Corrective Action Plans

Corrective Action Plan The University will update written procedures to include an additional manual process, which identifies and updates withdrawals within the National Student Clearinghouse with a higher frequency. These procedures are targeted for the summer term, in which the current year lapse was identified. This will ensure that no one is reported outside of the 60 day window.

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: In late June 2022, known settings and data required by the baseline report were in place, and a small sample of test records passed a basic test. In July 2022, full-term data generated by the PowerCAMPUS baseline tool was submitted to NSCH as a more extensive test for Summer 2022. Due to the discovery of a significant number of SIS data errors for at least two major categories and a quickly approaching deadline, the previous tool was used for that end-of-term enrollment data. In addition, the previous tool was used for earlier registration reporting within the Fall 2022 term. The PowerCAMPUS baseline tool is being updated and tested again during the Fall 2022 term with anticipation that the baseline tool will be used for reporting the final end-of-term enrollment data reported in January 2023. Person Responsible for Corrective Action Plan: Cagan Cummings, CIO and Christy Miller, Executive Director of Financial Aid Anticipated Date of Completion: January 2023

Finding Number: 2022-001 Planned Corrective Action: The School District has already implemented policies and procedures to ensure timely updating and has documented the remedies taken for the items noted as noncompliant in the audit. Anticipated Completion Date: January 31, 2023 Responsible Contact Person: Donna Solano, Financial Aid Coordinator

2022-007 Gramm-Leach-Bliley Act Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend that the College engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Tabor College is currently meeting with companies who provide services to assist with meeting the requirements of the Gramm-Leach-Bliley Act. Name(s) of the contact person(s) responsible for corrective action: Cathy Castle, Vice President for Business and Finance Planned completion date for corrective action plan: April 2023 and ongoing. If the Department of Education has questions regarding this plan, please call Cathy Castle at 620-947-3121 x 1056.

2022-004 National Student Loan Data System (NSLDS) Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Tabor College utilizes a clearing house for submitting student statuses. Tabor will ensure that all students statuses are filed accurately and timely. Name(s) of the contact person(s) responsible for corrective action: Scott Franz, Interim Financial Aid Director Planned completion date for corrective action plan: April 2023

2022-003 Return of Title IV (R2T4) Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review the return of Title IV funds requirements and implement procedures to ensure the return of Title IV funds calculations are using the correct number of break days and are accurately completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Tabor College will ensure the correct number days are used in all R2T4 calculations, including times when there are break days during the school term. Name(s) of the contact person(s) responsible for corrective action: Scott Franz, Interim Financial Aid Director Planned completion date for corrective action plan: This has begun with the 2022-23 school term

The College will put additional processes in place to ensure that student information is reviewed and reconciled between the NSC and NSLDS systems.

Finding 2022-001: Enrollment Reporting Federal Program - Federal Direct Student Loans Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable CFDA Number - 84.268 Federal Award Year - June 30, 2022 Condition/Context: The change in student status for 1 out of 25 students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. The student withdrew in September 2021 but was not reported until December 2021. Views of Responsible Officials and Planned Corrective Actions: The College agrees with the finding. The Office of Academic Success now notifies all pertinent offices of any student withdrawals in a timely manner. In addition, if a student withdraws with more than a week between their withdrawal and the last day of attendance, their change in status notification is processed immediately in NSLDS by the Registrar?s office. The Registrar also performs a monthly review of all status changes to verify all enrollment status changes are updated accurately and reported to NSLDS within the required timeframe. Names of Contact Persons Responsible for Corrective Action: Barbara Schmitt, Director of Financial Aid and Dan Cebrick, Registrar Anticipated Completion Date: Changes were effective for Fall 2022 semester.

2022-003: Loan disbursement notifications {14 day right-to-cancel letters). Management Views and Opinion The University of Miami acknowledges that some students did not receive their notifications informing them of the 14 day right-to-cancel for their Federal Direct Loans within the proscribed timeframe of 7 days from the date of disbursement. The root cause was a defect in the server set-up for our financial aid automated processing; the administrative software appeared to generate letters and provided no error message, however, notifications were not sent. Once identified by UM on October 21, 2021, UM sent notifications to any students not originally notified, however, this notification occurred outside the required window of time (7 days). Corrective Action The University has worked with the software provider to diagnose the issue as a missing instance of Microsoft Word on the server which processed the 14-day letters. We have addressed this issue and repaired the automated functionality as of September 21, 2022. During the down time, the university prepared these letters using a daily manual process to ensure that they were sent in a timely fashion. Timeline for Action Plan The issue was initially identified, and a temporary corrective action was put in place in October 2021 with a final correction in October 2022. Responsibre Individuals Daniel T. Barkowitz Roosevelt Deleveaux Beth Hernandez

2022-002: FOL and Pell Reporting Management Views and Opinion The University of Miami acknowledges that the disbursements as reflected on the individual student account were different by one day from the date reported to COD (Common Origination and Disbursement system). This error occurred due to the timing of scheduled jobs to run financial aid disbursement. The file process to disburse jobs ran late at night prior to midnight, but the job to post the disbursed aid ran after midnight and therefore showed a day later than reflected on the financial aid system. Corrective Action Plan In mid-August 2022, the University changed the evening job schedule to ensure that Federal financial aid will be both disbursed from the-financial aid system and posted to the Student Account on the same calendar day. This evening schedule job change will resolve this situation moving forward. Timeline for Action Plan The underlying issue was already corrected in August 2022. Responsible Individuals Daniel T. Barkowitz Roosevelt Deleveaux Norma De La 0

2022-001 Enrollment Reporting Management Views and Opinion Graduation Status Change UM management agrees that I out of 40 students had graduated but whose graduation status change was not reported at the campus or program level. While this student's graduation status change was not reported at the campus or program level, the student's record was reported as withdrawn within the allotted 60 days and therefore NSLDS was aware student was no longer enrolled. Enrollment Status Change UM management agrees that 14 out of 40 students' program level withdrawal date did not match their campus level withdrawal date. While all the students' withdrawal statuses were reported within the NSDLS guidelines and the final day of the Fall 2021 semester was used for their campus level withdrawal date, the first day of the Spring 2022 semester was incorrectly used for the program level withdrawal date. Corrective Action Plan Graduation Status Change Management will expand on the current controls in place by adding a review process for those student accounts that require manual status changes. Enrollment Status Change Management will expand on the current controls in place by adding a review process for those student accounts that require manual status updates based on the National Student Clearinghouse (NSC) Error Resolution Report. Timeline for Action Plan Graduation Status Change The review process for graduation status changes was implemented effective December 9, 2022. Enrollment Status Change The review process for enrollment status changes was implemented effective December 9, 2022. Responsible Individuals Allen Augustin, Associate Registrar

The finding was due to a human error. The Registrar?s Office failed to notify the Finance Division and Financial Aid Division of the student enrollment cancellation. These kinds of human errors will be prevented with the following procedure established by the university: Beginning with academic year 2022-2023 (August-2022), the university is taking the following measures: 1. A MSSharePoint was created in collaboration among the Registrar?s, Financial Aid and Finance Offices staff to serve as an easy access documentation repository and to enhance communication. Information of changes in the enrollment status of any student is documented internally for discussion among the offices (Monthly Withdrawal Conciliation Report). 2. Monthly meetings with the Registrar?s, Financial Aid and Finance Offices staff takes place. Personnel from the Institutional Effectiveness Office, and the Offices of the Dean and the Assistant Dean of Academic Affairs also attend to facilitate the discussion. During these meetings the three offices reconcile data on student enrollment status (as documented in the MSSharePoint). This best practice assures that: a. Student enrollment status is recorded accurately and on time. b. Withdrawal cases in which transactions are required with the USDoE are documented early so that funds are returned within the allowable prescribed period. c. As an extra bonus, communication is improved among the Registrar?s, Financial Aid and Finance Offices staff. 3. The dean of student affairs and the dean of academic affairs have provided faculty development seminars on the expectations of a faculty member to comply with federal regulations. Among the topics discussed is the importance of attendance recording and documentation. As well, faculty were required to refer to the Registrar?s and to the Dean of Admissions and Student Affairs Offices any student absent to two consecutive significant academic events. The purpose is: a. Early detection of a student that might be at risk of academic difficulties. b. Early awareness of a student that might be changing enrollment status. 4. To date four (4) attendance surveys have taken place taken place (3/semester). The attendance surveys provide the opportunity to capture any students at risk of changes in enrollment status. As a consequence, student enrollment status may be recorded accurately and on time and as well funds are returned to the USDoE within the allowable period. 5. Periodic letters to the faculty from the Office of the Dean of Academic Affairs to highlight the importance pf promptly referring any changes in student attendance to activate retention efforts or in order to identify and record accurately and on time any changes in student enrollment status.

This error was due to the fact that the professor did not notify that the student was missing. Instead, the student was graded as if she had completed the course.In order to prevent the recurrence of this error, the university has established the following procedure: 1. The dean of student affairs and the dean of academic affairs have provided faculty development seminars on the expectations of a faculty member to comply with federal regulations. Among the topics discussed is the importance of attendance recording and documentation. As well, faculty were required to refer to the Registrar?s and to the Dean of Admissions and Student Affairs Offices any student absent to two consecutive significant academic events. The purpose is: a. Early detection of a student that might be at risk of academic difficulties. b. Early awareness of a student that might be changing enrollment status. 2. To date four (4) attendance surveys have taken place (3/semester). The attendance surveys provide the opportunity to capture any students at risk of changes in enrollment status. As a consequence, student enrollment status may be recorded accurately and on time and as well funds are returned to the USDoE within the allowable period. 3. Periodic letters to the faculty from the Office of the Dean of Academic Affairs to highlight the importance of promptly referring any changes in student attendance to activate retention efforts or in order to identify and record accurately and on time any changes in student enrollment status.

An additional procedure was established since March 2023, incorporating a second checkpoint in the filling of the R2T4. After the filing, all dates required in the calculation of the withdrawal process (R2T4) will be reassured/validated by a different official at the Financial Aid Office other than the preparer. The reviewer will also initialize the R2T4 as evidence of the review and compliance with this new procedure. This system will help prevent human errors like this to occur again.

The identified instances were recorded before the university put in place the controls described below. In order to assure compliance with NSLDS reporting requirements, determinations of funds earned, and timing, beginning with academic year 2022-2023 (August-2022) the university is taking the following measures: 1. A MSSharePoint was created in collaboration among the Registrar?s, Financial Aid and Finance Offices staff to serve as an easy access documentation repository and to enhance communication. Information of changes in the enrollment status of any student is documented internally for discussion among the offices (Monthly Withdrawal Conciliation Report). 2. Monthly meetings with the Registrar?s, Financial Aid and Finance Offices staff takes place. Personnel from the Institutional Effectiveness Office, and the Offices of the Dean and the Assistant Dean of Academic Affairs will also attend to facilitate thediscussion. During these meetings the three offices reconcile data on student enrollment status (as documented in the MSSharePoint). This best practice assures that: a. Student enrollment status is recorded accurately and on time. b. Withdrawal cases in which transactions are required with the USDoE are documented early so that funds are returned within the allowable prescribed period. c. As an extra bonus, communication is improved among the Registrar?s, Financial Aid and Finance Offices staff. 3. The dean of student affairs and the dean of academic affairs have provided faculty development seminars on the expectations of a faculty member to comply with federal regulations. Among the topics discussed is the importance of attendance recording and documentation. As well, faculty were required to refer to the Registrar?s and to the Dean of Admissions and Student Affairs Offices any student absent totwo consecutive significant academic events. The purpose is: a. Early detection of a student that might be at risk of academic difficulties. b. Early awareness of a student that might be changing enrollment status. 4. To date four (4) attendance surveys have taken place (3/semester). The attendance surveys provide the opportunity to capture any students at risk of changes in enrollment status. As a consequence, student enrollment status may be recorded accurately and on time and as well funds are returned to the USDoE within the allowable period. 5. Periodic letter to the faculty from the Office of the Dean of Academic Affairs to highlight the importance to promptly refer any changes in student attendance to activate retention efforts or in order to identify and record accurately and on time any changes in student enrollment status. n addition to the above-mentioned procedures the following measures will be taken: 1. Late reporting of graduation dates in NSLDS and effective dates: a. Prior to graduation all academic program directors review the degrees to be conferred and certify candidates eligible for graduation b. The Registrar?s Office changes the status to graduate in the NSLDS Report after graduation date. c. To assure that all degrees are reported on time and accurately to the NSLDS system from now on, the Registrar?s Office, within ten days after graduation date, will process the changes in the NSLDS system. After the Registrar?s Office processes the changes in the NSLDS system, it will send to all program directors the list of all the students processed as graduated in the NSLDS system and they will be asked to double verify and attest accuracy of the lists of conferred degrees and asked to provide a certification within two days that the changes processed were accurate and that they agree with their record of students officially graduated during the last graduation date. This double certification of conferred degrees within the proposed time-frame will provide a second opportunity to add or delete any missing information within the NSLDS system increasing accuracy and timelines. d. A copy of the certification will be submitted to the Office of the Dean of Academic Affairs as evidence of the compliance with the new process established.

Student Financial Aid Cluster: Federal Pell Program ? Assistance Listing No. 84.063 Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the College disburse the proper Pell award to these students. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This was a Pell error due to COA calculation and assignment error. Procedures will be implemented to review COA components to confirm accuracy of COA which will result in correct Pell awards. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes, Travis Osburn and John Bender. Planned completion date for corrective action plan: Immediate

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant ? Assistance Listing No. 84.007 Federal Work Study Program ? Assistance Listing No. 84.033 Federal Perkins Loan Program? Assistance Listing No. 84.038 Federal Pell Grant Program ? Assistance Listing No. 84.063 Federal Direct Student Loans ? Assistance Listing No. 84.268 Teacher Education Assistance. for College and Higher Education Grants? Assistance Listing No. 84.379 Nursing Student Loans ? Assistance Listing No. 93.364 Recommendation: We recommend the College review its current procedures for tracking SAP requirements and implement procedures to ensure SAP status is accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procedures will be implemented to select a random sample of students each term to confirm accuracy of SAP calculation. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes, Travis Osburn and John Bender Planned completion date for corrective action plan: 06/01/2023

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant ? Assistance Listing No. 84.007 Federal Work Study Program ? Assistance Listing No. 84.033 Federal Perkins Loan Program? Assistance Listing No. 84.038 Federal Pell Grant Program ? Assistance Listing No. 84.063 Federal Direct Student Loans ? Assistance Listing No. 84.268 Teacher Education Assistance. for College and Higher Education Grants? Assistance Listing No. 84.379 Nursing Student Loans ? Assistance Listing No. 93.364 Recommendation: We recommend that the College work with their third party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely. And we recommend that the College implement formal review procedures to document the review process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procedures will be implemented to enhance the current process to ensure compliance and documentation of review process. The Registrar will formally document the review process for the initial reporting and all corrections submitted by the Assistant Registrar. The Financial Aid Team will expand the random review of select enrollment statuses and maintain documentation of such reviews. Name(s) of the contact person(s) responsible for corrective action: Soo Lee Bruce-Smith, Cheyenne Gaspar, Laura Hughes, Travis Osburn and John Bender Planned completion date for corrective action plan: April 15, 2023

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant ? Assistance Listing No. 84.007 Federal Work Study Program ? Assistance Listing No. 84.033 Federal Perkins Loan Program? Assistance Listing No. 84.038 Federal Pell Grant Program ? Assistance Listing No. 84.063 Federal Direct Student Loans ? Assistance Listing No. 84.268 Teacher Education Assistance. for College and Higher Education Grants? Assistance Listing No. 84.379 Nursing Student Loans ? Assistance Listing No. 93.364 Recommendation: We recommend the College identify and document safeguards over risks identified in the risk assessment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As part of a formal initiative, college IT at LCSC led a college-wide evaluation with the goal of constructing a formal Risk Register. As risks are identified and formally assessed, mitigation strategies are being developed to ensure each identified risk has been properly mitigated. Name(s) of the contact person(s) responsible for corrective action: Marty Gang Planned completion date for corrective action plan: May 19, 2023

Student Financial Aid Cluster ? Assistance Listing No.: Various Recommendation: We recommend the College review its procedures and policies surrounding reporting status changes to NSLDS to ensure their current process in place is reporting accurate effective dates to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The financial aid office and the registrar?s office will collaborate with one another to ensure that files transmitted to the National Student Clearinghouse contain accurate enrollment information, including program begin and end dates. Collaborative measures include monthly samples of withdrawn students to compare institutional information to the NSC file and then reconciling the sampled records to NSLDS. At the end of each semester the program begin and end dates will be tested for a larger sample of unofficial withdrawals and students who cease enrollment from one term to the next to ensure accurate reporting. Name of the contact person responsible for corrective action: John Cage, Director of Financial Aid Planned completion date for corrective action plan: January 31, 2023

Student Financial Assistance Cluster ? CFDA No. 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To ensure data accuracy, the Office of the University Registrar will review, evaluate, and update their current enrollment reporting procedures, as well as assess how reported data is verified and updated. Name(s) of the contact person(s) responsible for corrective action: Shivanthi Anandan, Provost Planned completion date for corrective action plan: April 28, 2023

Student Financial Assistance Cluster ? CFDA No. 84.038 Recommendation: We recommend the University evaluate is procedures and policies around recordkeeping and retention. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Master Promissory Notes are stored securely in the Bursar?s office in locked, fireproof cabinets until they are assigned. The University has sent master promissory notes for delinquent loans to the Department of Education. Assignment of past due loans to Department of Education is processed on a rolling monthly schedule. Original master promissory notes are required for the transfer. If loan records are determined to be missing we will request permission to assign these records to the Department of Education. Name(s) of the contact person(s) responsible for corrective action: Ashley Slowe, Director, Student Accounts Receivable Planned completion date for corrective action plan: April 28, 2023

2022-002 Student Financial Aid ? Assistance Listing No. 84.SFA Recommendation: CLA recommends the College implement a procedure to ensure the program begin date aligns with the first date of attendance, and inquire with the Clearinghouse when Effective Dates per NSLDS do not match the College's records. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Corrective Reports to National Student Clearinghouse: The Assistant Registrar will submit corrective reports to the National Student Clearinghouse (NSC) within one day of receipt of the error file to ensure compliance with reporting timelines. Candidates for Graduation: Completed Graduates: The Assistant Registrar will ensure that the Exit date field and Withdrawal date field for all graduation candidates are updated within 45 days of the last day of the term. Candidates who successfully complete all degree requirements are coded in Jenzabar as GR for graduation. The student record is sealed, and a final transcript is printed. The Assistant Registrar will run the special NSC Graduation Report as an ad hoc report periodically throughout the 45-day period. Candidates who do not complete: The Assistant Registrar will ensure that the Exit field date and the Withdrawal field date is updated for all candidates who do not complete their degree requirements within 45 days of the last day of the term. The departure reason will be updated as NR for non-returning (with the subheading of LOA if appropriate). The Assistant Registrar will run a report for the NSC on the 15th of each month as scheduled (May 15, June 15, etc.). Candidates who do not graduate will be reported to the NSC via the standard monthly report run on the 15th of each month. Enrolled Spring Students who do not register for the fall term: The Assistant Registrar will ensure that all students who are not registered for the fall term by June 5th are coded with the enrollment status of NR (non-returning) in Jenzabar. The Withdrawal and Exit fields in Jenzabar will be updated with the last date of attendance/last day of the term. The Assistant Registrar updates the National Student Clearinghouse (NSC) on the 15th of each month, and NSC subsequently updates the National Student Loan Data System (NSLDS). Students that register for the fall term after June 5th will be updated in Jenzabar, their WD and Exit dates will be revised, and the NSC updated of the new status. Name(s) of the contact person(s) responsible for corrective action: Adrienne Bolyard Dean of Academic Services and Registrar Planned completion date for corrective action plan: The completion date for this corrective action was executed February 24, 2023. This plan will be in effect going forward.

Contact Person(s): Shanell Tilo, Financial Aid Officer Dr. Emilia Le?i, Dean of Student Services Dr. Letupu Moananu, Vice President of Academics, Community, and Student Affairs Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): No disagreement Corrective actions taken/planned: Official Withdrawals: Financial Aid Counselors are responsible for the Identification of Official Withdrawals through the Attendance Pattern Comparison Report (APCR), which is run every Monday (or next business day). Each Counselor (control #1) is responsible for the performance of the R2T4 form for their respective students and forward to the designated Counselor (control #2) to ensure accuracy and completion. Control #2 is responsible to manually input the calculations into Datatel and ensure adjustments, if any, are processed and returned via COD. This action is to be completed and included in the next scheduled batch closure or no later than 45 days from the date of withdrawal. Unofficial Withdrawals: After final grades have been posted at the end of each session or semester, each counselor will review their respective students through student transcript, identify those with ?zero credits earned? and determine last date of attendance. Official Withdrawal procedures will then be performed. Official / Unofficial Withdrawal: All Withdrawals must then be reported to NSLDS by the Financial Aid Coordinator (with FA Officer as alternate) within 45 days. Anticipated completion of the corrective action is expected by June 2023.

Contact Person(s): Grace Tulafono-Asi, Information Officer Sonny Leomiti, Vice President of Administration and Finance Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): No disagreement Corrective actions taken/planned: The College has designated the Chief Information Officer (CIO) and on the following Items were completed in September 2022: a.ASCC Data / Information Security Program b.Risk Assessment that addresses (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures. The risk assessment identified action items to resolve findings and controls that are put in place in the meantime. Action Items and controls are reviewed and updated monthly. In November 2022, The Federal Student Aid (FSA) Cyber Compliance Team confirmed that ASCC has satisfied the minimum information security requirements under Gramm-Leach-Bliley Act (GLBA) and closed its. The next annual complete Risk Assessment will be completed in August 2023, and ASCC will continue to complete a Risk Assessment annually to stay in compliance with GLBA. Anticipated completion of the corrective action is expected by October 2023.