We performed a review of the Lutheran Gardens Corporation (Corporation) trust fund account in response to a HUD request, dated March 30, 2009. HUD believed that as much as $2.72 million was withdrawn from a trust account in violation of a trust agreement (agreement) with HUD, dated April 22, 2005, and questioned certain disbursements. Our objective was to determine whether the Corporation withdrew and expended trust funds in accordance with the agreement with HUD. The scope of our review was limited to addressing HUD’s request by determining whether the Corporation withdrew and expended trust funds in accordance with the agreement with HUD. Our review found that the Corporation expended the trust funds according to the eligible uses described in the agreement. We recommend that HUD ensure that the Corporation establishes the required trust account with HUD named as the trustee and provide signature cards for a HUD representative to sign; deposits the balance of the trust funds subject to the agreement held in a Wells Fargo Bank account, along with $87,076 in replacement reserves due the trust; and submits trust fund authorization forms to HUD for signature and approval before withdrawing trust funds from the trust account.