We concer with the auditors' finding that the project did not have adequate internal controls in place over tenant eligbility determination process per HUD's guidelines. While HANDS has internal policies and procedures for review of tenant certifications, the compliance position has been vacant and...
We concer with the auditors' finding that the project did not have adequate internal controls in place over tenant eligbility determination process per HUD's guidelines. While HANDS has internal policies and procedures for review of tenant certifications, the compliance position has been vacant and never properly functioned as it should. The CEO, Matthew Good, and the Director of Community Management, Cathy Consilgio, had decided prior to the audit engagement that a third party would be contracted to review applicant files prior to move-in for all HUD subsidized properties. (We have used AJ Johnson to review/approve LIHTC/HOME files for several years.) Employee training had been put on hold due to the upcoming HOTMA changes, and as the dates for HOTMA were pushed, training lagged. Our policy is as follows: once a new hire Property Manager or Assistant Property Manager completes the initial 90-day probationary period, they will be scheduled for formal HUD occupany training, and formal LIHTC training if it applies to their portfolio. Current employes will receive training bi-annually, which may include training that occures during the PAHMA conferences. All employes receive Fair Housing Training at least bi-annually, with new employees being scheduled for the first available training after their initial 90-day probationary period. The tracking sheet will be updated as training occurs, and any certificates earned will be kept on file.