Corrective Action Plan: The Housing Authority concurs with the auditor's recommendation. The outstanding inter-entity balance has been identified as a legacy balance associated with the RAD conversion and the transfer of assets and liabilities to Athens Housing Management, LLC. Management's review a...
Corrective Action Plan: The Housing Authority concurs with the auditor's recommendation. The outstanding inter-entity balance has been identified as a legacy balance associated with the RAD conversion and the transfer of assets and liabilities to Athens Housing Management, LLC. Management's review and reconciliation of the balance are in progress. Before recording any final disposition, the Authority will determine the balance's origin, funding source, supporting documentation, legal obligation, and collectability, including whether federally restricted or RAD/PBRA project funds are involved. The Board of Commissioners may authorize the accounting disposition of the balance, subject to the Authority's governing documents and applicable law; however, a Board vote alone will not be treated as authority to forgive or extinguish a federally restricted or project-level receivable. The Authority will complete the following process: 1. Complete and document the reconciliation and proposed accounting treatment in both entities' records, with management and legal review, and provide the supporting documentation to the Authority's auditor. 2. Determine whether the balance is subject to the RAD closing documents, HAP Contract, RAD Use Agreement, Surplus Cash requirements, or other Federal restrictions. If so, submit the reconciliation, proposed entries, supporting documentation, and draft resolutions to the appropriate HUD Field Office or Multifamily Account Executive and obtain written direction or concurrence, as applicable. 3.Present conditional resolutions to the governing boards of the Housing Authority and Athens Housing Management, LLC, as applicable, authorizing the Chief Executive Officer to record the disposition only after all required HUD approvals or concurrences have been received. 4. Record corresponding entries in both entities, retain the complete reconciliation and approval package, and disclose the final resolution to the auditor. This process is consistent with 2 CFR §§ 200.302 and 200.303, which require accurate, supported financial records, accountability for Federal funds and assets, and documented internal controls. It also recognizes the RAD Notice requirements governing Surplus Cash and related-party advances. Going forward, inter-entity balances will be reconciled monthly, reviewed by management, and any unresolved items will be reported to the Chief Executive Officer as part of the monthly financial review.