The United States Department of Agriculture (USDA) has made changes to the Rural Development (RD) Handbook for multi-family housing properties. Here is what they mean for RD properties and management companies.
Upcoming Rural Development Auditing Requirements
According to RD’s Multi-Family Housing Program final rule, published in October 2017, we expected several shifts in Rural Housing financial reporting requirements to ease the burden on properties. These changes in policies, confirmed in Chapter 4 of agency’s published handbook, reflect the USDA’s effort to better align their housing standards with those of the Department of Housing and Urban Development (HUD).
Starting FY 2018, RD properties must adhere to new rules, including:
- Audit requirement threshold based on amount of federal awards received, not number of units
- Elimination of Agreed-Upon-Procedures (AUPs)
- Elimination of RD tenant file testing
- Additional certification to ensure reserve accounts are used appropriately
For guidance on these new standards, see the RD office’s Unnumbered Letter for a full financial statement template.
Reason for Implementing Changes
As stated in the overview of the new standards, RD changed these reporting guidelines to help reduce the cost of filing financial statements, apply more strict standards to high-risk properties, and eliminate duplicate paperwork between government organizations.
By implementing the above guidelines, properties no longer have to deal with AUPs, and only high-risk properties that meet the threshold for financial reporting requirements need to have an audit done.
Impact of Rural Development Changes
All RD projects will no longer have to do AUPs as of FY 2018. Low-risk properties, whether for-profit or not-for-profit, are no longer required to submit audited financial statements. Instead, they must submit owner-certified statements. The threshold for high-risk properties is now the same as HUD’s requirements, laid out in the table below.
|Loan Amount||For-Profit Properties||Not-For-Profit Properties|
|<$500,000||Owner-certified prescribed forms*||Owner-certified prescribed forms*|
|$500,000 – $750,000||Audited Financial Statement||Owner-certified prescribed forms*|
|>$750,000||Audited Financial Statement||Audited Financial Statement|
*These include RD forms 3560-07 and 3560-10, along with the applicable supporting schedules, as well as the borrower’s Certification of Performance Standards.
Some property owners and management companies saw their accounting fees to drop in 2018 as they adopted RD’s new rules. However, this wasn’t the case for all properties. Because AUPs filled in part of the assurance service provided by the audit, auditors will have to make up for its absence by doing additional testing.
Though the overall process becomes simpler for everyone, the total time and cost of the audit may or may not change.
Financial Guidance from Donovan CPAs
If these changes are news to you, your property or management company may want a bottom-line determination of how much these changes could cost. We’re happy to provide a free analysis on submission requirements to aid your property’s budgeting process. All we need is FY 2017’s financial statements and RD forms 3560-07 and 3560-10. Give us a call and we’ll start the process.
If you have more questions about what these rules mean for your property, don’t hesitate to ask! Contact us online or give us a call. We’d love to hear from you and learn alongside you as we navigate these changes together.