Special Tests – Significant Deficiency in Internal Controls over Compliance (Utility Allocation – Section 811 Program) Management Response Management acknowledges that utility allocation errors occurred in a limited number of instances due to a miscalculation in the allocation spreadsheet. Specifically, utility expenses were allocated among four tenants instead of five occupied tenants, resulting in an overallocation of utility costs to certain residents. The error was due to an input/calculation issue within the allocation spreadsheet and not a deficiency in the underlying allocation methodology. The organization’s documented utility allocation policy requires that total utility costs be allocated equally among occupied tenants, which is consistent with HUD requirements. Management has evaluated the exceptions identified and determined that the issue was isolated to specific instances of spreadsheet error rather than a systemic failure of the allocation methodology. Corrective Actions Implemented / To Be Implemented • The utility allocation spreadsheet will be corrected to ensure that the total number of occupied tenants is accurately reflected in the allocation calculation. • A two-level review control will be implemented over utility allocations. The Leasing Assistant/Clerk will prepare the allocation, and the Leasing Manager will independently verify accuracy prior to finalization. • Verification will include tenant count validation to the rent roll or occupancy report, recalculation of the per-tenant allocation, and confirmation that total allocations agree to the original utility invoice. • Allocation schedules will be supported by rent roll or occupancy documentation. • A standardized checklist will be implemented for monthly allocation procedures. • Any identified allocation errors will be promptly corrected to ensure tenants are not overcharged. Training Training on utility allocation procedures will be conducted by May 1, 2026, for leasing staff and management, with annual refresher training. Responsible Staff: Leasing Assistant/Clerk – Preparation Leasing Manager – Review and verification Controller – Oversight Chief Executive Officer (CEO) – Final accountability Implementation Date: Corrective actions are being implemented immediately upon identification of the finding. Ongoing monitoring will occur monthly.