Finding 1217210 (2025-001)

Management Response: Management concurs with the finding. The withdrawal of $14,853 from the Replacement Reserve account was made to address an emergent roof repair that required immediate action to protect the property and its residents. At the time, management did not obtain HUD approval prior to the expenditure as required. Upon identification of the issue, management promptly consulted with HUD regarding the withdrawal and has worked with HUD to resolve the matter. HUD has accepted the explanation and the issue has been addressed. Management also identified that the required October 2025 Replacement Reserve deposit of $575 was inadvertently omitted. Upon discovery of the missed transfer, the deposit was made on March 27, 2026, restoring the reserve account to the required balance. To prevent future occurrences, management has implemented the following corrective actions: 1. A compliance checklist has been established for all HUD-regulated reserve accounts to ensure required approvals are obtained prior to any withdrawal. 2. Monthly reserve deposits have been incorporated into the organization's recurring accounting procedures and monitored through a monthly compliance review process. 3. Finance staff responsible for HUD properties have been provided additional training regarding reserve account requirements, including HUD approval requirements for withdrawals and required monthly reserve deposits. 4. Reserve account activity will be reviewed periodically by management to verify compliance with HUD regulations and applicable property agreements. Management believes these corrective actions adequately address the finding and strengthen internal controls over compliance with HUD reserve account requirements. Anticipated Completion Date: Completed with ongoing maintenance Responsible Officials: Holly Morgan, Executive Director