Finding 1240414 (2025-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-10-13

AI Summary

  • Core Issue: The Project's replacement reserve balance of $544,946 was not fully insured, with $294,946 exceeding the $250,000 federal deposit insurance limit.
  • Impacted Requirements: This situation violates 24 CFR Section 891.605(d), which mandates that replacement reserve funds be fully insured.
  • Recommended Follow-Up: Implement monitoring procedures to ensure compliance, such as using multiple federally insured accounts or HUD-approved arrangements for full insurance coverage.

Finding Text

Criteria: Per 24 CFR Section 891.605(d), replacement reserve funds must be deposited with HUD or in a Federally-insured depository whose balances are fully insured at all times. Condition: At June 30, 2025, the Project’s replacement reserve balance totaled $544,946 and was held in a single account at one financial institution. Accordingly, $294,946 exceeded the applicable $250,000 federal deposit insurance limit and was not fully insured. Cause: Project management did not have procedures in place to monitor the replacement reserve balance and ensure the amounts held at a single financial institution remained within federal deposit insurance limits. Effect: The Project did not comply with the replacement reserve requirements of 24 CFR Section 891.605(d). In addition, the uninsured balance of $294,946 was exposed to potential loss in the event the financial institution was to fail. Identification as a Repeat Finding, if applicable: Not applicable. Recommendation: Project management should implement procedures to periodically monitor the replacement reserve balance to ensure funds remain fully insured at all times. This may include maintaining the funds in accounts at multiple federal insured financial institutions or using another HUD-approved arrangement that provides full insurance coverage.

Corrective Action Plan

We have instructed Hawaii Affordable Properties to withdraw $300,000 from the replacement reserve account and purchase two $150,000 6 month certificate of deposits, which are to be rolled over every six months until the funds are needed.

Categories

HUD Housing Programs

Other Findings in this Audit

  • 1240412 2025-001
    Material Weakness Repeat
  • 1240413 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $1.71M
14.157 SUPPORTIVE HOUSING FOR THE ELDERLY $222,894