Finding 1223502 (2025-009)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-07-09

AI Summary

  • Core Issue: The HOME Program lacks an approved policy for underwriting standards, which is required by federal regulations.
  • Impacted Requirements: Noncompliance with 24 CFR 92.254(g) regarding homebuyer program policies, including underwriting standards and responsible lending.
  • Recommended Follow-Up: GHURA should develop and implement a compliant written policy to address the identified deficiencies.

Finding Text

Finding No.: 2025-009 Identification of the federal program: Federal Agency: U.S. Department of Housing and Urban Development (HUD) AL Program: 14.239 HOME Investment Partnerships (HOME) Program Federal Award No.: M17ST660202, M18ST660202 Area: Special Tests and Provisions – Underwriting Criteria or specific requirement (including statutory, regulatory or other citation): 24 CFR 92.254(g) states: Homebuyer program policies. The participating jurisdiction must have and follow written policies for: (1) Underwriting standards for homeownership assistance to determine the amount of assistance necessary to achieve sustainable homeownership. These standards must evaluate the projected overall debt of the family after the purchase of the housing, the maximum amount that a participating jurisdiction may provide a family, the appropriateness of the amount of assistance, assets available to a family to acquire the housing, and financial resources to sustain homeownership. A participating jurisdiction may not provide a single, fixed amount of assistance to each homebuyer that participates in the participating jurisdiction's homebuyer program; (2) Responsible lending, and (3) Refinancing loans to which HOME loans are subordinated to require that the terms of the new loan are reasonable. Condition: The HOME Program did not have an approved policy effective in FY2025. Cause: The condition was primarily due to delays in the formal review, update, and approval of the HOME Program policies to align with applicable federal requirements under 24 CFR 92.254(g). Finding No.: 2025-009, continued Effect or potential effect: GHURA is in noncompliance with applicable special test and provisions requirements. Questioned Costs: $0. No questioned cost is presented as this non-compliance pertains to a lack of policy. Identification as a repeat finding: Not applicable. Recommendation: GHURA should implement a written policy in compliance with the requirements of 24 CFR 92.254(g). Views of Responsible Officials: Management disagrees with the finding. Refer to Management’s position as outlined in the Corrective Action Plan. Conclusion: Management submitted additional information on June 28, 2026; however, due to time constraints, we were unable to sufficiently corroborate and evaluate the documentation provided. Accordingly, the finding remains, as there was insufficient evidence to support a determination of compliance as of the audit date.

Corrective Action Plan

Finding #2025-009 14.239 HOME Investment Partnerships (HOME) Program Special Tests and Provisions – Underwriting Views of Responsible Officials and Planned Corrective Action Management’s Position: Management respectfully disagrees with the finding of no approved policy effective FY2025. An approved policy addressing this requirement is in place and was submitted as requested on March 9, 2026. Explanation of Disagreement: The HOME Program has an approved and effective policy that documents underwriting standards used to determine the appropriate amount of homeownership assistance based on a household’s debt, assets, and overall financial resources. Corrective Actions: GHURA Community Development Division continues to working closely with HUD to ensure program compliance and alignment with federal requirements, and is currently in the process of updating and amending its policies to reflect current market conditions and strengthen long-term program sustainability. Responsible Party: Jo Lyn Terlaje, Community Development Manager Anticipated Date of Completion: Ongoing effort and as training is made available

Categories

Special Tests & Provisions Procurement, Suspension & Debarment HUD Housing Programs Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1223495 2025-002
    Material Weakness Repeat
  • 1223496 2025-003
    Material Weakness Repeat
  • 1223497 2025-004
    Material Weakness Repeat
  • 1223498 2025-005
    Material Weakness Repeat
  • 1223499 2025-006
    Material Weakness Repeat
  • 1223500 2025-007
    Material Weakness Repeat
  • 1223501 2025-008
    Material Weakness Repeat
  • 1223503 2025-010
    Material Weakness Repeat
  • 1223504 2025-011
    Material Weakness Repeat
  • 1223505 2025-012
    Material Weakness Repeat
  • 1223506 2025-013
    Material Weakness Repeat
  • 1223507 2025-014
    Material Weakness Repeat
  • 1223508 2025-015
    Material Weakness Repeat
  • 1223509 2025-016
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $51.89M
14.248 COMMUNITY DEVELOPMENT BLOCK GRANTS SECTION 108 LOAN GUARANTEES $11.31M
14.850 PUBLIC HOUSING OPERATING FUND $7.24M
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $5.62M
14.872 PUBLIC HOUSING CAPITAL FUND $4.19M
14.U01 EMERGENCY HOUSING VOUCHER $1.55M
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $1.14M
14.267 CONTINUUM OF CARE PROGRAM $1.05M
14.157 SUPPORTIVE HOUSING FOR THE ELDERLY $623,030
14.879 MAINSTREAM VOUCHERS $479,687
14.225 COMMUNITY DEVELOPMENT BLOCK GRANTS/SPECIAL PURPOSE GRANTS/INSULAR AREAS $429,662
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $245,283
14.896 FAMILY SELF-SUFFICIENCY PROGRAM $180,272
14.870 RESIDENT OPPORTUNITY AND SUPPORTIVE SERVICES - SERVICE COORDINATORS $79,730
14.191 MULTIFAMILY HOUSING SERVICE COORDINATORS $68,838
14.275 HOUSING TRUST FUND $33,902
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $16,106