Finding 393355 (2023-007)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-04-16

AI Summary

  • Core Issue: The Authority lacks a depository agreement with HUD, failing to safeguard federal funds as required.
  • Impacted Requirements: Non-compliance with depository agreement requirements, specifically the need for funds to be in an interest-bearing account.
  • Recommended Follow-Up: Establish a separate interest-bearing account and execute a depository agreement, or seek a waiver if local regulations prevent compliance.

Finding Text

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Numbers: 14.871/14.879 Federal Award Identification Number and Year: SC911VO - 2023 Award Period: July 1, 2022 – June 30, 2023 Compliance Requirement: Special Tests and Provisions – Depository Agreement Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: Authorities are required to enter into depository agreements with their financial institutions in the form required by the U.S. Department of Housing and Urban Development (HUD). The agreements serve as safeguards for federal funds and provide third party rights to HUD. Among the terms in many agreements are requirements for funds to be placed in an interest-bearing account (24 CFR section 982.156). Condition: The Authority does not have a depository agreement in place with HUD. Housing Voucher Cluster funds are not deposited in a separate interest-bearing account. Questioned costs: Unable to determine. Context: A depository agreement has not been executed. Cause: The Authority’s Housing Voucher Cluster funds are not deposited in a separate interest-bearing account. Effect: The Authority is not in compliance with depository agreement requirements. Repeat Finding: Yes, see finding 2022-003. Recommendation: We recommend that the Authority sets up a separate interest-bearing account and executes a depository agreement with their financial institution and HUD; alternatively, we recommend that the Authority obtains a waiver from this requirement if local regulation prohibits the Authority from following 24 CFR section 982.156. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Housing Voucher Cluster – Assistance Listing Numbers 14.871/14.879 Recommendation: We recommend that the Authority sets up a separate interest-bearing account and executes a depository agreement with their financial institution and HUD; alternatively, we recommend that the Authority obtains a waiver from this requirement if local regulation prohibits the Authority from following 24 CFR section 982.156. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Housing Voucher Cluster funds are held by the Treasurer for the State of South Carolina. The depository agreements in place are between the depository institution and the state Treasurer. SC Housing submitted a waiver request to the local HUD field office on March 29, 2023. We followed up on the request most recently on January 24, 2024 and to date, no response has been received. In the meantime, SC Housing is continuing to work with the State Treasurer’s Office to identify a solution that would allow SC Housing to enter into a general depository agreement (GDA) that would provide third party rights to HUD. Modifications have been made to the state financial accounting sytems to track the funds in question separately, but we are trying to determine how, and even if, the funds can be housed in a separate bank account, while still adhering to state regulation. Name(s) of the contact person(s) responsible for corrective action: Ellen Eudy, Deputy Director, Financial Operations and Lisa Wilkerson, Director of Rental Assistance and Compliance Planned completion date for corrective action plan: Waiver request submitted to HUD local field office on March 29, 2023. Alternative solution is in discussion with State Treasurer’s Office .

Categories

Special Tests & Provisions HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 393344 2023-002
    Material Weakness Repeat
  • 393345 2023-002
    Material Weakness Repeat
  • 393346 2023-002
    Material Weakness Repeat
  • 393347 2023-003
    Material Weakness Repeat
  • 393348 2023-003
    Material Weakness Repeat
  • 393349 2023-003
    Material Weakness Repeat
  • 393350 2023-004
    Material Weakness Repeat
  • 393351 2023-004
    Material Weakness Repeat
  • 393352 2023-004
    Material Weakness Repeat
  • 393353 2023-005
    Material Weakness Repeat
  • 393354 2023-006
    Material Weakness
  • 393356 2023-007
    Significant Deficiency Repeat
  • 393357 2023-007
    Significant Deficiency Repeat
  • 393358 2023-008
    Significant Deficiency
  • 393359 2023-008
    Significant Deficiency
  • 393360 2023-008
    Significant Deficiency
  • 393361 2023-009
    Significant Deficiency
  • 393362 2023-009
    Significant Deficiency
  • 393363 2023-009
    Significant Deficiency
  • 393364 2023-010
    Significant Deficiency
  • 393365 2023-010
    Significant Deficiency
  • 393366 2023-010
    Significant Deficiency
  • 969786 2023-002
    Material Weakness Repeat
  • 969787 2023-002
    Material Weakness Repeat
  • 969788 2023-002
    Material Weakness Repeat
  • 969789 2023-003
    Material Weakness Repeat
  • 969790 2023-003
    Material Weakness Repeat
  • 969791 2023-003
    Material Weakness Repeat
  • 969792 2023-004
    Material Weakness Repeat
  • 969793 2023-004
    Material Weakness Repeat
  • 969794 2023-004
    Material Weakness Repeat
  • 969795 2023-005
    Material Weakness Repeat
  • 969796 2023-006
    Material Weakness
  • 969797 2023-007
    Significant Deficiency Repeat
  • 969798 2023-007
    Significant Deficiency Repeat
  • 969799 2023-007
    Significant Deficiency Repeat
  • 969800 2023-008
    Significant Deficiency
  • 969801 2023-008
    Significant Deficiency
  • 969802 2023-008
    Significant Deficiency
  • 969803 2023-009
    Significant Deficiency
  • 969804 2023-009
    Significant Deficiency
  • 969805 2023-009
    Significant Deficiency
  • 969806 2023-010
    Significant Deficiency
  • 969807 2023-010
    Significant Deficiency
  • 969808 2023-010
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.023 Emergency Rental Assistance Program $179.83M
14.195 Section 8 Housing Assistance Payments Program $158.19M
21.026 Homeowner Assistance Fund $122.54M
14.275 Housing Trust Fund $6.62M
14.239 Home Investment Partnerships Program $4.63M
14.871 Section 8 Housing Choice Vouchers $2.26M
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $961,767
14.879 Mainstream Vouchers $285,184