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Finding No. 2025-003 - 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: Covington Commons - HUD 2011-HOME-11H01 2011 1 Total instances 1 Criteria Each owner must comply with the requirements set forth in 24 CFR Part 92 regulations as outlined in the "Compliance in HOME Rental Projects: A Guide for Property Owners" published by HUD which requires the property to maintain the contracted number of HOME units as well as the designated splits in bedroom size and High Home/Low Home unit ratios. Condition The owner did not make available to HOME tenants the contracted number and type of HOME units in one property out of three tested. Cause Management's policies with respect to maintaining the number and split of contracted HOME units were not consistently followed. Effect or Potential Effect The procedures for determining and maintaining the correct HOME units within the property were not applied. This could result in ineligible tenants occupying HOME designated units. Questioned Costs: Not applicable. Context In connection with the procedures applied to our HOME units testing, one of the three properties tested did not meet the contracted HOME units size portfolio as follows: Along with other unit bedroom types that are in compliance, in Covington Commons: there should be three 4-bedroom units (there are two). Repeat Finding: Yes - Finding 2024-003 Recommendation Management should follow procedures in place to ensure consistent application and adherence to the requirements in accordance with the "Compliance in HOME Rental Projects: A Guide for Property Owners" published by HUD. Views of Responsible Officials REACH’s 2024 consolidated audit report was issued in mid-November 2025. Once we were notified about this audit finding, Compliance Management conducted an in-depth review of this finding and determined that one extra 3-bedroom and one fewer 4-bedroom at Covington Commons were incorrectly set up in our Yardi system. REACH have since corrected this issue in the Yardi system. REACH will continue to monitor vacant two-bedrooms at Cascadia Village as they become available. There are only two 2-bedrooms that are not designated as HOME. We noted that unit #72 was not set up properly in our Yardi system. REACH have corrected this issue in the system.