Finding 1101171 (2024-001)

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Requirement
C
Questioned Costs
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Year
2024
Accepted
2025-02-27
Audit: 344151
Auditor: Uhy LLP

AI Summary

  • Core Issue: All sampled SBA Microloan payments were transferred to the MRF account beyond the required 10 working days, violating program guidelines.
  • Impacted Requirements: The Microloan Program's SOP mandates timely transfers of payments to the MRF, which were not adhered to due to inadequate monitoring procedures.
  • Recommended Follow-Up: Review and enhance monitoring processes to ensure compliance with the 10 working day transfer requirement, as management has already begun implementing weekly transfers.

Finding Text

Federal Agency: U.S. Small Business Administration Federal Program: Microloan Program (59.046) Federal Award Numbers: Federal Award Years: Reference: 2024-01 Criteria Microloan Program Standard Operating Procedures Manual (SOP 52 00 B), effective July 1, 2018, section 3.D.4 Microloan Revolving Fund (MRF) states all SBA Microloan payments must be transferred from the operating account to the MRF within two weeks (10 working days) of receipt or by the end of the quarter, whichever occurs first. Condition During the fiscal year ended September 30, 2024, we selected a sample of 40 SBA Microloan payments. We traced the flow of funds from receipt of the payments from the borrower to the date of transfer into the MRF account. All 40 loans in the sample had transfers beyond the 10 working day threshold ranging from 17 to 29 working days after receipt of the SBA Microloan Payment. Cause Monitoring procedures implemented by the Company to ensure compliance with the Microloan Program did not include a review of the MRF account to ensure funds are transferred in accordance with the 10 working day requirement. Possible Asserted Effect Without established monitoring procedures over the 10 working day requirement for transfers, non-compliance may continue. Questioned Costs Cannot be determined. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding No Recommendation We recommend that the Company review its monitoring procedures to ensure that funds are transferred to the MRF account within 10 working days from payment receipt from the borrower to the transfer into the MRF account. Views of Responsible Individuals We acknowledge the auditor’s comments and can confirm that the following corrective action has been implemented as of December 2024: Management has revised the process for identifying, segregating, and transferring Microloan repayments from a monthly process to a weekly process. This change will ensure Microloan repayments received by our operating account are transferred to the appropriate MRF accounts within 10 working days. By changing the frequency of this task, we will enhance our compliance with Microloan requirements and more effectively manage Microloan program funds.

Categories

Subrecipient Monitoring Matching / Level of Effort / Earmarking

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
59.046 Microloan Program $1.97M
21.033 Community Development Financial Institutions Fund Equitable Recovery Program (cdfi Erp) $797,000
21.020 Community Development Financial Institutions Program $496,551
59.050 Prime Technical Assistance $250,000
59.077 Community Navigator Pilot Program $16,451