Author: Tonia A. Crown

DOL Recordkeeping and Retention Requirements for Unions

Unions, like any other organization, are subject to financial recordkeeping requirements. The Labor-Management Reporting and Disclosure Act (LMRDA) provides specific guidelines for unions in regard to financial records and retention requirements, with the purpose of ensuring transparency and promoting democratic practices within labor organizations. According to the LMRDA, “unions must maintain financial records and other related records that clarify or verify any report filed with the Office of Labor-Management Standards (OLMS).” Your union’s treasurer and president—or the corresponding principal officers—are responsible for ensuring these recordkeeping requirements are met.

What records do you need to retain?

Per an OLMS Fact Sheet providing guidance on LMRDA recordkeeping requirements, examples of records that should be retained include, but are not limited to:

Receipts and disbursement journals
Cancelled checks and check stubs
Bank statements
Dues collection receipts
Employer checkoff statements
Per capita tax reports
Vendor invoices
Payroll records

In addition, unions should retain records that help explain or clarify financial transactions, including:

Credit card statements and itemized receipts for each credit card charge
Former members’ ledger cards
Union copies of bank deposit slips
Bank debit and credit memos
Vouchers for union expenditures
Internal union financial reports and statements
Minutes of all membership and executive board meetings
Accountants’ working papers used to prepare financial statements and reports filed with OLMS
Fixed assets inventory

Electronic records and software needed to complete, read, or file reports for the Office of Labor-Management Standards (OLMS) must also be retained. If you are not sure about whether to keep a record, you can contact the nearest OLM field office for advice.

How long do you need to retain records?

You must retain financial records (and other related records) for 5 years after a report is filed with the Office of Labor-Management Standards, during which time those records must be available for examination.

2025 Compliance Audit Finding Examples

OLMS conducts compliance audits of local unions under the Compliance Audit Program (CAP), following which closing letters are sent to the unions detailing any reporting or recordkeeping violations or deficiencies identified during the audit process. The closing letters for various unions audited thus far in 2025 can be viewed here. These letters reveal that, when it comes to OLMS recordkeeping requirements, details matter. Below are some examples of violations listed in these letters:

Missing receipts for meal expenses
Receipts for meal expenses were not itemized
Records of meal expenses did not include written explanations of union business conducted or the names and titles of people incurring the charges
Missing invoices for disbursements to vendors
Inadequate documentation for lost wage reimbursement payments to union officers and employees
Lack of documentation for reimbursed expenses and debit card expenses incurred by union officers
Inadequate documentation to support mileage reimbursements
Interest earned on savings accounts was not recorded in monthly financial books

As you can see, unions must accurately report financial activity and provide proper supporting documentation in order to avoid violations.

Contact Us

As you work to keep your union in compliance with recordkeeping requirements, you can count on RBT CPAs for all of your accounting, advisory, audit, and tax needs. Contact us today to learn how we can be Remarkably Better Together.

5 Common Findings in HUD Single Audits

Single audits—required for all non-federal entities expending over $750,000 in federal assistance during the fiscal year—examine an organization’s financial statements and compliance with federal award requirements. Single audits look at an entity’s financial records, policies, documentation, and internal controls, as well as how the organization spends its financial awards. These audits are a key element of oversight of federal funds, helping to detect mismanagement of funds, noncompliance, fraud, and waste. Below are five common findings in HUD single audits, as well as best practices PHAs can follow to avoid these findings.

Lack of Controls Over Eligibility

PHAs are required to maintain internal controls to provide reasonable assurance of compliance with grant/program requirements, including controls over program eligibility. During an audit, the PHA’s internal controls are documented and tested. Common control weaknesses found include (1) no formal checklist or process to ensure all HUD-required documentation is collected, and (2) no supervisory review of tenant files before completion.

Best Practice: Lacking internal controls over eligibility can lead to improper payments, admission of ineligible individuals, and repeat audit findings. PHAs can avoid these findings by maintaining a checklist for housing representatives to use during the admission and/or recertification process for each potential tenant to ensure all compliance requirements are met. The checklist should be signed or initialed by the housing representative performing the admission/recertification, reviewed and signed by a supervisor, and maintained in the tenant’s file to serve as documentation that all compliance requirements were verified.

Noncompliance with Federal Procurement Standards

PHAs are required to follow procurement standards including: maintaining a written procurement policy that complies with federal, state, and local regulations, using procurement methods by various procurement thresholds approved by HUD, conducting procurements in a manner that provides full and open competition, avoiding conflicts of interest, and ensuring contractors are not debarred or suspended. Common compliance findings include (1) no written procurement policy or outdated procurement policies that do not align with Uniform Guidance, (2) failure to follow procurement methods based on size of purchase, (3) failure to maintain proper records documenting procurement details, and (4) failure to verify that selected contractors were not suspended or debarred.

Best Practice: PHAs can avoid these findings by periodically reviewing and updating their procurement policies to ensure they are current and in line with appropriate laws and regulations. PHAs should also implement internal controls to ensure that proper procurement methods are used, document procurements thoroughly and maintain documentation in a secure location, and establish a process for verifying that vendors are not debarred or suspended before contracting with them.

Reporting Errors

PHAs are required to follow various reporting requirements depending on the programs they administer which can include Voucher Management System (“VMS”), Section 8 Management Assessment Program (“SEMAP”), form HUD-50058, and Financial Data Schedule (“FDS”). These reports are reviewed during the audit process. Common issues found during review include (1) mismatched financial data between the accounting system and reports being submitted to HUD, (2) failure to submit data, (3) failure to submit reports in a timely manner, and (4) missing forms.

Best Practice: PHAs can avoid these findings by implementing proper controls over each reporting requirement. For VMS reporting, PHAs should create a monthly reconciliation checklist and compare VMS entries against the accounting system. For HUD-50058, PHAs should submit these forms promptly (within 60 days of any tenant action), review error reports, automate data quality checks, and have a supervisor review the work of lower-level employees. For the SEMAP reporting, PHAs should implement a control to ensure this is submitted timely. SEMAP indicators should be tracked throughout the year to ensure timeliness. To ensure the FDS is submitted to the REAC FASS system timely and accurately, PHAs should establish clear controls and responsibilities amongst staff and third-party accountants. Accounts should be reconciled routinely to ensure there are no reporting delays at year-end. Documentation should be maintained for all reporting requirements.

Housing Quality Standards and Enforcement

PHAs are required to meet minimum physical standards which requires the PHA to have initial and routine unit inspections performed. Any failed inspection must be remedied in a timely manner. Common audit findings include (1) lack of evidence of inspection performed, (2) failure to correct deficiencies in a timely manner, and (3) failure to abate rent on units where deficiencies are not corrected in a timely manner.

Best Practice: To avoid audit findings related to housing quality standards and enforcement, PHAs should use inspection tracking software, maintain a listing of all inspections performed including any failures and dates of reinspections, maintain copies of unit inspections in the tenant’s files, and ensure rent is abated for any units where deficiencies are not remedied timely.

Recording of Declarations of Trust

A current Declaration of Trust, in a form acceptable by HUD, must be recorded against all public housing property owned by PHAs that have been acquired, developed, maintained, or assisted with funds from the U.S. Housing Act of 1937. During testing, common audit findings related to Declarations of Trust include the inability to locate the required documents for properties of the PHA.

Best Practice: To avoid audit findings, PHAs should complete and maintain a Declaration of Trust for all properties of the PHA and establish controls over these forms to ensure they are completed, current, and maintained in a secure location.

Further Guidance

For additional guidance on single audit preparation, please don’t hesitate to reach out to RBT CPAs. Connect with our experts today and find out how we can be Remarkably Better Together.

What Are Payroll Audits and Why Are They Important?

Labor Unions operate within a unique regulatory environment, and as such, must constantly monitor compliance in their financial processes. Compliance within labor unions is essential for maintaining the union’s financial and reputational integrity, as well as protecting the rights of both workers and employers. Compliance must be monitored at all levels of union operations, including among the contractors who employ union workers. One critical way to monitor compliance among union contractors is through payroll audits. Payroll audits ensure that contractors are correctly submitting union benefit contributions in compliance with Collective Bargaining Agreements (CBAs). It is important for unions to conduct regular internal payroll audits throughout the year in order to uphold the terms of CBAs, protect worker rights, minimize fraud risk, and avoid potentially serious penalties.

What happens during a union payroll audit?

During a union payroll audit, the auditor reviews a contractor’s payroll records for compliance with the terms of the union’s Collective Bargaining Agreement. Specifically, union payroll audits look to verify that contractors are reporting and remitting employee benefit contributions accurately. Payroll audits typically involve reviewing payroll records, verifying hours worked, checking for variable payments, and analyzing data for accuracy and compliance with the CBA. The goal is to protect the plan, trustees, and participants by verifying contributions are complete and accurate, and to prevent delinquencies and collections issues.

Who conducts union payroll audits and how often?

Payroll audits can be conducted by the union or benefit office. The union or benefit office can also obtain assistance from an outside vendor with experience in payroll audits, such as an accounting firm. Payroll audits can be conducted at various intervals, including annually, quarterly, and/or monthly. We recommend selecting a group of contractors each cycle to ensure that all are reviewed over a four-year period.

What are some common findings on union payroll audits?

Common findings include misreporting of hours and not properly submitting benefit contributions.

Why is it important for unions to carry out regular internal payroll audits?

Regular audits can lead to improved reporting accuracy, reduce delinquencies, prevent fraud, and help trustees identify problematic employers. They also provide feedback to plan administrators to ensure agreements are in place and contributions are made correctly. In addition, payroll audits help ensure compliance with ERISA (Employee Retirement Income Security Act) and other relevant regulations. They are required for ERISA audits. Frequent internal audits help the union avoid serious fines and penalties for noncompliance with Department of Labor regulations.

Looking for guidance?

One of the best ways to ensure compliance is by partnering with a reputable accounting firm like RBT CPAs. RBT CPAs’ experts are available to conduct payroll audits for your union and/or provide audit guidance. You can count on RBT CPAs’ accounting professionals to help maintain your union’s reputation for transparency and accountability. Our firm has been operating in the Hudson Valley and beyond for over 55 years, and we believe we succeed when our clients succeed. To learn more about our accounting, tax, audit, and advisory services, give us a call today.

NSPIRE Standards: An Overview and How to Prepare

By October 1, 2025, HUD-assisted properties must implement the NSPIRE standards, a new set of standards for physical inspections of HUD properties. HUD property owners and landlords should familiarize themselves with the new standards and implement the required changes to inspection procedures prior to the October 1 compliance date.

NSPIRE Overview

The NSPIRE Standards, replacing the Uniform Physical Condition Standards (UPCS) and the Housing Quality Standards (HQS), provide a new inspection model for HUD-assisted properties. NSPIRE, standing for the National Standards for the Physical Inspection of Real Estate, aims to improve the quality of HUD housing by focusing on the health, safety, and functionality of HUD properties. To allow HUD programs sufficient time to prepare for NSPIRE implementation, the compliance date for many programs was extended from October 1, 2023 to October 1, 2025. Properties wishing to implement NSPIRE before the compliance date are encouraged to do so, but must notify HUD of their planned transition date.

NSPIRE defines three different inspectable areas of HUD properties: “unit,” “inside,” and “outside.” The “unit” refers to the interior components of a building such as bathrooms, kitchens, carbon monoxide and smoke detectors, ceilings, floors, HVAC units, and lighting. “Inside” refers to common areas within the interior of the building such as basements, community rooms, utility rooms, laundry rooms, halls, stairs, offices, and shared kitchens. Also included under the “inside” category are building systems providing electricity, water, emergency power, etc. “Outside” refers to all building systems and components located outside of the building such as grounds, fences, mailboxes, lighting, parking lots, play areas, roads, walkways, storm drainage, balconies, fire escapes, and roofs. For a complete list of inspectable components, see page 1 of the NSPIRE Standards.

The standards use the terms “life-threatening,” “severe,” “moderate,” and “low” to describe the risk level of deficiencies identified during inspection. NSPIRE specifies the deficiency criteria, health and safety determination, rationale, and correction timeframes for each inspectable component. Life-threatening deficiencies must be addressed within 24 hours, while all other deficiencies must be corrected within 30 days (or a reasonable longer period determined by the PHA).

NSPIRE introduces several new protocols and requirements for property inspections. These include: new requirements for smoke and carbon monoxide alarms, new inspection processes and repair timeframes for infestations, new repair guidelines and timeframes for handrails and guardrails, and new processes and equipment for detecting mold-like substances.

How to Prepare for NSPIRE

According to HUD’s website and the NSPIRE Toolkit Cheat Sheet, landlords and owners of HUD properties can prepare for the upcoming compliance date in the following ways:

Carefully review the NSPIRE Standards (HUD provides this guide for reading the standards).
Refer to HUD’s notice on NSPIRE administrative procedures for details on inspection timeframes, preparation, and protocols.
Review the “Preparing for an NSPIRE Inspection” guide for landlords.
Train staff on new protocols and requirements.
Ensure that property profiles and contact information are correct (more details can be found on page 7 of HUD’s notice under “Property Verification and Document Collection”).
Perform regular preventative maintenance to identify and correct potential issues and hazards.
Consider resident feedback and respond promptly to resident concerns.
Utilize HUD’s NSPIRE Toolkit for additional resources, guidance, and training videos.

While you’re busy preparing for the upcoming NSPIRE compliance date, please know that RBT CPAs is here to support all of your accounting, tax, audit, and advisory needs. Reach out to us today and find out how we can be Remarkably Better Together.

The Importance of Internal Control Assessments

Internal controls are mechanisms that help to ensure an organization’s financial integrity. Unions rely on these internal controls to minimize financial risk, prevent fraud, and maintain the accuracy of financial records. It is crucial that these processes are regularly assessed in order to maintain their effectiveness.

What are Internal Controls?

Internal financial controls are processes designed to help prevent fraud, enhance reliability of financial statements, reduce the risk of unexpected financial losses, and ensure compliance with laws and regulations. Internal controls include procedures for authorization, record keeping, reconciliations, and auditing.

Why Do Unions Need Internal Controls?

Strong internal controls serve the following purposes for unions: they protect union funds, safeguard the union’s reputation, promote transparency, provide data for decision-making, and instill member trust.

Union officials are responsible for ensuring that union funds are used solely for the benefit of the union and its members. To ensure the proper use of funds, union leadership must maintain well-monitored systems for the following financial processes:

Collecting member dues
Managing union funds
Forming budgets
Keeping financial records
Providing financial reports to members
Conducting internal audits
Managing union bank accounts and credit cards

Preventing fraud, corruption, and financial risk is key to maintaining the reputation and integrity of any organization. The U.S. Department of Labor discusses several safeguards for preventing abuse in unions including:

Division of financial duties amongst multiple individuals
Issuing of records and receipts to members for dues paid
Maintenance of records and receipts for all union income and expenses
Transparency regarding union officer salaries and allowances
Cosigning of all checks from the union’s bank account
Full reports of union finances given by the financial officer at each membership or executive board meeting
Prior authorization for large or unusual transactions
Internal audit committees (or trustees)
Regular audits of the union’s financial records

Assessing Your Union’s Internal Controls

Regularly evaluating your union’s internal controls is a critical step for minimizing financial risk. Weaknesses in internal controls can develop if union officials misunderstand the guidelines or if the guidelines are not updated to match changing regulatory requirements. All of the mechanisms discussed above must be periodically reviewed to ensure that they are achieving their objectives in preventing risk to the union.

Reviewing internal controls may involve the use of risk assessments, which identify potential threats and weaknesses in the operations of the organization. Audits of financial records can also help to identify gaps in compliance. If weaknesses are found, then operating procedures can be amended accordingly.

It is critical to stay on top of your union’s financial health to reduce the risk of reputational and operational damage.

Looking to test your union’s internal control processes? RBT CPAs’ experts are happy to provide internal control assessments for your union. At RBT CPAs, we understand the unique compliance and regulatory environment that you operate within. Our firm has been serving organizations in the Hudson Valley and beyond for over 50 years. You can count on RBT CPAs’ professionals to help maintain your union’s reputation for transparency, accountability, and trustworthiness by providing exceptional accounting, advisory, audit, and tax services.

For more information about how our firm can help to maintain the financial health of your union, visit our website or give us a call.

Mitigating Fraud Risk in Public Housing Authorities

Public Housing Authorities (PHAs) can become vulnerable to fraud and corruption—by both external and internal parties— if proper precautions are not taken to safeguard these agencies against such risks. This article will discuss the measures Public Housing Authorities can take to prevent and detect potential fraud risks.

Types of Fraud

The Office of the Inspector General lists several of the most common fraud schemes that occur in Public Housing Authorities and other organizations that receive Housing and Urban Development funds. Some examples of common schemes are:

Embezzlement and theft
Contracting and procurement fraud
Bribery and kickbacks
Conflicts of interest
Identity theft
Disaster recovery grant fraud
False billing
Tenant/applicant fraud

Establishing a Formal Fraud Policy

The most important means of fraud prevention is a formal fraud policy. A formal fraud policy should be comprehensive, outlining the procedures for preventing and responding to fraud. The policy should be accessible and easily understood by tenants and employees. According to the Office of the Inspector General, a formal fraud policy should accomplish the following: declare the organization’s commitment to preventing fraud, lay out the activities that constitute fraud, ensure confidentiality in reporting, identify officials with authority to investigate suspected fraud, state the consequences and penalties for fraud, assure due process, and provide instructions for reporting suspected fraud. PHAs should consult with legal counsel to review their fraud policies and ensure compliance with tenant-landlord laws, as well as alignment with HUD policies.

Educating Relevant Parties

Awareness of a PHA’s fraud policy and procedures is key in fraud prevention. PHAs should make their fraud policies accessible to management, tenants, employees, contractors, and other relevant parties by distributing printed copies, hanging posters in common areas, and/or making the policy available online. Employees and stakeholders should be trained to recognize and report suspicious activity. Awareness of a strong anti-fraud policy can also help to deter potential fraudsters.

Maintaining Strong Preventative Procedures and Internal Controls

To safeguard against fraud, PHAs must have board-approved operational and financial procedures in place. These procedures should include systems for verifying tenant eligibility, policies for vetting vendors and third-party service providers, and regular risk assessments to determine the likelihood of various fraud scenarios. PHAs should conduct regular reviews and audits of processes and controls to ensure compliance and effectiveness. In addition to periodic audits, PHA staff should monitor data and transactions on a daily basis. Data analytics and AI technology can be utilized to improve the accuracy and efficiency of monitoring processes.

Establishing a Whistleblower System

PHAs must ensure that the systems in place for reporting fraudulent activity are clear, accessible, and confidential for those reporting. Whistleblowers who report suspected fraud, waste, or abuse are protected by the law from retaliation.

How Can an Accounting Firm Help Mitigate Fraud Risk?

It is critical that the proper policies and procedures are in place to prevent and detect fraud threats—from both inside and outside of the organization. A reliable accounting firm can help carry out these crucial procedures.

RBT CPAs provides a variety of services that help prevent fraud within Public Housing Authorities and other organizations. These include:

Internal control assessments: review controls to ensure proper checks and balances are in place to prevent fraud (segregation of duties, approval processes, etc.).
Fraud risk assessments: identify areas within the Authority’s operations with greater potential for fraud.
Agreed-Upon Procedures: perform specific tasks requested by an Authority, such as reviewing selected financial information.
Annual financial and compliance audits: conduct independent audits to ensure accuracy and compliance with accounting standards and regulatory requirements.
Consulting/Advisory services: provide insight and advice on various topics, such as strategies to mitigate financial, operational, and compliance risks; assist with the development of policies and procedures.
Bookkeeping/Fee Accounting services: maintain accurate financial records and assist the Authority in maintaining compliance.
Forensic audits: examine the Authority’s financial records for evidence of suspected fraud.

Protecting Public Housing Authorities from fraudulent activity is crucial for maintaining the operational integrity and reputation of these agencies. RBT CPAs’ accounting, tax, audit, and advisory experts are here to help safeguard your organization from fraud. Call us today and find out how we can be Remarkably Better Together.

Are You Keeping Up with Fair Housing Act Developments?

Activities to prevent bias and discrimination in housing have dramatically picked up speed on the Federal level and in New York. Guidance and communications reveal a multi-pronged approach to enforcing the Fair Housing Act by touching on a wide variety of activities from screenings to insurer practices and more. Following are highlights of a few national and state activities occurring since the start of 2024.

On February 23, HUD announced adjustments to civil monetary penalty amounts for 2024. These adjustments took effect on March 25. Fair Housing Act civil penalties range from $25,597 with no prior violations to $63,991 if there’s one prior violation and $127,983 if you have two or more priors. (Criminal proceedings may be pursued for complaints involving force or threat of force.)

In early April, HUD awarded over $30 million in grants to fair housing organizations working to address Fair Housing Act violations, including three in New York.

On April 29, HUD issued guidance on the Application of the Fair Housing Act to the Screening of Applicants for Rental Housing. It addresses ways to screen applicants in a nondiscriminatory manner and best practices for Fair Housing Act compliance. It also discusses the use of AI and machine learning in screenings. (Separate guidance was issued to address the use of AI in the advertising of housing opportunities.)

There’s also a proposed rule under consideration to amend existing regulations “for applicants with criminal records or a history of involvement with the criminal justice system and eviction or termination of assistance of persons on the basis of illegal drug use, drug-related criminal activity, or other criminal activity.” Stay tuned.

When it comes to New York, on April 22, an agreement was enacted as part of the 2025 budget “to address New York’s housing crisis by increasing the housing supply, promoting affordability, strengthening protections for New York renters and homeowners, and combatting bias and discrimination in housing.”

There were several changes to housing laws, including the Good Cause Eviction Notice taking effect in NYC and giving any other village, town, or city in New York the opportunity to opt in. As of the end of July, Albany, Kingston, Poughkeepsie, Rochester, and Ithaca had opted in.

On April 26, Governor Hochul shared a comprehensive assessment of fair housing in the state, with Fair Housing Matters NY and a new online mapping tool showing how fair housing issues impact New Yorkers. The report highlights key issues and defines goals and action items addressing housing disparities.

To promote Fair Housing compliance, an additional $2.2 million expanded New York’s Fair Housing Testing Program, where undercover testers act as renters and homebuyers to uncover discrimination and educate landlords, tenants, local governments, and real estate professionals on fair housing requirements. In addition, the Governor is creating a new unit dedicated to swift enforcement of housing discrimination related to Section 8 Housing Choice Vouchers.

As you focus on staying up-to-date on Fair Housing Act activities on both the Federal and state levels to promote compliance and protect your organization from penalties, you can count on RBT CPAs to be your trusted advisor for accounting, audits, taxes, and more. Learn how we can be Remarkably Better Together by contacting us today.

RBT CPAs never offshore work outside of the U.S., so you always know who is handling your financial information.

NOTE: RBT CPAs is not a law firm and the content in this article should not be construed as legal advice. Should you have questions about Fair Housing Act law or compliance, it’s in your best interest to contact your legal counsel.

Navigating Leadership Transitions in Unions: A Focus on the Treasurer Role

There are a lot of responsibilities that must be addressed as part of a union officer election. An important activity to keep on your radar is helping newly elected officers transition into their positions; this is especially important when there’s a newly elected treasurer.

Given a treasurer’s responsibility for a local’s financial well-being and compliance, preparing a transition plan in advance of an election puts you in the position to help a new treasurer acclimate quickly while maintaining member trust and loyalty.

To prepare for a potential transition in treasurers, explore resources your parent union may have available, including the union’s constitution (which typically defines duties), leadership handbooks, financial standards, and training focused on a treasurer’s responsibilities and financial guidance for union leaders.

Create a “toolkit” that you can share with a newly elected treasurer, so they quickly get up to speed on responsibilities, have an opportunity to ask questions, prepare to lead, and ensure compliance. In addition, consider whether the following actions can support the transition:

Plan ahead. The incumbent treasurer should update documentation regarding key processes, responsibilities, and relevant financial information, and prepare to hand off/transfer key items like bank accounts, checkbooks, and credit cards.
Knowledge transfer. A knowledge transfer process will allow time for the outgoing and incoming treasurers to discuss the union’s financial structure, internal controls, key responsibilities, and more. This is not just about handing over documents or providing a calendar of important deadlines and deliverables, but also sharing insights and experiences.
Training and support. The incoming treasurer may need training, in the form of courses, workshops, or mentorship from the outgoing treasurer or other experienced union leaders. Providing ongoing support to the new treasurer even after the transition period is essential to ensure they are positioned to succeed in their new role.
Communication. Open and transparent communication is key. Union members should be informed about the change in leadership and the transition plan. This communication fosters trust and ensures members that the union’s financial matters will remain in responsible hands.
Engage with auditors and advisors. The treasurer is typically the primary contact for the union’s auditors, accountants, bankers, and financial advisors. Early engagement with these individuals can help keep the union’s financial matters moving even during a transition.
Compliance with regulations. The treasurer is responsible for ensuring the union complies with all relevant financial regulations and reporting requirements. The transition plan should include a review of regulatory requirements and direction on where the new treasurer can turn for advice and direction.
Encourage teamwork. Lastly, a new treasurer should be encouraged to work closely with any staff that they oversee (like a bookkeeper), other union leaders, and any special committees they are assigned to. A strong team can provide support, share the workload, and contribute to effective decision-making.

A leadership transition is a significant event in the life of a union. Although the role of a treasurer comes with hefty responsibilities, with proper planning, effective knowledge transfer, and continuous support, a new treasurer can be put in the best position to help the union and its members succeed.

Whether your union is dealing with business as usual or handling a leadership transition, please know you can always count on RBT CPAs for accounting, audit, tax, and advisory services. Give us a call to see how we can be Remarkably Better Together.

RBT CPAs never offshores work outside of the U.S., so you always know who is handling your financial information.

Is 2024 the Year Public Housing Finally Moves on from COVID?

While much of society has moved beyond COVID, Public Housing Authorities (PHAs) continue feeling its impact.

A delay in the Emergency Rental Assistance Program (ERAP) disbursements in New York exasperated the issue, but now it seems that funds are moving and helping with accounts receivables. This appears to have a leveling off effect on eviction cases filed. However, other recent announcements from HUD may indicate the struggles aren’t completely in the rearview mirror.

According to New York’s Office of Temporary and Disability Assistance, as of January 26, 2023, the number of applications for:

ERAP applications for rent arrears, prospective rent, and utility arrears: 405,605
State-Funded ERAP for Over 80 Area Median Income (AMI): 6,872
LRAP applications: 55,009

The number of applications paid May 28, 2024:

ERAP for rent arrears and prospective rent: 306,667 applications paid in the amount of $3.49 billion
ERAP for utility arrears: 121,069 applications paid in the amount of $145 million
State-Funded ERAP for Over 80 AMI: 4,404 applications paid in the amount of $50 million
LRAP: 29,792 applications paid amounting to $298 million

(To see data by county or jurisdiction, as well as demographic information, click here.)

New York’s Statewide Landlord-Tenant Eviction Dashboard indicates that as of June 17, 2024 there were over 86,000 eviction filings for the year. Monthly data indicates a potential easing; we’ll know more when June’s month-end numbers are available.

There has also been a flurry of Federal and state legislative activity that seems to go back and forth between making things easier on PHAs and more challenging.

In December 2023, HUD proposed a rule requiring a 30-day notice period prior to starting eviction proceedings related to termination of a lease.

In April 2024, the state enacted the Good Cause Eviction Law, limiting evictions, requiring lease renewals, and capping rent increases, although municipalities outside of NYC must opt in.

In April 2024, HUD published a notice to extend its 2022 adjustment for assessing Tenant Accounts Receivable (TAR) in the Public Housing Assessment System with fiscal year ends up to December 31, 2023. However, the notice also indicates “HUD intends to return to the regular scoring methodology for HUD for PHAs with fiscal years ending in 2024.”

On May 7, 2024, HUD issued a final rule on HOTMA Housing Choice Voucher and Project Based Voucher implementation that simplify and clarify existing regulatory language and reduce the burden on PHAs.

On May 14, 2024, HUD announced the renewal of funding for the Housing Choice Voucher Program, with over $3.3 billion going to New York Housing Authorities.

On June 14, 2024, NSPIRE V Compliance was pushed back a year to October 1, 2025.

While you’re no doubt busy keeping up with all of this activity, we just want to remind you that RBT CPAs is here to support all of your accounting, audit, advisory, and tax needs. Give us a note or drop us a line any time to find out how we can be Remarkably Better Together.

Protecting Union Members’ Data: What You Should Know and Do

With growing frequency, cybercriminals are targeting unions, prompting a greater need for cybersecurity awareness, training, and protocols at all levels.

Last year, the Boston Pipefitters Union saw $6.4 million stolen from its health fund. In November, the Allied Pilots Association was the victim of a ransomware attack. Early this year, an SEIU local in California was breached resulting in the possible exposure of member Social Security numbers, home addresses, birth dates, and more. As unions play a vital role in fighting for members’ rights, like all organizations, they must also proactively put plans in place to protect union systems, funds, and sensitive information about members.

Why? A cyber attack can have far-reaching implications, ranging from financial loss, disruption of operations, recovery costs, and legal fees to damage to an organization’s reputation and loss of member trust. Cyber attacks are also easy to facilitate, with dubious links in emails that look like they come from legitimate sources or thumb drives embedded with a virus. Unfortunately, simple deceptions can wreak havoc on systems and organizations.

While a common misunderstanding is that cyber criminals focus on only the largest of organizations, it’s important to recognize a certain contingency of cyber criminals focus on smaller operations or low-hanging fruit that provides easier access to data and ransom fees. (That’s why school districts and local municipalities are frequent targets. With outdated infrastructure and limited resources, it’s easier for cyber criminals to breach their systems, causing chaos by locking systems for days or weeks and holding sensitive information for ransom.)

With the average cost of a cyber breach estimated to be over $4 million in 2023, organizations of all types and sizes – including unions and locals – need to make cybersecurity an ongoing priority. If your local handles members’ personally identifiable information like birth date, Social Security number, home address, phone number, and email address – not to mention any financial information, it’s critical to take steps to proactively protect this data while also having a plan so you know what to do should a breach occur.

A cyber security plan can include clearly defined roles and responsibilities; annual risk assessments and audits (including audits of third-party service providers); data encryption and controls; a response plan; periodic training and communications; and more. By having one in place, you can reassure members that the union is always looking out for their best interests.

A good place to start is with your union’s parent organization to see what policies, protocols, and tools are available to protect members’ information and union systems. In addition, the U.S. Cybersecurity & Infrastructure Security Agency (CISA) provides valuable free resources and tools, including the Shields Up program which is designed to help organizations prepare for, respond to, and mitigate the impact of a cyberattack.

As you explore what your local can and should be doing to protect member information, please remember RBT CPA professionals are available to provide accounting, tax, audit, and advisory services. To find out how we can be Remarkably Better Together, give us a call.

RBT CPAs is proud to say 100% of its work is prepared in America. We do not offshore work, so you always know who is handling your organization’s financial information.