANCE Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.871– SECTION 8 HOUSING CHOICE VOUCHERS Contract # N/A Criteria Special Reporting - HUD-50058, Family Report (OMB No. 2577-0083) - The PHA is required to submit this form electronically to HUD each time the PHA completes an issuance, admission, annual reexamination, interim reexamination, portability move-in, expiration, or other change of unit for a family. The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA's jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Key Line items - The following line items contain critical information Line 2a - Type of Action Line 2b - Effective Date of Action Line 3b, 3c – Names Line 3e - Date of Birth Line 3n - Social Security Numbers Line 5a - Unit Address Line 5h, 5i - Unit inspection Dates Line 7i - Total Annual income Lines 2k and 17a - Family's Participation in the Family Self Sufficiency (FSS) Program Line 17k (2) - FSS Account Balance Condition/Context The Authority received funding from the HUD. The Authority is required to submit HUD-50058 each time the PHA completes an issuance, admission, annual reexamination, interim .reexamination, portability move-in, expiration, or other change of unit for a family. Of the sixty (60) case files selected for testing in which 540 pieces of audit evidence (Special reporting forms as noted in the Criteria section above) were requested to be provided: • Eight documents related to HUD-50058 forms were not provided (One missing verification of Names; Three missing verification of Date of Birth; and Four missing Verification of Social Security. These forms are considered critical information for HUD -50058 forms. This documents are required documentation to be maintained in the case files to support HUD-50058 form for Section 8 Housing Choice Voucher Program. Therefore, we were not able to determine if the critical information in HUD-50058 form are supported by supporting documentation. Recommendation We recommend the Authority strengthen its controls over the Section 8 Housing Choice Voucher Program HUD-50058 form to ensure that all supporting documentation for HUD-50058 form are received, reviewed, and maintained to support HUD -50058 form. Corrective Action Plan There are some missing documentations pertaining to eligibility and admission in files for households admitted prior to 2011. Such documentation, which includes the application, vital documents, lease, and request for tenancy approval, is aged beyond 20 years for some cases and is not retrievable as part of a 2010 backfile conversion. This was noted as a condition in a previous Single Audit. Part III of the Schedule of Findings and Questioned Costs for Federal Awards year ending December 31, 2010, cited the condition as “For two of our selections, the Authority was not able to locate the tenant file containing the required documentation that the authority had obtained to verify income eligibility. Because the tenant file was not available, the authority was not able to provide all of the documents needed to test eligibility such as tenant applications, third party income verifications, or lease agreements.” NYCHA's response to that audit conveyed our confidence in the business improvement initiatives completed to streamline the document management process. As NYCHA noted in response to the 2010 audit: the backfile conversion process was part of a large-scale, multi-year implementation of a new computer system that went live in 2011, during which over 15 million documents were converted to electronic files. New system improvements included forms tracking using the Intelligent Forms Processing (IFP) scanning technology. The IFP technology associates and saves scanned documents and documents completed by tenants electronically directly to the tenant case files in Siebel. The Siebel Customer Relationship Manager (CRM) System provides process standardization and solutions for document retention needs. In the current audit, there are 30 files that are reflective of our improved document management and retention; NYCHA has continued to make such improvements since 2011 and NYCHA remains committed to making our best efforts to ensure that all eligibility and admission documentation is maintained in the system of record. Action Date September 10, 2025 Final Implementation September 10, 2025 Name And Phone Number Of Person Responsible for Implementation Lakesha Miller Executive Vice President for Leased Housing Office of the Chief Executive Officer +1-212-306-8818

Finding Number 2024-003 ELIGIBILITY – SIGNIFICANT DEFICIENCY - COMPLIANCE Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.871– SECTION 8 HOUSING CHOICE VOUCHERS Contract # N/A Criteria Eligibility for Individuals - Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). The PHA must do the following: • As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). • For both family income examinations and reexaminations, obtain and document in the family file third party verification of (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income- based rent (24 CFRsection 982.516). Condition/Context The Authority received funding from the HUD. The Section 8 Housing Choice Voucher Program provides rental assistance to help very low- income families afford decent, safe, and sanitary rental housing. The Mainstream Voucher program enables families for whom the head, spouse, or co-head is a person with disabilities to lease affordable private housing of their choice. Of the sixty (60) case files selected for testing in which 600 pieces of audit evidence (eligibility forms as noted in the Criteria section above) were requested to be provided: • Thirty-three eligibility forms related to five cases, were not provided (Thirty-two missing application forms, and one missing third -party verification of reported family annual income form). These forms are required documentation to be maintained in the case files to support eligibility for Section 8 Housing Choice Voucher Program. Therefore, we were not able to determine if the eligible participants met all the eligibility criteria. Recommendation We recommend the Authority strengthen its controls over the Section 8 Housing Choice Voucher Program case files to ensure that all eligibility forms are received, reviewed, and maintained in the case files to support the determination of eligibility. Corrective Action Plan There are some missing documentations pertaining to eligibility and admission in files for households admitted prior to 2011. Such documentation, which includes the application, vital documents, lease, and request for tenancy approval, is aged beyond 20 years for some cases and is not retrievable as part of a 2010 backfile conversion. This was noted as a condition in a previous Single Audit. Part III of the Schedule of Findings and Questioned Costs for Federal Awards year ending December 31, 2010, cited the condition as “For two of our selections, the Authority was not able to locate the tenant file containing the required documentation that the authority had obtained to verify income eligibility. Because the tenant file was not available, the authority was not able to provide all of the documents needed to test eligibility such as tenant applications, third party income verifications, or lease agreements.” NYCHA's response to that audit conveyed our confidence in the business improvement initiatives completed to streamline the document management process. As NYCHA noted in response to the 2010 audit: the backfile conversion process was part of a large-scale, multi-year implementation of a new computer system that went live in 2011, during which over 15 million documents were converted to electronic files. New system improvements included forms tracking using the Intelligent Forms Processing (IFP) scanning technology. The IFP technology associates and saves scanned documents and documents completed by tenants electronically directly to the tenant case files in Siebel. The Siebel Customer Relationship Manager (CRM) System provides process standardization and solutions for document retention needs. In the current audit, there are 30 files that are reflective of our improved document management and retention; NYCHA has continued to make such improvements since 2011 and NYCHA remains committed to making our best efforts to ensure that all eligibility and admission documentation is maintained in the system of record. Action Date September 10, 2025 Final Implementation September 10, 2025 Name And Phone Number Of Person Responsible for Implementation Lakesha Miller Executive Vice President for Leased Housing Office of the Chief Executive Officer +1-212-306-8818

Finding Number 2024-002 ELIGIBILITY – DEFICIENCY - COMPLIANCE Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.850 – PUBLIC AND INDIAN HOUSING Contract # N/A Criteria Eligibility for Individuals - Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of household signs (a) a certification that the information provided to the PHA is correct; (b) one or more release forms to allow the PHA to get information from third parties; (c) a federally prescribed general release form for employment information; and (d) a privacy notice. Under some circumstances, other members of the family may be required to sign these forms (24 CFR sections 5.212, 5.230, and 5.601 through 5.615). Condition/Context The Authority received funding from the HUD. The Public and Indian Housing Program is to provide and operate cost effective, decent, safe, and affordable dwellings for lower income families through an authorized local PHA. Of the sixty (60) case files selected for testing in which 540 pieces of audit evidence (eligibility forms as noted in the Criteria section above) were requested to be provided: • Ten eligibility forms were not provided (Three missing application forms, two missing Federally prescribed general release form for employment information; two missing verification of income; two missing calculation of rent forms and one missing reexamine family income). These forms are required documentation to be maintained in the case files to support eligibility for Public and Indian Housing Program. Therefore, we were not able to determine if the eligible participants met all the eligibility criteria. Recommendation We recommend the Authority strengthen its controls over the Public and Indian Housing Program case files to ensure that all eligibility forms are received, reviewed, and maintained in the case files to support the determination of eligibility. Corrective Action Plan In January 2011, NYCHA implemented the Siebel Customer Relationship Management (CRM) system, which included digital file storage and an online application process, which replaced our previous paper application process. Any applications in process from that date onward were subject to document scanning and documentation was stored digitally. Any applications processed prior to this date were kept in a paper format and stored at the development, where the applicant was certified or where the tenant resides. If a tenant family transferred to another development, the physical tenant folder and documents were sent to their new location. In June 2020, NYCHA sought to digitize all tenant folders; however, the cost of the project was determined to be prohibitive so the goal of digitizing the tenant folders was not realized. Any documents damaged or lost prior to 2011 cannot be recovered, including those impacted by Hurricane Sandy. Action Date September 12, 2025 Final Implementation September 12, 2025 Name And Phone Number Of Person Responsible for Implementation Sylvia Aude Senior Vice president Office of the Senior Vice President for Public Housing Operations Tenancy Administration +1-212-306-3921

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.