Finding Text
2025-006 ALN 14.850 – Public Housing Operating Fund – Special Tests and Provisions – Depository Agreements Condition and Criteria: Per HUD regulations and the Annual Contributions Contract (ACC), PHAs must execute and maintain a fully executed HUD Form 51999 with each depository in which federal funds are held. This agreement outlines the responsibilities of the financial institution and ensures that federal funds are protected in accordance with HUD requirements. During our testing of special tests and provisions related to depository agreements for the Public Housing program, the Authority was unable to provide documentation of an executed HUD Form 51999 – General Depository Agreement – for its financial institutions during the audit period. This form is required to be on file to ensure compliance with HUD regulations governing the custody and handling of federal funds. Amount of Questioned Costs: None. Context: The HUD Form 51999 – General Depository Agreement that was in place during the audit period was unable to be provided. Cause: The absence of an executed agreement appears to be due to a lapse in internal control and recordkeeping procedures related to required HUD documentation. This was the result of prior management's record keeping and current management being unable to locate documentation that was maintained by the prior management. Effect or Potential Effect: Without a properly executed HUD Form 51999, there is an increased risk that federal funds are not adequately protected or handled in accordance with HUD regulations. It also represents noncompliance with special tests and provisions requirements under the PH program. Auditor’s Recommendation: We recommend that the Authority strengthen its internal controls to ensure all required HUD depository agreements are fully executed and maintained on file for all institutions holding program funds. A periodic compliance review should be conducted to confirm all depository agreements are current and properly executed. Grantee Response: Management acknowledges the finding and will follow the auditor’s recommendation.