Corrective Action Plans

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Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Unauthorized Withdrawal from Replacement Reserve Account Recommendation: Conduct training with all those who are involved with the Project to review HUD requirements for making withdrawals from the Replacement Reserve a...
Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Unauthorized Withdrawal from Replacement Reserve Account Recommendation: Conduct training with all those who are involved with the Project to review HUD requirements for making withdrawals from the Replacement Reserve and create a documentation process for requests and approvals. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: o conduct training to review all HUD requirements regarding the process for withdrawing funds from the Replacement Reserve Account. Name(s) of the contact person(s) responsible for corrective action: Stacy Lawson, Chief Financial Officer, Jacob Schimming, Project Accountant. Planned completion date for corrective action plan: October 31, 2024
Contact person(s) responsible: Tiffany Tucker, Fiscal Director Corrective Action Planned: All Janus’ Rental Assistance Programming will be consolidated under two experienced Program Directors for whom Rental Assistance administration is a primary program component. Policies and procedures for obta...
Contact person(s) responsible: Tiffany Tucker, Fiscal Director Corrective Action Planned: All Janus’ Rental Assistance Programming will be consolidated under two experienced Program Directors for whom Rental Assistance administration is a primary program component. Policies and procedures for obtaining required documentation have been updated and include a mandatory documentation checklist submitted together with all initial payment requests, and a new policy has been created for the rare circumstances when youth are housed outside our primary service area of Multnomah, Clark or Cowlitz counties requiring Program Director sign off prior to payment. Anticipated Completion Date: November 15, 2024
Corrective Action Management has issued a formal response to HUD’s Findings dated August 12, 2024, outlining specific corrective actions and considers the corrective actions satisfactorily implemented as of November 5, 2024. The Authority’s Executive Director, Shannon Eady has assumed the responsib...
Corrective Action Management has issued a formal response to HUD’s Findings dated August 12, 2024, outlining specific corrective actions and considers the corrective actions satisfactorily implemented as of November 5, 2024. The Authority’s Executive Director, Shannon Eady has assumed the responsibility of continued execution of the corrective actions.
Planned Corrective Action Finding: The Organization did not have adequate and effective controls over compliance in place as it relates to applying the sliding fee discount. We found two (2) instances where an individual was not appropriately charged based on the sliding fee policy in place. Crite...
Planned Corrective Action Finding: The Organization did not have adequate and effective controls over compliance in place as it relates to applying the sliding fee discount. We found two (2) instances where an individual was not appropriately charged based on the sliding fee policy in place. Criteria: Uniform Guidance requires that controls are implemented to ensure the Organization is in compliance with special tests and provisions. This includes charging the appropriate sliding fee discount based on the Organization's policy. Corrective Response: Before the audit testing, management discovered there were situations where the sliding fee wasn’t being correctly applied. Discounts were being calculated by staff because the system calculations were wrong. The Sliding Fee Scale system rebuild has undergone successful testing and is now in the process of being implemented. Management has suggested adjustments to the sliding fee scale to guarantee accurate calculation of patient balances. The board has already approved those changes, and the updated Sliding Fee Scale involves removing the percentage-based charges and setting fixed payments for nominal and minimum fees per visit. The system rebuild for the Sliding Fee Scale has already been tested and is being rolled out. Alternatively, management has proposed changes to the sliding fee scale to ensure that the system will be able to properly calculate the amount due from patients by taking away the percentage due and making the nominal and minimum charges a flat amount per visit. These policy changes will make the application of the sliding fee scale easier to manage for the system, staff, and patients. Anticipated Completion Date 12/31/2024 Responsible Contact Person CFO/Revenue Cycle Director
The property manager will be responsible for the calculation. The income verification documentation will be reviewed and signed off by the property manager supervisor which is the COO for Comprehend.
The property manager will be responsible for the calculation. The income verification documentation will be reviewed and signed off by the property manager supervisor which is the COO for Comprehend.
Finding Number: 2024-002 Condition: The Corporation did not send HUD the approved residual receipts recapture requested by HUD in a reasonable period of time. The Corporation did not have a control in place to track that these funds were properly remitted to HUD. Planned Corrective Action: Managemen...
Finding Number: 2024-002 Condition: The Corporation did not send HUD the approved residual receipts recapture requested by HUD in a reasonable period of time. The Corporation did not have a control in place to track that these funds were properly remitted to HUD. Planned Corrective Action: Management is in the process of improving controls to ensure that all approved residual receipt recaptures requested by HUD are timely remitted to HUD. Contact person responsible for corrective action: Fikru Nigusse, CFO Anticipated Completion Date: June 30, 2025
Corrective Action Plan Audit Finding Number: 2024-001 – Capital Funds Draws for Operations Agency: Public Housing Capital Fund Responsible Person, Title: Shara LeBeau, Executive Director Completion date: 1/1/2024 Agency Response: Concur Corrective Action Plan: Management concurs with the recommen...
Corrective Action Plan Audit Finding Number: 2024-001 – Capital Funds Draws for Operations Agency: Public Housing Capital Fund Responsible Person, Title: Shara LeBeau, Executive Director Completion date: 1/1/2024 Agency Response: Concur Corrective Action Plan: Management concurs with the recommendation and has already implemented controls in January 2024 that operation draws (BLI 1406) are obligated & expensed the same day the voucher is submitted to LOCCS.
SECTION II AND SECTION III - FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AND FINANCIAL STATEMENTS AUDITS (CONTINUED) FINDING No. 2024-004: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Rental Housing Projects, ALN 14.155 Recommendation: The Projec...
SECTION II AND SECTION III - FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AND FINANCIAL STATEMENTS AUDITS (CONTINUED) FINDING No. 2024-004: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Rental Housing Projects, ALN 14.155 Recommendation: The Project should implement procedures to monitor the expiration of HUD required documents to ensure timely preparation and approval. Action Taken: Management is in the process of obtaining a new management agent certification. If the Oversight Agency for Audit has questions regarding the plan, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips Irene Phillips CFO
View Audit 329376 Questioned Costs: $1
SECTION II AND SECTION III - FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AND FINANCIAL STATEMENTS AUDITS FINDING No. 2024-003: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Rental Housing Projects, ALN 14.155 Recommendation: The Project should co...
SECTION II AND SECTION III - FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AND FINANCIAL STATEMENTS AUDITS FINDING No. 2024-003: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Rental Housing Projects, ALN 14.155 Recommendation: The Project should comply with HUD regulations for executing the required rent change as of its effective date when approved. Action Taken: New manager has been trained to implement gross rent changes immediately and new procedures have been implemented to ensure timely changes.
View Audit 329376 Questioned Costs: $1
FINDING No. 2024-002: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Rental Housing Projects, ALN 14.155 Recommendation: Management should implement procedures to ensure that the correct amount is deposited into the replacement reserve account each month. Action T...
FINDING No. 2024-002: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Rental Housing Projects, ALN 14.155 Recommendation: Management should implement procedures to ensure that the correct amount is deposited into the replacement reserve account each month. Action Taken: Escrows were underfunded due primarily to a high increase in insurance rates. The Project will fund the shortfall. Escrow balances will be reviewed on a regular basis to ensure adequate funding.
Oversight Agency for Audit, Jacksonville Towers, Inc., respectfully submits the following corrective action plan for the year ended March 31, 2024. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067. Audi...
Oversight Agency for Audit, Jacksonville Towers, Inc., respectfully submits the following corrective action plan for the year ended March 31, 2024. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067. Audit period: April 1, 2023 through March 31, 2024 The findings from the March 31, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers in the schedule. SECTION III - FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2024-001: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Rental Housing Projects, ALN 14.155 Recommendation: The Project should implement procedures to ensure that tenant eligibility is verified, tenant files are properly maintained, and tenant signatures are obtained in a timely manner. Action Taken: Staff training has been provided with additional HUD training inclusive of EIV reporting and included in monthly report procedures.
Continuum of Care – Assistance Listing No. 14.267 Recommendation: The Organization has not met its matching requirement for the NC0045 grant or the NC0221 grant. The Organization has determined that these awards have become too costly to administer and is now in discussions with HUD regarding the o...
Continuum of Care – Assistance Listing No. 14.267 Recommendation: The Organization has not met its matching requirement for the NC0045 grant or the NC0221 grant. The Organization has determined that these awards have become too costly to administer and is now in discussions with HUD regarding the objective of transferring these award programs to another entity. We recommend that the Organization continue these discussions with HUD in order to end its responsibilities for award programs that it has determined it is unable to comply with. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will continue working with HUD to transfer these award programs to another entity that has more capacity of complying with all requirements. As of July 2024, grant NC0045 was transferred to Brick Capital. The Organization is continuing to work with HUD to transfer the NC0221 grant. Name(s) of the contact person(s) responsible for corrective action: Tameka Gunn, President and Chief Executive Officer Planned completion date for corrective action plan: March 2025
GENESIS II APARTMENTS, INC. Mullins, South Carolina CORRECTIVE ACTION PLAN November 6, 2024 U. S. Department of Housing and Urban Development Charles Bennett Federal Building 400 West Bay Street, Suite 1015 Jacksonville, Florida 32202 Genesis II Apartments,...
GENESIS II APARTMENTS, INC. Mullins, South Carolina CORRECTIVE ACTION PLAN November 6, 2024 U. S. Department of Housing and Urban Development Charles Bennett Federal Building 400 West Bay Street, Suite 1015 Jacksonville, Florida 32202 Genesis II Apartments, Inc., HUD Project No. 054-EE081-WAH, respectfully submits the following Corrective Action Plan for the year ended June 30, 2024. Bernard Robinson & Company, L.L.P. Post Office Box 19608 Greensboro, North Carolina 27419-9608 Audit period: Year ended June 30, 2024 The findings from the Schedule of Findings and Questioned Costs for the year ended June 30, 2024 are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding 2024-001: U.S. Department of Housing and Urban Development, Supportive Housing for the Elderly (Section 202), Assistance Listing #14.157 Recommendation: We recommend the board of directors and management ensure that the annual financial reports to HUD are submitted by the required due date. Action Taken: We agree with Finding 2024-001 described in the accompanying schedule of findings and questioned costs. The management company will ensure the annual financial statements are submitted once the audits are back on track with the scheduled due dates. If HUD has questions regarding this plan, please call (803) 808-3966. Sincerely yours, Reese Quick, President Southern Development Management Company, Inc.
JUBILEE SENIOR HOMES, INC. 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN October 30, 2024 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development Jubilee Senior Homes, Inc. respectfully submits the following corrective action pla...
JUBILEE SENIOR HOMES, INC. 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN October 30, 2024 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development Jubilee Senior Homes, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Lindquist von Husen & Joyce LLP 301 Howard Street, Suite 850 San Francisco, CA 94105 Audit period: July 1, 2023, to June 30, 2024 The findings from the June 30, 2024, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS-FINANCIAL STATEMENT AUDIT None noted. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS 2024-001 Compliance over Eligibility Requirements to Perform Annual Recertification - Assistance Listing No. 14.157. Program - Section 202 Supportive Housing for Elderly Persons Significant Deficiency Recommendation: Jubilee Senior Homes should develop an operating plan in order to ensure that recertifications are performed timely each year, despite of staff shortages. Action Taken: Senior management now recognizes that additional resources must be utilized during periods of progressive discipline with a frontline employee, to ensure the timely completion of recertifications. A new Manager was hired for Jubilee Senior Homes through an internal transfer and this individual is in the process of catching up on all needed paperwork as a top priority. The John Stewart Compliance Department will perform a 100% file audit upon completion of the outstanding certifications. Additionally, the assigned Regional Manager is performing monthly spot checks on files and reviewing a recertification status report for monitoring of progress and ongoing compliance. The property management company has implemented a roving support team that will assist managers who are struggling to meet their deadlines, ensuring compliance and helping to maintain performance standards moving forward. The roving support team was established in 2024, partly due to our commitment to ensure HUD deadlines are met. The property management company has also implemented monthly monitoring at their corporate office by the Property Management Document Information Specialist and HUD Secure Coordinator. This individual is monitoring monthly submissions to TRACs by all properties, and flagging underperformance on annual recertifications in addition to other HUD key performance metrics. The report of data from TRACs is circulated to Regional Managers, Directors, and senior leadership every month. If the Department of Housing and Urban Development has questions regarding this plan, please call Zelda Ryan, Corporate Controller, at (510) 841-4410 x304#. Sincerely, Eric Knecht, CFO Resources for Community Development
3250 SACRAMENTO HOUSING, INC. 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN October 30, 2024 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development 3250 Sacramento Housing, Inc. respectfully submits the following corrective acti...
3250 SACRAMENTO HOUSING, INC. 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN October 30, 2024 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development 3250 Sacramento Housing, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Lindquist von Husen & Joyce LLP 301 Howard Street, Suite 850 San Francisco, CA 94105 Audit period: July 1, 2023, to June 30, 2024 The findings from the June 30, 2024, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS-FINANCIAL STATEMENT AUDIT None noted. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS 2024-001 Compliance over Eligibility Requirements to Perform Annual Recertification - Assistance Listing No. 14.157. Program - Section 202 Supportive Housing for Elderly Persons Significant Deficiency Recommendation: 3250 Sacramento should develop an operating plan in order to ensure that recertifications are performed timely each year, despite of staff shortages. Action Taken: Senior management now recognizes that additional resources must be utilized during periods of progressive discipline with a frontline employee, to ensure the timely completion of recertifications. A new Manager was hired for 3250 Sacramento through an internal transfer and this individual is in the process of catching up on all needed paperwork as a top priority. The John Stewart Compliance Department will perform a 100% file audit upon completion of the outstanding certifications. Additionally, the assigned Regional Manager is performing monthly spot checks on files and reviewing a recertification status report for monitoring of progress and ongoing compliance. The property management company has implemented a roving support team that will assist managers who are struggling to meet their deadlines, ensuring compliance and helping to maintain performance standards moving forward. The roving support team was established in 2024, partly due to our commitment to ensure HUD deadlines are met. The property management company has also implemented monthly monitoring at their corporate office by the Property Management Document Information Specialist and HUD Secure Coordinator. This individual is monitoring monthly submissions to TRACs by all properties, and flagging underperformance on annual recertifications in addition to other HUD key performance metrics. The report of data from TRACs is circulated to Regional Managers, Directors, and senior leadership every month. If the Department of Housing and Urban Development has questions regarding this plan, please call Zelda Ryan, Corporate Controller, at (510) 841-4410 x304#. Sincerely, Eric Knecht, CFO Resources for Community Development
Management’s Response- New Management has taken over responsibilities as of May 2024 and will review and implement stronger policies and procedures pertaining to tenant files
Management’s Response- New Management has taken over responsibilities as of May 2024 and will review and implement stronger policies and procedures pertaining to tenant files
View Audit 329150 Questioned Costs: $1
Contact Person Nichole Bristlin, Executive Director. Corrective Action Plan Management plans on adding a signed lease step to the quality control worksheet to ensure signed leases are included in all files. Planned Completion Date for CAP June 30, 2025
Contact Person Nichole Bristlin, Executive Director. Corrective Action Plan Management plans on adding a signed lease step to the quality control worksheet to ensure signed leases are included in all files. Planned Completion Date for CAP June 30, 2025
Independence Housing Authority (IHA) received an audit finding for failing to properly document the reinspection of a failed HQS inspection. During the previous year, IHA had 3 contractors inspecting for HCV and not using the internal software which led to multiple issues including missing documenta...
Independence Housing Authority (IHA) received an audit finding for failing to properly document the reinspection of a failed HQS inspection. During the previous year, IHA had 3 contractors inspecting for HCV and not using the internal software which led to multiple issues including missing documentation. IHA hired a full time, HQS/NSPIRE certified inspector in August 2023 to ensure HQS inspections are completed in a timely manner and within regulation. IHA has also purchased the BOB.AI software which monitors and schedules upcoming initial, reinspection’s, annual and special inspection requests. Inspection letters are generated in this program as well as results/finding items. Inspections spreadsheets have been created for tracking purposes by the HCV Director. The inspector reviews his weekly schedule with the HCV Director for accuracy.
Independence Housing Authority (IHA) also received an audit finding for failing to calculate the utility allowances correctly. This was caused by previous management instructing staff to provide an appliance credit to all tenants at move-in. All staff members have been retrained in the proper proced...
Independence Housing Authority (IHA) also received an audit finding for failing to calculate the utility allowances correctly. This was caused by previous management instructing staff to provide an appliance credit to all tenants at move-in. All staff members have been retrained in the proper procedures for calculations and allowances. All HCV program specialists have received rent calculations certifications and have been instructed to correct any prior errors immediately. The Compliance Officer is also doing random tenant file audits on a monthly basis. This should make finding
Independence Housing Authority (IHA) received an audit finding for failing to clear Interprogram Due To/Due From Activities from the financials at fiscal year-end. In order to remedy the situation, IHA has revised its internal monthly checklist to ensure that interfund transfers are cleared on a mon...
Independence Housing Authority (IHA) received an audit finding for failing to clear Interprogram Due To/Due From Activities from the financials at fiscal year-end. In order to remedy the situation, IHA has revised its internal monthly checklist to ensure that interfund transfers are cleared on a monthly basis to prevent the accumulation of interfund receivables and payables. IHA will also strengthen its cash management practices by reviewing and reconciling inter-program balances on a monthly basis. This process will include a detailed review to ensure that program-level cash components are accurate, and resources are being used exclusively for their intended purposes.
The Authority continues to strengthen its procedures surrounding tenant rent calculations at initial and recertification reviews in the Low-Income Housing Program. A second review, conducted by a Public Housing Manager, will be required for all such calculations. All Public Housing staff will be req...
The Authority continues to strengthen its procedures surrounding tenant rent calculations at initial and recertification reviews in the Low-Income Housing Program. A second review, conducted by a Public Housing Manager, will be required for all such calculations. All Public Housing staff will be required to maintain a Rent Calculation Certification on a bi-annual basis. For the file in question, a correction was made with an effective date of May 1, 2024.
View Audit 328981 Questioned Costs: $1
Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. C...
Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. Christina Beard, Executive Director, will be responsible to implement this corrective action by March 31, 2025.
View Audit 328914 Questioned Costs: $1
Condition: The District did not comply with the required standards of Support of Salaries and Wages, because employees who time was charged to federal grants during fiscal year PAR, were completed for May and June before the time had occurred. Criteria: The distribution of the salaries and wages o...
Condition: The District did not comply with the required standards of Support of Salaries and Wages, because employees who time was charged to federal grants during fiscal year PAR, were completed for May and June before the time had occurred. Criteria: The distribution of the salaries and wages of employees are to be supported by either time certification or personnel activity reports or equivalent documentation which meets the standards in Subsection 8.h (5) of the OMB Circular A-87 Part 225 Appendix B. The certification for employees who work on one cost objective must be prepared at least semi-annually. Personnel activity reports (PAR) for employees who work on multiple activities or cost objectives must be prepared at least monthly and meet certain prescribed standards, such as accounting for the employee’s total compensation, and reflecting an after-the-fact distribution of the actual activity of each employee. The costs of such compensation are allowable to the extent that they satisfy that specific requirement of this and other appendices under 2 CFR Part 225, and that the total compensation for the individual employees: (3) is determined and supported as provided in Subsection h. (8. Compensation for Personal Services. A. (3)). Questioned Costs: There are no questioned costs. Effect: It is more likely that the extent of effort charged to the various cost objectives may not be representative of the related time devoted to the respective cost objectives. Cause: District did not have a system in place to ensure the District complied with the required standards of Support of Salaries and Wages for an employee who needed to complete monthly or semi-annual certifications and that the time allocation on the grant is reported accurately. Corrective Action: A comprehensive tracking plan has been implemented to ensure the costs objectives associated with each employee for each period is tracked and PAR is returned for the corresponding period. Corrective Action Implemented by: The Corrective Action will be implemented by Robert Farrier, School Business Administrator in conjunction with Treasurer Kelly Kilmer. Corrective Action Implementation Date: This corrective action plan has already been implemented on 9/15/24.
Finding 2024-001 - Moving To Work Demonstration Tenant Files - Eligibility - Internal Control over Tenant Files- Noncompliance and Significant Deficiency Moving To Work Demonstration – subsidy ALN14.881 Corrective Action Plan: Effective November 1, 2024, the Authority will implement a Compliance...
Finding 2024-001 - Moving To Work Demonstration Tenant Files - Eligibility - Internal Control over Tenant Files- Noncompliance and Significant Deficiency Moving To Work Demonstration – subsidy ALN14.881 Corrective Action Plan: Effective November 1, 2024, the Authority will implement a Compliance Coordinator position for the review of tenant files on a regular basis. The Compliance Coordinator will be under the immediate direction of the Finance Director, so as to be independent of the public housing and voucher programs. Person Responsible: Alan Zais, Executive Director Anticipated completion Date: March 31, 2025
Findings - Financial Statement Audit: None Findings - Federal Award Programs Audit: U.S. Department of Housing and Urban Development Finding 2024-001: Section 223(f) Loan Program, CFDA 14.155 Recommendation: Make the required delinquent deposit to the replacement reserve account and ensure that al...
Findings - Financial Statement Audit: None Findings - Federal Award Programs Audit: U.S. Department of Housing and Urban Development Finding 2024-001: Section 223(f) Loan Program, CFDA 14.155 Recommendation: Make the required delinquent deposit to the replacement reserve account and ensure that all future deposits are made as required by the Regulatory Agreement. Action Taken: Management will fund delinquent deposit amount as soon as possible.
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