We are seeing many inconsistencies in Flags in REAC and MOR scores. Participants that have larger portfolios have a much harder time because at any given point in time they are going to get a failing REAC or MOR score. We have seen way more MOR flags with larger portfolio clients. These take a while longer work through the 30 day response cycle with the CA. While waiting for your REAC and MOR scores, another issue can easily pop up. This affects preservation deals.
Financial Flags – The system is riddled with these auto flags that 99% of the time the audit has been filed. A HUD AE should be able to look at the flags listed under their responsibility and identify the ones that should be resolved. There are flags in the system going back before 2010. A field office may not give these flags much attention when reviewing a 2530 but when a Organization change 2530 is filed at HUD HQ we have to provide the documentation that it was filed. HUD needs better oversight of the flags so that they are being applied properly and not punitively.
Secured Systems Consulting is a national top-rated HUD compliance consulting firm that specializes in advising owners, developers and managing agents in the affordable housing industry with their HUD transactions. Contact Us to help you navigate HUD Baseline requirements.
