Finding 1156801 (2024-001)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-09-30

AI Summary

  • Core Issue: LHOME did not meet the required performance goals for loan disbursements, achieving only $125,000 against a benchmark of $437,500.
  • Impacted Requirements: Noncompliance with CDFI Program regulations affects LHOME's standing and could lead to sanctions.
  • Recommended Follow-Up: LHOME should enhance marketing efforts, optimize services, and collaborate with CDFI to adjust performance goals and improve borrower readiness.

Finding Text

FEDERAL AWARD FINDING: Community Development Financial Institution Program – Financial Assistance CFDA No. 21.020; Grant No. 221FA059863 2024-001 Reporting - Performance Goals and Measures CONDITION: LHOME did not meet the established performance goals and measures as required under the terms and conditions of the federal award. Specifically, LHOME failed to achieve the benchmark of $437,500 in qualified loan fund disbursements for this federal award. LHOME disbursed $125,000 in qualified loan funds for this federal award for the year ended December 31, 2024. CRITERIA: As required by the Community Development Financial Institution (CDFI) Program regulations, LHOME is required to comply with certain performance goals. CAUSE: External factors were present as LHOME expressed challenges due to many prospective borrowers facing restricted cash flow which limited their ability to qualify for larger loans that would support both the prospective borrower’s business profitability and ongoing debt service. LHOME also noted that declining consumer confidence and increased inflation contributed to the lower demand and requests for smaller loans. EFFECT: LHOME’s noncompliance impedes CDFI’s ability to assess program success and can result in imposed sanctions on LHOME by CDFI. CONTEXT: During our review of LHOME’s performance progress reports submitted to CDFI, we became aware that LHOME did not meet its required performance goals and measures. RECOMMENDATION: We recommend that LHOME attempt to expand its target reach by increasing marketing and by optimizing its products and services to appeal to new customers/borrowers. LHOME could also collaborate with CDFI and their recommendations on meeting federal program benchmarks when external factors are present and influential. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS: Management acknowledges and agrees with the finding. LHOME will request a grant amendment to decrease Performance Goals and Metrics (PG&M) to align with the actual cash award, strengthen market outreach and partner referrals, enhance borrower readiness through targeted development services, and explore the development of a business incubator designed for existing businesses with growth potential, offering technical assistance, mentorship, and access to financing pathways.

Corrective Action Plan

September 26, 2025 Response to Findings – Views of Responsible Officials and Corrective Active Plan LHOME respectfully submits the following response to the federal award finding for the year ending December 31, 2024. Hicks and Associates, CPAs, PLLC 1795 Alysheba Way, Suite 6206 Lexington, KY 40509 Audit Period: January 1, 2024 – December 31, 2024 The findings from the FYE December 31, 2024, schedule of findings and questioned costs are discussed below and include LHOME’s management responses. Finding: 2024-001 Reporting – Performance Goals and Measures RECOMMENDATION: We recommend that LHOME attempt to expand its target reach by increasing marketing and by optimizing its products and services to appeal to new customers/borrowers. LHOME could also collaborate with CDFI and their recommendations on meeting federal program benchmarks when external factors are present and influential. RESPONSE: LHOME entered into a grant agreement in February 2023 to launch a new “strong roots” program. The grant performance goals and metrics (PG&M) were determined based on the grant application. The strong roots program supported loans to existing businesses with at least two years of operating history and focused on expansion. The minimum loan amount for the strong roots program was $50,000. The first period of performance (POP) ending December 31, 2024 and the goal was to disburse $437,500 through the strong roots program. The rules to prorate PG&Ms to match the cash award were not yet in place within the CDFI. LHOME successfully disbursed $125,000 in loans but below the goal of $437,500, creating the instance of non-compliance. No sanctions were imposed by the CDFI since this is the first POP for the grant. Response to Findings – Views of Responsible Officials and Corrective Active Plan - continued This shortfall is primarily due to the following factors: • CDFI rules require full achievement of goals stated in the application regardless of the awarded amount. Goals are not prorated to align with the actual cash award. • Restricted cash flow among prospective borrowers, limiting their ability to qualify for larger loans. • Declining consumer confidence and increased inflation, resulting in lower demand and a shift toward smaller loan requests. • Economic instability and increased delinquency rates on existing loans, creating additional pressure on organizational cash flows. • Launching a new loan product in a challenging economic environment, which required more time for market acceptance and borrower readiness. Corrective Actions: 1. Request a grant amendment to decrease Performance Goals and Metrics to align with the actual cash award. 2. Strengthen Market Outreach and Referral Networks • Expand marketing activities to increase awareness of the grant-funded loan product. • Partner with local banks, credit unions, business development organizations, and technical assistance providers to increase referrals and reach businesses that meet the loan size criteria. • Use targeted campaigns focusing on businesses with demonstrated growth potential. 3. Enhance Borrower Readiness and Capacity • Work closely with external development service providers to ensure their understanding of LHOME’s underwriting requirements. • Require external development to address cash flow issues, strengthen financial statements, and prepare borrowers to qualify for larger loans. 4. Develop a Business Incubator Program • Explore the development of a business incubator designed for existing businesses with growth potential, offering technical assistance, mentorship, and access to financing pathways. • Provide some structured support to help businesses scale operations to qualify for $50,000+ loans. Through the combined efforts of grant amendments, expanded marketing, targeted development, and stronger partnerships, LHOME is expected to meet performance goals and metrics for the CDFI compliance by the end of fiscal year 2025. Respectfully, Keith Talley, Sr President & CEO

Categories

Reporting Matching / Level of Effort / Earmarking

Programs in Audit

ALN Program Name Expenditures
14.218 Community Development Block Grants/entitlement Grants $322,289
21.033 Community Development Financial Institutions Fund Equitable Recovery Program (cdfi Erp) $295,518
21.020 Community Development Financial Institutions Program $225,000