| ID | Status | Date | Public/Private | Industry | AHACPA Contact |
|---|---|---|---|---|---|
| #6817 | Closed | public | Multifamily | Les Sparks |
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From September 20, 2016 We are members of your organization and Les has provided in-house CPE for us on numerous occasions over the years. I have a few questions regarding the status of residual receipt recapture for Section 202 & 811 projects. I have a copy of your 2/1/16 article which states that HUD was at that time seeking Congressional authority related to recapture of residual receipts. Has that happened to date? If so, where can I obtain that information? We are wrapping up 6/30/16 FYE audit for a client with a Section 202 project that has residual receipts far in excess of the $250 per unit. Their PRAC assistance contract did not expire within the period from July 19, 2015 through September 30, 2015. We are trying to determine if we need to go beyond footnote disclosure of this contingency. What are you all seeing in other 202/811 projects? |
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From Les Sparks: As of the last time I talked to a HUD Filed office, I can tell you the intention is to continue the recapture process. However, the overall approach is now fairly disjointed. Some offices are forcing an offset against Section 8 payments. Others are asking for the money directly. We seem to have arrived at a point of confusion due to the pending change of administrations. So, some clients are still contending that it will not happen. Our opinion is the HUD is going to take the money. It is just a question of when they finally decide when and how. Until then, I would seriously consider reserving against the future loss of those funds. Otherwise, we really need to have a note discussing the loss. |