| ID | Status | Date | Public/Private | Industry | AHACPA Contact |
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| #15025 | Closed | public | Multifamily | Les Sparks |
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hello Les, we have an entity that owns 2 projects, each one is project based section 8. thank you! |
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Kate, the guidance here is a little murky. From the attached notice, we can determine that HUD wants the determination of audit requirements to be based on the owner and not the project. I have sent a question to REAC to determine how to handle the major program reporting as well as the submission.
Les Sparks AHACPA (801) 547-0809
From: AHACPA Support <support@ahacpa.org> |
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I just heard back from REAC. They are two separate project, so neither on is audited. They can both be filed as Owner-certified statements.
Kathy and I believe this is a change from previous guidance from 7 years ago.
Les Sparks AHACPA (801) 547-0809
From: AHACPA Support <support@ahacpa.org> |
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Less, previously you haven mentioned that we need to file an audit since this is one entity with two HAP contracts. Now , it appears not? Each HAP contract is less than 500K , we believe the compliance report is not required , just an audit report. Back in June the owners requested to combine two projects for REAC submission since its under one entity EIN. Haven’t heard back. But we were planning to file a combined financial statements, wasn’t not sure on compliance aspect. Les Sparks February 10, 2021 3:21 pm 2 weeks ago
Kate, I believe this has already been answered outside of this system. EIN governs everything. If they share the same EIN, then you measure their expenditures at the EIN level. Housing Notice 2013-23 gives this guidance. It is attached. |