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City of San BuenaventuraLocal Government

EIN: 956000807

UEI: MNM1UJ1DMCX8

Audited by: The Pun Group, LLP

Cognizant agency: 66 [Environmental Protection Agency]

View federal awards & risk assessment →

Data as of August 31, 2026

City of San Buenaventura11 audit years9 findings2 repeat
11
Audit Years
9
Total Findings
2
Repeat Findings
$87.1M
Federal Awards Expended (FY 2025)

FY 2025-06-30

$87,075,283 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 31, 2026. 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 October 1, 2026 (29 days from today).

What is a management decision? →
2025-001
Cash Management
MATERIAL WEAKNESSREPEAT OF 2024-003OTHER MATTERS

The City’s Venture Pure Project is funded through multiple funding sources including WIFIA loans, Title XVI Water Reclamation and Reuse Program (the “Title XVI Program”), and funds accumulated through charges to rate payers. On September 18, 2023, the City received funding amendment no. 3 for another federal program, the Title XVI program, amending the award and allowing the City to claim expenditures incurred as far back as March 2022 for certain design, construction, and program management costs. Due to the funding amendment and reclassification of expenditures from WIFIA program to Title XVI program, WIFIA loans were over-drawn by $9,004,301 and $7,838,828 for Wastewater System and Water System, respectively, through of June 30, 2025. Cause: There was inadequate planning and grant management to properly identify the eligible costs for reimbursement in a timely matter. Although the amendment document was shared between the Water and Finance Department, there was ineffective communication between the departments related to the reimbursement and drawdown requests when there were changes in scope of work, period of performance, and reallocation of funding resources. Effect or Potential Effect: WIFIA loans were over drawn by $9,004,301 and $7,838,828 for Wastewater and Water System, respectively. Questioned Costs: None Context: See condition above for context of the finding. Identification as a Repeat Finding, If Applicable:Repeat finding from 2024-003. Recommendation: We recommend the City update its policies and procedures for the reimbursement/drawdown process for projects funded with multiple funding sources and improve its communication between the departments to prevent duplicating reimbursement and drawdown requests View of Responsible Officials: The City concurs with the finding. The City is committed to updating its policies and procedures for the reimbursement/drawdown process for projects funded with multiple funding sources and is committed to improving its communication between departments to prevent duplicating reimbursement and drawdown requests.

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Finding 2025-001 Cash Management – Internal Control and Compliance over Cash Management Information of the Federal Programs: Assistance Listing Number: 66.958 Assistance Listing Title: Water Infrastructure Finance and Innovation (WIFIA) Federal Agency: U.S. Environmental Protection Agency Federal Award Number and Award Year: WIFIA – N20179CA, WIFIA – N20108CA Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): In accordance with 2025 OMB Compliance Supplement – 2 CFR Part 200 Appendix XI, Part 3 – Compliance Requirements – Cash Management, non-federal entities must comply with applicable program requirements for payment under loans, loan guarantees, interest subsidies, and insurance. Pursuant to the WIFIA Credit Agreement, Article II, Section 4. (a), “WIFIA Credit Facility proceeds shall be disbursed solely in respect of Wastewater/Water System Eligible Project Costs paid or incurred and approved for payment by or on behalf of the City. If the City intends to utilize the WIFIA Credit Facility proceeds to make progress payments for Project construction work performed under the Construction Contracts, the City shall demonstrate to the satisfaction of the WIFIA Credit Provider that such progress payments are commensurate with the cost of the work that has beem completed. Condition: The City’s Venture Pure Project is funded through multiple funding sources including WIFIA loans, Title XVI Water Reclamation and Reuse Program (the “Title XVI Program”), and funds accumulated through charges to rate payers. On September 18, 2023, the City received funding amendment no. 3 for another federal program, the Title XVI program, amending the award and allowing the City to claim expenditures incurred as far back as March 2022 for certain design, construction, and program management costs. Due to the funding amendment and reclassification of expenditures from WIFIA program to Title XVI program, WIFIA loans were over-drawn by $9,004,301 and $7,838,828 for Wastewater System and Water System, respectively, through of June 30, 2025. Cause: There was inadequate planning and grant management to properly identify the eligible costs for reimbursement in a timely matter. Although the amendment document was shared between the Water and Finance Department, there was ineffective communication between the departments related to the reimbursement and drawdown requests when there were changes in scope of work, period of performance, and reallocation of funding resources. Effect or Potential Effect: WIFIA loans were over drawn by $9,004,301 and $7,838,828 for Wastewater and Water System, respectively. Questioned Costs: None Context: See condition above for context of the finding. Identification as a Repeat Finding, If Applicable:Repeat finding from 2024-003. Recommendation: We recommend the City update its policies and procedures for the reimbursement/drawdown process for projects funded with multiple funding sources and improve its communication between the departments to prevent duplicating reimbursement and drawdown requests View of Responsible Officials: The City concurs with the finding. The City is committed to updating its policies and procedures for the reimbursement/drawdown process for projects funded with multiple funding sources and is committed to improving its communication between departments to prevent duplicating reimbursement and drawdown requests.

Corrective Action Plan

The City concurs with the finding. The City is commited to updating its policies and procedures for the reimbursement/drawdown process for projects funded with multiple funding sources and is commited to improving its communicaton between departments to prevent duplicating reimbursement and drawdown requests. In fact, the City has already begun doing so. At the beginning of the current fiscal year (FY 2026), the City began split funding the Ventura Water Pure multi-funded projects at the point of preparation of requisitions, purchase orders, and invoices instead of performing the analysis and allocation after the fact as was done in the past. It was the result of this process that enabled the Accounting Division to identify duplicate reimbursements during its review of WIFIA drawdown requests. Once noted, the Accounting Division immediately communicated this issue to the Water Department, who then immediately notified the City’s Environmental Protection Agency (EPA) representative to determine next steps. Since then, in collaboration with the City’s EPA representative, the City did not draw down any WIFIA funds until the City incurred expenditures in excess of the amount overdrawn. Since implementing the above process, no additional duplicate reimbursement of drawdown requests has been noted. The City is commited to further strengthening its internal controls over cash management to prevent any such duplication of draw-down requests in the future. Additionally, the City’s Finance Department will increase collaboration with the City’s Water Department to further strengthen its grant policies and procedures and to further strengthen communication between the two departments to prevent duplicating reimbursement and drawdown requests.

Prior Finding References

2024-003

About Cash Management →
2025-002
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2024-001OTHER MATTERS

The City did not submit the required Cash on Hand Quarterly Report in a timely manner. The quarter ended March 31, 2025 was submitted on July 24, 2025. Cause: During the period the City was migrating to a new Enterprise Resource Planning software (ERP). The corrective action plan was not finalized until after the end of the fiscal year. Effect or Potential Effect: Delay in filing the reports resulted in noncompliance with the compliance requirements. Questioned Costs: None Context: See condition above for context of the finding. Identification as a Repeat Finding, If Applicable: Repeat finding from 2024-001. Recommendation: We recommend that the City follow its newly adopted policies and procedures to strengthen the report submission process to ensure all required reports are properly reviewed and approved and submitted timely. When a report cannot be submitted by the due date, the City should request an extension from the funding agency and maintain record of the approval. View of Responsible Officials: The City concurs with this finding and is committed to following its newly adopted policies and procedures to strengthen the report submission process to ensure all required reports are properly reviewed and approved and submitted timely.

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Finding 2025-002 Reporting – Internal Control and Compliance over Reporting Information of the Federal Programs: Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grants - Entitlement Grants Federal Agency: U.S. Department of Housing and Urban Development (“HUD”) Federal Award Number and Award Year: B-21-MC-06-0536, B-22-MC-06-0536, B-23-MC-06-0536, and B-20-MW-06-0536, B-24-MC-06-0536 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to the Guidance on Cash on Hand Quarterly Report (replaced the Federal Financial Report, SF-425) and financial reporting requirements in the cooperative agreement provisions, and 2 CFR 200.327: Quarterly reports: Program award recipients must submit Cash on Hand Quarterly Report reports to HUD quarterly, 30 days after the reporting period end date. Each report must cover all expenditures on the cooperative agreement from the start date of the reporting period to the reporting period end date. The following quarter reporting are due to HUD 30 days after the period end dates noted below. Reporting Period ------ Due Date of Report Quarter 1: 7/1/2024 - 9/30/2024 ------ October 30,2024 Quarter 2: 10/1/2024 - 12/31/2024------ January 30,2025 Quarter 3: 1/1/2025 - 3/31/2025------ April 30,2025 Quarter 4: 4/1/2025 - 6/30/2025------ July 30,2025 Condition: The City did not submit the required Cash on Hand Quarterly Report in a timely manner. The quarter ended March 31, 2025 was submitted on July 24, 2025. Cause: During the period the City was migrating to a new Enterprise Resource Planning software (ERP). The corrective action plan was not finalized until after the end of the fiscal year. Effect or Potential Effect: Delay in filing the reports resulted in noncompliance with the compliance requirements. Questioned Costs: None Context: See condition above for context of the finding. Identification as a Repeat Finding, If Applicable: Repeat finding from 2024-001. Recommendation: We recommend that the City follow its newly adopted policies and procedures to strengthen the report submission process to ensure all required reports are properly reviewed and approved and submitted timely. When a report cannot be submitted by the due date, the City should request an extension from the funding agency and maintain record of the approval. View of Responsible Officials: The City concurs with this finding and is committed to following its newly adopted policies and procedures to strengthen the report submission process to ensure all required reports are properly reviewed and approved and submitted timely.

Corrective Action Plan

The City concurs with this finding and is commited to following its newly adopted policies and procedures to strengthen the report submission process to ensure all required reports are properly reviewed and approved and submited timely. In fact, the City has already begun doing so. On October 15, 2025, the City met with the Single-Audit-Coordination Team (SACT) of the California Department of Housing and Community Development (HCD) to review FY 2023-2024 Single Audit Report Findings and to review the HCD’s recommendations for resolution. As a result of that meeting the Accounting Division adopted and implemented additional internal policies for all grants, to ensure that all grant reports are submited in a timely manner, which they communicated via a Memorandum to all affected staff on October 22, 2025. As a result of implementing this new internal policy, there have been no further instances of late reporting, and the HCD communicated to the City on March 10, 2026, that they officially consider the finding closed. The City is commited to the continual strengthening of its internal controls over reporting to ensure there are no repeat findings in the future.

Prior Finding References

2024-001

About Reporting →

FY 2024-06-30

LOW-RISK AUDITEE$54,455,705 federal awards expended

FAC accepted this audit on March 31, 2025 — management decision was due October 1, 2025.

2024-001
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

The City did not submit the required Cash on Hand Quarterly Report in a timely manner. The Quarter 2 and Quarter 3 reports were both submitted on August 1, 2024. Cause: During the period the City was migrating to a new Enterprise Resource Planning software (ERP). The grant accountant missed the deadline due to the ERP migration deadlines. Effect or Potential Effect: Delay in filing the reports resulted in noncompliance with the compliance requirements. Questioned Costs: None. Context: See condition above for context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommend that the City update policies and procedures to strengthen the report submission process to ensure all required reports are properly reviewed and approved and submitted timely. When a report cannot be submitted by the due date, the City should request an extension from the funding agency and maintain a record of the approval. View of Responsible Officials: Management concurs the finding.

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Information of the Federal Programs: Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grants - Entitlement Grants Federal Agency: U.S. Department of Housing and Urban Development (“HUD”) Federal Award Number and Award Year: B-21-MC-06-0536, B-22-MC-06-0536, B-23-MC-06-0536, and B-20-MW-06-0536 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to the Guidance on Cash on Hand Quarterly Report (replaced the Federal Financial Report, SF-425) and financial reporting requirements in the cooperative agreement provisions, and 2 CFR 200.327: Quarterly reports: Program award recipients must submit Cash on Hand Quarterly Report reports to HUD quarterly, 30 days after the reporting period end date. Each report must cover all expenditures on the cooperative agreement from the start date of the reporting period to the reporting period end date. The following federal fiscal year quarter reporting period will be used for all quarterly reports, are due to HUD 30 days after the period end dates noted below: Reporting Period - Due Date of Report Quarter 1: 10/1-12/31 - January 30 Quarter 2: 1/1-3/31 - April 30 Quarter 3: 4/1-6/30 - July 30 Quarter 4:7/1-9/30 - October 30 Condition: The City did not submit the required Cash on Hand Quarterly Report in a timely manner. The Quarter 2 and Quarter 3 reports were both submitted on August 1, 2024. Cause: During the period the City was migrating to a new Enterprise Resource Planning software (ERP). The grant accountant missed the deadline due to the ERP migration deadlines. Effect or Potential Effect: Delay in filing the reports resulted in noncompliance with the compliance requirements. Questioned Costs: None. Context: See condition above for context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommend that the City update policies and procedures to strengthen the report submission process to ensure all required reports are properly reviewed and approved and submitted timely. When a report cannot be submitted by the due date, the City should request an extension from the funding agency and maintain a record of the approval. View of Responsible Officials: Management concurs the finding.

Corrective Action Plan

The City staff will be stricter in following its established internal control procedures to ensure that all reporting requirements are met and submitted timely. The City will also establish access to the Integrated Disbursement and Information System (IDIS) for another member of the Finance Department in a backup capacity. Where applicable, the City will request an extension from the funding agency and maintain a record of the approval when a report cannot be submitted by the due date.

About Reporting →
2024-001
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

The City did not submit the required Cash on Hand Quarterly Report in a timely manner. The Quarter 2 and Quarter 3 reports were both submitted on August 1, 2024. Cause: During the period the City was migrating to a new Enterprise Resource Planning software (ERP). The grant accountant missed the deadline due to the ERP migration deadlines. Effect or Potential Effect: Delay in filing the reports resulted in noncompliance with the compliance requirements. Questioned Costs: None. Context: See condition above for context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommend that the City update policies and procedures to strengthen the report submission process to ensure all required reports are properly reviewed and approved and submitted timely. When a report cannot be submitted by the due date, the City should request an extension from the funding agency and maintain a record of the approval. View of Responsible Officials: Management concurs the finding.

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Information of the Federal Programs: Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grants - Entitlement Grants Federal Agency: U.S. Department of Housing and Urban Development (“HUD”) Federal Award Number and Award Year: B-21-MC-06-0536, B-22-MC-06-0536, B-23-MC-06-0536, and B-20-MW-06-0536 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to the Guidance on Cash on Hand Quarterly Report (replaced the Federal Financial Report, SF-425) and financial reporting requirements in the cooperative agreement provisions, and 2 CFR 200.327: Quarterly reports: Program award recipients must submit Cash on Hand Quarterly Report reports to HUD quarterly, 30 days after the reporting period end date. Each report must cover all expenditures on the cooperative agreement from the start date of the reporting period to the reporting period end date. The following federal fiscal year quarter reporting period will be used for all quarterly reports, are due to HUD 30 days after the period end dates noted below: Reporting Period - Due Date of Report Quarter 1: 10/1-12/31 - January 30 Quarter 2: 1/1-3/31 - April 30 Quarter 3: 4/1-6/30 - July 30 Quarter 4:7/1-9/30 - October 30 Condition: The City did not submit the required Cash on Hand Quarterly Report in a timely manner. The Quarter 2 and Quarter 3 reports were both submitted on August 1, 2024. Cause: During the period the City was migrating to a new Enterprise Resource Planning software (ERP). The grant accountant missed the deadline due to the ERP migration deadlines. Effect or Potential Effect: Delay in filing the reports resulted in noncompliance with the compliance requirements. Questioned Costs: None. Context: See condition above for context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommend that the City update policies and procedures to strengthen the report submission process to ensure all required reports are properly reviewed and approved and submitted timely. When a report cannot be submitted by the due date, the City should request an extension from the funding agency and maintain a record of the approval. View of Responsible Officials: Management concurs the finding.

Corrective Action Plan

The City staff will be stricter in following its established internal control procedures to ensure that all reporting requirements are met and submitted timely. The City will also establish access to the Integrated Disbursement and Information System (IDIS) for another member of the Finance Department in a backup capacity. Where applicable, the City will request an extension from the funding agency and maintain a record of the approval when a report cannot be submitted by the due date.

About Reporting →
2024-003
Cash Management
MATERIAL WEAKNESSOTHER MATTERS

The City’s Ventura Pure Project is funded through multiple funding sources including WIFIA loans, Title XVI Water Reclamation and Reuse Program (the “Title XVI Program”), and funds accumulated through charges to rate payers. On September 18, 2023, the City received funding amendment no. 3 for another federal program, the Title XVI program, amending the award and allowing the City to claim expenditures incurred as far back as March 2022 for certain design, construction, and program management costs. Due to the funding amendment and reclassification of expenditures from WIFIA program to Title XVI program, WIFIA loans were over-drawn by $4,989,112 and $4,194,295 for Wastewater System and Water System, respectively, as of June 30, 2024. Cause: There was inadequate planning and grant management to properly identify the eligible costs for reimbursement in a timely matter. Although the amendment document was shared between the Water and Finance Department, there was ineffective communication between the departments related to the reimbursement and drawdown requests when there were changes in scope of work, period of performance, and reallocation of funding resources. Effect or Potential Effect: WIFIA loans were over drawn by $4,989,112 and $4,194,295 for Wastewater and Water System, respectively. Questioned Costs: None. Context: See condition above for context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommend the City update its policies and procedures for the reimbursement/drawdown process for projects funded with multiple funding sources and improve its communication between the departments to prevent duplicating reimbursement and drawdown requests. View of Responsible Officials: The City concurs with the finding. The City is committed to updating its policies and procedures for the reimbursement/drawdown process for projects funded with multiple funding sources and is committed to improving its communication between departments to prevent duplicating reimbursement and drawdown requests.

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Information of the Federal Programs: Assistance Listing Number: 66.958 Assistance Listing Title: Water Infrastructure Finance and Innovation (WIFIA) Federal Agency: U.S. Environmental Protection Agency Federal Award Number and Award Year: WIFIA – N20179CA, WIFIA – N20108CA Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): In accordance with 2024 OMB Compliance Supplement – 2 CFR Part 200 Appendix XI, Part 3 – Compliance Requirements – Cash Management, non-federal entities must comply with applicable program requirements for payment under loans, loan guarantees, interest subsidies, and insurance. Pursuant to the WIFIA Credit Agreement, Article II, Section 4. (a), “WIFIA Credit Facility proceeds shall be disbursed solely in respect of Wastewater/Water System Eligible Project Costs paid or incurred and approved for payment by or on behalf of the City. If the City intends to utilize the WIFIA Credit Facility proceeds to make progress payments for Project construction work performed under the Construction Contracts, the City shall demonstrate to the satisfaction of the WIFIA Credit Provider that such progress payments are commensurate with the cost of the work that has been completed.” Condition: The City’s Ventura Pure Project is funded through multiple funding sources including WIFIA loans, Title XVI Water Reclamation and Reuse Program (the “Title XVI Program”), and funds accumulated through charges to rate payers. On September 18, 2023, the City received funding amendment no. 3 for another federal program, the Title XVI program, amending the award and allowing the City to claim expenditures incurred as far back as March 2022 for certain design, construction, and program management costs. Due to the funding amendment and reclassification of expenditures from WIFIA program to Title XVI program, WIFIA loans were over-drawn by $4,989,112 and $4,194,295 for Wastewater System and Water System, respectively, as of June 30, 2024. Cause: There was inadequate planning and grant management to properly identify the eligible costs for reimbursement in a timely matter. Although the amendment document was shared between the Water and Finance Department, there was ineffective communication between the departments related to the reimbursement and drawdown requests when there were changes in scope of work, period of performance, and reallocation of funding resources. Effect or Potential Effect: WIFIA loans were over drawn by $4,989,112 and $4,194,295 for Wastewater and Water System, respectively. Questioned Costs: None. Context: See condition above for context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommend the City update its policies and procedures for the reimbursement/drawdown process for projects funded with multiple funding sources and improve its communication between the departments to prevent duplicating reimbursement and drawdown requests. View of Responsible Officials: The City concurs with the finding. The City is committed to updating its policies and procedures for the reimbursement/drawdown process for projects funded with multiple funding sources and is committed to improving its communication between departments to prevent duplicating reimbursement and drawdown requests.

Corrective Action Plan

The City concurs with the finding. The City is committed to updating its policies and procedures for the reimbursement/drawdown process for projects funded with multiple funding sources and is committed to improving its communication between departments to prevent duplicating reimbursement and drawdown requests. In fact, the City has already begun doing so. At the beginning of the current fiscal year (FY 2026), the City began split funding the Ventura Water Pure multi-funded projects at the point of preparation of requisitions, purchase orders, and invoices instead of performing the analysis and allocation after the fact as was done in the past. It was the result of this process that enabled the Accounting Division to identify duplicate reimbursements during its review of WIFIA drawdown requests. Once noted, the Accounting Division immediately communicated this issue to the Water Department, who then immediately notified the City’s Environmental Protection Agency (EPA) representative to determine next steps. Since then, in collaboration with the City’s EPA representative, the City did not draw down any WIFIA funds until the City incurred expenditures in excess of the amount overdrawn. Since implementing the above process, no additional duplicate reimbursement of drawdown requests has been noted. The City is committed to further strengthening its internal controls over cash management to prevent any such duplication of draw-down requests in the future. Additionally, the City’s Finance Department will increase collaboration with the City’s Water Department to further strengthen its grant policies and procedures and to further strengthen communication between the two departments to prevent duplicating reimbursement and drawdown requests.

About Cash Management →

FY 2024-06-30

MATERIAL NONCOMPLIANCE DISCLOSEDLOW-RISK AUDITEE$61,930,902 federal awards expended

FAC accepted this audit on July 9, 2026 — management decision was due January 9, 2027.

2024-001
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

The City did not submit the required Cash on Hand Quarterly Report in a timely manner. The Quarter 2 and Quarter 3 reports were both submitted on August 1, 2024. Cause: During the period the City was migrating to a new Enterprise Resource Planning software (ERP). The grant accountant missed the deadline due to the ERP migration deadlines. Effect or Potential Effect: Delay in filing the reports resulted in noncompliance with the compliance requirements. Questioned Costs: None. Context: See condition above for context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommend that the City update policies and procedures to strengthen the report submission process to ensure all required reports are properly reviewed and approved and submitted timely. When a report cannot be submitted by the due date, the City should request an extension from the funding agency and maintain a record of the approval. View of Responsible Officials: Management concurs the finding.

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Information of the Federal Programs: Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grants - Entitlement Grants Federal Agency: U.S. Department of Housing and Urban Development (“HUD”) Federal Award Number and Award Year: B-21-MC-06-0536, B-22-MC-06-0536, B-23-MC-06-0536, and B-20-MW-06-0536 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to the Guidance on Cash on Hand Quarterly Report (replaced the Federal Financial Report, SF-425) and financial reporting requirements in the cooperative agreement provisions, and 2 CFR 200.327: Quarterly reports: Program award recipients must submit Cash on Hand Quarterly Report reports to HUD quarterly, 30 days after the reporting period end date. Each report must cover all expenditures on the cooperative agreement from the start date of the reporting period to the reporting period end date. The following federal fiscal year quarter reporting period will be used for all quarterly reports, are due to HUD 30 days after the period end dates noted below: Reporting Period - Due Date of Report Quarter 1: 10/1-12/31 - January 30 Quarter 2: 1/1-3/31 - April 30 Quarter 3: 4/1-6/30 - July 30 Quarter 4:7/1-9/30 - October 30 Condition: The City did not submit the required Cash on Hand Quarterly Report in a timely manner. The Quarter 2 and Quarter 3 reports were both submitted on August 1, 2024. Cause: During the period the City was migrating to a new Enterprise Resource Planning software (ERP). The grant accountant missed the deadline due to the ERP migration deadlines. Effect or Potential Effect: Delay in filing the reports resulted in noncompliance with the compliance requirements. Questioned Costs: None. Context: See condition above for context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommend that the City update policies and procedures to strengthen the report submission process to ensure all required reports are properly reviewed and approved and submitted timely. When a report cannot be submitted by the due date, the City should request an extension from the funding agency and maintain a record of the approval. View of Responsible Officials: Management concurs the finding.

Corrective Action Plan

The City staff will be stricter in following its established internal control procedures to ensure that all reporting requirements are met and submitted timely. The City will also establish access to the Integrated Disbursement and Information System (IDIS) for another member of the Finance Department in a backup capacity. Where applicable, the City will request an extension from the funding agency and maintain a record of the approval when a report cannot be submitted by the due date.

About Reporting →
2024-001
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

The City did not submit the required Cash on Hand Quarterly Report in a timely manner. The Quarter 2 and Quarter 3 reports were both submitted on August 1, 2024. Cause: During the period the City was migrating to a new Enterprise Resource Planning software (ERP). The grant accountant missed the deadline due to the ERP migration deadlines. Effect or Potential Effect: Delay in filing the reports resulted in noncompliance with the compliance requirements. Questioned Costs: None. Context: See condition above for context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommend that the City update policies and procedures to strengthen the report submission process to ensure all required reports are properly reviewed and approved and submitted timely. When a report cannot be submitted by the due date, the City should request an extension from the funding agency and maintain a record of the approval. View of Responsible Officials: Management concurs the finding.

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Full finding narrative

Information of the Federal Programs: Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grants - Entitlement Grants Federal Agency: U.S. Department of Housing and Urban Development (“HUD”) Federal Award Number and Award Year: B-21-MC-06-0536, B-22-MC-06-0536, B-23-MC-06-0536, and B-20-MW-06-0536 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to the Guidance on Cash on Hand Quarterly Report (replaced the Federal Financial Report, SF-425) and financial reporting requirements in the cooperative agreement provisions, and 2 CFR 200.327: Quarterly reports: Program award recipients must submit Cash on Hand Quarterly Report reports to HUD quarterly, 30 days after the reporting period end date. Each report must cover all expenditures on the cooperative agreement from the start date of the reporting period to the reporting period end date. The following federal fiscal year quarter reporting period will be used for all quarterly reports, are due to HUD 30 days after the period end dates noted below: Reporting Period - Due Date of Report Quarter 1: 10/1-12/31 - January 30 Quarter 2: 1/1-3/31 - April 30 Quarter 3: 4/1-6/30 - July 30 Quarter 4:7/1-9/30 - October 30 Condition: The City did not submit the required Cash on Hand Quarterly Report in a timely manner. The Quarter 2 and Quarter 3 reports were both submitted on August 1, 2024. Cause: During the period the City was migrating to a new Enterprise Resource Planning software (ERP). The grant accountant missed the deadline due to the ERP migration deadlines. Effect or Potential Effect: Delay in filing the reports resulted in noncompliance with the compliance requirements. Questioned Costs: None. Context: See condition above for context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommend that the City update policies and procedures to strengthen the report submission process to ensure all required reports are properly reviewed and approved and submitted timely. When a report cannot be submitted by the due date, the City should request an extension from the funding agency and maintain a record of the approval. View of Responsible Officials: Management concurs the finding.

Corrective Action Plan

The City staff will be stricter in following its established internal control procedures to ensure that all reporting requirements are met and submitted timely. The City will also establish access to the Integrated Disbursement and Information System (IDIS) for another member of the Finance Department in a backup capacity. Where applicable, the City will request an extension from the funding agency and maintain a record of the approval when a report cannot be submitted by the due date.

About Reporting →
2024-003
Cash Management
MATERIAL WEAKNESSOTHER MATTERS

The City’s Ventura Pure Project is funded through multiple funding sources including WIFIA loans, Title XVI Water Reclamation and Reuse Program (the “Title XVI Program”), and funds accumulated through charges to rate payers. On September 18, 2023, the City received funding amendment no. 3 for another federal program, the Title XVI program, amending the award and allowing the City to claim expenditures incurred as far back as March 2022 for certain design, construction, and program management costs. Due to the funding amendment and reclassification of expenditures from WIFIA program to Title XVI program, WIFIA loans were over-drawn by $4,989,112 and $4,194,295 for Wastewater System and Water System, respectively, as of June 30, 2024. Cause: There was inadequate planning and grant management to properly identify the eligible costs for reimbursement in a timely matter. Although the amendment document was shared between the Water and Finance Department, there was ineffective communication between the departments related to the reimbursement and drawdown requests when there were changes in scope of work, period of performance, and reallocation of funding resources. Effect or Potential Effect: WIFIA loans were over drawn by $4,989,112 and $4,194,295 for Wastewater and Water System, respectively. Questioned Costs: None. Context: See condition above for context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommend the City update its policies and procedures for the reimbursement/drawdown process for projects funded with multiple funding sources and improve its communication between the departments to prevent duplicating reimbursement and drawdown requests. View of Responsible Officials: The City concurs with the finding. The City is committed to updating its policies and procedures for the reimbursement/drawdown process for projects funded with multiple funding sources and is committed to improving its communication between departments to prevent duplicating reimbursement and drawdown requests.

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Information of the Federal Programs: Assistance Listing Number: 66.958 Assistance Listing Title: Water Infrastructure Finance and Innovation (WIFIA) Federal Agency: U.S. Environmental Protection Agency Federal Award Number and Award Year: WIFIA – N20179CA, WIFIA – N20108CA Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): In accordance with 2024 OMB Compliance Supplement – 2 CFR Part 200 Appendix XI, Part 3 – Compliance Requirements – Cash Management, non-federal entities must comply with applicable program requirements for payment under loans, loan guarantees, interest subsidies, and insurance. Pursuant to the WIFIA Credit Agreement, Article II, Section 4. (a), “WIFIA Credit Facility proceeds shall be disbursed solely in respect of Wastewater/Water System Eligible Project Costs paid or incurred and approved for payment by or on behalf of the City. If the City intends to utilize the WIFIA Credit Facility proceeds to make progress payments for Project construction work performed under the Construction Contracts, the City shall demonstrate to the satisfaction of the WIFIA Credit Provider that such progress payments are commensurate with the cost of the work that has been completed.” Condition: The City’s Ventura Pure Project is funded through multiple funding sources including WIFIA loans, Title XVI Water Reclamation and Reuse Program (the “Title XVI Program”), and funds accumulated through charges to rate payers. On September 18, 2023, the City received funding amendment no. 3 for another federal program, the Title XVI program, amending the award and allowing the City to claim expenditures incurred as far back as March 2022 for certain design, construction, and program management costs. Due to the funding amendment and reclassification of expenditures from WIFIA program to Title XVI program, WIFIA loans were over-drawn by $4,989,112 and $4,194,295 for Wastewater System and Water System, respectively, as of June 30, 2024. Cause: There was inadequate planning and grant management to properly identify the eligible costs for reimbursement in a timely matter. Although the amendment document was shared between the Water and Finance Department, there was ineffective communication between the departments related to the reimbursement and drawdown requests when there were changes in scope of work, period of performance, and reallocation of funding resources. Effect or Potential Effect: WIFIA loans were over drawn by $4,989,112 and $4,194,295 for Wastewater and Water System, respectively. Questioned Costs: None. Context: See condition above for context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommend the City update its policies and procedures for the reimbursement/drawdown process for projects funded with multiple funding sources and improve its communication between the departments to prevent duplicating reimbursement and drawdown requests. View of Responsible Officials: The City concurs with the finding. The City is committed to updating its policies and procedures for the reimbursement/drawdown process for projects funded with multiple funding sources and is committed to improving its communication between departments to prevent duplicating reimbursement and drawdown requests.

Corrective Action Plan

The City concurs with the finding. The City is committed to updating its policies and procedures for the reimbursement/drawdown process for projects funded with multiple funding sources and is committed to improving its communication between departments to prevent duplicating reimbursement and drawdown requests. In fact, the City has already begun doing so. At the beginning of the current fiscal year (FY 2026), the City began split funding the Ventura Water Pure multi-funded projects at the point of preparation of requisitions, purchase orders, and invoices instead of performing the analysis and allocation after the fact as was done in the past. It was the result of this process that enabled the Accounting Division to identify duplicate reimbursements during its review of WIFIA drawdown requests. Once noted, the Accounting Division immediately communicated this issue to the Water Department, who then immediately notified the City’s Environmental Protection Agency (EPA) representative to determine next steps. Since then, in collaboration with the City’s EPA representative, the City did not draw down any WIFIA funds until the City incurred expenditures in excess of the amount overdrawn. Since implementing the above process, no additional duplicate reimbursement of drawdown requests has been noted. The City is committed to further strengthening its internal controls over cash management to prevent any such duplication of draw-down requests in the future. Additionally, the City’s Finance Department will increase collaboration with the City’s Water Department to further strengthen its grant policies and procedures and to further strengthen communication between the two departments to prevent duplicating reimbursement and drawdown requests.

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FY 2023-06-30

LOW-RISK AUDITEE$6,411,346 federal awards expended

FAC accepted this audit on March 28, 2024 — management decision was due September 28, 2024.

2023-001
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

The City did not submit monthly activity reports for the months of March 2023 to June 2023. Questioned Costs: None. Context: Only three of twelve monthly activity reports were not properly submitted for the fiscal year. The sample was a statically valid sample. Cause: Lack of adequate controls in place to effectively monitor grant compliance as a subrecipient of the State. Effect: The City did not comply with the reporting requirements of the grant agreement. Recommendation: We recommend the City implement procedures to ensure compliance with the reporting requirements of the State HCD grant agreement. View of Responsible Officials: There is no disagreement with the audit finding.

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Criteria or Specific Requirement: The grant agreement between the City and the State HCD requires the City to submit monthly activity reports and must continue through the receipt and approval by HCD of the Project Completion Report. The City should have internal controls designed to ensure compliance with this provision. Condition: The City did not submit monthly activity reports for the months of March 2023 to June 2023. Questioned Costs: None. Context: Only three of twelve monthly activity reports were not properly submitted for the fiscal year. The sample was a statically valid sample. Cause: Lack of adequate controls in place to effectively monitor grant compliance as a subrecipient of the State. Effect: The City did not comply with the reporting requirements of the grant agreement. Recommendation: We recommend the City implement procedures to ensure compliance with the reporting requirements of the State HCD grant agreement. View of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

The City program leads responsible for specific grants will read the compliance requirements related to those grants prior to commencement. They will then work with Finance and Accounting to determine what the compliance requirements are along with the related deadlines. Additionally, they will also determine who is responsible for each compliance requirement and monitor the grant from commencement to completion to ensure each of those requirements are being complied with by the responsible parties and by the related deadlines.

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FY 2022-06-30

LOW-RISK AUDITEE$11,836,124 federal awards expended

FAC accepted this audit on March 29, 2023 — management decision was due September 29, 2023.

2022-001
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCY

The City was not able to provide supporting documentation that the City verified the vendor was not suspended or debarred prior to entering the transaction. Questioned Costs: None. Context: There was only one vendor during FY 21-22 that was a covered transaction for this program. Cause: The City did not maintain supporting documentation that the verification of suspension or debarment was performed prior to entering into the contract. Effect: The auditor noted no instances of noncompliance with the provisions of suspension, and debarment; however, we were not able to verify that the City followed their internal controls to ensure the vendor was not suspended or debarred prior to entering the transaction. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the City implement procedures to ensure that verification documentation for suspension and debarment is maintained to support the City's internal control over compliance. View of Responsible Officials: There is no disagreement with the audit finding.

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Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. The City should have internal controls designed to ensure compliance with those provisions. Condition: The City was not able to provide supporting documentation that the City verified the vendor was not suspended or debarred prior to entering the transaction. Questioned Costs: None. Context: There was only one vendor during FY 21-22 that was a covered transaction for this program. Cause: The City did not maintain supporting documentation that the verification of suspension or debarment was performed prior to entering into the contract. Effect: The auditor noted no instances of noncompliance with the provisions of suspension, and debarment; however, we were not able to verify that the City followed their internal controls to ensure the vendor was not suspended or debarred prior to entering the transaction. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the City implement procedures to ensure that verification documentation for suspension and debarment is maintained to support the City's internal control over compliance. View of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Department of Transportation 2022-001 Highway Planning and Construction Cluster? Assistance Listing No. 20.205 Recommendation: We recommend the City implement procedures to ensure that verification documentation for suspension and debarment is maintained to support the City's internal control over compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City?s Procurement Manual requires all vendors to comply with the Code of Federal Regulations (CFR), specifically 2 CFR Part 200 when the expenditure of Federal funds is anticipated, whether a grant, cooperative agreement or reimbursement of disaster expenses. While the City makes great effort to ensure that vendors are in good standing with the federal government and are not suspended or debarred prior to engaging their services, the City agrees that additional procedures are necessary to better document the verification. Therefore, the City will implement the following procedures when the expenditure of Federal funds is anticipated: ? The City will require project managers (during the bidding process) to verify that all responsible vendors are in good standing with the federal government and are not suspended or debarred. The City will also require that the project managers include documentation of such verification for vendors to be advanced to the next level of the procurement process. Additionally, documentation of the verification of the selected bidder shall be filed and forwarded to the Grant Accountant for their files. ? The Grant Accountant will confirm receipt of verification noted above for each vendor charged to federal grants. If such verification has not been received, they will reach out to the responsible department to obtain such verification. Name(s) of the contact person(s) responsible for corrective action: Jason Williams, Accounting Manager Planned completion date for corrective action plan: 06/30/2023

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FY 2021-06-30

LOW-RISK AUDITEE$13,894,200 federal awards expendedNo findings recorded this year

FAC accepted this audit on June 28, 2022 — management decision was due December 28, 2022.

FY 2020-06-30

LOW-RISK AUDITEE$5,493,018 federal awards expended

FAC accepted this audit on March 28, 2021 — management decision was due September 28, 2021.

2020-001
Reporting
OTHER MATTERS

During our testing, we noted the annual submission of the CAPER report for the fiscal year ended June 30, 2020 submission was filed on January 5, 2021. Questioned costs: None Context: The City is required to submit the CAPER within 90 days of the end of the quarter. HUD has granted a waiver and extension to submit the report until December 28, 2020. Cause: There was an oversight by City staff in submitting the CAPER in the IDIS system. Effect: The City was not in compliance with the reporting requirements. Repeat Finding: This is a first year finding. Recommendation: We recommend that the City reviews its processes to allow for reporting to take place in timely manner. Views of responsible officials and planned corrective actions: CDBG staff will add a procedure to print screen the report confirmation to ensure that we have the submission confirmation prior to the due date. In addition, we will also include it on the Accounting Department?s list of required reporting that is managed by the Senior Accountant and Accounting Manager.

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Federal agency: U.S. Department of Housing and Urban Development Federal program title: Community Development Block Grant, Entitlements Grant Cluster CFDA Number: 14.218 Award Period: July 1, 2019 through June 30, 2020 Type of Finding: ? Other Matter Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. The grantee must submit the annual performance and evaluation report for the CDBG program 90 days after the end of the grantee?s program year (June 30) or for fiscal year 2020, the extended due date of December 28, 2020. Condition: During our testing, we noted the annual submission of the CAPER report for the fiscal year ended June 30, 2020 submission was filed on January 5, 2021. Questioned costs: None Context: The City is required to submit the CAPER within 90 days of the end of the quarter. HUD has granted a waiver and extension to submit the report until December 28, 2020. Cause: There was an oversight by City staff in submitting the CAPER in the IDIS system. Effect: The City was not in compliance with the reporting requirements. Repeat Finding: This is a first year finding. Recommendation: We recommend that the City reviews its processes to allow for reporting to take place in timely manner. Views of responsible officials and planned corrective actions: CDBG staff will add a procedure to print screen the report confirmation to ensure that we have the submission confirmation prior to the due date. In addition, we will also include it on the Accounting Department?s list of required reporting that is managed by the Senior Accountant and Accounting Manager.

Corrective Action Plan

U.S. Department of Housing and Urban Development The City of San Buenaventura respectfully submits the following corrective action plan for the year ended June 30, 2020. Audit period: July 1, 2019 ? June 30, 2020 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS? FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Housing and Urban Development 2020 ? 001 HUD ? CFDA No. 14.218 Recommendation: The City is required to submit the CAPER within 90 days of the end of the quarter. HUD has granted a waiver and extension to submit the report until December 28, 2020. During our testing, we noted the annual submission of the CAPER report for the fiscal year ended June 30, 2020 submission was filed on January 5, 2021. We recommend that the City reviews its processes to allow for reporting to take place in timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CDBG staff will add a procedure to print screen the report confirmation to ensure that we have the submission confirmation prior to the due date. In addition, we will also include it on the Accounting Department?s list of required reporting that is managed by the Senior Accountant and Accounting Manager. Name(s) of the contact person(s) responsible for corrective action: Terri Johnson, Accounting Manager. If the United States Department of Housing and Urban Development has questions regarding this schedule, please call Terri Johnson at 805-654-7704.

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FY 2019-06-30

$6,107,808 federal awards expendedNo findings recorded this year

FAC accepted this audit on April 16, 2020 — management decision was due October 16, 2020.

FY 2018-06-30

$7,753,321 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 26, 2019 — management decision was due September 26, 2019.

FY 2017-06-30

MATERIAL NONCOMPLIANCE DISCLOSEDLOW-RISK AUDITEE$2,009,705 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 29, 2018 — management decision was due September 29, 2018.

FY 2016-06-30

LOW-RISK AUDITEE$3,777,419 federal awards expended

FAC accepted this audit on March 29, 2017 — management decision was due September 29, 2017.

2016-004
Procurement & Suspension/Debarment
OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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