Finding 1159858 (2024-004)

Material Weakness Repeat Finding

Requirement

Questioned Costs

Year

2024

Accepted

2025-10-03

Audit: 370401

Organization: Opportunities Credit Union (VT)

Auditor: Rsm US LLP

AI Summary

Core Issue: The CDFI Performance Progress Report was submitted with incorrect dates, covering January 1, 2024, to December 31, 2024, instead of the required timeframe.
Impacted Requirements: This error violates the grant agreement's requirement for timely and accurate reporting through AMIS.
Recommended Follow-Up: Implement stronger controls to ensure accurate reporting in line with grant requirements and monitor compliance regularly.

Finding Text

Identifying Number: 2024-004 Information on the Federal Program: ALN#21.033, U.S. Department of Treasury: COVID-19 Community Development Financial Institutions Fund Equitable Recovery Program (CDFI ERP) Criteria or Specific Requirement: The grant agreement specifies in Section A: Annual Reports, Performance Report Requirements, Performance Progress Reports and Uses of Award Reports must be submitted through AMIS. The CDFI Performance Progress Report and Uses of Award Report for Year 1 period of performance timeframe was from April 10, 2023 through December 31, 2024. Condition: The CDFI Performance Progress Report and Uses of Award Report for Year 1 was prepared by accounting, reviewed by management and submitted to CDFI timely, however the report was only completed for the timeframe January 1, 2024 through December 31, 2024. The reports were corrected and resubmitted. Cause: Management did not have effective controls in place to detect errors in the CDFI reports submitted. Effect: Failure to properly review can result in inaccurate reporting to CDFI and noncompliance with the grant agreement. Questioned Costs: Not applicable. Context: The reporting requirement is applicable only to this grant and therefore isolated. The population was tested 100%, therefore statistically valid. Repeat Finding: Not applicable. Recommendation: Procedures should be implemented and placed in service to ensure required reporting is completed according to the grant agreement. Views of responsible individuals: Management agrees with the Finding and recommendation. See corrective action plan for further information.

Corrective Action Plan

Management acknowledges the error and agrees with the recommendation to strengthen reporting controls. While the report was ultimately corrected and resubmitted, CU1 recognizes the importance of ensuring all reports align with the required performance timeframe. It should be noted that this reporting error occurred prior to the recent merger. Following the merger, the Credit Union is no longer a member of the CDFI Fund, and therefore the CDFI ERP reporting requirements will not apply going forward. To address the finding, CU1 has: • Corrected and resubmitted the Year 1 reports to ensure compliance with the grant agreement at the time. • Documented the issue as part of merger due diligence to ensure transparency and closure. As CDFI Fund membership and related reporting obligations no longer apply post-merger, no further corrective actions are necessary beyond these steps. Expected Completion Date – Completed Responsible Parties – Wendy Gorevan, CFO (FAFCU pre-merger) and Scott McDonald, CFO (post-merger)

Other Findings in this Audit

1159859 2024-005

Material Weakness Repeat
1159860 2024-006

Material Weakness Repeat
1159861 2024-007

Material Weakness Repeat

Programs in Audit

ALN	Program Name	Expenditures
21.033	Community Development Financial Institutions Fund Equitable Recovery Program (cdfi Erp)	$883,705
21.025	Small Dollar Loan Program	$23,724
21.020	Community Development Financial Institutions Program	$13,172