Finding 1215371 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-05-21
Audit: 401918
Organization: Dima Vi INC (DE)

AI Summary

  • Core Issue: The organization lacks a formal compliance monitoring process, relying on informal practices and institutional knowledge.
  • Impacted Requirements: This situation violates HUD program requirements for documented policies, routine supervisory reviews, and effective internal controls.
  • Recommended Follow-Up: Management should create a formal compliance monitoring process with clear roles, regular supervisory reviews, and a compliance checklist for HUD programs.

Finding Text

Finding 2025-001: Lack of Formalized Compliance Monitoring and Documented Management Oversight Criteria: The Consolidated Audit Guide for Audits of HUD Programs and the Uniform Guidance require that entities maintain effective internal controls over compliance with applicable program requirements. This includes documented policies and procedures for monitoring compliance, routine supervisory review of compliance-related activities, and sufficient evidence that oversight is occurring. Condition: The organization has not established a formalized compliance monitoring process. We were unable to identify documented evidence of routine supervisory review of compliance-related activities. Compliance processes and monitoring remain informal and are frequently undocumented. Cause: The organization's compliance functions historically relied on the institutional knowledge and experience of long-tenured staff rather than on functioning internal controls. In recent years, the management agent has experienced significant personnel turnover, exacerbating this deficiency. Effect: Without documented compliance monitoring, errors or instances of noncompliance could occur and remain undetected. These circumstances also limit the Project’s ability to demonstrate compliance to external parties. Failure to maintain and demonstrate compliance could result in noncompliance with the Project’s HUD capital advance and housing assistance payments contract. Recommendations: Management should establish a documented compliance monitoring process, including defined roles and responsibilities, routine supervisory review with documentary evidence, and a periodic compliance checklist addressing the key requirements of the entity's major HUD programs. Views of Responsible Officials: We concur with this finding. We are working to formalize our compliance procedures and document supervisory review activities going forward.

Corrective Action Plan

A. Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations 1. Finding 2025-001: Lack of Formalized Compliance Monitoring and Documented Management Oversight a. Comments on the Finding and Each Recommendation: We acknowledge the condition identified and note that corrective actions and compliance monitoring enhancements were implemented or initiated prior to report issuance. Historically, certain compliance oversight activities relied heavily on operational knowledge and informal review procedures that were not consistently documented. Following organizational restructuring and personnel transitions, management initiated a broader effort to formalize and strengthen internal compliance monitoring, supervisory review procedures, and documentation practices across our housing portfolio. b. Action(s) Taken or Planned on the Finding: 1. Monthly Compliance and Financial Oversight Meetings: We have implemented recurring monthly oversight meetings involving executive leadership, finance, and housing management personnel to review financial reporting, reserve activity, compliance requirements, tenant-related matters, and operational performance. Meeting documentation and evidence of supervisory review are maintained as part of our compliance monitoring procedures. 2. Expanded Finance and Compliance Oversight Structure: We have strengthened our internal oversight structure through the addition of a Chief Financial Officer with expanded oversight responsibilities for the housing entities and a Director of Housing and Compliance responsible for operational and regulatory compliance oversight. Responsibilities between accounting, compliance, and operational functions have been further segregated to strengthen internal controls and management review procedures. 3. Formalized Compliance Monitoring Procedures: We have implemented standardized compliance monitoring procedures, including monthly reserve deposit tracking, supervisory review checklists, documented financial statement review procedures, reconciliation monitoring, and periodic compliance checklists addressing key HUD program requirements. 4. Ongoing Monitoring and Documentation Retention: We will continue strengthening documentation retention procedures to ensure evidence of compliance monitoring, supervisory review, and reconciliation activities is consistently maintained and available for future audits and regulatory reviews.

Categories

HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring

Other Findings in this Audit

  • 1215372 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.181 SUPPORTIVE HOUSING FOR PERSONS WITH DISABILITIES $1.38M
14.195 PROJECT-BASED RENTAL ASSISTANCE (PBRA) $58,975