Finding 1240201 (2025-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-10-09

AI Summary

  • Core Issue: The University is not fully compliant with the Gramm-Leach-Bliley Act (GLBA), lacking proper documentation and vendor management.
  • Impacted Requirements: Insufficient security risk assessments, safeguards, and failure to provide a written annual report to the board.
  • Recommended Follow-Up: Allocate more resources to ensure compliance with GLBA requirements and implement corrective actions.

Finding Text

Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 Federal Award Identification #: 2024-2025 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not sufficiently documented its security risk assessment and safeguards including general threats nor implemented sufficient vendor management policies and reviews. The University also needs to fully implement the requirements for the written annual report to the board. Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: 2024-003 Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: Southwestern Christian University recognizes the importance of full compliance with the Gramm-Leach-Bliley Act (GLBA) and the updated Safeguards Rule. The University will continue working to complete and document the remaining requirements of its written information security program, including risk assessment and mitigation, multifactor authentication, security monitoring, employee training, service provider assessments, incident response procedures, and ongoing oversight. The University will work closely with Nomerel, our IT specialist, along with the Qualified Individual and appropriate University personnel, to review current safeguards, identify remaining gaps, and implement the necessary policies, procedures, and controls to achieve and maintain compliance. The University will also ensure that the required annual assessment and reporting of the information security program are completed and documented. The University will monitor compliance on an ongoing basis and update its information security program as necessary to address changes in technology, threats, and regulatory requirements. Person Responsible for Corrective Action Plan: Dustin Sells (VP of Academic Affairs) - Qualified Individual, in coordination with Mark Arthur (Chief Financial Officer), Nomerel IT personnel, and University Administration. Anticipated Date of Completion: June 30, 2027

Categories

Subrecipient Monitoring Significant Deficiency

Other Findings in this Audit

  • 1240198 2025-003
    Material Weakness Repeat
  • 1240199 2025-003
    Material Weakness Repeat
  • 1240200 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $1.26M
84.063 FEDERAL PELL GRANT PROGRAM $1.06M
84.033 FEDERAL WORK-STUDY PROGRAM $41,861
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $29,300