Management acknowledges the oversight and agrees with the recommendation to strengthen procurement documentation controls. At the time, FAFCU utilized a third-party vendor management service, CUVM, to perform vendor verification and ensure that all vendors were adequately reviewed. However, followin...
Management acknowledges the oversight and agrees with the recommendation to strengthen procurement documentation controls. At the time, FAFCU utilized a third-party vendor management service, CUVM, to perform vendor verification and ensure that all vendors were adequately reviewed. However, following the merger and given that more than 15 months have passed since, the current Credit Union no longer maintains documentation from CUVM, as CUVM is not a vendor of the merged institution. While no improper expenditures were identified, CU1 recognizes the importance of maintaining evidence of suspension and debarment checks when federal funds are used. This finding relates to expenditures incurred prior to the merger, and following the merger, the current Credit Union is no longer a member of the CDFI Fund. Accordingly, the procurement requirements under CDFI ERP and Uniform Guidance no longer apply. To address the finding, CU1 has: • Documented the procurement oversight issue as part of merger due diligence. • Confirmed that no questioned costs were identified and no further vendor payments will be made under the CDFI ERP program. As CDFI Fund membership and federal procurement requirements no longer apply post-merger, no additional corrective actions are necessary. Expected Completion Date – Completed Responsible Parties – Wendy Gorevan, CFO (FAFCU pre-merger) and Scott McDonald, CFO (post-merger)