Corrective Action Plans

Finding 2023-001: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Federal Assistance Listing Numbers: 14.871, 14.879, and 14.EHV Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility. Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 6,531 units. Of a sample size of seventy-seven (77) tenant files, the following was noted: - Section 214 citizen declaration form missing in 15 files - HUD 9887 consent to release information form missing in 2 files - Original application missing in 1 file - Annual inspection missing in 1 file - Lead based paint form missing in 4 files - Verification of income missing in 6 files Our sample size is statistically valid. Known Questioned Costs: 14.871 - Section 8 Housing Choice Vouchers - $36,728 14.879 - Mainstream Vouchers - $13,028 14.EHV - Emergency Housing Vouchers - $1,272 Cause: There is a material weakness in the Housing Voucher Cluster in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Housing Voucher Cluster is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Authority Response: The Authority accepts the recommendation of the auditor, and will make the several changes to its inspection process to ensure enforcement of Housing Quality Standards (or any subsequent replacement). Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Housing Voucher Cluster to ensure that established internal control policies are being followed on a timely basis. Shannon Koenig, executive director and CEO, is responsible for implementing this corrective action by December 31, 2024.

Late Submission Corrective action planned: Compliance calendar implemented; reports finalized at least 2 weeks before due date. Contact person: Candice Ivory, Executive Director. Anticipated completion date: June 1, 2025/ Ongoing Monitoring

SEMAP Supporting Documentation Corrective action planned: Revised control procedures and checklist system for future SEMAP submissions with backup file requirements. Updated ADMIN plan to enforce Quality Assurance procedure, to be performed quarterly. Contact person: Candice Ivory, Executive Director / Deputy Director Anticipated completion date: May 31, 2025/ Ongoing Monitoring

Tenant Files – Housing Choice Vouchers Corrective action planned: Staff retrained on HUD requirements. Standard audit process implemented for incoming and annual recertifications. Quarterly file reviews and a new checklist for income verification implemented. Contact person: Candice Ivory, Executive Director / Deputy Director Anticipated completion date: July 31, 2025/ Ongoing Monitoring

2023-004 Activities Allowed or Unallowed – Interprogram Activity Public and Indian Housing – CFDA Number 14.850 Other Matters, Questioned Costs Condition: The Authority has loaned monies from the Public and Indian Housing Program to the COCC. As of September 30, 2023 these loans totaled $349,352. Recommendation: The Authority should develop a plan based on budgeting and monitoring of COCC expenses to have the ability to reimburse funds to the Public and Indian Housing Program. Action Taken: To restore financial integrity and ensure proper use of COCC funds, the Authority will take the following actions: 1. COCC Optimization and Budget Reform: Develop and implement a proper, balanced COCC budget that reflects actual operating costs and allocates shared services appropriately. Establish budget accountability protocols, including monthly budget-to-actual reviews and variance reporting to the CFO, CEO, and Board. 2. Training and Capacity Building: Provide training for finance staff on COCC operations, HUD’s Asset Management model, and best practices for cost allocation and shared services. Engage external consultants to support financial modeling and long-term sustainability planning for RAD and LIHTC properties. 3. Shared Services Agreement: Formalize a Consulting and Shared Services Agreement to ensure that COCC services are appropriately billed and reimbursed by other programs. Monitor inter-program transactions to ensure compliance with HUD’s financial management requirements. 4. Salary Allocation and Cost Tracking: Conduct a salary allocation study to ensure that staff time is distributed adequately across programs. Implement time-tracking tools and cost allocation methodologies that align with HUD guidance and OMB Uniform Guidance. Effective Date: June 3, 2025 Contact Information Dr. Michael C. Threatt, Chief Executive Officer Sanford Housing Authority 317 Chatham Street Sanford, North Carolina 27330 (919) 776-7655

2023-003 Special Tests and Provisions – Wage Rate Requirements 14.872 Public Housing Capital Fund Material Weakness in Internal Control, Material Noncompliance Condition: Only one contract funded by the Capital Fund Program was awarded during the audit period above the small purchase threshold. The contract did not contain the required wage rate clause, and the Authority was not able to provide documentation showing that the contractor had submitted the required certified payrolls. Recommendation: We recommend that the Authority ensure the required wage rate clause is included in all contracts above $2,000 and that certified payrolls are being submitted and documentation retained. Action Taken: To address these deficiencies, the Authority will implement the following corrective action: 1. Staff Training: Provide targeted training for procurement, contract management, and asset management staff on Davis-Bacon wage requirements, certified payroll review, and labor compliance monitoring. Incorporate Davis-Bacon compliance into the Authority’s procurement and contract management SOPs. 2. Vendor Compliance Monitoring: Require all contractors and subcontractors to submit certified payrolls electronically. Establish a formal review process to verify wage classifications, hours worked, and compliance with prevailing wage rates. Conduct periodic wage interviews and maintain documentation in accordance with HUD and Department of Labor guidelines. 3. Payroll Analysis and Internal Controls: Assign a designated compliance officer or staff member to oversee wage rate compliance and maintain a centralized log of all Davis-Bacon projects. Implement a checklist and audit trail for each project to ensure all required documentation is collected and reviewed prior to payment authorization.

2023-001 Reporting – Late REAC Submission and Late OMB Data Collection Form Submission Section 8 Housing Voucher Cluster (Section 8): 14.871 Section 8 – Housing Choice Vouchers Material Weakness in Internal Control, Material Noncompliance Condition: The Authority’s audited Financial Data Schedule (“FDS”) filing was not submitted within the timeframes specified by HUD. The FDS filing was due by June 30, 2024, but the financials were not issued until June 3, 2025. The Authority was also required to submit the OMB Data Collection Form to the Federal Audit Clearinghouse (“FAC”) by June 30, 2024, but was not filed timely as the audit was completed on June 3, 2025. Recommendation: The Authority should ensure that they retain support for all required documentation and that it is organized and readily accessible. Storing documents electronically with frequent backups would help prevent loss of data from damage to any one location. Furthermore, the Authority should ensure that staff receives necessary training for proper document retention. Action Taken: To address the identified deficiencies and restore compliance with HUD requirements and the Trouble Recovery Agreement, the Authority will implement the following corrective actions: 1. Leadership and Governance Stabilization: Ensure that the new CEO is briefed on all relevant programs, financial updates, management, and strategic planning initiatives. Ensure that the Finance Committee, within the Board of Commissioners, continues to hold monthly meetings before all regular board meetings and monitors financial reporting, budget adherence, and audit readiness. Ensure that the Administrative Plan for the HCV Program is comprehensively updated to reflect current HUD regulations and strategies for program optimization. 2. Financial Staffing and Capacity Building: Maintain continuity in financial leadership by supporting the Interim CFO and ensuring adequate staffing, such as the new Staff Accountant in the Finance Department, to support audit preparation and HUD reporting. Develop a financial onboarding and training program for all new finance staff, with a focus on HUD systems (FDS, VMS, EPIC, LOCCS) and internal budget protocols. Ensure that Program and Finance Management staff of the HCV Program attend the HCV Financial Management and HCV Financial Accounting and Reporting sessions. 3. Budget Training and Accountability: Implement mandatory budget training for the Finance Department and the HCV Program Department, covering: Budget development and forecasting; Budget-to-actual variance analysis; HUD funding streams and eligible uses; Internal budget controls and documentation standards; Voucher Management System, FDS policies, and SOPs. Create an Accountability Chart for the Program and Financial Management of the HCV Program, outlining roles, responsibilities, and procedures for budget planning, monitoring, and reporting. Require monthly or biweekly meetings with budget reviews by department heads and mid-level managers, with variance explanations submitted to the CFO and CEO, and shared with the Board. 4. Fee Accountant Reinstatement and Optimize HCV Program Finances: Reinstate and formalize the partnership with BDO PHA Finance to support audit preparation, financial reporting, and staff training. Establish financial performance tracking, standard operating procedures (SOPs), contract compliance monitoring, and payment authorization protocols. 5. Technology and Data Management Improvements: Prepare the Chart of Accounts, Procure to Pay, and Voucher Management System (VMS), as well as the Two-Year Tool (TYT), and take other necessary financial steps to ensure a seamless transition from SACS to Reframe. Implement cloud-based storage and digital backup protocols to safeguard financial records and ensure continuity in the event of future disruptions. Establish a centralized digital archive for all financial documents, including budgets, invoices, contracts, and audit work papers. 6. Audit Readiness and Compliance Monitoring: Create an annual audit preparation calendar with clear deadlines for data collection, reconciliations, and internal reviews. Conduct monthly and quarterly internal audits to assess financial controls, procurement compliance, and budget adherence. Submit monthly and quarterly progress reports to HUD and the Board as part of the Troubled Recovery Agreement and internal HUD Recovery Strategic Plan, documenting improvements in financial management and audit readiness. 7. Transparency and Communication: Present monthly financial reports to the Board of Commissioners, including budget-to-actual comparisons and audit status updates. Publish an annual financial summary on the Authority’s website to promote transparency and public accountability

Name of auditee: Trinity Housing Corporation of Greeley HUD auditee identification number: 101-98145 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended October 31, 2023 CAP prepared by Name: Tashawndra Welch Position: Chief Financial Officer Telephone number: 901-435-7764 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Finding #2023-001 Comments on the Finding and Each Recommendation: For the year ended October 31, 2023, the Corporation paid management fees to the Agent in excess of the fees earned resulting in prepaid management fees of $8,370 at October 31, 2023. Action(s) taken or planned on the finding: The Corporation concurs with the finding and agrees with the auditor’s recommendation.

Views of Responsible Officials and Planned Corrective Actions: The Mississippi County Public Facilities Board has several findings in their past years audit. These findings were under the past administration that was let go on June 30th 2024. We were contacted by the board and took over on September 1st 2024 for a management contract. These findings will be corrected by the executive team that is managing the housing authority. We plan to have everything corrected and in place by July 1st 2026. This staff will follow all rules and regulations in the future and will bring everything up to date. Wixson Huffstetler, Executive Director 5/6/2025

Views of Responsible Officials and Planned Corrective Actions: The Mississippi County Public Facilities Board has several findings in their past years audit. These findings were under the past administration that was let go on June 30th 2024. We were contacted by the board and took over on September 1st 2024 for a management contract. These findings will be corrected by the executive team that is managing the housing authority. We plan to have everything corrected and in place by July 1st 2026. This staff will follow all rules and regulations in the future and will bring everything up to date. Wixson Huffstetler, Executive Director 5/6/2025

The Board and management are aware of the inadequate separation of accounting duties when reviewing the monthly operations and financial results of the District. As an ongoing mitigating control, at the board meetings management and the board members review the monthly check register of disbursements, interim financial reports, summary of cash and certificates of deposits held, and contract pay applications and construction project status as presented by the project engineer for review and approval by the Board.

Recommendation: Ideally, the City would hire the number of staff necessary to segregate all duties. However, we realize segregation of duties is not practical, if not impossible. Because of this internal control situation, the responsibility of the management is greatly increased because the City Council must rely on his/her knowledge of everyday operations to discover any material changes in the City’s financial position. Management’s Response: The City recognizes that the limited number of staff adds to the risk associated with the daily operations. To mitigate this risk, management has to take an active role in the day-to-day operations of the Business Office. They actively review all reconciliations and receipts to ensure they are posted to the accounting system properly.

The auditors reviewed 6 tenant files for initial admission criteria being met, such as Income calculations. Of the 6 files, 5 did not contain supporting documentation of how the income was calculated. Again, those staff are not present coming into FY2024. Of the 6 files reviewed, 3 also did not have 50058’s in the tenant file. And all 6 files could not be traced back to the waitlist to determine proper entrance to the program. In response to the tracking of the waitlist not being tracked on new admissions, there have not been any new HCV vouchers issued from the waitlist since the end of FY2022. RHA has an over utilization of voucher budget authority and has not issued new vouchers from that waiting list nor has RHA opened that waiting list up. RHA administration does not expect to open this waiting list in FY2024 nor FY2025. At the tail end of FY2023, RHA sent the PBV waiting lists over to the contracted third-party management company to track for RHA. Currently, that third-party management company is Allied Residential Management. Halfway through FY2024, RHA converted over to a different Housing Software which has better tracking reports than the prior software. Again, RHA has hired new staff and removed old staff that did not want to learn correct compliance procedures with the HCV department. RHA has a strong team coming into FY2025 now. FY2024 had staff in/out until we found good staff that wanted to learn and retain them.

Prior RHA staff were not ensuring that the Utility Allowance schedules were being completed correctly and matching up to the 50058, which made the HAP incorrect. Of the 40 tenant files sampled by the auditors, 29 files did not have correct utility allowances calculated; 9 files had 50058’s that did not agree with the HAP payments being paid to the landlords and 22 files had rents that did not fall between 90% and 110% of the HUD FMR for the areas. Staff have been replaced and there are no original HCV staff left that were at RHA when the new CEO took over on March 1, 2023. Staff are consistently being trained every week for a minimum of 1 hour a week for 52 weeks out of the year. An HCV Director has been added to supervise the HCV Staff and audits of the files are being completed by the Director of Housing along with the CEO. These issues should be limited and not commonly found by Auditors during future audits.

Prior RHA administrative staff were not getting the PHA’s Single Audit completed nor submitted by the deadline. RHA was 3 years behind when the new CEO took over on March 31, 2023. FY2020, FY2021 and FY2022 were not completed and submitted. By the time that these three were caught up, completed and submitted, that pushed FY2023 Audit to be late. The audit for FY2023 should be completed by the end of April 2025 and then we will be on task to start FY2024 in May and completed by the deadline of September 30, 2025. Then, RHA will stay on task and get these completed within its deadline timeline.

Prior RHA staff that were handling the Inspection Scheduling were not abating the HAP when units failed and did not keep up or track the amount of time between failed inspections and re-inspections to ensure that it was completed timely. As of September 2024, we have a new Landlord Liaison, who is also a new Inspection Coordinator, that is tracking everything on a spreadsheet. Part of FY2024 was not monitored for Failed Inspections and Abatements but is now being tracked and monitored by the Inspection Coordinator and her supervisor, the Director of Facilities and Development along with the CEO. FY2025 should be completely clean of issues dealing with HQS Compliance.

The Housing Authority will implement a standardized process for documenting rent reasonableness across all tenant files, including those from the Emery County merger, and will explore automated tools to streamline the determination and documentation process. Staff will also receive training to ensure compliance with the requirements moving forward.

Finding no.: 2023-001 Contact person(s) responsible: Kymberly Horner, Executive Director Corrective action planned: The late filing was due to significant turnover in the Fiscal Department beginning in 2021. Work was delayed as new staff required training on processes in conjunction with working through a large backlog of work in the Department that was necessary to complete in order to prepare the Financial Statements for audit. In addition to adapting its processes in the Fiscal Department to ensure the continuance of proper separation of duties and adherence to policies and procedures during staff transitions, Management is developing procedures to hire, train, and retain Fiscal Staff to help stabilize the department to ensure the work can continue in the event of unexpected staff turnover. Management is aware of the deadline related to the submission of the data collection form and anticipates that these measures will have a positive impact on the timeliness of future submissions. Anticipated completion date: October 2023

Federal Award Findings: Finding 2023-004 Reporting – Late REAC Submission and Late OMB Data Collection Form Submission 14.155 Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects 14.195 Section 8 Housing Assistance Payments Program Material Weakness in Internal Control – Material Noncompliance Condition: The Organization’s annual financial statement data was not submitted within the timeframes specified by HUD. The financial statement data was due by March 31, 2024, but the financials were not issued until May 20, 2025. The Organization was also required to submit the OMB Data Collection Form to the Federal Audit Clearinghouse (“FAC”) by September 30, 2024, but was not filed timely as the audit was completed on May 20, 2025. Auditor’s Recommendation: We recommend that the Organization make every effort to submit its annual financial statement data within the timeframe specified by HUD. Action Taken: The Organization has maintained contact with HUD and prioritized submitting the annual financial statement data after they were informed it was late. Effective Date: May 20, 2025 Contact Information: Kristy Hust, Director of Operations Northside Mental Health Center, Inc. Management Agent 12512 Bruce B Downs Blvd Tampa, FL 33612 (813) 977-8700

Finding Reference Number: 2023-003 Condition: In September 2023, HUD suspended its HAP subsidy to the Organization due to noncompliance regarding the tenant recertifications requirements under the HAP Contract. Recommendation: We recommend that control systems are put in place to ensure there are regular reviews of tenant files to enable management to identify deficiencies and provide training, guidance, and procedures to eliminate errors and issues of noncompliance in the future. Reporting views of responsible officials Our Just Future, on behalf of The Pines Housing, Inc., both concurs with these findings and agrees with auditor recommendations. Completion date or proposed completion date: December 18, 2024 Action(s) taken or planned on the finding OJF has completed all overdue tenant recertifications. To prevent future delinquent recertifications, OJF will conduct a root cause analysis by January 15, 2025 to identify gaps in the current process. Once gaps are identified, procedures will be updated to provide clear guidelines and timelines to staff. By February 15, 2025, OJF will implement a tracking system for tenant recertifications, including supervisory review of all tenant files. By March 15, 2025, relevant OJF staff will undergo training on compliance with HUD requirements. This will include the creation of a compliance calendar. OJF’s senior management team and board of directors will monitor progress towards these goals. Progress reports will be drafted no later than April 15, 2024

Finding Reference Number: 2023-002 Condition: As of December 12, 2024, management was unable to provide tenant income documents for 2 tenant files of 7 tenant files sampled out of the population (66 total tenant files). Management was unable to provide tenant security deposit documents for all 3 move-ins and move-outs sampled out of the population (9 total move-ins and 13 total move-outs during the audit period). Recommendation: We recommend that control systems are put in place to ensure there are regular reviews of tenant files to enable management to identify deficiencies and provide training, guidance, and procedures to eliminate errors and issues of noncompliance in the future. Reporting views of responsible officials Our Just Future, on behalf of The Pines Housing, Inc., both concurs with these findings and agrees with auditor recommendations. Completion date or proposed completion date: December 18, 2024 Action(s) taken or planned on the finding To address this finding, OJF will take the following actions: 1. Implement regular tenant file reviews at least semi-annually beginning January 15, 2025 a. Responsible party: OJF asset management director and property management portfolio manager 2. Develop a mandatory training program on compliance requirements for property management site staff to follow by February 15, 2025 a. Responsible party: OJF asset management director and property management portfolio manager 3. Revise and distribute existing tenant file management procedures by February 15, 2025 a. Responsible party: OJF asset management director and property management portfolio manager 4. Establish a monitoring and feedback system by March 15, 2025 for site staff to seek guidance on or report challenges of file management so that advice can be given and/or corrective action taken a. Responsible party: OJF asset management director and property management portfolio manager 5. Conduct quarterly management reviews beginning 4/15/2025 to discuss and evaluate the effectiveness of above actions a. Responsible party: OJF asset management director and property management portfolio manager

The Public Housing Authority of Butte will contract with the Certified Public Accounting firm to assist with timely submission of the FY 2024 unaudited Financial Data Schedule. This will provide su icient time for the audit to get completed by the audited FASSPHA deadline.

2023-003- REPORTING Material Weakness/Noncompliance Auditee’s Response and Planned Corrective Action WHA will develop written accounting policies and a deliverables calendar to eliminate late submissions moving forward. We will incorporate this into training for all staff and work with the fee accountant and Auditors to make sure deadlines are realistic, coordinated and attainable. Planned Implementation Date of Corrective Action: Immediately Person Responsible for Corrective Action: Maria DeMarco, President of DeMarco Management Corporation

2023-002- ELIGIBILITY Material Weakness/Noncompliance Auditee’s Response and Planned Corrective Action We follow HUD guidelines where required and Untimely recertifications are typically not within the control of the Housing Authority. Encompassing HUD guidelines, the recertification process for tenants begins 90 days prior to the recert date, but if tenants do not provide all the requested information, the recertification will be delayed until the information is provided, tenant is converted to a market rate rent, or we begin the termination process for termination of the voucher. We will continue to follow the HUD process for the management of the Housing Choice Voucher Programs/Mainstream voucher programs. Planned Implementation Date of Corrective Action: Immediately Person Responsible for Corrective Action: Maria DeMarco, President of DeMarco Management Corporation

Finding Reference Number: 2023-002 Description of Finding: The security deposits, residual receipts, and replacement reserve were not properly established in separate bank accounts, and the required monthly deposits to the replacement reserve were not made. Statement of Concurrence or Nonconcurrence: Management agrees with this finding. Corrective Action: Management has set up separate bank accounts and continues to make the required deposits. Name of Contact Person: Kimalee Williams, CEO - Faith Asset Management, LLC, (860) 528-5000, kimalee@faithassetmgt.com Projected Completion Date: December 15, 2024