Finding Text
2022-006 – Recording of Declarations of Trust Against Public Housing Property
U.S. Department of Housing and Urban Development
14.850 – Public and Indian Housing
N. Special Tests and Provisions – Significant Deficiency and Compliance Finding
Condition: During review of Public and Indian Housing program, RBT noted that the Authority could not locate the Declaration of Trust documents for all properties owned by the Authority and, therefore, the status of the documents was indeterminable.
Criteria: A current Declaration of Trust (DOT) in a form acceptable to HUD, must be recorded against all public housing property owned by PHAs that has been acquired, developed, maintained, or assisted with funds from the US Housing Act of 1937.
Cause: The Authority did not have controls in place over Declaration of Trusts sufficient to ensure the appropriate documents are current, recorded, and maintained for all properties owned by the Authority.
Effect: The Authority is not in compliance with the Declaration of Trust requirement of the program.
Questioned Costs: None identified.
Perspective: The Authority could not locate a current DOT for any of the three properties selected for testing.
Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Authority complete and maintain a Declaration of Trust in a form acceptable by HUD for all properties of the Authority and that the Authority establish controls over Declarations of Trust to ensure the forms are completed and current in the future.
Auditee’s Response: See corrective action plan.