Action Plan for Addressing Audit Finding on Intermediary Relending Program (IRP) Funds
1. Introduction
Purpose: To address the audit finding regarding the Intermediary Relending Program (IRP) funds that were not fully insured by the Federal Deposit Insurance Corporation (FDIC) and to implement cor...
Action Plan for Addressing Audit Finding on Intermediary Relending Program (IRP) Funds
1. Introduction
Purpose: To address the audit finding regarding the Intermediary Relending Program (IRP) funds that were not fully insured by the Federal Deposit Insurance Corporation (FDIC) and to implement corrective actions to ensure compliance with U.S. Department of Agriculture requirements.
Scope: This action plan focuses on ensuring that all reserves and cash in the IRP revolving fund are fully insured or collateralized with U.S. Government obligations, as outlined in 7 CFR Part 4274.332(b).
2. Audit Findings Summary
Finding: IRP funds on deposit with a local financial institution were not fully insured by the FDIC.
Questioned Costs: None.
Criteria: U.S. Department of Agriculture requires all reserves and cash in the IRP revolving fund to be fully insured or collateralized.
Cause: Management was aware of the requirement but inadvertently overlooked it due to an influx of cash received during the year.
Effect: Inadequate internal controls over compliance could result in noncompliance with grantor agency requirements and jeopardize LAIC’s continued participation in the program.
Recommendation: Management should be aware of all program requirements and take appropriate action to correct deficiencies.
3. Action Steps
Action Step 1: Review and Understand Program Requirements
Finding Addressed: Lack of full insurance or collateralization of IRP funds.
Description: Conduct a comprehensive review of 7 CFR Part 4274.332(b) and related requirements to ensure both team members and board of directors understand the compliance obligations.
Responsible Person: Executive Director
Resources Needed: Access to relevant regulatory documents, training materials.
Timeline: Complete review and training by July 15, 2024.
Success Criteria: All relevant staff have reviewed the regulations and can demonstrate understanding of the requirements.
Action Step 2: Implement Monitoring and Controls
Finding Addressed: Inadequate internal controls over compliance.
Description: Develop and implement internal controls to monitor the insurance and collateralization status of IRP funds regularly.
Responsible Persons: Executive Director and Administrative Assistant
Resources Needed: Financial monitoring and monthly reviews.
Timeline: Controls implemented by July 31, 2024.
Success Criteria: Regular monitoring reports indicating compliance with insurance and collateralization requirements.
Action Step 3: Secure Additional Insurance or Collateralization
Finding Addressed: IRP funds not fully insured by the FDIC.
Description: Ensure all IRP funds on deposit are either fully insured by the FDIC or collateralized with U.S. Government obligations.
Responsible Persons: Executive Director and Administrative Assistant
Resources Needed: Coordination with local financial institutions, legal advice if needed.
Timeline: Complete by September 1, 2024.
Success Criteria: Documentation showing that all IRP funds are fully insured or collateralized.
Action Step 4: Regular Reporting to Board of Directors
Finding Addressed: Inadequate internal controls over compliance.
Description: Establish a regular reporting through monthly financials to update governance on the status of IRP fund compliance.
Responsible Person/Team: Administrative Assistant
Resources Needed: Reporting template, monthly meeting schedules.
Timeline: Start regular reporting by September 26, 2024
Success Criteria: Monthly reports submitted to board of directors, with compliance status and any issues addressed.
4. Monitoring and Reporting
Monitoring Process: Progress will be monitored through regular monthly meetings and monthly internal audits.
Reporting Frequency: Monthly reports to board of directors.
Responsible Person/Team: Executive Director and Administrative Assistant
5. Review and Adjustments
Review Schedule: The action plan will be reviewed quarterly to assess progress and make necessary adjustments.
Adjustment Process: Adjustments will be based on feedback from internal audits and progress reports, with updates approved by board of directors.
6. Conclusion
Summary: This action plan outlines the steps to address the audit finding regarding the IRP funds and to ensure full compliance with USDA requirements.
Commitment: LAIC is committed to implementing these actions to enhance internal controls, ensure compliance, and maintain continued participation in the IRP program.
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Brooke Rollag, Executive Director