Finding 1228929 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-09-04
Audit: 410444
Organization: Comhar, Inc. and Affiliates (PA)

AI Summary

  • Core Issue: Required monthly deposits to replacement reserve funds for HUD projects were not made, violating HUD Regulatory Agreements.
  • Impacted Requirements: Each project must maintain a separate interest-bearing account and make consistent monthly deposits as outlined in HUD 9250.
  • Recommended Follow-Up: Implement processes for compliance, including an independent monthly review to ensure accurate deposits moving forward.

Finding Text

Finding 2025-001 - Replacement Reserve Deposits Assistance Listing Number: 14.157 Program Name: Supporting Housing for the Elderly (HUD) Federal Agency: U.S. Department of Housing and Urban Development Federal Award Year: July 1, 2024 – June 30, 2025 Criteria: The provision of the HUD Regulatory Agreements require the Group establish and maintain replacement reserve funds for each project in a separate interest-bearing bank account and deposit an identical amount on a monthly basis, as stated in each project’s most recent HUD 9250 which includes any changes in monthly deposits. Condition and Context: During the testing performed over the five HUD projects and related replacement reserve required monthly deposits, we noted that the required deposits for each project were not made. Effect or Potential Effect: The Group is not in compliance with HUD Regulatory Agreements. Cause: Administrative oversight on the part of the Group's management resulted in the items noted above. Questioned Costs: None Recommendations: We recommend the Group comply with their HUD Regulatory Agreements and implement appropriate processes and internal controls, including an independent monthly review, to identify the correct monthly replacement reserve amount for each project and make those deposits monthly in accordance with federal requirements. View of Responsible Officials: The Group agrees with this finding. The retroactive deposit for underpayment to the replacement reserve will be deposited and monthly deposits will be made monthly moving forward effective July 1, 2025.

Corrective Action Plan

Issue Identified: HUD regulations require that deposits into the Replacement Reserve account be made on a monthly basis. Our agency has historically made annual lump-sum deposits, which is not in compliance with HUD guidelines. Corrective Actions 1. Change in Deposit Frequency Action: Transition from an annual deposit schedule to a monthly deposit schedule in accordance with HUD requirements. Responsible Party: CFO and Accounting Manager Timeline: Effective July 1, 2025 monthly deposits will begin. Verification: Monthly entries and bank confirmations will be reviewed by Accounting. 2. Implementation of Automated Transfers Action: Establish and schedule automated monthly bank transfers to the Replacement Reserve account. Responsible Party: Accounting Manager in collaboration with Banking Institution Timeline: Setup completed by April 15, 2025. First automated transfer on July 1, 2025. Verification: Confirmation of automation setup from the bank and successful execution of first transfer. 3. Monthly Notifications to Fiscal Personnel Action: Create an automated monthly email notification system to alert key fiscal personnel of each deposit, including the amount and confirmation of receipt. Responsible Party: Budget & Reimbursement Manager Timeline: Notification system was remediated by July 1, 2025 Verification: Email log confirming monthly communications sent to fiscal team. Ongoing Monitoring and Compliance The Accounting Manager will review monthly bank statements to verify timely and accurate deposits. The Controller will incorporate verification into monthly closing procedures. Authorization and Approval

Categories

Internal Control / Segregation of Duties HUD Housing Programs

Other Findings in this Audit

  • 1228926 2025-001
    Material Weakness Repeat
  • 1228927 2025-001
    Material Weakness Repeat
  • 1228928 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.778 GRANTS TO STATES FOR MEDICAID $925,230
84.181 SPECIAL EDUCATION-GRANTS FOR INFANTS AND FAMILIES $700,000
14.235 SUPPORTIVE HOUSING PROGRAM $548,387
14.157 SUPPORTIVE HOUSING FOR THE ELDERLY $60,730
14.195 PROJECT-BASED RENTAL ASSISTANCE (PBRA) $8,604