jBruno & Tervalon LLP - LouisianaFILE/00011F15.pdf · CREDIT CARDS. CONTINUED 3a. Procedure Obtain...

HOUSING AUTHORITY OF THE CITY OF SEIDELL

INDEPENDENT ACCOUNTANTS' REPORT ON

APPLYING AGREED-UPON PROCEDURES

FOR THE NINE MONTHS ENDED DECEMBER 31, 2015

jBruno & Tervalon LLP ^^Certified Public Accountants

TABLE OF CONTENTS

PAGE

INDEPENDENT ACCOUNTANTS' REPORT ON APPLYING AGREED-UPON PROCEDURES 1

CREDIT CARDS 2

ETHICS/RELATED PARTIES 7

OVER INCOME POLICY 11

Member American Institute of

Certified Public Accountants Society of Louisiana

Certified Public Accountants

JBruno & Tervalon Certified

LLP Public Accountants

Alcide J. Tervalon, Jr., CPA Waldo J. Moret, Jr.. CPA Paul K. Andoh, Sr.. CPA

Joseph A. Akanji, CPA

(Retired) Michael B. Bruno, CPA (2011)



To the Board of Commissioners Housing Authority of the City of SUdell Slidell, Louisiana

We have performed the procedures enumerated below, which was agreed to by the management of Housing Authority of the City of Slidell (HACS) and the Legislative Auditor, State of Louisiana, solely to assist the users in evaluating management's assertions about HACS's compliance with certain laws and regulations during the period from April 1, 2015 through December 31, 2015. Management of HACS is responsible for its fmancial records and compliance with applicable laws and regulations. This agreed-upon procedures engagement was performed in accordance with attestation standards established by the American Institute of Certified Public Accountants and applicable standards of Government Auditing Standards. The sufficiency of these procedures is solely the responsibility of the specified users of this report. Consequently, we make no representation regarding the sufficiency of the following proeedures described either for the purpose for which this report has been requested or for any other purpose.

4298 ELYSIAN FIELDS AVENUE NEW ORLEANS, LA 70122 (504) 284-8733 FAX (504) 284-8296

6424 LAKEOVER RD., SUITE A JACKSON, MS 39213

(601) 366-2344 FAX (601) 366-8440



(CONTINUED)

The procedures performed, our findings and management's response, as applicable are summarized as follows:

CREDIT CARDS

1- Procedure

Determine if management maintains a listing of all active credit and debit card numbers and the name(s) of the person who maintains possession of the cards.

Finding

The HACS maintains a listing of all active credit and debit cards to include the card nmnbers (last four digits only) and the cards are maintamed by the Executive Director.

2. Procedure

Obtain and review HACS's written policies and procedures for credit and debit cards and determine if the following are addressed:

How cards are controlled Allowable business use Documentation requirements Required approvers and authorized users Monitoring card usage Approval required to open a credit card account Prohibition on cash advance

Finding

HACS has a Board approved written credit card/line of credit policy. The referenced policy generally addresses the above procedures.



(CONTINUED)

CREDIT CARDS. CONTINUED

3a. Procedure

Obtain the monthiy statements for all credit cards used during the period from April 1,2015 through December 31,2015, and select for detailed review two (2) statements for each card.

Finding

We obtained monthly statements and judgementally selected two (2) for each of the five (5) credit cards for a total of ten (10) statements.

Procedure

For each of the ten (10) statements selected, we performed the following procedures:

Obtained HACS's supporting documentation for all purchases/charges shown on the selected monthly statements and determined if each purchase and/or charge was supported by:

a. An original itemized receipt or contract, if applicable;

b. Documentation and determination of the business/public purpose to include other documentation required by HACS's policy; and

c. Documented evidence that the purchase was in accordance with established thresholds.



(CONTINUED)


Finding

0 In one (1) instance, we noted no original receipt for two (2) purchases totaling $666.75.

o In twelve (12) instances, we were xmable to evidence documented basis for the procurement of goods and/or services via the use of purchase order(s), quote(s), etc.

o In one (1) instance, we were unable to evidence the documented purpose for purchase.

0 In one (1) instance, the purchase was supported by an invoice from the vendor.

o In six (6) instances, we noted no original receipts but detail statements itemizing purchases attached to support items purchased and/or charged.

Management's Response

Management will continue to provide continuous training and oversight to ensure compliance with established procurement policies and procedures relative to the use of credit cards.



(CONTINUED)


3b. Procedure

Determine if there was any duplication of expenses by comparing all travel and related purchases on the selected statements to the appropriate persons expense.

Finding

None noted in our review of the selected statements.

3c. Procedure

Detennine if each monthly credit card statement selected was reviewed and approved, in writing before the bill was paid, by someone other than the person making the purchase.

Finding

0 In two (2) instances, we noted no documented evidence of prior approval of paid invoice.


Management will ensure documented evidence for all required approvals in future invoices prior to payment.



(CONTINUED)


3d. Procedure

Detennine if finance charges and/or late fees were assessed on the selected monthly statements.

Finding

o In three (3) instances, we noted the payment of late fees totaling $58.24.


Management will re-evaluate its bill paying schedule which is the 15^ of each month to eliminate any potential for late fees.

3e. Procedure

Determine if any purchases or re-occurring expenses found on the selected statements for materials or supplied exceeded $10,000. Were the purchases made in compliance with the Louisiana Public Bid Law.

Finding

None noted for the selected statements reviewed.



(CONTINUED) ~~~

ETHICS/RELATED PARTIES

4. Procedure

Obtain and review HACS's written policies and procedxares on ethics and detennine if they address:

a) The prohibitions as defined in Louisiana Revised Statute (R.S.) 42:1111-1121;

b) Actions to be taken if an ethics violation takes place;

c) Systems to monitor possible ethics violations; and

d) Requirement that all employees, including elected official, annually attest through signature verification that they have read H AC S' s ethics policy.

Finding

HACS has a written and formalized personnel policy on ethics which addresses selected requirements ofR.S. 42:1111-1121.

In addition, HACS has a required disclosure practice for all employees and board members for immediate family member participation in its housing program.

5. Procedure

Randomly select five (5) employees:

• Determine if a signed verification of having read the ethics policy is located in the employee file for the period under review;



(CONTINUED)

ETHICS/RELATED PARTIES. CONTINUED

5. Procedure. Continued

Determine if evidence is maintained to indicate required ethics training was completed;

Determine if there were any ethics violation reported to HACS during the year;

Detennine if the actions HACS took to investigate alleged ethics violations, and corrective actions taken, agreed to HACS's ethics policy.

Finding

As previously discussed, HACS has a personnel policy which includes a section on ethics for all employees.

For the period under review, we noted the following:

a) No documented evidence in employee file to document verification of having read the personnel manual.

b) Ethics training were completed by staff as of the date of this report.

c) No ethics violations were noted through discussion with management and review of personnel files.


Motion 2016-12 was passed on November 22, 2016 incorporating the content of R.S. 42:111-1121 into the Personnel Policy. HACS will expand upon a policy specific to Board members to become effective immediately.



(CONTINUED)

ETHICS/RELATED PARTIES. CONTINUED

6. Procedure

Obtain from management a list of immediate family members of each board member as defmed by R.S, 42:1101-1124 (the code of ethics); a Ust of all employees paid during the period under examination, and a list of outside business interests of all board members, immediate family members of board members, the executive director and other employees.

a) Determine whether any of those employees paid during the period imder examination are also included on the hsting of immediate family of board members;

b) Determine whether HACS made any payments to entities on the list of outside business interests of board members, immediate family members of board members, and employees; and

c) Detennine if the executive director has a residence in any properties owned by HACS.

Finding

For two (2) of five (5) board members serving during the period from April 1, 2015 through December 31, 2015, HACS was unable to provide a listing of immediate family members for each of the referenced board member as defmed by R.S. 42:1101-1124. The two (2) board member's terms have expired.

For current employees, HACS provided an independent confinnation from all current employees, listing immediate family members as defmedby R.S. 42:1101-1124.



(CONTINUED)

ETHICS/RELATED PARTIES, CONTINUED

Finding. Continued

For the period under review, we noted the following:

a) Management of HACS provided a certification of no outside business interest from three (3) of the five (5) board members. The two (2) have expired terms;

b) None of the employees listed and paid during the period under examination are on the listing of immediate family members provided by board members;

c) For the two (2) board members whose terms have expired, we were unable to detennine whether HACS made any payments to entities of outside business interests and any immediate family members; and

d) Detennined that the executive director has no residence in any properties owned by HACS.


Management will through implementation of its board adopted revised policy, ensure compliance with the ethics and related party aspects ofR.S. 42:1101-1124.

10



(CONTINUED)

OVER INCOME POLICY

7. Procedvire

Determine if HACS has established occupancy policies that include the eviction of public housing tenants who are over the income limit for eligibility to participate in public housing programs. If so, determine if the policies address:

a) Appropriate time limits during which overincome families can remain in public housing;

b) The timeframe needed to execute an eviction notice to the overincome family;

c) What specific classes are exempt from eviction (such as elderly persons and persons with disabihties, as long as civil rights laws are not violated); and

d) Asset limitations of overincome families (as long as the limitations meet state and local requirements).

Finding

HACS's approved Admission and Occupancy Policy and its Administrative Plan pursuant to the requirements of HUD regulations, subjects all tenants to annual and interim re-certifications for ehgibility and continued participation in its housing program.

11



(CONTINUED) ~

We were not engaged to, and did not, perform an examination, the objective of which would be the expression of an opinion onmanagement's assertions. Accordingly, we do not express such an opinion. Had we perfonned additional procedures, other matters might have come to our attention that would have been reported to you.

HACS's response to the findings in our agreed-upon procedures is described in this report under the caption "Management's Response". We did not perfonn any procedures on HACS's response and, accordingly, we express no opinion on it

This report is intended solely for the use of management, Board of Commissioners, and the Legislative Auditor, State of Louisiana, and should not be used by those who have not agreed to the procedures and taken responsibility for the sufficiency of the procedures for their purposes. Under Louisiana Revised Statue 24:513, this report is distributed by the Legislative Auditor as a public document.

BRUNO &TERVALON LLP CERTIFIED PUBLIC ACCOUNTANTS New Orleans, Louisiana

November 28, 2016

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