Finding 1229416 (2025-002)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2025
Accepted
2026-09-10
Audit: 410807
Organization: Kor Community Land Trust (OR)

AI Summary

  • Core Issue: There was a significant misuse of funds in the Self-Help Homeownership Opportunity Program, with money allocated for construction instead used for down payment assistance.
  • Impacted Requirements: The organization failed to comply with federal guidelines requiring a separate bank account for program funds and proper understanding of allowable costs.
  • Recommended Follow-Up: Establish regular communication with funders to clarify funding purposes and implement stronger internal controls to ensure compliance with grant requirements.

Finding Text

Finding 2025-002 – Material Weakness in Internal Controls Over Allowable Costs and Non- Compliance Identification of Federal Program: AL Number: 14.247 Self-Help Homeownership Opportunity Program (SHOP) Condition – A material amount of funding for the program was initially used for an unallowable activity. Funding for construction was used for down payment assistance. It was also noted that the program requires a separate bank account for the funds, yet the funds were not segregated. Criteria – Per Subpart E, Cost Principles, 2 CFR section 200, it is the grantee’s responsibility to understand the purpose of funding received, and other program requirements. Context and Cause – The Organization experienced turnover at the executive level. Management did not communicate with the funder in order to gain an understanding of allowable costs, and other program requirements. The organization subsequently met with the funder and re-submitted allowable invoices for the federal funding. Effect of Condition – The Organization was out of compliance until the costs were re-allocated. The Organization will need to open a separate account for the SHOP funds. Questioned Cost – None. Recommendation – The Organization should communicate with funders in order to understand the purpose of the funding and other program requirements, and develop an internal control system that ensures only allowable costs are charged to the grants. Views of Responsible Officials and Planned Corrective Actions – Management concurs with the finding and has developed a corrective action plan. We understand a material weakness is identified in the internal controls over allowable costs. Management will implement a procedure to ensure more frequent contact with funding sources regarding the purpose of funding and other program requirements.

Corrective Action Plan

2025-002 Finding – Material Weakness in Internal Controls over Allowable Costs and Non-Compliance Responsible official: Patti Lawrence, Accounting Manager Context and Cause: A material amount of funding for the program was initially used for an unallowable activity. Funding for construction was used for down payment assistance. It was also noted that the program requires a separate bank account for the funds, yet the funds were not segregated. The organization experienced turnover at the executive level. Management did not communicate with the funder in order to gain an understanding of allowable costs, and other program requirements. The organization subsequently met with the funder and re-submitted allowable invoices for the federal funding. The organization experienced turnover in executive management during the year, and organizational knowledge of the funding purpose was lost in that transition. Recommendation: It was recommended the Organization should communicate with funders in order to understand the purpose of the funding and other program requirements, and develop an internal control system that ensures only allowable costs are charged to the grants. Corrective Action Planned: The Organization has engaged a CPA firm as a 3rd party CFO service and accounting department. The firm has experience in single audits, and ensure funding is utilized per the terms of the grant. Implementation date: October 31, 2026

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1229409 2025-003
    Material Weakness Repeat
  • 1229410 2025-003
    Material Weakness Repeat
  • 1229411 2025-003
    Material Weakness Repeat
  • 1229412 2025-003
    Material Weakness Repeat
  • 1229413 2025-003
    Material Weakness Repeat
  • 1229414 2025-003
    Material Weakness Repeat
  • 1229415 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.247 SELF-HELP HOMEOWNERSHIP OPPORTUNITY PROGRAM $500,000
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $28,424