U.S. flag

An official website of the United States government Here’s how you know

The .gov means it’s official.

Federal government websites often end in .gov or .mil. Before sharing sensitive information, make sure you're on a federal government site.

The site is secure.

The https:// ensures that you are connecting to the official website and that any information you provide is encrypted and transmitted securely.

Hotline

Report Fraud, Waste and Abuse
September 28, 2018
  • Housing
2018-CH-1009
2018-CH-1009.pdf

We audited Rainbow Terrace Apartments based on our analysis of risk factors related to multifamily projects in Region 5’s jurisdiction and the activities included in our fiscal year 2018 annual audit plan.  Our objective was to determine whether the project’s owner and management agent operated the project in accordance with the regulatory agreement and the U.S. Department of Housing and Urban Development’s (HUD) requirements.

The project’s owner and management agent did not always operate the project in accordance with the regulatory agreement and HUD’s requirements.  Specifically, the project’s owner and management agent did not always provide sufficient documentation to support that project funds were used for reasonable operating expenses or necessary repairs of the project.  In addition, (1) project funds were not used for reasonable expenses or necessary repairs of the project, (2) excess management fees and unsupported bookkeeping fees were charged to the project, and (3) tenants’ security deposits were not maintained in the project’s security deposit bank account.  As a result, HUD and the owner lacked assurance that more than $2.3 million in project funds was used for reasonable operating expenses or necessary repairs of the project.  In addition, more than $141,000 in project funds was not used appropriately.

We recommend that HUD require the owner to (1) support the reasonableness of or reimburse the project from nonproject funds for disbursements from the project’s operating account without sufficient documentation, (2) reimburse the project from nonproject funds for unreasonable operating expenses or unnecessary repairs of the project, (3) use the project’s security deposit bank account to deposit and disburse security deposits, and (4) implement adequate procedures and controls to address the findings cited in this report.

Recommendations
Recommendation Status Date Issued Summary
2018-CH-1009-001-A Closed September 28, 2018 Support the reasonableness of or reimburse the project $2,232,004 ($1,719,736 $484,615 $27,653) from nonproject funds for the project funds disbursed without sufficient procurement or contract documentation.
2018-CH-1009-001-B Closed September 28, 2018 Support or reimburse the project from nonproject funds $7,091, as appropriate, for the project funds disbursed without sufficient supporting documentation.
2018-CH-1009-001-C Closed September 28, 2018 Reimburse the project from nonproject funds $46,024 for the project funds that were not used for reasonable operating expenses or necessary repairs of the project.
2018-CH-1009-001-D Closed September 28, 2018 Support or reimburse the project from nonproject funds $39,690, as appropriate, for the project funds disbursed without sufficient documentation supporting that the invoices were not for duplicate work.
2018-CH-1009-001-E Closed September 28, 2018 Implement adequate procedures and controls to ensure that project funds are used for only reasonable operating expenses or necessary repairs when the project is in a non-surplus-cash position.
2018-CH-1009-001-F Closed September 28, 2018 Reimburse the project $95,174 from nonproject funds for management fees in excess of the maximum yield.
2018-CH-1009-001-G Closed September 28, 2018 Support or reimburse the project $70,632 from nonproject funds, as appropriate, for the project funds disbursed to Vesta Corporation for bookkeeping fees without documentation showing that the bookkeeping fees charged were reasonable.
2018-CH-1009-001-H Closed September 28, 2018 Implement adequate procedures and controls, including but not limited to ensuring that the project receives HUD’s communications to ensure that its management and bookkeeping fees comply with HUD’s requirements.
2018-CH-1009-001-I Closed September 28, 2018 Implement adequate procedures and controls to ensure that its bookkeeping fees are based on actual costs.
2018-CH-1009-001-J Closed September 28, 2018 Use the project’s security deposits bank account to deposit and disburse security deposits.