Audit 385744

Finding 2025-001 Required Disclosures Major program: Student Financial Assistance Cluster Type of finding: Significant Deficiency in Internal Control and Compliance Questioned cost: $0 Criteria Per 34 CFR §668.164 and related federal disclosure requirements for Tier One arrangements, institutions must publicly disclose the following within 60 days after the end of the award year:  A copy of the contract with the third-party servicer providing banking services for Title IV funds;  The total consideration paid or received under the contract for the year;  The number of students who had financial accounts under the contract; and  The mean and median of actual costs incurred by account holders. Additionally, institutions must submit required banking services information to the U.S. Department of Education. Condition The University did not comply with several aspects of these disclosure requirements. Specifically, the contract and related data were not posted publicly on the University’s website, and there was no evidence of submission of required information to the Department of Education. Cause The University entered into the banking services contract during the fiscal year and was unaware of the associated disclosure requirements. Effect Required disclosures were not made timely, limiting transparency for students and other stakeholders and resulting in noncompliance with federal regulations. Recommendation We recommend the University implement formal processes and internal controls to:  Identify all federal disclosure requirements related to Title IV banking arrangements;  Ensure timely posting of required information on the University’s website; and  Confirm submission of required data to the Department of Education.