Audit 15365

FY End
2023-06-30
Total Expended
$940,392
Findings
20
Programs
1
Organization: New Visions Housing Corporation (CA)
Year: 2023 Accepted: 2024-02-02

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
11521 2023-001 Material Weakness Yes N
11522 2023-002 Material Weakness Yes AB
11523 2023-003 Material Weakness Yes L
11524 2023-004 Significant Deficiency - A
11525 2023-005 Significant Deficiency Yes E
11526 2023-001 Material Weakness Yes N
11527 2023-002 Material Weakness Yes AB
11528 2023-003 Material Weakness Yes L
11529 2023-004 Significant Deficiency - A
11530 2023-005 Significant Deficiency Yes E
587963 2023-001 Material Weakness Yes N
587964 2023-002 Material Weakness Yes AB
587965 2023-003 Material Weakness Yes L
587966 2023-004 Significant Deficiency - A
587967 2023-005 Significant Deficiency Yes E
587968 2023-001 Material Weakness Yes N
587969 2023-002 Material Weakness Yes AB
587970 2023-003 Material Weakness Yes L
587971 2023-004 Significant Deficiency - A
587972 2023-005 Significant Deficiency Yes E

Programs

ALN Program Spent Major Findings
14.181 Supportive Housing for Persons with Disabilities $62,199 Yes 5

Contacts

Name Title Type
PENJD8Z2A219 Bonnie Schlachte Auditee
8187081740 John Eusanio Auditor
No contacts on file

Notes to SEFA

Title: Basis of presentation: Accounting Policies: Expenditures on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The Organization has elected not to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. The accompanying schedule of expenditures of federal awards (the "Schedule") includes the federal award activity of New Visions Housing Corporation (the "Organization") under programs of the federal government for the year ended June 30, 2023. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards ("Uniform Guidance"). Because the Schedule presents only a selected portion of the operations of the Organization, it is not intended to and does not present the financial position, change in net deficit, or cash flows of the Organization.
Title: U.S. Department of Housing and Urban Development Capital Advance Program: Accounting Policies: Expenditures on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The Organization has elected not to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. The Organization has received funding under the U.S. Department of Housing and Urban Development ("HUD") Section 811 Capital Advance Program ("CAP") and Section 811 Project Rental Assistance Contract ("PRAC"), Federal Assistance Listing Number 14.181. The determination of the Supportive Housing for Persons with Disabilities (Section 811) as a Type A ("major") federal financial assistance program is based upon both the balance of the HUD CAP and the HUD PRAC payments received under Section 811 during the period as HUD considers both elements the same program because they fall under the same Federal Assistance Listing Number. The loan balance outstanding at the beginning of the year is included in the federal expenditures presented in the Schedule. The Organization received no additional loans during the year. The balance of the CAP outstanding at June 30, 2023, consisted of the following: Federal Assistance Listing Number 14.181 Program Name Supportive Housing for Persons with Disabilities (Section 811) Outstanding Balance June 30, 2023 $ 878,193

Finding Details

Finding No. 2023-001: Restricted Cash (Material Weakness) Statement of condition Special Tests and Provisions During the year ended June 30, 2023, management did not segregate the residual receipts deposits into a segregated, restricted cash account. For two months of the fiscal year, the monthly replacement reserve deposit was funded in the subsequent month. The replacement reserve was underfunded by one month's deposit at June 30, 2023. Criteria In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs, HUD projects are required to establish and maintain at all times fully funded, separate bank accounts in the name of the entity for all security deposits collected and for residual receipts deposits. The Regulatory Agreement requires a monthly deposit of $235 in the replacement reserve. Cause The residual receipts deposits were deposited into the replacement reserve account and were not transferred into segregated accounts as of June 30, 2023. The monthly replacement reserve transfer was delayed by several days into the subsequent month due to it being on a set interval of time rather than on a monthly date. This late funding resulted in only 11 deposits being made during the year ended June 30, 2023. Effect Management commingled the residual receipts deposits with its replacement reserve, resulting in the potential use of residual receipts deposits to fund repairs or replacements without obtaining the required prior approval of HUD. Late deposits to the replacement reserve could result in insufficient funds for repairs and replacements. Recommendation Management should review and enhance its policies, procedures and internal controls to ensure that residual receipts deposits are segregated into a separate, restricted cash account. Management should review and enhance policies, procedures and internal controls to ensure that the replacement reserve deposits are made timely. Identification of repeat finding The finding is a repeat of Finding No. 2022-001. Auditor non-compliance code D - Commingling funds Questioned costs None Finding resolution status In process
Finding No. 2023-002: Cash Disbursements and Classifications (Material Weakness) Statement of condition Allowable costs Activities allowed or unallowed During the year ended June 30, 2023, the Organization: did not properly classify certain expenditures between expense accounts; did not obtain bids for an expenditure over $10,000; did not properly cut off disbursements at fiscal year end, resulting in expenses not being recorded within the current audit period; and did not accurately record gross potential rent, due to and from affiliates, and receivables. Criteria Management must review invoices after fiscal year end to ensure all expenses related to the fiscal period are being accurately captured. Additionally, management should review expenditures for accurate expense account classification and review revenue classifications to the appropriate revenue account recording to ensure proper financial and HUD reporting. The Uniform Guidance requires bidding be obtained for expenditures over $10,000. Cause Review procedures were not sufficient to ensure expenditures were recorded in accurate expense accounts and revenue was recorded in the appropriate revenue account. Review procedures were not adequately followed to review subsequent invoices for relevance to the current fiscal period. Review procedures were not sufficient to ensure expenditures over $10,000 received competitive bids. Effect Certain utility expenses presented for the current fiscal year were not recorded until the next fiscal year, resulting in understated expenses. Additionally, improperly capitalized expenditures and inaccurate expenses, fixed assets, and revenue classification could result in improper financial and HUD reporting. Recommendation Management should revisit and enhance its internal controls and procedures over subsequent expenditures to ensure expenses are captured in the correct fiscal period. Management should implement an additional period-end review to ensure proper classification of expenses, complete accrued expenditures, and accurate recording of revenue, due to and from affiliates, and receivables. Management should review its controls over expenditure authorization to ensure competitive bids are obtained where necessary. Identification of repeat finding The finding is a repeat of Finding No. 2022-002. Auditor non-compliance code S - Internal control deficiencies Questioned costs None Finding resolution status In process
Finding No. 2023-003: Financial Reporting (Material Weakness) Statement of condition Reporting The lack of appropriate policies, procedures, and internal processes led to inaccurate recording of depreciation, accounts payable, property insurance expense, and the tenant security deposit liability, and late filing of required reporting. Certain information technology controls and procedures were not documented, properly designed, or followed appropriately, including, but not limited to: segregation of administrative user roles from the accounting function, user access review, removal of terminated users, physical access, complementary user entity controls assessment, backup restoration testing, penetration testing, and cybersecurity awareness training. Criteria The Organization is required to have internal controls and procedures in place in order to timely and accurately report the results of its operations, close its books, and timely file its reports with the applicable federal agencies. These procedures include documenting of levels of review, reconciling accounting records at month-end and year-end close, and maintaining a well-documented, designed, and applied information technology environment. Cause Management did not have sufficient internal controls in place to accurately and timely report the results of the Organization's operations and maintenance and maintain the information technology environment. Effect Insufficient controls, late closing and reconciliation of accounting records, and insufficiently maintained information technology environment could result in accounting errors and theft. A lack of controls over financial reporting can result in untimely filing of required reports or incomplete filings with the regulatory and oversight entities. Recommendation We recommend that management re-evaluate its internal controls, policies and procedures to ensure an appropriate member of management is in place to review the year-end and month-end close processes, as well as journal entries, reconciliations, and other accounting records. Management should appoint an individual to be responsible for the Organization's financial statements and reporting obligations. Management evaluate its controls and procedures over the information technology environment to ensure they are properly documented, designed, and followed, including but not limited to: ensuring segregation of administrative user roles from the accounting function, performing a regular review of user access, ensuring terminated users are removed from all systems and software, ensuring restriction of physical access to the system, performing an assessment of complementary user entity controls for relevant software vendors, performing backup restoration tests and penetration tests, and providing cybersecurity awareness training. Identification of repeat finding The finding is a repeat of Finding No. 2022-003. Auditor non-compliance code S - Internal control deficiencies Questioned costs None Finding resolution status In process
Finding No. 2023-004: Timely Work Order Address (Significant Deficiency) Statement of condition Activities allowed or unallowed During the year ended June 30, 2023, management was unable to demonstrate timely completion of 9 of 38 work orders selected. Criteria HUD projects are required to complete work orders timely. Cause The Organization did not have sufficient controls in place to ensure the timely completion of work orders as required by HUD. Effect Significant repairs could be delayed and repairs could be falsified or duplicated. Recommendation Management should review and enhance its internal controls and procedures over work orders to ensure they are completed on a timely basis. Identification of repeat finding The finding is not a repeat finding. Auditor non-compliance code S - Internal control deficiencies Questioned costs None Finding resolution status In process
Finding No. 2023-005: Verification of Tenant Assets (Significant Deficiency) Statement of condition Eligibility During the year ended June 30, 2023, management did not perform a verification of tenant assets as part of tenant certification and recertification procedures. Criteria In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs, HUD projects are required to verify tenant assets to ensure appropriate subsidy calculations. Cause The Organization's tenants are multi-handicapped blind low-income adults. The cash accounts held by the tenants are maintained by the Sponsor on behalf of the tenants and therefore other assets are not verified. Effect Subsidy receipts could be overstated. Recommendation Management should review and enhance its certification and annual recertification procedures to include a verification of tenant assets. Identification of repeat finding The finding is a repeat of Finding No. 2022-005. Auditor non-compliance code S - Internal control deficiencies Questioned costs None Finding resolution status In process
Finding No. 2023-001: Restricted Cash (Material Weakness) Statement of condition Special Tests and Provisions During the year ended June 30, 2023, management did not segregate the residual receipts deposits into a segregated, restricted cash account. For two months of the fiscal year, the monthly replacement reserve deposit was funded in the subsequent month. The replacement reserve was underfunded by one month's deposit at June 30, 2023. Criteria In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs, HUD projects are required to establish and maintain at all times fully funded, separate bank accounts in the name of the entity for all security deposits collected and for residual receipts deposits. The Regulatory Agreement requires a monthly deposit of $235 in the replacement reserve. Cause The residual receipts deposits were deposited into the replacement reserve account and were not transferred into segregated accounts as of June 30, 2023. The monthly replacement reserve transfer was delayed by several days into the subsequent month due to it being on a set interval of time rather than on a monthly date. This late funding resulted in only 11 deposits being made during the year ended June 30, 2023. Effect Management commingled the residual receipts deposits with its replacement reserve, resulting in the potential use of residual receipts deposits to fund repairs or replacements without obtaining the required prior approval of HUD. Late deposits to the replacement reserve could result in insufficient funds for repairs and replacements. Recommendation Management should review and enhance its policies, procedures and internal controls to ensure that residual receipts deposits are segregated into a separate, restricted cash account. Management should review and enhance policies, procedures and internal controls to ensure that the replacement reserve deposits are made timely. Identification of repeat finding The finding is a repeat of Finding No. 2022-001. Auditor non-compliance code D - Commingling funds Questioned costs None Finding resolution status In process
Finding No. 2023-002: Cash Disbursements and Classifications (Material Weakness) Statement of condition Allowable costs Activities allowed or unallowed During the year ended June 30, 2023, the Organization: did not properly classify certain expenditures between expense accounts; did not obtain bids for an expenditure over $10,000; did not properly cut off disbursements at fiscal year end, resulting in expenses not being recorded within the current audit period; and did not accurately record gross potential rent, due to and from affiliates, and receivables. Criteria Management must review invoices after fiscal year end to ensure all expenses related to the fiscal period are being accurately captured. Additionally, management should review expenditures for accurate expense account classification and review revenue classifications to the appropriate revenue account recording to ensure proper financial and HUD reporting. The Uniform Guidance requires bidding be obtained for expenditures over $10,000. Cause Review procedures were not sufficient to ensure expenditures were recorded in accurate expense accounts and revenue was recorded in the appropriate revenue account. Review procedures were not adequately followed to review subsequent invoices for relevance to the current fiscal period. Review procedures were not sufficient to ensure expenditures over $10,000 received competitive bids. Effect Certain utility expenses presented for the current fiscal year were not recorded until the next fiscal year, resulting in understated expenses. Additionally, improperly capitalized expenditures and inaccurate expenses, fixed assets, and revenue classification could result in improper financial and HUD reporting. Recommendation Management should revisit and enhance its internal controls and procedures over subsequent expenditures to ensure expenses are captured in the correct fiscal period. Management should implement an additional period-end review to ensure proper classification of expenses, complete accrued expenditures, and accurate recording of revenue, due to and from affiliates, and receivables. Management should review its controls over expenditure authorization to ensure competitive bids are obtained where necessary. Identification of repeat finding The finding is a repeat of Finding No. 2022-002. Auditor non-compliance code S - Internal control deficiencies Questioned costs None Finding resolution status In process
Finding No. 2023-003: Financial Reporting (Material Weakness) Statement of condition Reporting The lack of appropriate policies, procedures, and internal processes led to inaccurate recording of depreciation, accounts payable, property insurance expense, and the tenant security deposit liability, and late filing of required reporting. Certain information technology controls and procedures were not documented, properly designed, or followed appropriately, including, but not limited to: segregation of administrative user roles from the accounting function, user access review, removal of terminated users, physical access, complementary user entity controls assessment, backup restoration testing, penetration testing, and cybersecurity awareness training. Criteria The Organization is required to have internal controls and procedures in place in order to timely and accurately report the results of its operations, close its books, and timely file its reports with the applicable federal agencies. These procedures include documenting of levels of review, reconciling accounting records at month-end and year-end close, and maintaining a well-documented, designed, and applied information technology environment. Cause Management did not have sufficient internal controls in place to accurately and timely report the results of the Organization's operations and maintenance and maintain the information technology environment. Effect Insufficient controls, late closing and reconciliation of accounting records, and insufficiently maintained information technology environment could result in accounting errors and theft. A lack of controls over financial reporting can result in untimely filing of required reports or incomplete filings with the regulatory and oversight entities. Recommendation We recommend that management re-evaluate its internal controls, policies and procedures to ensure an appropriate member of management is in place to review the year-end and month-end close processes, as well as journal entries, reconciliations, and other accounting records. Management should appoint an individual to be responsible for the Organization's financial statements and reporting obligations. Management evaluate its controls and procedures over the information technology environment to ensure they are properly documented, designed, and followed, including but not limited to: ensuring segregation of administrative user roles from the accounting function, performing a regular review of user access, ensuring terminated users are removed from all systems and software, ensuring restriction of physical access to the system, performing an assessment of complementary user entity controls for relevant software vendors, performing backup restoration tests and penetration tests, and providing cybersecurity awareness training. Identification of repeat finding The finding is a repeat of Finding No. 2022-003. Auditor non-compliance code S - Internal control deficiencies Questioned costs None Finding resolution status In process
Finding No. 2023-004: Timely Work Order Address (Significant Deficiency) Statement of condition Activities allowed or unallowed During the year ended June 30, 2023, management was unable to demonstrate timely completion of 9 of 38 work orders selected. Criteria HUD projects are required to complete work orders timely. Cause The Organization did not have sufficient controls in place to ensure the timely completion of work orders as required by HUD. Effect Significant repairs could be delayed and repairs could be falsified or duplicated. Recommendation Management should review and enhance its internal controls and procedures over work orders to ensure they are completed on a timely basis. Identification of repeat finding The finding is not a repeat finding. Auditor non-compliance code S - Internal control deficiencies Questioned costs None Finding resolution status In process
Finding No. 2023-005: Verification of Tenant Assets (Significant Deficiency) Statement of condition Eligibility During the year ended June 30, 2023, management did not perform a verification of tenant assets as part of tenant certification and recertification procedures. Criteria In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs, HUD projects are required to verify tenant assets to ensure appropriate subsidy calculations. Cause The Organization's tenants are multi-handicapped blind low-income adults. The cash accounts held by the tenants are maintained by the Sponsor on behalf of the tenants and therefore other assets are not verified. Effect Subsidy receipts could be overstated. Recommendation Management should review and enhance its certification and annual recertification procedures to include a verification of tenant assets. Identification of repeat finding The finding is a repeat of Finding No. 2022-005. Auditor non-compliance code S - Internal control deficiencies Questioned costs None Finding resolution status In process
Finding No. 2023-001: Restricted Cash (Material Weakness) Statement of condition Special Tests and Provisions During the year ended June 30, 2023, management did not segregate the residual receipts deposits into a segregated, restricted cash account. For two months of the fiscal year, the monthly replacement reserve deposit was funded in the subsequent month. The replacement reserve was underfunded by one month's deposit at June 30, 2023. Criteria In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs, HUD projects are required to establish and maintain at all times fully funded, separate bank accounts in the name of the entity for all security deposits collected and for residual receipts deposits. The Regulatory Agreement requires a monthly deposit of $235 in the replacement reserve. Cause The residual receipts deposits were deposited into the replacement reserve account and were not transferred into segregated accounts as of June 30, 2023. The monthly replacement reserve transfer was delayed by several days into the subsequent month due to it being on a set interval of time rather than on a monthly date. This late funding resulted in only 11 deposits being made during the year ended June 30, 2023. Effect Management commingled the residual receipts deposits with its replacement reserve, resulting in the potential use of residual receipts deposits to fund repairs or replacements without obtaining the required prior approval of HUD. Late deposits to the replacement reserve could result in insufficient funds for repairs and replacements. Recommendation Management should review and enhance its policies, procedures and internal controls to ensure that residual receipts deposits are segregated into a separate, restricted cash account. Management should review and enhance policies, procedures and internal controls to ensure that the replacement reserve deposits are made timely. Identification of repeat finding The finding is a repeat of Finding No. 2022-001. Auditor non-compliance code D - Commingling funds Questioned costs None Finding resolution status In process
Finding No. 2023-002: Cash Disbursements and Classifications (Material Weakness) Statement of condition Allowable costs Activities allowed or unallowed During the year ended June 30, 2023, the Organization: did not properly classify certain expenditures between expense accounts; did not obtain bids for an expenditure over $10,000; did not properly cut off disbursements at fiscal year end, resulting in expenses not being recorded within the current audit period; and did not accurately record gross potential rent, due to and from affiliates, and receivables. Criteria Management must review invoices after fiscal year end to ensure all expenses related to the fiscal period are being accurately captured. Additionally, management should review expenditures for accurate expense account classification and review revenue classifications to the appropriate revenue account recording to ensure proper financial and HUD reporting. The Uniform Guidance requires bidding be obtained for expenditures over $10,000. Cause Review procedures were not sufficient to ensure expenditures were recorded in accurate expense accounts and revenue was recorded in the appropriate revenue account. Review procedures were not adequately followed to review subsequent invoices for relevance to the current fiscal period. Review procedures were not sufficient to ensure expenditures over $10,000 received competitive bids. Effect Certain utility expenses presented for the current fiscal year were not recorded until the next fiscal year, resulting in understated expenses. Additionally, improperly capitalized expenditures and inaccurate expenses, fixed assets, and revenue classification could result in improper financial and HUD reporting. Recommendation Management should revisit and enhance its internal controls and procedures over subsequent expenditures to ensure expenses are captured in the correct fiscal period. Management should implement an additional period-end review to ensure proper classification of expenses, complete accrued expenditures, and accurate recording of revenue, due to and from affiliates, and receivables. Management should review its controls over expenditure authorization to ensure competitive bids are obtained where necessary. Identification of repeat finding The finding is a repeat of Finding No. 2022-002. Auditor non-compliance code S - Internal control deficiencies Questioned costs None Finding resolution status In process
Finding No. 2023-003: Financial Reporting (Material Weakness) Statement of condition Reporting The lack of appropriate policies, procedures, and internal processes led to inaccurate recording of depreciation, accounts payable, property insurance expense, and the tenant security deposit liability, and late filing of required reporting. Certain information technology controls and procedures were not documented, properly designed, or followed appropriately, including, but not limited to: segregation of administrative user roles from the accounting function, user access review, removal of terminated users, physical access, complementary user entity controls assessment, backup restoration testing, penetration testing, and cybersecurity awareness training. Criteria The Organization is required to have internal controls and procedures in place in order to timely and accurately report the results of its operations, close its books, and timely file its reports with the applicable federal agencies. These procedures include documenting of levels of review, reconciling accounting records at month-end and year-end close, and maintaining a well-documented, designed, and applied information technology environment. Cause Management did not have sufficient internal controls in place to accurately and timely report the results of the Organization's operations and maintenance and maintain the information technology environment. Effect Insufficient controls, late closing and reconciliation of accounting records, and insufficiently maintained information technology environment could result in accounting errors and theft. A lack of controls over financial reporting can result in untimely filing of required reports or incomplete filings with the regulatory and oversight entities. Recommendation We recommend that management re-evaluate its internal controls, policies and procedures to ensure an appropriate member of management is in place to review the year-end and month-end close processes, as well as journal entries, reconciliations, and other accounting records. Management should appoint an individual to be responsible for the Organization's financial statements and reporting obligations. Management evaluate its controls and procedures over the information technology environment to ensure they are properly documented, designed, and followed, including but not limited to: ensuring segregation of administrative user roles from the accounting function, performing a regular review of user access, ensuring terminated users are removed from all systems and software, ensuring restriction of physical access to the system, performing an assessment of complementary user entity controls for relevant software vendors, performing backup restoration tests and penetration tests, and providing cybersecurity awareness training. Identification of repeat finding The finding is a repeat of Finding No. 2022-003. Auditor non-compliance code S - Internal control deficiencies Questioned costs None Finding resolution status In process
Finding No. 2023-004: Timely Work Order Address (Significant Deficiency) Statement of condition Activities allowed or unallowed During the year ended June 30, 2023, management was unable to demonstrate timely completion of 9 of 38 work orders selected. Criteria HUD projects are required to complete work orders timely. Cause The Organization did not have sufficient controls in place to ensure the timely completion of work orders as required by HUD. Effect Significant repairs could be delayed and repairs could be falsified or duplicated. Recommendation Management should review and enhance its internal controls and procedures over work orders to ensure they are completed on a timely basis. Identification of repeat finding The finding is not a repeat finding. Auditor non-compliance code S - Internal control deficiencies Questioned costs None Finding resolution status In process
Finding No. 2023-005: Verification of Tenant Assets (Significant Deficiency) Statement of condition Eligibility During the year ended June 30, 2023, management did not perform a verification of tenant assets as part of tenant certification and recertification procedures. Criteria In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs, HUD projects are required to verify tenant assets to ensure appropriate subsidy calculations. Cause The Organization's tenants are multi-handicapped blind low-income adults. The cash accounts held by the tenants are maintained by the Sponsor on behalf of the tenants and therefore other assets are not verified. Effect Subsidy receipts could be overstated. Recommendation Management should review and enhance its certification and annual recertification procedures to include a verification of tenant assets. Identification of repeat finding The finding is a repeat of Finding No. 2022-005. Auditor non-compliance code S - Internal control deficiencies Questioned costs None Finding resolution status In process
Finding No. 2023-001: Restricted Cash (Material Weakness) Statement of condition Special Tests and Provisions During the year ended June 30, 2023, management did not segregate the residual receipts deposits into a segregated, restricted cash account. For two months of the fiscal year, the monthly replacement reserve deposit was funded in the subsequent month. The replacement reserve was underfunded by one month's deposit at June 30, 2023. Criteria In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs, HUD projects are required to establish and maintain at all times fully funded, separate bank accounts in the name of the entity for all security deposits collected and for residual receipts deposits. The Regulatory Agreement requires a monthly deposit of $235 in the replacement reserve. Cause The residual receipts deposits were deposited into the replacement reserve account and were not transferred into segregated accounts as of June 30, 2023. The monthly replacement reserve transfer was delayed by several days into the subsequent month due to it being on a set interval of time rather than on a monthly date. This late funding resulted in only 11 deposits being made during the year ended June 30, 2023. Effect Management commingled the residual receipts deposits with its replacement reserve, resulting in the potential use of residual receipts deposits to fund repairs or replacements without obtaining the required prior approval of HUD. Late deposits to the replacement reserve could result in insufficient funds for repairs and replacements. Recommendation Management should review and enhance its policies, procedures and internal controls to ensure that residual receipts deposits are segregated into a separate, restricted cash account. Management should review and enhance policies, procedures and internal controls to ensure that the replacement reserve deposits are made timely. Identification of repeat finding The finding is a repeat of Finding No. 2022-001. Auditor non-compliance code D - Commingling funds Questioned costs None Finding resolution status In process
Finding No. 2023-002: Cash Disbursements and Classifications (Material Weakness) Statement of condition Allowable costs Activities allowed or unallowed During the year ended June 30, 2023, the Organization: did not properly classify certain expenditures between expense accounts; did not obtain bids for an expenditure over $10,000; did not properly cut off disbursements at fiscal year end, resulting in expenses not being recorded within the current audit period; and did not accurately record gross potential rent, due to and from affiliates, and receivables. Criteria Management must review invoices after fiscal year end to ensure all expenses related to the fiscal period are being accurately captured. Additionally, management should review expenditures for accurate expense account classification and review revenue classifications to the appropriate revenue account recording to ensure proper financial and HUD reporting. The Uniform Guidance requires bidding be obtained for expenditures over $10,000. Cause Review procedures were not sufficient to ensure expenditures were recorded in accurate expense accounts and revenue was recorded in the appropriate revenue account. Review procedures were not adequately followed to review subsequent invoices for relevance to the current fiscal period. Review procedures were not sufficient to ensure expenditures over $10,000 received competitive bids. Effect Certain utility expenses presented for the current fiscal year were not recorded until the next fiscal year, resulting in understated expenses. Additionally, improperly capitalized expenditures and inaccurate expenses, fixed assets, and revenue classification could result in improper financial and HUD reporting. Recommendation Management should revisit and enhance its internal controls and procedures over subsequent expenditures to ensure expenses are captured in the correct fiscal period. Management should implement an additional period-end review to ensure proper classification of expenses, complete accrued expenditures, and accurate recording of revenue, due to and from affiliates, and receivables. Management should review its controls over expenditure authorization to ensure competitive bids are obtained where necessary. Identification of repeat finding The finding is a repeat of Finding No. 2022-002. Auditor non-compliance code S - Internal control deficiencies Questioned costs None Finding resolution status In process
Finding No. 2023-003: Financial Reporting (Material Weakness) Statement of condition Reporting The lack of appropriate policies, procedures, and internal processes led to inaccurate recording of depreciation, accounts payable, property insurance expense, and the tenant security deposit liability, and late filing of required reporting. Certain information technology controls and procedures were not documented, properly designed, or followed appropriately, including, but not limited to: segregation of administrative user roles from the accounting function, user access review, removal of terminated users, physical access, complementary user entity controls assessment, backup restoration testing, penetration testing, and cybersecurity awareness training. Criteria The Organization is required to have internal controls and procedures in place in order to timely and accurately report the results of its operations, close its books, and timely file its reports with the applicable federal agencies. These procedures include documenting of levels of review, reconciling accounting records at month-end and year-end close, and maintaining a well-documented, designed, and applied information technology environment. Cause Management did not have sufficient internal controls in place to accurately and timely report the results of the Organization's operations and maintenance and maintain the information technology environment. Effect Insufficient controls, late closing and reconciliation of accounting records, and insufficiently maintained information technology environment could result in accounting errors and theft. A lack of controls over financial reporting can result in untimely filing of required reports or incomplete filings with the regulatory and oversight entities. Recommendation We recommend that management re-evaluate its internal controls, policies and procedures to ensure an appropriate member of management is in place to review the year-end and month-end close processes, as well as journal entries, reconciliations, and other accounting records. Management should appoint an individual to be responsible for the Organization's financial statements and reporting obligations. Management evaluate its controls and procedures over the information technology environment to ensure they are properly documented, designed, and followed, including but not limited to: ensuring segregation of administrative user roles from the accounting function, performing a regular review of user access, ensuring terminated users are removed from all systems and software, ensuring restriction of physical access to the system, performing an assessment of complementary user entity controls for relevant software vendors, performing backup restoration tests and penetration tests, and providing cybersecurity awareness training. Identification of repeat finding The finding is a repeat of Finding No. 2022-003. Auditor non-compliance code S - Internal control deficiencies Questioned costs None Finding resolution status In process
Finding No. 2023-004: Timely Work Order Address (Significant Deficiency) Statement of condition Activities allowed or unallowed During the year ended June 30, 2023, management was unable to demonstrate timely completion of 9 of 38 work orders selected. Criteria HUD projects are required to complete work orders timely. Cause The Organization did not have sufficient controls in place to ensure the timely completion of work orders as required by HUD. Effect Significant repairs could be delayed and repairs could be falsified or duplicated. Recommendation Management should review and enhance its internal controls and procedures over work orders to ensure they are completed on a timely basis. Identification of repeat finding The finding is not a repeat finding. Auditor non-compliance code S - Internal control deficiencies Questioned costs None Finding resolution status In process
Finding No. 2023-005: Verification of Tenant Assets (Significant Deficiency) Statement of condition Eligibility During the year ended June 30, 2023, management did not perform a verification of tenant assets as part of tenant certification and recertification procedures. Criteria In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs, HUD projects are required to verify tenant assets to ensure appropriate subsidy calculations. Cause The Organization's tenants are multi-handicapped blind low-income adults. The cash accounts held by the tenants are maintained by the Sponsor on behalf of the tenants and therefore other assets are not verified. Effect Subsidy receipts could be overstated. Recommendation Management should review and enhance its certification and annual recertification procedures to include a verification of tenant assets. Identification of repeat finding The finding is a repeat of Finding No. 2022-005. Auditor non-compliance code S - Internal control deficiencies Questioned costs None Finding resolution status In process