Finding Text
2024-002 – HUD CAPITAL FUND PROGRAM (CFDA #14.872) DRAWDOWNS Federal Program Name: Capital Fund Program Assistance Listing Number: 14.872 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Cash Management Criteria: Per HUD Capital Fund Program guidance and 2 CFR 200.305(b) (Cash Management), PHAs must minimize the time between the drawdown of federal funds and disbursement to vendors. HUD guidance further states: “Once funds are disbursed, i.e., transferred from LOCCS to the PHA’s bank account, the PHA must pay the applicable bill(s) within 3 business days. PHAs cannot expend nonfederal funds first to pay the applicable bills and then use Capital Funds to reimburse themselves.” Condition: During our testing of Capital Fund drawdowns, we identified three drawdown transactions where the PHA did not comply with the 3-day rule. In each case, vendor payments were made prior to funds being received. Cause: Oversight Effect: The PHA is not in compliance with HUD’s cash management rules for Capital Fund drawdowns. Repeat Finding: No Recommendation: We recommend the PHA establish procedures requiring that Capital Fund related vendor invoices not be paid until drawdowns have occurred.