Finding 1145269 (2024-001)

-
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-06-29
Audit: 360558
Organization: Alma Housing Commission (MI)

AI Summary

  • Core Issue: The Housing Commission exceeded the federally insured cash threshold at one financial institution, risking custodial credit exposure.
  • Impacted Requirements: HUD mandates that all cash accounts must be federally insured, and the Housing Commission must actively monitor compliance.
  • Recommended Follow-Up: Move funds to a compliant financial institution and implement regular monitoring of bank accounts to ensure adherence to coverage requirements.

Finding Text

Program Assistance Listing # 14.850 - Public Housing Operating Fund from Department of Housing and Urban Development (HUD) Criteria HUD requires all cash accounts to be federally insurance through FDIC or NCUA coverage. In order to monitor proper coverage the Housing Commission is required to maintain depository agreements with their financial institutions. As part of the depository agreement, the financial institution is to monitor cash accounts and inform the Housing Commission when they are reaching the FDIC or NCUA coverage threshold. Condition The Housing Commission has the proper depository agreements in place with all financial institutions. However, the cash amount in one of the financial institutions exceeds the federally insured threshold when considering the total cash deposited in the financial institution between the various programs. Questioned costs No questioned costs related to compliance finding. Context The Housing Commission relies on the financial institution to notify them when they are approaching the federally insured threshold. Effect The Housing Commission is exposed to a custodial credit risk and the potential for a loss. Cause The Housing Commission relied on the financial institution. The Housing Commission also had a misunderstanding with federal coverage requirements. The Housing Commission thought coverage was based on the different program's bank accounts and was not aware that federal coverage is based on the Housing Commission's EIN. Recommendation We recommend the Housing Commission move their funds to another financial institution to maintain proper FDIC or NCUA coverage. We also recommend the Housing Commission monitor's their bank accounts in order to confirm proper compliance requirements are being followed. Views of the Responsible Officials and Planned Corrective Action The Executive Director discussed federal coverage with the auditors and the financial institution to get a better understanding of FDIC and NCUA coverage. The Executive Director will monitor the bank accounts rather than strictly rely on the financial institutions. The Executive Director has moved the funds to another financial institution to be in fill compliance.

Categories

HUD Housing Programs

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
14.850 Public Housing Operating Fund $321,012
14.871 Section 8 Housing Choice Vouchers $272,144
14.182 Lower Income Housing Assistance Program_section 8 New Construction/substantial Rehabilitation $195,260
14.872 Public Housing Capital Fund $92,721