Finding 555740 (2024-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-04-23
Audit: 354366
Organization: Victory Oaks, Inc. (MD)
Auditor: Cohnreznick LLP

AI Summary

  • Core Issue: Tenant lease files are not being maintained properly, leading to eligibility determination issues.
  • Impacted Requirements: Compliance with HUD Handbook 4350.3 is lacking, specifically regarding timely use of the EIV system and completion of HUD Form 50059.
  • Recommended Follow-Up: Management should implement and monitor procedures to ensure correct recording of tenant deposits, eligibility determinations, and lease file maintenance as per HUD guidelines.

Finding Text

Criteria Tenant lease files are required to be maintained and tenant eligibility determined in accordancewith HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily HousingPrograms. Condition In connection with our lease file review we noted the following deficiencies: 2 of 6 new and existing tenants tested did not utilize the Enterprise Income Verification (EIV) system timely. 2 of 6 existing tenants tested did not complete the HUD Form 50059 timely. Cause The Project failed to follow the policies and procedures which have been established for proper tenant file maintenance and determining tenant eligibility in accordance with HUD guidelines. Effect or Potential Effect The procedures for determining tenant security deposits and eligibility and maintaining tenant lease files were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Noncompliance with HUD guidelines could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Context A sample of 6 tenant files from a population of 47 were selected. We identified exceptions in 4 of the 6 files tested. The sample was not a statistically valid sample. Identification as a Repeat Finding Finding is a repeat finding, see prior year finding 2023-001. Questioned Costs None Recommendation Management should establish procedures and monitor compliance with those procedures to ensure that tenant security deposits are correctly recorded, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Auditor Noncompliance Code: R - Section 8 program administration Finding Resolution Status: In-process Views of Responsible Officials As there has been a change in the Management Agent, the agent will ensure that the EIV Income Report and annual certifications are completed according to HUD guidelines. The site now has updated its file set-up review to make sure reports have been completed within HUD guidelines and new company policy as well as corporate compliance monitoring.

Corrective Action Plan

a. Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner as well as timely recertification, as required by HUD guidelines. We attribute this finding to prior management handling of compliance as well as the delay in software set-up at management transition. b. Action(s) Taken or Planned on the Finding As there has been a change in the Management Agent, the agent will ensure that the EIV Income Report and annual certifications are completed according to HUD guidelines. The site now has updated its file set-up review to make sure reports have been completed within HUD guidelines and new company policy as well as corporate compliance monitoring

Categories

HUD Housing Programs Eligibility Subrecipient Monitoring

Other Findings in this Audit

  • 555741 2024-002
    Significant Deficiency
  • 1132182 2024-001
    Material Weakness Repeat
  • 1132183 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.157 Supportive Housing for the Elderly $6.83M
14.239 Home Investment Partnerships Program $863,402