Sale of a NFP Project

ID Status Date Public/Private Industry AHACPA Contact
#7134 Closed public Multifamily Les Sparks
Customer Reply

Hi Les,
I have a NFP client with a 6/30 fiscal year-end that is a NFP project w/ 223(f) funding.

They have signed an agreement to sell their facility to a separate legal entity in April 2017 and I am wondering appropriate reporting requirements as I cannot find anything on the HUD website. Specifically:
1. Do I need to issue a short period audit 7/1 – date of sale or day before sale?
2. Do they expect a different basis of accounting in the report such as liquidation basis or just a standard report w/ a subsequent event disclosure?
3. Is a REAC submission required for the short period and will it be due 90 days after the short period or 90 days after their traditional fiscal year-end?

The client has minimal documentation at this point so I am hoping you can provide some clarification.

Kathy Christensen

From Les:

The project will be required to submit a stub period financial statement from July 1 through the day before the sale. No liquidation accounting is allowed. This is the reason for the day before the sale…

Unfortunately, you are so late int he year that no other choice of period is available to you. Everything should look as it did last year with the exception of a footnote regarding the sale.


From client:

One follow-up – timing of the REAC.

Is it due 90 days as of the stub reporting period or can it still be submitted 90 days after the normal fiscal year-end?


From Les:

Technically it should be 90 days from the closing date. However, there is no late tracking in the REAC system, so you get away with filing later at year end. I think that main thing is that is it received sometime before the end.


From client:

Thanks for all of the guidance. Once issue we just found out is that with the sale they no longer have access to the tenant files. Have you seen other audit firms with this issue and how did they resolve?


From Les:

All of the time. The truth is the new management company should never restrict access to the old auditor. If I had this occur, I would issue a scope limitation naming the new management company as the culprit. By name. This should never occur. However, it does all the time.

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