Finding 1176909 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-09
Audit: 390778
Organization: Presbyterian College (SC)
Auditor: CAPINCROUSE LLC

AI Summary

  • Core Issue: The College failed to maintain proper reserve accounts for USDA loans, lacking necessary documentation for three out of four accounts.
  • Impacted Requirements: This noncompliance violates the USDA loan agreements as outlined in 7 CFR 1942.17(i)(2).
  • Recommended Follow-Up: The College should work with its USDA loan representative to clarify reserve requirements and establish any missing accounts by June 30, 2025, while implementing procedures for ongoing compliance.

Finding Text

USDA Community Facilities Loan Reserve Accounts Material Weakness U.S. DEPARTMENT OF AGRICULTURE ALN #: 10.766 Community Facilities Loans and Grants Federal Award Identification #: CPAP000000422525, CPAP000000422526, CPAP000000422527, CPAP000000422528, CPAP000000422529, GLSX0002129718 Condition: The College is required to establish and maintain designated reserve accounts for its USDA loans in accordance with the loan agreements. While sufficient assets appear to be available, the required segregation and documentation for three of the four reserve accounts could not be located. Criteria: 7 CFR 1942.17(i)(2) Questioned Costs: $0 Context: The College did not administer its loan reserve accounts in accordance with the requirements outlined in its USDA loan agreements. Cause: Due to turnover in key management positions since the loans originated, the College did not have adequate procedures in place to monitor and ensure ongoing compliance with the loan reserve requirements outlined in the various USDA loan agreements. Effect: Failure to establish and maintain the required reserve accounts increases the risk of noncompliance with the loan agreements and potential adverse action by the lender. Identification as repeat finding, if applicable: Recommendation: We recommend the College consult with its USDA loan representative to confirm the specific reserve requirements for all active loan agreements. The College should establish any required reserve accounts that have not been funded as of June 30, 2025, and implement formal procedures to ensure ongoing compliance with reserve requirements and continuity of oversight during future transitions in key positions. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

USDA Community Facilities Loan Reserve Accounts Planned Corrective Action: Since the USDA loans were settled on December 10, 2020, Presbyterian College has held the required restricted reserves within its investment accounts. The College has confirmed with its USDA loan representative that a fully funded reserve is equal to the total annual payment for each loan. At all times, sufficient assets were maintained to meet the required reserve levels; however, the accounts were not separately titled or formally documented in accordance with the specific administrative requirements of the loan agreements. As soon as is practical, and following guidance regarding timing, the College will work with its investment advisors to make the administrative change to transfer the required balances into separately titled accounts designated “USDA Reserve Account.” The clear account description will ensure proper segregation and documentation of required reserves and prevent these funds from being commingled with other institutional funds in the future. In addition, the Finance Office will document reserve calculations and maintain supporting documentation to ensure ongoing compliance with USDA reserve requirements. Person Responsible for Corrective Action Plan: Elizabeth Oswald-Sease, Vice President of Finance and Administration and Elizabeth Shull, Controller Anticipated Date of Completion: As soon as is practical, but no later than July 1, 2026

Categories

Material Weakness Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Programs in Audit

ALN Program Name Expenditures
10.766 COMMUNITY FACILITIES LOANS AND GRANTS $56.00M
84.268 FEDERAL DIRECT STUDENT LOANS $14.79M
84.063 FEDERAL PELL GRANT PROGRAM $2.40M
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $300,120
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $205,229
84.033 FEDERAL WORK-STUDY PROGRAM $139,233
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $104,400
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $31,659
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $11,316
43.001 SCIENCE $9,327
43.008 OFFICE OF STEM ENGAGEMENT (OSTEM) $7,500