Finding 1226481 (2025-006)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-08-13
Audit: 409109
Auditor: COHNREZNICK LLP

AI Summary

  • Core Issue: Two out of three tenant lease files lacked required 3rd party income verification, violating HUD compliance standards.
  • Impacted Requirements: Management's failure to consistently follow policies for tenant eligibility and lease file maintenance as per the HUD Use Agreement.
  • Recommended Follow-Up: Implement and monitor procedures to ensure timely recertifications and proper income verification to maintain compliance with HUD requirements.

Finding Text

Finding No. 2025-006 Uniform Guidance Compliance Requirement Code: E-Eligibility - Significant Deficiency HUD Low Income Housing Preservation and Resident Homeownership Act of 1990 Federal Assistance Listing Number #99.999 Low Income Housing Preservation and ResidentHomeownership Act of 1990 - Capital Grant Entity IdentifyingNumber Initial Year Findinginstances Beacon 126-35062 1996 2 Total instances 2 Criteria Tenant lease files are required to be maintained and tenant eligibility determined in accordance with the HUD issued Use Agreement subject to the Low Income Homeownership Act of 1990 ("HUD Use Agreement"). Condition In connection with our lease file review, we noted two instances out of the three tested where management did not provide support that they performed a 3rd party income verification in accordance with policy. Cause Management's policies with respect to recertifications, eligibility and the maintenance of tenant lease files in accordance with the HUD Use Agreement 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 the LIHPRA units testing, two of the three tenants tested did not have a 3rd party income verification performed in accordance with policy. Repeat Finding: No 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 HUD issued Use Agreement subject to the Low Income Homeownership Act of 1990. Views of Responsible Officials REACH has policies in place to ensure recertifications and income verification are performed timely, tenant eligibility is correctly determined, and the tenant files are properly maintained. During the second quarter of 2026, REACH outsourced property management and compliance functions to a third-party management company to address the outstanding compliance issues.

Corrective Action Plan

REACH has policies in place to ensure recertifications and income verification are performed timely, tenant eligibility is correctly determined, and the tenant files are properly maintained. During the second quarter of 2026, REACH outsourced property management and compliance functions to a third-party management company to address the outstanding compliance issues.

Categories

Eligibility Questioned Costs HUD Housing Programs Significant Deficiency

Other Findings in this Audit

  • 1226476 2025-002
    Material Weakness Repeat
  • 1226477 2025-003
    Material Weakness Repeat
  • 1226478 2025-004
    Material Weakness Repeat
  • 1226479 2025-005
    Material Weakness Repeat
  • 1226480 2025-001
    Material Weakness Repeat
  • 1226482 2025-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $1.76M
14.275 HOUSING TRUST FUND $1.13M
14.251 ECONOMIC DEVELOPMENT INITIATIVE, COMMUNITY PROJECT FUNDING, AND MISCELLANEOUS GRANTS $801,890
14.195 PROJECT-BASED RENTAL ASSISTANCE (PBRA) $683,229
14.155 MORTGAGE INSURANCE FOR THE PURCHASE OR REFINANCING OF EXISTING MULTIFAMILY HOUSING PROJECTS $492,426
99.999 Low Income Housing Preservation and Resident Homeownership Act of 1990 - Capital Grant $444,763
14.241 HOUSING OPPORTUNITIES FOR PERSONS WITH AIDS $225,000
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $197,413
21.000 NeighborWorks America $77,629