Reporting RAD on FDS

ID Status Date Public/Private Industry AHACPA Contact
#7848 Closed public PHA Les Sparks
Customer Reply

Our PHA has been awarded a CHAP and we hope to close on 11/30/15.
Our FYE is 06/30. During the fiscal year, our developer applied for funds for our development project from the Community Development Cooperation. Because the funds had to be used by 07/2015, we paid soft cost for engineers, architects, legal fees etc. The Fee Accountant listed the transaction on the FDS as a Business Activity. Our auditor has determined this to be a major finding.

I have interpreted that the Fee Accountant should have recorded it as follows.

* Prior to Issuance of the HAP Contract – Report as part of the pre-conversion PH Project.

Kathy Christensen

From Les Sparks:

The answer to your question is answered, I believe, the RAD Accounting Brief #22. Here is the language I am referring to:

2. HUD issued the CHAP for the project on 9/30/2013, which is during the PHA’s FYE 12/31/2013. However, until the HAP contract is issued, the project is still public housing and remains on the PHA’s ACC. Therefore, on the PHA’s FYE 12/31/2013 FDS, the project will continue to be reflected in its own column of the Public Housing program for the entire fiscal year (1/1/2013 to 12/31/2013). However, the project’s RAD indicator will be automatically populated as “Yes,” so the project will not be scored through PHAS for this entire year.

So, it should not be in BA, but should remain in the project. This leaves you with the only real question as to whether the costs should be capitalized as part of the new financing in accordance with GAAP or whether they should be expensed. Wherever they go, they belong in the project. At the time of HAP issuance, they will flow to the appropriate FDS column based on GASB 61/14.

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