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Finding No. 2025-001 - Uniform Guidance Compliance Requirement Code: E - Eligibility - Significant Deficiency Housing Trust Fund Federal Assistance Listing Number #14.275 Housing Trust Fund Entity IdentifyingNumber Initial Year Findinginstances Passed through Oregon Department of Housing &Community Services: Rose Apartments The Mary Ann Apartments 3356 2019 1 3404 2020 1 Total instances 2 Criteria Tenant lease files are required to be maintained and tenant eligibility determined in accordance with the Compliance in State of Oregon Housing and Community Services HTF Program Compliance Manual. Condition In connection with our lease file review, we noted two instances of two 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 Compliance in State of Oregon Housing and Community Services HTF Program Manual 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 HTF units testing, two of the two tenants tested did not have a third-party income verification performed in accordance with policy. Repeat Finding: Yes - 2024-006 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 Compliance in State of Oregon Housing and Community Services HTF Program Manual. Views of Responsible Officials REACH’s 2024 consolidated audit report was issued in mid-November 2025. REACH Compliance Management reviewed the Oregon Housing and Community Services (OHCS) Housing Trust Fund (HTF) program manual and did not find any specific requirements about certifications other than at move-in. REACH reached out to OHCS and did not receive any clarifications. REACH operated with the available guidance for HTF at the time. OHCS have since updated the HTF manual as of June 2026. REACH now have an updated HTF manual which outlines when full recertification with income verifications are required and will follow those rules going forward.