Finding Text
Finding 2025-004: Material Weakness, Material Noncompliance - Special Tests and Provisions, Cash Receipts Repeat Finding: 2024-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Section 232 Mortgage Insurance for Nursing Homes and Section 241(a) Supplemental Loan Insurance Multifamily Rental Housing Assistance Listing Number: 14.129 and 14.151 Award Period: January 1, 2025 through December 31, 2025 Criteria or Specific Requirement: HUD regulations and the applicable HUD Regulatory Agreement require that project cash balances in excess of federally insured limits be maintained in financial institutions that meet minimum Government National Mortgage Association (GNMA) rating requirements in order to safeguard project funds. Condition/Context: The Organization maintained cash balances in excess of federally insured limits in financial institutions that did not meet HUD's minimum GNMA rating requirements. Questioned Costs: $698,600 in bank balances exceed the federally insured limits as of December 31, 2025. Cause: Management did not fully consider HUD-specific custodial requirements when selecting financial institutions and did not implement controls to monitor compliance with GNMA eligibility requirements for depository institutions. Effect: Although no loss of project funds was identified during the audit, maintaining uninsured cash balances in nonqualified financial institutions increases the risk of loss of project funds and reduces HUD's assurance that project assets are adequately safeguarded in accordance with program requirements. Recommendation: The Organization should transfer excess cash balances to financial institutions that meet HUD's GNMA rating requirements or otherwise structure its cash holdings to ensure compliance with federal insurance limits and HUD custodial requirements. Views of Responsible Officials: Nevins moved to this financial institution with the first HUD loan in 2015. This is a local bank that actively supports Nevin's mission in the community. Given Nevins’ current financial struggles, the balance in the bank seldom exceeds the $250,000 threshold. In addition, the receiver established its own account with East West Bank and was in the process of fully transitioning the operating account to East West Bank at the end of the fiscal year.