A CPA firm that takes on a housing authority or a HUD-assisted apartment owner meets a reporting rule that is separate from the audit standards. 24 CFR 5.801 says who files annual financial information with HUD, on what basis, by which date and how. The audit calendar, the engagement letter and the client's expectations all depend on it. This guide covers the rule and a planning approach. It does not cover the content of HUD's own audit guidance, which the firm should obtain from HUD directly and build into the program for each engagement.
Who the rule covers
Section 5.801(a) applies to six groups:
- Public housing agencies (PHAs) receiving assistance under sections 5, 9 or 14 of the 1937 Act.
- PHAs as Section 8 contract administrators. This covers project-based programs (New Construction, Substantial Rehabilitation, Loan Management Set-Aside, Property Disposition and Moderate Rehabilitation including SRO), Project-Based Voucher, project-based renewal contracts and the tenant-based Voucher program.
- Owners of Section 8 project-based housing, covering the same project-based HAP programs but excluding Moderate Rehabilitation (including SRO) and Project-Based Voucher.
- Owners of HUD-assisted or HUD-insured multifamily projects, including projects under Sections 202, 811, 207, 213, 220, 221(d)(3) and (5), 221(d)(4), 231, 232, 234(d), 236 and 241.
- HUD-approved lenders, meaning Title I and Title II supervised, nonsupervised and investing lenders, plus investing mortgagees.
- Operators of Section 232 projects with HUD-insured or HUD-held Section 232 mortgages.
Section 5.801(f) places responsibility for submitting the report on the individuals and entities listed in paragraph (a). The report belongs to the client. The auditor's work supports it.
Basis and format
Section 5.801(b) requires annual financial information as HUD requires, and says the reports must follow generally accepted accounting principles as HUD further defines them. Submission is electronic, through the internet or another format HUD designates. Paper is allowed only if HUD finds electronic reporting excessively burdensome. For Section 232 properties, reports also go to the mortgagee at the same time.
The practical consequence for the audit team: the financial statements audited are the statements the client must submit, and the GAAP basis is the baseline. Any HUD-specific definitions apply on top of it. Keep a record in the planning memo of where HUD's requirements modify the client's usual presentation.
Filing dates
Section 5.801(c) sets the dates for the submissions:
| Group | Due |
|---|---|
| PHAs | Within 60 days after fiscal year end (see also 24 CFR 903.33) |
| Owners | Within 90 days after fiscal year end |
| Lenders | Within 90 days after fiscal year end; extensions at the Secretary's sole discretion, requested 15 to 45 days before the deadline |
| Section 232 operators | Quarterly and year-to-date reports within 60 days after each quarter; the final quarter and year-end report within 90 days; the Commissioner may extend for good cause |
For PHAs, section 5.801(d) distinguishes between the unaudited report, due 60 days after year end, and the audited statements, due no later than nine months after year end under the Single Audit Act and 2 CFR part 200, subpart F. An auditor of a PHA therefore works to the nine-month date for the audit and the Single Audit package, while the client's unaudited submission is due much earlier. Make sure the client knows that the 60-day submission is theirs, and that the audit does not hold it up.
Section 232 operators and the audited statement exception
Under 5.801(c)(4)(i), operators of Section 232 projects may submit operator-certified statements in place of audited ones. If the operator is also the borrower, an annual audited statement is still required. Under (c)(4)(ii), HUD may require audited statements if certified statements appear unreliable or do not follow GAAP, and may request more frequent reports. A firm asked to audit a Section 232 operator should confirm which of these applies before it sets the fee and scope.
A planning calendar
Take a PHA with a fiscal year ending September 30, 2026.
- Unaudited report. Due 60 days after year end. Counting 60 days from September 30, 2026 gives Sunday, November 29, 2026.
- Audited statements and Single Audit package. Due no later than nine months after year end: Wednesday, June 30, 2027. For the federal single audit reporting package, the Federal Audit Clearinghouse deadline applies as well. See Single Audit late submission and remedies.
- Working backward. For a June 30 outer date, set the report date, exit meeting and fieldwork. A realistic plan puts interim work in the spring, final fieldwork in April and May, and the report in early June, which leaves room to resolve any extension request with HUD.
An owner of a multifamily project with a December 31, 2026 year end has 90 days after year end for the annual filing, which is Wednesday, March 31, 2027. For both clients, record in the engagement letter the date by which the client must give the firm the trial balance and records.
Procedures to build into the file
- Classify the client. Identify which paragraph (a) group the client belongs to, since it decides the filing date and the audited-statement requirement.
- Obtain HUD's current guidance for that program. The program's audit and reporting requirements sit outside this regulation and belong in the audit program.
- Confirm the basis. Document that the statements are GAAP statements and note any HUD-specific definitions applied.
- Calendar the dates. Unaudited and audited dates are separate for PHAs.
- Confirm electronic submission access. The client's staff need system access before the due date, not on it.
- Review mortgagee reporting. For Section 232 properties, check that the mortgagee gets the reports at the same time.
Related reading
For the federal compliance side, see the OMB Compliance Supplement standards page and the Single Audit walkthrough.
Where CORAA fits
CORAA prepares ready-to-review audit files for US CPA firms, including calendars, tie-outs and schedules. The firm keeps the client, the review and the signature. See /us.
Sources
- eCFR, 24 CFR 5.801, Uniform financial reporting standards: https://www.ecfr.gov/current/title-24/subtitle-A/part-5/subpart-H/section-5.801
- Legal Information Institute, 24 CFR 5.801, Uniform financial reporting standards: https://www.law.cornell.edu/cfr/text/24/5.801
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