The Berman Buzz

THE BH BULLETIN: FEBRUARY 2022


One Way To Address Employee Fraud Concerns

We recently presented a session on the Fraud Triangle at PHADA. If an individual in your organization experiences pressure in their personal life and a conscience that is not centered or feels underappreciated, mistreated, or underpaid, you might be at risk. If, as an organization, you can address the third “point” of the triangle, known as ‘the opportunity,’ you would be able to mitigate this level of risk. Your organization can reduce the exposure by not providing the opportunity through internal controls, including segregation of duties, and safeguarding your assets to these individuals. One of the key takeaways is to allow budget dollars to support the adequate staffing of the accounting department.


Get Ready to Sharpen Your Pencils for GASB 87 on Leases

We recently presented a webinar on implementing the new GASB 87 standard, specific to PHAs. It may be helpful to check it out* as the requirement to implement it is for FYE on or after June 30, 2022 (as extended by GASB 95).


In simple terms, the focus shifts away from “ownership” and moves towards the “right to use.” If you own an asset and are leasing it out as the lessor, you keep the asset on your books from an ownership perspective. You, however, would add a Lease Receivable account (dr) with an offset to the newly created Deferred Inflow account (cr) that you always wanted to use (FDS line 400).The lessee would book an asset called “right to use leased asset,” as well as a lease payable.


*The password to access the webinar recording is 1?VTPt2P


PIH Notice 2022-02

HUD recently issued PIH notice 2022-02 on 2/4/2022, reminding us that the PHAS waivers issued in PIH 2021-14 expire. Starting with March 31, 2022, the fiscal year ends, and the scoring will be back up and running.


Through PHAS, HUD evaluates indicators (as defined by 24 CFR Part 902) that measure the Authorities’ performance. The attributes HUD monitors via PHAS are critical to the performance of the Authority, including financial, operations, and the physical condition of the property and capital fund obligation. HUD allowed for the flexibility needed during the pandemic, but they are regulated to monitor these scores.


The MASS and FASS (Management and Financial) are subcomponents of PHAS and come directly from the Financial Data Schedule. As you begin doing tenant recertifications with third-party verification, you may have tenant retroactive rent adjustments and catch-up payment plans for misrepresentations in self- certification. These are considered fraud receivables and not tenant receivables. Therefore, these should be recorded in Tenant Fraud Receivable (FDS line 128) vs. Tenant Rent Receivable (FDS line 126), which impacts your scoring in one sub-indicator.


With all the issues related to rent collections, from eviction moratoriums to PHAs having difficulty managing rental collection activities, this notice takes care of that and adjusts the TARs score to be more reflective of the average activities during the pandemic.


In addition, SEMAP will be coming live starting with March 2022 fiscal year ends.


Upcoming Dates

February 28, 2022

12/31/21 FYE Unaudited REAC due

March 15, 2022

3/15/21 FYE Partnership Tax Returns due

March 31, 2022

12/31/20 FYE Audited REAC due

May 15, 2022

12/31/21 FYE Nonprofit Tax Returns due

May 31, 2022

3/31/22 FYE Unaudited REAC due

Save the Date! Tuesday, May 17, 2022

Berman Hopkins PHA Webinar - More Info to Follow.

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