Audit 26661

COMPLIANCE WITH LAWS AND REGULATIONS MATERIAL WEAKNESS Public and Indian Housing Finding 2022-001 Statement of Condition: During the audit it was noted the Commission held funds of $132,355 in excess of the FDIC insurance limit at one bank that were not insured and uncollateralized. Criteria: Compliance N.15 states that the Commission is required to have depository agreements signed by all financial institutions it does business with. The deposit agreement states that the financial institution will insure any of the Commission?s funds that exceed FDIC limits. Condition: The Commission was not in compliance with the ACC contract requiring funds held in excess of FDIC limits be insured. The Commission also did not have policies and procedures in place to monitor cash and investments to verify that the collateral provided by the financial institutions was adequate throughout the year. Questioned Costs: $132,355 Effect: The Commission is not in compliance with the ACC contract. Cause: Lack of internal controls over monitoring of collateralization of underinsured accounts. Recommendation: The Commission should require its financial institutions to provide documentation of collateral at a minimum on a quarterly basis. The Commission should also adopt policies and procedures to monitor its cash and investments continuously to verify that the collateral provided by the financial institutions is adequate throughout the year. Management?s Response: Management will implement a new process that will require the banks to provide proof of insurance coverage on a quarterly basis, at minimum.

COMPLIANCE WITH LAWS AND REGULATIONS SINGIFICANT DIFFIENCNEY Public and Indian Housing Finding 2022-003 Statement of Condition: During the review of low rent disbursements, it was noted there was no review of contractors to ensure they were not debarred from working on federal projects. Criteria: I. PROCURMENT: 2 CFR section 200.317 requires a PHA to ensure non-federal entities are not prohibited from contracting with parties that are suspended or debarred. Perspective Information: The Commission did not have effective internal controls over procurement, suspension and debarment for the federal program. Questioned Costs: Unknown. Effect: The Commission is not in compliance with the requirements as outlined in the Procurement, Suspension and Debarment section above. Cause: Lack of controls over grant requirements. Recommendation: The Commission should implement policies and procedures to ensure all federal compliances are followed pertaining to Procurement, Suspension and Debarment. Management?s Response: Management will implement policies and procedures to ensure the Commission is in compliance with all grant requirements pertaining to the Public and Indian Housing Grant.

COMPLIANCE WITH LAWS AND REGULATIONS SINGIFICANT DIFFIENCNEY Housing Choice Vouchers Finding 2022-002 Statement of Condition: During the review of the Housing Choice Voucher Program, it was noted the HUD Form 60002, Section 3 reporting requirement was not completed. Criteria: L. REPORTING ITEM B. HUD 60002, SECTION 3 SUMMARY REPORT, ECONOMIC OPPORTUNITIES FOR LOW- AND VERY LOW-INCOME PERSONS: 24 CFR sections 135.3(a)(1) and 135.90 requires the Commission that administers covered public and Indian housing assistance in excess of $200,000 must submit HUD 60002. Perspective Information: The Commission did not have effective internal controls over required reporting for the pertaining to the Housing Choice Vouchers Program. Questioned Costs: Unknown Effect: The Commission is not in compliance with the requirements as outlined in the reporting section above. Cause: Lack of internal controls over grant requirements Recommendation: The Commission should implement policies and procedures to ensure all proper reporting is completed per the grant requirements. Management?s Response: Management will implement policies and procedures to ensure compliance with all reporting requirements of the Housing Choice Voucher Grant.

COMPLIANCE WITH LAWS AND REGULATIONS MATERIAL WEAKNESS Public and Indian Housing Finding 2022-001 Statement of Condition: During the audit it was noted the Commission held funds of $132,355 in excess of the FDIC insurance limit at one bank that were not insured and uncollateralized. Criteria: Compliance N.15 states that the Commission is required to have depository agreements signed by all financial institutions it does business with. The deposit agreement states that the financial institution will insure any of the Commission?s funds that exceed FDIC limits. Condition: The Commission was not in compliance with the ACC contract requiring funds held in excess of FDIC limits be insured. The Commission also did not have policies and procedures in place to monitor cash and investments to verify that the collateral provided by the financial institutions was adequate throughout the year. Questioned Costs: $132,355 Effect: The Commission is not in compliance with the ACC contract. Cause: Lack of internal controls over monitoring of collateralization of underinsured accounts. Recommendation: The Commission should require its financial institutions to provide documentation of collateral at a minimum on a quarterly basis. The Commission should also adopt policies and procedures to monitor its cash and investments continuously to verify that the collateral provided by the financial institutions is adequate throughout the year. Management?s Response: Management will implement a new process that will require the banks to provide proof of insurance coverage on a quarterly basis, at minimum.

COMPLIANCE WITH LAWS AND REGULATIONS SINGIFICANT DIFFIENCNEY Public and Indian Housing Finding 2022-003 Statement of Condition: During the review of low rent disbursements, it was noted there was no review of contractors to ensure they were not debarred from working on federal projects. Criteria: I. PROCURMENT: 2 CFR section 200.317 requires a PHA to ensure non-federal entities are not prohibited from contracting with parties that are suspended or debarred. Perspective Information: The Commission did not have effective internal controls over procurement, suspension and debarment for the federal program. Questioned Costs: Unknown. Effect: The Commission is not in compliance with the requirements as outlined in the Procurement, Suspension and Debarment section above. Cause: Lack of controls over grant requirements. Recommendation: The Commission should implement policies and procedures to ensure all federal compliances are followed pertaining to Procurement, Suspension and Debarment. Management?s Response: Management will implement policies and procedures to ensure the Commission is in compliance with all grant requirements pertaining to the Public and Indian Housing Grant.

COMPLIANCE WITH LAWS AND REGULATIONS SINGIFICANT DIFFIENCNEY Housing Choice Vouchers Finding 2022-002 Statement of Condition: During the review of the Housing Choice Voucher Program, it was noted the HUD Form 60002, Section 3 reporting requirement was not completed. Criteria: L. REPORTING ITEM B. HUD 60002, SECTION 3 SUMMARY REPORT, ECONOMIC OPPORTUNITIES FOR LOW- AND VERY LOW-INCOME PERSONS: 24 CFR sections 135.3(a)(1) and 135.90 requires the Commission that administers covered public and Indian housing assistance in excess of $200,000 must submit HUD 60002. Perspective Information: The Commission did not have effective internal controls over required reporting for the pertaining to the Housing Choice Vouchers Program. Questioned Costs: Unknown Effect: The Commission is not in compliance with the requirements as outlined in the reporting section above. Cause: Lack of internal controls over grant requirements Recommendation: The Commission should implement policies and procedures to ensure all proper reporting is completed per the grant requirements. Management?s Response: Management will implement policies and procedures to ensure compliance with all reporting requirements of the Housing Choice Voucher Grant.