Finding 1154177 (2024-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
$1
Year
2024
Accepted
2025-09-23

AI Summary

  • Core Issue: The project failed to make required monthly deposits of $6,198 to the replacement reserve, totaling $74,376 for the year.
  • Impacted Requirements: This noncompliance violates the PRAC contract, leading to underfunding of the replacement reserve.
  • Recommended Follow-Up: Management should review the budget for potential cuts, seek a loan from the owner, and request a waiver from HUD for the missed deposits.

Finding Text

Finding No. 2024-003 – Special Tests and Provisions U.S. Department of Housing and Urban Development Federal Program Name: Section 202 Supportive Housing for the Elderly Assistance Listing Number: 14.157 Criteria: The Section 202 Project Rental Assistance Contract (PRAC contract) requires that the project make monthly deposits to its replacement reserve. Condition: During the year ended September 30, 2024, the project did not make the required monthly deposits to the replacement reserve in the amount of $74,376. The project is required to make monthly deposits to the reserve in the amount of $6,198 per month, or $74,376 for the year. Cause: The project does not generate sufficient cash flow to make the required monthly deposits, due to significant delays in receipt of PRAC funds for over a year. Effect or Potential Effect: Failure to make monthly payments resulted in an underfunding the replacement reserve and a violation of the PRAC subsidy contract. Questioned Costs: Twelve months of missing replacement reserve deposits of $6,198 per month - $74,376 Context: Due to significant delays in receipt of PRAC funds for over a year, management suspended making the deposits to the reserve until PRAC funding was replenished. Management also borrowed funds from the replacement reserve which funds were repaid during the year ended September 30, 2024 once past-due PRAC funds were received. Identification as a Repeat Finding: No Recommendation: Management should review the project budget to determine if nonessential costs can be cut (or request a loan from the owner) to ensure that the replacement reserve is funded in accordance with the terms of the regulatory agreement. Management should obtain from HUD a waiver for the missing replacement reserve deposits if possible. If not granted, management should fund the missing deposits. Auditor Noncompliance Code: N – Replacement reserve deposits Finding Resolution Status: In process Views of Responsible Officials: Due to significant delays in receipt of PRAC funds for over a year, management suspended making the deposits to the reserve until PRAC funding was replenished. Management also borrowed funds from the replacement reserve which funds were repaid during the year ended September 30, 2024 once past-due PRAC funds were received.

Corrective Action Plan

Project Legal Name: Evangeline Booth Residence, Inc., A Florida Corporation HUD Project No.: 063-EE011-WAH Audit Firm: CohnReznick LLP Period covered by the audit: 10/1/2023 – 9/30/2024 Corrective Action Plan prepared by: Name: Lee Auvenshine Position: Territorial Legal Director-General Counsel (THQ legal) Telephone Number: 404-728-6700 Finding 2024-003 Comments on the Finding and Each Recommendation The auditee agrees that replacement reserve deposits were not made. This was a result of significant delays in PRAC funding that severely affected cash flows. Action(s) Taken or Planned on the Finding Once the PRAC issues were corrected our cash flows have improved to allow us to make past due deposits. We will also reach out to our HUD account executive to discuss possible waiving of past due deposits.

Categories

Questioned Costs Special Tests & Provisions HUD Housing Programs Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1154173 2024-003
    Material Weakness Repeat
  • 1154174 2024-004
    Material Weakness Repeat
  • 1154175 2024-005
    Material Weakness Repeat
  • 1154176 2024-006
    Material Weakness Repeat
  • 1154178 2024-004
    Material Weakness Repeat
  • 1154179 2024-005
    Material Weakness Repeat
  • 1154180 2024-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.157 Supportive Housing for the Elderly $3.59M