Finding 1165408 (2024-005)

Material Weakness Repeat Finding
Requirement
P
Questioned Costs
-
Year
2024
Accepted
2025-12-18
Audit: 376068
Organization: Solutions for Change, Inc. (CA)
Auditor: LEAF & COLE LLP

AI Summary

  • Core Issue: Solutions for Change withdrew $19,240 from the replacement reserve account without County approval, violating the Regulatory Agreement.
  • Impacted Requirements: The replacement reserve account had a deficient balance of $205,929, indicating non-compliance with funding rules.
  • Recommended Follow-Up: Solutions for Change should repay the reserves, seek approval for future withdrawals, and consider a short-term loan if necessary.

Finding Text

Section III - Federal Award Findings and Questioned Costs Finding 2024-005 - Replacement Reserve Withdrawals – HOME Investment Partnership Program, Assistance Listing Number 14.239: Statement of Condition: Withdrawals in the amount of $19,240 were made by Solutions for Change from the replacement reserve account for the Projects acquired with HOME Investment Partnerships Program funds to cover operating cash flows needs during the year ended December 31, 2024. Criteria: According to the County of San Diego Department of Housing and Community Development (the “County”) Regulatory Agreement, disbursements from the replacement reserve accounts may only be made to fund Project expenses with the approval of the County Effect: Solutions for Change was not in compliance with the terms of the County Regulatory Agreement during the year and the replacement reserve had a deficient balance of $205,929 at December 31, 2024. Cause: Solutions for Change used funds from the replacement reserve account to cover operating cash flow needs. Recommendation: Replacement reserves should be repaid. Future withdrawals should be made with the approval of MHP. Management Response: Current management recognizes these withdrawals were made in error. Repayment of the reserves is planned to be funded through sale of the General Partner’s NSP properties, which will be in Q4 2026. A short-term loan may be necessary to fund the reserves prior to sale of the properties. Repayment may be sooner pending fundraising results. No future withdrawals which are not in compliance with the County Regulatory Agreement are planned.

Corrective Action Plan

Finding 2024-005 - Replacement Reserve Withdrawals – HOME Investment Partnership Program, Assistance Listing Number 14.239: Statement of Condition: Withdrawals in the amount of $19,240 were made by Solutions for Change from the replacement reserve account for the Projects acquired with HOME Investment Partnerships Program funds to cover operating cash flows needs during the year ended December 31, 2024. Criteria: According to the County of San Diego Department of Housing and Community Development (the “County”) Regulatory Agreement, disbursements from the replacement reserve accounts may only be made to fund Project expenses with the approval of the County Effect: Solutions for Change was not in compliance with the terms of the County Regulatory Agreement during the year and the replacement reserve had a deficient balance of $205,929 at December 31, 2024. Cause: Solutions for Change used funds from the replacement reserve account to cover operating cash flow needs. Recommendation: Replacement reserves should be repaid. Future withdrawals should be made with the approval of MHP. Management Response: Current management recognizes these withdrawals were made in error. Repayment of the reserves is planned to be funded through sale of the General Partner’s NSP properties, which will be in Q4 2026. A short-term loan may be necessary to fund the reserves prior to sale of the properties. Repayment may be sooner pending fundraising results. No future withdrawals which are not in compliance with the County Regulatory Agreement are planned. Action Taken: Current management is currently in discussion with the County of San Diego to meet the eligibility for loan forgiveness of the NSP properties.

Categories

Matching / Level of Effort / Earmarking

Programs in Audit

ALN Program Name Expenditures
14.256 NEIGHBORHOOD STABILIZATION PROGRAM (RECOVERY ACT FUNDED) $633,119
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $472,556
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $195,459