Finding 45206 (2022-002)

Significant Deficiency Repeat Finding
Requirement
P
Questioned Costs
-
Year
2022
Accepted
2023-04-03
Audit: 47385
Organization: Good Shepherd Housing (OH)
Auditor: Hw&co

AI Summary

  • Core Issue: Replacement reserve funds were improperly invested in mutual funds instead of guaranteed U.S. obligations, violating regulatory agreements.
  • Impacted Requirements: The investment strategy exposes funds to market and credit risks, which could lead to financial instability.
  • Recommended Follow-Up: Management should realign investments to comply with regulations and ensure funds are only in U.S. guaranteed obligations.

Finding Text

Reference Number: 2022-002 (S3800-010) Title and CFDA Number of Federal Program: Supportive Housing for the Elderly, Assistance Listing Number 14.157 (S3800-011) Type of Finding: Federal Award Finding (S3800-015) Finding Resolution Status: Unresolved (S3800-016) Information on Universe Population Size: Not applicable (S3800-017) Sample Size Information: Not applicable (S3800-018) Identification of Repeat Finding Reference Number: 2021-002 (S3800-019) Criteria: In accordance with the regulatory agreement, replacement reserve funds whether (S3800-020) in the form of a cash deposit or invested in obligations of, or fully guaranteed as to principal by, the United States of America. Statement of Condition: Replacement reserve funds were invested in obligations other than in (S3800-030) accordance with the regulatory agreement. Cause: Management invested a portion of the replacement reserve funds in mutual (S3800-032) funds in an effort to generate higher investment income. Effect or Potential Effect: The effect of this deficiency, which cannot be quantified, is that replacement (S3800-033) reserve funds invested in mutual funds are exposed to various risks such as market and credit risks. Auditor Noncompliance Code: O-Investment for Reserves for Replacements (S3800-035) Questioned Cost: $0 (S3800-040) Reporting Views of Responsible Officials: See management?s response (S3800-150) (S3800-045) ?FHA/Contract Number: 042EE171 (3800-037) ?Questioned Costs: $0 (3800-038) Context: Replacement reserve funds should be deposited in accordance with the (S3800-050) regulatory agreement. Recommendation: We recommend that management invest replacement reserve in obligations (S3800-080) of, or fully guaranteed as to principal by, the United States of America. Auditor?s Summary of the Auditee?s Comments on the Finding and Recommendation: (S3800-090) Management is aware of such market and credit risks and, therefore the Project Sponsor (Good Shepherd Home) is committed to reimburse the Project for any net cumulative realized investment losses that the Project may incur. ?Response Indicator: Disagree (3800-130) Response: (S3800-1500) Management is aware of such market and credit risks and, therefore the Project Sponsor (Good Shepherd Home) is committed to reimburse the Project for any net cumulative realized investment losses that the Project may incur. There is a cumulative net gain through December 31, 2022. Contact Person: Christopher P. Widman (S3800-160 to 180)

Corrective Action Plan

CORRECTIVE ACTION PLAN March 29, 2023 U.S. Department of Housing and Urban Development Good Shepherd Housing Corporation respectively submits the following corrective action plan for the year ended December 31, 2022. Name and address of independent public accounting firm: HW&Co. 23240 Chagrin Blvd., Suite 700 Cleveland, OH 44122-5450 Audit period: January 1, 2022 through December 31, 2022 The finding from the December 31, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDIT 2022-002 ? Replacement reserve Recommendation: In accordance with the regulatory agreement, replacement reserve funds whether in the form of a cash deposit or invested in obligations of, or fully guaranteed as to principal by, the United States of America. It was recommended that management invest replacement reserve in obligations of, or fully guaranteed as to principal by, the United States of America. Action Taken: Management is aware of such market and credit risks and, therefore the Project Sponsor (Good Shepherd Home) is committed to reimburse the Project for any net cumulative realized investment losses that the Project incurs. There is a cumulative net gain through December 31, 2022. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Chris Widman at 419-937-1801. Sincerely yours, Chris Widman, Executive Director

Categories

Reporting

Other Findings in this Audit

  • 45207 2022-002
    Significant Deficiency Repeat
  • 621648 2022-002
    Significant Deficiency Repeat
  • 621649 2022-002
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
14.157 Supportive Housing for the Elderly $105,213