Finding 1206212 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-04-08

AI Summary

  • Core Issue: The project fund account used by the non-profit Organization is not an interest-bearing account, violating HUD regulations.
  • Impacted Requirements: 24 CFR 891.400(e) mandates that all project funds must be deposited in an interest-bearing account.
  • Recommended Follow-Up: The non-profit Organization should switch to an interest-bearing account for project funds and evaluate management's response to ensure compliance.

Finding Text

Criteria In accordance with 24 CFR 891.400(e), a separate interest-bearing project fund account shall be maintained in a depository or depositories which are members of the Federal Deposit Insurance Corporation or National Credit Union Share Insurance Fund and all tenant payments, charges, income and revenues arising from project operation or ownership shall be deposited to this account. Condition The project fund account used by the non-profit Organization was not an interest-bearing account. Cause Subsequent to the initial rental assistance contract, changes to HUD regulations resulted in the requirement that the project fund account be an interest-bearing account. This change was an oversight by the non-profit Organization’s management. Questioned Costs None noted. Context When performing our audit, we noted that the project fund account used by the non-profit Organization was not an interest-bearing account. Effect Project funds would not earn interest in accordance with HUD requirements. Repeat Finding Repeat finding of 2024-002. Recommendation We recommend that the non-profit Organization utilize an interest-bearing account for project funds in accordance with HUD requirements. Views of Responsible Official and Planned Corrective Action Management concurs with the audit finding. Although the non-profit Organization does not currently use an interest-bearing account for project funds, due to the ongoing operation of the program and continuous activity within the project funds account, any interest earned in such an account would be negligible. Management is in the process of evaluating this recommendation to determine the appropriate course of action.

Corrective Action Plan

Name of auditee: The Pavilion Housing Development Fund Corporation HUD auditee identification number: 012-EE247 Name of audit firm: WithumSmith+Brown, PC Period covered by the audit: Year Ended September 30, 2025 CAP prepared by: Name: Father Ronald Giannone Position: Executive Director Telephone: 646-996-4234 1. Current Findings on the Schedule of Findings, and Questioned Costs a. Finding 2025-001. Special Tests and Provisions – Project Funds. i. Comments on the Finding and Each Recommendation: Management concurs with the finding and the auditor’s recommendation to utilize an interest-bearing account for project funds. ii. Actions Taken on the Finding: Management is in the process of evaluating the recommendation to determine that appropriate course of action. 2. Status of Corrective Actions on Findings Reported in the Prior Audit Schedule of Findings, and Questioned Costs. Finding 2024-001 - cleared. Delinquent deposits in the aggregated amount of $18,715 were funded in 2025.

Categories

Cash Management HUD Housing Programs Internal Control / Segregation of Duties

Programs in Audit

ALN Program Name Expenditures
14.157 SUPPORTIVE HOUSING FOR THE ELDERLY $584,236