Finding 565806 (2024-003)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-06-23

AI Summary

  • Core Issue: Lack of documentation for suspension and debarment checks before loan agreements.
  • Impacted Requirements: Non-compliance with CFR 200.303(a) due to ineffective internal controls over federal awards.
  • Recommended Follow-Up: Implement a formal process for suspension and debarment searches prior to loan agreements.

Finding Text

Department of Treasury Federal Financial Assistance Listing 21.033, Award 22ERP060843 Community Development Financial Institutions Equitable Recovery Program (CDFI ERP) Suspension & Debarment Significant Deficiency in Internal Control over Compliance Criteria: CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: In our testing of suspension and debarment, it was identified that there was no observable documentation to directly indicate that a search for suspension and debarment was performed for loans disbursed prior to entering into loan agreements. Cause: Meda does not have a formal process to search for suspension and debarment of entities prior to entering into a loan agreement. Effect: Failure to document the search for suspension and debarment before entering into the loan agreement could result in possibly noncompliance. Questioned Costs: None reported. Context: Two loans out of two tested accounted for $1,177,250 of the total expenses $2,094,298 charged to the federal award. Repeat Finding from Prior Years: Yes, 2023-002 Recommendation: We recommend that management add a formal process to search for suspension and department before entering into loan agreements. Views of Responsible Officials: Management agrees with the finding.

Corrective Action Plan

Federal Agency Name: Department of Treasury Assistance Listing Number: 21.033 Program Name: Community Development Financial Institutions Equitable Recovery Program Finding Summary: MEDA does not have a formal process to search for suspension and debarment of entities prior to entering into a loan agreement. Corrective Action Plan: MEDA has an extensive underwriting process that reviews all borrowers from a variety of state and national databases for fraud, debt, and money laundering activities. In our current underwriting process, we search SAM. gov for SBA loan requests. As of May 1, 2025, we are searching SAM. gov for all of our loan requests. Furthermore, we have added this requirement to our loan underwriting manual, as evidenced by Section 10, Letter D for the search list of legal, financial and personal documents that are required to approve a loan at MEDA. Responsible Individuals: Adrian Ruddock – VP of Lending & Business Consulting, Raynette Buerke – Sr. Loan Administration Manager Anticipated Completion Date: May 1, 2025

Categories

Procurement, Suspension & Debarment Significant Deficiency

Other Findings in this Audit

  • 565805 2024-002
    Significant Deficiency
  • 1142247 2024-002
    Significant Deficiency
  • 1142248 2024-003
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
21.033 Community Development Financial Institutions Fund Equitable Recovery Program (cdfi Erp) $2.09M
11.805 Mbda Business Center $278,866
59.005 Small Business Development Center Program $43,228
21.027 Coronavirus State and Local Fiscal Recovery Funds $21,600