From Les Sparks:
Since the client is a non-profit client, it should be following Uniform Guidance. The only time a NFP client would use the HUD Audit Guide would be when there was no compliance supplement. Even then the audit would be Uniform Guidance, but the audit steps would come from the Guide.
From client:
Thanks for the quick response. I forgot to add some additional details.
My original question was “We have a new client that has a 202 Loan. Should we be following Uniform Guidance or Hud?”
I should have specified that this is a for profit client. The loan was assigned from a non profit and a non profit is one of the partners in the Partnership. Therefore, should we be following Uniform Guidance or Hud?
From Les:
If the audit you are doing is on a for-profit entity, then you cannot do a UG audit. Do a for-profit audit using the Guide. I am assuming this is a direct-loan 202 and not a capital advance, correct?
Just make sure that you add the senior component to eligibility criteria.