DIMA II, Inc.

Criteria: Accurate financial reporting and compliance with the Uniform Guidance require a strong internal control system. This includes proper segregation of duties, consistent application of documented policies and procedures, and routine management oversight. Under 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provides reasonable assurance that the entity is managing the awards in compliance with the applicable requirements. Controls should be documented sufficiently to allow management to monitor their effectiveness and to demonstrate compliance to external parties. Criteria: Accurate financial reporting and compliance with the Uniform Guidance require a strong internal control system. This includes proper segregation of duties, consistent application of documented policies and procedures, and routine management oversight. Under 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provides reasonable assurance that the entity is managing the awards in compliance with the applicable requirements. Controls should be documented sufficiently to allow management to monitor their effectiveness and to demonstrate compliance to external parties. Condition: During the year, the former Senior Director of Housing & Facilities was responsible for the custody of assets and for authorizing and recording transactions in the Project’s accounting software, with limited routine oversight. Evidence of mitigating controls, such as supervisory review, documented by management approvals or signoffs, was not maintained. Cause: Staffing constraints and employee turnover have contributed to the current control environment’s inadequate segregation of duties and a lack of documented management oversight. Effect: This concentration of incompatible duties in a single individual, without documented oversight, increases the risk that errors or irregularities may occur and remain undetected. When control activities rely on a single individual’s institutional knowledge rather than documented procedures and effective internal controls, continuity and compliance can be difficult to maintain during periods of staff transition. Recommendations: Management should review existing policies and procedures and improve them where necessary to address gaps in the current control structure. Roles and responsibilities should be clearly defined and documented for all key financial reporting and compliance functions. Controls and mitigating controls should be designed, implemented, and documented, with particular attention given to segregation of duties and oversight. Evidence of supervisory review should be maintained routinely through sign-offs, checklists, or review logs. Staff involved in financial reporting and compliance should be familiar with applicable HUD requirements, the Uniform Guidance, and the entity's own policies to ensure ongoing adherence to federal program requirements. Management Comments: We concur with this finding and recognize the need for a more robust control environment. We are actively working to reevaluate staff responsibilities, expand the documentation of oversight procedures, and implement structured, recurring reviews of financial transactions and compliance-related data to ensure compliance with the Uniform Guidance.

A. Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations 1. Finding 2025-001 a. Comments on the Finding and Each Recommendation: We concur with the finding that DIMA II, Inc. requires segregation of duties. We recognize that the current structure does not adequately separate key financial responsibilities, which could lead to potential risks. Segregation of duties is essential to maintaining the integrity of our operations and ensuring that no single individual has unchecked control over critical financial or compliance-related processes. b. Action(s) Taken or Planned on the Finding: 1. Implemented Monthly Oversight Meetings: We have instituted monthly meetings to review financial statements, budgets, forecasts, and compliance-related data. These meetings include key stakeholders and team members to ensure timely discussions of financial status, variances, and compliance matters. This structure enhances accountability and provides regular managerial oversight. 2. Hired Key Finance Staff to Support Segregation of Duties: To improve internal controls, we have hired a new Chief Financial Officer with expanded responsibilities over the accounting functions of the housing entities. We have also hired a Senior Director of Housing & Compliance. These hires have significantly enhanced our ability to segregate duties. We are currently in the process of formalizing these new roles, along with related internal controls and procedures, to establish a more robust control environment.