Federal program: FAL 21.027, Coronavirus State and Local Fiscal Recovery Funds Significant deficiency Criteria: Management is responsible for designing, implementing, and maintaining effective internal controls to ensure accurate financial reporting and safeguard assets. Downstreet’s internal control procedures require the Vermont Housing Improvement Program (VHIP) expenditure tracking spreadsheets to be updated and reviewed prior to disbursements of VHIP grant funds to grant awardees. Condition: During testing of the VHIP grant fund disbursement process, the auditor found that the control designed to ensure all payments were supported by adequate documentation was not operating effectively. Corrective action plan: Downstreet has revised the VHIP approval process to ensure invoices and tracking sheets are verified before disbursement, with documentation uploaded to client files. Staff roles within the Homeownership Center have been realigned to improve accuracy, and a new staff member now supports the program, with responsibilities that include auditing files at disbursement to confirm completeness. All corrective actions have been implemented as of September 2025. Responsible official: Schuyler Anderson, CFO/COO