Finding Text
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Section 223(f) Mortgage Insurance for the Purchase or Refinance of Existing Multifamily Housing Projects Assistance Listing Number: 14.155 Award Period: October 1, 2024 through September 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: HUD requires the Organization to maintain fidelity bond coverage of at least two months cash collections. Condition: The Organization’s fidelity bond was below the requirement for the period under audit. Questioned costs: None. Context: The Organization’s resident service revenue increased in the current year to an amount that is higher than historical fidelity bond coverage. Cause: Following completion of the 2025 Mark-to-Market process for HRCA Housing for Elderly Inc., we failed to update our fidelity bond coverage to reflect the revised requirements. Effect: There were no negative effects on the Organization. Repeat finding: No. Recommendation: We recommend that the Organization obtain the requisite fidelity bond coverage and to monitor the coverage to ensure it is in compliance with HUD requirements. Views of responsible officials: Once the finding was identified, we immediately contacted our insurance broker and requested an increase to the fidelity bond coverage. The bond has since been raised to a $2M limit, and the updated policy became effective on 11/14/25. Going forward, the fiscal team will incorporate an annual verification of bond coverage into its routine monitoring procedures to ensure timely updates after significant organizational or regulatory changes. In addition, we are implementing an internal audit component to enhance our review of all HUD requirements. This added oversight will help mitigate future risk and ensure continued compliance with all applicable regulations