VI HOUSING FINANCE AUTHORITYLocal Government

Finding Number: 2023-010 Prior Year Finding Number: N/A Compliance Requirement: Special Test and Provision – Environmental Oversight/Review Program: Government Department/Agency: U.S. Department of Housing and Urban Development (HUD) U.S. Virgin Islands Housing Finance Authority (VIHFA) Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii ALN #: 14.228 Award #: B-17-DM-78-0001/B-18-DP-78-0001 Grant Award Period: 9/05/2017 – 09/30/2024 Award Year: 10/01/2022 to 09/30/2023 Criteria – Per HUD Section 104(g) of the HCDA (42 USA5304(G)). A state must: (1) require each of its units of general local government (subrecipients) to perform as a responsible federal official in carrying out all HUD environmental review requirements under 24 CFR Part 58, National Environmental Policy Act (NEPA), and other applicable authorities; (2) review and approved each subrecipient’s Request for Release of Funds (RROF) in accordance with the procedures provided under 24 CFR Part 58 Subpart H; (3) ensure that each subrecipient observes the statutory requirements that funds cannot be expended or obligated before the state approves its RROF and environmental certification, except as otherwise provided specifically in regulation or authorized by law; and (4) monitor and provide technical assistance to its subrecipients to ensure compliance with the environmental authorities (24 CFR Part 58) and the adequacy of environmental reviews. Further, activities must have an environmental review unless they meet criteria specified in the regulations that would exclude them from RROF and environmental certification requirements. A responsible entity does not have to comply with the requirements of 25 CFR 58 or undertake any environmental review, consultation, or other action under NEPA and the other provisions of law or authorities cited in 24 CFR 58.5 for exempt activities or projects consisting solely of exempt activities. Exempt activities include assistance for temporary or permanent improvements that do not alter environmental conditions and are limited to protection, repair, or restoration activities necessary only to control or arrest the effects from imminent threats to public safety. A CDBD-DR and CDBG-MIT grantee is required to ensure every project/activity undergoes the appropriate level of environmental review and receives clearance and Authorization to Use Grant Funds (AUGF) prior to expending any funds. As a result, special circumstances apply to HUD environmental reviews for disaster recovery efforts, and an Environmental Review is required accordingly: (a) analysis of impacts of a project on the surrounding environment and vice versa; (b) demonstrates compliance with federal environmental laws and authorities; and (c) encourages public participation. Condition – We sampled and selected 2 out of 5 projects and noted the following: • For the 2 projects, supporting documentation was not available for review. Question Costs – Not determinable Context – This condition was identified through a review of VIHFA’s compliance with the specific requirements, using a statistically valid sample. Effect – There is a risk that inadequate record keeping of environmental oversight and reviews could lead to non-compliance with Federal regulations, resulting in violation of Federal funding requirements and or disallowance of Federal funds. Cause – VIHFA does not appear to have adequate policies and procedures in place to ensure compliance with applicable special test, provision, and maintenance of underlying documentation. Recommendation – We recommend that the Authority improve internal controls to ensure adherence to Federal regulations related to special tests and provide environmental oversight and environmental reviews. Further, there should be supporting documentation to support compliance with applicable compliance requirements, and such information should also be maintained, monitored, and retained by responsible officials of the Authority. Views of Responsible Officials: While the audit identified a lack of supporting documentation for environmental oversight and reviews in two of five sampled projects, it is important to emphasize that the Virgin Islands Housing Finance Authority (VIHFA) has established robust compliance procedures in accordance with HUD Section 104(g) of the HCDA and 24 CFR Part 58. Serving as the Responsible Entity for all environmental reviews, the Authority consistently mandates that all projects undergo environmental review and submit Requests for Release of Funds (RROF) prior to the commitment or disbursement of any grant funds. Additionally, VIHFA conducts regular monitoring of subrecipients and provides technical assistance to ensure adherence to environmental regulations and the thoroughness of environmental reviews. The instances involving missing documentation were exceptional, likely resulting from administrative transitions that impacted the transmittal of environmental review records for the audit exercise. VIHFA affirms that all projects are subject to review: those with full approval and expended funds have completed an environmental review process, submitted a Request for Release of Funds (RROF), and received an Authority to Use Grant Funds (AUGF), or were determined to be exempt via the Categorical Excluded Not Subject to Part 58 determination. Any gaps in documentation are not indicative of systemic non-compliance but represent isolated occurrences that are being addressed. Management's Corrective Action Plan – Regarding the corrective action plan, VIHFA has established enhanced internal controls and comprehensive record-keeping protocols. This includes expanded training initiatives for staff and subrecipients, as well as strengthened procedures for record retention. The Authority has updated its policies and standard operating procedures to ensure greater coverage and effectiveness. VIHFA is committed to ongoing improvement and consistently meets all compliance requirements through detailed documentation. These measures have been implemented, training has taken place, and policies have been revised. The Authority maintains its dedication to continuous improvement and diligent fulfillment of all compliance obligations.

Finding Number: 2023-011 Prior Year Finding Number: 2022-003 Program: Emergency Rental Assistance (ERA) ALN: 21.023 Compliance Requirement: Eligibility Criteria --- Pursuant to 2 CFR §200.303, non-Federal entities are required to establish and maintain effective internal control over Federal awards to provide reasonable assurance of compliance with applicable laws, regulations, and award terms. In addition, the Emergency Rental Assistance (ERA) program, as established under the Consolidated Appropriations Act, 2021, and the American Rescue Plan Act of 2021, requires that funds be provided only to eligible households meeting specified criteria. The 2023 Compliance Supplement further requires grantees to obtain and retain documentation supporting residency, lease agreements, and rental obligations. Condition --- We sampled and selected 60 of 505 emergency rental assistance payment and noted for 57 samples multiple exceptions, including: • Missing or unsigned lease agreements • Lack of landlord ownership verification • Unsupported costs • Missing identification documentation • Incomplete or unapproved payment request forms • Incomplete or improperly notarized application documentation No exceptions were noted in the remaining three transactions tested. Questioned Costs --- $68,934.72 Context --- The condition was identified through testing performed using a statistically valid sample of program transactions. Effect --- Failure to maintain adequate supporting documentation increases the risk that ineligible beneficiaries may receive assistance, resulting in noncompliance with Federal program requirements. Cause --- Management did not consistently adhere to established policies and procedures requiring the retention of complete documentation supporting eligibility determinations. Recommendation --- We recommend that management strengthen internal controls to ensure that all required documentation is obtained, reviewed, and retained prior to approval of assistance. Views of Responsible Officials Management acknowledges the findings and appreciates the opportunity to provide clarification and context regarding the noted exceptions. First, with respect to landlord ownership verification, it should be noted that proof of property ownership was only required for private landlords in accordance with program policies and procedures. As such, this requirement was not applicable to all transactions reviewed. The documentation samples provided for audit testing were sourced from ERAP program files accessible to program staff. While some payment request forms within these files may appear incomplete or unsigned, the official, fully approved versions are maintained by Accounting. In certain cases, ERAP did not receive copies of the executed forms for inclusion in its files. Accordingly, although the sampled documents may not reflect final approval, the fully approved payment request forms are on file with Accounting and can be provided to support the transactions. Management also notes that staffing and process limitations during the earlier phases of program implementation contributed to documentation inconsistencies. The Grant Administrator position, which plays a critical role in oversight and compliance, was filled in February 2023. Since that time, significant improvements have been made to internal controls and operational procedures, including: o Strengthening document collection and verification processes o Improving timeliness in application review and approval to reduce bottlenecks o Enhancing case file completeness and organization o Transitioning from primarily paper-based records to electronic file management systems These procedural enhancements were formally documented in the ERAP Review Process to ensure consistency, accountability, and ongoing compliance with federal requirements. Additionally, administrative expenses exceeding the 15% threshold were reviewed and approved by Treasury, as the overage was directly attributable to the recapturing of $16 million by Treasury prior to the ERA1 closeout. Furthermore, Housing Stability Services’ expenditure remained within the 10% threshold for ERA2. Management remains committed to continuous improvement and has taken corrective actions to strengthen internal controls, ensure proper documentation retention, and maintain full compliance with applicable federal regulations.

Finding Number: 2023-012 Prior Year Finding Number: 2022-004 Program: Emergency Rental Assistance (ERA) ALN: 21.023 Compliance Requirement: Reporting Criteria --- In accordance with 2 CFR §200.303, entities must establish and maintain internal controls to ensure compliance with Federal requirements. ERA reporting guidance requires timely submission of accurate and complete reports, adherence to administrative cost limitations, and proper classification of expenditures. Condition --- Testing of two quarterly ERA2 reports and the ERA1 final close-out report identified the following: • Lack of evidence of review by the Chief Financial Officer prior to submission • Reports submitted after the required deadline • Incomplete demographic data • Exceedance of administrative and housing stability cost thresholds • Insufficient supporting documentation for reported amounts Questioned Costs --- Not determinable Context --- The condition was identified through testing of selected quarterly and final reports. Effect --- Inadequate controls over reporting increase the risk of inaccurate or unsupported financial and performance data being submitted to the Federal awarding agency. Cause --- Management did not establish or maintain effective controls over the preparation, review, and approval of reports. Recommendation --- We recommend that management enhance internal controls over reporting, including formal review procedures, timely submission processes, and retention of supporting documentation. Views of Responsible Officials: Management acknowledges the findings and provides the following context regarding the delay in submission of the FY 2023 reporting package. During FY 2023, the Internal Control Memoranda used to guide and review program operations that contained information that changed during the fiscal year due to the restructuring of the ARP Division and the implementation of the Grant Administrator role. These organizational changes affected reporting lines and oversight responsibilities, but the Internal Control Memoranda were not updated in real time to fully reflect them. To help ensure timely submission of the quarterly compliance reports, the reporting process was updated to remove the multi-level review requirement. The reports are highly detailed and require significant compilation and reconciliation within a limited timeframe between the close of the reporting period and the submission deadline. Eliminating the multi-level review process allowed management to meet reporting deadlines more efficiently. Additionally, administrative expenses exceeding the 15% threshold were reviewed and approved by Treasury, as the overage was directly attributable to the recapturing of $16 million by Treasury prior to the ERA1 closeout. Furthermore, Housing Stability Services expenditure remained within the 10% threshold for ERA2. It is also important to note that the report is cumulative in nature, which allows for corrections or updates to be incorporated in subsequent quarterly submissions, thereby maintaining overall reporting accuracy over time. Additionally, copies of all submitted reports are provided to both the CFO and the Executive Director (ED) for review and oversight. Further strengthening financial oversight, the CFO requires all direct reports to submit monthly to bi-monthly financial reports. These reports are used to continuously monitor program performance, identify any discrepancies, and address issues in a timely manner. Management remains committed to strengthening internal controls and ensuring the timely and accurate submission of all required federal reporting.

Finding Number: 2023-013 Prior Year Finding Number: 2022-005 Programs: Multiple Federal Programs Compliance Requirement: Reporting – Data Collection Form and Reporting Package Criteria --- In accordance with 2 CFR §200.512, the audit reporting package must be submitted to the Federal Audit Clearinghouse within the required timeframe. Condition --- The reporting package for the fiscal year ended September 30, 2023, was not submitted within the required deadline. Questioned Costs --- Not applicable Context --- The issue was identified through compliance review procedures. Effect --- Failure to submit the reporting package timely may result in sanctions, including potential reduction or loss of Federal funding. Cause --- Management did not have sufficient resources to ensure timely submission. Recommendation --- We recommend that management enhance staffing capacity and strengthen internal controls to ensure timely submission of required reports. Views of Responsible Officials: Management acknowledges the findings and provides the following context regarding the delay in submission of the FY 2023 compliance reports. During FY 2023, the Internal Control Memoranda used to guide and review program operations contained information that changed during the fiscal year due to the restructuring of the ARP Division and the implementation of the Grant Administrator role. These organizational changes impacted reporting lines and oversight responsibilities, and the Internal Control Memoranda were not updated in real time to fully reflect these changes. To ensure timely submission of the quarterly compliance reports, the reporting process was updated to remove the multi-level review requirement. The reports are highly detailed and require significant compilation and reconciliation within a limited timeframe between the close of the reporting period and the submission deadline. Eliminating the multi-level review process allowed management to meet reporting deadlines more efficiently. It is also important to note that the compliance reports are cumulative reports, which allows for corrections or updates to be incorporated in subsequent quarterly submissions, thereby maintaining overall reporting accuracy over time. Additionally, copies of all submitted reports are provided to both the CFO and the Executive Director (ED) for review and oversight. If changes are required, they are reporting in the subsequent quarterly submission. Further strengthening financial oversight, the CFO requires all direct reports to submit monthly to bi-monthly financial reports. These reports are used to continuously monitor program performance, identify any discrepancies, and address issues in a timely manner. Management remains committed to strengthening internal controls and ensuring the timely and accurate submission of all required federal reporting.

Finding Number: 2022-003 Prior Year Finding Number: N/A Compliance Requirement: Eligibility Program: U.S. Department of the Treasury Emergency Rental Assistance (ERA) Program AL #: 21.023 Award #: ERA1 and ERA2 Grant Award Period: 01/11/2021 to 09/30/2022 (ERA1) and 06/08/2021 to 09/30/2025 (ERA2) Award Year: 10/01/2021 to 09/30/2022 Criteria – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per section 501(k)(3)(A) of Division N of the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260 (Dec. 27, 2020), which established ERA1, and per section 3201(e)(3)(f)(2) of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 (March 11, 2021), which established ERA2, a grantee may only use the funds provided in the ERA to provide financial assistance and housing stability services to eligible households An eligible household is defined as a household of 1 or more individuals who are obligated to pay rent on a residential dwelling and with respect to which the eligible grantee involved determines— (i) that 1 or more individuals within the household has (I) qualified for unemployment benefits or (II) experienced a reduction in household income, incurred significant costs, or experienced other financial hardship due, directly or indirectly, to the novel coronavirus disease (COVID–19) outbreak, which the applicant shall attest in writing; (ii) that 1 or more individuals within the household can demonstrate a risk of experiencing homelessness or housing instability, which may include— (I) a past due utility or rent notice or eviction notice; (II) unsafe or unhealthy living conditions; or (III) any other evidence of such risk, as determined by the eligible grantee involved; and (iii) the household has a household income that is not more than 80 percent of the area median income for the household. Condition – During our testing of beneficiary eligibility compliance requirements of the Emergency Rental Assistance (ERA) program, we tested 60 assistance payments (48 of the assistance payments included in the Activities Allowed or Unallowed and Allowable Costs/Cost Principles sample and an additional 12 assistance payments). For the 48 assistance payments tested in the Activities Allowed or Unallowed and Allowable Costs/Cost Principles sample, we noted that for 31 out of the 48 assistance payments, all required supporting documentation to determine eligibility requirements were not represented at the time of testing. For the 12 additional assistance payments tested, no supporting documentation was provided at the time of testing. We were, therefore, unable to determine whether eligibility requirements were met. Questioned Costs – Undeterminable Context – This is a condition identified per review of VIHFA’ compliance with specified requirements using a statistically valid sample. Effect – Without proper maintenance of documentation to support eligibility determinations, ineligible beneficiaries may receive benefits under the ERA grant, and VIHFA may make payments on behalf of those beneficiaries, resulting in noncompliance with the eligibility requirements. Cause – We understand that the Authority relied on additional documentation from the USVI Department of Human Services regarding eligibility documentation from other programs, such as SNAP and TANF, to determine an applicant’s eligibility for the ERA grant. However, the Authority should consistently maintain any supporting documentation used to satisfy the eligibility requirement. Recommendation – We recommend that VIHFA strengthen its existing policies and procedures for reviewing and maintaining of appropriate documentation to ensure compliance with eligibility requirements. Views of Responsible Officials and Planned Corrective Actions – Over the course of the ERAP Program, Treasury made several modifications to the documentation requirements to include the recognition of proxy eligibility determinants (such as SNAP’s eligibility, TANF’s eligibility) and the use of self-attestation. In certain cases, these served to negate the need for the collection of other income documentation. Corrective Action Date: March 2023

Finding Number: 2022-004 Prior Year Finding Number: N/A Compliance Requirement: Reporting and Special Tests and Provisions - #2 ERA Funds Reallocation Program: U.S. Department of the Treasury Emergency Rental Assistance (ERA) Program AL #: 21.023 Award #: ERA1 and ERA2 Grant Award Period: 01/11/2021 to 09/30/2022 (ERA1) and 06/08/2021 to 09/30/2025 (ERA2) Award Year: 10/01/2021 to 09/30/2022 Criteria – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award Per review of the 2022 Compliance Supplement, grantees are required to submit reports in accordance with the guidance beginning in the first quarter of 2021 through September of 2022 for ERA1 (and December 2022 for recipients receiving reallocated funds) and through September of 2025 for ERA2. ERA1 grantees—excluding Indian tribes, tribally designated housing entities, and the Department of Hawaiian Home Lands consistent with the reporting allowances provided in section 501(g) of the Consolidated Appropriations Act, 2021—are required to submit monthly reports. The key lines on the monthly reports form are: 1. Total number of participating households that received ERA assistance of any kind; and 2. Total amount of ERA funds expended by the ERA grantee to or for participating households on behalf of eligible households. This is a key line item because it feeds into Treasury’s reallocation formula, as detailed in guidance at Treasury.gov. Per review of the Emergency Rental Assistance Program (ERA2) Reporting Guidance, each ERA2 Recipient must submit cumulative quarterly and final reports. The key line items in the form are: 1. The cumulative amount obligated by the grantee; and 2. The cumulative amount expended by the grantee For the Special Tests and Provisions compliance requirement for ERA Funds Reallocation, pursuant to section 501(d) of the Consolidated Appropriations Act, 2021, the Treasury is required to reallocate “excess” ERA1 award funds. Treasury’s objective in reallocations is to ensure ERA1 award funds remain available to grantees in accordance with their jurisdictional needs and demonstrated capacity to deliver assistance while the ERA appropriations remain available. Treasury’s ERA1 reallocation guidance on Treasury.gov describes how grantees that have expenditure ratios below designated thresholds as of September 30, 2021, were subject to involuntary recapture, in the absence of mitigating actions, requiring the grantee to return funds to Treasury within the provided timeframes. For the first assessment using data as of September 30, 2021, grantees could mitigate the impact of recapture by submitting a certification that the grantee’s financial assistance activity had since increased to a level beyond the minimum threshold, committing to a voluntary reallocation, or by providing a Performance Improvement Plan. Per the U.S. Department of the Treasury, Emergency Rental Assistance Under the Consolidated Appropriations Act, 2021 Reallocation Guidance “A Grantee whose Expenditure Ratio is below 30% for the First Assessment will be considered to have excess funds. Beginning with the 30% threshold established for September 2021, the minimum Expenditure Ratio will increase by 5% each calendar month (and, as indicated above, assessments will occur approximately every two months). For each g whose Expenditure Ratio is below the then-applicable minimum threshold at the time of an assessment, Treasury will calculate the grantee’s amount of excess funds as the difference between (i) the amount of expenditures needed for the grantee to achieve the minimum Expenditure Ratio applicable to that assessment and (ii) the grantee’s reported total assistance expenditures. As a result, the amount subject to recapture will be less for grantees whose Expenditure Ratios are closer to the minimum.” Per the 2022 Compliance Supplement, “the financial information certified as part of reallocation includes monthly expenditure and cumulative obligations levels, as described in the Treasury reallocation guidance. ERA1 expenditures reported monthly by the grantee are inputs to the Treasury’s reallocation expenditure ratio. ERA1 obligations certified in the Request for Reallocated Funds form (1505-0266), including in the Request for Voluntarily Reallocated Funds, are inputs into determining eligibility to receive reallocated funds. The reallocation expenditure ratio determines whether the grantee is subject to involuntary reallocation due to an insufficient ratio and the amount of excess funds subject to recapture by the Treasury. Condition – During the testing of the reporting requirements over the ERA Monthly Reports (1505-0266), we noted that for five (5) of the six (6) monthly reports tested for the ERA1 and ERA2 grants, supporting documentation was not provided at the time of testing to validate the “Number of Unique Households that Received ERA Assistance of Any Kind in the Reporting Period” reported on the monthly reports. In addition, for four (4) of these reports, supporting documentation was not provided to validate the “Total amount of ERA funds expended by the ERA grantee to or for participating households on behalf of eligible households” as reported on the report. During the testing of the reporting requirements over the ERA Quarterly Reports (1505-0266), we noted that for three (3) of the three (3) quarters tested for the ERA1 and ERA2 grants, supporting documentation was not provided at the time of testing to validate the cumulative amount obligated by the grantee reported on the quarterly reports. In addition, for one (1) of the three quarters, supporting documentation was not provided to validate the cumulative amount expended by the grantee. Further, for one (1) of these three (3) quarterly reports tested, supporting documentation was not provided to verify that the report was reviewed by the authorized personnel prior to submission to the federal grantor. We further noted that during the testing of the Special Tests and Provisions - ERA Funds Reallocation, supporting documentation was not provided to validate that the ERA1 expenditures reported monthly by the grantee through March 2022 (which are inputs to Treasury’s reallocation expenditure ratio) were accurate and supported by incurred expenditures. Questioned Costs – Undeterminable. Context – This condition is identified per review of VIHFA’ compliance with specified requirements. Effect – Without proper internal controls and policies and procedures in place over the review and approval of the ERA Monthly (1505-0266) and ERA Quarterly (1505-0266) reports, the ERA program may not report amounts that are supported by the expenditures incurred in the fiscal year 2022. In addition, failure to properly maintain underlying supporting documentation may affect the federal grantor’s reallocation calculation. Cause – Management did not have proper internal controls and policies and procedures in place over the review and approval of the ERA report to ensure that amounts are properly reported. In addition, supporting documentation was not provided for the Key Line Items reported on the ERA Monthly (1505-0266) and ERA Quarterly (1505-0266) reports. Recommendation – We recommend that VIHFA strengthen its policies, procedures, and controls over the review and approval of the ERA Monthly (1505-0266) and ERA Quarterly (1505-0266) reports to ensure that amounts reported for each grant are accurate for the ERA report prior to approval. In addition, we recommend that VIHFA adequately retain support for the information reported in the Key Line Items for the ERA Monthly (1505-0266) and ERA Quarterly (1505-0266) reports. Views of Responsible Officials and Planned Corrective Actions – The information provided in the reports were compiled using data from different sources: demographic information from HMIS and program expenditures from SAP. `The source data exists, but the working papers were not retained. Since the onboarding of the ARP Administrator, VIHFA improved its process through the creation of the Master Tracker (spreadsheet), which is updated daily and tracks each application and client file submitted for review. Going forward the Master Tracker is now used as the basis for reporting. Corrective Action Date: March 2023

Finding Number: 2022-005 Prior Year Finding Number: 2021-004 Compliance Requirement: Data Collection Form and Single Audit Reporting Package Program: Community Development Block Grants/State’s Program And Non-Entitlement Grants In Hawaii (Community Development Block Grant – Disaster Recovery Assistance Grant) AL #: 14.228 Program: Emergency Rental Assistance (ERA) Program AL #: 21.023 Program: Disaster Grants – Public Assistance – (Presidentially Declared Disasters) AL #: 97.036 Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition – The Authority did not comply with the required submission date of the data collection form and reporting package to the F AC for the fiscal year ended September 30, 2022. Questioned Costs – Not applicable. Context – This is a condition identified per review of the Authority’s compliance with the specified requirements. Effect – The Authority could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause – The Authority did not have the necessary resources to facilitate and ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation – We recommend that the Authority enhance its staffing levels and controls to ensure the reporting package is submitted to the FAC annually and within the required timeframe. Views of Responsible Officials – The Authority concurs with the auditor’s findings and recommendations. The planned corrective action is presented in the Authority’s Corrective Action Plan, attached is Appendix B to the Single Audit report.

VIRGIN ISLANDS HOUSING FINANCE AUTHORITY Schedule of Findings and Questioned Costs Year Ended September 30, 2021 Finding Number: 2021-004 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Program: AL# 14.228 Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii (Community Development Block Grant ? Disaster Recovery Assistance Grant) AL# 97.036 Disaster Grants ? Public Assistance ? (Presidentially Declared Disasters) Criteria ? The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor's report or nine (9) months after the end of the audit period unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The Authority did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2021. Questioned Costs ? Not applicable. Context ? This is a condition identified per review of the Authority's compliance with the specified requirements. Effect ? The Authority could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The Authority did not have the necessary resources to facilitate and ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the Authority enhance its staffing levels and controls to ensure the reporting package is submitted to the FAC annually and within the required timeframe. Views of Responsible Officials ? The Authority concurs with the auditor?s findings and recommendations. The planned corrective action is presented in the Authority?s Corrective Action Plan, attached is Appendix A to the Single Audit report.