Forensic and Financial Performance Review for the Town of Greenburgh

EFPR Group, CPAs, PLLC | 1/27/26

The following are excerpts from the EFPR report, under the section headings in which they appear.

Property Taxes and Real Estate Taxes (pages 4-6)

• Improper Treatment of Dishonored Tax Payments

  "We identified several instances where no additional interest or penalties were applied to payments made via checks that were subsequently returned by the bank.... Failure to asses the appropriate interest and tax penalties resulted in some taxpayers not being charged for the period during which their property tax liabilities remained unpaid, contrary to legal requirements."

• Delinquent Property Taxes "The review of the delinquent tax collection report identified 587 accounts with an aggregate outstanding balance of $29,390,813, as of December 31, 2024. Upon further review, we noted some of the outstanding balances trace as far back as 1967 and also include approximately $11,400,000 in penalties and interest....

  "The table below summarizes the amounts owed by tax year, including the penalties and interest noted above: 1967-1979 $ 22,825

  1980-1989 57,992

  1990-1999 142,545 2000-2009 3,527,057 2010-2019 11,222,153 2020-2024 14,418,241 Subtotal $ 29,390,813 "Large outstanding tax receivable balances has a double effect for the Town. In Westchester County, municipalities like Greenburgh are tasked with billing and collecting county and school real property taxes for the districts within their jurisdiction. If balances go unpaid, the Town is responsible to make the county and affected districts whole, placing the Town in a deficit situation."

• Lien and Foreclosure Process "It is our understanding through our interview, the foreclosure process has been stalled for several years.... The sale or transfer of encumbered properties may indicate gaps in the monitoring and enforcement of lien satisfaction at closing, suggesting a need for improved coordination with local real estate professionals, attorneys, and title agencies. Another, more likely possibility, is that the lien was never filed correctly with the County."

Water Department (pages 6-8)

• Insufficient Monitoring and Collection of Delinquent Accounts "At December 31, 2023, total receivables amount to $3,099,679, with a substantial portion, $1,237,776, or nearly 40%, outstanding for over 60 days. This indicates that a large number of accounts remain unpaid well beyond typical billing cycles, suggesting that current collection efforts are not effective in ensuring timely payments. It's our understanding that no follow-up collection procedures are currently in place to pursue outstanding payments, other than levying outstanding balances over $500, 60 days past due from 10/31 of the prior year."

Deficiencies Involving the Administration of the Budget (pages 8-9)

• Approved Budget Not Equal to Issued Financials "The approved budget amounts presented in the published Approved Budgets are not consistent with the amounts reported in the issued Financial Statements."

• Transfer Corrections "We identified several instances of transfers in which department heads had budget lines depleted without the necessary authorization."

• Reliance on Contingency Funds "A disproportionately high contingency allocation may indicate a lack of accurate forecasting and planning in the administration of funds. It suggests that there may be insufficient detail or clarity in the anticipated expenditures, or that risk assessment processes are not robust."

• Courthouse Reserves "Although the funds were budgeted for the Courthouse between 2019 through 2022...the money was never formally restricted for this purpose and was only included as part of the general fund's reserves. This approach limits transparency and accountability, and does not ensure that the allocated funds are protected and available exclusively for the Courthouse construction. As a result, of the $39,483,000 allegedly reserved between 2019 through 2022, only $7,400,00 actually exists within the Town's cash fund balance for courthouse-related expenditures. By not actually restricting the funds in these years, the Town was able to use them to plug other budget gaps year over year by reappropriating the funds intended for the Courthouse."

• Town Outside Village Fund – Permit Revenues "Recognizing the revenue prematurely, and including it in the current year fund balance, may overstate available resources and does not accurately reflect the intended use or restrictions of these funds."

Town Justice Court (page 11)

• Significant Outstanding Balances for Vehicle and Traffic Law Infractions and Parking Tickets "During our review of the Town Justice Court, we were provided with an aging report for outstanding parking tickets which totaled $3,136,000 as of February 2025. Of this amount, $2,635,000 was listed as being over 3 years old.... Nearly all 7,400 cases [of traffic law infractions] dating back to 2001 were listed as of January 2026, with net outstanding fines, fees and surcharges totaling approximately $1,850,000."

Financial (pages 11-12)

• Inaccurate Cash and Interfund Reconciliations "Large unsupported journal entries were included at year-end to balance the cash accounts. At December 2022, we observed a reconciling entry of $130,167, while at December 2023, two entries of $49,667 and $170,353 were made to balance cash."

• Aged Outstanding Checks "Certain outstanding checks [totaling $8,794,645 in the years 2020-2023] had remained uncashed for an extended period of time. Municipalities must...comply with state unclaimed property laws, remitting funds from checks uncashed after the statutory period to the NYS Comptroller's Office of Unclaimed Funds and retaining thorough records."

Miscellaneous (pages 13-14)

• Outdated Policies "The Town of Greenburgh's Financial Goals & Policies were last revised in 2014, and the Financial Handbook dates back to 1999. Both documents are significantly outdated and may not reflect current financial management practices or recent changes in laws and regulations."

• Payroll – Manual/Paper Checks "There is currently no review of payroll changes made on a regular basis. Management should review the payroll change report at least annually to ensure that all changes to employee compensation, status, and deductions are properly authorized and documented."

• Payroll – Certification Audit "The [Westchester County payroll certification] audit identified several significant issues, including employees with missing or incomplete paperwork, inactive/separated employees that remained in the payroll system, discrepancies of name/job titles/pay rates and previously noted exceptions that remain unresolved. Continued noncompliance with civil service requirements may subject the Town to penalties under Civil Service Law."

• Internal Control Weaknesses "The former Comptroller, who left in 2024, is still listed as a signatory on the Town's bank accounts.... EFPR identified 24 individuals whose service with Greenburgh has ended, yet remain active users [of the accounting and operations system]... In prior years (2021-2022) certain capital project funds either had no activity or consistently operated at a deficit... There were material corrected misstatements identified and subsequently adjusted in the financial statements for all years under review, 2020 through 2023."

SUMMARY (page 14)

"Key findings included deficiencies in the timely filing of tax liens and foreclosure proceedings, funds being reserved for the courthouse but not actually restricted, weakness in the monitoring and collection of delinquent taxes and water rents, inconsistencies in budget administration and reconciliations including outdated financial policies, and lapses in internal controls such as segregation of controls and maintenance of active user accounts. Additionally, certain capital project and special purpose funds exhibited periods of inactivity or operated at deficits, highlighting the need for more regular analysis and oversight.

"The findings underscore the importance of strengthened internal controls, updated policies, improved financial oversight, and enhanced communication among departments to ensure transparency, accountability, and effective stewardship of public resources."

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