Finding 1225511 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-08-03
Audit: 408391
Auditor: LEAF & COLE LLP

AI Summary

  • Core Issue: Personal expenses were improperly charged to the Project, violating HUD regulations.
  • Impacted Requirements: Project funds must only cover reasonable and necessary expenses directly related to Project operations.
  • Recommended Follow-Up: Enhance review procedures, require detailed documentation for expenses, and implement formal certifications to ensure compliance.

Finding Text

Finding 2025-002 – Personal Expenses Charged To The Project Condition: During audit testing procedures, we identified personal expenses charged and expensed to the Project. Criteria: The HUD Regulatory Agreement requires that Project funds be used solely for reasonable and necessary expenses directly related to the operation and maintenance of the Project and explicitly prohibits the use of Project funds for personal or non-Project-related purposes. Cause of Condition: Controls over expense review and approval were not sufficiently designed or consistently applied to ensure that only eligible Project-related costs were charged to the Project. In addition, supporting documentation was not adequately provided or reviewed to confirm the business purpose and Project eligibility of expenses prior to payment. Potential Effect of Condition: Charging personal expenses to the Project resulted in noncompliance with the HUD Regulatory Agreement, potential repayment of ineligible costs, and increased risk of regulatory findings or enforcement actions by HUD. Recommendation: Management should strengthen expense and invoice review and approval procedures to ensure that all costs charged to the Project are reasonable, necessary, and directly related to Project operations, in accordance with the HUD Regulatory Agreement. Expense reimbursements should require detailed supporting documentation clearly demonstrating a valid Project purpose. A formal certification should be implemented as part of the approval process to attest that expenses are not personal in nature and have been approved. Internal reviews of Project expenses should be performed to identify and promptly correct any ineligible charges, including reimbursement to the Project where necessary. View of Responsible Officials and Planned Corrective Action: The individuals involved in the issues identified during the audit are no longer associated with the Project. Specifically, the former resident property manager is no longer employed by the Corporation and the composition of the Board has changed since the period under review. Management believes the identified issues resulted from a breakdown in adherence to existing approval, oversight and monitoring controls, including collusion among individuals responsible for reviewing and approving expenditures. The Project’s established policies and procedures were not properly followed. With the turnover in key personnel and Board leadership, management expects improved compliance with existing controls and oversight responsibilities. Management and the Board will continue to monitor Project expenses and ensure that expenditures are reviewed and approved in accordance with Project requirements and fiduciary responsibilities.

Corrective Action Plan

Finding 2025-002 – Personal Expenses Charged To The Project Recommendation: Management should strengthen expense and invoice review and approval procedures to ensure that all costs charged to the Project are reasonable, necessary, and directly related to Project operations, in accordance with the HUD Regulatory Agreement. Expense reimbursements should require detailed supporting documentation clearly demonstrating a valid Project purpose. A formal certification should be implemented as part of the approval process to attest that expenses are not personal in nature and have been approved. Internal reviews of Project expenses should be performed to identify and promptly correct any ineligible charges, including reimbursement to the Project where necessary. View of Responsible Officials and Planned Corrective Action: The individuals involved in the issues identified during the audit are no longer associated with the Project. Specifically, the former resident property manager is no longer employed by the Corporation and the composition of the Board has changed since the period under review. Management believes the identified issues resulted from a breakdown in adherence to existing approval, oversight and monitoring controls, including collusion among individuals responsible for reviewing and approving expenditures. The Project’s established policies and procedures were not properly followed. With the turnover in key personnel and Board leadership, management expects improved compliance with existing controls and oversight responsibilities. Management and the Board will continue to monitor Project expenses and ensure that expenditures are reviewed and approved in accordance with Project requirements and fiduciary responsibilities. Management response: Management agrees with the recommendation. Action Taken: The individuals involved in the issues identified during the audit are no longer associated with the Project. Specifically, the former resident property manager is no longer employed by the Corporation, and the composition of the Board has changed since the period under review. Management believes the identified issues resulted from a breakdown in adherence to existing approval, oversight, and monitoring controls, including collusion among individuals responsible for reviewing and approving expenditures. The Project's established policies and procedures were not properly followed. with the turnover in key personnel and Board Leadership, management expects improved compliance with existing controls and oversight responsibilities. Management and the Board will continue to monitor Project expenses and ensure that expenditures are reviewed and approved in accordance with Project requirements and fiduciary responsibilities.

Categories

Eligibility Subrecipient Monitoring Cash Management HUD Housing Programs

Other Findings in this Audit

  • 1225510 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.155 MORTGAGE INSURANCE FOR THE PURCHASE OR REFINANCING OF EXISTING MULTIFAMILY HOUSING PROJECTS $1.68M
14.195 PROJECT-BASED RENTAL ASSISTANCE (PBRA) $405,546