| ID | Status | Date | Public/Private | Industry | AHACPA Contact |
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| #14058 | Closed | public | Multifamily | Les Sparks |
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I am reviewing with a client the information contained in HUD Housing notice H 20-4 and HUD Handbook 4350.3 as it relates to auditor access of EIV data. The HUD handbook limits IPAs access to EIV data to “only within hard copy files and only within the offices of the owner or management agent”. My client does not agree that the HUD Housing notice H 20-4 supersedes this restriction. Based upon travel restrictions due to COVID 19, the ability to review EIV data “only within hard copy files and only within the offices of the owner or management agent” will not be possible. The work arounds I can think of would be 1) to have the audit have a video call with the owner/management agent, and for the owner/management agent hold up the EIV data to the camera will the auditor confirms the data, 2) IPA hires a IPA that works in the same area as the owner/management agent and have them perform the EIV verification. Please provide any insight that you might have regarding this situation. Thank you. |
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John, I can imagine that a client does not think that access should be granted. However, what does it say when they allow access to all O/A records now. It could have said “except for EIV”, but it did not. Conversely, it could have said …”including EIV.”
We have requested on several occasions clarification on the language to no avail.
Personally, I would use a program such as Teamviewer or another screen -share program. Then, the client just gives you access to view their monitor and you see the data. NO ONE is going to hire another auditor. You either give us access, or you screen share or we qualify our reports. Those are the three choices.
Absent the client being in agreement, the only other reasonable choices is a screen share program. I do not think cameras work well in these scenarios.
I also want to add that these requirements only apply to for-profit Section projects. In the NFP world, I do not believe the viewing of EIV data is required.
Les Sparks AHACPA (801) 547-0809
From: AHACPA Support <support@ahacpa.org> |
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Thank you.
John F. Norton, CPA 585-503-1011 (Mobile)
2300 Buffalo Road, Building 200 | office 585-279-0120
Website
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From: AHACPA Support <support@ahacpa.org> Sent: Monday, October 5, 2020 5:48 PM |
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Les, This would seem to indicate that the screen share option as suggested in our previous correspondence would not be an option. What information have you heard from HUD or other firms on this issue? John Norton |
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John, another update. We have it on good authority that HUD will be clarifying 2000.4 to specifically exclude EIV data. That means it is assured that we will not have access to EIV. The conversation now is whether any of the larger firms will consider this a scope limitation. So far, two of them have indicated that they will not scope limit the compliance report.
All have indicated that they will make an effort to test in another way. Further, it is uncertain how big of a deal this is to HUD.
Les Sparks AHACPA (801) 547-0809
From: AHACPA Support <support@ahacpa.org> |