Finding 49996 (2022-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2022-11-27

AI Summary

  • Core Issue: The organization failed to demonstrate that at least 51% of tenants in properties with CDBG loans were low or very low-income, as required.
  • Impacted Requirements: Tenant certifications and recertifications were not completed for 49 of 52 units at Mid-City Apartments and all 10 units at Apple Tree Housing, Inc.
  • Recommended Follow-Up: Management must ensure timely completion of all tenant certifications to comply with federal income standards and avoid funding risks.

Finding Text

CONDITION: THE ORGANIZATION WAS UNABLE TO SUPPORT THAT AT LEAST FIFTY-ONE PERCENT (51%) OF THE TENANTS AT EACH PROPERTY SECURED BY CDBG LOANS WERE LEASED TO AND OCCUPIED BY LOW OR VERY LOW-INCOME PERSONS AS DETERMINED BY THE FEDERAL "SECTION 8" INCOME STANDARDS WITH COMPLETED TENANT CERTIFICATIONS AND RECERTIFICATIONS. AT MID-CITY APARTMENTS, 49 OF 52 OCCUPIED UNITS CERTIFICATIONS AND AT APPLE TREE HOUSING, INC. 10 OF 10 OCCUPIED UNITS CERTIFICATIONS WERE NOT COMPLETED DURING THE YEAR ENDED JUNE 30, 2022. CRITERIA: ALL CDBG LOANS INCLUDED IN THE CONSOLIDATED FINANCIAL STATEMENTS ARE SUBJECT TO RESTRICTIVE COVENANTS LISTED IN A DECLARATION OF RESTRICTIVE COVENANTS, CONDITIONS, AND RESTRICTIONS AGREEMENT WITH THE REDEVELOPMENT AUTHORITY OF THE CITY OF PHILADELPHIA THAT REQUIRES THAT AT LEAST FIFTY-ONE PERCENT (51%) OF THE DWELLING UNITS OF THE PROJECT TO BE LEASED TO AND OCCUPIED BY LOW OR VERY LOW-INCOME PERSONS AS DETERMINED BY THE FEDERAL "SECTION 8" INCOME STANDARDS. THE OWNER IS REQUIRED TO CERTIFY TENANT INCOME ANNUALLY TO DETERMINE COMPLIANCE WITH THIS RESTRICTIVE COVENANT. CAUSE: MANAGEMENT WAS UNABLE TO COMPLETE THE REQUIRED TENANT CERTIFICATIONS AND RECERTIFICATIONS TIMELY. EFFECT: LACK OF OVERSIGHT OF REGULATORY REQUIREMENTS COULD INCREASE THE RISK OF LOSS OF FUNDING AND DEFAULT OF LOANS. RECOMMENDATION: MANAGEMENT SHOULD ENSURE ALL TENANT CERTIFICATIONS ARE COMPLETED TIMELY TO ENSURE ADHERENCE TO THE REQUIREMENT THAT AT LEAST FIFTY-ONE PERCENT (51%) OF THE TENANTS OF THE DWELLING UNITS OF THE PROJECT TO BE LEASED TO AND OCCUPIED BY LOW OR VERY LOW-INCOME PERSONS AS DETERMINED BY THE FEDERAL "SECTION 8" INCOME STANDARDS.

Corrective Action Plan

VIEW OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION: IT IS THE GOAL OF THE ORGANIZATION TO MAINTAIN COMPLIANCE WITH REGULATORY REQUIREMENTS. AS OF REPORT ISSUANCE, THE ORGANIZATION ACHIEVED 51% INCOME CERTIFIED AT MID-CITY AND CONTINUING RECERTIFICATION EFFORTS AT APPLETREE. WHERE HARDSHIPS ARE ENCOUNTERED THE ORGANIZATION REMAINS IN ONGOING COMMUNICATIONS WITH THE RESPECTIVE REGULATORY AGENCIES TO PROMOTE TRANSPARENCY AND MITIGATE RISK OF LOSS IN FUNDING OR DEFAULT.

Categories

HUD Housing Programs Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 626438 2022-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.218 Community Development Block Grants/entitlement Grants $4.88M
14.267 Continuum of Care Program $2.26M
14.239 Home Investment Partnerships Program $250,000