Finding 519700 (2024-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-01-17

AI Summary

  • Core Issue: The project fund account is not interest-bearing, violating HUD regulations.
  • Impacted Requirements: 24 CFR 891.400(e) mandates that all project funds must be in an interest-bearing account.
  • Recommended Follow-Up: The non-profit should switch to an interest-bearing account and evaluate compliance with HUD requirements.

Finding Text

Criteria In accordance with 24 CFR 891.400(e), a separate interest-bearing project fund account shall be maintained in a depository or depositories which are members of the Federal Deposit Insurance Corporation or National Credit Union Share Insurance Fund and all tenant payments, charges, income and revenues arising from project operation or ownership shall be deposited to this account. Condition The project fund account used by the non-profit Organization was not an interest-bearing account. Cause Subsequent to the initial rental assistance contract, changes to HUD regulations resulted in the requirement that the project fund account be an interest-bearing account. This change was an oversight by the non-profit Organization’s management. Questioned Costs None noted. Context When performing our audit, we noted that the project fund account used by the non-profit Organization was not an interest-bearing account. Effect Project funds would not earn interest in accordance with HUD requirements. Recommendation We recommend that the non-profit Organization utilize an interest-bearing account for project funds in accordance with HUD requirements. Views of Responsible Official and Planned Corrective Action Management concurs with the audit finding. Although the non-profit Organization does not currently use an interest-bearing account for project funds, due to the ongoing operation of the program and continuous activity within the project funds account, any interest earned in such an account would be negligible. Management is in the process of evaluating this recommendation to determine the appropriate course of action.

Corrective Action Plan

Name of auditee: The Pavilion Housing Development Fund Corporation HUD auditee identification number: 012-EE247 Name of audit firm: WithumSmith+Brown, PC Period covered by the audit: Year Ended September 30, 2024 CAP prepared by: Name: Father Ronald Giannone Position: Executive Director Telephone: 646-996-4234 1. Current Findings on the Schedule of Findings, and Questioned Costs a. Finding 2024-001. Delinquent deposits into the replacement reserve account. i. Comments on the Finding and Each Recommendation: Management concurs with the finding and the auditor’s recommendation to transfer the funds to the replacement reserve account. ii. Actions Taken on the Finding: Management will transfer the funds as soon as cash flow permits. b. Finding 2024-002. Special Tests and Provisions – Project Funds. i. Comments on the Finding and Each Recommendation: Management concurs with the finding and the auditor’s recommendation to utilize an interest-bearing account for project funds. ii. Actions Taken on the Finding: Management is in the process of evaluating the recommendation to determine that appropriate course of action. 2. Status of Corrective Actions on Findings Reported in the Prior Audit Schedule of Findings, and Questioned Costs. Finding 2023-001 for delinquent deposits in the aggregated amount of $54,061 were funded in 2024.

Categories

Cash Management HUD Housing Programs Internal Control / Segregation of Duties

Other Findings in this Audit

  • 519699 2024-001
    Significant Deficiency Repeat
  • 1096141 2024-001
    Significant Deficiency Repeat
  • 1096142 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.157 Supportive Housing for the Elderly $555,187