FAC Explorer

Finding 1224425 (2023-024)

Material Weakness Repeat Finding
Requirement
F
Questioned Costs
-
Year
2023
Accepted
2026-07-22
Audit: 407734
Organization: Commonwealth of the Northern Mariana Islands (MP)
Auditor: ERNST & YOUNG (CNMI) INC

AI Summary

  • Core Issue: CNMI's capital asset listing is inaccurate and does not comply with federal requirements, leading to potential noncompliance with equipment management regulations.
  • Impacted Requirements: Failure to maintain proper records and conduct annual physical inventory counts as mandated by 2 CFR 200.313, affecting asset tracking and safeguarding.
  • Recommended Follow-Up: CNMI should seek federal support to enhance its financial management system and implement stronger monitoring controls for accurate property records and timely inventory counts.

Finding Text

Finding No. 2023-024 Federal Agency: U.S. Department of Transportation AL Program: 20.205 Highway Planning and Construction (Federal-Aid Highway Program) Federal Award Nos.: 3000013, FY10002, 3000003, FY14001 Area: Equipment and Real Property Management Questioned Costs: Undeterminable Criteria: In accordance with 2 CFR 200.303(a), the recipient and subrecipient must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Additionally, in accordance with 2 CFR Section 200.313(b), a state must use, manage, and dispose of equipment acquired under a federal award in accordance with state laws and procedures. The CNMI Property Management Policies and Procedures states that the Division of Procurement & Supply (PS) should conduct an annual inventory of property held by a designated official who has administrative control over the use of personal property within his area of jurisdiction. Also, PS shall perform random audits of property held by each accountable person to validate the integrity of the property control process. Further, in accordance with 2 CFR Section 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or another identification number, the source of funding for the property (including the Federal award identification number), the title holder, the acquisition date, the cost of the property, the percentage of the Federal agency contribution towards the original purchase, the location, use and condition of the property, and any disposition data including the date of disposal and sale price of the property. Lastly, 2 CFR 200.313(d)(3) requires that adequate maintenance procedures must be developed to keep the property in good condition. Condition: 1. CNMI’s capital asset listing is not prepared in accordance with 2 CFR 200.313(d)(1) and does not contain accurate information regarding the state or condition of the capital assets. Based on the physical inspection performed, some assets are already disposed but still included in the capital asset listing, resulting in the inability to ascertain the completeness of the population. In addition, CNMI did not provide the program’s schedule of disposals during the fiscal year. There was no federal capital assets charged to the program for FY2023. Finding No. 2023-024, continued Federal Agency: U.S. Department of Transportation AL Program: 20.205 Highway Planning and Construction (Federal-Aid Highway Program) Federal Award Nos.: 3000013, FY10002, 3000003, FY14001 Area: Equipment and Real Property Management Questioned Costs: Undeterminable Condition, continued: 2. CNMI did not provide the result of the physical inventory count. Accordingly, we were unable to verify if all capital assets are safeguarded and maintained properly as we did not receive both a capital asset listing that is complete and accurate and a supporting physical inventory count result that would include information of all existing assets. Cause: 1. CNMI lacks human resources and financial management system structure that would ensure all federally funded capital assets are traceable to specific programs used to purchase the equipment or real property and that proper monitoring is done to ensure that a capital asset listing is maintained and updated accordingly. 2. CNMI does not have an established policy and procedure to ensure that the annual physical inventory count is performed and to verify during the count that the federal capital asset is safeguarded and maintained in good working condition. Effect of Potential Effect: CNMI is in noncompliance with applicable equipment and real property management compliance requirements. Questioned costs cannot be determined as CNMI could not provide the program’s capital assets listing. Recommendation: CNMI should strengthen and enforce compliance with equipment and real property management compliance requirements over the following: 1. Consider seeking technical and financial support from Federal agencies to develop human resources and a financial management system capable of effecting compliance with applicable property management policies and procedures. 2. Responsible personnel should establish and implement effective monitoring controls to ensure that property records are accurately segregated by federal funding sources and that it is structured to be in accordance with the provisions of 2 CFR 200.313 (d). Finding No. 2023-024, continued Federal Agency: U.S. Department of Transportation AL Program: 20.205 Highway Planning and Construction (Federal-Aid Highway Program) Federal Award Nos.: 3000013, FY10002, 3000003, FY14001 Area: Equipment and Real Property Management Questioned Costs: Undeterminable Recommendation, continued: 3. Implement more stringent monitoring procedures to ensure that the annual physical inventory count is timely conducted and that part of the procedures performed is to verify if the equipment is safeguarded and maintained in good working condition. Identification as a Repeat Finding: This is not a repeat finding. Views of Responsible Officials: Condition 1 - DPW, TSD - Highway Branch agrees with this finding. Highway Branch has consistently tried to work with Procurement Services to update its yearly inventory records to remove all transferred and disposed properties from its inventory record to no avail. Additionally, Procurement Services Division agrees with this finding. Improvements are needed in the way federally funded assets are tracked and reported. At present, the inventory management system is not configured to readily identify assets by specific federal award number, which makes it difficult to generate reports identifying assets purchased under individual grants. In addition, staffing limitations have affected the Commonwealth’s ability to maintain and readily produce this information. Condition 2 - DPW, TSD - Highway Branch agrees with this finding. The Highway Branch has updated its Inventory Form to include the required information such as date acquired, item number, property/tag number, description of property, manufacturer, model, serial number, purchase order number/contract number, condition code, project number, FHWA project number, percentage of federal participation, location, person assigned and the date the inventory was conducted. Additionally, Division of Procurement Services agrees with this finding. The Division agrees that the annual physical inventory required for FY2023 was not completed. As a result, the existence, location, condition, and accountability of all assets could not be fully verified during the audit period. Refer to CNMI’s Corrective Action Plan for additional information.

Corrective Action Plan

Finding No.: 2023-024 AL Program: 20.205 – Highway Planning and Construction (Federal-Aid Highway Program) Area: Equipment and Real Property Management Questioned Costs: Undeterminable Contact Person(s): Stacy Atalig, Federal Programs Coordinator, DPW / Geraldine Cruz, Procurement Services Director Corrective Action Plan: Condition 1: DPW, TSD – Highway Branch agrees with this finding. Highway Branch has consistently tried to work with Procurement Services to update its yearly inventory records to remove all transferred and disposed properties from its inventory record to no avail. Request for Survey-Out forms for damaged, past its useful life or obsolete properties and Request for Transfer of old or inactive but still usable equipment to Divisions within the Department of Public Works were transmitted along with the Fiscal Year inventory list to Procurement Services to update its list but still encounter discrepancies because of Procurement Services overall lump sum master list including inventories of both local and federal properties. Highway Branch conducts its yearly inventory count and submits its list to Procurement Services. However, Procurement Services has not conducted its own inventory for our office for several years. Additionally, the Procurement Services Division agrees with this finding. Improvements are needed in the way federally funded assets are tracked and reported. At present, the inventory management system is not configured to readily identify assets by specific federal award number, which makes it difficult to generate reports identifying assets purchased under individual grants. In addition, staffing limitations have affected the Commonwealth's ability to maintain and readily produce this information. To address this issue, the Property Management Branch has developed a revised Standard Operating Procedure (SOP), which is currently under review and pending finalization. The SOP strengthens procedures related to asset acquisition, tagging, inventory management, record retention, transfers, surveys, disposals, and supporting documentation. The Commonwealth is also evaluating available options to improve tracking and reporting of federally funded assets, including system enhancements, alternative tracking methods, technical assistance, and additional staffing resources where feasible. Finding No.: 2023-024, continued AL Program: 20.205 – Highway Planning and Construction (Federal-Aid Highway Program) Area: Equipment and Real Property Management Questioned Costs: Undeterminable Contact Person(s): Stacy Atalig, Federal Programs Coordinator, DPW / Geraldine Cruz, Procurement Services Director Corrective Action Plan: In the meantime, the Property Management Branch has begun asset reconciliation efforts, including physical inventories, record reviews, asset verification, and updates to inventory records. These efforts will continue while the revised SOP is finalized and implemented. These actions will help improve accountability, strengthen inventory records, and support compliance with federal property management requirements. Proposed Completion Date: Completed - Ongoing Condition 2: DPW, TSD – Highway Branch agrees with this finding. The Highway Branch has updated its Inventory Form to include the following required information: Date Acquired, Item No, Property/Tag No., Description of Property, Manufacturer, Model, Serial No., Purchase Order No./Contract No., Condition Code, Project No., FHWA Project Number, Percentage of Federal Participation, Location, Person Assigned, and the date the inventory was conducted. In September 2025, Federal Program Coordinator IV met with Director of Procurement Services to ensure these line items are incorporated into the inventory log sheet as part of the requirements. The Director agreed to instruct her staff to implement these updates beginning FY2025. Additionally, the Procurement Services Division agrees with this finding. The Division agrees that the annual physical inventory required for FY2023 was not completed. As a result, the existence, location, condition, and accountability of all assets could not be fully verified during the audit period. To address this issue, Section 3 of the CNMI Property Management Policies and Procedures Manual was updated on September 9, 2024, changing the physical inventory requirement from an annual inventory to a biennial (every two years) inventory cycle. Finding No.: 2023-024, continued AL Program: 20.205 – Highway Planning and Construction (Federal-Aid Highway Program) Area: Equipment and Real Property Management Questioned Costs: Undeterminable Contact Person(s): Stacy Atalig, Federal Programs Coordinator, DPW / Geraldine Cruz, Procurement Services Director Corrective Action Plan: Property Management Branch is currently conducting physical inventories and random asset audits throughout the Commonwealth. These efforts include verifying asset locations, confirming accountability, reviewing asset condition and operational status, reconciling inventory records, and identifying assets that require transfer, survey, repair, replacement, or other corrective action. These inventory and reconciliation efforts are already underway and will continue while the SOP is finalized and implemented. Together, these measures will strengthen accountability, improve asset management practices, and help ensure compliance with federal and Commonwealth property management requirements. Proposed Completion Date: Ongoing

Categories

Equipment & Real Property Management Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 1224392 2023-010
    Material Weakness Repeat
  • 1224393 2023-010
    Material Weakness Repeat
  • 1224394 2023-011
    Material Weakness Repeat
  • 1224395 2023-012
    Material Weakness Repeat
  • 1224396 2023-013
    Material Weakness Repeat
  • 1224397 2023-014
    Material Weakness Repeat
  • 1224398 2023-015
    Material Weakness Repeat
  • 1224399 2023-016
    Material Weakness Repeat
  • 1224400 2023-017
    Material Weakness Repeat
  • 1224401 2023-018
    Material Weakness Repeat
  • 1224402 2023-019
    Material Weakness Repeat
  • 1224403 2023-020
    Material Weakness Repeat
  • 1224404 2023-015
    Material Weakness Repeat
  • 1224405 2023-016
    Material Weakness Repeat
  • 1224406 2023-017
    Material Weakness Repeat
  • 1224407 2023-018
    Material Weakness Repeat
  • 1224408 2023-019
    Material Weakness Repeat
  • 1224409 2023-020
    Material Weakness Repeat
  • 1224410 2023-015
    Material Weakness Repeat
  • 1224411 2023-016
    Material Weakness Repeat
  • 1224412 2023-017
    Material Weakness Repeat
  • 1224413 2023-018
    Material Weakness Repeat
  • 1224414 2023-019
    Material Weakness Repeat
  • 1224415 2023-020
    Material Weakness Repeat
  • 1224416 2023-015
    Material Weakness Repeat
  • 1224417 2023-016
    Material Weakness Repeat
  • 1224418 2023-017
    Material Weakness Repeat
  • 1224419 2023-018
    Material Weakness Repeat
  • 1224420 2023-019
    Material Weakness Repeat
  • 1224421 2023-020
    Material Weakness Repeat
  • 1224422 2023-021
    Material Weakness Repeat
  • 1224423 2023-022
    Material Weakness Repeat
  • 1224424 2023-023
    Material Weakness Repeat
  • 1224426 2023-025
    Material Weakness Repeat
  • 1224427 2023-026
    Material Weakness Repeat
  • 1224428 2023-027
    Material Weakness Repeat
  • 1224429 2023-028
    Material Weakness Repeat
  • 1224430 2023-029
    Material Weakness Repeat
  • 1224431 2023-030
    Material Weakness Repeat
  • 1224432 2023-031
    Material Weakness Repeat
  • 1224433 2023-032
    Material Weakness Repeat
  • 1224434 2023-033
    Material Weakness Repeat
  • 1224435 2023-034
    Material Weakness Repeat
  • 1224436 2023-035
    Material Weakness Repeat
  • 1224437 2023-036
    Material Weakness Repeat
  • 1224438 2023-037
    Material Weakness Repeat
  • 1224439 2023-038
    Material Weakness Repeat
  • 1224440 2023-039
    Material Weakness Repeat
  • 1224441 2023-040
    Material Weakness Repeat
  • 1224442 2023-041
    Material Weakness Repeat
  • 1224443 2023-042
    Material Weakness Repeat
  • 1224444 2023-039
    Material Weakness Repeat
  • 1224445 2023-040
    Material Weakness Repeat
  • 1224446 2023-041
    Material Weakness Repeat
  • 1224447 2023-042
    Material Weakness Repeat
  • 1224448 2023-039
    Material Weakness Repeat
  • 1224449 2023-040
    Material Weakness Repeat
  • 1224450 2023-041
    Material Weakness Repeat
  • 1224451 2023-042
    Material Weakness Repeat
  • 1224452 2023-043
    Material Weakness Repeat
  • 1224453 2023-044
    Material Weakness Repeat
  • 1224454 2023-045
    Material Weakness Repeat
  • 1224455 2023-046
    Material Weakness Repeat
  • 1224456 2023-047
    Material Weakness Repeat
  • 1224457 2023-048
    Material Weakness Repeat
  • 1224458 2023-049
    Material Weakness Repeat
  • 1224459 2023-050
    Material Weakness Repeat
  • 1224460 2023-048
    Material Weakness Repeat
  • 1224461 2023-049
    Material Weakness Repeat
  • 1224462 2023-050
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $104.07M
93.778 GRANTS TO STATES FOR MEDICAID $76.95M
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $31.11M
10.539 CNMI NUTRITION ASSISTANCE $16.44M
93.767 CHILDREN'S HEALTH INSURANCE PROGRAM $14.01M
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $10.33M
10.542 PANDEMIC EBT FOOD BENEFITS $9.86M
20.205 HIGHWAY PLANNING AND CONSTRUCTION $7.85M
84.425H Education Stabilization Fund-Governors (Outlying Areas) $6.68M
17.225 UNEMPLOYMENT INSURANCE $5.91M
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $4.56M
21.023 EMERGENCY RENTAL ASSISTANCE PROGRAM $3.57M
93.596 CHILD CARE MANDATORY AND MATCHING FUNDS OF THE CHILD CARE AND DEVELOPMENT FUND $3.54M
20.526 BUSES AND BUS FACILITIES FORMULA, COMPETITIVE, AND LOW OR NO EMISSIONS PROGRAMS $2.85M
66.600 Environmental Protection Consolidated Grants for the Insular Areas - Program Support $2.46M
66.801 HAZARDOUS WASTE MANAGEMENT STATE PROGRAM SUPPORT $2.18M
97.039 HAZARD MITIGATION GRANT $2.05M
93.667 SOCIAL SERVICES BLOCK GRANT $1.52M
15.611 WILDLIFE RESTORATION AND BASIC HUNTER EDUCATION AND SAFETY $1.45M
12.617 ECONOMIC ADJUSTMENT ASSISTANCE FOR STATE GOVERNMENTS $1.43M
15.875 ECONOMIC, SOCIAL, AND POLITICAL DEVELOPMENT OF THE TERRITORIES $1.39M
11.419 COASTAL ZONE MANAGEMENT ADMINISTRATION AWARDS $1.06M
15.605 SPORT FISH RESTORATION $1.03M
20.600 State and Community Highway Safety $1.02M
84.126A Rehabilitation Services Vocational Rehabilitation Grants to States $722,785
17.277 WIOA NATIONAL DISLOCATED WORKER GRANTS / WIA NATIONAL EMERGENCY GRANTS $642,983
97.067 HOMELAND SECURITY GRANT PROGRAM $586,122
11.482 CORAL REEF CONSERVATION PROGRAM $485,806
16.575 CRIME VICTIM ASSISTANCE $480,848
93.045 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART C, NUTRITION SERVICES $465,958
16.588 VIOLENCE AGAINST WOMEN FORMULA GRANTS $463,780
10.649 PANDEMIC EBT ADMINISTRATIVE COSTS $459,938
16.710 Public Safety Partnership and Community Policing Grants $439,489
97.012 BOATING SAFETY FINANCIAL ASSISTANCE $400,545
93.044 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART B, GRANTS FOR SUPPORTIVE SERVICES AND SENIOR CENTERS $392,210
17.278 WIOA DISLOCATED WORKER FORMULA GRANTS $374,455
15.615 COOPERATIVE ENDANGERED SPECIES CONSERVATION FUND $368,265
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $341,575
97.047 BRIC: BUILDING RESILIENT INFRASTRUCTURE AND COMMUNITIES $319,766
17.259 WIOA YOUTH ACTIVITIES $307,211
16.750 Support for Adam Walsh Act Implementation Program $273,641
81.041 STATE ENERGY PROGRAM $265,459
17.504 CONSULTATION AGREEMENTS $264,451
20.218 MOTOR CARRIER SAFETY ASSISTANCE $252,525
45.025 PROMOTION OF THE ARTS PARTNERSHIP AGREEMENTS $239,433
17.258 WIOA ADULT PROGRAM $229,634
17.235 SENIOR COMMUNITY SERVICE EMPLOYMENT PROGRAM $224,606
81.042 WEATHERIZATION ASSISTANCE FOR LOW-INCOME PERSONS $212,348
15.634 STATE WILDLIFE GRANTS $201,740
16.034 CORONAVIRUS EMERGENCY SUPPLEMENTAL FUNDING PROGRAM $197,962
10.766 COMMUNITY FACILITIES LOANS AND GRANTS $195,515
15.904 HISTORIC PRESERVATION FUND GRANTS-IN-AID $186,515
11.472 COOPERATIVE RESEARCH PROGRAM $168,303
93.464 ACL ASSISTIVE TECHNOLOGY $128,419
93.747 ELDER ABUSE PREVENTION INTERVENTIONS PROGRAM $123,018
17.285 REGISTERED APPRENTICESHIP $116,929
11.437 FISHERIES DATA PROGRAM $112,596
11.467 METEOROLOGIC AND HYDROLOGIC MODERNIZATION DEVELOPMENT $104,532
10.664 COOPERATIVE FORESTRY ASSISTANCE $103,272
15.663 NFWF-USFWS CONSERVATION PARTNERSHIP $91,690
11.035 BROADBAND EQUITY, ACCESS, AND DEPLOYMENT PROGRAM $87,681
97.062 SCIENTIFIC LEADERSHIP AWARDS $86,357
93.048 SPECIAL PROGRAMS FOR THE AGING, TITLE IV, AND TITLE II, DISCRETIONARY PROJECTS $85,373
93.127 EMERGENCY MEDICAL SERVICES FOR CHILDREN $84,663
15.957 EMERGENCY SUPPLEMENTAL HISTORIC PRESERVATION FUND $73,515
17.273 TEMPORARY LABOR CERTIFICATION FOR FOREIGN WORKERS $68,059
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $67,796
12.300 Basic and Applied Scientific Research $65,974
20.509 FORMULA GRANTS FOR RURAL AREAS AND TRIBAL TRANSIT PROGRAM $64,714
93.645 STEPHANIE TUBBS JONES CHILD WELFARE SERVICES PROGRAM $61,124
10.680 Forest Health Protection $60,114
10.179 MICRO-GRANTS FOR FOOD SECURITY PROGRAM $58,129
16.017 SEXUAL ASSAULT SERVICES FORMULA PROGRAM $58,045
10.170 Specialty Crop Block Grant Program - Farm Bill $52,296
93.053 NUTRITION SERVICES INCENTIVE PROGRAM $50,933
93.556 MARYLEE ALLEN PROMOTING SAFE AND STABLE FAMILIES PROGRAM $49,361
59.061 STATE TRADE EXPANSION $41,693
93.569 COMMUNITY SERVICES BLOCK GRANT $39,897
11.407 INTERJURISDICTIONAL FISHERIES ACT OF 1986 $36,146
45.310 Grants to States $32,929
12.022 DOD MENTOR-PROTEGE PROGRAM $31,470
93.369 ACL INDEPENDENT LIVING STATE GRANTS $31,188
21.029 CORONAVIRUS CAPITAL PROJECTS FUND $30,034
93.450 Ebola Healthcare Preparedness and Response for Select Cities with Enhanced Airport Entrance Screenings from Affected Countries in West Africa $27,956
12.600 Community Investment $25,881
66.442 WATER INFRASTRUCTURE IMPROVEMENTS FOR THE NATION SMALL AND UNDERSERVED COMMUNITIES EMERGING CONTAMINANTS GRANT PROGRAM $22,460
16.585 TREATMENT COURT DISCRETIONARY GRANT PROGRAM $18,807
93.052 NATIONAL FAMILY CAREGIVER SUPPORT, TITLE III, PART E $16,169
93.590 Community - Based Child Abuse Prevention Grants $15,683
10.698 STATE & PRIVATE FORESTRY COOPERATIVE FIRE ASSISTANCE $14,514
93.043 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART D, DISEASE PREVENTION AND HEALTH PROMOTION SERVICES $14,287
16.540 Juvenile Justice and Delinquency Prevention $13,470
84.177B Rehabilitation Services Independent Living Services for Older Individuals Who are Blind $13,468
17.600 Mine Health and Safety Grants $13,189
15.631 PARTNERS FOR FISH AND WILDLIFE $9,540
20.703 INTERAGENCY HAZARDOUS MATERIALS PUBLIC SECTOR TRAINING AND PLANNING GRANTS $9,151
45.129 PROMOTION OF THE HUMANITIES FEDERAL/STATE PARTNERSHIP $8,543
66.040 Diesel Emissions Reduction Act (DERA) State Grants $8,314
93.671 FAMILY VIOLENCE PREVENTION AND SERVICES/DOMESTIC VIOLENCE SHELTER AND SUPPORTIVE SERVICES $8,215
93.042 SPECIAL PROGRAMS FOR THE AGING, TITLE VII, CHAPTER 2, LONG TERM CARE OMBUDSMAN SERVICES FOR OLDER INDIVIDUALS $5,973
16.753 CONGRESSIONALLY RECOMMENDED AWARDS $5,484
11.032 STATE DIGITAL EQUITY PLANNING AND CAPACITY GRANT $4,673
15.657 ENDANGERED SPECIES RECOVERY IMPLEMENTATION $4,508
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $4,200
11.U01 2010 Census $2,255
93.630 Developmental Disabilities Basic Support and Advocacy Grants $1,917
11.016 STATISTICAL, RESEARCH, AND METHODOLOGY ASSISTANCE $1,265
10.950 Agricultural Statistics Report $1,113
12.113 STATE MEMORANDUM OF AGREEMENT PROGRAM FOR THE REIMBURSEMENT OF TECHNICAL SERVICES $1,029
93.568 LOW-INCOME HOME ENERGY ASSISTANCE $854
20.500 Federal Transit Capital Investment Grants $761
93.041 SPECIAL PROGRAMS FOR THE AGING, TITLE VII, CHAPTER 3, PROGRAMS FOR PREVENTION OF ELDER ABUSE, NEGLECT, AND EXPLOITATION $525
20.513 ENHANCED MOBILITY OF SENIORS AND INDIVIDUALS WITH DISABILITIES $318
11.473 OFFICE FOR COASTAL MANAGEMENT $169