Audit 350075

FY End
2024-06-30
Total Expended
$16.83M
Findings
8
Programs
9
Year: 2024 Accepted: 2025-03-28
Auditor: Gbq Partners LLC

Organization Exclusion Status:

Checking exclusion status...

Contacts

Name Title Type
NCBNNNMBAEL3 Brian Barrett Auditee
6145590115 Michael Purcell Auditor
No contacts on file

Notes to SEFA

Title: Federal Loan Balances Accounting Policies: Basis of Presentation The accompanying schedule of expenditures of federal awards includes the federal award activity of ECDI under programs of the federal government for the year ended June 30, 2024 in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the schedule presents only a selected portion of the operations of ECDI, it is not intended to and does not present the financial position, changes in net assets, or cash flows of ECDI. Summary of Significant Accounting Policies Expenditures reported on the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowed or are limited as to reimbursement. ECDI has elected to use the 10 percent de minimis indirect cost rate to recover indirect costs, as allowed under Uniform Guidance. De Minimis Rate Used: Y Rate Explanation: ECDI has elected to use the 10 percent de minimis indirect cost rate to recover indirect costs, as allowed under Uniform Guidance. Loans outstanding at the beginning of the year and loans made during the year are included in the federal expenditures presented in the schedule. The balances of loans outstanding at June 30, 2024 consist of the following:

Finding Details

Reference Number: 2024-001 Finding: Finding Type: Immaterial noncompliance with major program requirements Title and CFDA Number of Federal Program: 59.046 – Small Business Administration Microloan Program Finding Resolution Status: In review. Information on Universe and Population Size: Salaries and wages pursuant to approved budget for the period July 1, 2023 to June 30, 2024. Salaries and wages per approved budget is $1,885,028. Sample Size Information: A sample of 20 allocations of salaries and wages allocated to the program during the budget period were selected for testing compliance, including to approved time allocations within the payroll processor and as compared to the Executive Level II Salary max amounts in effect during the budget period. Identification of Repeat Finding and Finding Reference Number: N/A Criteria: The Organization is required to submit an award budget for approval, including direct costs to be allocated to the award. The Organization is then required to submit a schedule of actual allocated costs incurred for reimbursement. Statement of Condition: During our testing of allocated salaries and wages, we identified errors in how employee time was allocated to the program, and salaries and wages allocated to the program in excess of the Executive Level II Salary maximum. Specifically, one employee had salaries and wages allocated to the program in excess of hours tracked to the program for a selected month. Another employee had an inappropriate wage rate applied to allocated time to the program. Last, two employees had compensation levels allocated to the program in excess of the Executive Level II Salary max amount in effect for the respective period. Cause: The Organization did not have adequate procedures in place to ensure that payroll costs were supported by accurate time and rates reporting. Certain allocations were made subsequent to the approved budget amounts, however support was not substantiated for those allocations. Effect or Potential Effect: Salaries and wages charged to the program included unsupported amounts, resulting in projected questioned costs of $63,740. When the actual errors in the sample tested were projected across the population, the potential error exceeds $25,000, which requires reporting under 2 CFR 200.516(a). However, the total projected questioned costs were not material to the program. Auditor Noncompliance Code: A – Activities allowed or unallowed Reporting Views of Responsible Officials: Management agrees with the noncompliance with no sanctions imposed conclusion. Context: No additional context identified by the Organization which is not otherwise presented herein. Recommendation: The Organization should strengthen internal controls over payroll cost allocations, including regular reconciliation of payroll charges to actual time records and rates. Time and rate documentation should be properly reviewed and approved. Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations: Management should complete regular reconciliations of payroll charges to actual time records and rates. Time and rate documentation should be properly reviewed and approved. Response Indicator: Agree Completion Date: In process. Response: Management acknowledges noncompliance in the current fiscal year and is reviewing its internal controls over payroll cost allocations. Questioned Costs: $63,740
Reference Number: 2024-002 Finding: Finding Type: Immaterial noncompliance with major program requirements Title and CFDA Number of Federal Program: 59.046 – Small Business Administration Microloan Program Finding Resolution Status: Resolved Information on Universe and Population Size: All quarterly and annual reports pursuant to the mutually agreed upon Reporting Schedule. Sample Size Information: A sample of 3 reports for fiscal year 2024 were selected for testing compliance with reporting pursuant to the mutually agreed upon Reporting Schedule. Identification of Repeat Finding and Finding Reference Number: N/A Criteria: The Organization is required to submit the quarterly reports within 30 days following the reporting period. Statement of Condition: The Organization failed to submit the SF PPR report as of December 31, 2023 by January 30, 2024. The report was filed March 22, 2024. Cause: The Organization is unable to determine why the report was filed untimely. Personnel responsible for reporting at the time are no longer employed by the Organization. Effect or Potential Effect: The Organization is noncompliant for the performance period ended December 31, 2023 with no sanctions imposed. The Organization submitted the requested report late. Auditor Noncompliance Code: L - Reporting Reporting Views of Responsible Officials: Management agrees with the noncompliance with no sanctions imposed conclusion. Context: No additional context identified by the Organization which is not otherwise presented herein. Recommendation: All requested reports should be submitted in accordance with the mutually agreed upon Reporting Schedule. Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations: Management should submit all requested reports in accordance with the mutually agreed upon Reporting Schedule. Response Indicator: Agree Completion Date: March 1, 2025 Response: Management acknowledges noncompliance in the current fiscal year and has submitted the requested report to the awarding agency. Questioned Costs: None
Reference Number: 2024-001 Finding: Finding Type: Immaterial noncompliance with major program requirements Title and CFDA Number of Federal Program: 59.046 – Small Business Administration Microloan Program Finding Resolution Status: In review. Information on Universe and Population Size: Salaries and wages pursuant to approved budget for the period July 1, 2023 to June 30, 2024. Salaries and wages per approved budget is $1,885,028. Sample Size Information: A sample of 20 allocations of salaries and wages allocated to the program during the budget period were selected for testing compliance, including to approved time allocations within the payroll processor and as compared to the Executive Level II Salary max amounts in effect during the budget period. Identification of Repeat Finding and Finding Reference Number: N/A Criteria: The Organization is required to submit an award budget for approval, including direct costs to be allocated to the award. The Organization is then required to submit a schedule of actual allocated costs incurred for reimbursement. Statement of Condition: During our testing of allocated salaries and wages, we identified errors in how employee time was allocated to the program, and salaries and wages allocated to the program in excess of the Executive Level II Salary maximum. Specifically, one employee had salaries and wages allocated to the program in excess of hours tracked to the program for a selected month. Another employee had an inappropriate wage rate applied to allocated time to the program. Last, two employees had compensation levels allocated to the program in excess of the Executive Level II Salary max amount in effect for the respective period. Cause: The Organization did not have adequate procedures in place to ensure that payroll costs were supported by accurate time and rates reporting. Certain allocations were made subsequent to the approved budget amounts, however support was not substantiated for those allocations. Effect or Potential Effect: Salaries and wages charged to the program included unsupported amounts, resulting in projected questioned costs of $63,740. When the actual errors in the sample tested were projected across the population, the potential error exceeds $25,000, which requires reporting under 2 CFR 200.516(a). However, the total projected questioned costs were not material to the program. Auditor Noncompliance Code: A – Activities allowed or unallowed Reporting Views of Responsible Officials: Management agrees with the noncompliance with no sanctions imposed conclusion. Context: No additional context identified by the Organization which is not otherwise presented herein. Recommendation: The Organization should strengthen internal controls over payroll cost allocations, including regular reconciliation of payroll charges to actual time records and rates. Time and rate documentation should be properly reviewed and approved. Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations: Management should complete regular reconciliations of payroll charges to actual time records and rates. Time and rate documentation should be properly reviewed and approved. Response Indicator: Agree Completion Date: In process. Response: Management acknowledges noncompliance in the current fiscal year and is reviewing its internal controls over payroll cost allocations. Questioned Costs: $63,740
Reference Number: 2024-002 Finding: Finding Type: Immaterial noncompliance with major program requirements Title and CFDA Number of Federal Program: 59.046 – Small Business Administration Microloan Program Finding Resolution Status: Resolved Information on Universe and Population Size: All quarterly and annual reports pursuant to the mutually agreed upon Reporting Schedule. Sample Size Information: A sample of 3 reports for fiscal year 2024 were selected for testing compliance with reporting pursuant to the mutually agreed upon Reporting Schedule. Identification of Repeat Finding and Finding Reference Number: N/A Criteria: The Organization is required to submit the quarterly reports within 30 days following the reporting period. Statement of Condition: The Organization failed to submit the SF PPR report as of December 31, 2023 by January 30, 2024. The report was filed March 22, 2024. Cause: The Organization is unable to determine why the report was filed untimely. Personnel responsible for reporting at the time are no longer employed by the Organization. Effect or Potential Effect: The Organization is noncompliant for the performance period ended December 31, 2023 with no sanctions imposed. The Organization submitted the requested report late. Auditor Noncompliance Code: L - Reporting Reporting Views of Responsible Officials: Management agrees with the noncompliance with no sanctions imposed conclusion. Context: No additional context identified by the Organization which is not otherwise presented herein. Recommendation: All requested reports should be submitted in accordance with the mutually agreed upon Reporting Schedule. Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations: Management should submit all requested reports in accordance with the mutually agreed upon Reporting Schedule. Response Indicator: Agree Completion Date: March 1, 2025 Response: Management acknowledges noncompliance in the current fiscal year and has submitted the requested report to the awarding agency. Questioned Costs: None
Reference Number: 2024-001 Finding: Finding Type: Immaterial noncompliance with major program requirements Title and CFDA Number of Federal Program: 59.046 – Small Business Administration Microloan Program Finding Resolution Status: In review. Information on Universe and Population Size: Salaries and wages pursuant to approved budget for the period July 1, 2023 to June 30, 2024. Salaries and wages per approved budget is $1,885,028. Sample Size Information: A sample of 20 allocations of salaries and wages allocated to the program during the budget period were selected for testing compliance, including to approved time allocations within the payroll processor and as compared to the Executive Level II Salary max amounts in effect during the budget period. Identification of Repeat Finding and Finding Reference Number: N/A Criteria: The Organization is required to submit an award budget for approval, including direct costs to be allocated to the award. The Organization is then required to submit a schedule of actual allocated costs incurred for reimbursement. Statement of Condition: During our testing of allocated salaries and wages, we identified errors in how employee time was allocated to the program, and salaries and wages allocated to the program in excess of the Executive Level II Salary maximum. Specifically, one employee had salaries and wages allocated to the program in excess of hours tracked to the program for a selected month. Another employee had an inappropriate wage rate applied to allocated time to the program. Last, two employees had compensation levels allocated to the program in excess of the Executive Level II Salary max amount in effect for the respective period. Cause: The Organization did not have adequate procedures in place to ensure that payroll costs were supported by accurate time and rates reporting. Certain allocations were made subsequent to the approved budget amounts, however support was not substantiated for those allocations. Effect or Potential Effect: Salaries and wages charged to the program included unsupported amounts, resulting in projected questioned costs of $63,740. When the actual errors in the sample tested were projected across the population, the potential error exceeds $25,000, which requires reporting under 2 CFR 200.516(a). However, the total projected questioned costs were not material to the program. Auditor Noncompliance Code: A – Activities allowed or unallowed Reporting Views of Responsible Officials: Management agrees with the noncompliance with no sanctions imposed conclusion. Context: No additional context identified by the Organization which is not otherwise presented herein. Recommendation: The Organization should strengthen internal controls over payroll cost allocations, including regular reconciliation of payroll charges to actual time records and rates. Time and rate documentation should be properly reviewed and approved. Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations: Management should complete regular reconciliations of payroll charges to actual time records and rates. Time and rate documentation should be properly reviewed and approved. Response Indicator: Agree Completion Date: In process. Response: Management acknowledges noncompliance in the current fiscal year and is reviewing its internal controls over payroll cost allocations. Questioned Costs: $63,740
Reference Number: 2024-002 Finding: Finding Type: Immaterial noncompliance with major program requirements Title and CFDA Number of Federal Program: 59.046 – Small Business Administration Microloan Program Finding Resolution Status: Resolved Information on Universe and Population Size: All quarterly and annual reports pursuant to the mutually agreed upon Reporting Schedule. Sample Size Information: A sample of 3 reports for fiscal year 2024 were selected for testing compliance with reporting pursuant to the mutually agreed upon Reporting Schedule. Identification of Repeat Finding and Finding Reference Number: N/A Criteria: The Organization is required to submit the quarterly reports within 30 days following the reporting period. Statement of Condition: The Organization failed to submit the SF PPR report as of December 31, 2023 by January 30, 2024. The report was filed March 22, 2024. Cause: The Organization is unable to determine why the report was filed untimely. Personnel responsible for reporting at the time are no longer employed by the Organization. Effect or Potential Effect: The Organization is noncompliant for the performance period ended December 31, 2023 with no sanctions imposed. The Organization submitted the requested report late. Auditor Noncompliance Code: L - Reporting Reporting Views of Responsible Officials: Management agrees with the noncompliance with no sanctions imposed conclusion. Context: No additional context identified by the Organization which is not otherwise presented herein. Recommendation: All requested reports should be submitted in accordance with the mutually agreed upon Reporting Schedule. Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations: Management should submit all requested reports in accordance with the mutually agreed upon Reporting Schedule. Response Indicator: Agree Completion Date: March 1, 2025 Response: Management acknowledges noncompliance in the current fiscal year and has submitted the requested report to the awarding agency. Questioned Costs: None
Reference Number: 2024-001 Finding: Finding Type: Immaterial noncompliance with major program requirements Title and CFDA Number of Federal Program: 59.046 – Small Business Administration Microloan Program Finding Resolution Status: In review. Information on Universe and Population Size: Salaries and wages pursuant to approved budget for the period July 1, 2023 to June 30, 2024. Salaries and wages per approved budget is $1,885,028. Sample Size Information: A sample of 20 allocations of salaries and wages allocated to the program during the budget period were selected for testing compliance, including to approved time allocations within the payroll processor and as compared to the Executive Level II Salary max amounts in effect during the budget period. Identification of Repeat Finding and Finding Reference Number: N/A Criteria: The Organization is required to submit an award budget for approval, including direct costs to be allocated to the award. The Organization is then required to submit a schedule of actual allocated costs incurred for reimbursement. Statement of Condition: During our testing of allocated salaries and wages, we identified errors in how employee time was allocated to the program, and salaries and wages allocated to the program in excess of the Executive Level II Salary maximum. Specifically, one employee had salaries and wages allocated to the program in excess of hours tracked to the program for a selected month. Another employee had an inappropriate wage rate applied to allocated time to the program. Last, two employees had compensation levels allocated to the program in excess of the Executive Level II Salary max amount in effect for the respective period. Cause: The Organization did not have adequate procedures in place to ensure that payroll costs were supported by accurate time and rates reporting. Certain allocations were made subsequent to the approved budget amounts, however support was not substantiated for those allocations. Effect or Potential Effect: Salaries and wages charged to the program included unsupported amounts, resulting in projected questioned costs of $63,740. When the actual errors in the sample tested were projected across the population, the potential error exceeds $25,000, which requires reporting under 2 CFR 200.516(a). However, the total projected questioned costs were not material to the program. Auditor Noncompliance Code: A – Activities allowed or unallowed Reporting Views of Responsible Officials: Management agrees with the noncompliance with no sanctions imposed conclusion. Context: No additional context identified by the Organization which is not otherwise presented herein. Recommendation: The Organization should strengthen internal controls over payroll cost allocations, including regular reconciliation of payroll charges to actual time records and rates. Time and rate documentation should be properly reviewed and approved. Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations: Management should complete regular reconciliations of payroll charges to actual time records and rates. Time and rate documentation should be properly reviewed and approved. Response Indicator: Agree Completion Date: In process. Response: Management acknowledges noncompliance in the current fiscal year and is reviewing its internal controls over payroll cost allocations. Questioned Costs: $63,740
Reference Number: 2024-002 Finding: Finding Type: Immaterial noncompliance with major program requirements Title and CFDA Number of Federal Program: 59.046 – Small Business Administration Microloan Program Finding Resolution Status: Resolved Information on Universe and Population Size: All quarterly and annual reports pursuant to the mutually agreed upon Reporting Schedule. Sample Size Information: A sample of 3 reports for fiscal year 2024 were selected for testing compliance with reporting pursuant to the mutually agreed upon Reporting Schedule. Identification of Repeat Finding and Finding Reference Number: N/A Criteria: The Organization is required to submit the quarterly reports within 30 days following the reporting period. Statement of Condition: The Organization failed to submit the SF PPR report as of December 31, 2023 by January 30, 2024. The report was filed March 22, 2024. Cause: The Organization is unable to determine why the report was filed untimely. Personnel responsible for reporting at the time are no longer employed by the Organization. Effect or Potential Effect: The Organization is noncompliant for the performance period ended December 31, 2023 with no sanctions imposed. The Organization submitted the requested report late. Auditor Noncompliance Code: L - Reporting Reporting Views of Responsible Officials: Management agrees with the noncompliance with no sanctions imposed conclusion. Context: No additional context identified by the Organization which is not otherwise presented herein. Recommendation: All requested reports should be submitted in accordance with the mutually agreed upon Reporting Schedule. Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations: Management should submit all requested reports in accordance with the mutually agreed upon Reporting Schedule. Response Indicator: Agree Completion Date: March 1, 2025 Response: Management acknowledges noncompliance in the current fiscal year and has submitted the requested report to the awarding agency. Questioned Costs: None