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Finding No. 2025-002 - Uniform Guidance Compliance Requirement Code: E-Eligibility - Significant Deficiency HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 HOME Investment Partnership Program Entity Identifying Number Initial Year Findinginstances Passed-through Clark County: McCallister Village (Fruit Valley) Passed-through City of Vancouver: McCallister Village (Fruit Valley) 2010-HOME-0H0 2010 1 2010-HOME-601002 2010 1 Total instances 2 Criteria Tenant lease files are required to be maintained and tenant eligibility determined in accordance with the Compliance in HOME Rental Projects Guide from HUD. Condition In connection with our lease file review, we noted two instances of six tenants tested where management did not provide support that they performed a third-party income verification in accordance with policy. Cause Management's policies with respect to recertifications and eligibility and the maintenance of tenant lease files in accordance with the Compliance in HOME Rental Projects Guide from HUD were not consistently followed. Effect or Potential Effect This could result in units being rented to ineligible tenants. Questioned Costs: Not applicable. Context In connection with the procedures applied to our HOME units testing, two of the six tenants tested did not have a 3rd party income verification performed in accordance with policy. Repeat Finding: Yes - Finding 2024-002 Recommendation Management should establish procedures and monitor compliance with those procedures to ensure that recertifications and correct income verification procedures are performed timely, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of the Compliance in HOME Rental Projects Guide from HUD. Views of Responsible Officials REACH’s 2024 consolidated audit report was issued in mid-November 2025. REACH has policies and procedures in place to monitor compliance of recertifications, and correct income verification procedures are performed timely. Once we were notified of this finding, Compliance Management Compliance team conducted a full review of all HOME regulatory agreements in the portfolio, including County, City and Commerce HOME funding. Compliance Management also created a spreadsheet to track which units are due for the appropriate HOME recertification.