| ID | Status | Date | Public/Private | Industry | AHACPA Contact |
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| #7280 | Closed | public | Multifamily | Les Sparks |
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I wanted to ask a quick question before we come up for training in Chicago. We have a client that owns 100% of a project who recently sold it to a related party and the new entity took over the HUD financing. Would the client need two audits during the year? Thank you for your help, call me if you would like or need further information. |
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From Les Sparks: Okay, this is a tricky question. It is tricky because it all depends on definitions. If the TIN changes on a project, HUD will typically move to a TPA which will include a break in reporting. If the TIN does not change, but the owner does, it may still trigger a break in reporting and it may not. However, it is our opinion that in the second scenario, it probably always should trigger reporting, In the end it really depends on the individual facts and circumstances. and how HUD interprets the change. Please review the attached PDF issued by HUD Trying to explain how this works.
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