Finding 1237597 (2025-001)

Prior to May, 2025, Management did not have an internal compliance department and the property managemen t department was still experiencing high turnover as it made signi􀀁cant leadership changes to normalize operations and begin standardizing operations. Compliance was managed externally by a third-party partner named Townehousing Compliance. This meant that the new move-ins and applications were handled in a digital format, without an in-person team, and many physical 􀀁les were not properly digitized leading to 􀀁le misplacement, errors, and in some cases loss of documentation. Throughout 2025, the compliance department hired 9 internal team members, including 2 managers and a director. This late running start means that PY2025 is still incomplete as a result of timing. Standardizing, training, and ensuring there is a process around all tenant documentation was part of a year-long training initiative and as of September 2026 there are still portions of the plan being enacted and taught throughout the organization. Saving, backing up, and documenting inspection forms from their various sources is part of this 􀀁nal push in training. As inspection forms are done internally, by service partners, and through the county or city there are many formats to look for and identify – training a property management department of 60+ people on the proper handling and securing of documents has been an undertaking that is still taking shape. Proposed Corrective Plan Going Forward: Management will standardize the move-in inspection forms for HOME-assisted units and train all property managers to scan and save digitized versions of the documents into the Yardi database. All physical 􀀁les are being updated to include a table of content and an area for saving inspection and inspection-related correspondence forms. Inspections and their types will be listed along with 􀀁le requirements and compliance team members will check that they are in the 􀀁le and also attached in Yardi as they process move-ins. Management will have a supervisory review completed on a quarterly basis, led by the Director of Compliance, and a selection of 􀀁les will be reviewed for their content, including the correct inspection form and notes on the type of inspections and their frequency that the unit requires. This plan is already in action and will continue throughout the rest of 2026. December 2026 –All 􀀁les have been brought to the administration building from over 25 separate sites.March 2027 –Past resident 􀀁les have been archived and current resident 􀀁les have been reviewed, digitized, and placed into new folders and added to a directory . September 2027 –Work is expected to be completed on a full overhaul of all past 􀀁les (effective dates before May 2025) and current 􀀁les are being checked more rigorously by an internal department. Proposed Result: Into 2027 and beyond, management expects that the time and investment it has made into 􀀁le retention and compliance will result in quicker responses to audits, lack of missing documentation, and more complete audit responses.