Finding 512616 (2024-003)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2024-12-02
Audit: 330424
Auditor: Tanner LLC

AI Summary

  • Core Issue: The Organization did not consistently review homeowners' income support, despite having policies in place.
  • Impacted Requirements: This oversight could lead to future noncompliance with HAF guidelines, risking funding denial.
  • Recommended Follow-Up: Implement stricter review procedures and provide training to ensure accurate eligibility assessments and regular file reviews.

Finding Text

Program Name: 21.026 Homeowners Assistance Fund Criteria: The Organization is expected to establish and adhere to reasonable policies and procedures for evaluating homeowners’ applications in accordance with the Homeowners Assistance Fund (HAF) Guidance which permits HAF participants to reasonably rely on self‐attestation. Specifically related to income determination requirements, the Organization allows the homeowner to provide a written attestation as to household income together with supporting documentation such as paystubs, W‐2’s or other wage statements, IRS Forms 1099, tax filings, depository institution statements demonstrating regular income, or an attestation from an employer. Condition: The Organization had two instances in a sample size of 40 where appropriate review of homeowner’s income had not taken place. In both instances, the applicants’ income support was materially accurate and still met required eligibility and, therefore, were in compliance. Cause of Condition: The Organization failed to properly review and summarize income support provided by applicants. Potential Effect of Condition: Although the condition above did not result in noncompliance, if the cause of condition were to reoccur, noncompliance could occur and, ultimately, the HAF funding could get denied. Recommendation: The Organization should establish policies and procedures to carefully review income support and consider whether the individual meets eligibility requirements. Views of Responsible Officials: Management has acknowledged the finding and management will provide updated training to underwriters and processors to accurately fill out eligibility checklists and confirm that support matches. Additionally, the Program Manager will select and review files monthly and the Financial Services Director will review files on a quarterly basis.

Corrective Action Plan

CDCU’s UHAF Program Manager, Eleni Alatini, will update current checklists to explicitly state that Processors and Underwriters should confirm that all support matches intake allocation sheets. CDCU’s Financial Services Director, Brayan Nava and CEO, Todd Reeder, will approve the updated checklists. The UHAF Program Manager, Eleni Alatini, will conduct a training for all Processors and Underwriters to ensure they understand the process and will confirm with Brayan Nava and Todd Reeder once the training is complete. CDCU’s UHAF Program Manager, Eleni Alatini, will select 10% of approved files for internal monitoring every month to ensure Processors and Underwriters are following Processing and Underwriting checklists and verify income matches between allocation sheet and support. CDCU’s Financial Services Director, Brayan Nava, will review the files on a quarterly basis as well.

Categories

Eligibility

Other Findings in this Audit

  • 512614 2024-001
    Significant Deficiency Repeat
  • 512615 2024-002
    Significant Deficiency Repeat
  • 1089056 2024-001
    Significant Deficiency Repeat
  • 1089057 2024-002
    Significant Deficiency Repeat
  • 1089058 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.026 Homeowner Assistance Fund $32.44M
21.027 Coronavirus State and Local Fiscal Recovery Funds $800,000
14.239 Home Investment Partnerships Program $210,000
14.218 Community Development Block Grants/entitlement Grants $13,046