| ID | Status | Date | Public/Private | Industry | AHACPA Contact |
|---|---|---|---|---|---|
| #15194 | Closed | public | Multifamily | Les Sparks |
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I have downloaded both the basic compliance matrix and the audit guide compliance matrix v2019 from the website. The information on Fair Housing and Nondiscrimination seems to conflict between the two for 223(f) loans with the basic matrix marked No and the audit guide compliance matrix marked Yes. Which is correct? I have a new client with a 223(f) who says he has never been asked about it by prior auditors. |
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Kristin, the confusion is warranted to some extent. I have been trying to coordinate all of the items from the past. The story is that after 2012 when OIG removed the Fair Housing report they intended to get rid of the Fair Housing section from the Guide. They never got around to doing it. So, initially we took the stance that Fair Housing was irrelevant.
A couple of years go by and QASS begins to ding people for ignoring the Fair Housing procedures. So, we added a few of them back. It is an unstable relationship. Some work must be done on Fair Housing, but not enough to opine on it. The “how much” depends
I would not be surprised that the prior auditor never mentioned it.
Les Sparks AHACPA (801) 547-0809
From: AHACPA Support <support@ahacpa.org> |