Finding 1164471 (2024-002)

Material Weakness Repeat Finding
Requirement
P
Questioned Costs
-
Year
2024
Accepted
2025-12-11

AI Summary

  • Core Issue: Missing required documentation in tenant files and failure to make timely replacement reserve deposits.
  • Impacted Requirements: Compliance with HUD regulations for tenant eligibility documentation and timely reserve deposits.
  • Recommended Follow-Up: Establish procedures and internal controls to ensure all documentation is maintained and deposits are made on time.

Finding Text

Program U.S. Department of Housing and Urban Development (HUD) – Supportive Housing for Persons with Disabilities (Section 811) and Project Rental Assistance, Assistance Listing No. 14.181. This finding was partially reported as finding 2023-001 in the prior year. Condition/Context A haphazard sample of three tenant files out of twenty-four (not a statistically valid sample) were selected for testing and the required documentation to determine eligibility, as required by the HUD regulations, could not be located as follows:  For one of the files, Form HUD-50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures was not provided.  For one of the files, there was no verification of income by a third party provided.  For all of the files, there was no signed move-in/move-out inspection form provided. Additionally, our testing indicated that the required deposits to the replacement reserve account had not been made for the last quarter of the Corporation’s fiscal year for any tenants. Criteria Tenant files and all required documents should be completed and maintained as required by HUD requirements and replacement reserve deposits need to be made timely. Cause There were no procedures in place to ensure that all tenant files were properly completed and maintained or ensure that replacement reserve deposits were made. Effect Inadequate tenant file documentation and lack of timely replacement reserve deposits has resulted in the Corporation’s inability to comply with the HUD Regulatory Agreement. Recommendation We recommend the Corporation establish procedures and internal controls to ensure that all required documentation is maintained, and all required reserve deposits are made timely, in accordance with HUD requirements. Finding 2024-002 Program U.S. Department of Housing and Urban Development (HUD) – Supportive Housing for Persons with Disabilities (Section 811) and Project Rental Assistance, Assistance Listing No. 14.181. This finding was partially reported as finding 2023-001 in the prior year. Condition/Context A haphazard sample of three tenant files out of twenty-four (not a statistically valid sample) were selected for testing and the required documentation to determine eligibility, as required by the HUD regulations, could not be located as follows:  For one of the files, Form HUD-50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures was not provided.  For one of the files, there was no verification of income by a third party provided.  For all of the files, there was no signed move-in/move-out inspection form provided. Additionally, our testing indicated that the required deposits to the replacement reserve account had not been made for the last quarter of the Corporation’s fiscal year for any tenants. Criteria Tenant files and all required documents should be completed and maintained as required by HUD requirements and replacement reserve deposits need to be made timely. Cause There were no procedures in place to ensure that all tenant files were properly completed and maintained or ensure that replacement reserve deposits were made. Effect Inadequate tenant file documentation and lack of timely replacement reserve deposits has resulted in the Corporation’s inability to comply with the HUD Regulatory Agreement.

Corrective Action Plan

2024-002: Section 811, Assistance Listing No. 14.181 Three tenant files were selected for testing and the required documentation to determine eligibility, as required by the HUD regulations, could not be located as follows: • One of the files was missing Form HUD-50059, Owner’s Certification of Compliance. • One of the files was missing verification of income by a third party. • All three of the files were missing signed move-in/move-out inspection forms. Additionally, our testing indicated that the required deposits to the replacement reserve account had not been made for the last quarter of the Corporation’s fiscal year for any tenants. Recommendation: We recommend the Corporation establish procedures and internal controls to ensure that all required documentation is maintained, and all required reserve deposits are made timely, in accordance with HUD requirements. Action Taken: Management concurs with this recommendation. Since assuming property management on June 1, 2025, ULREDC has conducted a tenant file audit. All property management staff have been properly trained to ensure compliance with certification, documentation, and inspection requirements. Missing documentation, including Form HUD-50059, income verifications, and leasing inspections, is being corrected. Replacement reserve deposits were delayed because properties were not cash flowing. As leasing stabilizes, deposits will resume and be verified once RealPage is fully active. RealPage will serve as the compliance and record-retention platform. Quarterly internal compliance reviews will be instituted to confirm file accuracy and documentation completeness. We are committed to compliance and accuracy as required by the U.S. Department of Housing and Urban Development. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please contact Dr. Hawkins at shawkins@ulr.org.

Categories

HUD Housing Programs

Other Findings in this Audit

  • 1164470 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $1.93M
14.181 SUPPORTIVE HOUSING FOR PERSONS WITH DISABILITIES $67,347