Finding 1172831 (2025-002)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-02-09

AI Summary

  • Core Issue: Internal controls were ineffective, leading to a loan disbursed to a business outside the approved county listing.
  • Impacted Requirements: The Foundation failed to ensure compliance with SBA's county eligibility criteria, resulting in $15,965 in questioned costs.
  • Recommended Follow-Up: Management should review and strengthen loan approval processes to confirm business eligibility based on the SBA's approved county listing.

Finding Text

Agency: U.S. Small Business Administration (SBA) Assistance Listing Number: 59.046 Federal Program Title: 2025 Microloan Program Statement of condition: The internal controls over compliance were not operating effectively as a loan was disbursed to a business which operates outside of the approved county listing set by the SBA. Criteria: The Foundation failed to maintain effective internal controls over compliance to approve eligible businesses in compliance with counties set by the SBA. Questioned costs: The known questioned costs are $15,965. Context: During our testing, we sampled seven loans funded by the SBA. Out of the sample tested, one (1) had business operations during the application process within an approved county listing, however, at closing the business was outside of the approved county listing resulting in funds provided to an ineligible recipient. The sample size was not a statistical sample. Effect: The Foundation provided funds to a business which was not eligible to receive funding from the program. Cause: The Foundation did not have effective controls in place to confirm businesses operating in eligible counties at closing in which funding could be provided. Recommendation: We recommend management review their processes and controls over approval of loans to ensure the business operates in a county on the approved county listing provided by the SBA Management's Response: The Foundation has created a procedure for loans assigned to SBA as the loan capital funding source to verify before closing that the county for the business is in a SBA approved county The Foundation has since taken corrective actions by updating internal controls and training of staff involved in SBA loan disbursements. The Foundation has also received approval from the SBA to fund the business in the previously unapproved county subsequent to year end.

Corrective Action Plan

Condition The internal controls over compliance were not operating effectively as a loan was disbursed to a business which operates outside of the approved county listing set by the SBA. Corrective Action Plan Corrective Action Planned: The Foundation had 26 approved counties across the lower half of Michigan for businesses eligible to be funded by SBA loan capital. MWF assigned SBA funding to an applicant that was initially identified as being in an eligible county. However, by the time of the loan closing, the applicant had settled on a brick and mortar store located in a county that is not on MWF’s SBA approved list. MWF has created a procedure for loans assigned to SBA as the loan capital funding source to verify before closing that the county for the business is in an SBA approved county. The Foundation has also received approval from the SBA to fund loans for business in the previously unapproved county subsequent to year end. Name(s) of Contact Person(s) Responsible for Corrective Action: Tamara Jackson, the director of lending, will verify all loans assigned to SBA loan capital prior to closing the county of the business and confirm it is an eligible county for MWF Anticipated Completion Date: The procedure described above was created, MWF’s credit policy and MWF’s closing checklist reflect this procedure which was implemented in the first quarter of FY2026.

Categories

Eligibility Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Programs in Audit

ALN Program Name Expenditures
59.046 MICROLOAN PROGRAM $1.93M
21.031 STATE SMALL BUSINESS CREDIT INITIATIVE TECHNICAL ASSISTANCE GRANT PROGRAM $200,413
21.033 COMMUNITY DEVELOPMENT FINANCIAL INSTITUTIONS FUND EQUITABLE RECOVERY PROGRAM (CDFI ERP) $154,150
21.020 COMMUNITY DEVELOPMENT FINANCIAL INSTITUTIONS PROGRAM $105,213