Finding 1170237 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-01-22
Audit: 383306
Organization: Juliette Corporation (MA)
Auditor: COHNREZNICK LLP

AI Summary

  • Core Issue: Replacement reserves were not deposited on time, violating HUD regulatory agreements.
  • Impacted Requirements: Monthly deposits totaling $111,585 were delayed, affecting compliance for multiple projects.
  • Recommended Follow-Up: Management should review and strengthen internal controls to ensure timely deposits moving forward.

Finding Text

Finding No. 2025-002 - Material Weakness - Mortgage/Reserves: Replacement reserves not deposited timely Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Project-Based Rental Assistance Assistance Listing Number: 14.195 Criteria In accordance with the HUD regulatory agreements, Projects are required to make monthly deposits to its replacement reserves. Condition During the year ended June 30, 2025, the Projects were delinquent in making the required monthly deposits to the replacement reserve. BC HUD I required deposits for the period July 2024 through February 2025 in the amount of $60,928 were funded in February 2025. BC HUD II required monthly deposits for the period July through September 2024 in the amount of $7,278 were funded in February 2025, for the period October through December 2024 in the amount of $7,416 were funded in March 2025, and for the period January through April 2025 in the amount of $9,888 were funded in April 2025. BC HUD III required monthly deposits for the period July 2024 through May 2025 in the amount of $26,015 were funded In May 2025. Cause Management's internal controls over monitoring of the replacement reserves did not function consistently throughout the year ended June 30, 2025. Effect or Potential Effect Failure to deposit the replacement reserve timely resulted in a violation of the regulatory agreements. Questioned Costs Not applicable. Context N/A Identification as a Repeat Finding This is a repeat finding from 2024. Recommendation Management should establish or undertake a review of internal controls over monitoring of the replacement reserve deposits to ensure deposits are timely made as required. Views of Responsible Officials Management acknowledges that certain internal controls did not operate effectively during year ended June 30, 2025. This is attributed to an unusually high level of staff turnover within the finance team during the year. We have since supplemented our team with new senior leadership and experienced resources to ensure the replacement reserve is properly funded.

Corrective Action Plan

Finding 2025-002 - replacement reserves not deposited timely a. Issue: During the year ended June 30, 2025, the Projects were delinquent in making the required monthly deposits to the replacement reserve. BC HUD I required deposits for the period July 2024 through February 2025 in the amount of $60,928 were funded in February 2025. BC HUD II required monthly deposits for the period July through September 2024 in the amount of $7,278 were funded in February 2025, for the period October through December 2024 in the amount of $7,416 were funded in March 2025, and for the period January through April 2025 in the amount of $9,888 were funded in April 2025. BC HUD Ill required monthly deposits for the period July 2024 through May 2025 in the amount of $26,015 were funded In May 2025. b. Recommendation: Management should establish or undertake a review of internal controls over monitoring of the replacement reserve requirements to ensure deposits are made as required. c. Action taken: A tracking spreadsheet is now being used which lists the monthly amounts required to be transferred to the reserves and has a column for staff to input the date that the transfers were made. This spreadsheet is now reviewed on a weekly basis by both the Senior Cash Management Accountant and the Assistant Controller as part of the weekly check run to ensure that the monthly transfers to the reserves are made early in the month prior to paying other liabilities.

Categories

Subrecipient Monitoring HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1170236 2025-001
    Material Weakness Repeat
  • 1170238 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.195 PROJECT-BASED RENTAL ASSISTANCE (PBRA) $842,673
14.157 SUPPORTIVE HOUSING FOR THE ELDERLY $7,731