Underfunded Tenant Security Deposits

The situation may arise when tenant security deposit amounts do not match.

The submission will not be “flagged” If the amount in account 1191 – “Tenant/Patient Deposits Held in Trust” is GREATER than the amount in account 2191 – “Tenant/Patient Deposits Held in Trust (Contra)”.

However, if tenant security deposits are underfunded (resulting in 2191 being less than 1191) the submission will be flagged.  The guidance from “Submission and Review Requirements & REMS Critical Data Fields for Annual Financial Statements” states:

Section II – REAC FASS-MF Assessment and Referral

B. Automatically Referred to MFH or the DEC with Compliance Deficiencies

FASS-MF automatically refers (without a REAC analyst review) projects with one or more of the following compliance deficiencies identified by the system:

  • Failure to make residual receipts deposits
  • Failure to invest residual receipts
  • Failure to invest reserve for replacements
  • Under-funded tenant security deposits

https://www.hud.gov/sites/dfiles/PIH/documents/finl_memo_2004_1a.pdf