Core Issue: The internal control system lacks formal approval for cash disbursements, particularly for manual transactions like credit card expenses and reimbursements.
Impacted Requirements: The absence of a formal review process for cash disbursements and bank reconciliations violates compliance criteria.
Recommended Follow-Up: Management should reassess and strengthen the internal control processes to ensure all disbursements and reconciliations receive formal approval.
Finding Text
U.S. Department of Housing and Urban Development
Federal Financial Assistance Listing # 14.155
Section 223(f) Mortgage Insurance for the Purchase or Refinance of Existing Multifamily
Housing Projects
Special Tests and Provisions
Significant Deficiency in Internal Control over Compliance
Criteria: The Project’s internal control structure should be designed to have formal approval over each cash
disbursement.
Condition: The Project’s internal control system is designed to review and approve expenses only when the
disbursements are submitted formally through the system. Credit card transactions and various expense
reimbursements were processed manually with no formal documentation of review. In addition, there was no
formal review of bank reconciliations.
Cause: The controls in place did not operate as designed and did not account for documentation of a formal
review process.
Effect: There was no formal review over various cash disbursements and bank reconciliations.
Questioned costs: None reported.
Context: There were 443 invoices during the year that were subject to testing. A sample of 60 invoices during
the year were selected for testing and noted no formal approvals were documented on 28 of the invoices. There
was also no formal review of bank reconciliations.
Repeat Finding from Prior Year: No
Recommendation: We recommend management re-evaluate their internal control process over cash
disbursements and cash receipts to ensure each disbursement and reconciliation is formally approved.
Views of Responsible Officials: Management agrees with the finding.
Categories
Special Tests & ProvisionsProcurement, Suspension & DebarmentCash ManagementHUD Housing ProgramsSignificant DeficiencyInternal Control / Segregation of Duties