HUD Single Audit for prior years

ID Status Date Public/Private Industry AHACPA Contact
#17345 Closed public Multifamily Les Sparks
Customer Reply

We have been engaged to do a HUD Single Audit on a property with a Section 202 capital advance and rental assistance.  We previously audited this property in 2017, the last audit that has been done.  They have not been able to pay our fee for this 2017 audit until now.  We have the following questions about how to handle this 2018 audit (and the 2019, 2020, and 2021 audits as we catch them up):

  1. Do we audit under 2018 Uniform Guidance or 2022 Uniform Guidance?
  2. Should the audit reports be prepared under old reporting requirements or new requirements under SAS 134?
  3. In addition, the IRS revoked the entity’s nonprofit status effective May 15, 2021. In light of this status revocation, is a Single Audit required for the entity at this time?  Or is the audit based on the status at the audit date (12/31/18)?  The entity is working on getting the nonprofit status reinstated, but with current delays at the IRS, the timeline on this is unknown.
  4. Since the nonprofit status has been revoked, has the capital advance agreement been violated, since Section 202 is specifically designed for “private, nonprofit sponsors”?
  5. And, what type of tax return needs to be filed? Form 990, since the entity was a nonprofit in 2018 OR Form 1120, since the status was revoked prior to filing of the return?

Write a reply

The ticket has been closed. If you feel that your issue has not been solved yet or something new came up in relation to this ticket, you can re-open it by clicking this link.
Item Status Opt-in Date Opt-out Date Action
Subject
Additional Information
Subject