Finding Text
Finding 2025-001 - Significant Deficiency: Special Tests and Provisions - Compliance and Control Finding Student Financial Aid Cluster Federal Agency: U.S. Department of Education Federal Award Number: 84.007, 84.033, 84.063, 84.379 and 84.268 Criteria: 34 CFR 668.164(e) requires a school to provide an up-to-date URL for Tier One Arrangement contracts and cost information for students related to those contracts for publication in a centralized database accessible to the public. Condition: The University did not disclose the URL for its cash management contract with Bank Mobile (a Tier One Arrangement) to the Department of Education timely as the contract had been in place since 2013 and the communication of the URL was not sent to the Department of Education until July 2025. Cause: The University did not have adequate internal controls to ensure ongoing monitoring of federal disclosure requirements related to Tier One arrangements. Specifically, responsibility for submitting and updating the required URL in the Department of Education’s centralized database was not clearly assigned, and no periodic compliance review process was in place to detect the missing disclosure. Effect: Failure to timely disclose the URL for the University’s Tier One Arrangement resulted in noncompliance with 34 CFR 668.164(e). The lack of timely reporting increases the risk that required information is not readily available to the public or to the Department of Education. Questioned Cost: None. Context: During review of the University’s compliance with Tier One Arrangement requirements, it was noted that the University had entered into a contract with BankMobile dating back to 2013 that met the requirements of a Tier One Arrangement when the Department of Education’s Cash Management Final Regulations were published in 2015. The disclosure requirements were effective beginning in the year ended June 30, 2017; however, we identified that the University’s contract was not listed on the Department of Education’s cash management contract listing during our audit for the year ended June 30, 2025. Identification As A Repeat Finding: Not a repeat finding. Recommendation: We recommended to management that the University provide the required updates to the Department of Education and that the University monitor the Department of Education’s cash management contract listing periodically to ensure that the Department of Education updates its listing with the correct URLs for the contract and required disclosure information. Views Of Responsible Officials: Management has made the appropriate updates and communicated the URLs for its contract and cost information to the Department of Education in July 2025 for its contract with BankMobile. Management will monitor the Department of Education’s cash management contract listing and will ensure that the contract is listed once the Department of Education updates its cash management contracts database as the most recent update to the cash management contracts database published by the Department of Education listed an update date of mid-January 2024. Completion Date: July 2025 Contact Person: Joanne Rozborski, Assistant Vice President, Student Financial Services