First batch of audits show 95% compliance rate in APCHA ownership units
Program moves at a much faster pace than originally anticipated

Early results from APCHA’s audit program suggest that the overwhelming majority of homeowners are in compliance with the housing authority’s ownership regulations.
Out of 78 audit letters sent to homeowners in the latter half of 2023, 74 households have been deemed in compliance. The other four are unresolved as APCHA works through household-specific circumstances, allowing time to get folks into compliance.
If needed, they will begin the formal process with a Notice of Violation, but APCHA Executive Director Matthew Gillen said that is not the goal.
“The intent of the board and APCHA is to give people every opportunity to come into compliance,” said Gillen. “A Notice of Violation can be burdensome for both APCHA and the homeowner, and we’d prefer not to go down that route. We take the time to communicate with the homeowner what they need to show us, what their situation is, before we take any of these more formal steps.”
APCHA Compliance Officer Jackie Marinaro said she came across a “handful” of folks who appeared to be in violation of the eligibility requirements during the 2023 audits, but once APCHA communicated how they might be deficient, the households remedied the situation to stay in compliance.
The audits seek to verify what APCHA homeowners already swear to via affidavit annually: the owner lives in Pitkin County at least nine months out of the year, is employed full-time in the county, and does not own property within the Ownership Exclusion Zone.
Homeowners do not have to remain within certain income or asset brackets after purchasing a property but do need to meet the above basic eligibility requirements. Retirees do not have to prove full-time work hours, but they do need to qualify under APCHA’s retiree criteria and meet all other basic eligibility requirements.
“We understand these are real people. We have regulations, rules we follow. But these are real people with real lives. And our job is not to catch them,” Marinaro said. “Our job is not to get a technical error and kick you out of housing. Our job is what can we do to help you get back into compliance.”
After being notified via mail about the audit, homeowners must send in their latest tax returns, business tax returns, income verification like W-2s or 1099s, business plans, and profit and loss statements, as applicable. APCHA also asks for employer verification forms, which is an area Marinaro said she saw great cooperation from Pitkin County employers.
Homeowners have two weeks from the mail notice to upload the documents in HomeTrek, APCHA’s data management system. Still, the timeline is fluid as APCHA wants to work with homeowners.
A computer program randomly selects properties for audit by address, not by homeowner name. Marinaro said some folks balked at being selected, wondering if it had something to do with their position on their property’s Homeowners Association or prior communication with APCHA.
“I said, ‘No, sir. No, not at all. Everybody’s going through this and (don’t) worry,'” she said.
Marinaro resumed the program in February after taking a break over the holidays. In February, she sent out 42 audits. Seventeen have been returned and 42 are outstanding as of Monday, she said.
When the program launched in July 2023, Marinaro’s monthly audit goal was about five. After eight months of work, she said a couple of dozen audits per month is her new pace.
With that pace, APCHA will be on track to audit its full 1,733 ownership stock in just over five years.
APCHA has long battled public sentiment that “everyone cheats the system” or “APCHA doesn’t check eligibility” — especially for the homeowners under its umbrella.
For Gillen and Marinaro, these early results indicate that the rumors are false.
“Folks understand that it’s a privilege to be in this housing, and 95% are willing to work very hard to make sure that they stay in compliance,” Marinaro said. “They know that there’s a lot of folks that would love to have the opportunity to be able to do what they’re doing.”
Still, the full stock of APCHA is 1,733 units, according to the 2023 HomeTrek report. A full sample size is around 315 audits, a few hundred more than the data set APCHA has now.
Gillen and Marinaro said the APCHA Board of Directors will hear an update on the program closer to its anniversary in July.