Finding Text
Finding 2022-002 Disbursement Reporting Requirements for the Title IV Programs - Material Weakness Criteria: In accordance with the requirements at 34 C.F.R. ?685.301(a)(2), a school must submit Direct Loan disbursement records, including the disbursement amount and disbursement date, as defined in 34 C.F.R.1649a), to COD. The most recent Federal Register notice specifies that a school must submit disbursement records no earlier than 7 days prior to the disbursement date and no later than 15 days after making the disbursement. The actual disbursement date is the date that the Direct Loan funds are made available to the borrower (i.e.: posting or crediting the funds to the student?s account). Because several terms and conditions of Direct Loans are tied to the actual disbursement date, this date must be accurately reported. Statement of Condition: The actual disbursement dates of Federal Pell Grant and Direct Loan funds were not reported to COD correctly. Cause: The institution did not update disbursement dates in EDExpress and therefore shows a discrepancy between the date of disbursement on the student?s ledger and the COD disbursement date. Per the institution, not changing the disbursement date in EDExpress was a training discrepancy that has been corrected. Effect: In eighty-two (82) of two hundred fifteen (215) disbursements to students including Federal Pell Grant and Direct Loan funds, the disbursement dates were not updated in COD. Description of nature and extent of the issues reported: The disbursement dates were incorrectly reported to COD for Federal Pell Grant and Direct Loan disbursements.