EIN: 020395538
UEI: GSA_MIGRATION
Data as of August 23, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 7, 2021. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by July 7, 2021 (1874 days ago).
What is a management decision? →During our testing of compliance over the use of program income and expenditures of the organization?s revolving loan funds, we identified several disbursements of funds which lacked supporting documentation, and which were made in support of operating cash flow needs of the organization. Additionally, we noted that program income, in the form of principal repayments received on grant funded accounts receivable were comingled with non-program income funds. Criteria: 24 CFR section 570.489(e)(1)(v) classifies payments of principal and interest payments received on Community Development Block Grant funded receivables to be classified as program income. Repayment of principal must be used to capitalize the revolving loan funds. Use of the revolving loan funds is restricted to relending for purposes allowable under the provisions of Section 105 (a) of the Housing and Community Development Act of 1974, which lists the activities allowable under the program. Effect: Revolving loan funds were disbursed for inappropriate purposes. Additionally, commingling revolving loan funds with non-program funds increases the risk that activity within the fund may be miscategorized, and as a result, revolving loan funds may not be maintained at the necessary levels. Cause: Management?s interpretation of the allowable uses of CDBG funds was not consistent with the allowable uses identified in Section 105 (a) of the Housing and Community Development Act of 1974. Questioned Costs: Questioned costs in the amount of $309,470 were identified as known questioned costs based on total disbursements for unallowed purposes from the revolving loan funds. Recommendation: We recommend that management review the allowable uses of Community Development Block Grant funds as identified in Section 105 (a) of the Housing and Community Development Act of 1974. Additionally, we recommend that only allowable borrowing and repayment activity be recorded within the revolving loan funds. Finally, we recommend management review its process for tracking and reconciling revolving loan funds to ensure funds are maintained at the required levels.
Show full finding ▾Hide full finding ▴Condition: During our testing of compliance over the use of program income and expenditures of the organization?s revolving loan funds, we identified several disbursements of funds which lacked supporting documentation, and which were made in support of operating cash flow needs of the organization. Additionally, we noted that program income, in the form of principal repayments received on grant funded accounts receivable were comingled with non-program income funds. Criteria: 24 CFR section 570.489(e)(1)(v) classifies payments of principal and interest payments received on Community Development Block Grant funded receivables to be classified as program income. Repayment of principal must be used to capitalize the revolving loan funds. Use of the revolving loan funds is restricted to relending for purposes allowable under the provisions of Section 105 (a) of the Housing and Community Development Act of 1974, which lists the activities allowable under the program. Effect: Revolving loan funds were disbursed for inappropriate purposes. Additionally, commingling revolving loan funds with non-program funds increases the risk that activity within the fund may be miscategorized, and as a result, revolving loan funds may not be maintained at the necessary levels. Cause: Management?s interpretation of the allowable uses of CDBG funds was not consistent with the allowable uses identified in Section 105 (a) of the Housing and Community Development Act of 1974. Questioned Costs: Questioned costs in the amount of $309,470 were identified as known questioned costs based on total disbursements for unallowed purposes from the revolving loan funds. Recommendation: We recommend that management review the allowable uses of Community Development Block Grant funds as identified in Section 105 (a) of the Housing and Community Development Act of 1974. Additionally, we recommend that only allowable borrowing and repayment activity be recorded within the revolving loan funds. Finally, we recommend management review its process for tracking and reconciling revolving loan funds to ensure funds are maintained at the required levels.
Finding #2020-003 Allowability of Costs & Program Income: Planned Corrective Actions: Management and the Board of Directors will review the allowable uses of CDBGs as identified in Section 105(a) of the Housing and Community Development Act of 1974 (the 1974 Act). In the future we will only record allowable borrowings and repayment activity within the restricted funds. Management will report to the Board of Directors on a quarterly basis the activity within the restricted revolving loan fund (RLF) and the propriety of such activity under the 1974 Act. We will be working with the Community Development Finance Authority on a plan to refund the amounts disbursed from our RLF that were used for unallowable purposes. Subsequent to June 30, 2020, approximately $80,000 had been returned to the RLF. Anticipated Completion Date: June 30, 2021 Contact Person: George Hansel
FAC accepted this audit on February 20, 2018 — management decision was due August 20, 2018.
GSA_MIGRATION
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GSA_MIGRATION
2016-001
FAC accepted this audit on June 27, 2017 — management decision was due December 27, 2017.
GSA_MIGRATION
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GSA_MIGRATION
2015-001
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