Finding Text
Finding 2023-001
Section 202 Capital Advance Loan
CFDA No. 14.157
Questioned Costs: $166,464
Information on Universe and Population Size: N/A
Sample Size Information: N/A
Noncompliance Information: The project did not make all of the required deposits to the reserve for replacements (“RFR”) account during the years ended December 31, 2020, 2019, 2018, 2017, 2016, 2015, 2014, 2013, and 2012.
Condition: The RFR account is deficient $166,464 in deposits for the year ending December 31, 2023.
Criteria: HUD regulations and the HUD regulatory agreement require the Project to make 12 monthly deposits to the RFR account unless a waiver of deposits is approved by HUD.
Cause: The Project experienced significant vacancies which have resulted in a shortfall of operating cash available to make the RFR deposits.
Effect or Potential Effect: The RFR account is deficient in deposits as of December 31, 2023.
Recommendation: The Project should make the required deposits as soon as operating cash is sufficient to do so.
Reporting Views of Responsible Officials: The Project is experiencing significant vacancies which have resulted in a shortfall of operating cash available to make all RFR deposits. Those charged with governance agree with the finding and have requested a waiver of the RFR deposits from HUD that would apply retroactively to the delinquent deposits for prior years. Management has improved the cash flow of the project and was able to start making monthly deposits to the RFR during 2020 and plans to keep up with the monthly deposits as agreed to with the HUD project asset manager. Additionally, the Project currently maintains a balance of approximately $3,200 per unit, which is in excess of the HUD requirement of $1,000 per unit.