Finding 1205071 (2025-002)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-03-31

AI Summary

  • Core Issue: One out of eight loans disbursed under the USDA RMAP was made to an ineligible borrower outside the approved rural service area.
  • Impacted Requirements: Compliance with 7 CFR part 4280 and 2 CFR 200.303, which mandate eligibility verification for loan recipients.
  • Recommended Follow-Up: Enhance eligibility review controls by implementing procedures to verify and document borrower locations before loan approval and disbursement.

Finding Text

Finding Type: Immaterial noncompliance with major program requirements Title and ALN of Federal Program: 10.870 – United States Department of Agriculture Rural Microentrepreneur Assistance Program (USDA RMAP) Finding Resolution Status: In review. Information on Universe and Population Size: Loans disbursed during the period July 1, 2024 to June 30, 2025 from USDA RMAP loan fund. There were 8 unique loans disbursed totaling $227,000. Sample Size Information: All 8 loans were selected for testing eligibility compliance. Identification of Repeat Finding and Finding Reference Number: N/A Criteria: USDA RMAP is governed by 7 CFR part 4280, subpart D, which requires that loans made from the RMAP revolving loan fund be provided to eligible microentrepreneurs located in rural areas as defined in the regulations and the approved work plan for the award. These regulations, together with the Organization’s USDA RMAP agreement and approved work plan, require that loans be made only within the approved rural service area. In addition, 2 CFR 200.303 requires the auditee to establish and maintain effective internal control over compliance with federal statutes, regulations, and the terms and conditions of federal awards, including eligibility requirements for RMAP loan recipients. Statement of Condition: During eligibility testing of loan disbursements under the RMAP program, one of eight disbursements tested was made to a borrower located outside of the eligible area. The loan was disbursed in fiscal year 2025 for $10,000. Cause: Management did not verify the borrower’s business address against the approved rural service area map prior to disbursement. Effect or Potential Effect: Disbursement of RMAP loan funds to an ineligible borrower constitutes noncompliance with program eligibility requirements and may result in questioned costs of $10,000. Auditor Noncompliance Code: E – Eligibility Reporting Views of Responsible Officials: Management agrees with the noncompliance with no sanctions imposed conclusion. Context: No additional context identified by the Organization which is not otherwise presented herein. Recommendation: The Organization should strengthen eligibility review controls over RMAP loan disbursements by implementing procedures to verify and document that each borrower’s business location is within the approved service area prior to loan approval and disbursement. Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations: The Organization concurs with the finding and states that it will enhance its RMAP loan review procedures to ensure borrower locations are verified and documented as being within the approved rural service area prior to loan approval and disbursement. Response Indicator: Agree Completion Date: In process. Response: Management acknowledges noncompliance in the current fiscal year and is reviewing its internal controls over loan disbursements. Questioned Costs: $10,000

Corrective Action Plan

Condition: During eligibility testing of loan disbursements under the RMAP program, one of eight disbursements tested was made to a borrower located outside of the eligible area. The loan was disbursed in fiscal year 2025 for $10,000. Planned Corrective Action: The ECDI processing and loan allocation teams will not exclusively leverage it’s CRM system for determining USDA eligibility based on borrower/business address. The team will use the USDA website in determining eligibility prior to allocating USDA funds to a project. Related to the specific ineligible $10,000 USDA loan, the team has communicated to its USDA partner to make them aware of this specific issue and ECDI is in the process of removing USDA funds and replacing with another source. Contact Person Responsible for Corrective Action: Brian Barrett and Sean Henderson Completion Date: In process

Categories

Eligibility Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1205066 2025-001
    Material Weakness Repeat
  • 1205067 2025-001
    Material Weakness Repeat
  • 1205068 2025-001
    Material Weakness Repeat
  • 1205069 2025-001
    Material Weakness Repeat
  • 1205070 2025-002
    Material Weakness Repeat
  • 1205072 2025-003
    Material Weakness Repeat
  • 1205073 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
59.046 MICROLOAN PROGRAM $1.53M
10.870 Rural Microentrepreneur Assistance Program $754,804
59.043 WOMEN'S BUSINESS OWNERSHIP ASSISTANCE $714,657
21.020 Community Development Financial Institutions Program $673,912
23.001 APPALACHIAN REGIONAL DEVELOPMENT (SEE INDIVIDUAL APPALACHIAN PROGRAMS) $508,736
93.570 Office of Community Services $400,000
59.050 Prime Technical Assistance $289,831
93.576 REFUGEE AND ENTRANT ASSISTANCE DISCRETIONARY GRANTS $272,422
59.044 VETERANS OUTREACH PROGRAM $156,285
10.351 RURAL BUSINESS DEVELOPMENT GRANT $60,773
14.252 SECTION 4 CAPACITY BUILDING FOR COMMUNITY DEVELOPMENT AND AFFORDABLE HOUSING $33,954
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $8,201