Management acknowledges the oversight and agrees with the recommendation. At the time of the finding, the Credit Union had not established written policies and procedures specific to the administration of the CDFI ERP program, which was required under the grant agreement. However, this finding relates to the pre-merger entity’s administration of the CDFI ERP program. Since the merger, the current Credit Union is no longer a member of the CDFI Fund and therefore does not participate in federal programs subject to these requirements. Accordingly, the development of written policies and procedures related to federal grant administration is no longer applicable. To address the finding: • The issue has been documented as part of merger due diligence. • Management has confirmed that no further actions are required, as the current Credit Union does not administer CDFI or federal grant programs. CU1 will prepare adequate policies and procedures if it becomes applicable in the future. Expected Completion Date – Completed Responsible Parties – Wendy Gorevan, CFO (FAFCU pre-merger) and Scott McDonald, CFO (post-merger)