Segregation of Duties – Material Weakness Condition: The responsibility for performance of certain accounting duties, principally as related to review and approval of the award application and eligibility criteria, was vested in a limited number of employees wherein there was also a familial relationship amongst individuals overseeing the program, such that there was an overall lack of segregation of duties. Corrective Action Planned: Effective August 1, 2026, Covation Center completed a planned leadership transition: the Center's founder, who was previously involved in program oversight alongside a family member, has fully departed the organization and holds no ongoing role, formal or advisory, in the review or approval of CDBG program awards. Going forward, review and approval of grant applications and eligibility determinations will require sign-off from at least two unrelated individuals, with the Board of Directors (or a designated Board committee) providing independent oversight of program activity. The Center will formally document this approval workflow as part of its written program procedures (see response to Finding 2023-003). Name(s) of Contact Person(s) Responsible for Corrective Action: Stephanie Desaulniers, Executive Director; Covation Center Board of Directors Anticipated Completion Date: Implemented August 1, 2026; formal documentation of the workflow to be completed by December 31, 2026.