Audit 397603

FY End
2023-12-31
Total Expended
$148.58M
Findings
4
Programs
7
Organization: Reinvestment Fund, Inc. (PA)
Year: 2023 Accepted: 2026-04-03
Auditor: COHNREZNICK

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
1205855 2023-001 Material Weakness Yes L
1205856 2023-001 Material Weakness Yes L
1205857 2023-001 Material Weakness Yes L
1205858 2023-001 Material Weakness Yes L

Programs

Contacts

Name Title Type
QPRNKP2T3EF2 Perri McLoughlin Auditee
2155745800 Erin Todd Auditor
No contacts on file

Notes to SEFA

Community Development Financial Institutions (“CDFI”) Bond Guarantee Program (Bond Program): Through the Bond Program, Reinvestment Fund was approved to borrow $55,000,000 and $75,000,000 in 2014 and 2016, respectively. The Bond Program gives Reinvestment Fund access to long-term fixed rate capital for terms of up to 29.5 years. The 2014 and 2016 bond programs are fully deployed. As required by the program, Reinvestment Fund entered into a loan agreement with CRF QI, LLC (“Qualified Issuer”). As a condition of the program, Reinvestment Fund must pledge eligible collateral to draw down on the loan. Under the program, the bonds are purchased by The Federal Financing Bank and the U.S. Treasury guarantees repayment of those bonds. The federal expenditure presented in the Schedule under Assistance Listing Number 21.014 of $43,043,526 represents the bond loan payable at January 1, 2023 for the 2014 bond program. The federal expenditure of $67,186,296 represents the bond loan payable at January 1, 2023 for the 2016 bond program. As of December 31, 2023, the total bond loans payable for the 2014 bond program and 2016 bond program were $41,003,575 and $64,507,750 respectively, secured by pledged loans receivable of approximately $42,702,000 and $70,133,000, respectively, and restricted cash of approximately $180,000 and $198,000, respectively.
Capital Magnet Fund Program: During 2018, the Organization entered into an assistance agreement with the CDFI Fund in the amount of $4,500,000 in support of the Capital Magnet Fund Program (“CMF”). In accordance with the agreement, these funds are to be used to support rental affordable housing activities in underserved markets. CMF awards are considered federal awards expended upon allocation of the funds towards one of the eligible uses of the assistance, as outlined in the assistance agreement. During 2023, the Organization committed $256,000 towards eligible uses, which was from program income earned and reinvested in the program; as such, this amount is included in federal expenditures in the Schedule under Assistance Listing Number 21.011.
CDFI Program: During 2021 and 2023 the Organization was awarded financial assistance awards from the CDFI Fund of $5,016,530 and $3,407,900 respectively. The funds are considered federal awards expended once the awardee expenses the funds for the authorized uses as outlined in the assistance agreement. The Organization expended $293,524 and $497,059 respectively during the year ended December 31, 2023; as such, this amount is included in federal expenditures in the Schedule under Assistance Listing Number 21.020.
Coronavirus State and Local Fiscal Recovery Fund (ARP): During 2022, the Organization received a grant from the Pennsylvania CDFI Network, which was funded by the Coronavirus State and Local Fiscal Recovery Fund, to provide lending, grants and technical assistance to small business or nonprofits. During 2023, the Organization provided $94,000 of funding to business; as such, this amount is included in federal expenditures in the Schedule under Assistance Listing Number 21.027.
(a) The Organization entered into a grant agreement with Capital Impact Partners (previously NCB Capital Impact) to share grant funds of $3,600,000 awarded by the United States Department of Education (“US ED”) under the Credit Enhancement for Charter School Facilities Program. Capital Impact Partners and the Organization have agreed to each utilize $1,800,000 to act as a first loss reserve for the charter school loans originated by each organization. (b) The Organization received grant funds of $10,000,000 from US ED under the Credit Enhancement for Charter School Facilities Program. The Organization agreed to utilize funds to leverage funding of charter schools in accordance with Performance Agreement. In prior years, two charter school loans, which were enhanced by the funding from Credit Enhancement for Charter School Facilities Program under US ED, were determined to be impaired. Accordingly, $3,127,829 was drawn down from the grant reserve account. (c) The Organization entered into a grant agreement with Capital Impact Partners and received $2,366,228 of US ED funds from Capital Impact Partners to utilize as a first loss reserve for the charter school loans originated by the Organization. During the year ended 2016, the Organization entered into a grant agreement with Capital Impact Partners and received an additional $1,352,339 of US ED funds from Capital Impact Partners for the same purpose. (d) The Organization received grant funds of $6,019,231 from US ED under the Credit Enhancement for Charter School Facilities Program. The Organization agreed to utilize funds to leverage funding of charter schools in accordance with Performance Agreement. (e) The Organization entered into a grant agreement with Low Income Investment Fund (“LIIF”) and received $2,000,000 of US ED funds from LIIF to utilize as a first loss reserve for the charter school loans originated by the Organization.
The Organization invested the grant funds received in separate grant reserve accounts in accordance with the requirements of the grants. The federal expenditure of $24,571,298 presented in the Schedule under Federal Assistance Listing Number 84.354A represents the amount in the reserve accounts at the beginning of the year of $23,454,777 plus 2023 net investment income of $1,116,521. The reserve accounts as of December 31, 2023 consist as follows: See Notes to SEFA for the table.
In 2019, the Organization was awarded a grant of $2,000,000 from the USDA, Rural Business-Cooperative Service. The grant was amended in 2020 and again in 2021, to increase the total award amount to $8,377,652. The grant is to be used to implement the Healthy Food Financing Initiative to improve access to healthy foods in underserved areas, to create and preserve quality jobs, and to revitalize low-income communities. During the year ended December 31, 2023, the Organization expended $1,998,934 under this agreement, which is included in the federal expenditures presented in the Schedule under Federal Assistance Listing Number 10.872. In 2021, the Organization was awarded a grant of $3,621,131 from the USDA, Rural Business-Cooperative Service. This grant was amended in 2022 to increase the total award amount to $5,865,827. The grant is to be used to implement the Healthy Food Financing Initiative to improve access to healthy foods in underserved areas, to create and preserve quality jobs, and to revitalize low-income communities. During the year ended December 31, 2023, the Organization expended $148,856 under this agreement, which is included in the federal expenditures presented in the Schedule under Federal Assistance Listing Number 10.872. In 2022, the Organization was awarded a grant of $20,000,000 from the USDA, Rural Business-Cooperative Service. The grant is to be used to implement the Healthy Food Financing Initiative to improve access to healthy foods in underserved areas, to create and preserve quality jobs, and to revitalize low-income communities. During the year ended December 31, 2023, the Organization expended $10,325,317 under this agreement, which is included in the federal expenditures presented in the Schedule under Federal Assistance Listing Number 10.872. In 2023, the Organization was awarded a grant of $135,000,000 from the USDA, Rural Business-Cooperative Service. The grant is to be used to implement the Healthy Food Financing Initiative to improve access to healthy foods in underserved areas, to create and preserve quality jobs, and to revitalize low-income communities. During the year ended December 31, 2023, the Organization expended $106,048 under this agreement, which is included in the federal expenditures presented in the Schedule under Federal Assistance Listing Number 10.872.

Finding Details

Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “FFATA” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The subawards are required to be reported no later than the last day of the month following the month in which the subaward obligation was made or modified. Condition: We were unable to determine if internal controls were in place during 2023 to ensure FFATA reporting was performed, and subawards entered into by Reinvestment Fund, Inc. over $30,000 were not reported. Cause The Organization’s federal grant compliance controls did not address the general administrative controls over ensuring FFATA reporting is performed as required. Effect or Potential Effect: FFATA reporting was not performed timely and accurately. Questioned Costs: None Context: Reinvestment Fund, Inc. had 98 subawards that met the FFATA requirements which were not reported. The federal award identification numbers (FAIN) for the awards is pending from the USDA and is required to complete the FFATA reporting. Identification as a Repeat Finding: No Recommendation: We recommend that Reinvestment Fund, Inc. implement policies and procedures to review FFATA reporting and maintain documentation of internal controls as well as provide training to staff on FFATA reporting requirements. Views of Responsible Officials: The Organization acknowledges that we should have been filing information for all of our grantees over $30,000 on the FFATA Sub-award Reporting System website. We have a remediation plan in place to ensure that all past grantees over $30,000 are registered on the website, and we have included FFATA registration as a step in the creation of all future HFFI grantees.