Locus and Subsidiaries respectfully submits the following corrective action plan for the year ended December 31, 2022.
Name and address of independent public accounting firm:
Brown, Edwards & Company, L.L.P.
105 Arbor Drive, 3rd Floor
Christiansburg, VA 24073
Audit period: December 31, 2022
The findings from the December 31, 2022 Schedule of Findings and Questioned Costs (the “Schedule”) are discussed below. The findings are numbered consistently with the number assigned in the Schedule.
FINDINGS – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT
2022-002: Community Development Financial Institutions Fund – Assistance Listing No. 21.020, Capital Magnet – Assistance Listing No. 21.011, and Equitable Recovery Program – Assistance Listing No. 21.033, Restatement of Schedule of Expenditures of Federal Awards, Material Weakness
Criteria and Condition: Recipients of federal funds are required to prepare a complete and accurate Schedule of Expenditures of Federal Awards. Additionally, recipients must establish and maintain effective internal controls over federal awards to provide reasonable assurance of accurate financial reporting.
Context: The Organization restated the 2022 Schedule of Expenditures of Federal Awards by a material amount a result of misinterpretation of reporting requirements for loan loss reserves and allocations of other allowable purposes.
Cause: The omission occurred due to a misinterpretation of reporting requirements involving the treatment grant expenditures for the purpose of lending capital and loan loss reserve funds, which differs
in nature from general program expenditures. Management identified the issue and determined a change
in reporting was needed to simplify tracking and reporting of federal grants, and to ensure compliance
with the technical definition of expenditures in the guidance.
Effect: Loan loss reserves and other amounts allocated in the wrong period resulted in an overstatement of total federal expenditures on the Schedule of Expenditures of Federal Awards.
Recommendation: We recommend that the Organization implement a formalized review process to ensure all applicable expenditures, including loan loss reserves, are properly recorded in the period in which assigned.
Views of Responsible Officials and Planned Corrective Actions: We agree with the finding and have established a process to ensure all expenditures are properly included in the SEFA.
Name of Contact Person: Ashley Coleman, Executive Director of Finance
Signature of Contact Person: