Financial statement and other information must be submitted to REAC electronically by PHAs or multi-family program participants on FASS using templates (referred to as FASS templates) specifically designed for them. Auditors participate in this submission process. In order to insure accuracy and consistency of financial data in the assessment process, REAC requires the following as the basis for electronic submission:
- Audited annual basic financial statements prepared in conformity with GAAP (PHAs submit basic financial statements and certain auditor’s reports electronically to REAC as well as maintain a hard copy of all financial statements and audit reports for three years; however, multi-family program participants maintain a hard copy of the basic financial statements and audit reports for three years but do not submit the statements or reports electronically)
- Report by auditors on the hard copy of the FASS templates as to their “fair presentation in relation to audited basic financial statements” in accordance with the audit provisions of the AICPA Statement on Auditing Standards (SAS) No. 29, Reporting on Information Accompanying the Basic Financial Statements in Auditor-Submitted Documents, (PHAs must electronically submit the required FASS template and related SAS 29 reporting to REAC; multi-family program participants must electronically submit the required FASS templates to REAC, however, are not required to electronically submit the related SAS 29 reporting; PHAs and multi-family program participants must both maintain a hard copy of the SAS 29 reporting for three years); and
- A separate (i.e., not part of the above two requirements) attestation agreed-upon procedures engagement under AICPA Statement on Standards for Attestation Engagements where the auditor compares the electronically submitted data in the REAC staging database (the FASS template information) to the related hard copy documents (the attestation report is prepared and submitted to REAC electronically by the auditor).
REAC requires owners to engage a licensed CPA or CPA firm to perform the agreed-upon procedures (see previous bullet) enumerated in a document titled, Guidelines for Reporting and Attestation Requirements of Uniform Financial Reporting Standards For Public Housing Authorities, Not-for-Profit Multi-family Program Participants, For-Profit Multifamily Program Participants, and their Independent Accountants. The main purpose of this Guideline is to provide guidance to PHAs and multifamily participants and their auditors in meeting the above requirements.