Finding 1177785 (2021-001)

Material Weakness Repeat Finding
Requirement
P
Questioned Costs
-
Year
2021
Accepted
2026-03-10

AI Summary

  • Core Issue: The Housing Authority's loan program lacks proper oversight, allowing finance and management personnel to control loans they benefit from, leading to potential conflicts of interest.
  • Impacted Requirements: The program fails to meet standards for segregation of duties, risking inadequate loan repayment and financial accountability.
  • Recommended Follow-Up: Revise fiscal policies to enforce checks signed by a Tribal Council member and ensure independent monitoring of loan balances by the Council.

Finding Text

2021-001 Segregation of Duties – Loan Program Significant Deficiency This is a repeat finding. The prior-year’s auditing finding number is 2020-001. Condition: The Housing Authority administers a loan program, referred to internally as the HCRI loan program. The loans are administered and accounted for by finance and management level personnel that also participate in the program, without any additional oversight. Large loan balances are outstanding from finance and management level personnel individuals. Criteria: Management is responsible for administering a loan program, referred to internally as the HCRI loan program. The loans are administered and accounted for by finance and management level personnel. Individuals who benefit from the loan program should not have complete discretion over the approval of loan requests, or the recording of balances and repayments. Cause: Many of the loans go back years and the Housing Authority does not wish to write loan balances off in case tribal members request new loans. Effect: The loan program was not carried out pursuant to sound policies. Providing large balances to a few individuals increases the possibility that the Housing Authority may not receive full payment for amounts advanced. Recommendation: The Housing Authority’s fiscal policies should be revised to ensure that preventive controls are in place over check disbursements for loan disbursements, such that checks must be signed with live signatures at least the signature of one Tribal Council member. Further, individuals who benefit from the loan program should not have complete discretion over recording and processing of advances and repayment. We recommend a complete list of outstanding balances be presented to the Tribal Council, or its designee, for continued monitoring. Views of Responsible Officials: See Corrective Action Plan.

Corrective Action Plan

2021-001 Segregation of Duties – Loan Program Significant Deficiency Recommendation: The Housing Authority’s fiscal policies should be revised to ensure that preventive controls are in place over check disbursements for loan disbursements, such that checks must be signed with live signatures at least the signature of one Tribal Council member. Further, individuals who benefit from the loan program should not have complete discretion over recording and processing of advances and repayment. We recommend a complete list of outstanding balances be presented to the Tribal Council, or its designee, for continued monitoring. Action Taken: The SCCHA discontinued the Loan Program as of November 2019. A complete list of balances owed has been submitted to the Tribal Council with the outstanding balances of those whom had signatory authority forwarded to the St. Croix Tribal Court for further repayment actions.

Categories

Internal Control / Segregation of Duties Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1177772 2021-001
    Material Weakness Repeat
  • 1177773 2021-002
    Material Weakness Repeat
  • 1177774 2021-003
    Material Weakness Repeat
  • 1177775 2021-004
    Material Weakness Repeat
  • 1177776 2021-005
    Material Weakness Repeat
  • 1177777 2021-006
    Material Weakness Repeat
  • 1177778 2021-007
    Material Weakness Repeat
  • 1177779 2021-008
    Material Weakness Repeat
  • 1177780 2021-009
    Material Weakness Repeat
  • 1177781 2021-010
    Material Weakness Repeat
  • 1177782 2021-011
    Material Weakness Repeat
  • 1177783 2021-012
    Material Weakness Repeat
  • 1177784 2021-013
    Material Weakness Repeat
  • 1177786 2021-002
    Material Weakness Repeat
  • 1177787 2021-003
    Material Weakness Repeat
  • 1177788 2021-004
    Material Weakness Repeat
  • 1177789 2021-005
    Material Weakness Repeat
  • 1177790 2021-006
    Material Weakness Repeat
  • 1177791 2021-007
    Material Weakness Repeat
  • 1177792 2021-008
    Material Weakness Repeat
  • 1177793 2021-009
    Material Weakness Repeat
  • 1177794 2021-010
    Material Weakness Repeat
  • 1177795 2021-011
    Material Weakness Repeat
  • 1177796 2021-012
    Material Weakness Repeat
  • 1177797 2021-013
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.019 CORONAVIRUS RELIEF FUND $257,095
14.867 INDIAN HOUSING BLOCK GRANTS $98,880
21.023 EMERGENCY RENTAL ASSISTANCE PROGRAM $86,419