Corrective Action Plans

2025-001 – ALN 14.850 – Public Housing Operating Fund – Activities Allowed or Unallowed Planned Corrective Action: The Executive Director acknowledges the finding and is following the auditor’s recommendation as presented in the Audit Report. The Authority is now drawing down its CFP and is not using operating funds for CFP activities. Person Responsible for Correction of Finding: Wanda Allen, Executive Director Anticipated Completion Date: September 30, 2026

We will implement proper internal control procedures for the Housing choice Voucher VMS reconciliation process.

We will implement proper internal control procedures for the Housing Choice Voucher program eligibility requirements

Planned Implementation Date of Corrective Action: July 2026 Person Responsible for Corrective Action: Krishonna Murray, Executive Director I. 2025-001 Eligibility Rent Calculation Other Matter/Significant Deficiency The Authority had instances of missing income verification. Gardner Housing Authority has established a system of internal control over the participant recertification process that meets HUD's requirements. Seven (7) to ten (10) files will be reviewed fiscally for quality assurance.

Finding No. 2025-002 Corrective Action: The Authority will implement the following corrective actions for the fiscal year ended September 30, 2025 (audit period October 1, 2024 through September 30, 2025): 1. Standardize rent reasonableness documentation. Implement a standardized rent reasonableness form (or system-generated report) required at initial lease-up, rent increases, and other required points, and retain it in the tenant file. 2. Pre-approval control for HAP initiation/changes. Require supervisory verification that rent reasonableness support and inspection/HQS documentation are present prior to (a) initial HAP execution, (b) annual recertification processing where applicable, and (c) approval of rent increases. 3. Inspection scheduling and follow-up procedures. Implement a scheduling log and follow-up protocol to ensure (a) initial inspections, (b) annual/biennial inspections (as applicable), and (c) re-inspections are performed and documented timely; rejected/failed inspections will be tracked until resolved. 4. Quality control reviews. Perform periodic internal quality control reviews (e.g., quarterly) of a sample of active tenant files to verify the presence of rent reasonableness and inspection documentation and to identify trends requiring corrective action. 5. Training and written procedures. Update written procedures and provide training to HCV staff and inspectors on documentation standards, retention requirements, and supervisory review expectations. 6. Corrective review of affected files. Review the tenant files identified during audit testing and any similar files from the audit period to obtain/prepare missing rent reasonableness support and ensure inspections were performed/documented; take corrective action for any issues identified. Implementation timeline: • Standard form/procedure updates: within [30] days of report issuance • Supervisory pre-approval control implemented: within 45 days of report issuance • Inspection log and follow-up protocol implemented: within 60 days of report issuance • Staff/inspector training completed: within 90 days of report issuance • First quarterly QC review completed: by September 30, 2026 • Corrective review of affected files completed: by September 30, 2026. Contact Information: Rosario Contero-Oropeza, Executive Director Housing Authority of the City of Poteet 120 Avenue E Poteet, TX 78065 (830)742-3589

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED SEPTEMBER 30, 2025 Finding No. 2025-001 Corrective Action: The Authority will implement the following corrective actions for the fiscal year ended September 30, 2025 (audit period October 1, 2024 through September 30, 2025): 1. PIC/HUD-50058 submission tracking and accountability. Implement a tracking log (system report or spreadsheet) for all tenant actions requiring PIC/HUD-50058 reporting, including tenant name/ID, action type, effective date, due date, submission date, and evidence of HUD acceptance. 2. Supervisory review prior to file closeout. Require a supervisor to review and initial/approve each tenant action package to confirm PIC/HUD-50058 submission evidence and HUD acceptance confirmation are present before the file is closed, payments are continued, or the action is considered complete. 3. Monthly exception reporting and resolution. Run a monthly PIC exception report (or equivalent system query) to identify missing, rejected, or pending submissions. Assign exceptions to staff for corrective action, document resolution, and retain evidence of follow-up. 4. Tenant file checklist update. Update the tenant file checklist to include PIC/HUD-50058 submission evidence and HUD acceptance confirmation as required elements for applicable actions. 5. Staff training and written procedures. Update written procedures and provide refresher training to staff responsible for reexaminations, interim changes, move-ins, move-outs, and other actions that trigger PIC/HUD-50058 reporting, including documentation retention standards. 6. Lookback/corrective review of the audit-period exceptions. Perform a lookback review of tenant actions processed during the audit period to determine whether additional PIC/HUD-50058 submissions were missed and submit/correct outstanding items, as applicable. Retain documentation of the corrective submissions and acceptance. Monitoring procedures: Management will monitor ongoing compliance by (a) reviewing the monthly exception report and documenting sign-off, (b) performing quarterly quality control reviews of a sample of completed tenant actions to verify PIC/HUD-50058 submission evidence and acceptance confirmation are present, and (c) tracking aging of open exceptions to ensure timely resolution. Statement of ongoing compliance: The Authority will ensure timely and complete PIC/HUD-50058 submissions going forward by requiring each tenant action to be logged and reconciled to PIC submission/acceptance status, enforcing supervisory sign-off prior to action closeout, and promptly resolving any rejected or pending items identified through monthly exception reporting. Implementation timeline: • Tracking log/checklist updates and procedure revisions: within 30 days of report issuance • Supervisory review control implemented: within 45 days of report issuance • Monthly exception reporting and management sign-off begins: within 60 days of report issuance • Staff training completed: within 90 days of report issuance • Lookback review completed: by September 30, 2026. • First quarterly QC review completed: by September 30, 2026

We agree that Elm City Communities should have a control environment that allows the books to be closed and regulatory reports filed on a timely basis. In August 2025 we completed a conversion from Elite to Yardi. This caused us to take longer than normal for our year end close process. Planned Implementation Date of Corrective Action: Immediately Person Responsible for Corrective Action: Shenae Draughn, President.

Action Taken: The Management of the Authority agrees with the findings. We will implement improved internal controls to ensure that all annual recertifications are performed in a timely manner and that all required documents are kept in an organized manner. The Compliance Specialist will perform monthly quality checks on the files and work with staff to eliminate errors. The HCV Director is the responsible party, and controls will be in place by the end of the September 30, 2026 fiscal year.

Action Taken: The Management of the Authority agrees with the findings. We will implement improved internal controls to ensure that all annual recertifications are performed in a timely manner and that all required documents are kept in an organized manner. The Compliance Specialist will perform monthly quality checks on the files and work with staff to eliminate errors. The Director of Asset Management is the responsible party, and controls will be in place by the end of the September 30, 2026 fiscal year.

2025 – 001 Housing Choice Voucher Program – Assistance listing No. 14.871 Recommendation: We recommend the Authority review their process and internal controls for HQS annual inspections to ensure compliance with HUD requirements and their administrative plan. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Institute developed internal controls and increase vigilance of scheduled dates for inspections in accordance with regulations. Name(s) of the contact person(s) responsible for corrective action: Joyce Skelton, Section 8 Program Manager. Planned completion date for corrective action plan: June 23, 2026

In response to the finding regarding low occupancy rate, management contends that the Project is doing all that is within its control to get the vacant units rented.

To address the noted deficiencies in tenant file documentation, staff and supervisors will continue to follow established processes. Supervisors continue to track and monitor productivity and progress. The current supervisor has implemented clear and concise instructions and rules for completing and managing files. All forms are now saved in tenant files, and not on individual laptops as they were in the past. The supervisor has also implemented schedules and tracking systems for monthly voucher submissions, annual recertifications, quarterly income checks and other processes in the occupancy workflow. In addition, the supervisor and the lead staff for housing compliance perform regular checks on tenant application paperwork and random checks on tenant files to ensure accuracy and completeness and correct any mistakes. Ongoing staff training, support and mentoring continues.

To address the noted deficiencies in tenant file documentation, staff and supervisors will continue to follow established processes. Supervisors continue to track and monitor productivity and progress. The current supervisor has implemented clear and concise instructions and rules for completing and managing files. All forms are now saved in tenant files, and not on individual laptops as they were in the past. The supervisor has also implemented schedules and tracking systems for monthly voucher submissions, annual recertifications, quarterly income checks and other processes in the occupancy workflow. In addition, the supervisor and the lead staff for housing compliance perform regular checks on tenant application paperwork and random checks on tenant files to ensure accuracy and completeness and correct any mistakes. Ongoing staff training, support and mentoring continues.

To address the noted deficiencies in tenant file documentation, staff and supervisors will continue to follow established processes. Supervisors continue to track and monitor productivity and progress. The current supervisor has implemented clear and concise instructions and rules for completing and managing files. All forms are now saved in tenant files, and not on individual laptops as they were in the past. The supervisor has also implemented schedules and tracking systems for monthly voucher submissions, annual recertifications, quarterly income checks and other processes in the occupancy workflow. In addition, the supervisor and the lead staff for housing compliance perform regular checks on tenant application paperwork and random checks on tenant files to ensure accuracy and completeness and correct any mistakes. Ongoing staff training, support and mentoring continues.

In response to the finding regarding low occupancy rate, management contends that the Project is doing all that is within its control to get the vacant units rented.

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public Housing Capital Fund Program to ensure that established internal control policies are being followed on a timely basis. Ivy Melendez, Executive Director, will be responsible to implement this corrective action by September 30, 2026.

Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers Program and will implement internal control procedures related to reasonable rent that will ensure compliance with federal regulations. Starting in August 2025, the Authority hired a third party vendor to complete rent reasonableness determinations for all Housing Choice Voucher units. Ivy Melendez, Executive Director, will be responsible to implement this corrective action by September 30, 2026.

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor and will ensure all necessary DOTs are recorded. Ivy Melendez, Executive Director, will be responsible to implement this corrective action by September 30, 2026.

Reference Number: 2025-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Cluster Federal Catalog Number: 14.871 and 14.879 Federal Grant Number: Not Applicable Category of Finding: Special Tests and Provisions (Housing Quality Standards Inspections) Classification of Finding: Significant Deficiency in Internal Control over Compliance Instance of Noncompliance Authority’s Response & Actions Taken The Authority has made substantial progress in resolving the backlog of Housing Quality Standards (HQS) inspections that originated during the COVID-19 period, when HUD waivers and restricted unit access limited the ability to conduct timely inspections. Since that time, the Authority has reestablished normal inspection operations and significantly improved inspection volume and completion rates. All inspections noted in the audit were completed shortly after the required timeframes, and each unit ultimately passed HQS inspection and met HUD’s requirements for safe, decent, and sanitary housing. These results reflect that there was no impact to housing quality or participant eligibility, but rather timing-related delays within an actively managed inspection pipeline. The instances identified in the audit are largely attributable to timing of the audit sample selection, during which certain inspections were in process and scheduled but had not yet been completed. This does not fully reflect the Authority’s current operational performance or the progress achieved in reducing the inspection backlog. The Authority has established ongoing procedures to prioritize and monitor inspection timeliness, including use of the Emphasys Elite system in coordination with HUD’s PIC system to identify and track units approaching or exceeding inspection deadlines. Units identified as nearing noncompliance are actively scheduled and completed, and the Authority continues to work closely with its third-party HCV contractors to maintain consistent inspection coverage. The Authority continues to enhance oversight, tracking, and contractor accountability to ensure sustained compliance with HUD standards. The enhanced oversight and monitoring resulted in SEMAP fiscal year end 9/30/2025 with High Performer status, and current performance trends show the Authority is well positioned to maintain SEMAP High Performer status for the current fiscal year. Specifically for SEMAP Indicator 12 for Annual HQS Inspections, the Authority achieved 10 out of 10 points for fiscal year end 9/30/2025, which was an improvement from the prior fiscal year of 0 out of 10 points, and currently projected to maintain full points for this indicator with 97% timely annual HQS inspections completed. The key strategies and controls in place are as follows: Tenant-Based Program: 􀁸 Review the report of outstanding HQS Inspections on a weekly basis. 􀁸 Schedule outstanding HQS Inspections in order of aging date. 􀁸 Conduct HQS Inspections prior to the anniversary date of previously completed inspection. 􀁸 Running a monthly report of failed inspections and comparing them with future scheduled inspections to ensure that a second inspection has been scheduled. 􀁸 Running a monthly report to identify units with two failed inspections to ensure all have been abated correctly. 􀁸 Implement weekly monitoring to ensure all units are properly abated and lifted timely when units pass inspections and contracts are properly terminated after being in abatement for 180 days without a cure. The Authority has worked with Emphasys to identify the best ways to sort aged HQS inspections due and generate/schedule in bulk, as well as maximize the Inspector’s workday by routing the tenantbased units in a way that flows in a clear and orderly manner. Similar to the handling of delinquent annual reexaminations, the Authority is checking the data in PIC with the system of records and processing 50058 corrections where inspections have been completed but rejected in PIC due to out of sequence effective dates and any other fatal errors that require corrective action. Anticipated Implementation Date September 30, 2026 Name(s) and Title(s) of Contact Person(s) Responsible for Correction Action HCV Contractors Kendra Crawford, Director of Housing Operations

Reference Number: 2025-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Cluster Federal Catalog Number: 14.871 and 14.879 Federal Grant Number: Not Applicable Category of Finding: Eligibility Classification of Finding: Significant Deficiency in Internal Control over Compliance Instance of Noncompliance Authority’s Response & Actions Taken The Authority has taken substantial and measurable steps to address the prior backlog of annual reexaminations, including stabilizing third-party administration and implementing earlier and more structured reexamination processes. As a result of these efforts, all reexaminations identified during the audit period were ultimately completed, and all households were confirmed eligible with accurate housing assistance payments prior to the end of FY2025. The Authority’s current procedures—such as initiating reexaminations 150 days in advance, conducting weekly monitoring, and coordinating closely with property management and service providers—have significantly improved overall performance and strengthened operational consistency. The remaining instances of untimely reexaminations reflected in the audit are largely attributable to tenant non-responsiveness and timing factors associated with the audit sample period, during which a portion of cases were still in process despite being actively worked on and subsequently completed. These results do not fully reflect the progress achieved or the Authority’s current operational status. The Authority maintains a tenant-centered approach to program administration, ensuring that eligible households are not unnecessarily terminated due to documentation delays (this is especially important with the Authority being in shortfall which does not allow for voucher reinstatements). This approach is supported by structured outreach, enforcement protocols, and documented follow-up actions. The Authority continues to work diligently with its third-party HCV contractors, city department partners, onsite service providers and property management companies to ensure timely recertification of all assisted households. At the same time, the Authority has strengthened internal controls to better align tenant flexibility with HUD timeliness requirements. The Authority continues to enhance oversight, tracking, and contractor accountability to ensure sustained compliance with HUD standards. The enhanced oversight and monitoring resulted in SEMAP fiscal year end 9/30/2025 with High Performer status, and current performance trends show the Authority is well positioned to maintain SEMAP High Performer status for the current fiscal year. Specifically for SEMAP Indicator 9 for Annual Reexamination, the Authority achieved 5 out of 10 points for fiscal year end 9/30/2025, which was an improvement from the prior fiscal year of 0 out of 10 points, and currently trending in a positive direction to achieve 10 out of 10 points for FY2026. The corrective actions outlined below are designed to ensure that tenant-related delays are minimized, documented, and managed in a way that prevents the recurrence of this material weakness. To address this finding and in accordance with the Authority’s Administrative Plan and HUD rules and regulations, the Authority has already implemented the following actions starting fiscal year 2023-24: For the Project-Based program: Two project-based households were cited for late re-exams in relation to finding 2025-001. Prior to this year’s audit, those households were identified and brought into compliance prior to the end of FY2025. In addition to the actions taken in last year’s corrective action plan for finding 2024-002, the Project-Based Voucher Program has begun: 􀁸 Scheduling second notice in-person appointments for households who do not return the Annual Re-examination package in the required timeframe from the first mailing. 􀁸 Maintaining a live shared log of delinquent Annual Re-examinations which the property managers have access to. 􀁸 Including resident services and property management in the intent to terminate process to emphasize the importance of compliance and provide direct support to the resident. 􀁸 Streamlining Annual Re-examinations for senior and/or disabled households with fixed incomes through the triennial process. 􀁸 Scheduling and completing on-site visits for senior-disabled sites and non-restricted sites with large numbers of families out of compliance. 􀁸 Continuing to review discrepancies between the Authority’s System of Record and PIH Information Center, the official database of HUD. For the Tenant-Based Program: Two tenant-based households were cited for late re-exams in relation to finding 2025-001. Prior to the end of FY2025, each household was brought into compliance and had their annual reexaminations completed. In addition to the actions taken in last year’s corrective actions plan for finding 2024-002, the Tenant-Based Program has begun: 􀁸 Updating the administrative plan to allow for verification of documents to be dated with 120- days of submittal instead of 60-days which allows more flexibility and less likelihood of needing additional items from the client. 􀁸 Tracking annual reexaminations for each assigning housing specialist the moment packets are mailed and throughout the process, both through individual tracking sheets and the Authority's Customer Relations Management system. Housing Authority 2025 Corrective Action Plan Page 4 of 6 􀁸 Tracking late re-exams on the management level on a monthly basis and following up with the individual housing specialists. 􀁸 Utilizing case managers for special programs to assist with outreach and completion of the paperwork. 􀁸 Reviewing previous annual reexamination and HUD’s supplemental 92006 form to determine if the household has identified an individual to contact for assistance with the annual reexam and contacting them. 􀁸 Continuing to review discrepancies between the Authority’s System of Record and PIH Information Center, the official database of HUD. Anticipated Implementation Date September 30, 2026 Name(s) and Title(s) of Contact Person(s) Responsible for Correction Action HCV Contractors Kendra Crawford, Director of Housing Operations

2025-001 U.S. Department of Housing and Urban Development Housing Voucher Cluster - 14.871 Section 8 Housing Choice Vouchers and 14.879 Mainstream Vouchers Condition and Criteria: The Agency must inspect the unit leased to a family initially and at least biennially to determine if the unit meets Housing Quality Standards (HQS). The Agency did not perform an initial inspection for one unit in our sample. Cause: Procedures are in place for performing inspections, but this year the client converted some units at this location to project-based housing. It was assumed all the units were inspected at once in 2024 before the client began switching them over. Due to human error, the inspection was not performed during the fiscal year. Effect: There is a possibility that sanctions could be imposed if they do not perform inspections as required by the program. Context: The Agency is aware of the requirement and has a supervisory position to oversee the inspectors and their processes and ensure the Agency is complying with the requirements. CORRECTIVE ACTION PLAN RESPONSE: This complex, along with many others on our program, are now scheduled on one day, to prevent the inspectors from having to make multiple trips to each complex every month. This complex is inspected every May and if ever someone asks for a special inspection. Anticipated completion date: 9/30/26 Responsible party: Michelle Worthington, Section 8 Housing Director Please contact Vicky Pritchett, Finance Director at 573-213-4811 extension #10102 with questions regarding this plan.

We have implemented a plan for proper training to make sure everyone is aware of HUD rules regarding family eligibility. We will complete a quarterly audit of randomly selected files to ensure we are adhering to HUD rules. We will ensure staff monitors eligibility for each resident within the required time frame.

In order to keep cash as accurate as possible, we will work to clear interfund as often as possible. With upcoming development revenue that we will see come in over the next 1-2 years on the non profit side, we will work to prioritize returning funds to the Public Housing Operating Funds. To prevent co-mingling of cash, we will begin a plan to break apart the funds for each program - Spencer, COCC, 3rd and 11th. Each quarter, we access payroll allocations to better reflect employees’ use of time and actual costs incurred by program and by LITC property. Public Housing and COCC training is planned that all finance staff will attend to make sure proper HUD procedures, rules, and guidelines are followed. The plan is to reduce the receivable down to $-0- as soon as possible and within 5 years.

Corrective Action Plan – Single Audit Finding Entity Name: Brocton Housing Development Company, Inc. Audit Period: For the year Ended September 30, 2025 Finding Reference Number: 14.157 Federal Program: Supportive Housing for the Elderly (Section 202) 1. Audit Finding Summary Describe the audit finding and the specific noncompliance identified by the auditor. In accordance with 24 CFR 891.400(e), a separate interest-bearing project fund account shall be maintained in a depository or depositories which are members of the Federal Deposit Insurance Corporation or National Credit Union Share Insurance Fund and all tenant payments, charges, income and revenues arising from project operation or ownership shall be deposited to this account. 2. Root Cause Explain the underlying reasons for the finding, such as process gaps, training issues, or lack of controls. Subsequent to the initial rental assistance contract, changes to HUD regulations resulted in the requirement that the project fund account be an interest-bearing account. This change was an oversight by the Company's management. 3. Corrective Actions Action Item: Use an interest-bearing account for project funds Responsible Person: Chief Financial Officer Completion Date: TBD Status: In process 4. Monitoring Plan Describe how the implementation of corrective actions will be monitored and evaluated. Management inquired with the bank and deemed the cost outweighs the benefit due to the fees charged for an interest bearing account exceeding the interest that would be earned. 5. Contact Information Name: Aaron Hejmowski Title: Chief Financial Officer Phone: 716-884-7791 Email: ahejmowski@belmonthousingwny.org

The Authority will submit its SEMAP certification to HUD within sixty days of its fiscal year-end. Ms. LaTonya Coley-McKenley, Executive Director, has assumed the responsibility of executing this corrective action by November 29, 2026.