Audit 46041

Criteria or Requirement: Per GEN-21-03 ?Expansion of Collections Pause to Defaulted FFEL Program Loans Managed by Guaranty Agencies (Updated May 24, 2021)?, federal family education loans (FFEL) are categorized into three populations based on the respective default claim date. For all three populations of FFEL, guaranty agencies are required to set interest rates to zero as of the later of the date of receipt of the loan or March 13, 2020. 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that cash reconciliations are properly performed and reviewed monthly during the year. Condition Found: As of September 30, 2022, not all interest rates were reset to zero as of the effective date required by USDE. For a sample of 60 FFEL, one loan?s interest rate was reset to zero as of June 30, 2020 instead of March 13, 2020.Cause: Resetting the interest rates to zero was a manual process with multiple steps in order for each transaction to be appropriately reversed and the zero percent interest rate applied. Texas Guaranteed Student Loan Corporation (Trellis) had a control in place to identify FFEL where the interest rate was required to be reset to zero. The control is a system generated report which is prepared and reviewed on a periodic basis. The report identified FFEL which needed to be reset but was not designed to identify the effective date of the interest reset as compared to the claim date. Possible Asserted Effect: Trellis was able to generate a report of all open and closed FFEL that needed to be reviewed in order to determine if the effective date of the zero-interest rate reset was correctly applied. There were approximately 2,800 FFEL that were reviewed, compared to approximately 215,000 FFEL in the Trellis portfolio. The 2,800 FFEL were reviewed and any corrections necessary were made by fiscal year end September 30, 2022. An additional sample of 40 FFEL was reviewed from the population of 2,800 and no exceptions were noted. Therefore, there are no questioned costs as the FFEL were corrected in arrears. Recommendation: Trellis should continue to prepare and review both FFEL reports to determine if interest rates are all reset to zero with the appropriate effective date. Views of Responsible Officials: Trellis agrees with the recommendation to prepare and review both FFEL reports ongoing, making any corrections as necessary, until the zero percent interest rate requirement ends.

Criteria or Requirement: Per GEN-21-03 ?Expansion of Collections Pause to Defaulted FFEL Program Loans Managed by Guaranty Agencies (Updated May 24, 2021)?, federal family education loans (FFEL) are categorized into three populations based on the respective default claim date. For all three populations of FFEL, guaranty agencies are required to set interest rates to zero as of the later of the date of receipt of the loan or March 13, 2020. 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that cash reconciliations are properly performed and reviewed monthly during the year. Condition Found: As of September 30, 2022, not all interest rates were reset to zero as of the effective date required by USDE. For a sample of 60 FFEL, one loan?s interest rate was reset to zero as of June 30, 2020 instead of March 13, 2020.Cause: Resetting the interest rates to zero was a manual process with multiple steps in order for each transaction to be appropriately reversed and the zero percent interest rate applied. Texas Guaranteed Student Loan Corporation (Trellis) had a control in place to identify FFEL where the interest rate was required to be reset to zero. The control is a system generated report which is prepared and reviewed on a periodic basis. The report identified FFEL which needed to be reset but was not designed to identify the effective date of the interest reset as compared to the claim date. Possible Asserted Effect: Trellis was able to generate a report of all open and closed FFEL that needed to be reviewed in order to determine if the effective date of the zero-interest rate reset was correctly applied. There were approximately 2,800 FFEL that were reviewed, compared to approximately 215,000 FFEL in the Trellis portfolio. The 2,800 FFEL were reviewed and any corrections necessary were made by fiscal year end September 30, 2022. An additional sample of 40 FFEL was reviewed from the population of 2,800 and no exceptions were noted. Therefore, there are no questioned costs as the FFEL were corrected in arrears. Recommendation: Trellis should continue to prepare and review both FFEL reports to determine if interest rates are all reset to zero with the appropriate effective date. Views of Responsible Officials: Trellis agrees with the recommendation to prepare and review both FFEL reports ongoing, making any corrections as necessary, until the zero percent interest rate requirement ends.