Finding 42729 (2022-001)

Significant Deficiency
Requirement
A
Questioned Costs
-
Year
2022
Accepted
2023-06-28
Audit: 46953
Organization: Community Development Resources (NE)

AI Summary

  • Core Issue: A loan was issued to a microborrower with an interest rate of 8.5%, exceeding the SBA's maximum of 7.75% for loans over $10,000.
  • Impacted Requirements: The Organization failed to comply with SBA regulations due to a breakdown in internal controls during loan preparation.
  • Recommended Follow-Up: Implement a review process for loan terms to ensure compliance, with verification by both the Loan Officer and document preparer before closing.

Finding Text

2022-001 ? INTEREST RATE GREATER THAN MAXIMUM ALLOWED Condition: The Organization provided a loan to a microborrow in an amount greater than $10,000. The Organization charged an interest rate of 8.5% on this loan, even though it was for an amount greater than $10,000. Criteria: The SBA sets maximum interest rates allowed to be charged on the loans to the microborrowers. For loans greater than $10,000 the maximum interest rate allowed is 7.75%. Cause: The Organization had a breakdown in internal controls when preparing this loan. Effect: A microborrower is being charged interest at a higher rate than allowed by the SBA. The Organization will likely have to do a loan modification for the borrower that lowers the interest rate and applies the overage paid by the borrower as a reduction to the principal balance. Recommendation: We recommend the Organization ensures that processes are in place to review loan terms and agreements prior to issuing the loans to ensure all compliance requirements are met. Response: The Loan Officer, along with the preparer of the loan documents, if different, will verify the interest rate authorized by underwriting is compliant before issuing closing documents. Both should be knowledgeable about the rules and regulations associated with the process and double check one another.

Corrective Action Plan

Plan of Action - Implement an interest rate verification process before issuance of loan closing documents. Proposed Completion Date - June 30, 2023

Categories

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 42728 2022-002
    Significant Deficiency
  • 619170 2022-002
    Significant Deficiency
  • 619171 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
59.046 Microloan Program $682,606
21.024 Community Development Financial Institutions Rapid Response Program (cdfi Rrp) $302,221