Finding 1239513 (2025-001)

Material Weakness Repeat Finding
Requirement
P
Questioned Costs
-
Year
2025
Accepted
2026-09-30

AI Summary

  • Core Issue: The Organization failed to consolidate a related entity's financial statements, violating U.S. GAAP requirements.
  • Impacted Requirements: Financial statements do not reflect the related entity's assets, liabilities, and intercompany transactions, leading to potential material misstatements.
  • Recommended Follow-Up: Management should reassess consolidation criteria and evaluate impacts on federal award reporting as outlined in the Corrective Action Plan.

Finding Text

Departure from Generally Accepted Accounting Principles – Failure to Consolidate Related Entity Category Internal Control Over Financial Statements Criteria U.S. generally accepted accounting principles (U.S. GAAP), as set forth in ASC 958-810 Not-for-Profit Entities—Consolidation, require a not-for-profit organization to evaluate its relationship with another entity and to consolidate that entity when the applicable consolidation criteria are met, including situations in which the organization has a controlling financial interest. Condition The Organization has a controlling financial interest in a legally separate entity (the “Related Entity”) through common ownership and participation. The Organization did not consolidate the financial statements of the Related Entity with its financial statements for the year ended December 31, 2025. As a result, the Organization’s financial statements do not include the assets, liabilities, net assets, revenues, expenses, and cash flows of the Related Entity, nor do they reflect the elimination of intercompany balances and transactions between the Organization and the Related Entity. Cause Management determined that the Related Entity was a legally separate organization and, based on that determination, concluded that separate financial statement presentation was appropriate. Management did not appropriately evaluate the consolidation requirements under ASC 958-810 based on the nature of the Organization’s controlling financial interest. Effect The Organization’s financial statements are not presented in accordance with U.S. GAAP because the financial statements omit the financial position, results of operations, and cash flows of the Related Entity and do not reflect the required elimination of intercompany balances and transactions. The effect of this departure from U.S. GAAP has not been determined and is not reasonably practicable to quantify. Consequently, the amounts presented in the financial statements may be materially different from the amounts that would have been reported had the Related Entity been consolidated in accordance with U.S. GAAP. Additionally, because the Organization receives and administers federal awards, management should evaluate whether the no consolidation results in any impact on amounts, activities, or disclosures relevant to federal award reporting and the applicable compliance requirements identified in the OMB Compliance Supplement. Views of Responsible Officials Management of the Organization agrees with this finding. For details of the actions to be taken, refer to the Corrective Action Plan (CAP) section in this report. Responsible Person José Carrasquillo Delgado Finance DirectoR

Corrective Action Plan

Management agrees with the recommendation and will further calibrate and clarify the financial reporting relationship between Centro para la Reconstrucción del Hábitat, Inc. (“CRH”) and Desarrollos CRH, Inc. (“Desarrollos”) under applicable accounting standards. Desarrollos was established as a separate nonprofit entity to further CRH’s affordable housing mission and undertake activities requiring or benefiting from designation as a Community Housing Development Organization (CHDO). Its separate legal and governance structure was intentionally established, in part, to satisfy applicable CHDO requirements, including community representation on its governing board. Desarrollos maintains its own corporate, accounting, and financial records.During its initial years, Desarrollos had limited financial activity while completing organizational, tax-exemption, CHDO certification, and other activities necessary to begin operations. As Desarrollos transitions into active program and development activities, the organizations will approve a more refined collaborative agreement that more clearly documents their organizational relationship, respective responsibilities, and the procedures governing financial support, transfers, and other transactions between the entities. Beginning with the current fiscal year, Desarrollos has also engaged CPAs for the preparation of its own financial statements. CRH will coordinate with its accounting professionals and independent CPAs to better clarify and appropriately reflect the relationship between the entities in CRH’s financial reporting, including consolidation and elimination of intercompany balances and transactions where required under applicable accounting standards. Management notes that the finding concerns the presentation of the financial relationship between two separately organized nonprofit entities. Desarrollos maintains separate accounting records and financial documentation, and the measures described above will provide additional clarity regarding the entities’ relationship and its presentation in future financial statements.

Categories

Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1239514 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.228 Community Development Block Grant-Disaster Recovery (CDBG-DR) $3.41M
10.446 Rural Community Development Initiative (RCDI)-Rural Business Service $91,133
66.306 Enviromental Justice Collaborative Problem-Solving Cooperative Agreement Program $77,381
14.878 HOPE VI Main Street $53,699
14.259 Community Compass Technical Assistance and Capacity Building $39,305