Core Issue: The Project failed to increase the monthly deposit to the replacement reserve as required by HUD, indicating a significant deficiency in compliance.
Impacted Requirements: Non-compliance with HUD's funding and disbursement rules could lead to inadequate reserves for necessary replacements.
Recommended Follow-Up: The Project should review and improve internal controls and procedures to ensure proper documentation and compliance with eligibility requirements.
Finding Text
Criteria: Internal controls are required to be in place to ensure proper procedures are being followed and the Project is in compliance with HUD requirements regarding funding of and disbursements from the replacement reserve. Condition: During the testing of the replacement reserve, it was noted the Project did not increase the monthly deposit amount during the fiscal year as instructed by HUD. We consider this finding to be a significant deficiency with the Special Tests and Provisions Compliance Requirement. Effect: The Project is not in compliance with HUD requirements regarding special tests and provisions which could result in inadequate reserves being held for the required replacement reserve. Questioned Costs: $780 Cause: The Project experienced turnover resulting in inconsistent file management practices and ineffective internal review procedures to ensure that all required eligibility documentation is obtained and retained. Recommendation: The Project should consider reevaluating their established procedures and controls currently in place to ensure full compliance regarding eligibility and documentation retained in tenant files. The Project needs to correct the deficiencies noted in the tested files. Views of Responsible Officials: Management agrees with the findings and a response is included in the Corrective Action Plan.
Corrective Action Plan
Fund Account - Deposit additional funds to cover shortfall. - March 3, 2026 Segregation and Monitoring - Transfer all new deposits immediately; perform monthly reconciliations. - Effective immediately Policies and Training - Update policies; train staff on deposit handling and monitoring - May/June 2026 Oversight and reporting - CFO/Controller review monthly reconciliations; provide quarterly updates to Finance Committee - ongoing
Categories
Special Tests & ProvisionsEligibilityHUD Housing ProgramsSignificant DeficiencyInternal Control / Segregation of Duties