Finding Text
Program Name Public Housing Capital Fund Program Noncompliance Significant Deficiency
ALN Number 14.872 C Cash Management
2023-005 Drawing of Capital Funds
Criteria Per 24 CFR 200.05, Housing Authorites are to minimuze the time federal funds are dranw down to expenditure. Additionally 24 CFR 905.310 states that PHA shall iniiate a fund requisition from HUD only when funds are due and payable, unless HUD approves another payment schedule.
Condition Management did not follow the 3 day rule.
Context During a RAD conversion, management drew down CFP funds to provide funding for RAD tax credit property. Instead of providing all funds to the RAD development within 3 days. Management held onto the funds and paid for draws as invoiced.
Cause Management drew funds from CFP when funds were not due.
Effect The Authority is not in complinace with Cash Management rules relating to the Capital Fund Program.
Recommendations The Authority needs to understand and comply with Public housing Capital Fund Program's cash management rules.
Management Views Management agrees.