Corrective Action Plans

Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. These misallocations occurred across multiple fiscal years. The costs were determined to be immaterial to the financial statements overall. Cause: Insufficient internal controls over transaction coding and allocation within the centralized operating account resulted in errors. Supervisory review was inconsistent, and periodic reconciliations were not performed at a level sufficient to detect and correct misallocations. Corrective Action Plan: Management acknowledges the finding and has taken steps to strengthen internal controls and ensure accurate project level reporting in accordance with HUD Handbook 4370.2. 1. Enhanced Supervisory Review Management has implemented a mandatory supervisory review and approval process for all postings from the centralized operating account. Updated procedures require documentation supporting allocation decisions and verification that expenses benefit the appropriate project. Implementation Status: Implemented January 2026; ongoing. 2. Periodic Reconciliations Supervisory review of transactions are now performed to confirm that expenses are charged to the correct project. A periodic cross project allocation review has been established to ensure consistency and compliance with HUD requirements. Implementation Status: Implemented January 2026; ongoing. 3. Correction of Prior Year Misallocations A detailed review of prior year postings is underway to identify misallocated expenses. Adjusting journal entries will be recorded during Fiscal Year 2026 to reclassify expenses to the appropriate projects. Implementation Status: In progress; expected completion during FY 2026. 4. Improvements to Allocation Methodology and Coding Controls The address based allocation logic that contributed to the errors has been corrected. System controls now require project specific coding at the point of entry. Staff have received updated training on proper allocation procedures and HUD requirements. Implementation Status: Completed December 2025; training ongoing. Anticipated Completion Date: All corrective actions will be fully implemented by the end of Fiscal Year 2026.

The Organization has made the necessary accounting adjustments for the year ended June 30, 2025 on the September 2025 voucher request.

Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. These misallocations occurred across multiple fiscal years. The costs were determined to be immaterial to the financial statements overall. Cause: Insufficient internal controls over transaction coding and allocation within the centralized operating account resulted in errors. Supervisory review was inconsistent, and periodic reconciliations were not performed at a level sufficient to detect and correct misallocations. Corrective Action Plan: Management acknowledges the finding and has taken steps to strengthen internal controls and ensure accurate project level reporting in accordance with HUD Handbook 4370.2. 1. Enhanced Supervisory Review Management has implemented a mandatory supervisory review and approval process for all postings from the centralized operating account. Updated procedures require documentation supporting allocation decisions and verification that expenses benefit the appropriate project. Implementation Status: Implemented January 2026; ongoing. 2. Periodic Reconciliations Supervisory review of transactions are now performed to confirm that expenses are charged to the correct project. A periodic cross project allocation review has been established to ensure consistency and compliance with HUD requirements. Implementation Status: Implemented January 2026; ongoing. 3. Correction of Prior Year Misallocations A detailed review of prior year postings is underway to identify misallocated expenses. Adjusting journal entries will be recorded during Fiscal Year 2026 to reclassify expenses to the appropriate projects. Implementation Status: In progress; expected completion during FY 2026. 4. Improvements to Allocation Methodology and Coding Controls The address based allocation logic that contributed to the errors has been corrected. System controls now require project specific coding at the point of entry. Staff have received updated training on proper allocation procedures and HUD requirements. Implementation Status: Completed December 2025; training ongoing. Anticipated Completion Date: All corrective actions will be fully implemented by the end of Fiscal Year 2026.

None provided.

Finding #2025-014 14.850 Public Housing Operating Fund Eligibility Views of Responsible Officials and Planned Corrective Action AMP 1 Response: We agree that it is essential for responsible personnel to enforce these monitoring controls effectively. Ensuring that staff obtain and properly document all necessary verification documentation before recertification is crucial for maintaining program integrity. In addition, supervisory personnel will perform periodic reviews to ensure that established procedures are consistently followed. Any deficiencies identified will be promptly corrected. AMP 1 Response to Noted Items • Item #1 - Criminal History/Sex Offender Registry Search We respectfully disagree with this finding. Documentation of the sex offender registry search was performed, verified, and included in the file. The documentation is attached to this response for your review. • Item #4 - EIV Report Timeliness We agree with the finding. The EIV report was processed six and four months late. We acknowledge this issue and will ensure the timely completion of this report. Staff will be reminded of the required timeframes for all certifications. • Item #8 - Declaration of Eligible Immigration Status We respectfully disagree with this finding. Documentation verifying the Head of Household's (HOH) eligible immigration status is included in the file. SAVE verification was conducted and documented at the time of admission to the program. The HOH is the only non-citizen in the household. The relevant documentation is attached for your review. • Item #11 - Independently Calculated Tenant Rent We respectfully disagree with this finding. After reviewing Form HUD-50058, we believe that the correct utility allowance for a 4-bedroom unit is ($498), and the corresponding tenant rent share is $43. These amounts differ from those mentioned in your summary. We have attached the source document for your review and confirmation. AMP 2 Response: We acknowledge the need to reinforce monitoring controls to ensure full compliance with eligibility and verification requirements. Effective immediately, staff will be required to obtain, review, and properly document all mandatory verification materials before completing any recertification of benefits. Recertifications will not be finalized unless the file contains complete and accurate documentation supporting the eligibility determination. In addition, Property Site Managers (PSMs) will conduct periodic quality control reviews to confirm that established procedures are consistently followed and that all required verification activities are fully documented. Any deficiencies identified during these reviews will be corrected promptly and addressed through additional training, procedural reinforcement, or other corrective measures, as appropriate. AMP 2 Responses to Noted Items • Item #5 – EIV Report Timeliness We agree with this finding. The EIV reports used to support income eligibility were processed six and four months late, respectively. We acknowledge this deficiency and will reinforce timeliness requirements with staff to ensure future compliance. Staff will be reminded that EIV reports must be obtained and reviewed within the required timeframe for all annual and interim reexaminations. • Item #7 – Verification of Assets We respectfully disagree with this finding. Documentation verifying household assets was obtained and is included in the file. The source documents supporting asset verification are attached to this response for your review. Based on the documentation on record, the verification requirements were met. • Item #9 – Eligible Immigration Status We also disagree with this finding. Verification of eligible immigration status was completed for the one non citizen Head of Household. The SAVE verification was performed, confirmed, and is attached to this response as supporting documentation. The file contains the required evidence demonstrating eligibility for assistance. • Item #12 – Rent Calculation and Form HUD 50058 We do not agree with this finding. A review of the Form HUD 50058 indicates that the correct utility allowance for a two bedroom unit ($319) was recorded, along with the correct tenant rent share of $239. These amounts differ from those listed in your summary. The source document is attached for your review and confirmation. AMP 3 Response: Management agrees with the need to reinforce monitoring controls among responsible personnel to ensure compliance with eligibility processing requirements for admissions and recertifications. Management will enforce requirements for staff to obtain, review, and properly document all required verification documentation prior to recertification. Furthermore, Property Site Managers (PSMs) will conduct periodic quality control reviews to ensure proper procedures are followed in compliance with HUD requirements. Any identified deficiencies will be promptly corrected and addressed accordingly. AMP 4 Response: We acknowledge the vital need to reinforce internal monitoring controls to ensure full compliance with all eligibility and verification requirements. Enforcing these controls effectively is essential for maintaining program integrity and ensuring the accuracy of benefit determinations. Property Site Managers (PSMs) will conduct regular, periodic quality control reviews to confirm that established procedures are being consistently followed across all files. Any deficiencies or errors identified during PSM reviews will be handled with immediate corrective action. AMP 4 Response to noted items: Sexual Registry Clearance Item #2 and #13. We agree with this finding. Sexual Registry clearance form was not completed by staff. Staff will make corrections to complete Sexual Registry clearance form. Moving forward all intake forms will be verified before finalizing certification. Enterprise Income Verification Item #13. We agree with this finding. Staff oversight on certifying EIV report. Staff will be reminded that all documents requiring PHA staff certification must be completed prior to finalization of certification. Verification of Assets Item #13. We agree with tis finding. Staff failed to obtain third-party bank statement, self-certification, or tenant declaration of asset. Calculated Tenant rent and Utility allowance Item #13. We disagree with this finding. Calculated tenant rent is correct based on income documentation submitted to PHA. Documentation for this finding submitted as attachment “Item 13” Verified Income Item #13. We disagree with this finding. Verified income was calculated and inputted in system. Documentation for this finding submitted as attachment “Item 13 Income”. Responsible Party: Asset Management Property Site Managers – Jeanna Blas, AMP 1 Acting, Gina Cura, AMP 2, Patrick Bamba, AMP 3, and Bernadette Tyquiengco, AMP 4 Anticipated Date of Completion: September 30, 2027

Finding #2025-011 14.267 Continuum of Care Period of Performance Views of Responsible Officials and Planned Corrective Action Management’s Position: Condition 1, 2, & 4 Management concurs with the finding. The questioned cost relates to a payroll charge that was initially assigned to a subsequent CoC Planning Grant during the payroll reimbursement process because funding was available under that grant after the prior funding source had been exhausted. During the drawdown review, management identified that the pay period occurred prior to the start of the grant’s period of performance and therefore was not eligible to be charged to that federal award. Upon identification of the issue, the payroll cost was excluded from the reimbursement request and was not included in a federal drawdown. The appropriate corrective action was to reclassify the expense from the CoC Planning Grant to a local funding source. However, at the time the issue was identified, the accounting staff responsible for overseeing payroll reimbursements and related accounting adjustments were in the process of transitioning responsibilities. As a result, while the ineligible cost was not reimbursed with federal funds, the required accounting reclassification was not completed until the subsequent fiscal year. Corrective Actions: Management has strengthened and formalized its payroll reimbursement review procedures to ensure that grant period-of-performance requirements are verified prior to classification of payroll expenses. Management has also established procedures for documenting and tracking identified exceptions to ensure that required accounting adjustments are completed timely and reviewed by supervisory personnel. The RPE Accounting Department will be responsible for ensuring payroll reimbursement classifications are reviewed for compliance with applicable grant period-of-performance requirements. Accounting personnel responsible for payroll reimbursements and related accounting adjustments will maintain documentation of identified exceptions and ensure required adjustments are completed and reviewed by supervisory personnel. Condition 3 Management does not concur with the finding. Explanation of Disagreement: The Manual Journal Voucher (MJV) referenced by the auditor reflects a reclassification of payroll costs between federal grants. While the payroll expenditure relates to a pay period ending June 14, 2025, the expenditure was not ultimately charged to the grant with a period of performance ending December 31, 2024. The purpose of the MJV was to remove the payroll expenditure from the original grant and reclassify it to the appropriate federal grant. The corresponding entry within the same journal voucher charged the expenditure to a grant whose period of performance encompassed the payroll pay period. As a result, the payroll expenditure was not charged to a federal award outside of its period of performance. Management believes the exception resulted from reviewing only one side of the reclassification entry rather than the complete transaction. The supporting MJV demonstrates that the expenditure was removed from the grant with the expired period of performance and reassigned to the appropriate federal award. Accordingly, management respectfully requests reconsideration of this exception. Responsible Party: Katherine Taitano, Chief Planner Anticipated Date of Completion: Condition 1, 2, & 4 The enhanced payroll reimbursement review procedures and exception tracking procedures have been implemented.

Finding #2025-010 14.239 HOME Investment Partnerships (HOME) Program Special Tests and Provisions – Wage Rate Determination Views of Responsible Officials and Planned Corrective Action Management’s Position: 1. Purchase Order #241616 – Management concurs with the finding and acknowledges the need to strengthen internal controls. 2. Purchase Order #250207 – Management respectfully disagrees with this finding. 3. Purchase Order #250994 – Management respectfully disagrees with this finding. Corrective Actions: Purchase Order # 241616 Management continues to implement improved processes to ensure more consistent compliance monitoring and documentation. This file will be reviewed and corrected as necessary. Management will maintain ongoing monitoring to ensure continuous improvement and sustained compliance. Periodic internal reviews and oversight checkpoints will be conducted throughout the project lifecycle to identify issues early, reinforce accountability, and support timely corrective action where needed. Responsible Party: Jo Lyn Terlaje, Community Development Manager Anticipated Date of Completion: Management confirms that strengthened internal controls have been implemented to improve oversight, tracking, and compliance monitoring across program activities. These controls include enhanced documentation procedures, defined review and approval processes, and improved coordination among responsible divisions.

Finding #2025-009 14.239 HOME Investment Partnerships (HOME) Program Special Tests and Provisions – Underwriting Views of Responsible Officials and Planned Corrective Action Management’s Position: Management respectfully disagrees with the finding of no approved policy effective FY2025. An approved policy addressing this requirement is in place and was submitted as requested on March 9, 2026. Explanation of Disagreement: The HOME Program has an approved and effective policy that documents underwriting standards used to determine the appropriate amount of homeownership assistance based on a household’s debt, assets, and overall financial resources. Corrective Actions: GHURA Community Development Division continues to working closely with HUD to ensure program compliance and alignment with federal requirements, and is currently in the process of updating and amending its policies to reflect current market conditions and strengthen long-term program sustainability. Responsible Party: Jo Lyn Terlaje, Community Development Manager Anticipated Date of Completion: Ongoing effort and as training is made available

Finding #2025-008 14.239 HOME Investment Partnerships (HOME) Program Special Tests and Provisions – Houisng Quality Standards Views of Responsible Officials and Planned Corrective Action Management’s Position: #1 Management concurs with the finding and acknowledges the deficiency identified. Corrective action has been initiated. #2 Disagree, the inspection report was only requested for one of the units, submitted on March 12, 2026. Supporting documentation is available for review for the other units upon request. Explanation of Disagreement: For Item #2, GHURA completed onsite inspections for the two acquisition units reviewed. As these units required no rehabilitation, only one inspection was necessary. The remaining two units are new construction projects currently under development. GHURA has conducted ongoing progress inspections and maintained inspection reports prepared by a third-party inspector throughout the construction process. Units are scheduled to be completed 2nd quarter FY2027 at which time the final inspections will be conducted to ensure compliance with program requirements. Corrective Actions: Item #1 - Guam initiated HOME rental monitoring and technical assistance for the three rental developments currently within their compliance periods. Consistent with the schedule provided to HUD by GHURA, RPE conducted entrance meetings with the Subrecipient organization’s deputy director and key staff on June 17, 2026. The Subrecipient was notified of physical inspections scheduled for June 22, 23, and 25, 2026, to be conducted by GHURA AE. One complex, containing more than ten (10) HOME-assisted units, will also undergo financial viability monitoring. File reviews, interviews, and document collection are currently underway. Item #1 – RP&E has initiated this action and will continue as required moving forward. Responsible Party: Jo Lyn Terlaje, Community Development Manager Anticipated Date of Completion: Item #1 - The monitoring process will conclude within 30 days of the entrance meeting, on July 17, 2026, at which time a letter outlining the monitoring results will be issued.

Finding #2025-007 14.239 HOME Investment Partnerships (HOME) Program Eligibility Views of Responsible Officials and Planned Corrective Action Management’s Position: #1 Management concurs and acknowledges that approving the matter without a more thorough evaluation was an oversight. #2 Management disagrees. HOME maximum subsidy per 3-bedroom unit is $338,419.00. Total HOME investment is $112,500.00. Corrective Actions: Corrective actions include strengthening internal controls and oversight. Management will implement a more comprehensive review process moving forward. This process will include additional supervisory review, verification of supporting documentation, confirmation of regulatory and policy compliance, and consultation with appropriate program and legal staff, when necessary, before approvals are granted. Management will also establish review checklists and documentation standards to ensure that all relevant factors are consistently evaluated and adequately documented. Moving forward, the Community Development Division will undergo a more rigorous evaluation process standardized review checklists and documentation requirements will be implemented to promote consistency, accountability, and proper recordkeeping. Management will monitor compliance with these enhanced procedures to reduce the risk of future deficiencies, oversights and ensure approvals are supported by adequate due diligence. Responsible Party: Jo Lyn Terlaje, Community Development Manager Anticipated Date of Completion: Final approval checklists will be implemented by August 1, 2026.

Finding #2025-006 14.225 CDBG – Endtitlement Grants Cluster B19ST660001, B20ST660001, B21ST660001, B22ST660001, B23ST660001, B24ST660001 Special Tests and Provisions - Rehabilitation Views of Responsible Officials and Planned Corrective Action Management’s Position: Management partially concurs with the finding. Management acknowledges that documentation can be strengthened. However, management does not concur that controls for project documentation and assigned personnel are absent. Explanation of Disagreement: Pre-rehabilitation inspections are conducted by GHURA engineering personnel for all proposed acquisitions. The assessment process requires multiple visits while personnel build the details to develop the scope of the necessary rehab work. These assessments lead to the work writeups to address identified deficiencies (safety, structural, electrical, plumbing, HVAC, lead, radon, etcetera). Senior engineering personnel oversee this process from initial assessment to final writeup. Corrective Actions: Management will reassess current procedures and documentation of pre-rehab condition. This will include inclusion of a periodic review of these procedures. The purpose of this assessment is to augment compliance with rehab requirements and coordination between key divisions responsible for activity completion. The A&E Division will remain responsible for the rehabilitation of CDBG-funded activities and to maintain appropriate documentation. The RPE Division will remain responsible for coordinating and ensuring compliance with CDBG requirements for the rehabilitation of funded activities and to maintain appropriate documentation. Responsible Party: Katherine Taitano, Chief Planner Anticipated Date of Completion: The enhanced documentation procedures will be implemented by or before the beginning of the next program year cycle.

Finding #2025-005 14.225 CDBG – Endtitlement Grants Cluster B19ST660001, B20ST660001, B20SW660001, B21ST660001, B22ST660001, B23ST660001, B24ST660001 Reporting - Federal Funding Accountability and Transparency Act Views of Responsible Officials and Planned Corrective Action Management’s Position: Management partially concurs with the finding. Management acknowledges that documenting FFATA lagged in some instances during the earlier periods reviewed. In some instances, challenges with the reporting system complicated our ability to submit timely reports. This was discussed with the audit team. A review of additional requests by the auditor was not completed in time to be incorporated into this commentary. Explanation of Disagreement: FFATA submissions in FSRS are often complicated by limitations in the reporting system. For example, validation of an awardee’s address was often an impediment to completing the FFATA submission. The result is the inability to complete the reporting process. Responsible staff would make multiple varied attempts to enter verified information that would be rejected. In an effort to comply, responsible staff make attempts to resolve this either through the funder or the reporting system. Corrective Actions: To strengthen FFATA reporting, management will review its established processes of pre-award through award documentation. Management will review assigned responsibilities to ensure confirmation of FFATA submission. The RPE Division is responsible for FFATA reporting into SAM.gov. Specific responsibilities to oversee this process are assigned and necessary accesses assigned. Responsible Party: Katherine Taitano, Chief Planner Anticipated Date of Completion: Immediate. The processes of FFATA reporting are in place for all FFTA submissions. Personnel are assigned to ensure the FFTA process is executed and documented for all funded activities.

Finding #2025-004 14.225 CDBG – Endtitlement Grants Cluster B23ST660001, COVID-19 B20SW660001, B20ST660001 Reporting - CDBG Financial Summary Report Views of Responsible Officials and Planned Corrective Action Management’s Position: Management partially concurs with the finding. Management acknowledges that supporting documentation explaining differences between the PR26 – CDBG Financial Summary Report, PR26 – CDBG-CV Financial Summary Report, and the Authority’s accounting records can be further strengthened. However, management does not concur that the identified differences resulted in noncompliance with CDBG expenditure requirements or applicable Public Service (PS) and Planning and Administration (PA) expenditure limitations. Explanation of Disagreement: Management notes that the PR26 report referenced in the finding is not the final CDBG Financial Summary Report submitted for Program Year 2024. Management requests that the PR26 report submitted in response to audit request #204 be considered for purposes of evaluating the reported CDBG financial activity. Management also notes that the FY2025 expense detail does not represent the full amount of CDBG expenditures reflected in FY2025 draw activity. This is because certain payroll expenditures incurred during FY2024 were drawn during FY2025 and are therefore included in FY2025 cash activity reported through HUD. Management notes that the purpose of the PR26 reports is to summarize CDBG and CDBG-CV financial activity and demonstrate compliance with applicable program expenditure limitations, including the Public Service and Planning and Administration caps. Management has reviewed these calculations and confirmed, in coordination with HUD representatives, that the applicable caps were not exceeded. Management further notes that differences between the PR26 reports and the Authority’s accounting records may occur due to differences in reporting methodologies. The PR26 reports are prepared based on cash activity reported through HUD, while the Authority’s financial records are maintained on an accrual basis. As a result, differences may occur due to timing of draws, prior-period expenditures drawn during the current reporting period, and other applicable reconciling items. Based on the above, management maintains that the identified differences are attributable to reporting basis and timing differences rather than noncompliance with CDBG expenditure requirements. The final CDBG Financial Summary Reports and supporting documentation have been provided for the auditor’s consideration. Corrective Actions: Management will enhance existing PR26 preparation procedures by maintaining supporting documentation identifying significant reconciling items between HUD-reported activity and the Authority’s accounting records. The purpose of this documentation will be to explain differences resulting from reporting methodology, timing of draws, prior-period expenditures drawn during the current reporting period, and other applicable reconciling items. The RPE Accounting Department, will be responsible for maintaining supporting documentation for PR26 reporting and documenting significant reconciling items. Supervisory review will continue to be performed prior to submission of future PR26 reports to ensure reported information is supported and appropriately documented. Responsible Party: Katherine Taitano, Chief Planner Anticipated Date of Completion: The enhanced documentation procedures will be implemented beginning with the next PR26 reporting cycle.

Finding #2025-003 14.871 Section 8 Housing Choice Vouchers Special Tests and Provisions – Reasonable Rent Views of Responsible Officials and Planned Corrective Action Management’s Position: Management respectfully disagrees with this finding. GHURA’s HCV program remains committed the regulations 24 CFR 982.507 and is fully knowledgeable of the process when determining rent reasonableness with comparable units in the private market and properly document all comparables. Before executing a HAP Contract, a rent reasonableness analysis is conducted for all units. This analysis includes assessing comparable unassisted units taking into account the location, size, type, and age of unit, as well as any amenities (such as septic, sewer, air conditioning, etc.), and utility responsibilities. We have standard operating procedures and methodologies in place to conduct these analyses and certify that comparable rents are reasonable. Any identified errors are likely due to isolated oversights during the data entry process. Explanation of Disagreement: Listed below are the discrepancies with accompanying comments. Out of the seven (7) entries provided, one (1) was identified as a calculation error. TOTAL: 07 entries (table provided to support explanation) 1. 4 Rent Reasonableness entries were completed correctly. 2. 2 Rent Reasonableness entries were system input errors. 3. 1 Rent Reasonableness analysis was an administrative error. Voucher Number Effective Date Auditor Comment Section 8 HCV Response HCV2828 2/1/2025 Per examination of the Rent Reasonableness reports, it was noted the comparables are not within similar area locations. We noted that the unit is located in Yigo (Northern), while the comparable units used in the rent reasonableness determination were located in the Southern area. To properly check the unit comparisons, the rent reasonableness module was updated to reflect the correct location and the three highest scoring comparable units were selected based on the applicable comparison factors. From the revised analysis, the average rent of the comparable unassisted units were $1,924, which is less than the initial calculated average of $2,966.67. SYSTEM INPUT ERROR: Location of the Proposed Unit was inputted as 'Southern' when the Yigo unit is a 'Northern' located unit. As a result, comparables for units located in the southern location were pulled. SOLUTION: All Section 8 assisted units in the system will be assessed to verify location accuracy based off of village and zip code. NED0444 10/1/2024 The Authority did not rely on the comparable contract rents reflected in the Rent Reasonableness Determination Report (average $949.33), but instead recalculated contract rent using gross rent less a utility allowance, resulting in $1,000. This methodology is not directly supported by the market comparables presented in the report. ADMINISTRATIVE ERROR: The amount of $949.33 should have been the contract rent amount. SOLUTION: Review discrepancy with team to ensure errors will not happen in the future. HCV2796 1/1/2025 Per Mark McCormick on the Rent Reasonable Determination Report and Request for Tenancy Approval (RFTA), the documents indicate no comparable unassisted units were available in the proposed unit's area; however, a nearby unassisted unit in the RFTA is at Ladera Tower and appears reasonably comparable based on proximity. 12a. Owner’s Certification 1. Ladera Towers - Date rented: 9/1/24 - Rental amount: 2,450 2. Washington Dr - Date rented: 10/21/21 - Rental amount: 1,850 3. Quichocho St Villa - Date rented: 1/21/23 - Rental amount: 1,850 RR DETERMINED CORRECTLY: (1) Rent Determination Documents has a note that the unassisted units are not on premises. (2) The units listed in the RFTA-12A were not located on the premises of the unit to be under HAP contract which is why it was not referenced. (3) The Ladera Towers may or may not be in the unassisted units database; is was not in the database at the time the comparables were made. HCV2876 6/30/2025 The approved contract rent of $1,400 was calculated using the average column in the Rent Reasonableness Determination Report (exception); however, the three comparable unassisted units listed on the RFTA are each $1,200, which is lower than the approved amount. Owners Certification: 138 (#347) and 148 (#363) Chalan totche $1,200 132 Chalan Guihan #402 $1,200 RR DETERMINED CORRECTLY: RFTA lists LITHC properties. LITHC unit rates are not used in comparables. 6-05-0050- 56262 9/1/2025 The owner proposed rent of $2,500 was determined to be rent reasonable based on the average comparable unassisted units of $3,774 and Fair Market value of $2,964. However, it was noted that the unit is located in Chalan Pago (Central), while one of the comparable units used in the rent reasonableness determination was located in the Northern area. To properly check the unit comparisons, the rent reasonableness module was updated to reflect the correct location and the three highest scoring comparable units were selected based on the applicable comparison factors. From the revised analysis, the average rent of the comparable unassisted units were $1,870, which is less than the initial calculated average of $3,774. SYSTEM INPUT ERROR: Location of unassisted unit was labelled as 'Central' when the village and zip code indicates that unit is located in the 'Northern' area. SOLUTION: All Section 8 unassisted units in the system will be assessed to verify location accuracy based off of village and zip code. 6-08-0353- 60378 1/1/2025 Per examination of the rent determination report, we noted the approved rent exceeds the rent reflected in the owner-certified lease for a comparable unit; however, no documentation was provided to support or justify the variance between the approved and contracted rent amounts. RR DETERMINED CORRECTLY: Tenant exercised the rent burden rule for this contract. The $100 amount does not exceed the tenant's 40% of AMI. NED0070 11/1/2024 Rent determination documentation indicates an approved amount of $940; however, the executed lease agreement (dated 10/29/2024) reflects a rent of $942 as requested by the landlord. No supporting documentation was provided to justify the variance between the approved rent and the amount charged. RR DETERMINED CORRECTLY: Approved amount for the contract was $942; which aligns with landlord's request. Corrective Actions: (1) SYSTEM INPUT ERRORS: All Section 8 unassisted and assisted units in the system will be assessed to verify location accuracy based off of village and zip code. (2) ADMINISTRATIVE ERRORS: Review discrepancy with team to identify the cause of this issue and ensure similar errors do not happen in the future. Preventive Measures: Closely assess rent determination calculations to ensure accuracy and certified rental amounts are correct. Responsible Party: Nicole Alejandro, Section 8 Administrator Anticipated Date of Completion: Timeline for Resolution: (1) SYSTEM INPUT ERRORS: • 6/18/2026: Request report from MIS to provide list of units with location in the systems. • 6/22/2026: Received report from MIS, consisting of 4,922 units. • 6/22-6/10/2026: Review report, identify deficiencies, and create plan to correct deficiencies. • 6/13/2026: Assign staff to update system with accurate data to address any location deficiencies. • 7/31/2026: Complete assignment. Preventive Measures: Pull quarterly report for assisted and unassisted units in the system and review list of units and ensure location is accurate based off of village and zip code of unit. (2) ADMINISTRATIVE ERRORS: Review discrepancy with team to identify the cause of this issue and ensure similar errors do not happen in the future. • 6/17/2026: Review and discuss discrepancy with HCV Inspection Supervisor • 6/18/2026: Conduct Inspection Team Meeting to address discrepancy with HCV Inspection Team to identify the cause of the issue. Review SOP with team to ensure similar errors do not happen in the future • 6/18/2026: Assignment completed.

Finding #2025-002 14.871 Section 8 Housing Choice Vouchers Special Tests and Provisions - National Standards for the Physical Inspection of Real Estate (NSPIRE)/Housing Quality Standards Inspection Views of Responsible Officials and Planned Corrective Action Management’s Position: Management respectfully disagrees with this finding. GHURA’s HCV program remains committed to our biennial inspection requirements and are fully compliant with all applicable regulations. When a unit fails inspection, we work quickly to resolve the issues and ensure housing standards are met, as outlined in 24 CFR Part 982. In accordance with 24 CFR 982.405(d), we provide both participants and landlords adequate time to correct deficiencies, which is documented in our system. We remain compliant in our conduct and oversight of these requirements. Should there be a late HQS biennial inspection, this should not interrupt the HAP. Suspending these payments creates an undue burden for participants and strains our partnership with landlords. Unless a unit is deemed unsafe, HAP will continue. HAP abatement and reimbursement policies are in place should they need to be activated to retrieve HAP in instances where it was not entitled. Explanation of Disagreement: The list provided below is insufficient to claim any finding in HQS due to the following: TOTAL: 32 entries (table provided to support explanation) 17 families ended their participation before the biennial inspection was due. 5 families were port-out participants before the biennial inspection was due. 5 units were recorded to have inspections completed before the biennial inspection due date and passed inspection. 1 unit inspection was completed on time, but failed on the first inspection. 1 unit inspection was completed on time, but was a no entry on the first attempted inspection. 1 family moved out of the unit before the biennial inspection. 1 family had incorrect dates in this list and was recorded to have met the biennial inspection and passed inspection. 1 family’s inspection was late by 17 days, however, the inspection was completed and passed in that same month, which did not affect the HAP. Voucher Latest HQS Inspection Activity Sum of Amount Section 8 HCV Response 6-01-0105-926 09/28/23 $ 220.00 EOP: 1/31/25 6-01-0212-58183 04/13/23 $ 13,824.00 EOP: 3/31/25 6-03-0198-2327 4/4/2022 (should be 9/19/22) $ 27,648.00 NOTE: Latest HQS Inspection Activity is 9/19/22 and inspection passed on 9/11/24. The 4/4/22 Inspection Date is for Voucher #6-04-0171-47367 (different tenant). 6-05-0005-42278 07/12/22 $ 25,320.00 NO ENTRY: 7/9/24 | PASSED: 8/21/24 6-05-0145-47900 07/18/22 $ 12,794.00 PASSED: 7/9/24 6-05-0241-46089 08/29/23 $ 2,280.00 OUTSEARCHING: 4/1/25 6-07-0028-2139 07/19/22 $ 23,996.00 FAILED: 7/17/24 | PASSED: 8/19/24 6-07-0115-1927 09/11/23 $ 6,278.00 EOP: 2/28/25 6-07-0289-52502 05/06/22 $ 28,316.00 PASSED: 5/6/24 EHV0132 08/23/23 $ 1,076.00 PORT-OUT: 10/31/24 FUP0156 08/21/23 $ 17,607.00 EOP: 5/31/2025 HCV0134 01/05/22 $ (402.65) PORT-OUT: 6/30/22 HCV0521 04/22/22 $ 18,997.00 PASSED: 4/3/24 HCV0561 08/16/23 $ 14,409.00 EOP: 6/30/25 HCV0735 12/09/22 $ 1,227.00 EOP: 11/30/24 HCV0874 04/17/23 $ 4,383.00 EOP: 12/31/24 HCV1038 03/17/22 $ 5,130.00 PASSED: 1/17/24 HCV1083 9/12/2022 (should be 2/15/22) $ 17,987.00 PASSED: 1/17/24 HCV1333 08/17/23 $ 4,686.00 EOP: 12/31/24 HCV1699 10/18/22 $ (90.40) PORT-OUT: 8/10/23 HCV1704 09/12/23 $ 5,596.00 EOP: 1/31/25 HCV1811 08/31/23 $ 9,096.00 EOP: 3/31/25 HCV1873 07/11/23 $ 1,096.00 EOP: 11/30/24 HCV2024 07/06/22 $ 22,875.00 PASSED: 7/23/24 (LATE) HCV2110 07/19/23 $ 8,344.00 PORT-OUT: 4/30/25 HCV2452 08/02/23 $ 6,256.00 EOP: 1/31/25 HCV2457 07/13/23 $ (1,681.00) PORT-OUT: 7/5/24 HCV2466 08/31/23 $ 1,374.00 EOP: 6/30/25 MS0028 04/05/23 $ 1,449.00 EOP: 10/31/24 MS0031 04/14/23 $ 1,026.00 EOP: 4/30/25 NED0213 07/11/23 $ 9,642.00 EOP: 3/31/25 VASH0149 08/03/23 $ 6,272.00 EOP: 7/31/25 Corrective Actions: Due to my explanation above, there are no corrective actions needed for Finding No.: 2025-001. Due to my explanation above, there are no corrective actions needed for Finding No.: 2025-001. Due to my explanation above, there are no corrective actions needed for Finding No.: 2025-001. Responsible Party: Nicole Alejandro, Section 8 Administrator Anticipated Date of Completion: Due to my explanation above, there are no corrective actions needed for Finding No.: 2025-001.

Finding No. 2025-001 - Replacement Reserve Deposit Increases Planned Corrective Action - Management has since implemented additional procedures to ensure that future replacement reserve deposit changes are implemented by the mortgage servicer. Management has made the 2025 shortage deposit to the replacement reserve. Anticipated Completion Date - June 2026 Responsible Contact Person - Stephen Hoover, President, Board of Directors, E-mail: sbhoover@outlook.com

a. Management is negotiating a solution with the State of Utah and HUD for a refund of the payment.

CORRECTIVE ACTION PLAN -For FY 2025 Audit Finding FINDING: 2025-002-ALN 14.872: U.S. Department of Housing and Urban Development’s (HUD’s) Capital Fund Program CRITERIA: 24 CFR 905.202(j) requires financial assistance to make improvements to existing public housing units. CONDITION: During the audit, it was discovered a purchase of a maintenance vehicle was made with funds under Budget Line Item 1480, “General Capital Activity”. HUD has issued guidance stating such purchase is considered an operational cost and CFP 1480 BLI cannot be used for such purchase. PLAN FOR CORRECTION: Management has reviewed 24 CFR 905.200 and 24 CFR 905.202 and will ensure no future purchases of maintenance vehicles, or equipment, will be planned to use any funds under the CFP BLI 1480, “General Capital Activity”. CONTACTS FOR PLAN: Chris Wallen – Finance Manager Ph. (503) 623-8387 Ext. 332 cwallen@wvpha.org Christian Edelblute - Executive Director Ph. (503) 623-8387 Ext. 314 cedelblute@wvpha.org

CORRECTIVE ACTION PLAN -For FY 2025 Audit Finding FINDING: 2025-001-ALN 14.871 & 14.879: U.S. Department of Housing and Urban Development’s (HUD’s) Section 8 Housing Choice Voucher (HCV) Program & Housing Quality Standards Inspection/HQS Enforcement CRITERIA: 24 CFR 982.405 & 983.103 require units leased, under the HCV Program, to be inspected at least biennially to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. CONDITION: During the audit, three (3) failed HQS inspections, with life threatening issues as defined by the WVHA’s Administrative Plan, was found that did not receive a pass in conformance with the Criteria noted above and no HAP abatement process was enforced. Additionally, two (2) HCV units were found to have not been inspected at least biennially. PLAN FOR CORRECTION: Inspection Protocols- With the limitation of time imposed by the 24-hour remedy period, staff were calling and/or emailing the landlords as soon as they noted a Life, Health & Safety deficiency. Inspection staff have been informed that all Life Health and Safety deficiencies will immediately trigger a letter to the landlord (with a copy to the HCV caseworker) stating that Housing Assistance Payments will be placed in abatement and the HCV caseworkers will perform such abatement action as soon as the 24-hour period has elapsed (unless informed by the inspector that the property has subsequently corrected the deficiencies). Documentation- Physical inspection records will be provided to each HCV caseworker and be added to the tenant household’s HCV file within 24 hours of the inspection. HCV caseworkers are required to ensure all inspection documentation is properly located within each HCV file and such documentation is in accordance with the program’s rules and regulations. CONTACTS FOR PLAN: Cheryl Slagle – Housing Programs Manager Ph. (503) 623-8387 Ext. 328 cslagle@wvpha.org Christian Edelblute - Executive Director Ph. (503) 623-8387 Ext. 314 cedelblute@wvpha.org

The agency submitted and received a formal waiver for the prior two years PILOT. To prevent future deficiencies, PILOT waiver requests have been incorporated into the Authority's annual budget process, and payment status will be reviewed annually to ensure waivers are permitted or payment was submitted as part of the financial close process.

Management has strengthened its recordkeeping practices to ensure that all revenues are fully supported by appropriate source documentation and are readily available for audit, monitoring, and financial reporting purposes. The Finance Director has conducted a review of current revenue documentation procedures to identify any gaps in record retention and establish standardized filing requirements for all revenue sources, including tenant rent, HUD operating subsidies, Capital Fund reimbursements, Housing Assistance Payments (HAP), administrative fees, miscellaneous income, grant revenues, and other receipts. Where documentation is incomplete, management has made reasonable efforts to obtain or recreate supporting records from available internal and external sources.

Recommendation: Management should strengthen its tenant file review and monitoring procedures to ensure that reasonable rent determinations and utility allowance calculations are completed, documented, and reviewed in accordance with the Housing Authority’s policies and applicable program requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The Authority will address the identified deficiencies and prevent recurrence by strengthening file review procedures, enhancing staff training, and improving internal controls. A standardized quality control process will be implemented to ensure required tenant file elements are accurate, complete, and properly reviewed prior to approval, along with periodic monitoring to identify and correct errors in a timely manner. Staff will receive targeted and refresher training to reinforce key requirements, calculations, and documentation standards. Additionally, the Authority will evaluate opportunities to improve system controls to reduce the likelihood of errors or missed steps. Name(s) of the contact person(s) responsible for corrective action: Lowel Krueger, Executive Director. Planned completion date for corrective action plan: December 31, 2025.

Memo: Cause and Corrective Action Plan for Finding 2025-003 This correspondence serves as Cook County Health (CCH) and Cook County Department of Public Health (CCDPH) response to Finding 2025-003. During the FY2025 Single Audit, one audit finding was identified by Washington, Pittman & McKeever, LLC. The root cause and corrective action plan is identified below. Condition During the current audit period, the Cook County Department of Public Health (DPH) did not comply with federal regulations regarding the use and reporting of program income as it relates to funds awarded through the RWHAP Root Cause Analysis The HIV grants transitioned to CCH from an external organization in July 2025. Award amounts were granted in multiple phases, requiring four budget revisions, with the final revision approved in December 2025. The contractual period covered March 2025 through December 2025. During the transition period, CCH lacked formal operational procedures to identify, record, and track program income. Several operational and administrative challenges contributed to this issue, including: • No written internal procedures were in place to define or track program income requirements. • No formal transition teams were established to identify core grant obligations, resulting in unclear interpretation of sponsor requirements. • CCH had not yet identified the appropriate internal systems or interdepartmental collaborations necessary to retrieve and reconcile program income data. • Organizational priorities during the transition focused on maintaining existing deliverables, including vouchering, budget compliance, hiring, and onboarding of direct and administrative staff. • Staffing Shortages, CCH onboarded personnel quickly as contractual employees, direct staff transitioned onboard as CCH employees in phases upon execution of grant contracts. Corrective Action Plan CCH Director of Grants Accounting is implementing formal written processes and procedures to ensure compliance with Federal Uniform Guidance requirements related to program income. The corrective action plan includes: • Developing standardized written procedures that clearly define program income requirements and tracking responsibilities. • Establishing shared roles and responsibilities across departments to support consistent data collection, reconciliation, and reporting. • Identifying the specific data elements required to accurately record and monitor program income. • Formalizing interdepartmental collaboration processes necessary to retrieve and validate program income information. • Defining the systems and reporting tools that will be used to track and maintain program income records. • Providing staff training on program income requirements, documentation standards, and compliance expectations. These actions will strengthen internal controls and ensure timely, accurate identification and tracking of program income moving forward, official approval/implementation is expected December 2026

The Housing Authority has addressed the staffing levels for the program and is working with HUD to secure reimbursements for under funded HAP remittances. Additionally, the Authority is working with HUD to utilize reserve funds to alleviate the issue.

2025-001 Finding SDSI Housing Corporation, Inc. (SDSI Housing) received reimbursement from the reserve for replacements of $135,824 for roof repairs that were previously funded with insurance proceeds. The reserve for replacements is under funded by $135,824 due to the reimbursement of ineligible items. A reimbursement request was submitted for major roof repairs which are traditionally contemplated as eligible for draws under HUD Occupancy Handbook 4350.3 REV-1. However, management did not consider the fact that such repairs had already been funded by insurance proceeds, so the major roof repairs resulted in no cost to the Project. Comments on Finding and Recommendations Management agrees with the finding and recomendations. Actions Taken Management returned ineligible funds of $135,824 to reserve for replacements on April 16, 2026.