Finding Text
FINDING NO. 2024-006 PROCUREMENT AND CONTRACTOR OVERSIGHT Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Federal Financial Assistance Listing 14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii Federal Award No: B-18-DP-72-0001 Compliance Requirement: Special Tests and Provisions Questioned Costs: None Repeated Finding: No Criteria: The subrecipient agreement between the Bank and the Puerto Rico Department of Housing (PRDOH), established in the Terms and Conditions Section Y. Conduct, Subsection 1. Contracts, under letter e. Notification, the following: “The Subrecipient shall notify and provide a copy of any and all contracts related to this agreement and CDBG-DR funds to the Contracts Administration Area of the CDBG-DR Legal Division within three (3) days of its execution”. Conditions and Context: During our audit procedures over the special tests and provisions, it was observed that the Bank entered into an agreement with a third party on June 13, 2023. The Bank submitted the agreement and its amendment to the PRDOH CDBG-DR Legal Division on September 21, 2023, three months past the execution date. Cause: Management has not consistently applied procedures as described in the “Conduct Section” to ensure compliance with special requirements. Effect: The Bank did not comply with notifying and providing a copy of the awarded subcontracts to PRDOH CDBG- DR Legal Division within the established period. Recommendation: Management must establish internal controls that permit the proper detection of any instance of non- compliance with the special requirements. By doing so, the Bank will avoid falling in noncompliance with federal requirements and the terms and conditions established in the subrecipient agreement.