| ID | Status | Date | Public/Private | Industry | AHACPA Contact |
|---|---|---|---|---|---|
| #7463 | Closed | public | Multifamily | Les Sparks |
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As a follow up to the Chicago Multifamily update, what is the status of recapturing residual receipts balances for PRAC contracts? At that CPE, it was clarified that this related to contracts that expire 7/19/15 – 9/30/15 only, but the intention was to write this into law for later expiration dates. Was there anything written into law as of 12/31/15 or later? Also, we have a NFP Multifamily entity that has federal expenditures of ~$515k. Therefore, it will not require a compliance audit for 2015 due to the increased threshold of $750k. However, I looked at the FASS Industry User Guide updated in December 2015, and that guide still references to the previous threshold of $500k when discussing which type of REAC submission to file. Please advise. |
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From Les Sparks: As of today (6/21/2016), I have not heard whether HUD has additional authority to collect RR. Until they make a statement, I would do nothing but disclose the possibility of a recapture. I did go back to M/F website. There are no recent releases discussing this. My advice is stay patient and disclose the possibility. From client: Thank you for your guidance on the residual receipts recapture. Please see my second question below about the REAC filings – it looks like in the templates they are still indicating that the owner-certified filings must be under $500k to be audited. Please advise how we treat this for a client that has federal awards just over $500k (but below the new audit threshold of $750k). From Les: Elizabeth, I have not been in the system in the last few days, however, I have been told that for a NFP, the amount should have been changed to $750,000. For the for-profit items they remain at $500k. If the submission is being performed is 12/31/15 and is a NFP, let me know if the amount is still $500K. Just send us a screen shot. In summary: If it is not like that we need to know. |