Finding 916 (2022-001)

- Repeat Finding
Requirement
P
Questioned Costs
-
Year
2022
Accepted
2023-10-30
Audit: 1699
Organization: Pilgrim Towers, Inc. (CT)
Auditor: Whittlesey PC

AI Summary

  • Core Issue: The Agency has not documented the repayment status of the Flexible Subsidy Loan, which may indicate a default since the related HUD mortgage was paid off in 2016.
  • Impacted Requirements: The Flexible Subsidy Loan agreement requires immediate repayment upon the payoff of the HUD Section 202 mortgage, which has not been fulfilled.
  • Recommended Follow-Up: The Agency should contact its HUD field representative to clarify repayment terms and resolve the outstanding issue by December 31, 2023.

Finding Text

Finding reference number: 2022-001 Title and CFDA: Flexible Subsidy Loan 14.164 Type of Finding: FA Finding resolution status: In process Identification of repeat finding: 2021-002 Criteria: The Flexible Subsidy Loan "Residual Receipts Note" clause 3(a) cites that the entire principal together with interest is immediately due and payable when the HUD Section 202 mortgage is paid off. Statement of Condition: During our audit for the year ended December 31, 2021, we inquired and requested documentation regarding the repayment status of the Flexible Subsidy Loan from the Agency's officers and from its management company. The Agency did not have documentation regarding the mortgage status of the Flexible Subsidy Loan available since the HUD Section 202 mortgage was paid off in November 2016. Cause: The Agency is waiting for a response from HUD as to their inquiry regarding the repayment of the Flexible Subsidy Loan. Effect of Potential Effect: Based on the literal terms of the Flexible Subsidy Loan, the Agency appears to be in default as it has not established repayment with HUD. Auditor non-compliance code: S Amount of questioned costs: $0 Reporting Views of Responsible Officials: We continue to follow up, as we diligently have over many recent months, starting in 2008. Most recently, via an attorney, who, like Pilgrim Towers, has not been able to elicit any response from HUD to resolve this matter. FHA/Contract number: CT26M000251 Questioned Costs: $0 Context: It has been brought to the Agency's attention that the repayment of the HUD Section 202 mortgage that they would need to contact their HUD field representative regarding repayment of the Flexible Subsidy Loan. Recommendation: We recommend that the Agency follow up with its HUD field representative to determine the next steps regarding the repayment terms of the Flexible Subsidy Loan. Auditor's Summary of the Auditee's Comments on the Findings and Recommendations: Pilgrim Towers, Inc. concurs with the audit finding. The Board of Directors is in communication with HUD to negotiate repayment terms. Response Indicator: A Completion date of proposed recommendation: December 31, 2023 Response: We continue to follow up, as we diligently have over many recent months, starting in 2008. Most recently, via an attorney, who, like Pilgrim Towers, has not been able to elicit any response from HUD to resolve this matter.

Corrective Action Plan

Finding No. 2022-001: Federal Awards Federal Program Information: Assistance Listing Program Title and Number: Flexible Subsidy Loan #14.164 Federal Agency: U.S. Department of Housing and Urban Development Pass-through Entity: NI A Description of Finding: The Flexible Subsidy Loan "Residual Receipts note" clause 3(a) cites that the entire principal together with interest is immediately due and payable when the HUD Section 202 mortgage is paid off. The agency appears to be in default as it has not yet established terms or'repayment with HUD. Statement of Concurrence: Pilgrim Towers, Inc. concurs with the audit finding. Corrective Action: Pilgrim Towers, Inc. will be following up with its HUD field representative to determine the next steps for repayment related to the Flexible Subsidy loan. They continue to follow-up with HUD to attempt to receive a response. Name of Contact Person: Pat Thatcher, Executive Director, patthatcherl@gmail.com Projected Completion Date: December 31, 2023

Categories

HUD Housing Programs Cash Management Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
14.218 Community Development Block Grants/entitlement Grants $1.63M
14.239 Home Investment Partnerships Program $800,000
14.164 Flexible Subsidy Loan (section 201) $373,400
14.856 Lower Income Housing Assistance Program_section 8 Moderate Rehabilitation $304,264
14.191 Multifamily Housing Service Coordinators $50,827