Finding 1163376 (2024-003)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2024
Accepted
2025-12-03

AI Summary

  • Core Issue: There are repeated compliance failures in managing grant awards, including incorrect calculations and missing documentation.
  • Impacted Requirements: The Bank must adhere to PRDOH’s policies and guidelines, particularly in underwriting, expenditure reviews, and grant closeout procedures.
  • Recommended Follow-Up: Review and strengthen compliance procedures as outlined in finding 2024-004 to prevent future issues.

Finding Text

FINDING NO. 2024-003 GRANT AWARDS REVIEW Repeated Finding: Yes Criteria: As more fully described in finding 2024-004, the subrecipient agreement between the Bank and the Puerto Rico Department of Housing (PRDOH), establishes in the Terms and Conditions that the Bank, as Subrecipient, shall comply with applicable PRDOH’s policies and guidelines as established in Program Guidelines and their amendments, if any, which made an integral part of the subrecipient agreement. Condition: As described in finding 2024-004, during our examination, we performed different audit testing to validate compliance with criteria described above. From a total of 974 SBF Program Recovery Grants (the grants) awarded to business applicants during the year ended June 30, 2024, in the amount of $66,108,871, we performed a grant award test to validate various compliance requirements for the grant. We selected a sample of sixty-one (61) grants awarded as follows: sixteen (16) awarded for working capital purposes, fourteen (14) awarded for working capital and equipment and thirty-one (31) grants awarded for the purchase of equipment, in total amount of $3,630,774. In addition, we performed a closeout test to validate procedures surrounding closeout of the grant. We selected a sample of sixty-one (61) cases, in the total amount of $3,598,259 from a total of 1,911 grants awarded amounting to $99,766,799 for which closeout procedures were completed during the year ended June 30, 2024. Also, we performed a recapture of funds test to validate procedures surrounding recapture of grant funds. We selected a sample of twenty-five (25) cases, in the total amount of $906,561 from a total of 318 grants awarded amounting to $11,492,282 for which recapture of funds were completed during the year ended June 30,2024. As more fully described in finding 2024-004, we noted the following: - Amount Awarded Computed Incorrectly - Incorrect Data in Grant Management System of Record for the Grants - Missing Documents in Grant Management System of Record for the Grants - Inadequate Documentation and Implementation of Procedures Cause: Management has not consistently applied procedures as described in the Bank’s policies for underwriting, duplication of benefits, expenditure review and closeout as more fully described in finding 2024-004. Effect: Refer to finding 2024-004 for the effect of this observation. Recommendation: Refer to finding 2024-004 for the recommendation for the observations associated with this finding.

Corrective Action Plan

Management does not concur with the finding. The cases identified were processed in accordance with the policies, guidelines, and procedures established by the Recipient (PRDOH) and were reviewed at each stage of the grant process, including award, disbursement, and closeout. All determinations were made following the internal controls, Program Guidelines, and systems established by the Recipient. The observations noted do not represent noncompliance by the Bank but, in some cases, reflect situations inherent to the grant management systems, which are administered directly by the Recipient and its consultants.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles Equipment & Real Property Management

Other Findings in this Audit

  • 1163375 2024-002
    Material Weakness Repeat
  • 1163377 2024-004
    Material Weakness Repeat
  • 1163378 2024-005
    Material Weakness Repeat
  • 1163379 2024-006
    Material Weakness Repeat
  • 1163380 2024-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $69.05M