Finding Text
Finding SA2020-006: Lack of documentations for Declaration of Trust (DOT) and Declaration of
Restrictive Covenants (DORC)
AL number: 14.850
AL Title: Public and Indian Housing
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2020)
Criteria: 24 CFR section 905 required non-federal entities including Public Housing Authorities (PHA)
are required to maintain current or valid DOT or DORC recorded against all public housing properties
that have received funding under the U.S. Housing Act of 1937.
Condition: During our audit, we noted the DOTs provided for certain housing properties are outdated
and didn’t reflect subsequent modernization improvements.
Cause: We understand that the staff overseeing the federal awards during fiscal year 2020 are no longer
with the Authority, and therefore, the staff overseeing the federal awards subsequent to the fiscal year
were unable to provide the supporting documents.
Effect: The Housing Authority is not compliance with the HUD requirements as stated in 24 CFR
section 905.
Recommendation: The Housing Authority should maintain a list of all owned and insured properties,
including land, non-residential facilities, and modernization efforts, and ensure that each property has a
current and valid DOT/DORC on record.
Management Response: The Authority maintains a comprehensive list of all owned and insured assets
within our Asset Repositioning strategy document. In alignment with the recommendation, the
Housing Authority will establish an electronic filing system to securely store all declarations of trust. In
accordance with PHI Notice 2014-14, the Housing Authority will formally request the release of the
Declaration of Trust (DOT) from HUD prior to the closing or transfer of the title of any public housing
property.