Condition: The Organization did not report actual loan disbursement dates to the Common
Origination and Disbursement (COD) system for 7 of the 8 students in the sample (87.5%). We
consider this condition to be a material weakness in internal control over compliance relating to the
Eligibility compli...
Condition: The Organization did not report actual loan disbursement dates to the Common
Origination and Disbursement (COD) system for 7 of the 8 students in the sample (87.5%). We
consider this condition to be a material weakness in internal control over compliance relating to the
Eligibility compliance requirement. Statistical sampling was not used in making sample selections.
Corrective Action Plan: The issue regarding reporting of loan disbursement dates occurred as the
result of a miscommunication between the Financial Aid officer at SIEAM and our CPA. Our
accountant was unaware that the specific disbursement date reported by Campus Ivy was
required to be the disbursement date recorded in our student ledgers. All disbursements occurred
very close to the date, but were not recorded on the exact date. This miscommunication and
knowledge gap has already been remedied. At this time, both our CPA and our Financial Aid
officer understand the statutory requirement for this reporting and have made the needed
changes.
Responsible Person for Correction Action Plan: Craig Mitchell, President, in conjunction with
Sabu Kallingal, Dean of Students and Financial Aid Officer, and Franz Aponte, CPA.
Implementation Date for Corrective Action Plan: The CAP was implemented on May 17, 2024.