HomeMy WebLinkAboutMINUTES - 02122008 - C.2 HOUSING AUTHORITY OF THE COUNTY OF CONTRA COSTA
TO: BOARD OF COMMISSIONERS
FROM: Joseph Villarreal, Executive Director
DATE: February 12, 2008
SUBJECT: ACCEPTANCE OF AUDIT REPORT FOR FISCAL YEAR ENDED MARCH 31, 2007
SPECIFIC REQUEST(S) OR RECOMMENDATION(S) & BACKGROUND AND JUSTIFICATION
I. RECOMMENDED ACTION:
ACCEPT financial audit report for the period April 1, 2006 through March 31, 2007,
performed by Harn & Dolan CPA's, Walnut Creek, California.
II. FINANCIAL IMPACT:
Funding has been provided for the audit contract in the Housing Authority's Fiscal Year
2006/2007 Consolidated Operating Budget.
III. REASONS FOR RECOMMENDATION/BACKGROUND
The Authority (HACCC) is required by the U. S. Department of Housing & Urban Development
(HUD) to complete an independent audit of its financial statements and business activities annually.
Harn & Dolan has completed their audit of the financial records of the Housing Authority of
the County of Contra Costa and all financial records of the Housing Authority are in order. No
material findings were identified.
Two, non-financial reportable conditions were made. These findings are not financially
material and so are not reported to HUD. However, they highlight programmatic deficiencies that
need to be addressed. Harn & Dolan noted that during the previous year's audit, annual
recertifications for Section 8 clients had not been conducted on a large majority of sample files.
They also noted that the current audit showed errors in the amounts paid to graduates of the
Authority's Family Self-sufficiency program (FSS).
On the matter of recertifications, Harn & Dolan indicated that the Authority had developed
and implemented internal control procedures during the fiscal year. However, because this was
the first year these controls were implemented, they were not able to conclude whether or not they
had been effective. They, or another auditor, since we are currently out to bid for auditing
services, will make that determination in next year's audit. In the meantime, HACCC will continue
implementation and use of these new controls. Concerning the FSS program, the Authority is
currently conducting an internal audit of all payments made to graduates during the past fiscal
CONTINUED ON ATTACHMENT: YES SIGNATURE
Joseph Villarreal,Executive Director
RECOMMENDATION OF EXECUTIVE DIRECTOR RECOMMENDATION OF BOARD COMMITTEE
APPROVE OTHER
SIGNATURE(S):
ACTION OF BOARD ON ; bru�,r(a �Z� ��$ APPROVED AS RECOMMENDED V__�OT/ER
VOTE OF COMMISSIONERS
Q� I HEREBY CERTIFY THAT THIS IS A
UNANIMOUS (ABSENT Y ) TRUE AND CORRECT COPY OF AN
AYES: _ NOES: ACTION TAKEN AND ENTERED ON THE
ABSENT: _ ABSTAIN: MINUTES OF THE BOARD OF
COMMISSIONERS ON THE DATE SHOWN.
ATTESTED Febn�, �I 12-1 ZAXO
JOSEPH V LARK AL,CLERK OF
THE BOARD OF COMMISSIONERS
cc: CAO Office AND EXECUTIVE DIRECTOR
BY6 b"L/ v�LDEPUTY
1-1:Uudyl-layes\MSOFI�ICE\WINWORD\BOARD\BO-Al-JDI-I'FYI=3-31-07.doc
year. Corrections are being made as appropriate and new internal procedures are being
developed to ensure that all graduate payments are calculated correctly.
Harn & Dolan also addressed the status of two findings from the audit report for the fiscal
year ending March 31, 2006. The first concerned controls over the posting of rent in the public
housing program. That audit noted inconsistencies and inaccuracies in the posting of rent to both
the general and tenant ledgers. There were also inconsistencies in the reimbursement of utility
allowance expenses to clients. Harn & Dolan stated that the Authority has improved in these
areas and did not list this item as a finding again. While there are still some inconsistencies that
HACCC needs to address, the differences are immaterial. The second previous finding concerned
the annual recertifications for Section 8 clients noted above. As stated previously, another year
must pass before Harn & Dolan are able to assess the efficacy of these changes.
The Auditor's Report, the report on internal controls over financial reports, the report on
programmatic compliance, the Status of Prior Audit Findings and the Schedule of Findings and
Questioned Costs are all attached. A full copy of the audit is on file with the Clerk of the Board.
IV. CONSEQUENCES OF NEGATIVE ACTION:
Should the Board of Commissioners elect not to accept the financial audit report as
performed by the certified public accountancy firm of Harn & Dolan, it would become necessary to
expend additional funds to either redo the financial audit report or contract with another certified
public accountancy firm to conduct an audit of HACCC's finances and programs.
bo-audit
Harn & Dolan
Certified Public Accountants
2423 Stirrup Court
Walnut Creek,California 94596-6526
(925)280-1693 Fax(925)938-4829
INDEPENDENT AUDITORS' REPORT
To the Board of Commissioners
Housing Authority of the
County of Contra Costa
Martinez, California
We have audited the accompanying financial statements of the business-type activities, the aggregate
discretely presented component units, and the major fund of the Housing Authority of the County of
Contra Costa,California,as of and for the year ended March 31,2007,which collectively comprise the
Authority's basic financial statements as listed in the table of contents. These financial statements are
the responsibility of the Housing Authority of the County of Contra Costa, California's, management.
Our responsibility is to express opinions on these financial statements based on our audit. We did not
audit the financial statements of HACCC Casa Del Rio, Inc, a California Nonprofit Public Benefit
Corporation and CDR Senior Housing Associates,a California Limited Partnership,which are combined
and reported as blended component units titled Casa Del Rio Housing in the fund financial statements.
We did not audit the financial statements ofDeAnza Housing Corporation,a California Nonprofit Public
Benefit Corporation and DeAnza Gardens L.P. a California Limited Partnership,which are combined
and reported as discretely presented component units titled Component Units in the Authority-wide
financial statements. Those financial statements were audited by other auditors whose reports thereon
have been furnished to us,and our opinion, insofar as it relates to the amounts included for Component
Units and Casa Del Rio Housing is based on the reports of the other auditors.
We conducted our audit in accordance with auditing standards generally accepted in the United States
of America and the standards applicable to financial audits contained in Government Auditing
Standards,issued by the Comptroller General ofthe United States. Those standards require that we plan
and perform the audit to obtain reasonable assurance about whether the financial statements are free of
material misstatement. An audit includes examining,on a test basis, evidence supporting the amounts
and disclosures in the financial statements. An audit also includes assessing the accounting principles
used and significant estimates made by management, as well as evaluating the overall financial
statement presentation. We believe that our audit and the reports of other auditors provide a reasonable
basis for our opinions.
In our opinion,based on our audit and the reports of other auditors,the financial statements referred to
above present fairly, in all material respects, the respective financial position of the business-type
activities, the aggregate discretely presented component units, and the major fund of the Housing
Authority of the County of Contra Costa,California,as of March 31,2007,and the respective changes
in financial position and cash flows thereof for the year then ended in conformity with accounting
principles generally accepted in the United States of America.
In accordance with Government Auditing Standards, we have also issued a report dated September 7,
2007, on our consideration of the Housing Authority of the County of Contra Costa's internal control
over financial reporting and on our tests of its compliance with certain provisions of laws,regulations,
contracts and grant agreements and other matters. The purpose of that report is to describe the scope
of our testing of internal control over financial reporting and compliance and the results of that testing,
and not to provide an opinion on the internal control over financial reporting or on compliance. That
report is an integral part of an audit performed in accordance with Government Auditing Standards and
should be considered in assessing the results of our audit.
The management's discussion and analysis and the schedule of relevant statistics on pages 3 through
11 and page 62, are not a required part of the basic financial statements but are supplementary
information required by accounting principles generally accepted in the United States of America. We
and the other auditors have applied certain limited procedures,which consisted principally of inquiries
of management regarding the methods of measurement and presentation of the required supplementary
information. However, we did not audit the information and express no opinion on it.
Our audit was conducted for the purpose of forming opinions on the financial statements that
collectively comprise the Housing Authority of the County of Contra Costa,California,basic financial
statements. The accompanying Schedule of Expenditures of Federal Awards is presented for the
purpose of additional analysis as required by the U.S. Office of Management and Budget Circular A-
133,Audits of States, Local Governments, and Non-Profit Organizations, and is not a required part of
the basic financial statements. The accompanying Financial Data Schedule is presented for purposes
of additional analysis as required by U.S.Department of Housing and Urban Development, Real Estate
Assessment Center and is not a required part of the basic financial statements. The accompanying
Combining Schedules for Use in the County CAFR are presented for the purpose ofadditional analysis as
required by the County of Contra Costa and are not a required part of the basic financial statements.
Finally,the accompanying Statement of Completed Capital Fund Program Projects is presented for the
purpose ofadditional analysis as required by the U.S.Department ofHousing and Urban Development and
is not a required part ofthe basic financial statements. Such information has been subjected to the auditing
procedures applied in the audit of the basic financial statements and,in our opinion,is fairly stated,in all
material respects, in relation to the basic financial statements taken as a whole.
September 7,2007
2
Harn & Dolan
Certified Public Accountants
2423 Stirrup Court
Walnut Creek, California 94596-6526
(925) 280-1693 Fax(925) 938-4829
INDEPENDENT AUDITORS' REPORT ON INTERNAL CONTROL OVER FINANCIAL
REPORTING AND ON COMPLIANCE AND OTHER MATTERS BASED
ON AN AUDIT OF FINANCIAL STATEMENTS PERFORMED IN
ACCORDANCE WITH GOVERNMENTAUDITING STANDARDS
To the Board of Commissioners
Housing Authority of the
County of Contra Costa
Martinez, California
We have audited the accompanying financial statements ofthe business-type activities,the aggregate discretely
presented component units, and the major fund of the Housing Authority of the County of Contra Costa,
California, as of and for the year ended March 31, 2007,which collectively comprise the Housing Authority
of the County of Contra Costa,California's basic financial statements and have issued our report thereon dated
September 7,2007. We conducted our audit in accordance with auditing standards generally accepted in the
United States of America and the standards applicable to financial audits contained in Government Auditing
Standards, issued by the Comptroller General of the United States.
Internal Control Over Financial Reporting
In planning and performing our audit, we considered the Housing Authority of the County of Contra Costa,
California's internal control over financial reporting as a basis for designing our audit procedures for the
purpose of expressing our opinions on the financial statements,but not for the purpose of expressing an opinion
on the.effectiveness of the Housing Authority of the County of Contra Costa,California's internal control over
financial reporting. Accordingly,we do not express an opinion on the effectiveness of the Housing Authority
of the County of Contra Costa,California's internal control over financial reporting.
A control deficiency exists when the design or operation of a control does not allow management or employees,
in the normal course of performing their assigned functions,to prevent or detect misstatements on a timely basis.
A significant deficiency is a control deficiency,or combination ofcontrol deficiencies,that adversely affects the
Housing Authority of the County of Contra Costa,California's ability to initiate,authorize,record,process,or
report financial data reliably in accordance with generally accepted accounting principles such that there is more
than a remote likelihood that a misstatement of the Housing Authority County of Contra Costa, California's
financial statements that is more than inconsequential will not be prevented or detected by the Housing Authority
of the County of Contra Costa, California's internal control.
A material weakness is a significant deficiency,or combination of significant deficiencies,that results in more than
a remote likelihood that a material misstatement of the financial statements will not be prevented or detected by
the Housing Authority of the County of Contra Costa, California's internal control.
Our consideration of the.internal control over financial reporting was for the limited purpose described in the first
paragraph of this section and would not necessarily identify all deficiencies in internal control that might be
significant deficiencies or material weaknesses. We did not identify any deficiencies in internal control over
financial reporting that we consider to be material weaknesses, as defined above.
64
Compliance and Other Matters
As part of obtaining reasonable assurance about whether the Housing Authority of the County of Contra Costa,
California's financial statements are free of material misstatement,we performed tests of its compliance with
certain provisions of laws,regulations,contracts,and grant agreements,noncompliance with which could have
a direct and material effect on the determination of financial statement amounts. However, providing an
opinion on compliance with those provisions was not an objective of our audit, and accordingly, we do not
express such an opinion. The results of our tests disclosed no instances of noncompliance or other matters that
are required to be reported under Government Auditing Standards.
We noted certain matters that we reported to management of the Housing Authority of the County of Contra
Costa, California, in a separate letter dated September 7, 2007.
This report is intended solely for the information and use of the County Board of Supervisors,the Advisory
Housing Commission,management, others within the organization,and federal awarding agencies and pass-
through entities and is not intended to be and should not be used by anyone other than these specified parties.
September 7,2007
65
Harn & Dolan
Certified Public Accountants
2423 Stirrup Court
Walnut Creek, California 94596-6526
(925) 280-1693 Fax(925) 938-4829
INDEPENDENT AUDITORS' REPORT ON COMPLIANCE WITH REQUIREMENTS
APPLICABLE TO EACH MAJOR PROGRAM AND INTERNAL CONTROL
OVER COMPLIANCE IN ACCORDANCE WITH OMB CIRCULAR A-133
To the Board of Commissioners
Housing Authority of the
County of Contra Costa
Martinez, California
Compliance
We have audited the compliance of the Housing Authority of the County of Contra Costa,California,with the
types of compliance requirements described in the U.S. Office of Management and Budget(OMB) Circular
A-133 Compliance Supplement that are applicable to each of its major federal programs for the year ended
March 31,2007. The Housing Authority of the County of Contra Costa,California's major federal programs
are identified in the summary of auditor's results section of the accompanying schedule of findings and
questioned costs. Compliance with the requirements of laws,regulations,contracts, and grants applicable to
each of its major federal programs is the responsibility ofthe Housing Authority ofthe County of Contra Costa,
California's management. Our responsibility is to express an opinion on the Housing Authority of the County
of Contra Costa, California's compliance based on our audit.
We conducted our audit of compliance in accordance with auditing standards generally accepted in the United
States.of America; the standards applicable to financial audits contained in Government Auditing Standards,
issued by the Comptroller General of the United States; and OMB Circular A-133, Audits of States, Local
Governments, and Non-Profit Organizations. Those standards and OMB Circular A-133 require that we plan
and perform the audit to obtain reasonable assurance about whether noncompliance with the types of
compliance requirements referred to above that could have a direct and material effect on a major federal
program occurred. An audit includes examining,on a test basis,evidence about the Housing Authority of the
County of Contra Costa,California's compliance with those requirements and performing such other procedures
as we consider necessary in the circumstances. We believe that our audit provides a reasonable basis for our
opinion. Our audit does not provide a legal determination on the Housing Authority of the County of Contra
Costa, California's compliance with those requirements.
In our opinion the Housing Authority of the County of Contra Costa, California, complied, in all material
respects,with the requirements referred to above that are applicable to each of its major federal programs for
the year ended March 31, 2007. However, the results of our auditing procedures disclosed instances of
noncompliance with those requirements,which are required to be reported in accordance with OMB Circular
A-133 and which are described in the accompanying schedule of findings and questioned costs as items III-
2007-A and III-2007-13.
Internal Control Over Compliance
The management of the Housing Authority of the County of Contra Costa, California is responsible for
establishing and maintaining effective internal control over compliance with requirements of laws,regulations,
contracts,and grants applicable to federal programs. In planning and performing our audit,we considered the
Housing Authority of the County of Contra Costa, California's internal control over compliance with
66
requirements that could have a direct and material effect on a major federal program in order to determine our
auditing procedures for the purpose of expressing our opinion on compliance, but not for the purpose of
expressing an opinion on the effectiveness of internal control over compliance. Accordingly,we do not express
an opinion on the effectiveness of the Housing Authority of the County of Contra Costa,California's internal
control over compliance.
Our consideration of the internal control over compliance was for the limited purpose described in the
preceding paragraph and would not necessarily identify all deficiencies in the internal control that might be
significant deficiencies or material weaknesses as defined below. However,as discussed below,we identified
a certain deficiency in internal control over compliance that we consider to be a significant deficiency.
A control deficiency in an entity's internal control over compliance exists when the design or operation of a
control does not allow management or employees,in the normal course of performing their assigned functions,
to prevent or detect noncompliance with a type of compliance requirement ofa federal program on a timely basis.
A significant deficiency is a control deficiency,or combination of control deficiencies,that adversely affects the
entity's ability to administer a federal program such that there is more than a remote likelihood that noncompliance
with a type ofcompliance requirement ofa federal program that is more than inconsequential will not be prevented
or detected by the entity's internal control. We consider the deficiency in internal control over compliance
described in the accompanying schedule of findings and questioned costs as item II I-2007-B to be a significant
deficiency.
A material weakness is a significant deficiency,or combination of significant deficiencies,that results in more than
a remote likelihood that material noncompliance with a type ofcompliance requirement ofa federal program will
not be prevented or detected by the entity's internal control. We did not consider any ofthe deficiencies described
in the accompanying schedule of findings and questioned costs to be material weaknesses.
We have audited the financial statements of the business-type activities, the discretely presented component
units and the major fund of the Housing Authority of the County of Contra Costa, California as of and for the
year ended March 31, 2007, and have issued our report thereon dated September 7, 2007. Our audit was
performed for the purpose of forming our opinions on the financial statements that collectively comprise the
Housing Authority of the County of Contra Costa,California's basic financial statements. The accompanying
schedule of expenditures of federal awards is presented for purposes ofadditional analysis as required by OM B
Circular A-133 and in not a required part of the basic financial statements. Such information has been
subjected to the auditing procedures applied in the audit of the basic financial statements and, in our opinion,
is fairly stated, in all material respects, in relation to the basic financial statements taken as a whole.
The Housing Authority of the County of Contra Costa, California's response to the findings identified in our
audit are described in the accompanying schedule of findings and questioned costs. We did not audit the
Housing Authority of the County of Contra Costa, California's response and, accordingly, we express no
opinion on it.
This report is intended solely for the information and use of the County Board of Supervisors, the Advisory
Housing Commission, management, others within the organization, and federal awarding agencies and pass-
through entities and is not intended to be and should not be used by anyone other than these specified parties.
September 7, 2007
67
HOUSING AUTHORITY OF THE COUNTY OF CONTRA COSTA
STATUS OF PRIOR AUDIT FINDINGS
MARCH 31,2007
The audit report for the fiscal year ended March 31,2006,contained the following findings. The following
is a discussion of the status of these findings.
Finding II-2006-1 - Public Housing Programs - Controls over the Posting of Dwelling Rent(CFDA
#14.850)
During our prior audit,we noted inconsistencies and inaccuracies in the posting of the
monthly rent to the general ledger and the tenant ledgers (subsidiary ledgers). We
noted that adjustments were not always posted to the general ledger and the subsidiary
ledger in the - same period, throwing the two out of agreement. We noted
inconsistencies in the reimbursement of utility allowances owed to extremely low
income families.
These conditions caused us to question the accuracy of the dwelling rent revenue and
tenant accounts receivable balance as of March 31,2006. We recommended that the
Authority improve their controls over the accounting and recording of tenant rent
revenue.
Although it does appear that the Authority has made strides in the improvement of
controls over the accounting and recording of the tenant rent revenue, we continued
to note inconsistencies between the general ledger and the subsidiary ledgers. All
differences are immaterial. We reported this matter to management of the Housing
Authority of the County of Contra Costa, California in a separate letter dated
September 7, 2007.
Finding Ill.-2007-A Housing Choice Voucher Program-TenantEligibilityand Annual Recertification
(CFDA#14.871)
During our prior audit,we noted that recertifications of family income and composition
were not being performed on an annual basis as required by HUD regulations.
During our current audit, we noted improvement in the Authority's compliance with
the HUD regulation requiring annual recertification of family income and composition.
However,we continued to note instances in which more than fourteen months spanned
the time between the current recertification and the last recertification. It will take
another year's cycle to determine the Authority's full compliance with these
regulations. See also item II1-2007-A in the schedule of finding and questioned costs.
68
HOUSING AUTHORITY OF THE COUNTY OF CONTRA COSTA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
MARCH 31,2007
Section I- Summary of Auditors' Results
Financial Statements
Type of auditors'report issued: unqualified
Does the report contain a going concern explanatory paragraph? no
Internal control over financial reporting:
Material weaknesses identified? no
Reportable conditions identified not considered to be material weaknesses? no
Noncompliance material to financial statements noted? no
Federal Awards
Internal control over major programs:
Material weaknesses identified? no
Reportable conditions identified not considered to be material weaknesses? yes
Are any known questioned costs reported? no
Type of auditors' report issued on compliance for major programs: unqualified
Any audit findings disclosed that are required to be reported in accordance
with OMB Circular A-133, Section .510(a)? yes
Identification of major programs:
Shelter Plus Care Program 14.238
Public Housing Program 14.850
Housing Choice Voucher Program 14.871
Dollar threshold used to distinguish between Type A and Type B programs $ 2,581,314
Auditee qualified as low-risk auditee? no
Section II-Financial Statement Findings
None
69
HOUSING AUTHORITY OF THE COUNTY OF CONTRA COSTA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
MARCH 31,2007
(Continued)
Section III- Federal Award Findings
III-2007-A Housing Choice Voucher Program - Tenant Eligibility and Annual Recertification
(CFDA#14.8711
Criteria - HUD requires the Authority to review each participating family's income and
composition on an annual basis. The purpose of these annual recertifications is to establish
the family's continued eligibility and to calculate the tenant's portion of the dwelling rent and
the Housing Assistance Payment(HAP)owed by the Authority.
Condition -During our prior review of the Housing Choice Voucher tenant files, we noted
that annual recertifications had not been performed for a large majority of the samples
selected. The gaps in recertifications ranged from 1 to 3 years. This condition improved
during the current fiscal year, with most of the samples tested having a recertification
performed during the current fiscal year. We noted one sample for which a recertification has
not been completed since July 2005.
Questioned Costs-There are no specific questioned costs. HAP would likely have changed
if the annual recertification had been performed in a timely manner. It is unknown how this
would have effected the Authority's financial statements.
Cause- Internal control procedures were developed and implemented during the fiscal year
ended March 31, 2007,to ensure that recertifications of family income and composition are
being performed on an annual basis. However, due to the fact that this is the first year of
implementation of these revised controls, we can not conclude on the effectiveness of these
controls and whether or not recertifications are being completed on an annual basis. Another
year of implementation is needed to make this conclusion.
Effect-A control deficiency in the Authority's internal control over compliance with HUD
regulations regarding the annual recertification of participant income,family composition,and
the calculation of HAP continues to exist.
Recommendation -We recommend that the Authority continue to improve and implement
their controls to insure compliance with HUD regulations regarding the annual recertification
of participant income, family composition and the determination of HAP.
Authority's Response-As previously reported,a work plan was developed and put in place.
This plan achieved getting most of the recertifications up to date, what we are now adding is
a monitoring component to assure all recertifications are completed.
III-2007-B Housing Choice Voucher Program -Family Self Sufficiency (CFDA#14.871)
70
1
HOUSING AUTHORITY OF THE COUNTY OF CONTRA COSTA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
MARCH 31,2007
(Continued)
Criteria-HUD requires the Authority to administer a family self sufficiency(FSS)program.
The program is offered to any interested clients of the Housing Choice Voucher Program. The
program requires a five year commitment by the participant. During that time,the participant
is required to set self sufficiency goals, seek employment, and perform other tasks to meet
their self sufficiency goals. The Authority is required to support their clients self sufficiency
needs by providing supportive services such as employment counseling,credit counseling,and
other self-help workshops and sessions. The client is rewarded for their self sufficiency efforts
with an escrow account that accumulates the increases in their rental payments, due to their
self sufficiency efforts,until they graduate from the program. At graduation,they are entitled
to receive the escrow account plus any interest earned on the account. The Authority is also
required to provide an annual accounting of the balances in the escrow account to each
participant.
Condition - During our review of the FSS program we noted errors in the amounts paid to
graduates of the program. We noted that escrow statements were not sent to the program
participants for the fiscal year ended March 31, 2007.
Questioned Costs - We tested 37% of the escrow payments made to graduates during the
fiscal year ended March 31, 2007. Of the two payments tested; one was overpaid, while the
other was underpaid. The net error was an underpayment of$709. The Authority will, in all
likelihood,correct the underpaymenfby making an additional payment to the participant. This
will leave the overpayment of$1,799 as outstanding.
Cause- Effective internal control procedures have not been developed and implemented to
ensure that the correct final escrow is paid to participants upon graduation from the FSS
program.
Effect-A significant deficiency exists in the Authority's controls over the administration of
escrow balances and the final payment of escrow balances to participants of the FSS program.
Recommendation -We recommend that the Authority improve their controls to insure that
final payments to program participants are accurate. We also recommend that the Authority
provide each participant with an annual statement of their escrow account.
Authority's Response - The Authority is conducting an internal audit of all graduate
payments during this fiscal year. Underpayments will be corrected, overpayments will be a
reduction to HAP expense and incurred by administrative fees. Further,a new internal process
will be established that will provide for a complete audit of all graduate payments that are
made.
71