Finding 505141 (2020-004)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2020
Accepted
2024-11-08
Audit: 327808
Auditor: Moss Adams LLP

AI Summary

  • Core Issue: There was a failure in segregation of duties for loan approvals and check distributions, increasing the risk of errors or fraud.
  • Impacted Requirements: This noncompliance violates Uniform Guidance Part 200.303, which mandates effective internal controls for managing federal awards.
  • Recommended Follow-Up: Implement stronger internal controls to ensure segregation of duties is maintained, reducing risks associated with loan management.

Finding Text

2020-004 Segregation of Duties (Significant Deficiency; Other Noncompliance) Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: HOME Investment Partnerships Program Assistance Listing Number: 14.239 Condition: During our testing of new loans charged to the HOME Investment Partnerships Program, we tested a sample of 4 loans out of the population of 22 new loans granted during 2020. For one loan out of our sample we identified that the same two people who approved the loan also signed the distribution check. Criteria: In accordance with Uniform Guidance Part 200.303, DBAS must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Context: Using the complete population of 22 new loans in 2020 charged to the HOME Investment Partnerships Program, we tested a sample of 4 loans. Effect: Proper segregation of duties was not followed presenting elevated risks of unauthorized or inaccurate issuance of loan proceeds. Questioned costs: None Cause: Management did not have adequate internal controls in place for proper segregation of duties.

Corrective Action Plan

Segregation of Duties Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: HOME Investment Partnerships Program Assistance Listing Number: 14.239 Name of Contact Persons: Faaeteete Sio and Ruth Matagi Corrective Action: Due to the COVID-19 pandemic, DBAS had to work a staggered schedule for the staff to include vulnerable employees who are 60+ year olds (management) to work remotely from home. Two of the signors fall under this category. DBAS will ensure and enforce proper segregation of duties will be followed. Loan approval and check signer controls will be reviewed and revised to ensure segregation of duties concerns are mitigated moving forward. Proposed Completion Date: Ongoing

Categories

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Significant Deficiency

Other Findings in this Audit

  • 505140 2020-003
    Significant Deficiency
  • 1081582 2020-003
    Significant Deficiency
  • 1081583 2020-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.239 Home Investment Partnerships Program $5.03M
11.307 Economic Adjustment Assistance $560,072
14.225 Community Development Block Grants/special Purpose Grants/insular Areas $62,800
93.569 Community Services Block Grant $20,664