Bank Fees Replacement Reserve and Residual Receipts

ID Status Date Public/Private Industry AHACPA Contact
#7008 Closed public Multifamily Les Sparks
Customer Reply

I have a client and their replacement reserve bank recently started charging monthly fees on their replacement and residual receipts accounts. They also billed them for audit confirmations for the first time this year. Does she have to reimburse the accounts for those fees or is that an allowable withdraw from the account? She has never had this in the past. I’m not sure if this matters, but here is some back ground: They have a Section 202 loan and flex subsidy loan. They pay their mortgage to HUD directly and therefore, must make the monthly R&R deposits on their own to a bank account that they control (but they only withdraw with HUD approval). Thank you.

Kathy Christensen

From Les Sparks:

Generally, such fees are allowable project expenses. Most CPAs net them against interest income. That works until the income amounts are negative. It is usually best to just separate them. Do not put the charges in the “approved withdrawal” line item. Just list them in other.

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