Finding 1228715 (2022-001)

Material Weakness Repeat Finding
Requirement
A
Questioned Costs
-
Year
2022
Accepted
2026-09-03

AI Summary

  • Core Issue: Funds were disbursed without prior approval from the City of Philadelphia, violating contract requirements.
  • Impacted Requirements: The contract mandates that all disbursements receive approval before funds are released.
  • Recommended Follow-Up: Management should enforce policies to ensure approvals are obtained before any future disbursements.

Finding Text

Section II - Financial Statement Findings No matters were reported. Section III - Federal Award Findings and Questioned Costs 2022-001 ? Activities Allowed or Unallowed and Allowable Costs / Cost Principles Information on Federal Program(s) - CDBG ? Entitlement Grants Cluster, Community Development Block Grant ? Entitlement Grants, 14.218, Philadelphia Department of Commerce, contract number 23-0489 (the ?Contract?) Criteria or Specific Requirement ? The Contract requires the Corporation to obtain approval to disburse funds from City of Philadelphia Department of Commerce prior to making the disbursement. Condition ? During our testing of activities allowed or unallowed costs, we noted the following exception: ? For one of the eight sample selections tested, the amount disbursed exceeded the amount approved by the City of Philadelphia Department of Commerce (approval for the excess disbursement was subsequently approved at a later date); Cause ? The Corporation did not follow its policy to ensure the disbursement was approved and was allowable at the time of disbursement. Effect or Potential Effect ? Funds were disbursed prior to obtaining approval by the City of Philadelphia Department of Commerce. Context ? We tested a sample of eight items totaling disbursements of $5,230,989 and identified one exception in the amount of $179,739. Disbursed funds in the amount of $3,079,739 exceeded the amount approved by the City of Philadelphia Department of Commerce in the amount of $2,900,000 by $179,739. The excess disbursement was approved subsequent to December 31, 2022. Repeat Finding - This is a new finding during the year. Recommendation - We recommend that management ensure its policies and procedures are followed on a consistent basis and that prior approval is obtained prior to disbursement of loan funds. Views of Responsible Officials ? The Mosaic/Sharswood loan was originally structured to be financed as a Line of Credit (LOC) grant-bridge financing product; however, after further consideration and through discussions between the Corporation?s lending team and the City of Philadelphia (the City), the decision was made to fund the loan with CDBG funding, in 2021. The approved CDBG loan amount, in 2021, was for $2,400,000. Subsequently, it was determined, as the project progressed, that additional funding was needed and requested, from the borrower, of the Corporation. Through discussions with the Corporation?s lending team and the City, the loan amount was increased and amended for an additional $500,000, taking the total loan amount funding to $2,900,000. As loan repayments came in on the loan during 2022, loan disbursements were being made, as well. As the project was continuing progress, again, the Corporation?s lending team met with the City in early 2023, to discuss the then current and future project funding needs requiring additional funding. Through these discussions, the City approved an additional amendment for a loan increase for an additional $2,550,625, taking the total loan amount to $4,950,625. The additional increase of $2,550,625 was to cover the funding of $179,739 disbursed in 2022, as well as any future project-related disbursements.

Corrective Action Plan

Managements Corrective Action Plan: Individual(s) Responsible for Corrective Action Plan Tysha Dixon Director, Financial Reporting (215) 496-8168 Completed March 2023 Questioned Program: ALN #14.218 Community Development Block Grants (CDBG) Finding #2022-001 – Activities Allowed or Unallowed and Allowance Costs / Cost Principles Information on Federal Program – CDBG Entitlement Grants Cluster, Community Development Block Grants – Entitlement Grants, 14.218, Philadelphia Department of Commerce, contract number 23-20489 Management’s Corrective Action Plan Management will continue to rely on its existing controls that are in place, including the ongoing communication with the City for any changes in transactions that require their approval. In the circumstances where management is pending a contract amendment from the City for loans requiring additional funding, management will determine if there are unrestricted funding sources to support the change in the approved amount of the loan until the amended contract is finalized.

Categories

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

Programs in Audit

ALN Program Name Expenditures
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $4.02M
21.024 COMMUNITY DEVELOPMENT FINANCIAL INSTITUTIONS RAPID RESPONSE PROGRAM (CDFI RRP) $1.70M
20.205 HIGHWAY PLANNING AND CONSTRUCTION $241,750
21.020 COMMUNITY DEVELOPMENT FINANCIAL INSTITUTIONS PROGRAM $199,371
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $188,654
17.258 WIOA ADULT PROGRAM $66,091