On April 22, 2024, OMB issued revisions to 2 CFR Part 200, Subpart F, which among other things increased the audit threshold for single audits (non-profit) to $1,000,000 for auditee fiscal years beginning on or after October 1, 2024. This means it should take effect for September 30, 2025, with a reporting period of 10/01/2024 – 09/30/2025.
As of 12/15/2025, the REAC-FASSUB Multifamily submission template has not been updated to reflect the increase in the audit threshold – it still shows $750K. There are certain instances in which this can prevent an owner certified submission from validating – when the total federal awards are over the old threshold and under the new threshold.
Example:
A 9/30/2025 YE owner certified submission with $811,000 in HAP will not validate. The federal awards are less than $1,000,000 and the reporting period begins on 10/01/2024 – an owner certified submission should now be allowed.
The problem:
The REAC-FASSUB template still has the old $750,000 threshold and the validation error states that the sum of the applicable accounts (listed below) is over the threshold allowed for an owner certified submission.
The “Solution”:
There isn’t anything that can be done until the template is updated. This is one of the rare instances in which is may be beneficial to request an extension.
If the sum of the accounts listed is greater than the threshold amount, then the submission must be entered as audited.
Projects with HUD-Insured Mortgage:
- 2170 – Mortgage Payable – First Mortgage (Short Term)
- 2175 – Flexible Subsidy Loan Payable (Short Term)
- 2320 – Mortgage (or Bonds) Payable – First Mortgage (or Bonds)
- 5121 – Tenant Assistance Payments
- 5193 – Special Claims Revenue
Projects without HUD-Insured Mortgage:
- 5121 – Tenant Assistance Payments
- 5193 – Special Claims Revenue
https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-F
Basis for determining Federal Awards expended: https://www.ecfr.gov/current/title-2/section-200.502