Finding 602236 (2022-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-09-27

AI Summary

  • Core Issue: Tenant security deposits and residual receipts were not kept in separate, restricted accounts, leading to potential misuse of funds.
  • Impacted Requirements: This violates HUD guidelines requiring fully funded, segregated accounts for security deposits and timely deposits to the replacement reserve.
  • Recommended Follow-Up: Management should improve policies and controls to ensure proper segregation of funds and timely tracking and deposits of security deposits and reserves.

Finding Text

Finding No. 2022-001: Restricted Cash (Material Weakness) Statement of condition During the year ended June 30, 2022, management did not segregate certain tenant security deposits and the residual receipts deposits into a segregated, restricted cash account. For three months of the fiscal year, the monthly replacement reserve deposit was funded in the subsequent month. Security deposit funding liability was not properly tracked. Criteria In accordance with the U.S. Department of Housing and Urban Development ("HUD") Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs, HUD projects are required to establish and maintain at all times fully funded, separate bank accounts in the name of the entity for all security deposits collected and for residual receipts deposits. The Regulatory Agreement requires a monthly deposit of $235 in the replacement reserve. Security deposits owed to tenants are required to be tracked for accurate financial and HUD reporting. Cause Certain tenant security deposits and the residual receipts deposits were deposited into the replacement reserve account or operating cash account and were not transferred into segregated accounts as of June 30, 2022. The Therapeutic Living Centers for the Blind, Inc. (the "Sponsor") funds tenant security deposits and the deposits funded during the year were included within the amounts owed to the Sponsor instead of within the tenant security deposit liability. The monthly replacement reserve transfer was delayed by several days into the subsequent month due to it being on a set interval of time rather than on a monthly date. Effect Management commingled certain tenant security deposits and residual receipts deposits with its replacement reserve and operating cash accounts, resulting in the potential use of tenant security deposit cash or residual receipts deposits to fund repairs or replacements without obtaining the required prior approval of HUD. Inaccurate tracking of the tenant security deposit liability could result in understated liability and improper refunding of tenant security deposits. Late deposits to the replacement reserve could result in underfunding of the replacement reserve. Recommendation Management should review and enhance policies, procedures and internal controls to ensure that all tenant security deposits and residual receipts deposits are segregated into separate, restricted cash accounts in the name of New Visions Housing Corporation (the "Organization"). Management should revisit its review procedures for tracking tenant security deposits and its timing schedule for making deposits to the replacement reserve. Identification of repeat finding The finding is a repeat of Finding No. 2021-001. Questioned costs None Finding resolution status In process Reporting views of responsible officials and planned corrective actions Management will ensure that security deposits are tracked so they can be recorded accordingly when there is a move in and/or move out. Management is also in the process of opening a new account for this HUD entity. Moving forward management will put in place controls to ensure that the calculation is done at the end of the fiscal year.

Categories

HUD Housing Programs Cash Management Material Weakness Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 25788 2022-001
    Material Weakness Repeat
  • 25789 2022-002
    Material Weakness Repeat
  • 25790 2022-003
    Material Weakness Repeat
  • 25791 2022-004
    Material Weakness Repeat
  • 25792 2022-005
    Significant Deficiency Repeat
  • 25793 2022-006
    Significant Deficiency Repeat
  • 25794 2022-001
    Material Weakness Repeat
  • 25795 2022-002
    Material Weakness Repeat
  • 25796 2022-003
    Material Weakness Repeat
  • 25797 2022-004
    Material Weakness Repeat
  • 25798 2022-005
    Significant Deficiency Repeat
  • 25799 2022-006
    Significant Deficiency Repeat
  • 25800 2022-001
    Material Weakness Repeat
  • 25801 2022-002
    Material Weakness Repeat
  • 25802 2022-003
    Material Weakness Repeat
  • 25803 2022-004
    Material Weakness Repeat
  • 25804 2022-005
    Significant Deficiency Repeat
  • 25805 2022-006
    Significant Deficiency Repeat
  • 602230 2022-001
    Material Weakness Repeat
  • 602231 2022-002
    Material Weakness Repeat
  • 602232 2022-003
    Material Weakness Repeat
  • 602233 2022-004
    Material Weakness Repeat
  • 602234 2022-005
    Significant Deficiency Repeat
  • 602235 2022-006
    Significant Deficiency Repeat
  • 602237 2022-002
    Material Weakness Repeat
  • 602238 2022-003
    Material Weakness Repeat
  • 602239 2022-004
    Material Weakness Repeat
  • 602240 2022-005
    Significant Deficiency Repeat
  • 602241 2022-006
    Significant Deficiency Repeat
  • 602242 2022-001
    Material Weakness Repeat
  • 602243 2022-002
    Material Weakness Repeat
  • 602244 2022-003
    Material Weakness Repeat
  • 602245 2022-004
    Material Weakness Repeat
  • 602246 2022-005
    Significant Deficiency Repeat
  • 602247 2022-006
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
14.181 Supportive Housing for Persons with Disabilities $4,400