Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student financial information pertaining to the period under audit.