Finding 25487 (2022-001)

Significant Deficiency
Requirement
EG
Questioned Costs
-
Year
2022
Accepted
2023-09-26
Audit: 21457
Organization: Vantage West Credit Union (AZ)
Auditor: Doeren Mayhew

AI Summary

  • Core Issue: Some loans reported as eligible for CDFI purposes do not actually meet the required criteria.
  • Impacted Requirements: Performance goals in the Grant Assistance Agreement may be inaccurately reported due to a lack of proper tracking.
  • Recommended Follow-Up: Implement procedures to accurately identify and track eligible loans, ensuring they align with the reported data.

Finding Text

Condition: The Credit Union has contracted with a third-party vendor named CU Strategic Planning for CDFI reporting purposes. According to CU Strategic Planning?s reporting, the Credit Union met the total financial products (loans) deployed in the designated target market (TM) requirement as reported on the Annual Performance Report. From our testing, we were also able to support the Credit Union satisfied the requirements. However, during our testing of eligible loans, we found several loans in our sample that did not meet the eligibility requirements. Criteria: Eligible loans meeting an established threshold (performance goal) as outlined in the Grant Assistance Agreement are to be deployed within the TM. Questioned Costs: None Context: Eligible loan deployment as reported in the Annual Performance Reports were unable to be supported on an individual basis outside of CU Strategic Planning?s reporting at this time. Effect: Performance goals as stipulated in the Grant Assistance Agreement may not be met or reported inaccurately. Cause: A deficiency in internal controls to identify and track eligible loans deployed during the RRP grant performance period. Recommendation: Complete established procedures to identify and track eligible loans deployed during the RRP grant performance period and reconcile the totals to the underlying loan data. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will ensure we are able to identify eligible loans deployed in the TM in the future.

Corrective Action Plan

Department of the Treasury ? CDFI Fund Grant Vantage West Credit Union respectfully submits the following corrective action plan for the year ended December 31, 2022. Name and address of independent public accounting firm: Doeren Mayhew 305 West Big Beaver Rd., Ste. 200 Troy, MI 48084 Audit period: January 1, 2022 ? December 31, 2022 The finding from the December 31, 2022 schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF TREASURY CDFI Program ? CFDA No. 21.024 Significant Deficiency: See Finding 2022-001. Recommendation: Complete established procedures to identify and track eligible loans deployed during the RRP grant performance period and reconcile the totals to the underlying loan data. Action Taken: Vantage west will enhance its reporting to our third party CDFI reporting consultant to clarify and fully define borrower data points, in support of improving the accuracy of financial products reported annually on the Performance Reports to the CDFI Fund.

Categories

Eligibility Period of Performance Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 601929 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.024 Community Development Financial Institutions Rapid Response Program (cdfi Rrp) $1.83M
21.020 Community Development Financial Institutions Program $625,000