Finding 22663 (2022-002)

-
Requirement
N
Questioned Costs
$1
Year
2022
Accepted
2022-10-19
Audit: 18368
Organization: YWCA Apartments, Inc. (CA)

AI Summary

  • Core Issue: The Corporation made an unauthorized transfer of project assets by assigning leases to YWCA GGSV, violating HUD regulations.
  • Impacted Requirements: This action breaches the regulatory agreement with HUD, specifically Section VI, Paragraph 36.f, which prohibits such transfers without prior approval.
  • Recommended Follow-Up: Terminate the lease assignment with YWCA GGSV and ensure that all commercial rents are paid directly to the Corporation.

Finding Text

Finding # 2022-002 Federal Grantor: Department of Housing and Urban Development AL # / Program : 14.155 - Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects Type of Finding: Federal Award Finding Finding Resolution Status: Unresolved Information on Universe Population Size: The universe population size is not applicable to the finding. Sample size information: The sample size information is not applicable to the finding. Criteria: The Corporation entered into a regulatory agreement with HUD dated January 1, 2013 on form HUD-92466M (Rev. 04/11). Section VI. Paragraph 36. f. states the Corporation shall not without prior written approval of HUD convey, assign or transfer any right to receive the Rents of the Mortgaged Property, except as provided in the Security Instrument. Statement of Condition: The Corporation entered into an Assignment of Leases with YWCA Golden Gate Silicon Valley (YWCA GGSV) on March 1, 2021. Cause: The Assignment of Leases constitutes an unauthorized distribution of project assets to an affiliate organization. Effect or Potential Effect: The Corporation is not in compliance with the HUD regulatory agreement dated January 1, 2013 Section VI Paragraph 36. f. Auditor Non-Compliance Code: H - Unauthorized Distribution of Project Assets Questioned Costs: $161,786 Reporting Views of Responsible Officials: Management agrees with finding. Context: During testing of commercial rents, it was noted that the Corporation had assigned their interest in the commercial leases to YWCA GGSV. Recommendations: We recommend the Corporation terminate the Assignment of Leases agreement with YWCA GGSV and that the commercial rents due under the leases be paid to the Corporation. Auditor's Summary of the Auditee's Comments on the Findings and Recommendations: Management agrees with finding. Response Indicator: Agree Completion Date: 12/31/2022 Response: See Corrective Action Plan

Corrective Action Plan

Finding # 2022-002 (Unauthorized Distribution of Project Assets) Questioned Costs: $161,786 Response Indicator: Change from ?Disagee? to ?Agree? Comments on Findings and Recommendation: The Corporation acknowledges its inadvertent oversight in not obtaining advance HUD approval of the March 1, 2021 Assignment of Leases with YWCA Golden Gate Silicon Valley (YWCA GGSV) (the ?Assignment?). Actions Planned on the Finding: The Corporation plans to rescind the Assignment no later than December 31, 2022, and will seek approval from HUD for the assignment of $161,786 in commercial rents to YWCA GGSV pursuant to the Assignment.

Categories

Questioned Costs HUD Housing Programs Procurement, Suspension & Debarment Reporting

Other Findings in this Audit

  • 22662 2022-001
    Material Weakness
  • 22664 2022-003
    Material Weakness
  • 22665 2022-004
    -
  • 22666 2022-005
    Material Weakness
  • 599104 2022-001
    Material Weakness
  • 599105 2022-002
    -
  • 599106 2022-003
    Material Weakness
  • 599107 2022-004
    -
  • 599108 2022-005
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.155 Mortgage Insurance for the Purchase Or Refinancing of Existing Multifamily Housing Projects $4.11M
14.195 Section 8 Housing Assistance Payments Program $2.03M
21.019 Coronavirus Relief Fund $3,470