Finding Text
2023 – 001: Depository Agreement
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Choice Voucher Program
Assistance Listing Number: 14.871
Award Period: January 1, 2023 to December 31, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance
Other Matter
Criteria or specific requirement: HUD regulations at 24 CFR S982.52 Section 8 Tenant Based
Assistance states, “the PHA must comply with the consolidated ACC, HUD regulations and other
requirements for the program, issued by HUD headquarters, as regulations, Federal Register notices or
other binding program directives as will as PHAs HUD-approved applications for program funding.”
24 CFR S 982.156(c) states, “the PHA must enter into an agreement with the depository in the form
required by HUD.” Additionally, Section 13, Paragraph b of form HUD-5250, the “Consolidated Annual
Contributions Contract” (ACC) requires PHAs to enter into an agreement with the depository institution,
on the form required by HUD.
Condition: The Authority has not executed a General Depository Agreement for accounts holding EHV
Service Fee funds in accordance with HUD requirements.
Questioned costs: None
Context: We reviewed the General Depository Agreement (GDA) and HUD report No. QAD-EHV-2023-
WI186 noting the Authority had a GDA in place with its financial institution, but was not updated for the
inclusion of the EHV related bank accounts.
Cause: The Authority currently maintains two (2) accounts with Nicolet Bank which hold EHV service
fee funds, a municipal checking account and a pooled funds sweep account. These accounts are not
currently covered by a GDA.
Effect: A lack of a properly executed GDA negatives affects HUDs ability to exert control over EHV
funds held by the Authority, if HUD should need to freeze those funds because of default on part of the
Authority.
Repeat Finding: No
Recommendation: We recommend that the Authority implement a process for ensuring that the GDA
is updated with the financial institution when bank accounts are created or closed.
Views of responsible officials: There is no disagreement with this finding.