Criteria 34 CFR 668.173(b): Return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic funds transfer initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew, or the date on the cancelled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. Condition Significant Deficiency in Internal Control over Compliance and Noncompliance – During testing of Return to Title IV requirements, we noted eight of the fifty-seven Return to Title IV calculations tested for Chabot College were not returned within the 45 day requirement. Questioned Costs There are no questioned costs associated with the condition identified. Context There were 462 Return to Title IV calculations completed by Chabot College during the year ended June 30, 2025. Effect The District is not in compliance with the time requirements for Return to Title IV funds as described in the criteria above. Cause The District’s internal controls associated with the Return to Title IV procedures were not sufficient to ensure that all required funds were returned to ED within the required time frame. Repeat Finding No. Recommendation The District should implement or modify internal controls to ensure that the Return to Title IV funds are returned within 45 days from the date the District determines the student withdrew from all classes. This could include developing a regular schedule for completing Return to Title IV calculations and initiating returns in a specific timeframe that ensures returns are completed within 45 days.