(NEW) Auditor Attestation for Nonprofit Owners
The Federal Audit Clearinghouse (FAC) is currently modifying their electronic reporting system to be in compliance with the new OMB Uniform Administrative Requirements. These changes will not be implemented until sometime this summer. The text of the FASSUB auditor attestation for nonprofits requires auditors to certify that a copy of the reporting package required by OMB is available for review. Since the FAC has not yet modified their system we realize that it is currently not possible for owners to acquire the complete OMB reporting package. We are posting this notice to formally announce that we are suspending this part of the attestation requirement. There is not sufficient time before the filing deadline to modify the text of the electronic attestation, but we will not hold auditors/owners responsible for producing a complete OMB reporting package for the 12/31/15 fiscal year end reporting period.
Office of Management and Budget (OMB) Uniform Guidance
On the evening of December 23, 2015 the FASSUB data templates for nonprofit audits were updated to comply with the OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements. Major changes include increasing the federal awards threshold for audits from $500,000 to $750,000, changes to the titles and reporting requirements of auditor reports, and changes to the format and content of the auditor’s Schedule of Findings and Questioned Costs. Specific details regarding reporting changes can be found in the updated versions of Appendices E and F of the Industry User Guide.
- Federal Audit Clearinghouse (FAC) Image Management System
Audit submissions due to the Federal Audit Clearinghouse between 7/22/2015 and 1/31/2016 have been granted extensions through February 1, 2016. Since the HUD audit attestation process references the submission of the OMB Data Collection Form, HUD is mirroring this extension for nonprofit audited FASS submissions with due dates between 7/22/15 and 1/31/16. These submissions will now be due on or before 2/1/16.
- Office of Management and Budget (OMB) Uniform Guidance
On December 26, 2013, the OMB issued the final rule for the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Uniform Guidance supersedes several OMB circulars including A133. The new rule makes several important policy changes the most significant of which is increasing the federal audit threshold for nonprofits from the current limit of $500,000 to $750,000. This means that nonprofit owners of federally assisted multifamily properties that receive less than $750,000 in federal financial assistance will be able to file owner-certified financial statements instead of audited financial statements. The new rule is effective for owners with fiscal years beginning December 26, 2014 and thereafter, so this means that owners filing their yearend December 31, 2015 financial statements will be subject to the new requirements.
The federal awards threshold change only applies to nonprofit owners of HUD-assisted properties. Profit-motivated owners will still use the $500,000 federal awards threshold. Owners are reminded that owner-certified financial statements must be prepared in accordance with Generally Accepted Accounting Principles (GAAP) and must include a full set of notes to financial statements. Federal financial assistance for HUD multifamily properties includes the combination of:
- The outstanding beginning balance of HUD-insured or HUD-held mortgages
- The original amount of 202/811 capital grants
- Project-based rent subsidies received during the year
- Interest reduction payments receiving during the year
- Retained excess income
- Other federal grants received during the year (e.g. service coordinator)
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