Finding 11896 (2023-003)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-02-06

AI Summary

  • Core Issue: Incomplete internal loan checklists were found in microloan files, violating federal compliance requirements.
  • Impacted Requirements: The lack of proper documentation undermines the internal controls mandated by 2 CFR section 200.204.
  • Recommended Follow-Up: Implement tailored checklists for each loan program to ensure all necessary documents are included before loan issuance.

Finding Text

Microloan Program Assistance Listing Number 59.046 Grant Numbers SBAOCAML220293/230448; Grant period – Year(s) ended June 30, 2023 and June 30, 2024. Criteria: Per the OMB Compliance Supplement, the 2 CFR section 200.204 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: Improper or lack of completion of the Organization’s internal loan checklist within microloan files tested, which was identified as an internal control over the completeness of loan file documentation. Cause: Loan checklists were not completed by responsible officials. Effect: Loan files subjected to testing did not include the required documents. Repeat Finding: N/A Recommendation: Policies and procedures should be put in place to eliminate the risk of loan documents not being included in the files, this includes the use of pre-approved checklists that ensure personnel reviewing the loan files notate that all required documentation is retained in the loan file, prior to final issuance of the loan. The checklists should be tailored to specific requirements for each relevant loan program, should required documentation among loan programs vary. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the recommendation to utilize a checklist specific to each loan program to ensure all required documents are entered into files. The Organization has implemented a loan filing system for each loan program dividing out the necessary documents required to be inserted into each loan file. The Production and Servicing Departments will be responsible for completing and reviewing the files to ensure all sections have been completed and updated as needed.

Corrective Action Plan

Management agrees with the recommendation to utilize a checklist specific to each loan program to ensure all required documents are entered into loan files. The organization has implemented a loan filing system for each loan program dividing out the necessary documents required to be inserted into each loan file. The Production and Servicing Departments will be responsible for completing and reviewing the files to ensure all sections have been completed and updated as needed.

Categories

Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 11895 2023-002
    Significant Deficiency
  • 11897 2023-002
    Significant Deficiency
  • 11898 2023-003
    Significant Deficiency
  • 11899 2023-002
    Significant Deficiency
  • 11900 2023-003
    Significant Deficiency
  • 588337 2023-002
    Significant Deficiency
  • 588338 2023-003
    Significant Deficiency
  • 588339 2023-002
    Significant Deficiency
  • 588340 2023-003
    Significant Deficiency
  • 588341 2023-002
    Significant Deficiency
  • 588342 2023-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
59.046 Microloan Program $360,000
21.020 Community Development Financial Institutions Program $338,416
21.033 Covid-19 - Community Development Financial Institutions (cdfi) Prorgam, Equitable Recovery Program $322,506
14.218 Community Development Block Grants/entitlement Grants $121,098