Finding Text
Federal Agency: U.S. Department of Treasury Federal Program Name: Community Development Financial Institutions Equitable Recovery Program Assistance Listing Number: 21.033 Federal Award Identification Number and Year: 22ERP061061 – 2022 Award Period: April 10, 2023 through December 31, 2028 Type of Finding: - Significant Deficiency in Internal Control Over Compliance - Other Matters Criteria or specific requirement: The CDFI ERP Grant Agreement requires recipients to track the use of award funds, maintain separate accounting records, and ensure that the initial payment is fully expended within 12 months of the award announcement date. Furthermore, 2 C.F.R. § 200.305(b)(7) requires entities to deposit advance payments in interest-bearing accounts and remit any interest earned to the federal government, with appropriate documentation retained. Condition: The Credit Union did not maintain supporting documentation to demonstrate that interest earned on unused CDFI ERP funds held in interest-bearing accounts was remitted to the federal government as required. Additionally, the full amount of the initial grant payment was not fully expended within the 12-month period specified in the grant agreement. Questioned costs: None Context: The deficiency was identified during the audit of the SEFA and reconciliation of unearned grant revenue. The original SEFA lacked sufficient documentation, and the timing of expenditures did not align with the grant agreement’s 12-month requirement. The absence of documentation regarding interest earned and remitted may result in audit findings or repayment obligations. Cause: The Credit Union did not implement adequate internal controls to ensure timely and complete documentation of grant expenditures and to monitor compliance with grant terms regarding expenditure timing and interest remittance. Effect: Failure to maintain adequate documentation and comply with grant terms increases the risk of noncompliance with federal requirements. This could result in audit findings, repayment obligations, or other sanctions imposed by the federal awarding agency. Repeat finding: Not a repeat finding. Recommendation: We recommend that the Credit Union implement and enforce internal controls to track and document interest earned on federal funds, ensure timely remittance to the federal government, and monitor compliance with all grant terms, including the 12-month expenditure requirement. Views of responsible officials and planned corrective actions: Management concurs with the finding and acknowledges the significance of the deficiency. They are committed to strengthening internal controls and ensuring full compliance with grant requirements.