Finding 1165331 (2025-001)

Assistance Listing, Federal Agency, and Program Name - 84.007, 84.033, 84.038, 84.063, 84.268; U.S. Department of Education; Student Financial Assistance Cluster Federal Award Identification Number and Year - 2024-2025 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - For Tier 1 and Tier 2 banking arrangements, the institution must perform a due diligence review at least every two years to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates (34 CFR 668.164(e)(2)(ix) and (f)(4)(vii)). Condition - The University did not have controls in place to ensure that the required due diligence review was completed in the last two year period related to the current established contract. Questioned Costs - None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - N/A Identification of How Questioned Costs Were Computed - N/A - there are no questioned costs related to the applicable compliance requirement. Context - The University did not perform a due diligence review in the last two year period related to the existing contract. There was only one contract in place during the year ended June 30, 2025. Cause and Effect - A control was lacking to ensure the required due diligence review was performed. Recommendation - We recommend a control be implemented to ensure a due diligence review is performed at least every two years. Views of Responsible Officials and Corrective Action Plan - In order to ensure that the terms of the consumer accounts offered through UC’s Tier 1 banking agreement are not inconsistent with the best financial interest of students who choose to open an account, UC Campus Services will, at a minimum, every 2 years, beginning October 2025: a. Conduct a due diligence review to ascertain whether the fees imposed under the current agreement are consistent with or below prevailing market rates. a. This will be accomplished by downloading and comparing “consumer schedule of fees” documents from UC’s current provider as well as several local competitors (e.g. US Bank, Fifth Third Bank, Chase Bank, Superior Credit Union). b. Ensure that termination provisions are maintained in the active agreement. These provisions are listed in the current agreement under Exhibit G. 4. (g). (1). In addition, the university will organize a Title IV compliance working group to meet monthly to review any communications or new requirements published by the U.S. Department of ED, State of Ohio, or other regulatory agencies. This core working group will be comprised of members of the Student Financial Aid Office, the Office of the Bursar, and the Office of the Controller, the three offices primarily responsible for awarding, disbursing, and drawing down funds related to the Title IV programs. This group will be responsible for communicating any changes to institutional responsibilities to other university partners who may need to review or revise policies and procedures based on the regulatory changes.