Finding 1086214 (2023-005)

Significant Deficiency
Requirement
B
Questioned Costs
$1
Year
2023
Accepted
2024-11-22
Audit: 329488
Organization: People Trust (AR)

AI Summary

  • Core Issue: The organization improperly disbursed funds net of application or origination fees, violating federal guidelines.
  • Impacted Requirements: CDFI ERP rules prohibit using funds for fees; costs totaling $11,404 were questioned.
  • Recommended Follow-up: Update policies to waive fees and consult with the federal agency for corrective actions on previously allocated fees.

Finding Text

Federal Agency: U.S. Department of Treasury Federal Program: CDFI Equitable Recovery Program (ERP) Assistance Listing Numbers: 21.033 Federal Award Identification Number and Year: 22ERP061482 – 2023 Award Period: January 1, 2023 – December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Compliance - Other Matter Criteria or Specific Requirement: Under the FY2022 CDFI ERP Supplemental FAQ (updated on September 9, 2022), award recipients cannot use the ERP funds to issue financial assistance net of fees charged by the award recipient, or any of its affiliates. If the award recipient would like to use ERP funds for this purpose, it would do so by waiving the processing or origination fee for the borrower or beneficiary and use the available operational support funds to cover those underlying costs (e.g. salaries). Condition: The Organization disbursed grant payments to beneficiaries and loans to borrowers that were net of an application or origination fee assessed by the Organization. Questioned Costs: $11,404 Context: Of the loan and grant disbursements tested it was identified twenty-four loans and ten grant disbursements sampled were net of fees assessed by the Organization. The total fees amounted to $11,404 which reduced the loan or grant disbursement made to the individual and was included as part of the total financial products/ grants paid under the federal award’s "program activities" budget line. The underlying costs associated with these fees are primarily derived from salaries of the employees who processed the applications or originated the loans. As these salaries are directly charged to the award as part of “operational support activities” budget line, the Organization effectively charged the federal award twice for the same or similar costs. Cause: Management assumed they could charge fees consistent with their other program and lending activities. They were not fully aware of the federal regulations and program requirements related to fees assessed by the award recipient under the ERP program. Effect: Questioned costs were identified. Repeat Finding: No Recommendation: Management should update its policies and procedures to waive any organizational fees for the borrower or beneficiary and instead recover those costs through directly charging the underly expenses as part of the federal award’s “operational support activities” budget line. In addition, management should consult the appropriate federal agency on any further corrective action related to the fees already paid and allocated as “program activities”. Views of Responsible Officials: There is no disagreement with the audit finding.

Categories

Questioned Costs Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 509771 2023-004
    Material Weakness
  • 509772 2023-005
    Significant Deficiency
  • 509773 2023-006
    Significant Deficiency
  • 1086213 2023-004
    Material Weakness
  • 1086215 2023-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.033 Cdfi Equitable Recovery Plan (erp) $1.81M
21.020 Community Development Financial Institutions Program $325,000
14.231 Emergency Solutions Grant Program $110,146
14.267 Continuum of Care Program $72,256