Finding Text
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 the following deficiencies: Two out of two lease files for new tenants tested had EIV reports generated outside of the 90 day period; Three out of ten lease files for existing tenants tested had EIV reports generated outside of the 120 day period or no EIV ran; One out of ten lease files for existing tenant tested had different rent amounts on the rent roll and the 50059 form. Cause Management’s policies with respect to the maintenance of tenant leases 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 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 Identification as a Repeat Finding This is a repeat finding. Recommendations Management should establish procedures and monitor compliance with those procedures to ensure that 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: Z. Other. View of Responsible Officials Management agrees with the findings and has implemented the policies below and will continue to train and connect our team members with the in-house HUD Compliance Specialist for support. 1. Move in EIV’s – All move in files will be sent to our in-house compliance department and Franklin Group have an EIV specialist how follows and tracks all moves for accuracy for all move files and the EIV specialist also sends out the 90-day reminders for all move in. 2. Existing Tenant EIV – It is the policy that all existing tenant EIV & 120-day reports are run per the 4350 guidelines. The Community Manager for Renaissance Gardens has been provided the HUD Trainings and have noted on her daily task reminder from One Site to pull all reports as required. The Regional Manager is required during monthly visits to spot check at least 5 existing tenants. Finding Resolutions Status: Resolved