We performed different audit testing to validate compliance with the Terms and Conditions that the Bank as Subrecipient shall comply with applicable Puerto Rico Department of Housing’s policies and guidelines. We noted the following instances where the amount of the award was computed incorrectly:
- We recomputed the amount of the grant awarded and noted that in one (1) case, representing 2% of the total sample, the amount of the award was computed incorrectly. The amount of over payment to the Business Applicant amounted to $308.
- In one (1) case, representing 2% of the total sample, the amount of award was computed incorrectly. The amount of over payment to the Business Applicant amounted to $3,283.
We noted the following instances where documents were missing in the Grant Management System of Record for the Grants (Canopy) or the document had missing information.
- For the grants awarded for equipment, we reviewed the supporting documentation for required quotes and noted that in fourteen (14) cases, or 23%, the quotes provided by the Business Applicants did not have a date.
- For three (3) cases, representing 5% of total sample, the grant award agreement in the documents presented in Canopy was not dully signed. Total awarded grants to these business applicants amounted to $150,000. As a result of our observation, management uploaded to Canopy the signed grant award agreements.
- For one (1) case, representing 3% of total sample, the grant award agreement was not located on file. The document was found in the grant award extension file.
- For two (2) cases, representing 6% of the total sample, certain documentation related to the benefits received was not located in the file. Documents were found in the grant award extension file.
We noted two duplicated grant disbursements made by the Bank as follows:
- On June 14, 2023, the Bank identified a duplicated grant disbursement made for $50,000 to one Business Applicant. The grant was disbursed by the Bank two times, on July 15, 2021 and July 20, 2021. The expenditure reimbursement by PRDOH was not duplicated since the funds were properly billed to PRDOH. The Bank, once the incident was identified, made the necessary arrangements and was able to recover the duplicated amount completely.
- On June 26, 2023, the Bank identified a duplicated grant disbursement for $49,271 made to two different bank accounts. Due to an inadvertent error when processing the disbursement on June 28, 2020, the grant was disbursed to an incorrect account and then was later disbursed to the correct bank account. The investigation of the first disbursement was not completed by the Bank at the time of processing the second disbursement for the grant. The expenditure of the grant reimbursed by the PRDOH was not duplicated since the funds were billed properly to PRDOH. The Bank has not been able to recover the duplicated amount completely.
We noted several instances where the information in the Grant Management System of Record was inaccurate. The situations noted were as follows:
• While reviewing the report provided for closeout procedures, we noted differences in four (4) cases for the grant amount as per the grant award agreement and the amount included in the closeout report. The differences amounted to $112,390 and were due to cases with a grant award extension application where the Grant Management System of Record replaced the first award information with the second award.
• As a result of our closeout procedures testing, we noted the following situations:
- For twelve (12) cases, representing 20% of total sample, we could not validate the eligibility review start date. The data disclosed in this field on the first application was the date of the grant award extension.
- In one (1) case, representing 2% of total sample, we could not obtain certain information from the Award Coordination Section in the Grant Management System of Record in relation to the application evaluated (first application) due to system problem that replaced information with the data for the extension award application for additional funds.
- For five (5) cases, representing 8% of total sample, the approved grant amount as per Grant Management System of Record, does not agree with the amount disclosed in the corresponding grant award agreement nor in the grant award report provided for audit purposes due to replacement of data with information for extension award application.
- In one (1) case, representing 2% of total sample, the approved grant amount as per the Grant Award Agreement does not agree with the amount in the Grant Award Report provided for audit purposes due to replacement of information with second award application in extension for additional funds. B4
- For five cases (5), representing 16% of the total sample, we could not validate the Duplication of Benefits (DOB) status updated date. The data disclosed in this field on the first application was from the grant award extension and not for the grant being evaluated.
- For two cases (2), representing 6% of the total sample, some data from the DOB Section in the Grant Management System of Record was not related to the first application. The data disclosed on the first application was from the grant award extension.
- For one case (1), representing 3% of the total sample, the approved grant amount as per Grant Management System of Record did not agree with the amount disclosed in the corresponding Grant Award Agreement nor in the Closeout Report provided for audit purposes. The information in the Grant Management System of Record reflected data from the grant award extension instead of data related to the first application.