Consolidated Multifamily Submission

If you have several projects that are under the same Tax ID Number a consolidated submission can be entered. The following information is required for a consolidated electronic submission:

CONSOLIDATED STATEMENT

(no details on misc.
accounts)

 INDIVIDUAL PROJECT – Info needed for
EACH project
(details needed for misc accounts)
Balance Sheet x x
Profit & Loss x x
Equity x x
Cash Flow x x
Reserve for Replacement   x
Residual Receipts   x
Computation of Surplus Cash   x
Schedule of Changes in Fixed Assets   x
Footnotes x  
Auditor Reports (on audited financials only) x  
Findings (on audited financials only) x  
Certification Page (on audited financials only) x  
SEFA (on audited non-profit financials only)  x  

Multifamily Grace Period – Submission Due Date

Multifamily Projects have a 10 day grace period followed by the 30 day letter as outlined in “Submission and Review Requirements & REMS Critical Data Fields for Annual Financial Statements“:

Page 11 – V. Overdue Financial Statements

If an AFS is not received by the 10th day of the month following the AFS [Annual Financial Statement] due date, an e-mail letter is automatically sent to the owner’s Secure System coordinator on the 11th day. The message informs the owner the AFS is overdue and that a noncompliance flag has been entered into APPS. It also advises the owner if the AFS is not received within the next 30 days (grace period), HUD will refer the owner to the DEC.

Once the AFS has been submitted, if within the grace period, the APPS flag will be removed.

See Also: Requesting an Extension

Enter your FYE in the red-text field below to view the various deadlines.

Requesting an Extension for a Multifamily Electronic Submission

An extension request must be completed online through REAC’s online systems. It has to be requested before the due date. If AHACPA does your electronic submissions, we will request the extension for you. The information needed for an extension request is as follows:

  1. A short explanation of why the request is needed. (See below for Approval and Denial Criteria)
  2. Audit firm’s name
  3. Audit firm’s phone number
  4. Audit engagement date (must be at least 60 days prior to year end).

HUD has issued guidance on the extension process in “Submission and Review Requirements & REMS Critical Data Fields for Annual Financial Statements”. On Page 29 it states:

Extension Request Procedures

The procedures for the submission and review of the requests are:

  1. The owner’s coordinator accesses FASS and enters an explanation as to why they believe an extension is warranted, and enters personal contact information in case REAC needs to discuss the request.
  2. The request is electronically transmitted to REAC via FASSUB.
  3. The REAC analyst assigned to that Hub would act on the request based on the Office of Asset Management’s approval/denial criteria as outlined below.
  4. Once the request is approved or denied, the decision, and an explanation for the decision, is posted in FASSUB and is available for viewing in the submitter’s online Administrative Request Status Box.
  5. If the request is approved, then the due date is automatically changed in the FASS-MF overdue tracking module, thus preventing an overdue letter from being emailed to the owner’s coordinator.

Approval and Denial Criteria

The following criteria will be used in approving and denying extension requests:

  • Approve requests when:circumstances exist that are beyond the owner’s control
  • database problems beyond the control of the Project Manager and the owner prevent the owner from filing (examples include situations in which a former owner’s information was deleted from REMS, or problems with the FASS effective date or expiration date)

Deny requests when:

  • the hard copy audit report was not prepared in time to meet the electronic submission deadline
  • the owner failed to register as a coordinator in secure systems at least 30 days prior to the end of the fiscal year the owner does not have Internet access
  • the owner has overdue submissions from previous years that have not been received
  • the owner fails to engage an auditor at least 60 days prior to the end of the fiscal year

REAC understands that these criteria constitute a Housing policy decision and that the Office of Housing retains the authority to amend, adjust, or suspend these criteria at their discretion.

To request an extension you must log into the REAC system and then click on FASSUB.  Click through the announcements.  You will then be to a screen in which you can select “Extension Request”.  Fill out the following form.  HUD does not notify you of their decision.  You must go back to the REAC system in a day or two.  Click on the “Administrative Requests” link to view HUD’s response.

Click here for some samples of extension requests and their approval/denial from HUD.

Multifamily Supplemental Information Requirement

We at AHACPA are frequently asked if supplemental information must be included in the hard copy financial statements. The list of items which make up a properly formatted set of financial statements comes from several different sources. The quick list of items required are:

  • Independent Auditor’s Report & Independent Auditor’s Report on the Supplemental Information
  • Balance sheet
  • Statement of profit and loss
  • Statement of changes in partner’s capital
  • Statement of cash flows
  • Footnotes to the basic financial statements, including descriptions of accounting policies.
  • Supplemental Information:
    • Balance Sheet Data
    • Profit & Loss Data
    • Equity Data
    • Cash Flow Data
    • Notes
    • Auditor’s Reports (not needed for owner-certified submissions)
    • Findings & Prior Audits
    • Reserve Accounts Data
    • Surplus Cash & Fixed Asset Data
    • Nursing Home / Assisted Living Data
    • Federal Awards (Non-Profit only)
    • Certification
  • Other required auditor’s reports depending on entity type (profit motivated or non-profit)

Continue reading if you would like more detailed information on the source of the above listed items.

1 – Guidance from HUD Audit Guide Chapter 3

  • Independent Auditor’s Report
  • Independent Auditor’s Report on the Supplemental Information
    • Supplemental information includes REAC Financial Data Templates [aka FASS Templates]
  • Balance sheet.
  • Statement of profit and loss.
  • Statement of changes in partner’s capital.
  • Statement of cash flows.
  • Footnotes to the basic financial statements, including descriptions of accounting policies.
  • Must adhere to UFRS

2 – Guidance from Guidelines on Reporting and Attestation Requirements of Uniform Financial Reporting Standards (UFRS)

  • FASS Templates +
    • The financial data templates must be produced in hard copy and reported on as information supplementary to the financial statements, before they are submitted (emphasis added)
    • The financial data templates are defined in the appendices of the Industry User Guide

3 – List of FASS Templates from the Appendices of the Industry User Guide. These FASS Templates include the HUD Chart of Account numbers.

  • Balance Sheet Data
  • Profit & Loss Data
  • Equity Data
  • Cash Flow Data
  • Notes
  • Auditor’s Reports (not needed for owner-certified submissions)
  • Findings & Prior Audits
  • Reserve Accounts Data
  • Surplus Cash & Fixed Asset Data
  • Nursing Home / Assisted Living Data
  • Federal Awards (Non-Profit only)
  • Certification

4 – As further confirmation that supplemental information is necessary in the hard copy financial statements, see the following Agreed-Upon Procedures as listed in REAC:

Profit-Motivated Audited Entities

PROCEDURE UFRS RULE INFORMATION HARD COPY DOCUMENTS
1. Balance Sheet, Revenue and Expense and Cash Flow data (account numbers 1120 to 7100T and the S1200 series) Financial Data Templates (i.e. Supplemental Schedules)
2. Surplus Cash (S1300 series accounts) Note: Cooperatives are exempt from submitting surplus cash accounts. Financial Data Templates (i.e., Computation of Surplus Cash, Distributions and Residual Receipts – (Annual))
3. Footnotes (S3100 series of accounts) Footnotes to Audited Basic Financial Statements
4. Type of opinion on the Financial Statement and Compliance (account number S2100-020, S2300-020) Auditor’s Reports on the Financial Statements and Compliance
5. Type of opinion on Financial Data Templates (i.e. Supplemental Data) (account S2100-100) Auditor’s Supplemental Report on Financial Data Templates
6. Audit findings narrative (S2700 series of accounts) Schedule of Findings and Questioned Costs

 

Non-Profit Audited Entities

PROCEDURE UFRS RULE INFORMATION HARD COPY DOCUMENTS
1. Balance Sheet, Revenue and Expense and Cash Flow data (account numbers 1120 to 7100T and the S1200 series) Financial Data Templates (i.e. Supplemental Schedules)
2. Surplus Cash (S1300 series accounts) Note: Cooperatives are exempt from submitting surplus cash accounts. Financial Data Templates (i.e. Computation of Surplus Cash, Distributions, and Residual Receipts ­ (Annual))
3. Footnotes(S3100 series of accounts) Footnotes to Audited Basic Financial Statements
4. Type of opinion on the Financial Statement and auditor reports(S3400, S3500 and S3600 series of Accounts) Auditor’s Reports on the Financial Statements, Compliance and Internal Control
5. Type of opinion on Financial Data Templates (i.e. Supplemental Data) (account S3400­100) Auditor’s Supplemental Report on Financial Data Templates
6. Audit findings narrative (S3800 series of accounts) Schedule of Findings and Questioned Costs
7. General information (S3300, S3700 and S3800 series of accounts) Schedule of Findings and Questioned Costs and Federal Awards Data

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