Corrective Action Plans

Stoneboro Development Corporation Stoneboro, Pennsylvania November 18, 2024 U.S. Department of Housing and Urban Development City Crescent Building 10 South Howard Street Baltimore, Maryland 21201-2505 Stoneboro Development Corporation respectfully submits the following Corrective Action Plan for the year ended June 30, 2023. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Post Office Box 19608 Greensboro, North Carolina 27419-9608 The findings from the year ended June 30, 2023 Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding 2023-001: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Market Interest Rate, Assistance Listing #14.155 Recommendation: We recommend that management and the board of directors work to improve occupancy and submit special claims requests to HUD for vacant units to improve cash flow to ensure timely payment of the mortgage payments and escrow deposits. Action Taken: We agree with Finding 2023-001 described in the accompanying schedule of findings and questioned costs. Effective June 1, 2023, the board of directors contracted with a new management company. The new management company is increasing advertising to fill vacancies and submitting special claims requests to improve the cash flow. Additionally, the new management company is working with the lender to make additional mortgage payments and escrow deposits as cash flow permits. Finding 2023-002: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Market Interest Rate, Assistance Listing #14.155 Recommendation: We recommend the board of directors and management ensure that the audit and data collection forms are completed timely and the data collection form and required reported package are submitted electronically to the FAC each fiscal year going forward. Action Taken: We agree with Finding 2023-002 described in the accompanying schedule of findings and questioned costs. Effective June 1, 2023, the board of directors contracted with a new management company. The new management company will ensure the data collection forms are submitted electronically to the FAC each fiscal year. Finding 2023-003: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Market Interest Rate, Assistance Listing #14.155 Recommendation: We recommend the board of directors and management ensure that the annual financial reports to HUD are submitted by the required due dates. Action Taken: We agree with Finding 2023-003 described in the accompanying schedule of findings and questioned costs. Effective June 1, 2023, the board of directors contracted with a new management company. The new management company will ensure the annual financial reports to HUD are submitted once the audits are back on track with the scheduled due dates. Finding 2023-004: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Market Interest Rate, Assistance Listing #14.155 Recommendation: We recommend that management and the board of directors work to improve occupancy and submit special claims requests to HUD for vacant units to improve cash flow to ensure timely monthly deposits to the replacement reserve account are made as required. Action Taken: We agree with Finding 2023-004 described in the accompanying schedule of findings and questioned costs. Effective June 1, 2023, the board of directors contracted with a new management company. The new management company is increasing advertising to fill vacancies and submitting special claims requests to improve the cash flow. Finding 2023-005: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Market Interest Rate, Assistance Listing #14.155 Recommendation: We recommend that management ensure supporting documentation is maintained for all disbursements from project operations. Action Taken: We agree with Finding 2023-005 and the recommendation described in the accompanying schedule of findings and questioned costs. Effective June 1, 2023, the board of directors contracted with a new management company. The new management company will ensure supporting documentation is maintained for all disbursements from project operations. Finding 2023-006: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Market Interest Rate, Assistance Listing #14.155 Recommendation: We recommend that management ensure supporting documentation is maintained for all cash receipts of the project. Action Taken: We agree with Finding 2023-006 and the recommendation described in the accompanying schedule of findings and questioned costs. Effective June 1, 2023, the board of directors contracted with a new management company. The new management company will ensure supporting documentation is maintained for all cash receipts of the project. If HUD has questions regarding this corrective action plan, please call (412) 246-9213. Sincerely yours, Trisha Jester Director of Multifamily Housing Arbors Management, Inc. Managing Agent

FEDERAL AWARD FINDING Federal Agency: Program Title: Assistance Listing Number: Award Number: Award Period: All Awards reported on the schedule of expenditures of federal awards. All Awards reported on the schedule of expenditures of federal awards. All Awards reported on the schedule of expenditures of federal awards. All Awards reported on the schedule of expenditures of federal awards. All Awards reported on the schedule of expenditures of federal awards. 2023-007 - Late Submission of Single Audit Reporting Package (Significant Deficiency) Statement of Condition The Single Audit reporting package and related data collection form for the year ended June 30, 2023, was not submitted within nine months after the end of the audit period. Criteria In accordance with 2 CFR 200.512, the audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Internal control systems over financial reporting are to prevent late submission of the Single Audit reporting package, including the data collection form to the Federal Audit Clearinghouse. Cause The submission of the Single Audit reporting package was delayed due to a forensic audit needed to be completed before the single audit could be completed. Effect Management became aware of the improprieties and hired an independent forensic investigator. The forensic investigator identified improper disbursements to ineligible participants along with other disbursements that required further research, inconclusive, insufficient, unverified, and LLC discrepancy disbursements. Management also notified the State of New Jersey Department of Community Affairs Office of Auditing. Recommendation Management should review the internal controls in place over the filing of the data collection form and reporting package so it can be submitted timely to the Federal Audit Clearinghouse. View of Responsible Officials Management agrees with the finding and has provided the accompanying corrective action plan. Corrective Action: Management believes that the extraordinary circumstances that lead to the delayed submission of the 2023 fiscal audit reporting package are a one-time occurrence, future submission should not be affected. Management expects that the 2024 fiscal audit reporting package and data collection form will be submitted timely to the Federal Audit Clearinghouse. Projected Completion Date As mentioned, the actions note above have been implemented. Contact Person Robert Waite, Controller 856-342-4186; robert.waite@camdendiocese.org

Finding 2023-003: For the year ended June 30, 2022, the Corporation did not submit audited financial statements to the Federal Audit Clearinghouse within 30 days after receipt of the auditor's report on October 6, 2022. The audited financial statements were submitted to the Federal Audit Clearinghouse on July 5, 2024. Comments on the Finding and Each Recommendation: The Corporation should submit audited financial statements to the Federal Audit Clearinghouse within the time frames required. Action(s) taken or planned on the finding: The audited financial statements have been submitted to the Federal Audit Clearinghouse.

Due to turnover of the Commission's accounting staff, the Commission was unable to have the annual audit completed within the required timeframe, and subsequently was also late in submission of the FAC report. The Commission has hired internal staff to help with the audit preparation and contracted with an accounting firm that has provided the Commission a CPA to conduct audit preparation and other financial services as requested. The Commission will work on getting financial information in a timely fashion and submit the reporting package in accordance with the guidelines. Anticipated completion date: November 30, 2024.

Finding 2023-003 Deadline for Federal Single Audit – Reporting - Noncompliance and Significant Deficiency in Internal Control Over Compliance Name of Contact Person: Sarah J. Villalon, CFO Planned Corrective Action: Management agrees with the finding and plans to establish processes and procedures to ensure the audit is completed timely and the reporting package is submitted within the required timeframe. Anticipated Completion Date: March 31, 2025

MANAGEMENT’S CORRECTIVE ACTION PLAN Finding 2023-001: Late submission of December 31, 2023 audit report – Federal Filing Federal Program: ALN 10.664 and 10.902 Criteria: The Corporation is required to file its audit report each year to the Federal Audit Clearinghouse within nine months after the end of fiscal year in accordance with 34 CFR 200.512. Condition: The Corporation did not file its December 31, 2023 report to the Federal Audit Clearinghouse within nine months after the end of fiscal year. Cause: The Corporation underestimated the time required to gather necessary information for the audit due to a lack of recent experience with single audits, leading to delays in completion. Effect: The Corporation did not meet the submission requirements as set forth by 34 CFR 200.512. Recommendation: We recommend the Corporation closely monitors this important submission requirement to avoid missing the deadline. Management’s Response: Management will take corrective action to make sure the audit report is submitted to the Federal Audit Clearinghouse in compliance with the submission requirements.

The City transitioned auditors in 2023 and as a result was unable to complete its audit timely. The City intends to meet the September 30, 2025 filing deadline for its December 31, 2024 Federal Single Audit

Corrective Action Plan We have scheduled the start of 2024 audit to begin early April 2024 which gives us time to complete the process and file the report with the Federal Audit Clearinghouse on time. Person(s) Responsible: Yomi Ibrahim Timing for Implementation: 2024 Audit Yomi _Ibrahim, VP of Finance______ Client, Title

Name of Contact Person James Starks, Chief Financial Officer Corrective Action Plan Starting Point has pushed the date of the audit to an early start date. We have revised and implemented stronger internal control and procedures to ensure compliance with and timely submission of a complete and accurate Data Collection Form and Single Audit Report package to the Federal Audit Clearinghouse with the appropriate timeframe of nine months after the end of the audit period. Proposed completion date: November 1, 2024

We are working in implementing adequate internal control procedures in order to comply with the submission of all required information for the Single Audit for Fiscal Year 2024.

2023-001: Data Collection Form and Single Audit Reporting Package Response: Transitions in WCSC financial personnel during and after year-end resulted delays to the audit process for the audit period ending September 30, 2023. To address this problem, WCSC hired a fiscal consultant in August 2022 to oversee the fiscal office, prepare and complete all grant reports, and to coordinate all fiscal audits. WCSC also hired a full-time bookkeeper in October 2022 to conduct day-to-day financial transactions and to assist with audit and grant reporting. WCSC has already engaged its Auditors to conduct the FY2024 audit, which will be completed by April 30th, 2025. Estimated Completion Date: April 30th, 2025 Contact: Carolyn Forno, Fiscal Officer

The Board of Directors hired Gorman Management Company (GMC) on March 1, 2024, to operate the property, Ardmore Village. GMC has extensive experience in the on-site and financial management of properties like Ardmore Village. Specifically, GMC has procedures in place to maintain compliance with the regulations applicable to the Section 8/202 program and the FHA Section 223f program. GMC is well versed with CFR §200.512 (single audit data collection form), HUD Handbooks 4350.3, 4370.2 and 4381.5. GMC manages over 40 properties that have similar reporting and auditing requirements. All of the issues related to these findings will cure through GM C's policies and procedures.

Views of Responsible Officials: Management agrees and has drafted a corrective action plan following to address the issue. Corrective Action Plan: (unaudited) We have designated staff and established timelines to ensure timely completion of reporting to all stakeholders when we have to file with the Federal Audit Clearinghouse Data Collection Form.

Corrective Actions Taken or Planned: ▪ Taken: This finding was a result of staff turnover and Center on Halsted has put in place an established relationship with an external accounting firm (Sikich), that will help create stability and support in all financial processes including grant reconciliation. This updated contractual agreement & relationship occurred on March 1, 2024. ▪ Planned: Center on Halsted leadership will ensure proper documentation, internal controls, and processes that will support a timelier audit. This includes an organization-initiated internal audit for the Center on Halsted processes that will stress test our ability to produce accurate supporting documentation and allows us to build more effective and efficient processes prior to our annual audit. This will be led by the Senior Director of Finance, Reginald Walker, in partnership with Sikich. Anticipated completion date: December

The Alliance in partnership with the BGCA Fiscal Team will enhance the process to comply with the reporting requirements for timely completion of the audit.

Recommendation: Marshall Jones recommends that the Organization establish a process to close their year-end books in a timely manner and begin the audit well in advance of the filing deadline for the data collection form and reporting package. Views of Responsible Officials: Management of BGCCG acknowledges the finding and concurs with the recommendation. Response of Responsible Officials: To continuously improve BGCCG’s Accounting and Financial Reporting, workflow, and internal controls, BGCCG has begun the process to transition the back-office accounting providers from part-time status to full-time status to sufficiently accommodate the needs of the Organization. BGCCG will employ a full-time Chief Finance & Administrative Officer (CFAO), preferably with CPA/CGMA certification, and strong analytical and financial modeling and forecasting skills as well as deep knowledge of GAAP for nonprofits. This pivotal role will provide strategic direction to ensure the financial health of the Organization while driving innovative financial solutions. The CFAO will oversee all financial and accounting operations of the Organization, including the creation and execution of sound financial policies, procedures and internal controls, budgeting, accounting, cash and debt management, audits, investments, tax compliance, and weekly Accounting and Finance reporting to the CEO and Board Finance Chair. The CFAO will report directly to the CEO. This position will be employed on or before December 31, 2024. BGCCG will also employ a full-time Finance Manager (FM) with commensurate experience that demonstrates exemplary strategic and financial acumen. The FM will be responsible for intermediate-level finance and accounting functions such as general ledger/account maintenance, timely account reconciliation, accounts payable, accounts receivables, data processing, payroll processing, and reporting to the CFAO. The FM will report directly to the CFAO. This position will be employed on or before December 31, 2024. Upon the hiring and on-boarding of the CFAO and FM, BGCCG will immediately begin the process of updating its Financial Management & Accounting Control Policies & Procedures to further strengthen BGCCG’s internal controls. Corrective Action Plan: Upon the hiring and on-boarding of the new full-time CFAO and FM, management of BGCCG will work closely with the CFAO and FM to immediately implement a process to close out its 2024 fiscal year-end books in a timely manner. BGCCG will seek to close out its 2024 fiscal year-end books on or before March 30, 2025, and will seek to begin the 2024 auditing process on or before June1, 2025, well in advance of the filing deadline for the data collection form and reporting package. Acknowledged, Phillip Bryant President & CEO

GENESIS II APARTMENTS, INC. Mullins, South Carolina CORRECTIVE ACTION PLAN October 18, 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, 2023. Bernard Robinson & Company, L.L.P. Post Office Box 19608 Greensboro, North Carolina 27419-9608 Audit period: Year ended June 30, 2023 The findings from the Schedule of Findings and Questioned Costs for the year ended June 30, 2023 are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding 2023-001: 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 2023-001 described in the accompanying schedule of findings and questioned costs. The new management company will ensure the annual financial statements are submitted once the audits are back on track with the scheduled due dates. Finding 2023-002: 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 audit and data collection forms are completed timely and the data collection form and required reporting package are submitted electronically to the FAC each fiscal year going forward. Action Taken: We agree with Finding 2023-002 described in the accompanying schedule of findings and questioned costs. The new management company will ensure the data collection forms are submitted electronically to the FAC each fiscal year. If HUD has questions regarding this plan, please call (803) 808-3966. Sincerely yours, Reese Quick, President Southern Development Management Company, Inc.

End of 1st quarter: Close out the prior year financials by developing checklist and a streamlined process. Within the 2nd quarter: Establish a timeline with the audit firm to provide audit request listing and fieldwork start date. Work with all staff involved to submit all documents to the auditors by the due dates within the timeline. Within the 3rd quater: Engage with the audit firm to ensure timely audit report completion. Ongoing: Monitor monthly closing to ensure deadlines are met to ensure timely start of the audit fieldwork.

The Alliance will implement more stringent internal controls and administrative oversight with respect to reporting requirements and deadlines to audit is timely completed.

The Alliance will implement more administrative oversight with respect to reporting requirements and deadlines to make sure all audits are completed timely.

Due to no fault of Southern Workforce Board, Inc., and circumstances beyond the previous CAP's control, the audit report for the period ending 6/30/2023 was not completed as required. Upon notification of prior audit firm closing, Southern Workforce Board, Inc. performed an immediate procurement by soliciting a Request for Proposal to 13 audit firms. Upon completion of the procurement, Michael Green, CPA was selected to perform the 6/30/2023 audit as soon as their schedule would allow. Upon successful completions of 6/30/2023 audit report, the audit process for the period ending 6/30/2024 will proceed on time. Southern Workforce Board, Inc. will ensure in the future that the audit firm selected will be able to perform the planned audits in a timely manner in the future.

Significant Deficiency and Noncompliance over Reporting Repeat Finding: Yes Auditee’s Corrective Action Plan: The City has purchased Workday, an Enterprise Resource Planning (ERP) system, and implemented the software with the assistance of Accenture consultants. Although Workday is “live” as of August 2022, the City is currently working to refine the software and fully utilize functionality. The Workday grants modules requires the grant funding source be defined prior to grant approval and fields are available for the AL titles and numbers and sub-recipients’ information. The implementation of the Workday grants modules centralizes much of the grant management function by requiring the agencies to upload the grant documents into Workday. Prior to the completion of the SEFA, the City instituted training sessions with the agencies to ensure that the reporting is understood by the agencies, with special emphasis on subrecipient payments being reported properly. Additionally, the City will give access to the grant report upon which the SEFA is based. The City will keep a check list to ensure that all agencies respond to the grant certification to ensure that all agencies review the grant data. Based on FY 23 training and feedback the City is expanding that training schedule to begin with agency preparation in November 2024. Additionally, the corrective actions for grants have included citywide trainings in the fourth quarter FY24 led by the Grants Management Office and BAPS on key grant accounting functions in Workday; including for example, Billing, Creating an Award, Sub Recipients with each training having between 50-70 agency grant staff attending. Contact Person: Michael Moiseyev, Chief Financial Officer, Baltimore City Completion Date: December 2024

Finding 2: Delayed Single Audit Delivery Background: The delivery of our single audit has been delayed due to staffing challenges and the need for improved coordination. With our organization’s expansion post-pandemic, increased hiring has required administrative staff to adapt to complex compliance requirements. Corrective Actions: 1. Audit Timeline Adjustment o Action: Begin the audit process no later than April each year to allow sufficient time for completion and submission. o Responsibility: Executive Team and Audit Committee o Timeline: Adjust the audit schedule for the upcoming year immediately. 2. Training for Administrative Staff o Action: Provide targeted compliance and audit process training for administrative staff to improve their proficiency and efficiency. o Responsibility: Administration o Timeline: Start training sessions within 60 days. 3. Regular Check-ins with Auditors o Action: Schedule regular monthly check-ins with auditors to ensure alignment on timelines and address potential issues early. o Responsibility: Finance Department o Timeline: Implement monthly check-ins starting [insert date]. 4. Resource Allocation o Action: Assess and allocate additional resources to support the audit process, ensuring staff have the necessary tools and support. o Responsibility: Administration o Timeline: Complete resource assessment within 60 days. ________________________________________ Conclusion AYUDA, INC. is committed to addressing these findings with urgency and transparency. By implementing the corrective actions outlined above, we aim to strengthen our financial management and compliance processes, ensuring these issues do not recur. We appreciate the auditors' feedback and are eager to demonstrate our improvements in the upcoming audit cycle. Approval: ________________________________________ Miguel Chacon Co-Executive Director

Corrective Action Plan October 29, 2024 Person responsible: Fernando Soto, President / CEO Fiscal Year Ended December 31, 2023 Section III – Federal Awards Findings and Questioned Costs Item 2023 – 001 Federal Assistance Listing Number: 93.914 HIV Emergency Relief Project Grants – Public Health Solutions Condition The Organization’s Data Collection Form submission to the Federal Audit Clearinghouse was not filed on time within nine months of the end of its fiscal year. Views of Responsible Officials and Corrective Action Although a new audit firm was engaged to complete the December 31, 2022, financial statements audit, and the necessary staffing changes were made to ensure filing of the December 31, 2023, was completed within nine months of the end of the fiscal year, additional time was needed to complete accurate fiscal records for the year ended December 31, 2023. Monthly closings and fiscal records reconciliations for the year ending December 31, 2024, are timely being conducted. Timely filing of the Data Collection form for the year ended December 31, 2024 is anticipated.

Finding 2022-001—Reporting The administrative staffing turnover BAERI experienced was detrimental to our ability to meet the reporting deadline for the 2022 audit. Moving forward, BAERI will ensure that our audit report and SF-SAC form are submitted to the Federal Audit Clearinghouse within nine months after the end of the audit period. Corrective Action Plan for Finding 2022-001—Reporting BAERI has taken the following steps in order to meet the reporting and deadline requirements outlined in 2 CFR 200.512 moving forward: 1. Implement policies and procedures to ensure that the internal documentation needed for our annual audit is easily accessible by finance staff and not onerous for staff to compile for the auditor. 2. Hire and train additional finance staff in order to implement the above mentioned policies and procedures needed to allow for a smooth, timely audit.