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IN THIS ISSUE:
- No Word on Availability of Extension on Submission Deadline
- FHA Changes LASS Template
- AHACPA Comments on OMB's Proposed Rule on A-133
- Information on Annual PHA Conference, Multifamily Conference & Lender Update in Las Vegas
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Be among the first to know if HUD extends the submission deadline! 
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NO WORD ON AVAILABILITY OF EXTENSION OF SUBMISSION DEADLINE |
| We have received many calls in the past week inquiring about the possibility of an extension of the electronic filing deadline. Questions directed to REAC have reminded everyone that REAC does not have the power to extend the deadline. The decision is made solely by Multifamily Housing. As of Friday, there was no indication that an extension is pending. |
FHA CHANGES THE LASS TEMPLATE |
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This past week, FHA made changes to the LASS financial submission template. The changes were made to the Data Collection Form (DCF) section of the template. The change added three new lines to the "Financial Statements" tab. The three new lines are as follows:
G3000-120 Lenders Liquidity Shortage
G3000-120 Lender's Net Worth Shortage
G3000-140 CPA Certification
The liquidity and net worth shortage lines are to be used when shortages are noted in either liquidity or net worth. The CPA certification line is to be used only when the State of the CPA differs with the State of the Lender. If none of the three lines are applicable to your client DO NOT select anything from the drop down as there are no other choices but to attach a related document. Simply leave each line at "--Select--" and move to the next screen.
In situations where the condition exists, the attachment should contain documentation to support the correction of the deficiency. It is unclear whether these documents are to replace documents already included in the client's Corrective Action Plan as FHA has not released documentation on this issue as of yet.
For CPAs whose home state is different from the lender's home-office state, they should attach documentation that indicates they are licensed in the state of the lender. Some firms simply printed web pages from the state's licensing division indicating that such licenses are in place. Again, it is unclear what will be acceptable in this situation.
Additional information compiled by AHACPA, including screen shots, may be found here. |
AHACPA COMMENTS ON OMB's PROPOSED RULE ON A-133 |
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On February 28, 2012, OMB issued a proposed rule to modify the A-133 reporting requirements as well as other proposals related to modifying the Cost Standards under Circulars A-87, A-110 and A-122. The proposed rule had a 30-day comment period expiring on Thursday, March 29, 2012. Click here to see the proposed rule.
The proposed rule would adopt the following general ideas:
- Remove audit procedures for all recipients expending less than $1 million in federal awards.
- Recipients expending $1 million and less than $3 million would have a single audit, but the compliance procedures would be limited to two, one of which would always be allowable/unallowable costs. The agency would select the remaining test to be performed.
- Recipients expending $3 million in awards would undergo a complete A-133, but OMB would be considering additional changes to simplify the compliance supplements.
- Other changes related to the cost principle standards and changes for subrecipients.
AHACPA's comments were limited primarily to those effecting A-133. Specifically, AHACPA is not in favor of eliminating all single audit requirements for entities expending less than $1 million dollars. Despite recognition among practitioners that the single audit requirements are indeed burdensome to both the auditor and the recipient, AHACPA feels that elimination of these requirements is not in the best interest of the recipient or the agency. This is primarily due to the fact that the recipient's reporting requirements will continue and such entities generally require the services of a CPA to even complete the required owner-certified filing. Rather, we have proposed to eliminate the financial audit requirement in favor of a compilation or review engagement supported by additional compliance requirements in an AUP engagement.
For entities expending three million or more, we are not in favor of restricting the compliance requirements tested to two. This is especially true since one would always be allowable and unallowable costs. Our objection in this case is that limiting the audit to such procedures will not achieve the agency's objectives. Further, many of the compliance requirements being tested are derived from the audited statements. We suggest that the agency retain the flexibility to select the compliance procedures to be tested.
A complete copy of AHACPA's comment letter may be found here.
Also, since this proposal has the potential to severely limit the amount of audits performed by AHACPA's membership, we believe it is important that each member firm submit its own comments directly to OMB. Comments may either be submitted directly or firms may attach a comment letter. We acknowledge the inconvenience of having to respond in the last week of March, but by commenting directly to the website, we hope the time may be reduced.
Comments may be submitted directly to OMB here. |
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13th ANNUAL PHA CONFERENCE |
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Planet Hollywood Resort
3667 Las Vegas Blvd, South
Las Vegas, NV 89109
June 7, 2012 8:00 am - 5:00 pm
June 8, 2012 8:00 am - 3:10 pm
Course Fee: $625 ($575 for AHACPA Members)
Fee includes course materials, continental breakfast, lunch,
soda/coffee breaks and a social hour on June 7, 2012 at 5:00 pm
Click here to pay by credit card - Regular registration
Click here to pay by credit card - AHACPA Member registration (member ID required)
Click here to download a printable registration form **Register by May 7th to receive $50 early registration discount** |
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14th ANNUAL MULTIFAMILY CONFERENCE |
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**NEW LOCATION**
The Cosmopolitan of Las Vegas
3708 Las Vegas Boulevard South
Las Vegas, NV 89109
December 4, 2012 8:00 am - 5:00 pm
December 5, 2012 8:00 am - 3:10 pm
Course Fee: $625 ($575 for AHACPA Members)
Fee includes course materials, continental breakfast, lunch,
soda/coffee breaks and a social hour on December 4, 2012 at 5:00 pm
Registration will be open at the beginning of April.
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LENDER UPDATE - LAS VEGAS |
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**NEW LOCATION**
The Cosmopolitan of Las Vegas
3708 Las Vegas Boulevard South
Las Vegas, NV 89109
December 3, 2012 8:30 am - 4:30 pm
Course Fee: $375 ($325 for AHACPA Members)
Fee includes course materials, continental breakfast, lunch,
soda/coffee breaks.
Registration will be open at the beginning of April.
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FALL MULTIFAMILY and LENDER UPDATE COURSES |
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The Multifamily and Lender Update courses have not yet been scheduled. As these course dates and locations are determined the information will be posted here. |
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 AHACPA is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.learningmarket.org
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