Finding Text
Recordkeeping and Documentation for the HOME Investment Partnerships Program (Material Weakness ? Eligibility & Special Tests) Condition: Sufficient records were not maintained to support projects assisted with HOME funds in accordance with 24 CFR ?92.508 Recordkeeping. The City does not maintain a complete schedule of all HOME assisted projects including the necessary information in order to comply with continuing compliance requirements on outstanding loans. We noted several loans not listed on either the HOME Rehab or Homebuyer Down Payment Assistance schedules. We noted loans listed on the incorrect schedule. Home Rehab loans and Homebuyer Down Payment Assistance loans have different continuing compliance requirements. We also noted properties listed on the schedules but were missing information (for example: IDIS #, forgivable loan amount, deferred loan amount). The loan amounts are necessary for reporting the total amount of outstanding loans with continuing compliance requirements on the SEFA. Eligibility: Documentation to support eligibility determinations for new loans issued is incomplete. Special Tests - Continuing Compliance Requirements: Housing Quality Standards Reviews, Income Reverifications, Proof of Residency Verifications, and other Continuing Compliance monitoring requirements were not completed during fiscal year 2022. Criteria: ? Records demonstrating that each project meets the property standards of ?92.251 and the leadbased paint requirements of ?92.355. (?92.508 (a)(3)(iv)) ? Records demonstrating that each family is income eligible in accordance with ?92.203. (?92.508 (a)(3)(v)) ? Records demonstrating that each rental housing project meets the affordability and income targeting requirements of ?92.252 for the required period. Records must be kept for each family assisted. (?92.508 (a)(3)(vii)) ? Records demonstrating that each homeownership project meets the affordability requirements of ?92.254 for the required period. (?92.508 (a)(3)(xi)) Cause: 1) Documentation required to support eligibility determinations is not maintained in applicant files. 2) The City does not maintain a complete listing of all HOME assisted projects including the information necessary to support that eligibility determinations were completed according to compliance requirements and to ensure continuing compliance requirements are met during the period of affordability for outstanding loans. 3) Housing quality inspections, income reverifications, and other continuing compliance requirement monitoring were not completed during FY22 due to recent staff turnover. Effect: The City was unable to identify the projects completed during the fiscal year which can lead to noncompliance with recordkeeping regulations (24 CFR ?92.508), eligibility requirements (24 CFR ?92.2, ?92.1, & ?92.203), and other continuing compliance requirements throughout the period of affordability as noted above. Isolated Instance or Systemic Problem: We consider this to be a ?systemic? problem. Repeat of Finding in the Immediately Prior Audit (with Prior Year Audit Finding Number (where applicable)): Yes. (Prior Year Finding Number 2021-001) Recommendation: We recommend that the City establish and maintain sufficient records in accordance with 24 CFR ?92.508 as well as maintain a complete listing of all HOME assisted projects to also include the program each project received funding through (Homebuyer Down Payment Assistance and Home Rehab Assistance in FY22), the period of affordability and due dates of required verifications or inspections, indication of whether the continuing compliance requirements were met, and any other information or data that would be useful to ensure sufficient tracking of funds provided through the HOME program and compliance with related requirements mentioned above.