Corrective Action Plan: The NCHA has implemented CFP drawdown procedures to ensure that all eLOCCS requests are supported by eligible expenditures, properly documented, and submitted in accordance with applicable federal cash management requirements and HUD Capital Fund Program regulations. Effective immediately, the Authority has established the following corrective actions: CFP Drawdown Review and Approval Process All CFP drawdown requests are now reviewed by Finance staff before submission to verify that requested amounts are supported by eligible CFP expenditures, available obligations, and approved Capital Fund budgets. A Management approval requirement has been implemented for all eLOCCS draw requests before submission. Supporting documentation, including invoices, purchase orders, contracts, payroll allocations, and other eligible expenditure support, is maintained with each draw request. Monthly eLOCCS-to-Expenditure Reconciliation Finance staff perform a monthly reconciliation of CFP eLOCCS drawdowns to actual expenditures recorded in the accounting system. The reconciliation process confirms that: o Drawdowns do not exceed eligible costs incurred; o Funds are properly recorded for the appropriate Capital Fund grant year and project; o Outstanding balances and remaining grant funds are accurately monitored; and o Any discrepancies are identified and corrected on time through appropriate accounting adjustments. Improved Cash Management Controls NCHA revised its CFP cash management procedures to align drawdown timing with actual cash needs and incurred eligible costs. Draw requests are limited to amounts necessary to reimburse expenditures and avoid excessive cash balances. Finance staff have been trained in federal cash management requirements, CFP eligible cost principles, and proper eLOCCS drawdown procedures. Documentation and Record Retention NCHA implemented a CFP Drawdown Checklist to document: o Grant availability; o Eligible expenditures supporting the draw; o Required approvals; o Reconciliation completion; and o Supporting documentation retention. CFP financial records are maintained in accordance with federal record retention requirements and are available for HUD review. Ongoing Monitoring and Quality Control The CFO or designee conducts periodic quality control reviews of CFP drawdowns and related reconciliations to ensure continued compliance. Any identified exceptions are documented, corrected, and incorporated into ongoing staff training and process improvements. Responsible Official: CFO, Sr. Staff Accountant with oversight by Executive Director/CEO Responsible for implementation, monitoring, and continued compliance with CFP drawdown procedures. Expected Completion Date: Implemented July 2026; Ongoing monitoring and monthly reconciliation procedures will continue as part of the Authority’s standard financial management practices