FAC Explorer

Finding 964078 (2023-003)

Significant Deficiency
Requirement
ABCEFGHIJLMN
Questioned Costs
-
Year
2023
Accepted
2024-03-28
Audit: 299718
Organization: Plan International Inc. (NY)
Auditor: Pricewaterhousecoopers LLP

AI Summary

  • Core Issue: Significant deficiencies in the classification, completeness, and accuracy of bank accounts were identified, risking compliance with financial reporting requirements.
  • Impacted Requirements: Accurate financial records are essential for compliance with the Bank Secrecy Act and for ensuring all active bank accounts are reported correctly.
  • Recommended Follow-Up: Implement a process to confirm bank closures, conduct monthly reviews of bank accounts, and ensure accurate updates to bank account listings and reconciliations.

Finding Text

Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant deficiency) Federal Agency: All Program: All Assistance Listing: All Award #: All Award year: FY23 Pass-through: All applicable Criteria: Accurate and reliable financial records, including listing of bank accounts and bank reconciliations, are necessary to ensure that testing populations are complete, accurate and bank accounts are correctly classified. Condition: Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The following points were noted during the Plan Inc. financial statement audit: 1. From our testing performed over opening and closing bank accounts at the regional hub level, we noted an account which was classified as closed prior to receiving a formal letter from the bank confirming the closure. The account remains open with a balance of €36. 2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two additional bank account balances of €212k (immaterial and below de minimis reporting threshold) which were not included in the general ledger. 3. During our testing, differences in bank account numbers were noted in several instances between either bank confirmations / bank statements / bank reconciliations compared to the bank account listing which reflected the old account numbers. This was the case for accounts at five banks across different Country Offices (‘CO’). 4. During our testing, differences in bank account numbers were noted from three bank reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account listing for these accounts, however, was correct. 5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had incorrect local currencies input into the bank reconciliation in the currency field. This had no financial impact on the bank reconciliations performed. 6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the denominated balance in bank reconciliation and the denominated balance per trial balance were noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly revaluation process for these two specific GL accounts. Cause: For the first point, Plan had acted on the request to close the bank account when the request had been acknowledged but before it had been confirmed, and therefore removed the account from the cash listing despite a formal confirmation letter from the bank not being received. For the second, the root cause of this issue is the CO not following the process in relation to opening bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’). For points three and four, the revised bank account numbers were not updated on the bank account listing which still contained the old account numbers; and for point five the CO had not picked up the incorrect currency field noted or incorrect bank account number following review of the reconciliation. For the sixth point, two GL accounts had an incorrect variant set up causing differences between the bank reconciliation and the trial balance. Effect: Classifying balances as closed creates risks over the completeness of the bank account listing. There is a risk that a large number of accounts are classified as closed despite still being open or an account with a material cash balance could be excluded from the cash listing. Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers inaccurately reflected on the bank account listing or bank reconciliations creates risks over the completeness of the bank account listing. Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then performs ad hoc checks of various entities and if Plan is found not reporting a full list of active accounts, they will receive penalty fines for not complying with US requirements. Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not included creates risk over the completeness and accuracy of bank reconciliations. Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the foreign currency translation of bank accounts. Recommendation: We recommend the following: Bank accounts are not classified as closed until a formal closure letter from the bank is received. The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are reminded of the process around opening and closing bank accounts and the required notifications to RH and GH. Management put in place a process whereby appropriate review of bank details is performed at a CO level during the year end FBAR process as reliance is placed by GH on what is reported by the Country Offices. Management update the bank account listing to reflect updated bank account numbers. Management ensure COs review the bank reconciliations for accuracy of financial and non-financial data (such as account numbers). Management ensure the correct set up of the monthly revaluation process for bank related GL accounts. Views of Responsible Officials and Management’s Corrective Action Plan : Views of responsible officials and management’s corrective action plan are included at the end of this report after the summary schedule of prior audit findings and status.

Categories

Reporting Significant Deficiency

Other Findings in this Audit

  • 387600 2023-003
    Significant Deficiency
  • 387601 2023-004
    Significant Deficiency Repeat
  • 387602 2023-003
    Significant Deficiency
  • 387603 2023-004
    Significant Deficiency Repeat
  • 387604 2023-003
    Significant Deficiency
  • 387605 2023-004
    Significant Deficiency Repeat
  • 387606 2023-006
    -
  • 387607 2023-003
    Significant Deficiency
  • 387608 2023-004
    Significant Deficiency Repeat
  • 387609 2023-003
    Significant Deficiency
  • 387610 2023-004
    Significant Deficiency Repeat
  • 387611 2023-007
    -
  • 387612 2023-003
    Significant Deficiency
  • 387613 2023-004
    Significant Deficiency Repeat
  • 387614 2023-003
    Significant Deficiency
  • 387615 2023-004
    Significant Deficiency Repeat
  • 387616 2023-003
    Significant Deficiency
  • 387617 2023-004
    Significant Deficiency Repeat
  • 387618 2023-003
    Significant Deficiency
  • 387619 2023-004
    Significant Deficiency Repeat
  • 387620 2023-003
    Significant Deficiency
  • 387621 2023-004
    Significant Deficiency Repeat
  • 387622 2023-003
    Significant Deficiency
  • 387623 2023-004
    Significant Deficiency Repeat
  • 387624 2023-003
    Significant Deficiency
  • 387625 2023-004
    Significant Deficiency Repeat
  • 387626 2023-003
    Significant Deficiency
  • 387627 2023-004
    Significant Deficiency Repeat
  • 387628 2023-003
    Significant Deficiency
  • 387629 2023-004
    Significant Deficiency Repeat
  • 387630 2023-003
    Significant Deficiency
  • 387631 2023-004
    Significant Deficiency Repeat
  • 387632 2023-003
    Significant Deficiency
  • 387633 2023-004
    Significant Deficiency Repeat
  • 387634 2023-003
    Significant Deficiency
  • 387635 2023-004
    Significant Deficiency Repeat
  • 387636 2023-003
    Significant Deficiency
  • 387637 2023-004
    Significant Deficiency Repeat
  • 387638 2023-003
    Significant Deficiency
  • 387639 2023-004
    Significant Deficiency Repeat
  • 387640 2023-003
    Significant Deficiency
  • 387641 2023-004
    Significant Deficiency Repeat
  • 387642 2023-007
    -
  • 387643 2023-003
    Significant Deficiency
  • 387644 2023-004
    Significant Deficiency Repeat
  • 387645 2023-007
    -
  • 387646 2023-003
    Significant Deficiency
  • 387647 2023-004
    Significant Deficiency Repeat
  • 387648 2023-003
    Significant Deficiency
  • 387649 2023-004
    Significant Deficiency Repeat
  • 387650 2023-003
    Significant Deficiency
  • 387651 2023-004
    Significant Deficiency Repeat
  • 387652 2023-003
    Significant Deficiency
  • 387653 2023-004
    Significant Deficiency Repeat
  • 387654 2023-003
    Significant Deficiency
  • 387655 2023-004
    Significant Deficiency Repeat
  • 964042 2023-003
    Significant Deficiency
  • 964043 2023-004
    Significant Deficiency Repeat
  • 964044 2023-003
    Significant Deficiency
  • 964045 2023-004
    Significant Deficiency Repeat
  • 964046 2023-003
    Significant Deficiency
  • 964047 2023-004
    Significant Deficiency Repeat
  • 964048 2023-006
    -
  • 964049 2023-003
    Significant Deficiency
  • 964050 2023-004
    Significant Deficiency Repeat
  • 964051 2023-003
    Significant Deficiency
  • 964052 2023-004
    Significant Deficiency Repeat
  • 964053 2023-007
    -
  • 964054 2023-003
    Significant Deficiency
  • 964055 2023-004
    Significant Deficiency Repeat
  • 964056 2023-003
    Significant Deficiency
  • 964057 2023-004
    Significant Deficiency Repeat
  • 964058 2023-003
    Significant Deficiency
  • 964059 2023-004
    Significant Deficiency Repeat
  • 964060 2023-003
    Significant Deficiency
  • 964061 2023-004
    Significant Deficiency Repeat
  • 964062 2023-003
    Significant Deficiency
  • 964063 2023-004
    Significant Deficiency Repeat
  • 964064 2023-003
    Significant Deficiency
  • 964065 2023-004
    Significant Deficiency Repeat
  • 964066 2023-003
    Significant Deficiency
  • 964067 2023-004
    Significant Deficiency Repeat
  • 964068 2023-003
    Significant Deficiency
  • 964069 2023-004
    Significant Deficiency Repeat
  • 964070 2023-003
    Significant Deficiency
  • 964071 2023-004
    Significant Deficiency Repeat
  • 964072 2023-003
    Significant Deficiency
  • 964073 2023-004
    Significant Deficiency Repeat
  • 964074 2023-003
    Significant Deficiency
  • 964075 2023-004
    Significant Deficiency Repeat
  • 964076 2023-003
    Significant Deficiency
  • 964077 2023-004
    Significant Deficiency Repeat
  • 964079 2023-004
    Significant Deficiency Repeat
  • 964080 2023-003
    Significant Deficiency
  • 964081 2023-004
    Significant Deficiency Repeat
  • 964082 2023-003
    Significant Deficiency
  • 964083 2023-004
    Significant Deficiency Repeat
  • 964084 2023-007
    -
  • 964085 2023-003
    Significant Deficiency
  • 964086 2023-004
    Significant Deficiency Repeat
  • 964087 2023-007
    -
  • 964088 2023-003
    Significant Deficiency
  • 964089 2023-004
    Significant Deficiency Repeat
  • 964090 2023-003
    Significant Deficiency
  • 964091 2023-004
    Significant Deficiency Repeat
  • 964092 2023-003
    Significant Deficiency
  • 964093 2023-004
    Significant Deficiency Repeat
  • 964094 2023-003
    Significant Deficiency
  • 964095 2023-004
    Significant Deficiency Repeat
  • 964096 2023-003
    Significant Deficiency
  • 964097 2023-004
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
10.608 Food for Education $1.08M
19.019 International Programs to Combat Human Trafficking $298,150
19.517 Overseas Refugee Assistance Programs for Africa $210,755
17.401 International Labor Programs $183,493
98.001 Usaid Foreign Assistance for Programs Overseas $319