Audit 350650

Condition: The Land Bank has not adopted a written procurement policy. The Land Bank did not retain supporting documentation for procurements entered during the year ended December 31, 2023. Context: The Land Bank represented contractors were evaluated by analyzing City of Wilmington permit information. The Land Bank did not retain documentation of this analysis to support its procurement actions. Criteria: CFR § 200.318, General Procurement Standards and § 200.320 Methods of Procurement to be Followed, of the Uniform Guidance apply to the State and Local Fiscal Recovery Funds Program and require the following: i. The Land Bank must adopt documented procurement procedures that are consistent with the applicable State, local and federal regulations. ii. The Land Bank’s documented procurement procedures must include the following elements at a minimum: a. Micro-purposes - purchases up to $50,000 may be made without soliciting competitive price or rate quotations if the price is considered reasonable. b. Small Purchases - purchases between $50,000 and $250,000 may be made with soliciting competitive price or rate quotations from an adequate number of qualified sources. c. Formal Procedures - purchases over $250,000 must be made by sealed bid or competitive proposal. Cause: The Land Bank does not have a written procurement policy. Questioned Costs: None Effect: The Land Bank did comply with the Uniform Guidance requirement to adopt a procurement policy and did not fully document its procurement actions. Recommendation: We recommend Land Bank establish a procurement policy and prepare documentation for each procurement action.

Condition: The Land Bank did not submit timely or complete quarterly project and expenditure reports to the State of Delaware. For the two quarterly reports tested, The Land Bank submitted both reports after their due date and did not report obligation information. Criteria: As detailed in Exhibit A to the grant agreement between the State of Delaware and the Land Bank, the Land Bank is required to submit quarterly project and expenditure reports to the State of Delaware 15 days after each quarter end. The Land Bank is also required to include the following information in the Report Contents: “Obligations and Expenditures: Subrecipient shall report on each program's obligations and expenditures including (1) current period obligations, (ii) cumulative obligations, (iii) current period expenditures, and (iv) cumulative expenditures.” Cause: The Land Bank did not submit the selected reports timely or with all of the required information. Questioned Costs: None Effect: The Land Bank did not comply with the State of Delaware grant agreement to submit timely and complete quarterly reports. Recommendation: We recommend the Land Bank implement controls and policies to ensure reports are completed as required by the grant agreement.

Condition: The Land Bank has not adopted a written procurement policy. The Land Bank did not retain supporting documentation for procurements entered during the year ended December 31, 2023. Context: The Land Bank represented contractors were evaluated by analyzing City of Wilmington permit information. The Land Bank did not retain documentation of this analysis to support its procurement actions. Criteria: CFR § 200.318, General Procurement Standards and § 200.320 Methods of Procurement to be Followed, of the Uniform Guidance apply to the State and Local Fiscal Recovery Funds Program and require the following: i. The Land Bank must adopt documented procurement procedures that are consistent with the applicable State, local and federal regulations. ii. The Land Bank’s documented procurement procedures must include the following elements at a minimum: a. Micro-purposes - purchases up to $50,000 may be made without soliciting competitive price or rate quotations if the price is considered reasonable. b. Small Purchases - purchases between $50,000 and $250,000 may be made with soliciting competitive price or rate quotations from an adequate number of qualified sources. c. Formal Procedures - purchases over $250,000 must be made by sealed bid or competitive proposal. Cause: The Land Bank does not have a written procurement policy. Questioned Costs: None Effect: The Land Bank did comply with the Uniform Guidance requirement to adopt a procurement policy and did not fully document its procurement actions. Recommendation: We recommend Land Bank establish a procurement policy and prepare documentation for each procurement action.

Condition: The Land Bank did not submit timely or complete quarterly project and expenditure reports to the State of Delaware. For the two quarterly reports tested, The Land Bank submitted both reports after their due date and did not report obligation information. Criteria: As detailed in Exhibit A to the grant agreement between the State of Delaware and the Land Bank, the Land Bank is required to submit quarterly project and expenditure reports to the State of Delaware 15 days after each quarter end. The Land Bank is also required to include the following information in the Report Contents: “Obligations and Expenditures: Subrecipient shall report on each program's obligations and expenditures including (1) current period obligations, (ii) cumulative obligations, (iii) current period expenditures, and (iv) cumulative expenditures.” Cause: The Land Bank did not submit the selected reports timely or with all of the required information. Questioned Costs: None Effect: The Land Bank did not comply with the State of Delaware grant agreement to submit timely and complete quarterly reports. Recommendation: We recommend the Land Bank implement controls and policies to ensure reports are completed as required by the grant agreement.