Finding 1164420 (2024-004)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-12-10
Audit: 373851
Auditor: COHNREZNICK LLP

AI Summary

  • Core Issue: The property owner failed to provide the required number and types of HOME units to tenants, violating HUD regulations.
  • Impacted Requirements: Compliance with 24 CFR Part 92 and the "Next Available Unit" rule was not maintained, risking eligibility for low-income tenants.
  • Recommended Follow-Up: Management should ensure adherence to established procedures to maintain compliance with HUD guidelines for HOME units.

Finding Text

Finding No. 2024-004 - Uniform Guidance Compliance Requirement Code: E-Eligibility - Significant Deficiency HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 HOME Investment Partnership Program Entity Identifying Number Initial Year Finding instances Passed-through Clark County: McCallister Village (Fruit Valley) 2010-HOME-0H0 2010 1 Total instances 1 Criteria Each owner must comply with the requirements set forth in 24 CFR Part 92 regulations as outlined in the "Compliance in HOME Rental Projects: A Guide for Property Owners" published by HUD which requires the property to maintain the contracted number of HOME units as well as the designated splits in bedroom size and High Home/Low Home unit ratios. Condition The owner did not make available to HOME tenants the contracted number and type of HOME units. This is considered a temporary noncompliance as follows: "Next Available Unit" rule: The owner must rent the next comparable or smaller unit that becomes vacant to a low-income household. Temporary noncompliance: The unit is temporarily out of compliance with HOME requirements, but the property can regain compliance by following the "next available unit" rule. Unit conversion: If the owner fails to comply and rents a comparable vacant unit to a non-low-income tenant, the over-income unit loses its low-income status and the building's compliance is reduced. A two bedroom unit did become available in 2024 and this tenant was not relocated. Cause Management's policies with respect to maintaining the number and split of contracted HOME units were not consistently followed. Effect or Potential Effect The procedures for determining and maintaining the correct HOME units within the property were not applied. This could result in ineligible tenants occupying HOME designated units. Questioned Costs: Not applicable. Context In connection with the procedures applied to our HOME units testing, one of the five properties tested did not meet the contracted HOME units size portfolio (a tenant is over the max HOME income limit allowed)). Repeat Finding: No Recommendation Management should follow procedures in place to ensure consistent application and adherence to the requirements in accordance with the "Compliance in HOME Rental Projects: A Guide for Property Owners" published by HUD. Views of Responsible Officials ________________OPEN FOR REACH REPLY

Corrective Action Plan

Finding No. 2024-004 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition The owner did not make available to HOME tenants the contracted number and type of HOME units. This is considered a temporary noncompliance as follows: "Next Available Unit" rule: The owner must rent the next comparable or smaller unit that becomes vacant to a low-income household. Temporary noncompliance: The unit is temporarily out of compliance with HOME requirements, but the property can regain compliance by following the "next available unit" rule. Unit conversion: If the owner fails to comply and rents a comparable vacant unit to a non-low-income tenant, the over-income unit loses its low-income status and the building's compliance is reduced. A two bedroom unit did become available in 2024 and this tenant was not relocated. Corrective Action Plan A new review process is in placed to review the HOME units that will be re-classified the next time there is a vacant unit of the corresponding size/type.

Categories

Eligibility HUD Housing Programs Significant Deficiency

Other Findings in this Audit

  • 1164417 2024-001
    Material Weakness Repeat
  • 1164418 2024-002
    Material Weakness Repeat
  • 1164419 2024-003
    Material Weakness Repeat
  • 1164421 2024-005
    Material Weakness Repeat
  • 1164422 2024-006
    Material Weakness Repeat
  • 1164423 2024-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $1.76M
14.275 HOUSING TRUST FUND $1.63M
99.999 LOW INCOME HOUSING PRESERVATION AND RESIDENT HOMEOWNERSHIP ACT OF 1990-CAPITAL GRANT $964,955
14.195 SECTION 8 HOUSING ASSISTANCE PAYMENTS PROGRAM $597,560
14.155 MORTGAGE INSURANCE FOR THE PURCHASE OR REFINANCING OF EXISTING MULTIFAMILY HOUSING PROJECTS $510,266
21.000 SECTION 607(e ) OF THE NEIGHBORHOOD REINVESTMENT CORPORATION ACT, AS AMENDED $418,750
14.241 HOUSING OPPORTUNITIES FOR PERSONS WITH AIDS $380,000
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $221,798