Audit 330424

Program Name: 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria: Federal loans are required to be reported on the Schedule of Expenditures of Federal Awards. (Section 200.502(b) of 2 CFR Part 200). Condition: The Organization had a federal loan of $500,000 received in a prior year that was not originally included on the Organization’s Schedule of Expenditures of Federal Awards (SEFA). This is a repeat finding of item 2023‐001. Cause of Condition: The Organization failed to properly identify the loan as needing to be reflected on the SEFA. Potential Effect of Condition: The Organization’s federal loan not being included in the audited SEFA. Recommendation: The Organization should establish policies and procedures to carefully review loans and consider whether they should be included on the SEFA. Views of Responsible Officials: Management has acknowledged that this should be included in the Schedule of Expenditures of Federal Awards and will include it as required in any applicable year. Management will implement federal grant and loan management policies and procedures and provide training to staff responsible for completing the Schedule of Expenditure of Federal Awards (SEFA) to ensure all federal grants and loans are included in the SEFA (pursuant to Section 200.502(b) of 2 CFR Part 200). Additionally, management will create and maintain an electronic repository of relevant federal grant and loan information that contains key information relating to each federal program to assist in preparing the SEFA.

Program Name: 14.239 Home Investment Partnership Program Criteria: Federal loans are required to be reported on the Schedule of Expenditures of Federal Awards. (Section 200.502(b) of 2 CFR Part 200). Condition: The Organization had a federal loan of $210,000 received in a prior year that was not originally included on the Organization’s Schedule of Expenditures of Federal Awards (SEFA). This is a repeat finding of item 2023‐002. Cause of Condition: The Organization failed to properly identify the loan as needing to be reflected on the Schedule of Expenditures of Federal Awards. Potential Effect of Condition: The Organization’s federal loan not being included in the audited Schedule of Expenditures of Federal Awards. Recommendation: The Organization should establish policies and procedures to carefully review loans and consider whether they should be included on the Schedule of Expenditures of Federal Awards. Views of Responsible Officials: Management has acknowledged that this should be included in the Schedule of Expenditures of Federal Awards and will include it as required in any applicable year. Management will implement federal grant and loan management policies and procedures and provide training to staff responsible for completing the Schedule of Expenditure of Federal Awards (SEFA) to ensure all federal grants and loans are included in the SEFA (pursuant to Section 200.502(b) of 2 CFR Part 200). Additionally, management will create and maintain an electronic repository of relevant federal grant and loan information that contains key information relating to each federal program to assist in preparing the SEFA.

Program Name: 21.026 Homeowners Assistance Fund Criteria: The Organization is expected to establish and adhere to reasonable policies and procedures for evaluating homeowners’ applications in accordance with the Homeowners Assistance Fund (HAF) Guidance which permits HAF participants to reasonably rely on self‐attestation. Specifically related to income determination requirements, the Organization allows the homeowner to provide a written attestation as to household income together with supporting documentation such as paystubs, W‐2’s or other wage statements, IRS Forms 1099, tax filings, depository institution statements demonstrating regular income, or an attestation from an employer. Condition: The Organization had two instances in a sample size of 40 where appropriate review of homeowner’s income had not taken place. In both instances, the applicants’ income support was materially accurate and still met required eligibility and, therefore, were in compliance. Cause of Condition: The Organization failed to properly review and summarize income support provided by applicants. Potential Effect of Condition: Although the condition above did not result in noncompliance, if the cause of condition were to reoccur, noncompliance could occur and, ultimately, the HAF funding could get denied. Recommendation: The Organization should establish policies and procedures to carefully review income support and consider whether the individual meets eligibility requirements. Views of Responsible Officials: Management has acknowledged the finding and management will provide updated training to underwriters and processors to accurately fill out eligibility checklists and confirm that support matches. Additionally, the Program Manager will select and review files monthly and the Financial Services Director will review files on a quarterly basis.

Program Name: 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria: Federal loans are required to be reported on the Schedule of Expenditures of Federal Awards. (Section 200.502(b) of 2 CFR Part 200). Condition: The Organization had a federal loan of $500,000 received in a prior year that was not originally included on the Organization’s Schedule of Expenditures of Federal Awards (SEFA). This is a repeat finding of item 2023‐001. Cause of Condition: The Organization failed to properly identify the loan as needing to be reflected on the SEFA. Potential Effect of Condition: The Organization’s federal loan not being included in the audited SEFA. Recommendation: The Organization should establish policies and procedures to carefully review loans and consider whether they should be included on the SEFA. Views of Responsible Officials: Management has acknowledged that this should be included in the Schedule of Expenditures of Federal Awards and will include it as required in any applicable year. Management will implement federal grant and loan management policies and procedures and provide training to staff responsible for completing the Schedule of Expenditure of Federal Awards (SEFA) to ensure all federal grants and loans are included in the SEFA (pursuant to Section 200.502(b) of 2 CFR Part 200). Additionally, management will create and maintain an electronic repository of relevant federal grant and loan information that contains key information relating to each federal program to assist in preparing the SEFA.

Program Name: 14.239 Home Investment Partnership Program Criteria: Federal loans are required to be reported on the Schedule of Expenditures of Federal Awards. (Section 200.502(b) of 2 CFR Part 200). Condition: The Organization had a federal loan of $210,000 received in a prior year that was not originally included on the Organization’s Schedule of Expenditures of Federal Awards (SEFA). This is a repeat finding of item 2023‐002. Cause of Condition: The Organization failed to properly identify the loan as needing to be reflected on the Schedule of Expenditures of Federal Awards. Potential Effect of Condition: The Organization’s federal loan not being included in the audited Schedule of Expenditures of Federal Awards. Recommendation: The Organization should establish policies and procedures to carefully review loans and consider whether they should be included on the Schedule of Expenditures of Federal Awards. Views of Responsible Officials: Management has acknowledged that this should be included in the Schedule of Expenditures of Federal Awards and will include it as required in any applicable year. Management will implement federal grant and loan management policies and procedures and provide training to staff responsible for completing the Schedule of Expenditure of Federal Awards (SEFA) to ensure all federal grants and loans are included in the SEFA (pursuant to Section 200.502(b) of 2 CFR Part 200). Additionally, management will create and maintain an electronic repository of relevant federal grant and loan information that contains key information relating to each federal program to assist in preparing the SEFA.

Program Name: 21.026 Homeowners Assistance Fund Criteria: The Organization is expected to establish and adhere to reasonable policies and procedures for evaluating homeowners’ applications in accordance with the Homeowners Assistance Fund (HAF) Guidance which permits HAF participants to reasonably rely on self‐attestation. Specifically related to income determination requirements, the Organization allows the homeowner to provide a written attestation as to household income together with supporting documentation such as paystubs, W‐2’s or other wage statements, IRS Forms 1099, tax filings, depository institution statements demonstrating regular income, or an attestation from an employer. Condition: The Organization had two instances in a sample size of 40 where appropriate review of homeowner’s income had not taken place. In both instances, the applicants’ income support was materially accurate and still met required eligibility and, therefore, were in compliance. Cause of Condition: The Organization failed to properly review and summarize income support provided by applicants. Potential Effect of Condition: Although the condition above did not result in noncompliance, if the cause of condition were to reoccur, noncompliance could occur and, ultimately, the HAF funding could get denied. Recommendation: The Organization should establish policies and procedures to carefully review income support and consider whether the individual meets eligibility requirements. Views of Responsible Officials: Management has acknowledged the finding and management will provide updated training to underwriters and processors to accurately fill out eligibility checklists and confirm that support matches. Additionally, the Program Manager will select and review files monthly and the Financial Services Director will review files on a quarterly basis.