Finding Text
Finding No. 2024-001; Federal Assistance Listing Number 14.157
Criteria
Tenant lease files are required to be maintained and tenant eligibility determined in accordance
with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing
Programs.
Condition
In connection with our lease file review, we noted that three out of four tenants' income
verification was not performed timely with the use of the HUD Enterprise Income Verification
("EIV").
Cause
Management's policies with respect to recertifications and eligibility and the maintenance of
tenant lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of
Subsidized Multifamily Housing Programs were not consistently followed.
Effect or Potential Effect
The procedures for determining tenant recertification eligibility and maintaining tenant lease files
were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy
Requirements of Subsidized Multifamily Housing Programs. This could result in units being
rented to ineligible tenants or errors in the rent subsidies paid by HUD.
Questioned Costs
N/A
Context
Three out of four tenants' tenants tested did not have the EIV run timely.
Identification as a Repeat Finding
Yes: 2023-001
Recommendation
Management should establish procedures and monitor compliance with those procedures to
insure that recertifications are performed timely and signed, tenant eligibility is correctly
determined and that tenant lease files are properly maintained in accordance with the
requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily
Housing Programs.
Auditor Noncompliance Code: E - Eligibility for Uniform Guidance
Finding Resolution Status: Unresolved
Views of Responsible Officials and Planned Corrective Actions:
REACH has policies in place to complete certifications in a timely manner but due to staffing
shortages and tenant noncompliance issues the Property continued to have issues with timely
completion of income certifications in 2024. As new staff are brought onboard training is
provided and annual HUD training is completed by all staff. Management will continue to
coordinate and provide assistance to on-site staff to ensure that the properties are in
compliance.