Audit 415718

Finding Number: 2025-001 - Equipment and Real Property Management Program Name: Economic Development Initiative, Community Project Funding, and Miscellaneous Grants Assistance Listing: 14.251 Award Number and Government Department/Agency: B-23-CP-NY-1118, U.S. Department of Housing and Urban Development Federal Award Period: 12/19/2024 - 8/31/2031 Criteria: Article IV.F of the grant agreement requires compliance with 2 CFR Part 200. Under 2 CFR 200.310, the non-federal entity must provide at minimum the equivalent insurance coverage for real property acquired with federal funds as it provides to property it owns. Condition: The Center acquired real property at 50 Spring Valley Road, Ossining, New York on April 15, 2025 at a cost of $1,542,213, funded entirely by the federal award. No property, hazard, or general liability insurance was in force with respect to the property at any time during the year ended December 31, 2025. Cause: The Center relied on third parties to place coverage and did not obtain written confirmation that coverage had been bound. No individual was assigned responsibility for verifying that insurance was in force. Effect or potential effect: Without insurance coverage in force, the Center was exposed to: - Uninsured loss of real property carried at $1,542,213. - Exposure of the federal interest in the property to loss. - Inability to carry out the purpose of the award following a casualty event. Questioned costs: None. Context: This is not a sampling-based finding. The condition applied to the entirety of the real property acquired under the award. Repeat finding: No. Recommendations: We recommend that the Center: - Obtain property, hazard, and general liability coverage naming the Center as insured. - Require written confirmation that coverage has been bound before relying on it. - Confirm insurance in force annually through a designated individual and report to the Board. Views of Responsible Officials: See management corrective action plan attached.

Finding Number: 2025-002 - Special Tests and Provisions: Uniform Relocation Act Program Name: Economic Development Initiative, Community Project Funding, and Miscellaneous Grants Assistance Listing: 14.251 Award Number and Government Department/Agency: B-23-CP-NY-1118, U.S. Department of Housing and Urban Development Federal Award Period: 12/19/2024 - 8/31/2031 Criteria: Article IV.K of the grant agreement requires compliance with the Uniform Relocation Act and 49 CFR Part 24, including the relocation provisions applicable to any person who moves from real property as a direct result of acquisition for a federally assisted project. 2 CFR 200.303 requires effective internal control over the federal award. Condition: The Center acquired occupied residential real property using federal award funds on April 15, 2025, and the vacancy of existing tenants was a condition of its purchase terms. The Center did not assess whether the relocation provisions of 49 CFR Part 24 applied, did not identify the occupants or retain occupancy records, and did not issue any notice required by 49 CFR 24.203. Cause: The Center had not established written policies or procedures addressing compliance with 49 CFR Part 24, and no individual was assigned responsibility for identifying and monitoring relocation requirements in connection with property acquisition undertaken with federal funds. Effect or potential effect: Without an assessment and supporting records, the Center: - Cannot demonstrate whether any occupant was a displaced person entitled to relocation assistance. - Did not provide required notices or advisory services to occupants. - May not have made relocation payments that were required. Questioned costs: Undetermined. The amount, if any, could not be quantified in the absence of an assessment of the occupants' eligibility for relocation assistance. Context: This is not a sampling-based finding. The condition applies to the single real property acquisition carried out under the award. Repeat finding: No. Recommendations: We recommend that the Center: - Determine, in consultation with HUD, whether any occupant was a displaced person under 49 CFR Part 24. - Take such corrective action as HUD directs. - Adopt written policies addressing 49 CFR Part 24 for future related activity. Views of Responsible Officials: See management corrective action plan attached.