Status of Financial Filing Deadline Extensions

June 26, 2020: MULTIFAMILY Submission Due Date Extensions

Today HUD posted the following notice on the Multifamily Housing – Highlights and Announcements page:

Global Extension for All Submissions Due Before September 30th

The Office of Housing has issued approval for an extension of all financial statements due before September 30, 2020.
Any submission with a due date before September 30th will now be due on September 30th.
This extension applies to both audited and unaudited submission types.

To Further clarify, here is a list of the Multifamily FYEs with due dates before September 30, 2020.

FYE Original Due Date New Extended
Due Date
12/31/2019 03/30/2020 09/30/2020
01/31/2020 04/30/2020 09/30/2020
02/29/2020 05/29/2020 09/30/2020
03/31/2020 06/29/2020 09/30/2020
04/30/2020 07/29/2020 09/30/2020
05/31/2020 08/29/2020 09/30/2020
06/30/2020 09/28/2020 09/30/2020

Updated April 30, 2020 [Added information below regarding Residual Receipts]

Multifamily

FASSUB (Multifamily) has just now approved an additional extension of the filing deadline. The revised due date is June 30th. This will cover all submissions (owner-certified, owner-certified greater than $750K, OMB audits with 9 month due dates, etc.) that were due April 30th (originally March 30th) and May 31st. The announcement is posted on the FASSUB announcements page within the REAC system.

Global Extension Til June 30th: REAC  is extending due dates on all submissions that are due April 30th [originally 3/30] and May 31st. the new due dates for these submissions will be June 30th. This applies to all submissions due within this time frame.

Residual Receipts

Q: With the REAC deadline being extended, is the deadline to submit surplus cash into a residual receipts account also extended?

A. All of AHACPA’s communications with HUD indicate that the extension DOES NOT apply to residual receipts requirements.

Public Housing (PHA)

The latest information was posted in this Q&A document dated 4/22.  It states:

HUD is extending the reporting due date of PHAs unaudited submission to the REAC as required by 24 CFR 5.801(c) and 24 CFR 5.801(d)(1) for PHAs with a fiscal year end FYE) of December 31, 2019. The new due date for these PHAs unaudited submission is now August 31, 2020. For PHAs with a FYE of March 31, 2020, the new due date is November 30, 2020. The information below provides the extended due date for the unaudited submission by fiscal year.

FYE Due Date Extended
Due Date
12/31/2019 02/29/2020 08/31/2020
03/31/2020 05/31/2020 11/30/2020

This extension does not require individual PHAs to seek HUD approval for the extension.

FHA Lender Submissions

We contacted the FHA-Lender Recertification Branch.  They have indicated they will not issue another blanket extension.


March 23, 2019

Last week HUD announced a blanket 30-day extension for the filing of all REAC financial statements. That extension is automatic and does not require any action by the project. However, REAC has clarified that the extension DOES NOT EXTEND THE 60-day RESIDUAL RECEIPTS deposit requirement.
 
Rural Development – Contacts with Rural Development indicate that they DO NOT intend to issue a blanket 30-day extension of the filing deadline. They had previously instructed state offices to consider granting extensions due to the timing of the issuance of their 2019 audit guidance. They consider that COVID-19 related extensions would fit within the same guidance. PLEASE NOTEClients must request such extensions by contacting state RD officials.
 
Single Audit Extension – Later last week OMB issued memo M-20-17 which among other things, granted an automatic 6-month extension of the deadline for filing audited financial statements. This extension applies to all Uniform Guidance requirements for audited financial statements due through June 30, 2020.
 
FHA Lender Submissions – Conversations with LEAP management indicate that they have granted an automatic 30-day extension for all LEAP filings. These extensions were automatically placed in the lender’s LEAP recertification screen. Evidence of such extension can be found by each client by simply accessing the LEAP recertification page. Just note the new due date.
 
Ginnie Mae, Fannie Mae and Freddie Mac Filings – Detailed searches of the related web pages of these entities DID NOT reveal any evidence of a Covid-19 related extension. Emails to those entities requesting information about possible extension have not been responded to. If any response is forthcoming we will let you know.

03/24/2020 Rural Development Extension

Another question has arisen regarding a Rural Development extension. An extension was mentioned on the AICPA’s GAQC website last week. Apparently the Department of Agriculture announced that an extension was granted to Rural Development Rural Utility Service under 7 CFR part 1377. The question was whether this extension relates to Rural Development multifamily projects. We believe it did not apply.

However, this morning we received an email from RD indicating they will issue a blanket 30-day extension on the Annual Financial Statement deadline, to April 30, 2020. In addition, RD is extending the Lender’s Review of the property’s Audited Financial Statement by 30 days to May 31, 2020. At this time we do not have a link to this announcement.  We will post on our website when available.

Information on LEAP Submission Deadline Extension

LEAP has not made an official announcement regarding an extension to the electronic submission deadline. However, it appears that an extension has been generated within their system. Log into LEAP and look at the next recertification due date. This is a screenshot of what it looks like:

Possible LEAP Extension

To recap:

  • There is a 30-day extension for multifamily financials submitted through REAC-FASSUB. 
  • The above shows an apparent extension for FHA-Lender financials filed through LEAP
  • We do not know of any extensions related to Public Housing or Rural Development at this time.

We continue to receive emails and phone calls regarding this situation. Unfortunately, it is impossible for us to answer them all. We will post any additional information on our website as it becomes available.

Deadline Extension for Multifamily Submissions Due 3/31/2020

It is now March 13th. Yep, Friday the 13th. We hope everyone is staying safe and sane. It looks like “March Madness” may now be remembered just a little differently. While our hopes are for the safety of all of you out there, what you really want to know is “Will REAC grant a blanket extension this year?”

We have received over one hundred calls and emails in the last 24 hours alone. Unfortunately, it has been impossible for us to answer all of the phone calls and emails regarding this issue. REAC has just now approved a 30-day extension of the filing requirement. The revised due date is 4/30/2020. This announcement will be posted on the FASSUB announcements page within the REAC system.

Global 30-day Extension for All Submissions with a Due Date of 3/31/20
Due to business disruptions caused by the COVID-19 virus, the Office of Housing has issued approval for a 30-day extension of all financial statements having a due date of 3/31/20. This will include the owner-certified greater than $750K submissions with a 3/31/20 due date, and the 6/30/19 OMB audited submissions that are due on 3/31/20. It will also include both unaudited and audited submissions for for-profit entities due on 3/31/20. The revised due date is 4/30/20.

We are awaiting updates from FHA and RD.

We want to assure you that we are aware of the challenges you are facing. Best of luck and be safe out there.

Les, Kathy, and the AHACPA Team


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Details on Deadline Grace Period

 

Clarification of HUD’s 30-day Extension Due to FAC Data Breach

UPDATE – HUD posted the following update regarding submission extensions.

“Audit submissions due to the Federal Audit Clearinghouse between 7/22/2015 and 1/31/2016 have been granted extensions through February 1, 2016. Since the HUD audit attestation process references the submission of the OMB Data Collection Form, HUD is mirroring this extension for nonprofit audited FASS submissions with due dates between 7/22/15 and 1/31/16. These submissions will now be due on or before 2/1/16.” [end update]


Beginning in September (2015) HUD granted a 30‐day extension of the REAC filing requirement due to delays resulting from the closure of the Federal Clearinghouse. Language used by REAC in its announcement implies that REAC filings cannot be completed due to the lack of filing with the Clearinghouse. The current language is as follows:

“A recent security breach at the U.S. Department of Census has caused the Federal Audit Clearinghouse (FAC) to be taken down. As a result, submissions of Data Collection Forms and reporting packages are not able to be made and the FAC has provided an extension until October 31, 2015. Since the HUD Agreed‐Upon procedures engagement performed on FASS submissions includes procedures comparing information in the Data Collection Form to the information submitted to HUD via FASS, HUD is extending the due date for financial statements with fiscal year ending June 30, 2015, until October 31, 2015. This is a global extension and will apply to all submissions including owner certified and audited. This may also impact December 31, 2014 audit submissions only that face the 9 month A‐133 filing deadline which the FAC extended to October 31, 2015. If needed, those auditees should file for an extension request using the FASSUB electronically.”

This language has led to many inquiries from practitioners questioning whether this means that they cannot file the REAC submission until the Data Collection Form is filed. The following is an example of such inquiry.

“Still trying to get some clarification on the blanket extension ‐ one of my coworkers recently attended one of the (AHACPA) multifamily update classes and said that you told them that there was no connection between the AUP on the HUD submissions and the data collection form, and that the extension was there just if we want it. Some of our staff agree and didn’t see what the big deal with going ahead and submitting would be; however, it reads to most of us as “you can’t complete the AUP, since part of that is comparing to the DCF, so you can’t/shouldn’t submit the HUD submission until you can file the DCF.”

So ‐ some of our filings got submitted by 9/30/15 and some got held up for this and other reasons, but it’s caused quite a bit of confusion on exactly what we are/are not supposed to do. And trying to explain to clients has been interesting. Any clarification you can provide will be most appreciated.”

AHACPA has been reluctant to answer each of these emails as we were unsure the source of the implied restriction. We have included the current AUP procedures as they currently exist:
Agreed-upon-procedures-v1

Agreed-upon-procedures-v2

THE AUP procedures, as currently outlined, do call for the comparison of the General Information (S3300, 3700 and S3800 series of accounts) to the Schedule of Findings and Questioned Costs and Federal Awards Data. Federal Award Data is usually contained on a sheet in the AFS package and represents the “Hard Copy Data”. Other commenters have indicated a potential conflict in the following language:

“We have performed the procedure described in the second paragraph of this report, which was agreed to by XYZ, Inc. and the U.S. Department of Housing and Urban Development, Public Indian Housing ‐ Real Estate Assessment Center (PIH‐REAC), solely to assist them in determining whether the electronic submission of certain information agrees with the related hard copy documents included within the OMB Circular A‐133 reporting package.”

To the best of our knowledge, no firms have been delaying their issuance of the REAC submission until the filing of the Data Collection Form with the FAC. This would be a major change in procedure. In reality AHACPA does not see such a significant link to warrant any delays in filing the REAC submission if the auditor may file the REAC submission before the filing to the Clearinghouse as long as the Federal Awards data contained in the hard copy is consistent with the DCF data when ultimately filed with the Clearinghouse.

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