Special Tests and Provisions – Material Weakness in Internal Controls over Compliance (Replacement Reserve Disbursement – HUD Approval Requirement) Management Response Management acknowledges that a disbursement of $15,000 was made from the replacement reserve account without obtaining prior written approval from HUD, as required under the Capital Advance Regulatory Agreement. Management recognizes that appropriate controls were not in place to prevent disbursement of restricted reserve funds without required approval, resulting in noncompliance. Management has initiated communication with HUD to disclose the transaction and request guidance on the appropriate resolution. The organization will comply with all directives issued by HUD and will continue to follow up as necessary to ensure timely resolution. Corrective Actions Implemented / To Be Implemented • A formal control will be implemented requiring documented written HUD approval prior to any disbursement from the replacement reserve account. • All reserve disbursements will require documented HUD approval prior to processing and will be subject to Controller review to ensure compliance with HUD requirements. • Replacement reserve accounts will be formally designated as restricted funds within internal financial procedures. • A formal policy governing replacement reserve disbursements will be established. • Alternative funding sources will be used when HUD approval is not available. • Training will be provided to relevant staff on HUD requirements and reserve controls.Training Training on reserve account procedures will be conducted by May 1, 2026, with refresher training annually. Responsible Staff: Controller – Oversight of compliance Chief Executive Officer (CEO) – Final accountability Implementation Date: Corrective actions related to implementation of review controls will be implemented immediately. Resolution will follow HUD guidance.